ML20045C204
| ML20045C204 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 06/01/1993 |
| From: | Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20045C201 | List: |
| References | |
| 70-1257-93-06, 70-1257-93-6, NUDOCS 9306220202 | |
| Download: ML20045C204 (47) | |
Text
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L U.S. NUCLEAR REGULATORY COMMISSION REGION V Report No. 70-1257/93-06 Docket No. 70-1257 License No. SNM-1227 Licensee:
Siemens Power Corporation 2101 Horn Rapids Road Richland, Washington 99352-0130 Facility Name: Siemens Power Corporation (SPC)
Conference at: Region V Office - Walnut Creek, California Conference Conducted May 17, 19 3
/
3 Approved by:
J.f;'H. Reese, CM ef Date' Signed acFlities Radiological Protection Branch Conference Summary:
The purpose of the enforcement conference was to discuss the apparent violations and weaknesses identified during an Augmented Inspection Team (AIT) inspection (NRC Inspection P,eport No. 70-1257/93-02), and the subsequent in-office review of the AIT findings, as described in NRC Inspection Report No.
70-1257/93-05, dated April 30, 1993, and the corrective actions taken or planned by Siemens in response to these findings. These findings were based on the review of the event that occurred on February 7, 1993, involving the inadvertent discharge of a large quantity of low enriched uranium from the confines of its process system into a lexan enclosure. A copy of the NRC's enforcement conference agenda and a copy of the licensee's handouts are enclosed.
9306220202 930602 PDR ADDCK 07001257 C
l 1
1
. DETAILS 1.
Enforcement Conference Participants 1.1 Siemens Power Corporation B. N. Femreite, Plant Manager M. K. Valentine, Manager, Manufacturing Engineering R. L. Feuerbacher, Manager, Plant Operations L. J. Maas, Manager, Regulatory Compliance R. E. Vaughan, Manager, Safety, Security and Licensing H. W. Brook, General Counsel W. A. Baker, Manager, Marketing and Advertising 1.2 Nuclear Reaulatory Commission Reaion V Office B. H. Faulkenberry, Deputy Regional Administrator l
R. A. Scarano, Director,-Division'of Radiation Safety & Safeguards, F. A. Wenslawski, Deputy Director, Division of Radiation Safety and Safeguards W. J. McNulty, Director, Office of Investigations J. H. Reese, Chief, Facilities Radiological Protection Branch F. R. Huey, Regional Enforcement Officer C. A. Hooker, Fuel Facilities Inspector G. N. Cook, Senior Public Affairs Officer Headauarters Office t
J. T. Greeves, Deputy Director, Fuel Cycle and Safeguards Division, Office of Nuclear Materials Safety and Safeguards W. M. Troskoski, Senior Enforcement Specialist, Office of. Enforcement M. L. Klasky, Criticality Safety Specialist, Licensing Branch, Fuel Cycle and Safeguards Division, NMSS Note: There were no members of the media or public present at this Open Enforcement Conference.
2.
Enforcement Conference Details Mr. Wenslawski summarized the four apparent violations, described in Inspection Report 70-1257/93-05, that involved the failure to: (1) i follow procedures for modification of systems that involve fissile material, (2) follow operating procedures (taping of a safety interlock), (3) include safety modifications in the applicable criticality safety analyses, and (4) perform an adequate evaluation of the potential for moderator intrusion.
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Mr. Femreite stated that SPC had reviewed the inspection report and that Mr. Mass would present SPC's position relative to the NRC's findings as described in the report.
Mr. Valentine summarized SPC's immediate response and corrective actions related to the February 7th event and their evaluation regarding the potential for the intrusion of moderating liquids into the conversion line 2 powder preparation systems (Enclosure 2). Mr. Maas presented the licensee's response to the apparent violations (Enclosure 2) and stated that SPC did not disagree with the violations involving the failure to (1) follow procedures for modification of systems that involve fissile material, and (2) follow operating procedures (taping of a safety interlock). However, SPC did not concur with the apparent violations involving the failure to (1) incorporate the limit switches into the CSAs, and (2) perform an adequate evaluation of the potential for moderator intrusion.
