ML20045G753
| ML20045G753 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/06/1993 |
| From: | Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307150130 | |
| Download: ML20045G753 (6) | |
Text
.
SIEMENS July 6,1993 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen:
Re: Letter, J.H. Reese to Siemens Power Corporation, " Notice of Violation NRC inspection Report No. 70-1257/93-03," dated June 7,1993.
Enclosed is Siemens Power Corporation's reply to the Notice of Violation contained in the referenced letter. If you have any questions regarding this reply, please contact me at 509-375-8537.
Very truly yours,
[7kh L. J. Maas, Manager Regulatory Compliance LJM:pm cc:
B. H. Faulkenberry Region V Administrator 140001
((8 Siemens Power Corporation
/
Nuclea' Dwison - Engmering and Manufactunny Fadiity 7
2101 Horn Rands Roar 1 PO Box 130 -
Rchiand. WA 99352 0130 Tel (509; 376 8100 Fi (509) 375 8402 9307150130 930706 B
PDR ADOCK 07001257 M
.C PDR Q..
4 REPLY TO NOTICE OF VIOLATION (93-03)
Statement of Violation 93-03-01 A. License Condition No. 9 of License No. SNM-1227 authorizes the use of licensed-materials in accordance with the statements, representations, and conditions contained in Part i of the licensee's application dated July 1987, and supplements dated November 12,1987, through November 25,1992.
Section 2.4.3, " Health Physics Technician Training, "Part i of the license application states:
" Health Physics Technicians [ Health and Safety Technicians] are given special training related to their radiation protection assignment. Previous training is accepted if considered equivalent to the Advanced Nuclear Fuels [Siemens Power Corporation] training program. Despite previous acceptable training, the Health Physics Technicians are required to be to become proficient in Advanced Nuclear Fuels radiation protection and criticality safety programs, specifications, procedures, and routines, as demonstrated by successfully passing a Advanced Nuclear Fuels certification examination within six months after employment as a Health Physics Technician. In addition, refresher training is provided to all Health Physics Technicians annually."
Contrary to the above, as of April 16,1993, no certification exams had been given to five Health & Safety Technicians [H&STs] within six months of employment as a H&ST. The five H&STs had either been hired in as a qualified H&ST or had been promoted to a qualified position: (1) one individual was hired on July 25,1990, (2) one individual was promoted on July 29,1992, (3) one individual was hired on September 1,1992, (4) one individual was hired on September 8,1992, and (5) one individual was hired on September 22,1992.
This is a Severity Level IV violation (Supplement VI).
Reasons for Violation There were two underlying reasons for this violation. First, the examination and certification -
process for HSTs had not been adequately supported with administrative procedures and followup tracking to the extent that it assured compliance with the license requirements.
Second, a number of HSTs terminated employment with SPC in mid-1992 and therefore management and supervisory attention focused on the areas of recruitment, hiring, and training, thereby allowing certification activities to slip.
Immediate Corrective Steps The Supervisor of Radiological Safety reviewed the training status of the HSTs. Based en this review the Supervisor concluded that on-the-job training and experience qualified the HSTs in question to take the certification examination. The examination was given to and passed by
4 i
l the HSTs such that the entire HST staff is now in compliance with the written examination requirement set forth in the license.
Corrective Steps to Avoid Further Violations The Health Physics / Radiation Safety Procedures Manualis being updated and strengthened by the addition of a procedure formalizing both training and certification requirements.
Compliance with this procedure will be overseen by the Supervisor of Radiological Safety, a position which was created in August 1992.
Date to be in Full Compliance All HSTs are now in compliance with the written examination requirement specified in the license. Addition of an appropriate procedure to the Health Physics /Rediation Safety Procedures Manual will be completed by August 31,1993.
