ML20042F510
| ML20042F510 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 05/04/1990 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9005090008 | |
| Download: ML20042F510 (6) | |
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GE Nucle:r Energy
< u Ikche fue & Cominwn:s wxtectwing G:neral Electnc Cofn;m.s l'O Box 780, ui!!mngton. NC 26#2 919 675 4000 May 4, 1990.
U.S. Nuclear. Regulatory Commission
- Document Control Desk Washington, D.C.-
20555 c
Subject:
REPLY TO NOTICE OF VIOLATION 1
References:
(1) NRC License'SNM-1097, Docket 70-1113
'(2) NRC: Inspection Report 70-1113/90-03 dtd 3/27/90 GE. Nuclear Energy is responding to the Notice of Violation resulting.from the inspection conducted at our licensed fuel fabrication plant by Messrs. G.
B.
Kuzo and C. H. Bassett of youri Loffice February 5-9, 1990.
Due to conflicts in preparing for the-April 26th NRC-GE management meeting at Region II, an extension until'May 4,'1990, for this reply was granted on" April 25,-1990, by Mr. G.-Troup of your office.
Our reply to.the items of apparent noncompliance with NRC
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t requirements 1s given in'the attachment to this letter.
The-inspection' report comments.and suggestions are' helpful to us-in'our: constant efforts to improve our programs, ensure the continuedzhealth and safety of1 plant personnel, and ensure our i
compliance with NRC regulations.and license conditions.
-Your inspection report referred to above does not contain-
.information which we believe to be proprietary.
. Sincerely, GE NUCLEAR ENERGY b
=AM T.
Preston Winslow, Manager Licensing & Nuclear Materials Management-cc: -Stewart D. Ebneter, Region II
.TPW-90-068 l
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f U.S. Nuclear Regulatory Commission Document Control Desk May~4, 1990-Page'1 of 5 i
ATTACEMENT'1 k
The information_given below refers to items in Enclosure 1,
" Notice of. Violation", from NRC Inspection Report 70-1113/90-03
~ dated March 27, 1990.
"A.
License Condition Number
(; o.) 9 of SNM-License N
1097-requires that licensed material be used in i
accordance with statements, representations, and conditions of Part I of the License Application dated October 23, 1987.
Part 1, Section 2.7.1 of the licensee's Application for License No. SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures.
Process Requirements and. Operator Document (PROD) j No.
80.12, Rev. 9, dated November 18, 1989, requires in the FMO Method Sheet, Step _15,.that the i
can storage pad'be kept locked wheneve:
unattended.
Contrary _to the above, the licensee failed to follow procedures-for maintaining.can storage pads locked in-that, on February 7, 1990, from approximately 5:00 p.m.
until 6:15 p.m.,
Can Storage Pad 2 was q
noted to be unlocked with rua personnel in attendance.
i This is a Severity Level IV violation (Supplement IV)."
i GE' RESPONSE:
GE concurs that the gate to the-can storage pad was not locked nor attended as observed on February 7, 1990, by the NRC inspector.
For the outside storage pads, the Nuclear Safety Release /
Requirements (NSR/R) provides the key nuclear. safety control l
requirements for the manufacturing operators.
At the time of the NRC~ inspection, the inspector was advised that locking of the pads L
was not a radiation safety requirement according to the NSR/R j
section of PROD 80.12.
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U.S. Nuclear Regulatory Commission l
Document Control Desk-May.4, 1990 Page=2 of 5 l
Following receipt of the inspection report, we reviewed the applicable radioactive material storage and safeguard regulatory requirements.
For the can storage pads. located within the fenced Controlled Access Area (CAA), no additional security controls.are required such as locking of the gates.
Locking of the internal pad gates is solely:a preferred operational practice, not a regulated functional activity.
The practice was documented in the Method Sheet portion of PROD 80.12 for which conformance is desired and expected; however, GE does not consider a singular observed missed step to be in violation of the objectives set forth in the procedure, or to have any regulatory or safety significance.
While not directly related, compliance with internal procedures has been identified as a long-term program improvement effort in
.our response to NRC inspection 89-05.
Although the program will primarily focus upon strict compliance with regulatory and quality requirements, compliance with other internal procedure requirements will also be emphasized.
GE respectfully requests the violation be withdrawn since locking of the internal can storage pad gates is not a nuclear safety control cnr other regulatory requirement.
"B.
License Condition Number (No.) 9 of SNM-License No. 1097 requires that licensed material be used in accordance with statements, representations, j
and conditions of Part I of the License-Application dated October 23, 1987.
