ML20036B785
| ML20036B785 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 05/21/1993 |
| From: | Fici J GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| CON-NRC-93-013, CON-NRC-93-13 NUDOCS 9306020311 | |
| Download: ML20036B785 (15) | |
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Commacial Nuclear fuel Divistati Electric Corporation -
g,,,,, a Columbia South Carolina 29250 203: 778 2610 May 21, 1993 NRC-93-013 Director, Office of Enforcement U.S.
NUCLEAR REGULATORY COMMISSION ATTN:
Document Control Desk Washington, DC 20555 Gentlemen:
SUBJECT:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
1.
DOCKET NO. 70-1151, LICENSE SNM-1107, EA 93-044
- 2. NRC INSPECTION REPORT NOS:
70-1151/92-04 AND 70-1151/93-01 Pursuant to the provisions delineated in Section 2.201 of the NRC's
" Rules of Practice," Part 2, _ Title 10, Code of Federal Regulations, Westinghouse herein provides, in APPENDIX A, formal response to i
your letter of April 23,
- 1993, regarding inspections of the
-l Columbia Fuel Fabrication Facility conducted during the periods of August 17-28 and October 28-29,1992, and February-15-19, 1993.
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-Should you have any questions or require additional information, i
please telephone me at (803)-776-2610.
.t I hereby affirm that the statements made in this response are true and correct to the best of my knowledge and belief.
l Sincerely, WESTINGHOUSE ELECTRIC CORPORATION mes A.
Fici, Plant Manager i
Columbia Fuel Fabrication Facility Attachments:
APPENDIX A
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CC:
U.S.
NUCLEAR REGULATORY _ COMMISSION-REGIONAL ADMINISTRATOR'
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REGION II-N.W.
101 MARIETTA STREET, ATLANTA, GA. 30323 020023 3g 9306020311~ 930521-t )
PDR ADDCK 07001151 C-PDR u
APPENDIX A
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WESTINGIIOUSE RESPONSE TO TIIE ITEMS OF NONCOMPLIANCE IDENTIFIED IN TIIE NRC NOTICE OF VIOLATION i
NRC Inspection Report Nos. 70-1151/92-04 and 70-1151/93-01 document the results of the Operational Safety Assessment (OSA) conducted on August 17-28,1992,- and the followup inspections conducted on October _28-29,1992, and February 15-19,1993, at the l
Westinghouse Electric Corporation's Commercial Nuclear Fuel Division (CNFD) plant located in Columbia, South Carolina. The subject Notice of Violation cited one violation for which a civil penalty was assessed and seven violations for which a civil penalty was not assessed. Each violation is restated below, followed by the corresponding Westinghouse response.
I.
Violation Assessed A Civil Pennity i
Condition 9 of Special Nuclear Material (SNM) License Number 1107 (SNM-1107) requires that licensed material be used in accordance with the statements, representations, and conditions contained in Chapters 2,3, and 4 of the license application dated March 26,1984, and supplements thereto.
Chapter 2, Minimum Specifications and Capabilities, Section 2.3.1.10 of the license application, states that where practicable, reliance will be placed on equipment design in which dimensions are limited rather than on administrative controls for nuclear criticality safety. When non-favorable geometry is used, Westinghouse shall justify the proposed use' of non-favorable geometry and establish appropriate administrative controls. After justifying the need for non-favorable geometry equipment, the analysis must take into consideration identified contributing causes of criticality accidents,' demonstrate that such causes will be subject to administrative controls, and demonstrate compliance with the double contingency t
principle. Contributing causes to be addressed will include process upsets.
Contrary to the above:
1.
As of August 28,1992, the licensee did not meet the minimum specifications and capabilities specified in the license application. Specifically, the licensee did not justify the use of a non-favorable geometry sump, which was added to the diked or curbed area underneath uranyl nitrate storage tanks at some point in time during or l
after installation / construction of the tanks. No nuclear criticality safety analysis was performed to consider the contributing causes of criticality accidents, establish appropriate administrative controls, and demonstrate compliance with the double I
NRC92-04/NRc93-01 Page I of14 l
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contingency principle. As a consequence, appropriate administrative controls were not established.
2.
Attachment RA-301-1, " Floor Storage Plan," of Procedure RA-301, " Nuclear Criticality Control Criteria," Revision 6, dated January 10,1990, authorized the use of non-favorable geometry containers (55-gallon drums) without requiring justifications for the containers nor criticality analyses of the various applications of the containers which considered the contributing causes of process upsets.
