ML20044G291
| ML20044G291 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 05/28/1993 |
| From: | Fici J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9306020284 | |
| Download: ML20044G291 (9) | |
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Westinghouse Commercial Nuclear Nawa R Electric Corporation Fuel Division Sjfh8ygg a caea 292w g
May 28, 1993
'U.S.
NUCLEAR REGULATORY COMMISSION ATTN:
Document Control Desk Washington, DC 20555 Gentlemen:
SUBJECT:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
NRC INSPECTION REPORT NO. 70-1151/93-02 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 your letter of April 29,
- 1993, regarding inspections of the Columbia Fuel Fabrication Facility conducted during the period of March 1-5, 1993.
Should you have any questions or require additional information, please telephone me at (803) 776-2610.
I hereby affirm that the statements made on this response are true and correct to the best of my knowledge and belief.
Sincerely.
WESTINGHOUSE ELECTRIC CORPORATION
- 1. h s '
ames A.
Fici, Plant Manager Columbia Fuel Fabrication Facility Attachment _.
APPENDIX A cc:
U.S. NUCLEAR REGULATORY COMMISSION REGION II REGIONAL ADMINISTRATOR 101 M AR1ETTA STREEr, N.W.
ATLANTA, GA 30323 020072 93060202B4 930528
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APPENDIX A WESTINGHOUSE RESPONSE TO THE ITEMS OF NONCOMPLIANCE IDENTIFIED IN THE NRC NOTICE OF VIOLATION
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i VIOLATION A EXAMPLE 1:
With respect to the observation that, radiation protection activities were not followed in controlling radioactive contamination in that, on March 1,1993, at or about 1:0C pm, three entrances to the UNH Tank Area (a controlled area) were found t
without step-off pads -- the following information is provided:
1 A.l.1 The observation is correct as stated in the Notice of Violation.
I A.l.2 The reason for the violation was:
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The UNH Tank Area had previously been redesignated from I
a Limited area to a Controlled Area. When this occurred, all of the necessary controls were not fully implemented.
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The use of three entrances decentralized the control of access to/ egress from the UNH Tank Area and allowed access to be gained without adequate control and supervision.
A.l.3 Immediate action to correct the observation, and results achieved, include:
The UNH Tank Area was temporarily placed under the control of a Radiation Work Permit while permanent
- i actions were being evaluated and implemented.
Two of the three entrances to the UNH Tank Area were designated as being for emergency access / egress only.
Each of these two gates was posted on both the inside and outside of the gate.
Both gates were equipped with numbered seals and URRS management has been charged with the responsibility for routinely ensuring their integrity.
One entrance was retained as the routine access / egress area.
At this location, a Step-Off Pad was installed at the edge of the diked area, a hand monitor was installed, and instructions were posted beside the Step-Off Pad to f acilitate personnel monitoring, in accordance with SNM-1107 requirements.
i All URRS and Maintenance employees attended a retraining t
session, during which time, Step-Off Pad procedural requirements were reviewed.
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A.1.4 Actions planned, to prevent recurrence of events of the type observed, include:
The concrete pad in the UNH Tank Area has been resurfaced with an acid resistent epoxy coating, and any unnecessary materials / equipment removed from the area An elevated grating will be installed which will enable operators to enter the area without stepping on the concrete pad.
The combination of these two actions will minimize-the potential for personel contamination as a result of entry into the diked area, minimize the likelihood of any spread of contamination, and simplify clean up efforts in the event of a minor leak.
Pump pressure gauges will be oriented to allow operators to obtain readings without entering the diked area, thereby reducing traffic.
The general area around the UNH Tank Area will be placed on a daily inspection frequency.
One URRS employee has been assigned responsibility for ensuring that good housekeeping is maintained in the UNH Tank Area.
A.l.5 Full compliance was achieved on March 22, 1993.
EXAMPLE 2:-
With respect to the observation that, radiation protection activities were not followed in controlling radioactive contamination in - that, on March 1,
1993, at. or about 1:30 pm, contaminated protective clothing was found stored on contaminated shelves adjacent to the entrance on the uncontaminated side of the UNH Tank Area (a controlled area) -- the following information is provided:
A.2.1 The observation is correct as stated in the Notice of Violation.
A.^.2 The reason for the violation was:
Policies which define the proper storage of protective equipment were not followed.
This situation was complicated by a lack of shelving on the contaminated.
side of the UNH. Tank Area.
Inadequate placement of the shelves on the uncontaminated -
side made proper use difficult.
v..
A.2.3 Immediate action to correct the' observation, and results achieved, include:
The shelves on which the contaminated clothing was stored were removed, cleaned and relocated on the potentially contaminated side of the UNH Tank Area.
An additional shelf unit was located on the uncontaminated side of the UNH Tank Area.
