ML20248L268
| ML20248L268 | |
| Person / Time | |
|---|---|
| Site: | 07000036 |
| Issue date: | 03/13/1998 |
| From: | Sharkey R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-0036-98-201, 70-36-98-201, NUDOCS 9803190238 | |
| Download: ML20248L268 (3) | |
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March 13,1998 l
Docket No. '/0-0036 License No. SNM-33 0
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 SUILIECT: REPLY TO A NOTICE OF VIOLATION Enclosed is Combustion Engineering's Reply to a Notice of Violation dated February 12, 1998, concerning NRC Inspection Report No. 070-0036/98-201.
We appreciate your recognition of the effort and results of our Criticality Safety Program Update (CSPU). As you are aware the wet recovery area is the current focus of this effort. When complete this year, the criticality safety bases will be updated and the area will be assessed by perfonning an Integrated Safety Assessment 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 or Mr. Michael Eastburn of my staff at (314) 937-4691.
Sincerely, COMBUSTION ENGINEERING. INC.
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Robert W. Sharkey Director, Regulatory Affairs cc: Elizabeth Q. Ten Eyck, Director, Division of Fuel Cycle Safety and Safeguards Bill Beach, Regional Administrator, Region 111 t
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ABb CENO Fuel Operations Combustm Enginseong Inc 3300 State Road P Telephone (314) 937-4691 Post o%ce Box 107 St Louis (314) 2E5640 Hematite, Missoun 63047 Fax (314) 937-7955 lL__-
d Enclosure to RA98/702 March 13,1998 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NO. 070-00036/98-201 Response to Violation No. 70-0036/98-201-10 Violation:
License Section 4.2.4 states, in part, that " Fissile aqueous solution transfers from safe to unsafe geometry vessels in the wet recovery system shall have at least two independent methods for control of the fissile content of the solution prior to release of the solution to the unsafe geometry vessel."
Procedure RAAP-108, " Nuclear Criticality Evaluation," Section 6.5.4, states that "A comparison is made of the barrier (s) associated with each contingency to every other barrier / contingency for the location, thereby revealing the potential for common mode failure. This ensures that the " independent" requirement of the double contingency principle is met."
Contrary to the above, as of January 16,1998, the two identified controls designed to meet the requirements above are dual independent sampling of the fissile material content of the solution. Independence of the dual sampling controls could not be demonstrated In that the possibility of common mode failure had not been evaluated.
Response
- 1. Reason for the violation: The violation occurred because the nuclear criticality safety analyst did not consider the use of a single operator during the sampling and analysis processes to be a common-mode failure mechanism in the transfer of fissile aqueous solution from safe to unsafe geometry vessels in the wet recovery filtrate processing system.
- 2. Corrective steps that have been taken and the results achieved: Fissile aqueous j
solution transfers from safe to unsafe geometry sessels in the wet recovery system i
have been suspended. Wet recovery sampling procedures and laboratory analysis procedures will be revised to ensure compliance with License Section 4.2.4. The processes will not restart until corrective steps are completed. Completion is expected by March 31,1998.
- 3. Corrective steps taken to avoid future violations: RAAP-108 is being revised to require that a single operator be explicitly evaluated as a common-mode failure mechanism whenever dual independent sampling and analysis is used as independent criticality controls Completion is expected by March 31,1998.
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Enclosure to RA98/702 October 3,1997
- 4. : When full compliance will be achieved: The actions outlined above will ensure compliance when the transfers of fissile aqueous solution from safe to unsafe geometry vessels in the wet recovery system are resumed. Completion is expected by i'
March 31,1998.
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