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SECOOFAN MAELSa an ~rnas arowcs cowanr

RE: 9474-N I|.

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June 16, 1994 '

|Certified MailReturn Receipt Requested '

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!U.S. NUCLEAR REGULATORY COMMISSION

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ATTN: Document Control DeskWashington, D.C. 20555

RE: License SUB-1010; Docket No. 40-8027 :

Reply to Notice of ViolationNRC Inspection Report No. 40-8027/94-01

Gentlemen:

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Please find enclosed Sequoyah Fuels Corporation's response to'

Notice of Violation B as required in the subject inspection report.

With respect to Violation A, the inspection report indicated that !

no response was required since SFC had, subsequent to theinspection, submitted a license amendment request on organizationalchanges. Accordingly, SFC has not prepared a formal response tothis NOV. However, SFC wishes to state for the record that thefunctional responsibilities and duties of the management positionsdescribed in SFC's license have continued to be fulfilled byqualified, experienced personnel, despite changes in title orlines of reporting. SFC understands the importance of theseresponsibilities and duties and will continue to be diligent incarrying them out. *

If there are any questions, please contact me at 918/489-3386.

Sincerely,

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.iA.

Craig . H r1 nDirec r, Reg tory Affairs

xc: L. J. Callan, Region IV

' .Nf094062902'59 940616PDR ADDCK 04008027C PDR ;

HIGHWAY 10 & 140 PO BOX 610, OORE OKL AHf;MA 74435 (9181489 6511 FAX- (918) 489 2291

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ISequoyah Fuels Corporation's,

Reply to a Notice of Violation

Inspection Report No. 40-8027/94-01

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Statement of the Violation: !

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B. License Condition 9 authorizes use of licensed material in |accordance with the statements, representations, and i

conditions contained in Chapters 1-8 of the license renewal iapplication dated August 23, 1985, as supplemented. Chapter |

2, Section 2. 2, of the license renewal application states, in '

part, that the Manager, Licensing and Health Physics, shall beresponsible for developing and implementing programs,procedures, and guidance in the functional areas of healthphysics.

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1. Section 4.5.3 of Procedure HS-301, " Radiation,Contamination, and Release Surveys," requires, in part,that equipment that has been used in restricted areasmust be monitored before release to the unrestrictedareas and the limits and criteria contained in Attachment7 of the procedure shall apply to these surveys.Attachment 7 specifies that equipment and vehiclesreleased for unrestricted use must be decontaminated whencontamination levels exceed 5,000 disintegrations perminute (dpm) average and 15,000 dpm maximum for alpha andbeta-gamma contamination.

Contrary to the above, on February 23 and March 2, 1994contamination was identified in levels exceeding thelimits noted above on a nitrogen tank which was releasedfrom the facility for unrestricted use in October 1993.Specifically, fixed beta contamination ranging from25,000 to 30,000 dpm per 100 square centimeters wasidentified on the legs of the tank and on a beam weldedto the tank bottom.

SFC Response:

(1) Reason for the Violation

The release survey performed on the nitrogen tank in Octoberdid not adequately consider the potential contaminationcharacteristics of the nitrogen tank.

(2) Corrective Steos That Have Been Taken And The Results Achieved

The subject contamination has been removed.

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Health and Safety personnel have been instructed verbally j,

regarding the intent and application of release surveys and I

associated radiation level limits. The instruction was |provided in the context of preventing occurrences such as the jsubject violation. SFC Procedure HS-301, " Radiation,

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Contamination, and Release Surveys," has been revised to |

include similar instructions.

All SFC personnel allowed unescorted access to the restricted ,

areas were provided written direction regarding release of Iequipment and materials for unrestricted use. The direction I

was provided in the context of preventing occurrences such as |the subject violation. The written direction was published as ;

Management Communication Notice 94-01 " Release of Materials !and Equipment for Unrestricted Use," dated February 14, 1994.

(3) Corrective Steos That Will Be Taken To Avoid FurtherViolations

The corrective steps described above are considered sufficientto avoid further violations of this type.

(4) The Date When Full Compliance Will Be Achieved

SFC is in full compliance with the requirements of Section4.5.3 of procedure HS-301, " Radiation, Contamination, and jRelease Surveys," and has been in compliance since the ;

issuance of Management Communication Notice 94-01 on February14, 1994.

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Statement of the Violation:

2. Section H of Procedure HS-301, " Radiation, Contamination,and Release Surveys," specifies, in part, that visiblecontamination shall be cleaned from normally inaccessibleexterior surfaces when observed during routine visualcontamination inspections as prescribed elsewhere in theprocedure. Further, any smear (removable) survey resultgreater than 2,000 disintegrations per minute (dpm)/100centimeters square for alpha or greater than 20,000dpm/100 square centimeters for beta / gamma in controlledaccess areas must be reported to the area supervisor whoshall take action to clear these areas within 72 hours ofbeing notified of the results.

Contrary to the above, on December 1, 1993, removablebeta contamination of =25,300 dpm/100 square centimeterswas identified on insulation covering a uranyl nitratehexahydrate (UNH) surge tank, which is located in acontrolled access area, and was not cleared untilFebruary 14, 1994, a period in excess of 72 hours. In ,

addition, on February 24, removable alpha contamination 1

of 26,200 to 7,200 dpm/100 square centimeters andremovable beta contamination of =26,900 to 36,900 dpm/100square centimeters was identified on a leg of the UNHsurge tank and was not cleared until March 1, 1994, a '

period in excess of 72 hours.

SFC Response:

(1) Reason for the Violation;

Appropriate consideration was not given to the condition ofthe UNH surge tank, with respect to contamination control.

(2) Corrective Steos That Have Been Taken And the Results Achieved

Management has emphasized, among themselves and to staffpersonnel, the importance of timely resolution of conditionsidentified as requiring control to prevent spread ofcontamination. The emphasis has been provided in the form ofverbal direction and instruction at daily planning meetings,weekly staff meetings, and periodic departmental meetings.

Certain corrective action projects that may be broadlyclassified as stabilization of existing conditions ormaterials have been reconsidered with respect to schedule andresource application. In that regard, to a degree someprojects have been reprioritized to accomplish their goal ina more progressive fashion; i.e. they have begun or will beginsooner than originally planned and are scheduled to be

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. " completed sooner than originally planned. This action is d

expected to reduce the number of circumstances requiringattention to contamination control now and in the future.

(3) Corrective Steos That Will Be Taken To Avoid FurtherViolations

The corrective steps described above are considered sufficient |to avoid further violations of this type.

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(4) Date When Full Comoliance Will Be Achieved

SFC is in full compliance with the requirements of Section4.3.2 H of Proceduta HS-301, " Radiation, Contamination, andRelease Surveys".

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