ML20248J171

Memorandum & Order (Request for Info).* Lists Conclusions, Subj to Further Consideration of Contrary Filings or Argument,Per Review of Rt Lancet Affidavit Filed on 890927. W/Certificate of Svc.Served on 891005

ML20248J171
Person / Time
Site:	07000025
Issue date:	10/04/1989
From:	Bloch P Atomic Safety and Licensing Board Panel
To:	NRC OFFICE OF THE GENERAL COUNSEL (OGC), ROCKWELL INTERNATIONAL CORP.
References
CON-#489-9268 89-594-01-ML, 89-594-1-ML, ML, NUDOCS 8910130093
Download: ML20248J171 (4)

Text

-- _ - . .

l: I t

5 ,.i '

- C ".,v. ,

l

, October 4, 1989

'89 OCT -5 P1 :03 1 UNITED STATES OF AMERICA , l

. NUCLEAR REGULATORY COMMISSION [_0[ f ri.. , 1,- l

? ?. A h , +

ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judge -

Peter B. Bloch SERVED OCT ,a 1989 In the Matter of Docket 70-25 " k b O ROCKWELL INTERNATIONAL Request to Renew CORPORATION For Ten Years  !

Rocketdyne Division '

(Special Material License ASLBP No. 89-594-01-ML  !

Number SNM-21) 1 MEMORANDUM AND ORDER 1 (Request for Information)  !

After reviewing the Affidavit of Robert T. Lancet,  !

filed by Applicants on September 27, 1989, I have some additional concerns and questions.  !

I have preliminarily and tentatively reached the l i

following numbered conclusions, subject to further consideration should any of the parties submit contrary filings or argument, that: 1

1. The following incidents, disclosed by Applicants, have in common that they were contributed to by a material defect or other design error that may have been caused by I careless engineering: (a) 9/23/88, " improper material se-lection by designer"; (b) 6/20/88, " material 1

incompatibility"; (c) 2/18/86, " material defect" (appears to .j J

8910130093 891004 PDP C ADOCK 07000025 ppg 7fj

)P l

have resulted fro.m improper plugging of the drain line --

not clear the extent to which this is an engineering error);

(d) 9/26/85, " material failure" (not clear whether this resulted from improper engineering or even whether the disposition represented proper engineering -- ERA the similar incident on 2/18/86); (e) 4/13/84, " incompatible material", (f) 7/1/82, failure of a gasket seal -- with prescription for regular inspections but no indication of engineered gasket life or replacement period, (g) 5/22/81 (apparently inadvertently omitted from Table 1), sodium leak due to intergranular stress corrosion cracking apparently caused by direct contact between mineral fiber insulation and the pipe, with "no sheet metal oven between", (h) 8/5/72, " design error resulted in fatigue failure of thermowell" (failure of engineer to consider properly forces resulting from flow-induced vibration), (i) 2/6/71, cause of l incident not clear but solution is to re-engineer the system to delete a hot trap, and (j) 9/28/70, " material failure" (bellows seal valve to be replaced by a stem freeze seal type valve).

2. This may represent a pattern of events that should have been trended.'

'The Application is required by 10 C.F.R. S 70.22(f),

l including footnote 2 to that section, to comply with 10 C.F.R. Part 50, Appendix B, particularly 1 XVI, which requires prompt identification and correction of conditions adverse to quality and -- for significant conditions --

determination of the cause of the condition and corrective 1

1

3.

b The reports given may also show patterns with respect to procedure errors and operator errors, possibly due to training, quality assurance deficiencies er personnel selection.

There appears to be insufficient information on the forms to know whether any systematic errors of these types exist.

There is no indication on the forms that serious attention has been given to trending.

I respectfully request that similar reports (unusual occurrences, NCRs, RDs, environmental non-conformance reports, etc.)

for events that occurred during the past 20 years, involving releases of radioactive materials , should be filed within one month, regardless of whether or not the standards of 10 C.F.R.

SS 20.105 and 20.106 have been exceeded.

Applicants may file other comments on this memorandum within one month as well.

Interveners may desire to litigate a concern derived from my inquiries. To do so, they may file their concern within 28 days or, if it relates to Applicant's response to this memorandum, within 15 days of the filing of that response.

Respectfully ORDERED, g , f /v[ _

P'eter B. Bloch Administrative Judge action to preclude repetition.

O' UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of i

. I ROCKWELL INTERNATIONAL CORPORATION 1 Docket No.(s) 70-25-ML l

(Rocketdyne Division, Special I Nuclear Materials License SNM-21) i I

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing LB M&O (REQUEST FOR INFO.)10/4 have been served upon the following persons by U.S. mail, first class, except as otherwise noted and in accordance with the requirements of 10 CFR Sec. 2.712.

Administrative Judge Atomic Safety and Licensing Appeal Peter B. Bloch Board Presiding Officer U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, DC 20555 U.S. Nuclear Regulatory Commission Washington, DC 20555 Administrative Judge Sustave A. Linenberger, Jr.

Special Assistant Office of the General Counssi Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Cosmission Washington, DC 20555 Washington, DC 20555 R. T. Lancet Director Rockwell International Corporation Jon Scott Rocketdyne Division 6 Roundup Road 6633 Canoga Avenue Bell Canyon, CA 91307 Canoga Park, CA 91304 Estelle Lit Jerome E. Raskins, et. al.

18233 Bermuda Street c/o 18350 Los A11mos Northridge, CA 91326 Northridge, CA 91326 Alan Langville Simi Valley Library Public Document Room 2969 Tapo Canyon Road Simi Valley, CA 93063 Dated at Rockville, Md. this 5 day of October 1989

~ ~

ffice f the Secretary of ihe Com5ission

__-_____ __-______ _ _-_- _ -