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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217J8171999-10-14014 October 1999 Responds to NRC GL-98-03,completing Portion Which Applies to Safety & Process Control Activities of Y2K Readiness Program to Assure That Computer Sys Will Not Prevent or Degrade Safety Function of Structure,Sys or Component ML20217B7511999-10-11011 October 1999 Forwards Siemens Power Corp Responses to RAI in Ltr ML20217C7671999-10-0606 October 1999 Forwards Proprietary Rev 32 EMF-12(P), Nuclear Matls Safeguards Procedures Description for Fuels Fabrication Plants, Replacing Chapters 2 & 3 of Rev 32,dtd Jul 1999. Proprietary Info Withheld,Per 10CFR2.790(d) ML20217C5651999-10-0404 October 1999 Requests Addl Info Needed Before Action Can Be Taken on Siemens Application for Amend to License SNM-1227 to Authorize Activities with SNM in Fuel Services Bldg.Info Specified in Encl Should Be Provided within 10 Days of Ltr ML20216J5381999-09-30030 September 1999 Forwards RAI Per 990721 Application Requesting Amend to License SNM-1227 to Add Process Waste Storage Area Consisting of Four Tanks & Ion Exchange Column to Ammonia Recovery Facility as Part of Wastewater Treatment Process ML20212G3631999-09-21021 September 1999 Forwards Two Sheets from R Burklin Dose Calculations for Heather & Julie ML20212A1921999-09-10010 September 1999 Submits follow-up to NRC Operations Center Rept 36030 Re Bulletin 91-001 Rept on over-batching of Waste Drums Due to Inaccurate Determinations of U Contents ML20217B5621999-09-0202 September 1999 Ack Receipt of 990806 Application for Amend to License SNM-1227.Acceptance Review Completed & Identified No Administrative Omissions or Deficiencies.Formal Review Anticipated Completion Date of Dec 1999 ML20212G1281999-08-31031 August 1999 Informs That Corporation Is Expected to Produce Approx 40,000 Gallons of Ammonium hydroxide-ammonium Nitrate Solution Per Week.Unsold Solution Will Be Processed Through Arf for Recovery of Ammonia & Then Be Sent to Sewer ML20211G1681999-08-26026 August 1999 Ack Receipt of Transmitting Application for Amend to License SNM-1227 Re Addition to Ammonium Recovery Facility.Acceptance Review Has Identified No Administrative Errors of Omissions ML20211F5791999-08-25025 August 1999 Forwards Insp Rept 70-1257/99-201 on 990802-05.No Violation Noted.Proprietary Document Enclosed ML20211B9101999-08-19019 August 1999 Forwards Insp Rept 70-1257/99-202 on 990802-05.No Violations Noted ML20210R8961999-08-12012 August 1999 Forwards Insp Rept 70-1257/99-02 on 990712-16.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representatives Records,Interviews with Personnel & Observation of Activities in Progress ML20210T4811999-08-11011 August 1999 Informs That NRC Has Completed Acceptance Review of Application for Amend to License SNM-1227 & Have Identified No Administrative Omissions or Deficiencies.Nrc Anticipates Completing Formal Review by End of Oct 1999 ML20210U0561999-08-11011 August 1999 Responds to 990714 Correspondence,By Which Siemens Sent Revised Page Change to Table I-1.1, Authorized Activities. Since NRC Had Previously Authorized Activity Stated,Change to Application Is Administrative & No Action Is Required ML20210G0681999-07-28028 July 1999 Concludes That Proposed Additions to Chapter 15 of License Application Submitted by Listed Ltrs Demonstrate Applicant Adherence to Conditions in Part I of License Application & That No Amend to License Necessary ML20210E9551999-07-26026 July 1999 Forwards Amend 17 to License SNM-1227,allowing Storage of Moderated Uranium Compounds in sea-land Containers.Safety Condition