ML19208B366
| ML19208B366 | |
| Person / Time | |
|---|---|
| Site: | 07000135 |
| Issue date: | 06/22/1979 |
| From: | Austin M BABCOCK & WILCOX CO. |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19208B364 | List: |
| References | |
| NUDOCS 7909200092 | |
| Download: ML19208B366 (5) | |
Text
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Babcock &Wilcox sociea, ue,iai, ossion 609 North Warren Avenue, Apollo, Pa.15613 Telephone: (412) 842-o111 June 22, 1979 Mr. Boyce H. Grier, Director, Region I Office of Inspection and Enforcement United States Nuclear Regulatory Comnission 631 Park Avenue King of Prussia, PA.
19406 Docket 70-135:
SNM-145 Docket 70-364:
References:
(1) Docket No.70-135 Inspection Report No. 78-25 Dated 1/26/79 (2) Letter of 2/13/79 from Michael A. Austin to Boyce H. Grier, Director, Region I, Office of Inspection and Enforcement, U.S.N.R.C., containing specific responses to disclosed items of Ref.1 (3) Letter of 4/17/79 from Boyce H. Grier to Michael A. Austin, responding to Ref. 2
Dear Mr. Grier:
Attached are the Nuclear Materials and Manufacturing Division, Pennsylvania Operations (PA. Ops) specific responses and corrective actions relating to disclosed items 1, 2 and 6 resulting from your Mr. Kinney's inspection of December 5-8, 1978.
This letter also refers to references (2) and (3) listed above, and to the meeting held on June 6, 1979, attended by: Messrs. J. M. Allan, G. H. Smith, H. W. Crocker, W. L. Kushner, and W. M. Kinney of Region I of the NRC Inspection and Enforcement Branch; Messrs. W. Burkhardt and W. Nixon of the NRC Fuel Pro-cessing and Fabrication Branch; Mr. W. T. Crow of the NRC Ucanium Fuel Fabrica-tion Section; and, Messrs. W. F. Heer, E. M. Benson, and M. A. Austin of B&W, NM&MD PA. Operations.
Below is a sunmary of the specific responses and corrective actions which have been implemented to resolve and prevent recurrence of the disclosed items.
Relative to Appendix A, Item 1, personnel have been permanently assigned to the subject positions and the appropriate evaluations and approvals have been per-formed.
In addition, an amendment request was submitted on June 21, 1979 to NRC Licensing to further clarify the requirements for such organizational evaluations.
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Babcock & Wilcox Mr. Boyce H. Grier June 22, 1979 Relative to Appendix A, Item 2, contaminated combustible solid materials in operating low enriched uranium production areas are stored in covered metal containers, or sprinklered areas, or areas specifically designated by Health &
Safety.
Contaminated combustible solid materials in the high enriched uranium production areas are stored on transfer carts or in covered 55-gallon drums in areas approved by Health & Safety.
In addition, the license specifications and demonstrations relative to this item have been revised, and amendments have been submitted for approval to NRC Licensing on June 21, 1979, for the purpose of expanding and clarifying these fire prevention practices.
Relative to Appendix A, Item 6, the functions of the Secretary of the Safety Advisory Board (SAB) have been maintained and are currently being performed by the Manager of Compliance.
In addition, a licensing amendment has been submitted to NRC for the ouroose of deleting the assignment of the secretarial duties to the Manager of Compliance, while still ensuring that the secretarial functions are maintained.
If you have any questions concerning this letter, please contact me.
Sincerely, V
Michael A. Austin Manager, Technical Control MAA/pvm Att.
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i SPECIFIC NUCLEAR MATERIALS AND MANUFACTURING DIVISION (PENNSYLVANIA OPERATIONS)
RESPONSE TO NUCLEAR REGULATORY COMMISSION INSPECTION REGION I 0F DECEMBER 5-8,1978.
REFERENCE INSPECTION REPORT NO. 70-135/78-25 INFRACTION:
APPENDIX A (ITEM 1)
License Condition 9 of License No. SNM-145 authorizes use of special nuclear materials in accordance with statements, representations and conditions con-tained in Section I of the licensee's application.
Specification 4.0, Organization, of Section I states, in part, that, "The professional qualifica-tions statements detailed in this specification are minimum (basic) academic and experience requirements for an incumbent without any unique qualifications for the position described.
In special cases, unique qualifications such as extended service in the facilities involved, superior academic attainment, access to a former incumbent to the position and/or access to an individual (s) with the minimum academic and experience requirements, etc., may be substituted for the base requirements.
In such special cases, an individual may hold the position, provided the evaluation and approvals required by section 4.6.1 of this specification are met."
a.
Specification 4.2.3(c), Professional Qualifications for the Manaaer of Comoliance, requires that the incumoent have a Baccalaureate Degree in Science or Engineering and five (5) years of nuclear industry experience in the areas of health and safety, nuclear materials control, and/or physical security, including two (2) years of supervisory experience.
b.
