ML20237E900
| ML20237E900 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 08/27/1998 |
| From: | Sharkey R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-0036-98-03, 70-36-98-3, NUDOCS 9809010279 | |
| Download: ML20237E900 (3) | |
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Mpp August 27,1998 Docket No. 70-0036 License No. SNM-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 a Notice of Violation concerning NRC Inspection Report No. 70-36/98-003, dated July 30,1998.
In addition to the actions stated in the enclosed reply, we have taken action to enhance our self assessment program. The enhancement involves frequent (usually weekly) review by plant management of the status ofitems identified during quarterly inspections.
These reviews have resulted in improved completion of noted items.
We will be glad to discuss any questions you have concerning our response. If you have any questions or need further information, please contact me at (314) 937-4691.
Sincerely, COMBUSTION ENGINEERING,INC.
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Robert W. Sharkey 1
Director, Regulatory Affairs
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cc: Jim Caldwell, Regional Administrator (Acting), NRC Region III RA98/790 diO'
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9009010279 980827 PDR ADOCK 07000036 C
PDR ABB CENO Fuel Operations Combusbon Engineenng, Inc 3300 S: ate Road P Telephone (314) 937 4091 Post Othce Box 107 St Louis (314) 296 %40 Hemat >te. M.ssoon t 3047 Fax (314) 937-7955 1
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1 Combustion Engineering, Inc.
Docket 70-36 August 27,1998 License No. SNM33 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 70-36/98-003 Response to Violation No. 98-003-01 Violation:
Safety Condition S-1, ofSpecial Nuclear Afaterials License, SNAl-33, authorizes the use oflicensed materials in accordance with the statements representations, and conditions in Chapters 1 through 8 ofthe application dated October 29,1993, andsupplements and revisions thereto.
Chapter 2, Section 2.6, " Operating Procedures, " ofthe supplement, dated August 8, 1997, requires, in part, that all operations which affect licensed material shall be
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conductedin accordance with approvedprocedures.
Sections 6.0 and 7.0 ofOperational Safety Procedure O.S 604.12, " Operational Inspection and Checklists, " required, in part, that certain equipment be checkedper the
" Weekly and Afonthly Checklist, " at weekly and monthlyfrequencies to maintain safety and/or operability ofthe Oxide Building.
Section 6.6, ofNuclear Industrial Safety (NIS) Procedure 213, "Ha:ardous Afaterials Afanagement, " required, in part, that chemicals shall be compatible with their containers, lockers, containment, and the other materials with which they are stored. A guideline isprovided in the Ha:ardous Afaterial Data Table.
1 Contrary to the above, operations which affected licensed material were not conducted in i
accordance with approved written procedures in thefollowing examples:
From Februwy I998 to July 17,1998, plant stafffailed to check certain equipment a.
at weekly and monthlyfrequencies as required by Procedure O.S 604.12, to maintain safety and/or operability ofthe Oxide Building. Specifically, twelve weekly and two monthly checks were not conductedfrom February 1998 to July 17, 1998.
b.
Prior to July 16,1998, a carboy (approximately 30-gallon container) ofnitric acid was stored on the westfloor ofthe South Vault, where thefloor was contaminated with oil, an organic combustible chemical incompatible with nitric acid, as defined in the Ha:ardous Afaterial Table in NIS Procedure 213.
RA98n90 1
Combustion Engineering, Inc.
Docket 70-36 I
1 August 27,1998 License No SNM33
Response
- 1. Reason for the violation:
a.
Failure to conduct some of the weekly and monthly safety and operability checks in the Oxide Building wr due to maintaining the checklist on a clipboard which required operator diligence outside of normal daily activities and lack of specific assignment of operators to conduct the checks.
- b. Storage of the nitric acid carboy in the South Vault was due to the presence of outdated postings in the vault and inadequate training of the operators involved.
- 2. Corrective steps that have been taken and the results achieved:
a.
Weekly and monthly preventative maintenance checks required by procedure O. S. 604.12 have been incorporated into the Maintenance Work Order System which tracks completion of the tasks.
- b. The carboy was removed from the South Vault and placed in proper storage. The outdated postings were also removed.
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- 3. Corrective steps taken to avoid further violations:
I Incorporation of the checks into the Maintenance Work Order System to provide a.
more formal assignment, tracking and documentation of the checks will avoid further violations in this area.
- b. Training in the proper handling and storage of chemicals will be conducted for operators involved in this activity. This training will be completed by September 30,1998.
- 4. Date when full compliance will be achieved: Full compliance has been achieved on both items.
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