S-1 Has Also Been Revised to Include Date of 990527.Safety Evaluation Rept,Encl ML20210F1791999-07-23023 July 1999 Forwards Proprietary Rev 32 to EMF-12(P), Nuclear Matls Safeguards Procedures Description for Fuel Fabrication Plants, Replacing All Sections of Existing Plan.Proprietary Encl Withheld ML20216D4351999-07-21021 July 1999 Provides Description of Modifications That Will Be Made to Ammonia Recovery Facility.Wastewater Flowsheet Encl ML20209H5361999-07-15015 July 1999 Ack Receipt of 990519 Application for Amend to License SNM-1227 Re Sale of Ammonium Nitrate/Ammonium Hydroxide Solution Fertilizer.Initial Review of Application Has Identified No Administrative Omissions or Deficiencies ML20209G2561999-07-12012 July 1999 Informs That Staff Has No Comments on Siemens Power Corp Ammonium Recovery Facility - Sepa Determination of non-significance in Response to ML20209D8121999-07-0606 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/99-01. Corrective Actions Will Be Reviewed During Future Insp to Determine That Full Compliance Has Been Achieved ML20196H0021999-06-23023 June 1999 Submits Response to NRC GL 98-03 for Y2K.Upgraded Y2K Ready Primary Control Sys Will Be Installed & Tested in July 1999 ML20196A0931999-06-15015 June 1999 Responds to NRC Re Violations Noted in Insp Rept 70-1257/99-01.Corrective Actions:Info Requested by NRC Is Fully Available in Previously Docketed Correspondence ML20209C2711999-06-11011 June 1999 Requests Review & Comment on Encl Sepa Checklist & Other Info on File with City,By 990625 ML20195F9401999-06-0707 June 1999 Concurs That 990331 Proposed Changes to Richland Facility Emergency Plan Do Not Decrease Effectiveness of Plan.Nrc Will Amend License,Within Next Six Months,To Ensure Latest Rev to Plan Is Reflected ML20207B3681999-05-21021 May 1999 Forwards Insp Rept 70-1257/99-01 on 990322-26,0514 & 21 & Nov.Three Violations Identified Involving Two Examples of Using Transport Containers Which Did Not Meet Terms & Conditions of Applicable Certificate of Compliance ML20206L5371999-05-11011 May 1999 Forwards Amend 16 to License SNM-1227,allowing Storage of Moderated Special Nuclear Matl in sea-land Containers.Ser Also Encl ML20207M0151999-03-11011 March 1999 Informs That Encl Ltr Dtd 950622,explains How NRC Staff Plans to Institute Round Robin Sample Exchange Program Administered by Nbl for Verifying Quality of Licensee U Destructive Measurement Systems.Invoice FL0236-99 Encl ML20207J7221999-02-24024 February 1999 Ack Receipt of 980121 Application for Amend to License SNM-1227.Completed Initial Review with No Administrative Omissions or Deficiencies Identified.Anticipates Technical Review Will Be Completed by First Week in April ML20203G2191999-02-16016 February 1999 Responds to Which Expressed Concerns Re USNRC Plans to Distribute 981221 SRM Re SECY-98-232 & Commission Paper to All Agreement States.Informs That NRC Does Not Plan to Delay Implementation of Actions Specified in SRM ML20202E4141999-01-29029 January 1999 Ack Receipt of 990122 Response to Violations Noted in Insp Rept 70-1257/98-204.Implementation of Licensee Corrective Actions Will Be Reviewed During Future Insps ML20202H6241999-01-29029 January 1999 Forwards Siemens Power Corp Best Estimate of Upcoming Work Which Will Require NRC Licensing Actions ML20199K9571999-01-19019 January 1999 Informs of Listed New Address,For Docket 7106851,for Siemens Power Corp,Effective 990101.Postcard with New Address,Encl ML20199F3741999-01-12012 January 1999 Responds to NRC Re Violations Noted in Insp Rept 70-1257/98-204.Corrective Actions:All Work on Line 1 Ammonium Diuranate (Adu) Project Was Stopped