Specification 4.2.4(c), Professional Qualifications for Licensing and Nuclear Safety Specialist, for the Licensing function requires, in part, that the incumbent have five (5) years experience in obtaining licenses and permits from Regulatory Agencies.
Contrary to the above, individuals have been named to positions and duties who do not have the qualifications specified for the position, and the evaluations and approvals required in Section 4.6.1 of the specification in such instances have not been done.
Specifically:
a.
On October 17, 1978, for an indefinite period an individual was named Acting Manager of Compliance who does not have either a college degree or experience in the health physics aspects of health and safety, nuclear materials control, or physical security.
b.
Since August 25, 1978, when the position of Licensing and Nuclear Specialist became vacant, the Licensing function of the position of Licensing and Nucia Safety Specialist has been performed by the Manager of Technical Control.
On October 15, 1978, an individual was named Manager of Technical Control who has no exoerience in obtaining licenses and oermits from Regulatory Agencies.
SPECIFIC RESPONSE:
On February 2, 1979, Mr. D. G. Ortz was permanently assigned to the position of Manager of Compliance, and Mr. T. V. Congedo was permanently assigned to t i 7 /;
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' the position of Licensing and Nuclear Safety Specialist. The evaluations and approvals required by section 4.6.1 of Specification I-4 were performed -
for these assignments.
In addition, an amendment to License SNM-145 has been requested in Specifications I-4 and I-5 to clarify the procedures for im-plementing replacement of personnel in key Pennsylvania Operations management and supervisory positions described in Specification I-4.
These corrective actions are expected to prevent recurrence of this dis-closed item.
INFRACTION APPENDIX A (ITEM 2)
License Condition 9 of License No. SNM-145 authorizes use of special nuclear material in accordance with statements, representations and conditions con-tained in Section I of the licensee's application. Technical Specifications 5.1.4 of Section I, Industrial Safety Within the Facility, Part A, Fire Safety, states, in part, "Out-of-confinement, contaminated, combustible solid wastes (in process areas) shall be stored in covered metal containers."
Contrary to the above, on December 6,1978, out-of-confinement, contaminated, combustible solid wastes stored in cardboard boxes in the CF-1 area, the CRP-1 area, the CP-1 area, the CP-1 annex, the ISAS counting room, and HEU Storage Area I were not stored in covereci metal containers.
SPECIFIC RESPONSE:
In the low enriched uranium operation areas, to localize contaminated com-bustible solid materials, they are discarded into cardboard packages which rest within metal containers.
Once filled, the cardboard package is removed from the metal container and transported to the counting area, where it is analyzed for uranium content.
Contaminated combustible solid material is considered waste if it has no designated remaining value as a resource or product, as determined by this analysis.
Packages determined to contain waste are stored in sprinklered areas, or areas specifically designated by Health and Safety.
During decommissioning of the high enriched uranium operation areas, contaminated combustible solid materials are either placed in cylindrical cardboard containers of 7-inch diameter and 10-inch length, or else wrapped in sealed plastic bags, prior to being transported to a counting area for analysis of uranium content.
Packages determined to con-tain waste are stored either on transfer carts or in covered 55-gallon drums in zones specified by Nuclear Safety and approved by Health and Safety.
The above described practices have been reviewed and approved by the facility fire insurer, as documented in a letter of 6/21/79 from Factory Mutual In-surers to B&W, NM&MD, PA. Operations.
In addtion, changes reflecting these practices were made to the appropriate pages of the Specifications and Demonstrations of SNM-145, and submitted to NRC Licensing on 6/21/79.
These corrective actions are expected to prevent recurrence of this dis-closed item.
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y.
, DEFICIENCY:
APPENDIX A (ITEM 6)
License Condition 9 of License No. SNM-145 authorizes use of special nuclear naterials in accordance with statements, representations and conditions con-tained in Section I of the licensee's application.
Specification 4.2.3, Manager of Compliance, and Specification 4.6.1, Pennsylvania Operations Safety Adviscry Board (SAB), of Section I, state, in part, that the Manager of Compliance shall serve as Secretary to the Safety Advisory Board.
Contrary to the above, since October 17, 1978, the Acting Manager of Com-pliance has not served as Secretary to the Safety Advisory Board.
SPECIFIC RESPONSE:
From October 17, 1978 to February 2,1979, the secretarial functions of the SAB were maintained.
Since the permanent assignment of Mr. D. G. Ortz to Manager of Compliance, Mr. Ortz has served as Secretary to the SAB and continues to function in this capacity.
In addition, PA. Operations has applied for amendments to Specification I.B.4.2.3. A, page I.B.4.10, Specifica-tion 4.6.1. A, page I.B.4.25, and Specification 4.6.1.C, page I.B.4.26, which will delete the reference to the duties of the Manager of Compliance as Secretary of the SAB, but will ensure that documentation of SAB meeting minutes is maintained.
These corrective actions are expected to prevent recurrence of this disclosed item.
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