ML20056C903
| ML20056C903 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 07/13/1993 |
| From: | Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| References | |
| NUDOCS 9307260118 | |
| Download: ML20056C903 (2) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
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E REGION V 1450 MARIA t#4E T,.
WALNUT CREEK.CAUFORNIA 94596-5368 4,,,,,
JUL 131993 Docket No. 70-1257 License No. SNM-1227 Siemens Power Corporation 2101 !!orn Rapids Road P. O. Box 130 Richland, Washington 99352-0130 Atfention: Mr. L. J. Maas, Manager 3
Regulatory Compliance RESPONSE TO NOTICE OF VIOLATION CONTAINED IN NRC INSPECTION
Subject:
REPORT NO. 70-1257/93-03 Thank you for your letter dated July 6,1993, in response to our Notice of 70-1257/93-03, dated June 7, 1993, Violation and Inspection Report No.
informing us of the steps you have taken to correct the items which we brought to your attention.
Your ' corrective actions appear to resolve our concerns regarding the violation referenced in the subject report.
Your corrective actions will be reviewed during a future' inspection.
Your cooperation with us is appreciated.
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a i ities Radiological Protection Branch g-cc:
State of Washington 9307260118 930713
PDR C
.ADOCK 07001257 PDG
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JUL 1353S3 Docket No. 70-1257-License f00. SNM-1227' Siemens Power Corporation 2101 Horn Rapids Road P. O. Box 130 Richland, Washington 99352-0130 8
Attention: Mr.jl. J. Maas, Manager Regulatory Compliance
Subject:
RESPONSE TO NOTICE OF VIOLATION CONTAINED IN NRC' INSPECTION REPORT NO. 'G-1257/93-03 Thank you for your letter dated July 6,1993, in response to our Notice of Violation and Inspection Report No. 70-1257/93-03, dated June 7, 1993,-
. informing us of'the steps you have taken to correct the-items which we brought to your attention.
Your corrective actions appear to resolve our concerns regarding 'the violation referenced in the subject report. Your corrective actions will be reviewed during_a future inspection.
Your cooperation with us is appreciated.
Sincerely, t
James H. Reese, Chief Facilities Radiological Protection i
Branch cc:
State of Washington bec w/ copy of letter dated July 6,1993:
PDR Inspection File M. Adams, NMSS G. Cook B. Faulkenberry cc w/o copy of. letter dated July 6,1993:
M. Smith
' REGION-V
.CHooker J ese
-7/43/93 3
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l July 6,1993 U.S. Nuclear Regulatory Commission
- Attn: Document Control Desk Washington, DC 20555
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Gentlemen:
Letter, J.H. Reese to Siemens Power Corporation,' Notice of Violation NRC inspection Re:
' 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 cont 6ct me at 509-375-8537.
Very)truly yours, l
L J. Maas, Manager Regulatory Compliance LJM:pm cc:
B. H. Faulkenberry Region V Administrator
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!Siemensl Power Corporation Nuclear. Division Engineering afd Manufacturing Faciliy.
2101 H'orn Rapids Road PO Box 130 ' RicNand. WA 993520130. Tet (509) 375 8100 Fex (509) 375-8402 J
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i REPLY TO NOTICE OF VIOLATION (93-03)
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Statement of Violation 93-03-01 A. Ucense Condition No. 9 of Ucense No. SNM-1227 authorizes the use of licensed 4
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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
'l training related to their radiation protection assignment. Previous training is acceptedif 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 j
Advanced Nuclear Fuels radiation protection and criticality safety programs, specifications, procedures, and routines, as demonstratpd by successfully q
passing a Advanced Nuclear Fuels certification examination within six months.
j 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 Stoos De Supervisor of Radiological Safety reviewed the training status of the HSTs. Based on 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
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Statement of Violation 93-03-05 C.10 CFR 71.87(j) requires that prior to each shipment of licensed material, the t
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 licensee maintain for a period of three -
years after shipment a record of each shipment of licensed material showing the l
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).
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 measurements is the fact that there was no place on the Radioactive Shipment Record (RSR) form 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 Steps
. Traffic and Warehousing personnel and HSTs hav9 been re-instructed on survey requirements for radioactive material shipments.
s Corrective Steps to Avoid Further Violations The RSR form has been redesigned to provide specific space for radioactive survey resuits 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.
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Date to be in Full Compliance SPC willimpose 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.
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