Until Incident Could Be Fully Investigated & Necessary Actions Implemented ML20206R9451999-01-0707 January 1999 Forwards Pages 15-159 Through 15-174 to Include in Chapter 15 of Siemens Power Corp License Application.Pages Provide Summary of Criticality Safety Analysis for Processes Carried Out in Lagoon U Recovery & Solids Processing ML20198P0991998-12-30030 December 1998 Submits Response to GL 98-03 Re Program Set Forth in EMF-2097, Siemens Power Corp Yr 2000 Readiness & Administered by Yr 2000 Project Team ML20198M8901998-12-23023 December 1998 Forwards Amend 15 to License SNM-1227,amended to Allow Processing of TVA Lead Test Assembly Fuel ML20198A9651998-12-15015 December 1998 Submits Addl Info to Support Request to Amend Limit for transuranic-related Activity in Feedstock for License SNM-1227.Revised License Pages 1-5 & 1-6,correcting Inadvertent Omission of Section 1.6.12,encl ML20198F5701998-12-15015 December 1998 Forwards Insp Rept 70-1257/98-05 on 981026-30.No Violations Noted.Areas Examined During Insp Were Operational Safety & Event Review Feedback & Mgt Organization & Controls ML20198B4041998-12-14014 December 1998 Forwards Insp Rept 70-1257/98-204 on 981109-13 & Notice of Violation Involving Failure to Control Decommissioning Operations So That Operators Would Verify That Disassembled Equipment Free from Visible U Deposits ML20154S1881998-10-20020 October 1998 Submits follow-up to NRC Operations Ctr Rept 34819 Bulletin 91-001 on Failure to Remove Accumulated Solids from Dismantled Ductwork ML20155A5371998-10-0909 October 1998 Informs That NRC Has Reviewed Changes to Part II of Application for License SNM-1227.Administrative Error Re Three 500 Kw Generators Was Noted.Nrc Would Like to Be Informed as to Whether Interpretation Is Correct ML20153C3091998-09-18018 September 1998 Submits Response to GL 98-03,re Year 2000 Readiness Program ML20151X0591998-09-11011 September 1998 Forwards Insp Rept 70-1257/98-04 on 980810-14.No Violations Noted.During Insp,Licensee Conduct of Activities at Siemens Facility Was Generally Characterized by Effective Implementation of Operational Safety,Maint & Surveillance ML20239A5221998-09-0202 September 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/98-03 on 980717 ML20151W9751998-09-0202 September 1998 Forwards Amend to License SNM-1227,revising to Incorporate Fundamental Nuclear Matl Control Plan.Revised License & Evaluation Rept,Encl ML20151W9951998-09-0101 September 1998 Forwards Amend 13 to License SNM-1227 to Reflect Correct Location of UF6 Cylinder Storage,Adding Filter Presses to Table I-4.1 & Sale of Ammonium Hydroxide for Fertilizer ML20237E7701998-08-26026 August 1998 Forwards Pages 15-133 Through 15-139 Which Provide Summary of Criticality Safety Analysis for Recovery of U from Pellets in Gd Scrap U Recovery Facility for Info & Inclusion in Chapter 15 of Siemens Power Corp License Application 1999-09-30
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217C5651999-10-0404 October 1999 Requests Addl Info Needed Before Action Can Be Taken on Siemens Application for Amend to License SNM-1227 to Authorize Activities with SNM in Fuel Services Bldg.Info Specified in Encl Should Be Provided within 10 Days of Ltr ML20216J5381999-09-30030 September 1999 Forwards RAI Per 990721 Application Requesting Amend to License SNM-1227 to Add Process Waste Storage Area Consisting of Four Tanks & Ion Exchange Column to Ammonia Recovery Facility as Part of Wastewater Treatment Process ML20217B5621999-09-0202 September 1999 Ack Receipt of 990806 Application for Amend to License SNM-1227.Acceptance Review Completed & Identified No Administrative