I. l.
WESTINGIIOUSE'S RESPONSE TO PART I.1:
I.1.1 The violation is acknowledged as stated in the Notice of Violation.
I.l.2 The reason for the violation was:
Failure to establish and implement adequate controls to ensure that an appropriate nuclear criticality safety analysis was performed prior to installation of the sump.
I.1.3 Corrective actions taken and results achieved:
On February 14, 1993, the sump was reduced in size to a favorable geometry.
On February 26,1993, a total revision of Regulatory Affairs Procedure RA-104, " Change Authorizations," was approved and implemented. This procedure provides rigorous controls to ensure that appropriate nuclear criticality safety analyses are performed for all new installations, and for all modifications of existing installations, at the facility.
On March 12, 1993, a fault tree analysis was performed for the original sump.
This analysis confirmed that there had been double contingency protection in place for the subject system.
1.1.4 Corrective actions to avoid further violations:
Westinghouse believe.s that the corrective actions already taken will preclude recurrence of a violation of this type for future facility changes.
1.1.5 Westinghouse is currently in full compliance.
I.2 WESTINGIIOUSE'S RESPONSE TO PART I.2:
I.2.1 The violation is acknowledged as stated in the Notice of Violation.
NRC92 04WRC93-01 Page 2 of 14
i 1.2.2 The reason for the violation was:
Failure to establish and implement adequate controls to ensure a safety review prior to the introduction of non-favorable geometry containers in the chemical j
processing areas of the plant.
I.2.3 Corrective actions taken and results achieved:
Immediately following the August 17-28, 1992, Operational Safety Assessment, a comprehensive plan was initiated to minimize the use of non-f avorable geometry containers in chemical processing areas of the plant, and to I
provide appropriate nuclear criticality safety controls for those remaining.
This plan included: 1) forming a multi-disciplinary task team to review control and use of such containers, and to make recommendations to management; 2) conducting an inventory of the containers; 3) removing unnecessary containers; and,4) performing enhanced personnel training on the use and control of such contamers.
1 On January 21, 1993, a new Regulatory Affairs Procedure RA-306, " Movable Non-Favorable Geometry (NFG) Containers," was approved and implemented.
This procedure provides rigorous controls to ensure that a safety review is performed prior to the introduction of non-favorable geometry containers in the chemical processing areas of the plant.
Salient accomplishments of the control effort include a reduction in the number of moveable non-favorable geometry containers by 62%, with the remaining
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38% having been subjected to Nuclear Safety Analyses (NSA) and their use specificially authorized. The NSA's include all credible process upset and accident scenarios. In addition,41 operating procedures were revised and implemented, and three new procedures were created and implemented, to reflect the changes in handling NFG containers.
On March 12,1993, a fault tree analysis was performed for the original
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condition. This analysis confirmed that there had been double contingency protection in place for the subject systems -- both liquid and non-liquid.
s 1.2.4 Corrective actions to avoid further violations:
Westinghouse believes that the actions already taken will preclude further violations;
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however, a program of inspections has been initiated to assure that the actions taken 1
remain in place and are effective.
I.2.5 Westinghouse is currently in full compliance.
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NRC92-04/NRC93-01 Page 3 of 14
II.
Violations Not Assessed A Civil Penaltv II.A. Condition 9 of License SNM-1107 requires that licensed material be used in accordance with statements, representations, and conditions contained in Chapters 2, 3, and 4 of the license application dated March 26,1984, and supplements thereto, s
Chapter 3, Section 3.1.2.3 (11) of the license application requires the Radiation Protection Component to review and approve all site procedures specifically related to radiation protection, nuclear criticality safety, emergency planning, and SNM safeguards.
Contrary to the above, as of August 28,1992, the Radiation Protection Component failed to perform an adequate review of safety-related procedure RO-06-003,
" Ambient Environmental Air Monitoring for Radioactivity," Revision 5, dated July 9, 1992. The review was inadequate in that the procedure revision climinated the self-absorption factor in the calculations for alpha activity, which could result in lower than actual (non-conservative) radioactive measurements of routine environmental air samples.
II.A.1 The violation is acknowledged as stated in the Notice of Violation.
II.A.2 The reason for the violation was:
When Procedure RO-06-003 was revised to provide additional clarifications, the originator inadvertently omitted the self-absorption factor from the formula for calculating alpha activity on environmental air samples. In addition, this omission was a change which was not noted on the " Description of Changes" page which accompanied the revised document through the review and approval process. Because of an incomplete description of specific changes made in the revision, this omission was not detected during subsequent procedure review and approval.
