ML20196D234

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-0036/98-04 & 990115 Commitment to Provide Addl Steps to Be Taken Subsequent to Mgt Review of Root Cause Assessment Team Findings

ML20196D234
Person / Time
Site:	07000036
Issue date:	11/24/1998
From:	Obrien K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kaiser B ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
70-0036-98-04, 70-36-98-4, NUDOCS 9812020181
Download: ML20196D234 (2)

Text

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November 24, 1998 Dr. Bruce Kaiser Vice President, Fuel Operations ABB Combustion Engineering, Inc.

3300 State Road P Hematite, MO 63047

SUBJECT:

RESPONSE TO INSPECTION REPORT 070-00036/98004(DNMS) l

Dear Dr. Kaiser:

I 1

This refers to your November 20,1998, response to the Notice of Violation (NOV) transmitted I to you by our letter dated October 21,1998, with inspection Report 070-00036/98004(DNMS).

We have reviewed your corrective actions and have no further questions at this time. Your corrective actions will be examined during future inspections.

l We further acknowledge your January 15,1999, commitment to provide additional " steps to be taken" subsequent to management's review of the root cause assessment team findings and recommendations.

If you have any questions, please contact me at (630) 829-9800.

Sincerely, i

Original Signed by T. Reidinger for Kenneth G. O'Brien. Acting Chief Fuel Cycle Branch Docket No. 070-0036 j License No. SNM-33 cc: R. W. Sharkey, Director, Regulatory Affairs R. A. Kucera, Director, Missouri Department of Natural Resources DOCUMENT NAME: G;\SEC\COM98004.RES Ta receive a copy of this document, Indicate in the box:"C" = Copy without enclosure 'E" = Copy with enclosure *N" No copy IOTilCE Rill lC Rlli ,., ,

NAME Kinceley:ib O$

O'BrienM&/(A/

DATE 11/-)A/98 117%/98 0

' OFFICIAL RECORD COPY 9012O20181 981124 PDR ADOCK 07000036

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~ B. Kaiser bec w/ltr dtd 11/20/98: Docket File PUBLIC IE-07 C. Emeigh, NMSS R. Soong, NMSS -

P. Ting, NMSS R. Be!!amy, RI EJM, Ril (e-mail)

D. B. Spitzberg, RIV/WCFO Greens w/o enci f

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.A s 7%ERED November 20,1998 Docket No. 70-0036 License No. SNM-33 U. S. Nuclear Regulatory Commission l ATTN: Document Control Desk Washington, DC 20555 SUILIECT: REPLY TO A NOTICE OF VIOLATION Gentlemen:

Enclosed is Combustion Engineering's (CE) Reply to a Notice of Violation concerning NRC Inspection Report No. 70-36/98-004, dated October 21,1998. The findings resulting from this inspection were discussed at a manage nent meeting with NRC Region 111 on October 30,1998 During the management meeting CE described several reasons for the procedural non-compliance described in this inspection report and other inspections and audits. A root cause assessment (RCA) team has been formed to thoroughly investigate the matter. The RCA team will also make recommendations on lasting corrective actions to prevent recurrence Tracking of the RCA is in accordance with our Corrective Action Request procedure. CE's approach to investigating this issue along with the plan to provide additional information supporting this reply by January 15,1999, was discussed with Mr. Patrick liiland by telephone on November 18, 1998.

The RCA team is a multidisciplinary and cross sectional group of operators, engineers, technicians, and supervisors. The team will use our six-step process for problem solving. The team's report of conclusions and recommendations is due by December 31,1998. CE will furnish a summary to the NRC by January 15,1999. On that date CE will also report the results  ;

of our assessment ofintake regarding the finding on lapel air sampler use. To aid in this l assessment, CE will incre_ase the number ofindividuals selected for in-vivo lung counting i scheduled for this December.

We will be glad to discuss any questions you have concerning our response. If you have any questions or need further information, please contact me at (314) 937-4691.

Sincercly,'

COMBUSTION ENGINEERING,INC. I W /h.20-18 Robert W. Sharkey s

'f Date l Director, Regulatory Affairs ,

. cc: Jim Caldwell, Regional Administrator (Acting), NRC Region 111

~ Patrick 11iland, NRC Region III l

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Combustion Engineering,Inc. Docket 70-36  ;

November 20,1998 License No. SNM33 l:  :

REPLY TO A NOTICE OF V!OLATION i l INSPECTION REPORT 70-36/98-004 )

L i Response to Violation No.98-004 ) ,

Violation: '

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! During an NRC inspection conducted from September 14 through.18,1998, one j violation of NRC requirements was identified. In accordance with the " General )

i Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement j Policy) NUREG-1600, Rev.1, the violation is listed below:

Safety Coadition S-1, of Special Nuclear Materials license, SNM-33, authorizes the use of licensed materials in accordance with the statements, representations, and conditions in Chapters I through 8 of the application dated October,29,1993, and l supplements and revisions thereto.

j' Chapter 2, Section 2.6, " Operating Procedures," of the supplement, dated August 8,1997, requires,in part, that all operations which affect licensed j - material shall be conducted in accordance with approved procedures.

l a. Operation Safety Procedure No.1725, "Erbia Master Blend Makeup,"

paragraph 2.3.6. stated, in part, that all containers of master blend material i must be tagged with a " Moisture OK" tag before storage on a conveyer m t the Erbia Plant. I

b. Quality Control Procedure No. 5002.04, Revision 2, " Change Control Management," dated March 27,1998, paragraph 5.6, stated, in part, that each change control package is to be evaluated for license compliance, industrial safety and radiological safety considerations. In addition, paragraph 6.1, stated, in part, that the change control documentation (change control package) shall be thoroughly described and documented along with system or component drawings, process and instrumentation diagrams, and

operating procedures. Attachment A stated that required cognizant directors must sign and approve the change control package prior to release.

i Nuclear Industrial Safety Procedure No. 219, " Control ofIlazardous Energy,"

c.

dated March 15,1996, Section 6.2 stated, in part, that a tagout shall be used to remove equipment for any condition, other than what may be reasonably expected, that adversely affects the safety of affected personnel. In addition, L Section 6.3 stated, in part, that a lockout shall be used to remove equipment

- when work to be performed can result in an exposure to electrical energy L . while maintenance is being performed.