During the course of the conference, Mr. Vaughan presented a summary of SPC's CSA Update Program (Enclosure 2). Mr. Femreite presented a summary of improvements SPC has made during the past year, mitigating factors for enforcement and conclusions as to why escalated enforcement action should not be taken in this case (Enclosure 2). Regarding the taping of the limit switched, Mr. Femreite stated that SPC's management does not condone such actions regardless of the safety significance involved. Mr. Faulkenberry acknowledged the licensee's program improvements and stated that the NRC would review the issues discussed to determine the appropriate enforcement action.
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s OPEN ENFORCEMENT CONFERENCE (EA 93-085)
SIEMENS POWER CORPORATION May 17, 1993 2:00 PM AGENDA
SUBJECT:
APPARENT VIOLATIONS OF PROCEDURAL AND CRITICALITY SAFETY REQUIREMENTS
REFERENCES:
AUGMENTED INSPECTION TEAM REPORT NO. 70-1257/93-02 AND INSPECTION REPORT NO. 70-1257/93-05 I.
OPENING REMARKS:
Bobby H. Faulkenberry Deputy Regional Administrator Bernie H. Femreite Plant Manager II.
SUMMARY
OF APPARENT VIOLATIONS:
Frank A. Wenslawski Deputy Director, Division of Radiation Safety and Safeguards III.
SAFETY SIGNIFICANCE:
Ross A. Scarano 0F THE VIOLATIONS Director, Division of Radiation Safety and Safeguards IV.
LICENSEE RESPONSE:
Bernie N. Femreite TO VIOLATIONS V.
NRC FOLLOWUP QUESTIONS:
Staff VI.
ENFORCEMENT POLICY:
Randy Huey Regional Enforcement Officer VII.
CLOSING REMARKS:
Bobby H. Faulkenberry i
' ENCLOSURE 2.
SIEMENS AGENDA INTRODUCTION Bernie Femreite 1
THE FEBRUARY 7,1993 EVENT Mike Valentine SPC Response / Investigation Corrective Actions Moderation Intrusion Analysis SPC RESPONSE TO APPARENT VIOLATIONS Loren Maas CRITICALITY SAFETY UPDATE PROGRAM Ray Vaughan LICENSEE PERFORMANCE Bernie Femreite MITIGATING FACTORS FOR ENFORCEMENT Bernie Femreite CONCLUSION Bernie Femreite r
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SUMMARY
OF FEBRUARY 7,1993 POWDER SPILL EVENT l
9 The Accu-Rate powder feeder discharge tube on the Line 3 blender separated from the hopper, spilling 124 Kg of UO powder into the enclosure (hood).
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A limit switch, in place to shut down the feeder if the discharge tube begins to separate from the hopper, was disabled by tape.
The spilled powder was dry and was contained within the HEPA-filtered enclosure.
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l SPC-ND RESPONSE TO FEBRUARY 7,1993 POWDER SPILL D
EVENT I
I Shutdown all three Powder Prep Lines Assemble Management NRC's Augmented Response Team inspection Team I
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Initiate immediate Form Incident Charter Generic Conduct Moderator Corrective Actions investigation Board Implications Task Team intrusion Evaluation l
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SPC-ND ORIGIN OF ACCU-RATE FEEDER LIMIT SWITCHES Over-filling of safe-batch container occurred on August 27,1992.
i Generic implications study was performed to evaluate other locations where batch and spill control may need improvement.
A list of nine locations was created with short-term and long-term corrective actions i
and estimated completion schedules.
Item #9 on this list recommended that limit switches be installed on the Accu-Rate feeder discharge housings to prevent powder spill into the enclosure should the feeder discharge separate from the hopper.
Limit switches were installed in September 1992 via Work Order.
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SPC-ND
. ORIGIN OF ACCU-RATE FEEDER LIMIT SWITCHES Over-filling of safe-batch container occurred on August 27,1992.