Part 1, Section 2.7.1 of the licensee's Application for License No. SNM-1097 requires that radiation protection function activities be conducted in accordance with written procedures.
Nuclear Safety Instruction (NSI) No. E-3.0 Nuclear Safety Review Request, Revision (Rev.) 14, dated December 14, 1989, requires for Facility Change Requests (FCRs) requiring a radiological safety review that the Nuclear Safety Engineer compile and generate an index of all necessary documentation, including air flow verification data and drawings.
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'U.S.-Nuclear Regulatory Commission Document Control-Desk May 4, 1990' Page 3 of 5 NSI No..E-1.0, Nuclear Safety Review Records, Rev.
13,_ dated December 19, 1990, details required air flow verification letter / memo records, pertinent drawings and sketches, as applicable, to be included-as part of the Nuclear Safety Review records.
NSI No. E-7.0, Radiological Safety Review for Process and Equipment Change Request, Rev. 11, dated October 12, 1989, requires the assigned NSE engineer to ensure that the required documents per NSI E-1,0, as appropriate, be included in the request file folder.
Contrary to the above, the licensee failed to follow-procedures in that on February 8, 1990, the file folder for FCR No. 89.263, dated December 4, 1989, did not contain documentation of air flow evaluations conducted for the immediate areas surrounding the Uranium Purification System (UPS) containment structure.
This is-a Severity Level V violation (Supplement IV)."
t GE RESPONSE:
The violation-is correct as stated.
Air flow evaluations were performed on January 29 and 30, 1990, by the assigned NSE Engineer. _ Subsequent adjustments were made to the applicable stationary air samplers (SASS) prior to authorization for work activities to begin.
Documentation of the air flow study was completed and filed for the' area inside the large containment structure erected around the
.UPS area.
However, although an air flow study.had been performed and-noted for the immediate areas adjacent to the UPS containment structure, formal documentation had not been prepared due'to other work activities and oversight on the part of the NSE engineer _in.
misplacing his air study notes.
Based on this oversight, another study was promptly performed and formally documented on February 12'following the February 5-9, 1990, NRC inspection.
As a result
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'of this air. flow re-study, no adjustments were required for the I
SASS-in the immediate areas surrounding the UPS contajnment structure.
')
l To avoid further violations, the necessity to retain and formalize
'j air flow study information and documentation on a timely basis was stressed to the responsible NSE engineer.
In addition, effective April 23, 1990, an additional NSE person reported to the NSE
.j function to support.the overall workload activities of the assigned engineer.
Based on completion of these actions, full compliance has been j
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achieved.
"C.
License Condition Number (No.) 9 of SNM-License No. 1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part I of the License Application dated October 23, 1987.
Part-1, Section 2.7.1 of.the licensee's
-Ap'lication for License No. SNM-1097 requires p
'that radiation protection function activities be conducted in accordance with written procedures.
Nuclear-Safety Release / Requirements (NSR/R)
Control No.
4.8.16, Rev.
8, dated November 7, 1989, requires in. Step 3 of the radiological safety section that the Queuing Pad in the Shop Support area near the Incinerator Building be clearly identified and posted " Caution -
Radioactive Materials" and "Every Container In This Area May Contain Radioactive Materials."
Contrary to above, the licensee failed.to follow procedures-for posting areas in that', on February 7,
1990, the Queuing Pad in-the Shop Support area was not posted with a sign indicating " Caution -
Radioactive Materials" and "Every Container In This Area May Contain Radioactive Materials."
This is a Severity Level V violation (Supplement IV)."
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U.S. Nuclear Regulatory Commission Document Control Desk May 4, 1990.
g Page 5 of 5 GE RESPONSE:
GE concurs with the NRC finding that the required posting was not present at the queuing pad south of the incinerator building on-February 7, 1990.
Radiation Protection routinely performs a weekly inspection of.all outside storage areas and NSE quarterly audits include checks for-1 area postings.
For several months-prior to this NRC inspection occasional, isolated occurrences had been found where postings had been missing.
Based on the NRC inspection and these occurrences, Shop Operations supervision were apprised of the concern for unauthorized removal of postings,.possibly by their
. personnel and/or activities.
No new occurrences of missing l
postings have been found since the NRC inspection.
{
i Additionally, we completed on April 16, 1990, our annual survey of i
all posting and replacement of signs subject to weathering.
l During this survey we found most signs to be in good-condition and i
no signs were found which were unreadable.
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Based on completion of these corrective actions, full compliance 1
-has been achieved.
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