II.A.3 Corrective actions taken and results achieved:
On August 20,1992, a corrected, reviewed, and approved Procedure RO,
003 was issued.
Regulatory Operations confirmed that no alpha activity calculations had been performed using the deficient procedure.
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NRC9MWNRC93-01 Pap 4 of 14 i
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II.A.4 Corrective actions to avoid further violations:
An initiative is being undertaken to move all Regulatory Affairs procedures to the computer-based PRONET system for document control. Because this document control system is administered by a separate group, who will, independently from the procedure originator, ensure that changes are clearly marked, this process will enable procedure revision reviews to be more ef5cient and to determine more accurately that all required changes have been made. Changes will also be marked on a separate " description of changes" page which will accompany the procedure through the revision review and approval process. Also to be included with the " description of changes" page is the reason for the changes. This initiative is scheduled for completion by December 31,1993.
II.A.5 Westinghouse is currently in full compliance.
II.B.
Chapter 2, Section 2.6 of the license application states that special nuclear material (SNM) proces:ing shall be conducted in accordance with approved written procedures or instructions.
Procedure TA-005, "S.O.I and P.I.F. Preparation and Distribution," Revision 3, dated February 27,1992, establishes the procedure for the preparation, approval, and distribution of Supplementary Operating Instructions (SOI) and SOI acknowledgement sheets. sol's establish or modify written approved procedures or instructions for SNM processing. Section 6 requires, in part, that sol's and SOI Acknowledgement Sheets be distributed and maintained in the respective areas. Section 7 requires, in part, that an expiration date be designated for each SOI, and the date of issuance is entered on each SOI and SOI Acknowledgement Sheet.
Form TAF-005-8, " Supplementary Operating Instructions Acknowledgement Sheet,"
Part C, " Supervisor's Instructions," Part 1, states that the supervisor is to complete the SOI acknowledgement process within Sve (5) working days which includes having all the operators read and sign the SOI with the supervisor signing last to indicate that all operators' names are on the sheet.
Contrary to the above, during the Operational Safety Assessment (OSA) conducted during the period from August 17-28, 1992, the licensee failed to control the preparation and distribution of sol's and SOI Acknowledgement Sheets, as evidenced by the following:
1.
sol's C-142, C-143, and C-144, contained in the ammonium diuranate (ADU) conversion area control room SOI log, had no date of issuance nor expiration.
NRC92-04?NRC9341 Page 5 of 14 l
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r-3 Several of the supervisor acknowledgement sheets were missing from the respective area logbook, despite the fact that the SOI had not expired.
2.
SOI Acknowledgement Sheets that did not receive a complete supervisor sign off within the five days included SOI I-087, SOI I-123, and SOI IDR-0100.
l 3.
SOI PEL-340 and the SOI logbook for the indirect dry route (IDR) area FA-2 could not be located. In addition, SOI PEL-358, which had an expiration date of August 21,1992, had not been removed by August 24,1992.
II.B.1 The violation is acknowledged as stated in the Notice of Violation.
II.B.2 The reasons for the violation were:
i Administrative Procedure TA-005, "S.O.l. And P.I.F. Preparation And Distribution," was unclear as to requirements; and, when left to individual interpretation, was not always executed as intended. In addition, shop floor supervisors were not consistent in administrative handling of such documents.
II.B.3 Corrective actions taken and results achieved:
Prior to conclusion of the subject inspection, the specific conditions cited in the Inspection Report were corrected.
Procedure TA-005 has been revised and implemented to eliminate the use of
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sol's as interim changes to procedures, and to improve the movement, storage, and retrievability of SOI Acknowledgement Sheets.
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II.B.4 Corrective actions to avoid further violations:
Process Engineering has initiated a conformance audit of all current sol's.
This audit will be completed on May 28,1993.
In March 1993, a process improvement team was appointed to review, and initiate improvements for, the controlled document system -- including sol's.
Scheduled improvements include:
The Electronic Procedure System (EPS) will be modified to provide for cross-references between procedures and sol's (by June 30,1993);.
SOI's will be added to the EPS (by December 31,1993).
i II.B.5 Westinghouse is currently in full compliance.
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NRC92-04/NRC93-01 Pope 6 of 14 I
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i II.C. Chapter 2, Section 2.3.1.1 of the license application sta:es that written procedures describing general nuclear criticality control requirements shall be maintained in the.