Generic implications study was performed to evaluate other locations where batch and spill control may need improvement.
A list of nine locations was created with short-term and long-term corrective actions and estimated completion schedules.
Item #9 on this list recommended that limit switches be installed on the Accu-Rate feeder discharge housings to prevent powder spill into the enclosure should the feeder discharge separate from the hopper.
Limit switches were installed in September 1992 via Work Order.
MKV:jjo 05/93
SPC-ND IMMEDIATE CORRECTIVE ACTIONS (February 7-12,19931 Shutdown of all three powder preparation and affected vacuum transfer lines Assemble Management Team Notify NRC via Bulletin 91-01 Assess safety of situation and authorize cleanup Create incident investigation Board (llB)
Establish " Generic Implications" Task Team Revoke use of Work Orders for any modifications Inspect and adjust limit switches to prevent incidental trips Perform functional tests of limit switches Delineate re-start conditions (with special operations) 05/93 MKV:jjo
SPC-ND PRINCIPAL IIB FINDINGS A procedural requirement to not disable interlocks was violated.
A procedure requiring use of an ECN to modify fissile-containing equipment was not followed.
Review of the use of Work Orders was less than adequate.
The existence of powder feeder interlocks and their operation was not in a procedure.
The design / installation of the interlock was less than adequate.
05/93 MKV:jjo
SPC-ND llB RECOMMENDATIONS STATUS Review all in-process work orders; reissue modification work under ECN's.
Complete Revise work order and ECN preparation procedures (EMF-858) and train engineers.
Complete Revise applicable SOP's to include identification of interlocks.
Complete
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Conduct incident critique and train all operators on interlecks.
Comp!cte
+
Complete a Work Station Training and Operator Qualification Guide.
Complete
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Plant Manager emphasize to all Manufacturing personnel the importance of inter-Complete locks (and consequences of disabling).
Revise SOP's and safety manuals to emphasize interlocks.
Complete Review design of powder feeder discharge tube for improvements.
Complete (mods to be completed by Aug.1993)
Revise powder prep log to encourage' recording of needed maintenance.
Complete Review 12-hour shift implementation.
In progress
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L RESULTS OF GENERIC IMPLICATIONS TASK TEAM ON INTERLOCKS AND LIMIT SWITCHES:
STATUS investigate use of interlocks plant-wide.
Complete Identify short-term and long-term corrective actions (where needed).
Complete Establish preventive maintenance procedure for critical interlocks July 1993 Modify ECN procedure to include check-off for SOP change and operator training.
Complete
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Implement a commitment tracking system for Manufacturing.
In progress
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SUMMARY
OF MODERATOR INTRUSION ANALYSIS
( EMF-93-068 [P] )
Adequate controls exist to prevent criticality in blending / powder preparation equipment.
Moderators are adequately excluded from the Conversion Line 2 blending and powder preparation equipment, even under accident conditions.
The following enhancements are recommended and will be completed by May 21,1993.
1) install Vac-U-Max shutdown switches in control rooms.
2)
Install " deadman" switches on vacuum wands.
3)
Install moisture detectors in hoods interlocked to vacuum system.
4)
Upgrade access ports (spring-activated doors) and install lighting in hoppers.
5)
Install covers on vacuum system air inlets within hoods.
Two additional modifications are estimated for completion by August 1993.
1)
Modify steam supply system to calciners.
2)
Redesign'(relocate) vacuum pickup heads.
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SUMMARY
OF GENERIC IMPLICATIONS TASK TEAM ON MODERATOR INTRUSION All existing moderator control areas were reviewed to identify potential moderator sources.
Compensatory action was taken, as needed, to mitigate the risk of moderator intrusion.
The CSS which defines moderator control was upgraded.
Seven enhancements were identified and scheduled.
Three have been completed Four scheduled for completion by July 1993 MKV:jjo 05/93
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SPC-ND NRC INSPECTION REPORT NO. 70-1257/93-05 STATEMENT OF APPARENT VIOLATION 1 The AIT concluded that between September 11-14,1992, a modification was made involving the installation of limit switches on the discharge tube of the UO feed hopper on each of four blenders to 2
prevent unanticipated discharges of fissile material from the confines of its normal process system.
