ML20211M034

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Forwards Response to Violations Noted in Insp Rept 70-0036/97-03.Corrective Actions:Placed Hand Written Tag on Steam Trace Supply Valve
ML20211M034
Person / Time
Site: 07000036
Issue date: 10/07/1997
From: Sharkey R
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
70-0036-97-03, 70-36-97-3, NUDOCS 9710100320
Download: ML20211M034 (2)


Text

ABI October 7,1997 Docket No. 70-0036

- License No. SNht 33 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

REPLY TO A NOTICE OF VIOLATION Gentlemen:

Enclosed is Combustion Engineering's Reply to Notice of Violation dated September 12, 1997, concerning NRC Inspection Report No. 070-00036/97003(DNhiS).

We will be glad to discuss any questions you have concerning our response. If you have any questions or need further information, please can'act me or hir Hal Eskridge of my staff at (314) 937-4691.

Very tmly yours, COhiBUSTION ENGINEERING, INC.

W Robert W. Sharkey Director, Regulatory Affairs r

cc: Bill Beach, Regional Administrator

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Response to Violation No 97003-01 Violation:

Safety Condition S 1 of Special Nuclear Material License S14M 33 requires that licensed material be used in accordance with the statements, representations, and conditions in Chapters I through 8 of the application dated October 29,1993, with supplements.

Section 2.6 of Chapter 2 of the application dated January 28,199$, requires, in part, that all operations which affect licensed material shall be conducted in accordance with approved procedures.

Nuclear Industrial Safety Procedure (NIS) No. 219, " Control of flazardous Energy," dated March j

15,1996, Section 6.2 states, 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, Section 6.3 states, in part, that a lockout shall be used to remove equipment i

if work to be performed can or could result in an exposure to mechanical or hydraulic energy while maintenance is being performed.

Contra y to the above, betwren August 4 and August 7,1997, maintenance actisitics were conducted during which the licensee failed to establish a lockout or install a danger tag on equipment removed from senice. Specifically, no danger tag or a lockout was installed on the I

steam isolation vahc that supplied trace steam heating to the feed line that contained " solid" UF.6

Response

1.

Reason for the violation: The violation occurred because the shift supenisor and opirators imolved overlooked the requirement to tag the steam trace supply valve out of senice, although they were aware that it should not be operated and the possible consequences of inadvertent valve opening.

2. Corrective steps that have been taken and the results achieved: As immediate corrective action, a hand written tag was placed on the steam trace supply valve.
3. Corrective s'eps taken to avoid future violations: The importance of obsening lockout /tagout procedures was stressed in recently conducted safety retraining for operating personnel. The retraining emphasized the proper lockout /tagout process. Additional local lockout /tagout stations have been purchased to facilitate implememation of that process.

4.

When full compliance will be achieved: We are currently in full compliance with the requirement to observe lockout /tagout procedures.