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Regulatory Affairs Procedures Manual by the Radiation Protection Component. This section also states that operations shall be conducted in accordance with these i
procedures to ensure compliance with NRC regulations and license conditions, j
i Procedure RA-104, " Regulatory Affairs Review Requests," Revision 6, dated March f
3,1992, requires, in part, that the person originating the requested change (s) complete Section 1 of form RA-104-1 by providing sufficient information including f
accurate red-lined drawings or sketches to adequately describe the change (s); that Regulatory Engineering review the proposed changes, determine applicable radiological and nuclear criticality safety requirements (which generally entails performing criticality safety analyses) and complete RA-104-1, Section 11, by signing the form. Once the form RA-104-1 is completed, the originator is to implement the I
required radiological and nuclear criticality safety controls established by Regulatory l
Engineering and have existing working drawings revised and/or new drawings prepared and submitted to Regulatory Engineering for final review and approval.
Procedure RA-104 then requires Regulatory Engineering to sign the appropriate j
drawings to ensure implementation of all required control criteria.
Contrary to this requirement, a review of selected Regulatory Affairs Review Requests for Change (facility change requests) by the OSA team during the period i
August 17-28, 1992, and during the inspection the week of February 15-19, 1993, indicated that some of the change requests did not contain all the information required i
by procedure, in that-1.
Concerning the nuclear safety analysis for RA-104-1-754:
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a.
the form did not indicate who performed the analysis or who did the second party review, i.e., there were no signatures, l
b.
there were no equipment drawings or literature of the equipment -
involved and no updated drawings, and
.t c.
the accident or upset conditions used in the nuclear criticality safety analysis were not identified.
I 2.
Concerning the nuclear safety analysis for RA-104-1-783:
j a.
the analysis did not indicate who performed the original analysis, i.e.,
there was no signature, and b.
there were no drawings of equipment or layout drawings accompanying the package.
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II.C.1 The violation is acknowledged as stated in the Notice of Violation.
II.C.2 The reason for the violation was:
Regulatory Affairs Procedure RA-104, " Regulatory Affairs Review Requests,"
was vague in prescribing format and content of safety evaluations, and did not.
I include details of the type disclosed by the inspection.
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II.C.3 Corrective actions taken and results achieved:
J Remedial Nuclear Safety Analyses were performed on the two Review Requests referenced in the Notice of Violation -- RA-104-1-754 and RA-104-1-783 - and the documentation was upgraded to address the findings cited.
On May 12,1993, the Criticality Safety Function Manager completed verification and formal approval of these upgedes.
i On February 26,1993, Procedure RA-104, " Regulatory Affairs Change Authorizations," was re-issued -- having been revised to specify documentation required to be submitted for safety reviews, and to detail the meaning of each required signature.
On February 26,1993, Procedure RA-300, " Nuclear Criticality Safety Evaluations," was re-issued -- having been revised to specify required format and content of a Nuclear Criticality Safety Evaluation.
On February 26,1993, Procedure RA-307, " Criticality Safety Assessments,"
was issued -- having been created to formally specify performance and responsibility considerations for the on-going (since June 1991), zero-based Criticality Safety Assessments being conducted for the Columbia Fuel Fabrication Facility.
r II.C.4 Corrective actions to avoid further violations:
Wesiinghouse believes that the corrective actions already taken will preclude further violations.
II.C.5 Westinghouse is currently in full compliance.
II.D. Chapter 2, Section 2.2.15.3 of the license application requires supervisor or chief operator verification of Uranium-235 concentration and free acid content in adjustment tanks prior to transfer.
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i NRC92-04'NRC934f1 Pye 8 of 14 b
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y Contrary to the above, during the OSA conducted during the period from August 17-28,1992, the OSA team determined that the licensee failed to perform an adequate veri 6 cation of U-235 concentration and free acid content in adjustment tanks prior to transfer. Speci6cally, the supervisor or chief operator did not independently verify that the operators received and recorded the correct sample results for the contents of tanks about to be transferred. Rather, the supervisors and chief operators relied on the operators obtaining the correct sample results via telephone.
II.D.1 The violation is acknowledged as stated in the Notice of Violation.
II.D.2 The reason for the violation was:
The use of unverified telephone transmittal of measurement results. This e
could provide inadequate controls to ensure against data being recorded for the wrong tank and/or incorrect data being recorded for a tank.
II.D.3 Corrective actions taken and results achieved:
e On October 13, 1992, an enhanced telephone veri 6 cation practice was implemented as an interim procedure. The new interim procedure required Uranium Recycle and Recovery Services (URRS) Area personnel to call the Health Physics Laboratory at least once each working day to verify all Uranium-235 concentration and free acid content results previously phoned-in on that day. This proved to be an effective interim practice until revised computer programs described below were implemented on March 29,1993.
