ML20239A522

Ack Receipt of 980813 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/98-03 on 980717

ML20239A522
Person / Time
Site:	Framatome ANP Richland
Issue date:	09/02/1998
From:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Femreite B SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
References
70-1257-98-03, 70-1257-98-3, NUDOCS 9809090305
Download: ML20239A522 (2)

Text

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k' 8 844 UNITED STATES g 'g NUCLEAR REGULATORY COMMISSION

{ $ REGloN IV f 611 RYAN PLAZA DRIVE, SulTE 400

/ AR LINGTON, TEXAS 760114064 j September 2, 1998 B. N. Femreite, Vice President i

Manufacturing Siemens Power Corporation 2101 Horn Rapids Road P.O. Box 130 l Richland,. Washington 99352-0130 7/

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SUBJECT:

RESPONSE TO NRC INSPECTION REPORT 70-1257/98-03

Dear Mr. Femreite:

Thank you for your letter of August 13,1998, in response to our letter and Notice of )

i Violation dated July 17,1998. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We 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,

(

Ross A. Scarano, Director Division of Nuclear Materials Safety Docket: 70-1257 License: SNM-1227 '

cc w/ copy of ltr dtd 8/13/98:

Siemens Power Corporation ATTN: L. J. Maas, Manager Regulatory Compliance 2101 Horn Rapids Road P.O. Box 130 Richland, Washington 99352-0130 Washington Radiation Control Program Director 9809090305 980902 PDR ADOCK 07001257 C PDR L -- _-

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SIEMENS -- - -

rP d 1ILe G 0 tLL*h t August 13,1998

)J WJB1T.r' h,h JBE:98:083 ~- 'i l ggg;gy n U.S. Nuclear Regulatory Commission Ann: Document Connot Desk

- Washington, DC 20555

- Gentlemen:

Subject:

Reply to a Notice of Violation (License No. SNM-1227; Docket No. 70-1257) f Ref.: Letter, R.A. Scarano to B.N. Femreite, "NRC Inspection Report 70-1257/98-03 and Notice of Violation" dated July 17,1998 .

Attached is Siemens Power Corporation's (SPC's) reply to the notice of violation accompanying the referenced letter.

If you have any questions regarding these actions or require more information, please contact me at 509-375-8663.

Very truly yours,

)

- n gg % b3 James B. Edgar Staff Engineer, Licensing

/pg Enclosure -

cc: U.S. Nuclear Regulatory Commission Regional Administrator, Region IV Arlington, TX

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Siemens Power Corporation QS-19 $ 9 i

Nuclear Division Headquarters P.o. Box 130 Tel: (509) 375-8100 Engineering & Manufacturing 2101 Horn Rapids Road Fax: (509) 375 8402 Richtand, WA 99352-0130

.t Attachment 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 1 of the

. licensee's application dated October 28,1996, and supplements and revisions thereto.

Part I, Section 2.5, " Operating Procedures, Standards and Guides," of the license

. application specifies, in past, that the, licensee is committed to controlling activities in ,

. accordance with Standard Operating Procedures, Company Standards, and Policy Guides.

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In addition, the procedures and standards shall be prepared, reviewed, revised, approved, '

' and implemented in accordance with the Approval and Responsibility Matrix.

Standard Operating Procedure P66,427, " Fuel Rod and Cladding Rework," Revision 13, Section 5.6.1, specifies, in part, that operators first cut [ fuel] cladding to fit into a 55- ,

. gallon barrel, then verify [fuell cladding is' empty, and finally place the [ fuel] cladding into j the barrel.

Standard Operating Procedure P66,803, " Class A Waste Generator Requirements,"

Revision 16, Section 6.1, specifies, in part, that only the waste that is designated for each ,

respective waste container shall be discarded into that container. -

Contrary to the above, operational safety activities were not implemented in accordance with documented standard operating procedures appropriate to the circumstances in the s following examples:

a) Prior to February 1998, operations staff failed to first cut fuel cladding to fit into a 55-

gallon barrel and then verify that the cladding was empty prior to placing it into a barrel.

Instead, operations staff performed fuel cladding rework by verifying the fuel cladding was empty prior to cutting the fuel cladding to fit into a 55-gallon barrel. Fuel cladding was not verified to be empty prior to being placed into a barrel as evidenced by a shipment of empty fuel cladding to a commercial facility for decontamination in August

.1997, which contained at least two fuel pellets in the cladding, b) Prior to April 15,1998, operations staff did not discard waste containing nitric acid into a respective waste container designated for that type of waste. Specifically, an't analysis of the contents of the waste collection basket involved in the fire on April 15, 1998, documented the presence of nitric acid, a hazardous waste. The waste collection basket involved in the fire was designated only for disposal of combustible

_.and non-combustible wastes. Hazardous wastes, such as nitric acid, were not designated for disposal in the waste container.