Both shelf units were labeled, and color coded (Yellow =Potentially Contaminated, White = Uncontaminated) to ensure that the appropriate protective clothing is located in the proper location.
A.2.4 Actions planned, to prevent recurrence of events of the type observed, include:
The area will be placed on a daily inspection frequency.
I This frequency will continue as long as the area remains j
a Controlled area.
All URRS, Maintenance, and Regulatory Operations personnel have been retrained in contamination control l
issues to' heighten their awareness of potential problems.
j A.2.5 Full compliance was achieved on March 10, 1993.
EXAMPLE 3:
With. respect to the observation that, radiation protection activities were not followed in controlling radioactive contamination in that, on March 1,1993, at or about 3:30 pm, a low level radwaste storage trailer parked inside the truck bay on i
Loading Dock #3 was found unlocked and open when not in use; and, in addition, no Radiation Work-Permit had been prepared and"the i
activity was not covered by an operating procedure and the key was
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not controlled; and, the posting-on the trailer was hidden by the open door folded back against the - side; and, contamination. of approximately 3,000 cpm was found on the loading dock adjacent'to-the trailer -- the following information is provided:
l A.3.1 The observation is correct as stated in the Notice of Violation.
A.3.2 The reason for the violation was:
Regulatory personnel were notified in advance of the intent to move'a radwaste storage trailer into Loading Dock 3 for the purpose of removing scrap equipment and preparing it for disposal.. Approval to move the trailer-into position was granted and Operations personnel'were informed that-an RWP would be required prior to the entry 1
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t of any employee into the trailer.
It was not understood that the doors would be opened prior to issuance of said RWP, thereby creating the violation.
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A.3.3 Immediate action to correct the observation, and results achieved, include:
i Access to the trailer was restricted (the area i
barricaded).
The entrance to the trailer was placed under lock and-key.
An RWP was issued and posted during trailer unloading.
-l The portable steps which were found to be contaminated were moved from the dock area into the Chemical Area.
t The dock was extensively surveyed and decontaminated, and -
the trailer decontaminated and removed.
The RWP under which this operation was conducted received a final review, and was closed out for this operation in
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accordance with procedural requirements.
P A.3.4 Actions planned, to prevent recurrence of events of the type observed, include:
The RWP procedure (RA-207) was modified to strengthen the process.
lt Regulatory Operations Technicians are formally included
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in the review process and documentation is maintained in l
the RWP file.
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Future regulatory review' processes will include a visual j
inspection of the site of the planned activities.
A.3.5 Full compliance was achieved on March 8, 1993.
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EXAMPLE 4:
With respect to the observation that, radiation protection activities were not followed in controlling radioactive i
contamination in that, on March 1, 1993, at or about 3:00 pm, a l
used contaminated respirator was - found on the 1 third shelf of a storage cabinet in the-Advanced Waste Water Treatment Building (a t
contaminated area) with a carbonated beverage can and gum wrappers next to or in close proximity -- the following information is l
provided:
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i A.4.1 The observation is correct as stated'in the Notice of l
Violation, A.4.2 The reason for the violation was:-
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There was a failure to_ follow the proper regulatory
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requirements by an employee working in the area.
This failure was likely aggravated by the designation of.the Advanced Wastewater Treatment Area.as a " Limited" area, indicating a lower degree of contamination.
Also, it is likely that the employee believed that, since the respirator was being used for control of ammonia, strict controls on storage of respirators were unnecessary.
A.4.3 Immediate action to correct the observation, and results achieved, include:
The beverage can, respirator, and gum wrappers were removed from the storage cabinet.
The entrance to the Advanced Wastewater Treatment Area was posted with instructions prohibiting eating or drinking in the area.
All personnel who work in the area received area-specific -
retraining on their shift and in their work place.
All potential areas where respirators could-be stored-were inspected by area management for unauthorized materials.
A.4.4 Actions planned, to prevent recurrence of events of _ the type observed, include:
Signs were posted indicating the authorized storage locations for respirators.
A mobile respirator storage rack was procured and is currently being evaluated.
A meeting was held with Chemical Area Trainers'to gain insight into their needs and to better understand the problems facing Operations personnel in the performance of their responsibilities when respiratory protection is -
needed.
Regulatory Operations Technicians are conducting daily-radiation protection area tours and emphasizing proper health physics practices.
An additional workplace script is being prepared for presentation to all Chemical Area employees which will strengthen existing radiological health and-safety.
policies.
This.will be presented by July 1, 1993.
A.4.5 Full compliance was achieved on March 10, 1993.
EXAMPLE 5:
With respect to the observation that, radiation
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" rotection activities were not followed in controlling radioactive p
contamination in that, during the week of August 17-28,
- 1992,
,seve'ral examples of failure to perform surveys of incoming shipments of radioactive material, inadequate surveys of food i
preparation, eating and drinking areas, and inadequate HP coverage for some work performed under radiation work permits (OSA item 92-04-30) were identified by record review the.
following
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information is provided:
A.S.1 The observation is correct as stated in'the Notice of Violation.
