ML20217L799

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/97-05 on 970708

ML20217L799
Person / Time
Site:	Framatome ANP Richland
Issue date:	08/13/1997
From:	Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Femreite B SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
References
70-1257-97-05, 70-1257-97-5, NUDOCS 9708190053
Download: ML20217L799 (2)

Text

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August 13, 1997 ,

B. N. Femreite, Vice President Engineering and Manuf acturing Siemens Power Corporation 6 2101 Horn Rapids Road P.O. Box 130 .

Richland, Washington 99352 0130

SUBJECT:

NRC INSPECTION REPORT 701257/97 05 AND NOTlCE OF VIOLATION

Dear Mr. Femreite:

Thank you for your letter of August 7,1997,in response to our letter and Notice of Violation dated July 8,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. Ws will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely, e

Frank A. Wenslawski, Chief Materials Branch Docket: 70 1257 License: SNM 1227 f

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JBE:97:133 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 ,

Gentlemen:

Subject:

Reply to a Notice of Violation Ref: Letter, R.A. Scarano to 8.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 violation accompanying the referenced letter, Violation 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 1, of the license application states, in part, that the licensee is committed to controlling activities in accordance with Standard Operating Procedures, Company Standards and Policy Guides.

Section 6.3, " Posting," states, in part, the Criticality Safety Limit Cards (Postings) are 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 supervision / management, understandable by users, and that procedures and training will be provided to assure compliance with the postings.

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 leseteer oMelon 2101 Hom Rapida Road Tel: (509) 375 810o sche, . W 993524130 sqopMomW

Distribution JdE:07:112 August 7,1997 Page 2 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 Reply Reason for the Vio'ation 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 location , be established to allow storage of used HEPA filters and pre filters after they were c anged out and prior to the!r removal from contrelled areis 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 plant provided greater than three feet spacing was maintained between the HEPA/ pre filter storage array and other accumulations of fissile material. Because of close conditions in the NAF facility, there was a request by Operations to accommodate less than three fect 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 filt rs 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 Vocations, 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 pisced 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 lovel. 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 r:rray contained pre filters, he unknowingly violated the spacing requirement.

The root causes of the violation were:

Distribution JBE:97:112 August 7,1997 Page 3

1. There were no instructions at the bucket lift 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.

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3. The instructions for the filter storage array requiring greater than three feet spacing  !

were not visible from the bucket lift workstation. l

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 inve=tigation that there is a general misconception that fissile material in transit only had to maintah a one foot spacing, not three f 3et as in this case, from accumulations of fissile material and; therefore, the bucket lift could be used when the filter storage erray was being used provided the bucket being lifted was immediately moved to an approved storage location greater than three feet from the filter storege array.

6. "Out of Gervice" signs were not posted on the bucket storage locations that were within three feet of the filter storage array.

Immediate Corrective Actions 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 Srfety 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 Opsrations and Safety expect to complete this training by 8/31/97.

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'o Distribution JBE:97:112 August 7,1997 Page 4 Date of Full Comollance Full compliance was achieved by actions taken directly after discovery of the violation; l a. 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.

Furthermore, SPC encourages proactiveness on 6afety mattcts by its employees cs is 1,orne 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 thert, fore embarked on the tralning described above to re emphasize its proactive commitment to compliance with safety rules. -

t if you have any questions regarding these actions or require more information, please contact me at 509 375 8663. ,

Very truly yours, 6

Jarnes 8. 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

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