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Reason for Violation '

L Fy example "a" of NRC's Notice of Violation (NOV):

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. There was no single procedure directly applicable to the work being performed, i.e.

downloading of fuel rods with the intent of sending the empty cladding for offsite -

recycle, packaged in 55 gallon drums. Instead, workers were required to select and utilize pertinent sections of two pre-existing and indirectly applicable SOP's written to -

cover downloading of rods in the UO and NAF rod loading areas - P66,421, " Fuel Rod Downloading" and P66,427, " Fuel Rod and Cladding Rework."

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• The requirement to " cut" then '"look", which originally applied to cutting the end caps Y off full length cladding, emptying out the pellets and then looking to see if the cladding .i was empty, did not get 'effectively translated into cutting the cladding into shorter lengths and then looking through it for pellett prior to packaging the cladding for

, - shipment. Although in SOP P66,427 the statement in paragraph 5.6.1 refers to. cutting L cladding to fit into 55 gallon drums, the procedure itself is intended to describe the

! steps for minor rework that does not change the form, fit or function of the fuel rods

~and does not involve downloading pellets. SOP P66,427 refers to SOP P66,421 to describe the actions to be taken to remove pellets.

it was, therefore, not a case of ignoring SOP requirements, but rather one of inadequate procedural guidance and the reliance on two indirectly applicable SOP's, r}either of

. which by itself described all the actions to be taken.

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For example "b" of the NOV:

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. - SOP's were not adequately specific to describe required waste handling operations and

. also lacked information on the consequences of mixing incompatible wastes.  ;

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. . Training on SOP's was less than adequate.  ;

• Many operators were unfamiliar with the document that describes the satellite waste collection program.

l .: ... The current program for disseminating SOP's is an on-line system which some , 1 l'

operators, due to lack of training, do not find easy to use. '

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' Corrective Steos Taken l

. For example "a" in the NOV, the operators have been retrained on the pertinent sections of l

'the two existing SOP's with particular emphasis on examining the cladding pieces for i

- pellets after cutting them.

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For' example "b" in the NOV, the following actions have been taken.  ;

• ' Applicable SOP's have been revised to include information on the consequences.of mixing incompatible wastes and to more fully describe pertinent operations.

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i Operators have been given additional training to facilitate locating applicable SOP's on the on-line system and applicable SOP's have been relocated on the on-line system to make them easier to access.

Operators have been given additional training on the SOP covering the station used to neutralize acid soaked rags and mop heads in order to decrease the volume of

. hazardous waste generated. Additional training has also been provided on the SOP on waste generation, with emphasis on the segregation of'the waste streams and incompatible material hazards.

A program of quarterly operator training on waste segregation has been scheduled. i

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The document describing the satellite waste collection program has been added to the on-line system.

Corrective Stoos That Will Be Taken To Avoid Future Violations For example "a" in the NOV, the two controlling SOP's for reworking and downloading in the rod loading areas will be rewritten to clearly define that one applies to reworking rods for reuse and the other applies to downloading rods whose cladding is to be scrapped. The latter SOP will more clearly describe the steps required for packaging scrap cladding for burial or for decontamination and recycle.

For example "b" in the' NOV, in addition to the actions already taken, an "in the field" operator training class will be conducted to refamiliarize personnel with each of SPC's waste streams and how they are to be handled. In addition, UO2 Support Operations will initiate monthly compliance inspections of pertinent waste collection points.

Date When Full Compliance Will Be Achieved ' -

~ SPC is currently in full procedural compliance with reg,ard to the two operations associated with the NOV examples. Regarding the corrective stehs to be taken to avoid future violations, that described under example "a" is scheduled to be completed by 9/30/98 and those under example "b", by 8/31/98.

Other SPC Actions a

.While SPC has taken and will take the steps described above to strengthen proced ral guidance and compliance, SPC is also investigating various cladding downloading and l inspection techniques that will rely less on human actions to avoid unintentional shipments of stray pellets with supposedly empty cladding. Furthermore, SPC will soon start up a new work area specifically designed for and dedicated to rod downloading operations, complete with an SOP that fully addresses all pertinent process steps. In regards to the waste area fire that involved the acid-contaminated materials, SPC is proceeding with the design and installation of a closed waste container that would mitigate the effects of fires, irrespective of the container contents.