ML20206G934

Ack Receipt of 990422 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-0036/99-01 Issued on 990323

ML20206G934
Person / Time
Site:	07000036
Issue date:	05/03/1999
From:	Hiland P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kaiser B ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
70-0036-99-01, 70-36-99-1, NUDOCS 9905100179
Download: ML20206G934 (1)

Text

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..fe May 3, 1999 Dr. Bruce Kaiser Vice President, Fuel Operations ABB Combustion Engineering, Inc.

3300 State Road P Festus, MO 63028

SUBJECT:

RESPONSE TO INSPECTICN REPORT 070-00036/99001(DNMS)

Dear Dr. Kaiser:

This refers to your April 22,1999, response to the Notice of Violation (NOV) transmitted to you by our letter dated March 23,1999, with Inspection Report 070-00036/99001(DNMS). We have reviewed your corrective actions and have no further questions at this time. Your corrective actions will be examined during future inspections.

If you have any questions, please contact me at (630) 829-9603.  ;

Sincerely,

/s/ P. L. Hiland Patrick L. Hiland, Chief Fuel Cycle Branch Docket No. 070-00036 License No. SNM-33 cc: R. W. Sharkey, Director, Regulatory Affairs R. A. Kucera, Director, Intergovernmental Cooperation, Missouri Department of Natural Resources bec w/Itr dtd 04/22/99: Docket File PUBLIC IE-07 C. Emeigh, NMSS R. Soong, NMSS P. Ting, NMSS R. Bellamy, RI ll EJM, Ril (e-mail)

D. B. Spitzberg, RIV Greens w/o enci DOCUMENT NAME: G:\SEC\COM99001.RES To receive a copy of this document, Indicate in the box:"C" w Copy without enclosure "E*= Copy with endosure"N's No copy lDFFICE Rlli lt Rlli lM l l Kniceley:ib ' 4@ Hiland P.t.\t hAME PATE 04/-)(/99 04!!99i9l3/46 OFFICIAL RECORD COPY 9905100179 990503 PDR ADOCK 07000036 C PDR t.

l 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 Enclosed is Combustion Engineering's Reply to a Notice of Violation concerning NRC Inspection Report No. 070-00036/99001, dated March 23,1999. The violation occuns d as the result of a procedure modification that removed a periodic load cell test. The test provided assurance of the operation of the system for preventing the potential overfilling of the UF6cold trap. The procedure for implementing the reliability assurance program for items important to safety has been updated to include functional testing of this safety function.

As CE progresses on schedule to conduct ISAs for the facility and in light of the pending revision of 10 CFR 70 we have continued to refine our process. One area that we are currently focused is the summary ofISA results. When complete this will enhance our ability to quickly recognize safety important systems or items and allow the focus of our self assessment process on these systems that contribute most to risk reduction.

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.

y W2.2-99 Robert W. Sharkey Director,llegulatory Affairs cc: Jim Dyer, Regional Administrator, NRC Region III APR 2 6 1999 RA99/074 ABB Combustion Engineering Nuclear Power Combuston Engineonng, Inc 3300 State Road P Teleptone (314) 937-4691 Festus. MO 63028 (314) 29G5640 1 { j O Q ' ,j Fax (314)917 7955

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Combustion Engineering,Inc. Docket 70-36 April 22,1999 License No. SNM-33 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 070-00036/99001 Response to Violation No. 99001 Violation:

During an NRC inspection conductedfrom March 1 through 5,1999, one violation of NRC requirements was identified. In accordance with the "GeneralStatement ofPolicy and Procedurefor NRC Enforcement Actions, " (Enforcement Policy) NUREG-1600, Revisioni, the violation is listed below:

License No. SNM-33, Safety Condition S-1 states, in part, that the license is authorized for use in accordance with the statements and representation in Chapters 1 thorough 8 of the opplication.

5 Chapter 1.6(e), " Exemptions and Special Authorizations, " requires, in part, that ABB t Combustion Engineering, Inc., shallperform Integrated Safety Assessments / Hazard y Analysisforplantprocesses. For equipment important to safety, programsfor testing, i calibration, and inspection ofall instrumentation and control systems (important to b safety) are required to be included in the hazard analyses to assure the equipment reliability.

