ML20237E652

Responds to NRC Re Violations Noted in Insp 70-1100/87-03.Corrective Actions:Each Furnace Posted W/ Nuclear Safety Sign & Positive Restraint Installed to Keep Fuel Carts Away from Fuel Storage Rack

ML20237E652
Person / Time
Site:	07001100
Issue date:	11/02/1987
From:	Mcgill P ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20237E643	List: ML20237E641 ML20237E652
References
NUDOCS 8712290110
Download: ML20237E652 (3)

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l COMBUSTION ENGINEERING License SNM-1067 Docket 70-1100 v

l Eovember 2, 1387 U. S. Nuclear Rgula';ory Commission Region I i

l 631 Park Avenue 4

King of Prussia, PA 19406 Attention:

Mr. Thamas T. Martin, Director i

Division of Radiation Saf ety and Saf eguards Ref erenc e:

Letter from Thomas T. Martin, NRC, to H. V. Lichtenberger, CE, dated October 9, 1987 Deat: :fr. Martin:

Our response to the notice of violation, Appendix A, contained within the referenced letter is as follows:

Aypendix A, Item A Section 4.1.4, " Posting of Limits", of your NRC approved license application (Pat $ P - Criteria), dated June 15, 1984, states, in part, that all work stations and storage areas shall be posted with nuclear saf ety limits approved by the Manager, Nut lear Lhensing, Saf ety, Accountability and Security (NLSA&S) or thb Nuclear Criticality Specialist.

Contrary to the above, on June 2, 1987, four of five furnaces (work stations) located in the pellet shop were not posted with nuclear saf ety limits.

.R.'SE2ngg_

Since one person attends all five furnaces, we took the position that this was one work station and posted one furnace with a nuclear safety sign since all furnaces have the same nuclear saf ety limit.

However, we have now posted each of the five furnacts with its own nuclear safety sign.

A pendix A, i._t em B l

Section 4.3.20 of your NRC-approved license application (Part 3 - Criteria),

siated January 12, 1987, states, in part, that shipping container arrays shall be ser,arated from one atiother by at least 20 feet.

4; 8712290110 B71218 PDR ADOCK 07001100 C

DCD Power Systems 1000 Prospect Hdl Road (203) 688 1911 Combustion Engincoung, Inc.

Post Othce Box 500 Telex. 90297 Windsor, Connecticut 06095-0500 T

U. S. Nuclear Regulatory Commission November 2,1987 Contrary to the above, on June 1,1987, an array of 26 Model CE-250 shipping containers in the powder trailer storage area located outside the northwest corner of Building 17, containing uranium bearing scrap material, was within 12 f eet of the building wall.

Inside the building, within three feet of the wall, was another array of shipping packages containing uranium bearing scrap materials.

The total distance between the two arrays was 15 feet.

Responer Nuclear safety limit signs posted in the area prohibit the storage of SNM within 20 feet of the building. Material operators were instructed in the. meaning of the nuclear safety signs. A larger sign is also posted on the side of the building which states that no fissile material is to be stored within 20 f eet of the building.

To eliminate the recurrence of this condition, a yellow line has been painted on the ground that is parallel to Building 17 and 20 feet away from Building 17.

All material handling personnel have been reinstructed regarding the meaning of the nuclear safety signs and the painted yellow line.

Appendix A, Item C bection 2.2.2, " Nuclear Fuel Manufacturing-Windsor", of your NRC-approved license application (Part 1 - Criteria) states that the General Manager delegated to the Production and Material Control Manager and to the Engineering Manager responsibility to assure that all operations involving nuclear materials have been analyzed to establish the required saf ety lbaits and controls.

The Manager, NLSA&S or Nuclear Criticality Specialist shall assist the Engineering Manager and the Production and Material Control Manager by performing the analysis required and establishing the appropriate controls.

The Supervisor, Health Physics and Saf ety shall assure that the required saf ety limits and controls are being followed by the use of daily internal audits.

Contrary to the above, between May 10, 1986 and June 4, 1987, the Supervisor, Health Physics and Saf ety did not assure that the required safety limits and controls were being followed with regard to a modification of the fuel rod storage rack at the fluoroscope work station. One of the conditions for approval of the storage rack modification required the installation of a positive restraint to assure that carts containing fuel could not come within 12 inches of the fuel storage rack.

The required positive restraint had not been installed as of June 4,1937.

Response

The positive restraint was inetalled shortly after the inspector's audit.

In cJdition, a recall file has been instituted to maintain control of equipment modification change requests.

The recall file will remain active until the modification has been completed and signed off by the Supervisor, Health Physics and Safety to make certain that the modification will not be utilized until all requirements, imposed on the change request, have been completed.

U. S. Nuclear Regulatory Commission November 2, 1987 With regard to the internally identified violation that involved the placement of unmeasured uranium bearing waste water into not-safe-by-geometry containers following a release of contaminated water from a defective centrifuge in the Building 17 pellet shop, the pellet shop supervisors.and operators have been instructed not to accumulate water in any bucket other than designated mop buckets. This training was documented.

In addition, we have instructed shop personnel to stop all operations where continued use of equipment could jeopar-dize or violate our nuclear safety restrictions. This information was verbally communicated to all shop personnel and is being formally documented by a letter from the Windsor Plant Manager.

We have taken corrective action, as noted above, with respect to the violations cited and believe that we are in full compliance with license conditions. We will continue to devote time and effort to assure compliance with all conditions stated in our license.

Very truly yours, COMBUSTION ENGINEERING, INC.

Nuclear Power Systems

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. McGill' Vice President, Nuclear Fuel PLM/RES/lyc l

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