I e-
-m am--
l i
Statement of Violation 93-03 02 B.10 CFR 20.311(d) states that any generating licensee who transfers radioactive l
waste to a land disposal facility shall comply with the requirements in paragraphs (d)(1) through (d)(8). Paragraph (d)(3) states that a licensee shall conduct a quality control program to assure compliance with 10 CFR 61.55, " Waste Classification,"
i and 10 CFR 61.56, " Waste Characteristics."
a Contrary to the above, on December 22,1992, through December 29,1992, the licensee on five occasions transferred radioactive waste to a land disposal facility and did not conduct a quality control program to assure compliance with 10 CFR 61.55 and 10 CFR 61.56. Specifically, as of April 16,1993, the licensee did not have procedures in place to conduct the quality control program referenced in 10 CFR 20.311(d)(3).
This is a Severity Level IV violation (Supplement V).
Reason for Violation The reason for this violation is the failure of management to implement a quality control program of sufficient scope to address all required areas of the radiological waste shipping / disposal program. To date SPC's quality control overchecks of waste packaging 3
and shipments have consisted mainly of independent overchecks of loaded containers for proper marking, labelling and shipment paperwork. The actual packaging of the waste, although covered by written procedure, has not received the same consistent level of quality control oversight. The scope of these overchecks has been inadequate to be considered the quality control program envisioned in 10 CFR 20.31 t(d), especially with respect to waste characterization. SPC feels that waste classification, however, is adequately addressed in Chapter 5 of SPC's Safety Manual, EMF-30.
Immediate Corrective Steps SPC has taken the following interim step concerning near term upcoming waste shipments.
For each shipment a letter will be prepared and inserted in the shipment file describing the steps taken to classify and characterize the waste. Among those steps will be the re-inspection of each package to confirm contents, classification, and characterization. The letter for each shipment will be reviewed independently and formally concurred with.
Corrective Steps to Avoid Further Violations SPC is in the process of updating operational procedures dealing with classifying, characterizing, packaging and shipping waste. A new section will be added to the Safety Manual, EMF-30, describing the quality control program for waste classification /
characterization that these procedures comprise. The program will also provide for periodic management audits of its effectiveness.
i l
y
+
r
--i- --
~1
i 4
Date to be in Full Compliance SPC will impose the interim quality control measures on all outgoing waste shipments until the updated OC program has been implemented. SPC expects the updated OC program to be in-place by September 30,1993.
i n
i l
-.m
I Statement of Violation 93-03-05 C.10 CFR 71.87(j) requires that prior to each shipment of licensed material, the licensee ensure that external radiation levels around the package and around the vehicle, if applicable, will not exceed the limits specified in 10 CFR 71.47 at any -
time during transportation.
10 CFR 71.91(a)(10) requires that each license _e maintain for a period of three years after shipment a record of each shipment of licensed material showing the-results of the determinations required by 10 CFR 71.87.
Contrary to the above, on March 29,1993 through April 2,1993, the licensee made three shipments of fuel assemblies containing licensed material and did not maintain a record showing the results of required external radiation surveys of the transport vehicle.
This is a Severity Level V violation (Supplement V).
t Reason for Violation it is SPC's standard practice to survey packaging and the transport vehicle prior to departure and to record the survey results in the " Repetitive Survey" log maintained by the health and safety technicians (HSTs). In the instances mentioned above, it is not clear whether the vehicle surveys were made and not recorded or not made. The major reason for a lack of consistency in recording these measu ments is the fact that there was no place on the Radioactive Shipment Record (RSR) fann to record vehicle survey readings. Reliance on the repetitive survey log instead of recording vehicle survey results on the RSR form has also at times made it difficult to correlate survey results with a specific shipment.
Immediate Corrective Stoos Traffic and Warehousing personnel and HSTs have been re-instructed on survey requirements -
for radioactive material shipments.
Corrective Steps to Avoid Further Violations The RSR form has been redesigned to provide specific space for radioactive survey results on shipment vehicles. Both Shipping and Warehousing personnel and HSTs have been trained in the use of the revised form.
Date to be in Full Compliance Complete.
i
.-