A new Imcal Area Network system, the Solvent Extraction Tank Sampling e
System, has been developed and implemented as of March 29,1993, for computerized control of samples. URRS operators log samples into the -
system; the system assigns sample numbers; personnel in the Health Physics Laboratory analyze the camples and report results on the system; and URRS operators may then view sample results on the computers in their area.
Reports can be generated upon demand. To identify samples for which analysis is in progress, information is displayed without measurement results.
The system calculates concentration, tests to determine if the results meet acceptable limits, and indicates the tank release status to the operator.
An analogous system for verifying Analytical Chemistry Laboratory free acid content results is also provided for the computer workstations.
II.D.4 Corrective actions to avoid further violations:
4 Westinghouse believes that corrective actions already taken will preclude further violations.
NRC9MWNRe93-01 Page 9 of 14 t
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p II.D.5 Westinghouse is currently in full compliance.
II.E.
Chapter 2, Section 2.3.1.1 of the license application requires, in part, that operations shall be conducted in accordance with the written procedures maintained in the Regulatory Affairs Procedures Manual which describe general nuclear criticality control requirements.
Procedure RA-302, " Criticality Signs," Revision 5,' dated April 21,- 1989, requires, in part, that criticality signs identifying applicable criticality control parameters and instructions shall be conspicuously posted, maintained, and complied with, in areas or on equipment where SNM is present as required by Regulatory Engineering.
f Contrary to this procedure, during the OSA conducted during the period from August
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17-28, 1992, the licensee failed to follow this procedure in that:
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The Rod Reclamation Hood (Reject Rod Unloading Station) was in use, but no criticality sign was posted.
2.
The criticality sign located on the tray elevator in the Conversion Dissolver
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Area was not conspicuously posted in the front of the work station and was not l
available for reference by workers when required.
3.
The following posted criticality signs were not complied with:
i a.
Several 9.5 inch diameter polypacks containing 3.8 percent enriched uranium "hardscrap" were stored on a rack in the Rotary Blender Area which was limited, according to the posted sign, to 3.7 percent enriched."hardscrap,"
b.
The twelve inch spacing between SNM, required by postings, on storage racks and in an array of drums containing SNM standards was l
not maintained, and c.
A storage rack in the Rod Loading Area contained trays of fuel pellets-with a posting limiting the trays to a slab thickness of 4' inches.
l Several instances were noted where the 4 inch slab thickness was exceeded.
II.E.1 The violation is acknowledged as stated in the Notice of Violation.
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II.E.2 The reason for the violation was:
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NRC92-04/NRC93-01 Page 10 of 14 f
Specific conditions requiring such postings were not clearly dermed in Procedure RA-302, " Criticality Signs."
II.E.3 Corrective actions taken and results achieved:
On August 28,1992, criticality signs were posted on the cited Rod Reclamation Hood and the Tray Elevator.
On August 28,1992, all materials in the cited Rotary Blender Area, containing uranium enriched to greater than 3.7 weight-percent U-235, were placed in 8-inch diameter polypaks.
On August 28,1992, spacing of containers in the cited array of drums was corrected to 12-inches. The Storage Rack was provided with a passive engineered control to preclude spacing containers less than the required 12-inches.
On August 28,1992, a Criticality Safety Engineer measured the height of material in the cited pans (" trays") of fuel pellets in the Rod Loading Area and verified that, although the double-stacked pans plus lids plus gaps did exceed l
the posted 4-inch limit, the slab thickness of the material did not.
On April 1,1993, Procedure RA-302 was re-issued -- having been revised to enable criticality safety requirements to be provided in work procedures and/or on postings, as appropriate.
Pellet Pan Storage Areas have been limited to one pan high until a new safety analysis can be performed. This analysis will determine the criteria to be used for pellet pan storage in the future.
II.E.4 Corrective actions to avoid further violations:
A program is underway to evaluate all criticality safety postings in the facility; and, to revise them as necessary to clarify their intent and purpose. This activity is scheduled for completion by June 30,1993.
A Floor Storage Spacing Team has been appointed to address strict minimization of routine floor storage of containers of SNM at the facility.
This activity is scheduled for completion by June 30,1993.
The safety analysis referenced above to determine the criteria to be used for pellet pan storage is scheduled for completion by June 30,1993.