This modification was made using a Work Order (WO) and not under the control of an Engineering Change Notice (ECN) and is identified as an apparent violation of License Condition No. 9 (70-1257/93-03-01).
05/93 LJM:pm
SPC-ND
SUMMARY
OF SPC RESPONSE TO APPARENT VIOLATION 1 l-l Apparent Violation 1 (Use of WO vs ECN)
SPC investigation identified weaknesses in ECN/WO procedures.
l SPC concurs that procedures were violated.
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Immediate and long-term corrective actions have been applied.
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NRC INSPECTION REPORT NO. 70-1257/93-05 STATEMENT OF APPARENT VIOLATION 2 On February 7,1993, following the inadvertent discharge of about 124 kg of UO powder from the 2
Line 3 blender's feed hopper to its respective lexan enclosure, the licensee and an NRC inspector observed that the limit switches (interlocks) on the discharge tube on the feed hopper of the Line 2 and Line 3 blenders had been taped (bypassed) to prevent the automatic shutdown of the feed system if the discharge tube should dislodge during operation. The tape on the Une 3 limit switch resulted in UO powder being discharged from the confines of its analyzed process system. There 2
had been no approval from a shift supervisor or other licensee management authorizing the taping of the switches. Taping of these limit switches is also identified as an apparent violation of License Condition No. 9 (70-1257/93-03-02).
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SPC-ND
SUMMARY
OF SPC RESPONSE TO APPARENT VIOLATION 2
-Apparent Violation 2 (Taping of Limit Switches)
SPC concurs with procedural violation.
Taping was a licensee-identified condition.
Licensee's report of powder spill under NRC Bulletin 91-01 identified switch taping.
Immediate and long-term corrective actions have been applied.
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l NRC INSPECTION REPORT NO. 70-1257/93-05 STATEMENT OF APPARENT VIOLATION 3 The AIT concluded that as of February 12,1993, the licensee had not carefully evaluated the potential for moderator intrusion into the chemical conversion Line 2 unfavorable geometry powder preparation systems from nearby systems containing moderating materials. Specifically, the licensee could not provide any technical basis for the assertion that the moderating liquid systems did not pose a criticality safety concern in the event of a spill of UO powder into the lexan enclosures such as 2
occurred on February 7,1993. In addition, the licensee could not provide any justification that nearby moderating systems did not pose a cri'.cali. safety concern relative to the design and operations associated with the UO powder vacue i transfer systems. Failure to perform such an evaluation is 2
identified as an apparent violation of License Condition No. 9 (70-1257/93-03-03).
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SPC-ND
SUMMARY
OF SPC RESPONSE TO APPARENT VIOLATION 3 Apparent Violation 3 (Moderator Intrusion Analysis)'
a SPC does not concur with apparent violation.
i-Apparent violation does not recognize existing technical bases underlying moderation control.
Criticality safety analyses for power preparation process equipment Criticality safety specification for moderation control areas Criticality safety review on ECNs for hoods and vacuum transfer systems Apparent violation represents citing of condition for which corrective action pursuant to prior enforcement, action was already underway.
05/93
SPC-ND NRC INSPECTION REPORT NO. 70-1257/93-05 STATEMENT OF APPARENT VIOLATION 4 The AIT disclosed that as of February 12,1993, applicable CSAs had not been amended to incorporate the limit switches (equipment) that were installed on the feed system of each of the four blenders in September 1992, to prevent discharges of low enriched UO powder from the confines of 2
the process system. Failure to include the limit switches in the applicable CSAs and lower tier documents is identified as an apparent violation of License Condition No. 9 (70-1257/93-03-04).
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SUMMARY
OF SPC RESPONSE TO APPARENT VIOLATION 4 Apparent Violation 4 (Limit Switches in CSA)
SPC does not concur with apparent violation.
l Limit switch installation identified as long-term corrective action under SPC internal Criticality Safety Corrective Action (CSCAR) program.