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. i l . Combustion Engineering, Inc. Docket 70-36 November 20,1998 License No. SNM33

d. Health Physics Procedure No. 326, " Respiratory Selection, Use, Inspection, and Maintenance," dated November 5,1996, paragraph 13, required the  ;

respirator user to verify the ability to maintain a facial seal when a respirator l is issued and befbre each use. I

e. Operation Safety Procedure No. 202, " Health Physics Controls," paragraph 2.2 stated, in part, that all visible surface contamination, outside of a hood or  !

i process equipment. must be cleaned up immediately.

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f. Health Physics Procedure No. 330, " Radiation Work Permit," paragraph 3.0, stated in part, that radiation work permits are required ihr activities that involve potential for significant intake of, or exposure to, radiological material. In addition, paragraph 5.1.5 stated,in part, that any work requiring the breaking of a system or pipe containing radioactive material or that may be potentially contaminated requires a radiation work permit.

g. Operation Safety Procedure No. 202, " Health Physics Controls," paragraph 2.1 stated, in part, that lapel air samplers shall be worn (turned on) for breathing zone sampling. Health Physics Procedure Na. 303, " Lapel Air Sampling," paragraph 2.0 stated, in part, that lapel samplers were used where uranium handling operations were pursued and improper operation or suspected malfunction of a lapel air sampler shall be repoMed to the HP staff.

Contrary to the above, opera.es which affected licensed material were not conducted in accordance with approved written procedures in the following examples, respectively:

a. On September 16,1998, licensee staff failed to post a " Moisture OK" control tag on an "Erbia Master 131end Makeup" container before, storage on a conveyor in the Erbia Plant.

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b. On September 15,1998, plant management failed to ensure that UF6 detector l system documentation received the cognizant directors review and i documented authorization. In addition, the change control documentation  !

(change control package) was not described and documented along with system or component drawings, process and instrumentation diagrams. and operating procedures.

c. On September 15,1998, plant management, failed to establish an electrical ,

lockout or install a danger tag on equipment removed from service during l maintenance activities. Specifically, no tagout (danger tag) or lockout was established on the electrical power supply panel during UF , detector system installation activities.

RA98/826

l Combustion Engineering Nc. Docket 70-36 November 20,1998 License No. SNM33

d. On September 14 and 15,1998, several maintenance staff fitiled to verify the ability to maintain a facial seal (by conducting either the positive 10-second l negative pressure fit check) when donning respirators prior to conductmg work activities. l

c. On September 16,1998, plant management failed to ensure that immediate cleanup was conducted for visible surface contamination on the floor near work stations.

f. On September 15, 1998, plant management failed to ensure that a radiation work permit was written prior to conducting contaminated heat exchanger work activities.

g. On September 17,1998, plant management failed to ensure that operations staff had lapel air samplers turned on (fbr breathing zone sampling) while l uranium handling operations were in progress. l This is a Severity Level IV violation (Supplement VI).

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• Combustion Engineering, Inc. Docket 70-36 November 20,1998 License No. SNM33 l

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Response

1. Reason for the violation: The findings resulting from this inspection were discussed at a management meeting with NRC Region 111 on October 30,1998. During the meeting CE management described several reasons for the procedural non-compliance described in this inspection report and audits and inspections. To further understand the root cause of thi,s issue, an RCA team has been formed to thorouchly investigate the matter. The RCA team will also make recommendations on lasting

' corrective actions to prevent recurrence.

2. Corrective steps that have been taken and the results achieved: Corrective actions taken to date include: (a) Radiation worker refresher training was conducted for plant operations persor.nel. During this training the findings from this inspection were discussed and the importance of following procedures emphasized. (b) Nuclear j criticality safety training was provided for plant personnel. During this training the result of this inspection were discussed and again the importance of following approved procedures and postings was emphasized. (c) For conversion plant operators, individual training is being conducted ihr each operator for every nuclear l criticality safety posting in this area of the plant. This instruction includes a i walkthrough with the nuclear criticality safety specialist for NCS postings in the conversion plant followed by a signed statement from each operator stating that they understand the posting as presented. (d) RWP procedure IIP-230 has been revised to more explicitly state RWP requirements. (e) The importance of ensuring that lapel air j samplers are on when required has also been emphasized. Random spot inspections conducted since training has shown compliance in that monitors checked were operating.

3. Corrective steps taken to avoid further violations: In addition to the actions stated above, several organizational changes have been made as presented during the October 30 meeting. These changes include: the addition of three new production supervisors, the creation and filling of a new position responsible fbr the radioactive-material shipping program, the addition of one professional to the regulatory affairs stafT, and the reallocation of non-regulatory tasks assigned to the llP supervisor.

Additionally, one supervisor has recently returned to work after an extended medical

-leave. Additional steps to be taken will be determined by management based on the findings and recommendations of the RCA team. These steps will be furnished to NRC by January 15,1999.

! 4. Date when full compliance will be achieved. A schedule fbr implementing

corrective action steps will be furnished to NRC by January 15,1999.

RA98/826