ML20217J588
| ML20217J588 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 08/07/1997 |
| From: | Edgar J SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-1257-97-05, 70-1257-97-5, JBE:97:133, NUDOCS 9708140340 | |
| Download: ML20217J588 (4) | |
Text
.
SIEMENS i
August 7,'1997 JBE:97:133 U.S. Nuclear' Renulatory Commission Attn: Document Lontrol Desk i
Washington, DC 20555 l
t i
a Gentlemen:
Subject:
Reply to a Notice of Violation Ref:
Letter, R.A. Scarano to B.N. Femreite, *NRC inspection Report 701257/97 05 and Notice of Violation" dated July 8,1997 Below is Siemens Power Corporation's (SPC's) reply to the notice of vlotation accompanying the referenced letter.
M91all9.0 Safety Condition S 1 of License SNM 1227 authorizes the use of licensed materials in accordance with the statements, representations, and conditions contained in Part i the licensee's application dated October 28,1996, and supplements and revisions thereto.
Section 2.5, " Operating Procedures, Standards and Guides," Part I, of the license application states, in part, that the licensee is committed to controlling activities in accordence with Standard Operating Procedures, Company Standards and Policy Guides.
Section 6.3, " Posting," states, in part, the Criticality Safety Limit Cards (Postings) are t
prepared and approved by Safety, Security, and Licensing, and accepted by Operations.
The acceptance by the Operating group indicates that the limits are understood by r' f supervision / management, understandable by users, and that procedures and training wilM, )'
be provided to assure compliance with the postings.
)p' Criticality Limit Card No. P90,316, Rev 0, *HEPA Filter and Pre Filter Storage,1 Tier,"
posted at the filter storage array on the second level mezzanine of the gadolinium fuel powder production area, stated that the array shall be equal to or greater than 3 feet from other accumulations of uranium.
Siemens Power Corporation Nudear DMeion-2101 Horn Rapids Road Tel:
(509) 375 8100 Engineeri,vj & Manuf actur6ng P,o, Dou 130 -
Fax:
(5091 375 8402 Richland. WA.99352 o130 9708140340:970807
=5 PDR ADOCK 07001257 C
PDR m
t Distribution JBE:97:112 l
August 7,1997 Page 2 4
Contrary to the above, on June 10,1997, a 5 gallon bucket containing low enriched uranium was stored on a transfer platform 12 inches from the filter storage array, and a 5 gallon bucket of low enriched uranium in a nearby fixed storage grid was 18 inches from the filter storage array.
SPC's Realv Reason for the Violation j
A bucket storage array was established on the Neutron Absorber Fuel (NAF) facility mezzanine in 1988. In 1992 SPC's Plant Engineering Air Balance group requested that j '
locations be established to allow storage of used HEPA filters and pre filters after they l
were changed out and prior to their removal from controlled areas to waste storage.
Creating these specified locations was intended to prevent violations resulting from such storage in temporary locations.
A generic analysis was performed by Criticality Safety to allow HEPA/ pre filter storage in various approved locations of the rWcit provided greater than three feet spacing was maintained between the HEPA/preN. storage array and other accumulations of fissile material. Because of close conditio*r. en the NAF f acility, there was a request by Operations to accommodate less than three feet spacing between a bucket storage array and a filter storage array, by allowing either a full storage array of buckets and no filters or 12 specified empty bucket storage locations along with filter storage. This was accomplished by administratively requiring that the specified empty bucket storage locations or the filter storage array be posted "out of service," when the other needed to be used.
On April 7,1997, Air Balance technicians replaced the pre filters from the NAF hammermill, and stored the used pre filters in the NAF mezzanine filter storage array, There were no buckets in the nearest bucket storage locations, thereby meeting the greater than three feet spacing requirement. However, the "out of service" postings on the appropriate empty bucket storage locations were not put in place.