Criticality Safety Specialist evaluated switch installation as not impacting existing CSA.
Switch installation was not an equipment modification that required a new or modified CSA.
Apparent violation represents citing of condition for which corrective action pursuant to prior enforcement action was already underway.
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1 SIEMENS POWER CORPORATION CRITICALITY SAFETY ANALYSES UPDATE PROGRAM
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SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Development Chronology i
DATE-EVENT
~ August 8,1992 Slab hopper powder transfer incident August 12-14,1992 NRC special ori-site inspection - NRC Report No. 70-1257/92 September.22,1992 Enforcement conference - SPC commits to long-term programmatic review of all CSAs September 30,1992 Enforcement conference summary issued - NRC Report No. 70-1257/
92-07 Q
October 23,1992-Notice of Violation and imposition of civil penalty - NRC Report No.
70-1257/92-06 November 23,1992 SPC response to Notice of Violation Report No. 92-06 with corrective f
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December 30,.1992 CSA update program plan transmitted to NRC l
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Siemens Power Corporation Criticality Safety Analyses Update Program Description Three phase program Phase 1:
Review, validate and categorize CSAs, ECD June'30,1993 Phase 2:
Prioritize and reanalyze Category l CSAs, ECD: January 31,1994 4
Phase 3:
Prioritize and reanalyze Category 11 CSAs, ECD: January 31,1995 Expected duration:
Two years - completion scheduled for January 31,1995 Plan resource analysis:
' Expected 8.5 to 11.5 man-year effort Multi-disciplinary effort:
Operations, Manufacturing-Engineering, Criticality Safety, Clerical i
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L SIEMENS POWER CORPORATION CRITICALITY SAFETY ANALYSES l
UPDATE PROGRAM-TASK OUTLINE r
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Phase 1 Review, Validate, Categcrire CSAs e
. Consultant Reviews Existing Criticality Safety Review CSAs and Provide Team Defines List of Assumptions Process Systems
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Project Manager Arranges Groups of CSAs into Systems Packages I
Project Manager Prepares Summary of Assumptions, Accident Condition i
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Engineering and Operations Validation of Current Assumptions and Accident Conditions.
I Criticality Safety Review for Ucense Compliance and 90-01 Reportability i
Sort CSAs into Safety Impact Categories I
I Category i Category 11 Category ll!
CSAs for the System are CSAs for the System CSAs for the System Need Needs Major / Urgent Addenda to Strengthen Adequate as is and will be Upgrading to Demonstrate Controls Pending Final Upgrade Reformatted as Part of Periodic Review Safe Operation Phase 1 g
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i Phase 2 Prioritize and Reanalyze Category 1 CSA's
- As-Built" Each Process System l
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! As-Builts & Validated Assumptions &
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Engineering to Mark Complete New System CSAs
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l Matrix for Future Review l Pertinent Drawings as Requiring C.S. Approval i
Before Changing System C.S. Review Team Validates Dimension, Assumption, Accident Condition etc.
A Plant Manager Indicates by i
i Signature That Safety Margin and Residual Risk are Appropriate Place all Criticality Safety iTechnical Basis l
Requirements in Criticality l Document Safety Specifications I
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_ Matrix for Future Review l Pertinent Drawings as u-Requiring C.S. Approval Before Chancing System JTechnical Basis
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SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Progress Report-DATE
. ACCOMPLISHMENT i
December 11,1992 Draft plan of CSA update program issued December. 29,1992 Resource requirements analysis completed December 30,1992 Plan approved by SPC management 4
January 6,1993 Draft task' outline for CSA update plan issued January 8,1993
.CSA program Steering Committee established / Project Manager appointed L
Criticality safety system review teams assigned with written charter -
l Phase lA begins Criticality safety review teams establish 53 systems envelopes to January 29,1993
. encompass 216 existing CSAs l
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February,4,1993 CSA assumption validation teams (Plant Engineering / Operations) l
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SPC-ND Siemens Power Corporation Criticality Safety Analyses Update Program Progress Report (Continued)
DATE ACCOMPLISHMENT February 10,1993 CSA systems packages prepared February 16,1993 All CSA systems packages issued by Project Manager to revie.v teams March 29,1993 Implement weekly status reporting and status review at SS&L Weekly Planning Meeting April 27,1993.