Omissions or Deficiencies.Formal Review Anticipated Completion Date of Dec 1999 ML20211G1681999-08-26026 August 1999 Ack Receipt of Transmitting Application for Amend to License SNM-1227 Re Addition to Ammonium Recovery Facility.Acceptance Review Has Identified No Administrative Errors of Omissions ML20211F5791999-08-25025 August 1999 Forwards Insp Rept 70-1257/99-201 on 990802-05.No Violation Noted.Proprietary Document Enclosed ML20211B9101999-08-19019 August 1999 Forwards Insp Rept 70-1257/99-202 on 990802-05.No Violations Noted ML20210R8961999-08-12012 August 1999 Forwards Insp Rept 70-1257/99-02 on 990712-16.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representatives Records,Interviews with Personnel & Observation of Activities in Progress ML20210U0561999-08-11011 August 1999 Responds to 990714 Correspondence,By Which Siemens Sent Revised Page Change to Table I-1.1, Authorized Activities. Since NRC Had Previously Authorized Activity Stated,Change to Application Is Administrative & No Action Is Required ML20210T4811999-08-11011 August 1999 Informs That NRC Has Completed Acceptance Review of Application for Amend to License SNM-1227 & Have Identified No Administrative Omissions or Deficiencies.Nrc Anticipates Completing Formal Review by End of Oct 1999 ML20210G0681999-07-28028 July 1999 Concludes That Proposed Additions to Chapter 15 of License Application Submitted by Listed Ltrs Demonstrate Applicant Adherence to Conditions in Part I of License Application & That No Amend to License Necessary ML20210E9551999-07-26026 July 1999 Forwards Amend 17 to License SNM-1227,allowing Storage of Moderated Uranium Compounds in sea-land Containers.Safety Condition S-1 Has Also Been Revised to Include Date of 990527.Safety Evaluation Rept,Encl ML20209H5361999-07-15015 July 1999 Ack Receipt of 990519 Application for Amend to License SNM-1227 Re Sale of Ammonium Nitrate/Ammonium Hydroxide Solution Fertilizer.Initial Review of Application Has Identified No Administrative Omissions or Deficiencies ML20209G2561999-07-12012 July 1999 Informs That Staff Has No Comments on Siemens Power Corp Ammonium Recovery Facility - Sepa Determination of non-significance in Response to ML20209D8121999-07-0606 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/99-01. Corrective Actions Will Be Reviewed During Future Insp to Determine That Full Compliance Has Been Achieved ML20195F9401999-06-0707 June 1999 Concurs That 990331 Proposed Changes to Richland Facility Emergency Plan Do Not Decrease Effectiveness of Plan.Nrc Will Amend License,Within Next Six Months,To Ensure Latest Rev to Plan Is Reflected ML20207B3681999-05-21021 May 1999 Forwards Insp Rept 70-1257/99-01 on 990322-26,0514 & 21 & Nov.Three Violations Identified Involving Two Examples of Using Transport Containers Which Did Not Meet Terms & Conditions of Applicable Certificate of Compliance ML20206L5371999-05-11011 May 1999 Forwards Amend 16 to License SNM-1227,allowing Storage of Moderated Special Nuclear Matl in sea-land Containers.Ser Also Encl ML20207M0151999-03-11011 March 1999 Informs That Encl Ltr Dtd 950622,explains How NRC Staff Plans to Institute Round Robin Sample Exchange Program Administered by Nbl for Verifying Quality of Licensee U Destructive Measurement Systems.Invoice FL0236-99 Encl ML20207J7221999-02-24024 February 1999 Ack Receipt of 980121 Application for Amend to License SNM-1227.Completed Initial Review with No Administrative Omissions or Deficiencies Identified.Anticipates Technical Review Will Be Completed by First Week in April ML20203G2191999-02-16016 February 1999 Responds to Which Expressed Concerns Re USNRC Plans to