A.5.2 The reason for the violation was:
There was a failure in the procedures to adequately address all applicable contamination control concerns.
A.5.3 Immediate action to correct the observation, and results achieved, include:
The Regulatory Operations Procedure RO-02-008 was I
modified to address incoming shipments of radioactive materials.
- i Regulatory Operations Procedure RO-05-014 was modified to include the food preparation areas of the facility in addition to the eating and drinking. areas.
The Regulatory Affairs Procedure RA 207 was revised to include a pre and a post job engineering analysis, an r
ALARA review, and a final RWP closure to ensure that all necessary documentation is present, and that all-necessary actions have been taken.
These procedure changes were reviewed with all Regulatory Operations
'I technicians.
A.5.4 Actions planned, to prevent recurrence of events of the -type I
observed, include:
F Contamination survey results are now being. routinely reviewed by Regulatory Engineering with direct interface l
between the responsible engineer and the Regulatory i
Operations Technicians responsible for the program.
Problem' solving and review sessions are routinely scheduled to' identify undesirable trends and to ensure that all areas of the Plant are properly monitored.-
i Additional initiatives which will continue to improve j
programs associated with the control of radioactive material j
are enumerated below:
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- The Regulatory Operations function has initiated work place meetings with individual groups within the I
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Chemical Area.
At this time, nineteen such meetings have been held.
Their purpose is to reinforce and re-educate employees about health and safety programs and their importance; and expectations of employees' performance.
The meetings are also intended to motivate employees and to promote dialogue so that-problems are identified and resolved.
The remaining i
five meetings will be completed by July 15, 1993.
- A program is currently being developed to provide additional training to selected Manufacturing Area personnel.
The anticipated goal in providing the training is the organization of a team of qualified HP coordinators within the work force and throughout the Plant.
Areas of emphasis will include contamination control, the ALARA philosophy, housekeeping, airborne awareness, etc.
Team members will be instructed in self identification and correction of potential problems both in their work areas and in other areas of I
the Plant.
The program outline and implementation plans will be completed by June 30, 1993.
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- Regulatory Operations technicians have been retrained i
in contamination surveillance techniques with particular emphasis placed on improving effectiveness in detecting potential problems.
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- Protective clothing needs are being reevaluated to ensure that the proper clothing is being provided based i
on the work areas and responsibilities of the employees.
A recommendation will have been made by
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July 16, 1993.
- All Chemical Area access points have been reevaluated.
f In addition to determining the need to retain each i
access point, the monitoring equipment, postings, i
personnel monitoring equipment, and step-off pad c
adequacy are being reviewed.
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- The management and control of waste materials are continuing to be reviewed to ensure that potentially contaminated wastes are not inadvertantly moved offsite.
Waste containers used to transport clean trash have been relocated away from areas where slightly contaminated materials may be routinely i
encountered.
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- Contamination control progran audits have been enhanced f
to verify that the contaminction control program is consistent with the ALARA pullosophy.
- An evaluation and assessment of the adequacy of l
personnel contamination control practices, plant-wide, i
is in progress to assure that the program fully meets l
P f
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site needs.
This will have been completed by July 30, 1993.
A.5.5 Full compliance was achieved on March 31, 1993.
VIOLATION B
{
With respect to the observation that, the Radiation Protection Inspection Plan was not performed as required by the procedure nor were corrective actions adequately implemented; and, radiation protection inspections in accordance.with a written inspection plan had not been conducted during the 1992 calendar year tha following information is provided:
i B.1.1 The observation is correct as stated in the Notice of Violation.
B.1.2 The reason for the violation was:
r Increased regulatory expectations and regulatory initiatives such as NRC Bulletin 91-01 and 10CFR70.50, resulted in an inadvertant failure to apply adequate resources to assure compliance with the inspection program, and inadequate oversight to assure that the i
intent of license conditions and procedures were followed for this program.
B.1.3 Immediate action to correct the observation, and results achieved, include:
Regulatory Affairs management' appointed a Regulatory
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Affairs Inspection Coordinator to reestablish the inspection coordination function to assure compliance with Procedure RA-102, including the performance of f
inspections at the required frequencies in accordance with a written plan, and. following up on implementation of corrective actions. The Regulatory Affairs Inspection Coordinator was designated March 16, 1993 and the first inspections under this new plan were completed March 23, 1993.
B.1 4 Actions planned, to prevent recurrence of events of the type.
observed, include:
Management has committed to maintaining a Regulatory Affairs Inspection Coordinator (or equivalent) to 3
facilitate plant inspections and to assure compliance j
with applicable plant inspection requirements.
B.l.5 Full compliance was achieved on March 23, 1993.
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