NRC Bulleting 91-01 reportable condition on inadequate SWUR incineration criticality safety controls May 13,1993 Phase-1 A complete - initial CSRT review of all CSA systems packages completed Current Status:
Review and categorization (Phase-1B) by criticality safety component in progress; completion of Phase-1 by June 30,1993 still achievable 05/93
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Siemens Power Corporation Criticality Safety Analyses-1 Update Program Observations Expected Benefits:
Improved safety analyses document. packages to meet evolving standards Multi-disciplinary review - greater involvement of, and understanding by Operations and Manufacturing Engineering personnel Improved logic in establishing systems and interfaces Reduced number of CSAs to administer
' Expanded and clear statement of accident / upset condition scenarios evaluated and barriers / defenses to preclude criticdity i-05/93
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SIEMENS Important Developments in 1992 SPC-NRC Management Meeting NRC's perceived SPC weaknesses:
Inadequate management oversight of safety programs Safety staff too small HPTs not proactive enough NRC Bulletin 91-01 reporting procedure instituted by SPC SPC has taken a proactive approach:
SPC made three reports prior to NRC approval of the procedure SPC errs conservatively in determining reportability SPC major initiatives to upgrade compliance program Review criticality safety program Improve configuration control Improve incident investigations Make needed organizational / staffing changes
SIEMENS Maior Initiatives As a result of SPC-NRC Interactions in 1992, the following areas for improvement are in progress:
Criticality Safety Analysis (CSA) update program
, Review and verify assumptions Identify and document additional accidents Ensure double contingency principle applies Configuration control Improve documentation of changes Upgrade training Incident investigation Improve timeliness Formalize methods Organizational / staffing changes Improve management oversight Increase safety staff
SIEMENS Criticality Safety Analysis Update Program Three phase program to review and update, as necessary, SPC's existing criticality safety analyses.
Phase 1 - Initial review and system grouping (by 4/30/93) and categorization by need for reanalysis (by 6/30/93).
Phase 2 - Reanalysis and documentation of most urgent (category I) CSAs -
duration,7 months Phase 3 - Reanalysis and documentation of less urgent (category 2) CSAs -
duration,12 months t
Periodic review such that each CSA reviewed at least every five years i
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Configuration Control Strengthened training program for changed processes and equipment Enhanced configuration control program as part of CSA update program Have made major changes to Engineering Change Notice procedure to strengthen control of equipment changes
SIEMENS TRAINING Management training programs have improved incident investigations, self-assessment, and operational performance.
Abnormal Event Reporting implemented new procedure for informing line and safety management of off-standard conditions with possible safety implications.
TAPROOTm Root Cause Analysis Fifty-three supervisors, managers, and engineers were formally trained in April 1993 by Systems improvements, Inc.
Conduct of Ooerations@Techstar Twenty-six managers, supervisors, and engineers completed training in December 1992. One-hundred and twenty-nine supervisors, lead technicians, and engineers
. were trained on 18 fundamentals of effective operations. Completed May 1993.
Effective Problem Closecut @ W.R. Corcoran Twenty-eight persons who report to the Plant Manager and selected senior engineers were trained in root cause, casual factors, barrier analysis, and generic implications in March 1993. Vice President, Manufacturing, Richland Plant Manager, and Manager, Quality Control completed the course previously.