Distribute 981221 SRM Re SECY-98-232 & Commission Paper to All Agreement States.Informs That NRC Does Not Plan to Delay Implementation of Actions Specified in SRM ML20202E4141999-01-29029 January 1999 Ack Receipt of 990122 Response to Violations Noted in Insp Rept 70-1257/98-204.Implementation of Licensee Corrective Actions Will Be Reviewed During Future Insps ML20198M8901998-12-23023 December 1998 Forwards Amend 15 to License SNM-1227,amended to Allow Processing of TVA Lead Test Assembly Fuel ML20198F5701998-12-15015 December 1998 Forwards Insp Rept 70-1257/98-05 on 981026-30.No Violations Noted.Areas Examined During Insp Were Operational Safety & Event Review Feedback & Mgt Organization & Controls ML20198B4041998-12-14014 December 1998 Forwards Insp Rept 70-1257/98-204 on 981109-13 & Notice of Violation Involving Failure to Control Decommissioning Operations So That Operators Would Verify That Disassembled Equipment Free from Visible U Deposits ML20155A5371998-10-0909 October 1998 Informs That NRC Has Reviewed Changes to Part II of Application for License SNM-1227.Administrative Error Re Three 500 Kw Generators Was Noted.Nrc Would Like to Be Informed as to Whether Interpretation Is Correct ML20151X0591998-09-11011 September 1998 Forwards Insp Rept 70-1257/98-04 on 980810-14.No Violations Noted.During Insp,Licensee Conduct of Activities at Siemens Facility Was Generally Characterized by Effective Implementation of Operational Safety,Maint & Surveillance ML20239A5221998-09-0202 September 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/98-03 on 980717 ML20151W9751998-09-0202 September 1998 Forwards Amend to License SNM-1227,revising to Incorporate Fundamental Nuclear Matl Control Plan.Revised License & Evaluation Rept,Encl ML20151W9951998-09-0101 September 1998 Forwards Amend 13 to License SNM-1227 to Reflect Correct Location of UF6 Cylinder Storage,Adding Filter Presses to Table I-4.1 & Sale of Ammonium Hydroxide for Fertilizer ML20236R2661998-07-17017 July 1998 Forwards Insp Rept 70-1257/98-03 on 980615-19 & Notice of Violation Re Lack of Rigor in Implementation of Std Operating Procedures Used in Segregation of Hazardous Wastes Onsite & Rework of Fuel Cladding ML20236P2141998-06-26026 June 1998 Forwards Proprietary Request for Addl Info Identified in Encl to Ltr Re Revs to Fundamental Nuclear Matl Control Plan.Proprietary Encl Withheld (Ref 10CFR2.790(d)) ML20249A7211998-06-15015 June 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/98-202 ML20249A9691998-06-15015 June 1998 Refers to 980610 Meeting Conducted at Richland,Wa Re NRC Review of Performance Related to NRC Licensed Activities. List of Attendees & Slides Encl ML20249A2331998-06-11011 June 1998 Informs That QA Program Description Is Acceptable,Based on Review of Organizational Changes Described in Submittals & Addressing of NRC Comments in 980527 Submittal ML20249B2151998-06-0808 June 1998 Discusses Nrc'S Plans to Develop Emergency Response Technical Manual (Rtm) Supplements for Licensee Facility. Copy of Draft Outline for Rtm Supplements,Encl.W/O Encl ML20248J9831998-06-0202 June 1998 Forwards Insp Rept 70-1257/98-02 on 980413-17 & 980504-08.No Violations Noted.Insp Included Review of Circumstances Involved W/Fire That Occurred in Waste Handling Facility on 980415 Acceptable ML20248D8441998-05-21021 May 1998 Forwards Amend 12 to License SNM-1227,adding Operation of Solids Processing Facility as Authorized Location for Uranium Recovery.Safety Condition S-1 Revised to Include Dates of 960730 & 970128.Safety Evaluation Rept,Encl ML20248E0791998-05-18018 May 1998 Forwards Amend 11 to License SNM-1227,reflecting New