ML20132G506

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-0036/96-04

ML20132G506
Person / Time
Site:	07000036
Issue date:	12/23/1996
From:	Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kaiser B ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 9612260272
Download: ML20132G506 (1)

Text

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bcb Deceber 23,1996 ,

i Dr. Bruce Kaiser i Vice President, Fuel Operations ABB Combustion Engineering 3300 State Road P Hematite, MO 63047

SUBJECT:

RESPONSE TO INSPECTION REPORT NO. 070-00036/96004(DNMS)

Dear Dr. Kaiser:

This will acknowledge receipt of your letter dated November 22, 1996, in response to our letter dated October 31, 1996, transmitting two Notices of l Violation associated with failures to follow nuclear criticality safety l procedures. We have reviewed your corrective actions and have no further l questions at this time. These corrective actions will continue to be examined i during further inspections.

If you have any questions, please contact Gary Shear at (630) 829-9876.

Sincerely, l OngMal Sigtfed yY ROY 'eJ Caniano Cynthia D. Pederson, Director Division of Nuclear Materials Safety License No. SNM-33 Docket No. 070-00036 cc: R. W. Sharkey, Director of Regulatory Affairs R. A. Kucera, Missouri Department of Natural Resources bec: R. Pierson, NMSS P. Ting, NMSS S. Soong, NMSS N. Mamish, OE B. Burgess, RIII PUBLIC (IE07)

DOCUMENT NAME: A:\CE96005 REP T cetve a copy of this document. indicate in the boa "C" = Copy without attach / enc 1 "E" = Copy with attach / enc 1 "N" =

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NAME Krsek:ibEO N Shear 845 PedersonkCh DATE 12/D/96 12/23/96 12/2J96N I 0FFICIAL RECORD COPY ,/

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A BD 7% DED November 22,1996 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 j Gentlemen:

Enclosed is Combustion Engineering's Reply to Notice of Violation dated October 31,  ;

1996, concerning NRr Inspection Report No. 070-00036/96004(DNMS).

1 As addressed in our submittal of September 20,1996 concerning our Criticality Safety Program Update (CSPU), we have a comprehensive plan in place to focus on the implementation of criticality limits and controls. We have a Criticality Specialist starting in January who has been tasked with direction of the CSPU. One of the major goals is to simplify administration of criticality limits and controls by inaking the process simpler, thus avoiding items of noncompliance of the type cited.

We will be glad to discuss any questions you have conceming our response. Ifyou have any questions or need further information, please contact me or Mr. Hal Eskridge of my staff at (314) 937-4691.

Very truly yours, I

COMBUSTION ENGINEERING,INC.

V I Robert W. Sharkey Director, Regulatory Affairs l

cc: Bill Beech, Regional Administrator Region Ill j

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Enclosure to RA96/523 November 22,1996 4

REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT NO. 070-00036/96004(DNMS) d Response to Violation No. 96004-01 1- Violation:

Operating System (OS) Procedure 801.10," Filter Processing," requires in Section 5.1.2. ,

i that 24" by 24" filters, stacked on pallets near the building 240-3 maintenance room, have l

no more than 2 kilograms (kgs) net weight or no more than 75 grams of U-235 per gamma count.

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Contrary to the above, on September 24,1996, two filters were stacked on pallets near the i

building 240-3 maintenance room with greater than 2 kgs net weight and 77.5 grams and 81.5 grams of U-235 per gamma count, respectively.

l Response:

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1. Reason for the violation: The violation occurred because the employee who stacked

the filters did not observe limits as specified in the procedure and posted on the criticality limit sign.

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2. Corrective steps that have been taken and the results achieved: As immediate corrective action, the two filters were removed from the stack to a proper criticality control spacing of one foot, and the area was roped off. This action brought the area d

into full compliance with the criticality safety requirements. Also, the criticality limit sign was relocated to improve its visibility, and the employee involved was counciled

on the importance of observing criticality limit sign postings.

3. Corrective steps taken to avoid future violations

The importance of observing criticality limit sign postings was stressed in recently conducted criticality safety l training. Additional emphasis has been placed in this functional area and described in

! our CSPU, dated September 20,1996.

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4. When full compliance will be achieved: We are currently in full compliance with the criticality safety limits for stacking filters. I i

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4 Enclosure to RA96/523 i November 22,1996 4

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Response to Violation No. 96004-02

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1 Violation:

Nuclear Inspection System (NIS) Procedure 201, " Nuclear Safety Parameters," requires in l Section 1.6, " Containers in Transit," that a Safe Individual Unit (SIU) must be placed at least one foot from other (SIU) units. Furthermore, Section 1.6 requires that no more than two SIUs may be "in transit" at one time in the immediate work area.

l Contrary to the above, on September 25,1996, one (55 gallon) drum of packaged filter media waste, an SIU, was placed less than one foot from another drum of packaged filter

' media waste, another SIU. In addition, three packaged filter media waste drums, three SIUs, were "in transit" at one time in the immediate work area.

i i Response:

1. Reason for the violation: The violation occurred because of not incorporating specific criticality requirements in the OS or SET procedure for the drum filling operation.

2. Corrective steps that have been taken and the results achieved: The filter work -

area was quarantined and processing of filters was Wpped. The drums were moved I to proper storage, which resulted in the area being braught into full compliance with the criticality safety requirements.

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3. Corrective steps taken to avoid future violations: Revised procedures containing the criticality requirements will be issued prior to resuming the filter processing  ;

operation. Specific criticality' safety training was given on application of the "two  ;

items in tran:;it" rule to preclude a similar problem in other work areas,

4. When full compliance will be achieved: We are currently in full compliance on this item.

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