II.E.5 Westinghouse is currently in full compliance.
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II.F.
Chapter 2, Section 2.3.1.1 of the licene appliwion requires, in part, that operations shall be conducted in accordance with the written procedures maintained in the Regulatory Affairs Procedures Manual which describe general nuclear criticality control requirements.
Procedure RA-301, " Nuclear Criticality Control Criteria," Revision 6, dated January 10,1990, requires, in part, that a minimum of one foot.9 acing shall be maintained between counters, racks, carts, and equipment containirg SNM under moderation control, and that greater separation distances may be nquired in areas containing interacting SNM which have " surface density" areas (3 ellow exclusion areas) assigned to them.
Procedure RA-302, " Criticality Signs," Revision 5, (.ated April 21, 1989, requires, in part, that criticality signs identifying applicable criticality control parameters and instructions shall be conspicuously posted on equipment or in areas where SNM is i
present as required by Regulatory Engmeenng.
Contrary to the above, during the OSA conducted during the period from August 17-1 28,1992, a work table, used for the repair and cleaning of pumps and other pieces of
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equipment and located adjacent to a vertical safe geometry tank in the ADU Conversion Area, was situated over a portion of the yellow exclusion area for this tank and no restrictions or guidance was given for placement of SNM on the portion of the table that was above the exclusion area nor upon placing SNM on the shelf of the table located about six inches above the exclusion area.
II.F.1 The violation is acknowledged as stated in the Notice of Violation.
II.F.2 The reason for the violation was:
Overdependence on administrative controls regarding establishment of exclusion areas for criticality safety control.
II.F.3 Corrective actions taken and results achieved:
The cited work table has been provided with a passive engineered control to preclude intrusion of pumps and other pieces of equipment into the tank's exclusion area.
II.F.4 Corrective actions to avoid further violations:
All yellow floor markings in the Chemical Manufacturing Area are being eliminated, except for those specifically defining criticality safety exclusion areas. Then, any work surfaces within the envelope of such areas will either NRC92 04/NRC93-01 Page 12 of 14
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be removed, or provided with passive engineered controls to preclude intrusion into the exclusion areas.
II.F.5 Westinghouse is currently in full compliance.
II.G. Chapter 2, Section 2.3.1.1 of the license application requires, in part, that operations shall be conducted in accordance with the written procedures maintained in the Regulatory Affairs Procedures Manual which describe general nuclear criticality control requirements.
RA-104, " Regulatory Affairs Review Requests," Revision 6, dated March 3,1992, a procedure which describes general nuclear criticality safety requirements for proposed additions or modifications, requires, in part, that Regulatory Engineering complete Section II of RA-104-1.
Review Request R.A-104-1-872, "IDR Vaporization Process, Liquid Level Probe / Gravity Drain,"Section II, required, in part, that the test engineer document the initial interlock verification using test data sheets in Procedure RA-109, " Safety t
Significant Interlock Test Documentation."
Contrary to the above, on September 2,1992, Review Request RA-104-1-782 was signed off as complete although, as of February 19,1993, procedure RA-109, " Safety Significant Interlock Test Documentation," had not been approved and issued.
II.G.1 The violation is acknowledged as stated in the Notice of Violation.
II.G.2 The reason for the violation was:
Regulatory Affairs procedure RA-104, " Regulatory Affairs Review Requests,"
referenced procedure RA-108, " Safety Significant Interlocks," which in turn referenced subject procedure RA-109. A manual procedure control system, in use at the time of the violation, permitted issuance of RA-108 without verification that all of the referenced documents (such as RA-109) were concurrently issued.
II.G.3 Corrective actions taken and results achieved:
Form RA-109-1 (from RA-109) was verbally authorized for use on a temporary basis, to provide a consistent methodology for documenting the operability of safety-significant interlocks -- thus enabling necessary documentation to be completed in support of the regulatory review process.
This verbal approval was formally documented on May 14, 1993.
NRC92-04/NRC93-01 Page 13 or 14
f N.GA Corrective actions to avoid further violations:
Forms previously contained in RA-109 are being renamed and rr 'ed for approval as forms to be contained in RA-108. Procedure RA-108 is being revised to delete the reference to RA-109. This activity is scheduled for completion by June 30,1993.
All Regulatory Affairs (RA) procedures, and their associated forms and sketches, are being entered into the PRONET document control system.
Among the functions of this network-based system is a module that will verify that all referenced documents in fact reside in the approved document database, before issuance of new or revised procedures.
II.G.5 Westinghouse is currently in full compliance.
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