ML20203P018
| ML20203P018 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 03/26/1986 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Thomas R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20203P016 | List: |
| References | |
| NUDOCS 8605060278 | |
| Download: ML20203P018 (3) | |
Text
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%[lTo ERON NUCLEAR COMPANYINC.
g 2ggmoggx uo.rucm.mo.wams2 if'"nglj March 26,1986
D' /, :. -
Mr. R. Thomas, Chief Nuclear Materials Safety Section U.S. Nuclear Regulatory Commission, Region V I450 Mario Lane, Suite 210 Walnut Creek, CA 94596 License No. SNM-1227 Docket No. 70-1257
Dear Mr. Thomas:
This is in response to Notice of Violation dated March 5,1986 pursuant to the provisions of 10 CFR 2.201.
The notice identified three separate items which are repeated below followed by our response.
Violation A Procedure No. P43,078 Rev. O, " Inspection and Testing of UF6 Cylinders,"
Section 7.5 requires that the air test of cylinder valves be conducted at 100 psig, and that the volve threads be checked for leaks at this pressure. Also, this test pressure is consistent with ANSI N14.1,1982.
Contrary to this requirement, at the time of the inspection, the licensee's operational test procedure used af ter replacement of f aulty volves on UF6 cylinders in the conversion room, specified that valves be tested between 70 and 90 psig.
Response
Procedure No. P43,078 Rev. O is designed to comply with the five year inspec-tion and testing requirement outlined in Section 6.3.2 of ANSI N14.1, 1982.
One of those requirements is an air test at a pressure of 100 psig.
The operational test procedure referred to above (P66,371, Rev. 2) is indepen-dent of Procedure No. P43,078 Rev. O and is designed to comply with Section 6.3.3 Cylinder Maintenance of ANSI NI4.1, 1982 which states that " Plug or valve replacements should be followed by air leak tests."
No conditions are specified.
8605060278 860430 PDR ADOCK 07001257 C
PDR AN M FIUAff OF E N XON CORPOHAflON
Mr. R. Thmus March 26, 1986 Page 2 However, to be - internally consistent, procedure P66,371 will be revised to require a test pressure of 100 psig.
This will be accomplished by May 1,
1986.
Violation B Procedure No. P66,336 Rev. 18 " Preparing and Removing UF6 Cylinders-Line 1" requires that the licensee shall put the protective cover for the valve in place' prior to hookup of the lif ting device, and also Section 6. A.4 requires that-the licensee shall place the protective cover on the volve prior to installing the lifting yolk.
Contrary to the above requirement, a protective valve cover on cylinder number EX827 was not used when removing it from a vaporization chest in Line I Conversion Room on February 4,1986.
Response
We have carefully reviewed the need for the use of UF6 cylinder valve covers
- during movement of cylinders.
We determined that during our movement of cylinders the contents are in the solid phase and not under pressure but under a vacuum with respect to atmosphere. The cylinder wall extends out beyond the valve on both 30A and 30B cylinders thus of fording significant protection. We
-have ;found no technical standards providing guidance on the use of valve covers and there appears to be no standard industrial practice in their use.
For the above reasons we do not believe the movement of cylinders without valve covers presents a significant hazard and do not plan to use volve covers during our UF6 cylinder handling operation.
We are revising our procedures.
occordin~ gly. This will be accomplished by May 1,1986.
Violation C Procedure N o. P43,078 Rev. O, " Inspection and Testing of UF6 Cylinders,"
Section 7.8, Equipment Winterization requires that the licensee shall remove the hose reels, crate and store them in the warehouse and also that the licensee shall lock the piping cabinet.
Contrary to the above requirement, at the time of the inspection, the hose reels used for testing the UF6 cylinders had not been winterized in that the reels were located outside without any shelter from the winter weather.
Also the piping cabinet was not locked.
Mr. R. Thoms March 26, 1986 Page 3
Response
The winterizing -section of Procedure No. P43,078 Rev. O is strictly a preven-tive maintenance item and is separate and apart from cylinder testing and/or personnel safety.
We.have withdrawn this item from the procedure and placed it in our preventive maintenance schedule.
Sincerely, C. W. Molody, Monoger Corporate Licensing i
CWM:jrs
.