SIEMENS Organizational / Staffing Changes Improve Management Oversight Established waste engineering group to allow Regulatory Compliance to concentrate on compliance 1
Strenghtened criticality safety and radiation protection corrective action reporting systems Created and filled Richland Plant Manager position in October 1992 Strenghtened abnormal event reporting and incident investigation system Increase Safety Staff Hired a certified Health Physicist Hired a second Criticality Safety Specialist and a third will be hired in early 1993 Created and filled the Health and Safety Supervisor position Increased the Radiation Protection staff from 11 to 21 Provided Senior Technician assistants for Health Physicist and Healt.h and Safety Supervisor
SIEMENS; sec-No Page 2 of 2 All abnormal events distributed daily to area General Supervisor, Manager, Plant Operations and Plant Manager.
Manager, Plant Operations distributes to Safety, Security & Licensing (SS&L) and/or t
Manufacturing Engineering as appropriate.
Abnormal event logs saved in centralized notebook for each area of operation for shift turnover and historical purposes.
4 AUTHORITY FOR RESUMING OPERATION AFTER ABNORMAL EVENT SOP defines events when shift supervisor must shut down and contact management.
i Only area general Supervisor and Manager, Plant Operations can authorize whether affected operations may continue.
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If necessary, Manager, Plant Operations contacts Plant Manager to make recommendation I
for safety and technical related support.
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SIEMENS Page 1 of 2 MITIGATING FACTORS 10 CFR Part 2 Appendix C c
Licensee identified and reported the event, the weaknesses, and procedural problems.
i-Strong licensee initiative in conducting the investigation and taking effective action.
Timely, appropriate reporting and action.
Comprehensive investigation: root cause(s), causal factors, generic implications, barrier analysis.
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Immediate management oversight.
Immediate and lasting deterrent effect within the organization.
Communications regarding the event and causal factors Procedure changes and training Corrective actions involved Manufacturing staff-Strong communications regarding safety systems, expectations, and license requirements.
- ' Retraining of Manufacturing staff i
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SIEMENS Page 2 of 2 Causal factors (list of 9) predated September 1992 enforcement and SPC compliance upgrade plan.
Licensee's findings and appropriateness of actions were corroborated by NRC.
Potential violations do not meet section IV criteria, except deficiencies acknowledged under current escalated enforcement action.
Aggregation - do not have a common cause Repetition - do not repeat prior violations Willful: lack of understanding, self reporting, concerns for overbatching Reporting - was timely Escalated enforcement already in effect for programmatic deficiencies Double jeopardy Section Vil B (5) criteria Section Vil B (4) criteria
SIEMENS l
LICENSEE PERFORMANCE L
Section Vil l
l Siemens Power Corporation is not a recalcitrant licensee, as evidenced by positive reaction to increased NRC surveillance.
Proactive approach to NRC concerns Aggressive implementation of NRC Bulletin 91-01 Enhance problem-solving skills Rapport with Region V staff Constructive and open approach with NRC inspectors Extensive training Intended emphasis on Conduct of Operations, Self-Assessment, Compliance Participative management = Buy-in via self-assessment, statistical process control, task teams, readiness reviews, area teams.
SPC-ND l
CONCLUSION l
Siemens Power Corporation's response to the event has been timely, appropriate, and effective. Our recent actions and program initiatives are clear evidence that we are not reluctant to make necessary changes to improve safety or address compliance issues. We have undertaken significant programs to strengthen our staff, to upgrade staff training, increase management control, and to bring about
" cultural" changes.
Escalated enforcement is not merited by NRC criteria. Enforcement sanctions are not likely to enhance our resolve or ability to make improvements. Enforcement-related activity has and would divert valuable resources away from the tasks at hand.
SIEMENS SPC-ND Page 1 of 2 ABNORMAL EVENT REPORTING PURPOSE Inform supervision and management of abnormal events.
Ensure safe operation of the plant by focusing proper attention to abnormal events before' resuming operation.
PROCEDURE FOR REPORTING Used only for safety-related items (emphasizes safety first)
Standard Operating Procedure (SOP) includes definitions for events to be reported.
Does not supersede other license-required reporting (e.g.,91-01).
Form completed for every shift by shift supervisor Description of incident -
Cause and corrective action Justification for continued operation Management levels contacted BNF:jjo 05/93
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