ML20055F819
| ML20055F819 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 07/13/1990 |
| From: | Vaughan R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Kasun D NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9007190240 | |
| Download: ML20055F819 (4) | |
Text
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ABB ASEA BROWN DOVERI 2
k July 13, 1990 L
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Docket No.- 70-1100 License-No. SNM-1067 Mr. Donald J.
Kasun, Acting Chief Domestic Safeguards and Regional oversight Branch Office of Nuclear Material Safety and Safeguards U.1 S. Nuclear. Regulatory Commission Attn:
Document Control Desk Washington, D.
C.
20555
Subject:
Response to Notice of Violation (Inspection Report No. 70-1100/90-201)
Reference:
Letter, D. J. Kasun (NRC) to C. R. Waterman (C-E), dated June 14, 1990
Dear Mr. Kasun:
Combustion Engineering has reviewed the Notice of Violation 1
received with the Reference letter, and our-reply is provided herewith (Enclosure I).
If I can be of further assistance on_this matter, please do
-not hesitate.to' call'me or Mr.~J. F. Conant, Manager, Nuclear Materials Licensing at (2 03 ) _ 2 8 5-5002 ~.
f very truly yours, C
U! TION E 4GINEERING, INC.
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/c au~ an Plant Ma ger Windsor clear el Manufactu REV:nly
Enclosure:
As Stated cc:
G. Bidinger (NRC)
J. Roth-(NRC - Region I)
M. Williams'(NRC) f0 ABB Combustion Engineering Nuclear Power q
Combust:on Engineenng ine-1000 Prospect Hdt Road Telephone (203) 688-1911 s
Post Offce Box 500 Fox (203) 285 9512 900h190240 900713' P
winosor, connecticH 060950500 Telex 09297 COMBEN WSOR PDR ADOCK'07001100 C~
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t' Enclosure I e
1i RESPONSE TO NOTICE OF VIOIATION (NRC INSPECTION REPORT NO. 70-1100/90-201)
I R
RESPONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT NO. 70-1100/90-201 YJ.g]Ation:
10 CFR 74.31(c)(8) requires the licensee to " Independently assess the effectiveness of the material control and accounting system at least every 24 months, and document management's action on prior assessment recommendations."
Paragraph 2 of the licensee's current Fundamental Nuclear Material Control Plan, (approved under 10 CFR Part 74) requires that this assessment be completed within 24 months of the completion of the previous assessment and specifies that the audit is complete when the final written report is submitted to the Vice President, Nuclear Fuel.
Contrary to these requirements, the licensee failed to complete the biennial nudit within 24 months of the previous audit.
Specifically, documentation of the January 1988 audit was dated March 7,1988, while documentation of the audit performed January 11-17, 1990 was completed after the beoinning of this inspection and dated May 8, 1990.
This exceeds the e4 months required.
Response
Although the physical performance of the biennial audit was completed within the allocated 24 month period, Combustion Engineering concurs that the documentation of audit results was not completed within the specified time period.
The delay in issuance of the audit report resulted from the auditor's heavy workload caused by Combustion Engineering's revitalization program at our Hematite, Missouri Nuclear Fuel Manufacturing Facility where the auditor is based.
Delays in
documentation and completion of MC&A biennial audits have not been a recurring problem. We believe the delay occurred because of the unusually heavy work mentioned and is not indicative of a degradation of our commitnmnt to the program, We will, nevertheless, in the future include the biennial audit requirement into a database which we use to formally track various plant activities.
It is our expectation that the necessary information will be entered in the database within 90 days, Combustion Engineering believes tha' the above circumstances will not be a factor when the next biennial audit is scheduled (January, 1992), and th'at the inclusion of the audit requirement in a database will assure performance of that audit in full compliance with license requirements in the future.
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