Chapter 2.6 " Operating Procedures, " states, in part, that operations which affect licensed material shall be conducted in accordance with approved written procedures.

Suitable control measures are prescribed, andpertinent controlprocedures relative to nuclear criticality safety and radiological safety arefollo wed.

IntegratedSafety Analysisfor the Oxide Conversion Facility, DatedMarch 27,1996, defined the scale / load cellfor the uranium hexafluoride cold trap system in the vaporization room as equipment important to radiological safety and required that the scale / load cell be calibrated.

Operation Sheet Procedure No. 4101.00 " Oxide Inspection and Alarm Calibration / Testing, " prescribed the implementation ofthe programfor testing, calibration, and inspection ofall instrumentation and control systems important to safety, relative to the uranium hexafluoride cold trap system, to assure equipment reliability.

l RA99/074

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," Combustion Engineering, Inc. Docket 70-36 l April 22,' 1999 - License No. SNM-33 l l

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Contrary to the above, prior to March 3,1999, the licensee 's operatingproceduresfailed to prescribe control measuresfor the programs to test, calibrate and inspect j instrumentation and control systems important to safetyfor the uranium hexafluoride cold trap system, a.s identifled in the Integrated Safety Analysis. Specifically, Procedure No. 4101.00, " Oxide laspectix o ad Alarm Calibration / Testing, " failed to prescribe a i programfor the testing, calibration, and inspectionfor the scale / load cell ofthe uranium hexafluoride cold trap system, equipment defined as important to radiological safety in the Oxide Conversion Facility, IntegratedSafety Assessment.

Response

1. Reascn for the violation: .

In late 1995 through early 1996 CE conducted an Integrated Safety Assessment (ISA) of the oxide conversion area using what-if methodology. The what-if analysis recognized overfilling of the cold tiap with UF as6 a potential upset condition and listed several protections or safeguards to prevent the consequence. These included i weighing the cold trap on a calibrated load cell and limiting the number of cylinders cold trapped. Additionally, the administrative limit for the maximum weight allowed ,

in the cold trap was established with a significant safety margin. The management l measures used to assure the availability and reliability of the load cell included a load  !

cell test following the vaporization of the cold trap cylinder contents, typically after l seven 30B cylinder were cold trapped. Operation sheet O.S. 604.13 captured and was used to document the load cell test. In March of 1998 during a revision of O.S. 1 604.13 the load cell test was deleted from the procedure. The procedure typically used to capture the testing and calibration of safety systems, O.S. 4101, was not used for this system check. The safety significance of the load cell test deletion was not recognized by the engineer or during the management review of the procedure prior to its implementation.

2. Corrective steps that have been taken and the results achieved:

a. A Special Evaluation Traveler (SETi was implemented on March 5,1999 to assure that the system to prevent the overfilling of the U6 cold trap would perform its intended safety function. .

b. In March the conversion plant was shutdown for planned maintenance.

During this shutdown the cold trap cylinder was removed, cleaned and re-certified. The cleaning of the cylinder resulted in a re-zeroing of the load cell.

l c. Training was provided for all conversion plant operators on the safety function ,

of the cold trap load cell.

, d. An ISA team convened to review items important to safety for the cold trap system, the R2 reacter system and the R3 reactor system and ensure that measures to assure their availability end reliability were in place.

RA99/074

Combustion Engineering, Inc. Docket 70-36 April 22,1999 License No. SNM-33 t

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3. Corrective steps taken to avoid further violations:

a. Operation Sheet (OS 4101)" Oxide Inspection and Alarm Calibration" has l been revised and issued. This procedure provides for periodic functional test i of the system to prevent the overfilling of the cold trap. This procedure and l tha maintenance tracking system are the primary methods for implementing l the reliability assnrance program for safety related systems.

b. The maintenance tracking system has been updated to include monthly load cell checks for the cold trap system.

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4. Date when full compliance wili be achieved:

Full compliance has been achieved for this item.

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l RA99/074