Subsequently, two buckets were placed by NAF Operations in mezzanine bucket storage locations that were closer than three feet from the HEPA/ pre filter storage array which contained pre filters. These buckets were placed in storage locations in violation of the HEPA/ pre filter storage array spacing requirements that were posted at that array.
Also, on June 10,1997, a NAF Operations technician moved a bucket up the elevator onto the mezzanine level. He did not go up to the mezzanine to remove the bucket because there were no instructions for the elevator that mentioned the greater than three
- feet spacing requirement between it and the filter storage array when occupied. By
- moving this bucket up the elevator when the filter storage array contained pre filters, he unknowingly violated the spacing requirement.
The root causes of the violation were:
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Distribution JBE:07:112 August 7,1997 Page 3
- 1. There were no instructions at the bucket lif t workstation that referred to the required three feet spacing when the filter storage array was being used.
- 2. Two fissile material workstations were allowed to overlap with conflicting requirements because of convenience.
- 3. The instructions for the filter storage arrny requiring greater than three feet spacing were not visible from the bucket lif t workstation.
- 4. The technicians needed to be familiar with the requirements for two different workstations and how they interacted in various storage combinations.
- 5. It was determined during the investigation that there is a general misconception that fissile material in transit only had to maintain a one foot spacing, not three feet as in this case, from accumulations of fissile material and; therefore, the bucket lif t could be used when the filter storage array was being used provided the bucket being lif ted was immediately moved to an approved storage location greater than three feet from the filter storage array.
- 6. "Out of Service" signs were not posted on the bucket storage locations that were within three feet of the filter storage array, immediate Correctly.g_enfiQm When the problem was discovered, the buckets were removed to storage locations which were greater than three feet away from the filter storage array.
Corrective Actions to Avoid Further Violations To prevent recurrence of causes 1,2,3 and 4, described above, Plant Operations and Criticality Safety evaluated the location of the NAF HEPA/ pre filter storage array. This array was relocated on 7/11/97 to an area where greater than three feet spacing can be maintained with no overlapping controls.
To prevent recurrence of causes 5 and 6, described above, Plant Operations and Safety will conduct a refresher training program for all fissile material handlers (Plant Operations, Maintenance, Quality and Safety) that reemphasizes the requirement to read all Criticality Safety Limit Cards when approaching a workstation and, also, that the normal one foot spacing requirement between storage arrays and in transit fissile material may, in some cases, be other distances. This training session will also review the "Out of Service" posting requirements and procedures. Plant Operations and Safety expect to complete this training by 8/31/97.
Distribution JBE:97:112 August 7,1997 Page 4 Qate of Full Comoliance Full compliance was achieved by actions taken directly af ter discovery of the violation; i.e. removal of the buckets from the offending locations. The filter storage array was permanently moved on 7/11/97. As noted above, training to further solidify compliance will be completed by 8/31/97.
In the letter with which you transmitted the inspection report and violation notice you expressed an interest in SPC's view as to why an " obvious conflict between criticality posting criteria and existing conditions "was not observed and whether this might be indicative of rote actions by operators. SPC's investigation of this violation resulted in the conclusion that extenuating circumstances and not rote operations resulted in this condition's not being discovered earlier.
Furtherrnore, SPC encourages proactiveness on safety matters by its employees as is borne out by the f act that the vast majority of safety non compliances are reported by employees other than the safety staff. SPC believes that such proactiveness is not indicative of operation by rote. Nevertheless, SPC has taken this violation seriously and has therefore embarked on the training described above to re emphasize its proactive commitment to compliance with safety
- rules, if you have any questions regarding those actions or require more information, please contact me at 509 375 8663.
Very truly yours, 6
James B. Edgar Staff Engineer, Licensing
/pg cc: U.S. Nuclear Regulatory Commission Regional Administrator, Region IV Arlington, TX U.S. Nuclear Regulatory Commission Region IV Field Office Walnut Creek, CA 1