Location for Liquid Effluent Sampling & Flow Measurements. Safety Condition S-1 & Safeguards Condition SG-2.1 Have Been Revised.Ser & Safeguards Evaluation Rept,Encl ML20247D7051998-05-0808 May 1998 Discusses NRC Performance Review of Licensed Activities on 961231-980101.Concludes That NRC Decided to Increase Insp Effort in Packaging & Shipping of Nuclear Fuel & Seek to Reduce Level of Insp in Area of Safeguards ML20247N1791998-05-0808 May 1998 Ack Receipt of ,Which Transmitted Rev 15 to Physical Protection Plan Entitled, Physical Protection Plan for SNM of Low Strategic Significance. Review of Changes Were Found to Be Consistent w/10CFR70.32(e) ML20248J0271998-05-0808 May 1998 Forwards Outline of NRC Review of Licensee Performance in Areas of Safety Operations,Safeguards,Radiological Controls, Facility Support & Licensing Activities ML20217Q9501998-05-0404 May 1998 Forwards Proprietary NOV & Insp Rept 70-1257/98-202 for Insp Conducted on 980406-10.Violation Involved Failure to Maintain Current Knowledge of Special Nuclear Matl Bearing Items.Nov & Insp Rept Withheld,Per 10CFR2.790 ML20216H6381998-04-15015 April 1998 Responds to & Affidavit Signed by Re Vaughan on 980316,requesting That Certain Info in Response to RAI Be Withheld Per 10CFR2.790.Determined That Info Sought to Be Withheld Contains Proprietary Info & Will Be Withheld ML20217J8541998-04-0101 April 1998 Forwards Insp Rept 70-1257/98-201 on 980313-19 on Nov. Violations Re Use of Unapproved Procedures & Operator Aids. Corrective Actions Taken by Staff ML20217A9071998-03-17017 March 1998 Forwards Amended License SNM-1227 & SER Re Authorization of Low Level Radioactive Waste Shredding & Uranium from LLRW in Modular Unit ML20217Q5141998-03-0505 March 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/97-07 ML20203K3581998-02-24024 February 1998 Forwards Insp Rept 70-1257/98-01 on 980126-30.No Violations Noted.Inspector Noted That Staff Had Implemented Effective Programs in Mgt Organization & Controls,Operational Event Review & Feedback & Operator Training & Requalification ML20203A4081998-02-0303 February 1998 Informs That Project Management for Facility Has Been Changed Due to Reorganization of Staff.P Lain Will Be Project Manager Effective 980217 ML20198S4771998-01-16016 January 1998 Forwards Insp Rept 70-1257/97-07 on 971215-19 & 971222-24 & Nov.Insp Included Review of Selected Activities at Facility in Richland,Washington.Noted Staff Implemented Effective Programs in EP & Areas of Operation Reviewed During Insp ML20198Q1211998-01-15015 January 1998 Forwards Amend 9 to License SNM-1227 & Ser.Amend Authorizes Use of Operations Scrap Warehouse 1999-09-30
[Table view] |
Text
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REGION IV g
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Walnut Creek. Caltfomia 94596-5368 4
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
'cc: i Siemens Power Corporation ATTN: L. J. Maas, Manager k Regulatory Compliance 2101 Horn Rapids Road P.O. Box 130 Richland, Washington 99352 0130 State of Washington ggl l l 9708190053 970813 PDR ADOCM 07001257 go/l-
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DOCUMENT NAME: G:\SPC9705 THY To receive copy of document, indiosto in boa: "c" = Copy weout enclosures "E" = Copy we enclosures *N" = No copy R1V:WCFO / 6 C:WCF0:MB - l G - l FAWenslawski p CAHooker M ~
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I SIEMENS ntcc,yyy HRC i VIV WCFC August 7,1997 II PHI:50 '
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.
l
- 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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