ML20058D522
| ML20058D522 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse, 07001171 |
| Issue date: | 11/22/1993 |
| From: | Fici J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-93-034, CON-NRC-93-34 NUDOCS 9312030179 | |
| Download: ML20058D522 (4) | |
Text
__.
NRC-93-034 Westinghouse Commercial Nuclear Sawem Electric Corporation Fuel Division sph8 SgCasa 292M g
November 22,1993 U.S. NUCLEAR REGULATORY COMMISSION ATTN: Document Control Desk Washington, DC 20555
SUBJECT:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
NRC Inspection Report No. 70-1151/93-06 Docket No. 70-1151 -- License No. SNM-1107 Gentlemen:
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 formal response to your letter of October 15,1993, regarding your Region II Inspector C. H. Bassett's inspection of the Columbia Fuel Fabrication Facility, conducted during the periods August 16-20 and September 13-16, 1993.
In accordance with a telecon agreement between Mr. Cha;les Sanders of Westinghouse and Mr. Bassett on October 26, 1993, the response to the subject notice of violation has been extended to November 22,1993, because of a delay in our receipt of said notice.
j Appendix A of this document addresses the particular concern expressed in the NRC Notice of Violation that the corrective actions for the first event involving an accurnulation of powder were not sufficient to prevent another such event less that a month later. Appendix B provides our response to the apparent violations of NRC requirements specified in the Notice of Violation.
I hereby affirm that the statements made in this response are true and correct to the best of my knowledge and belief. Should you have any questions, or require additional information, please telephone me at (803) 776-2610.
I Sincerely, WESTINGHOUgE ELECTRIC CORPORATION
.a.=a mes A. Fici, Plant Manager Columbia Fuel Fabrication Facility j
Attachments: Appendices A and B 1
i CC:
U.S. Nuclear Regulatory Commission M[ 7 8 Regional Adnuaistrator 29 ioi m'i # =>
>8 AGanta, GA. 30m j
l Itte Msting!!ouse Commerch!NuclearfuelDii'ision - Winneroftrie 1988/Ja/colmBaldrige NationalOualityAward 9312030179 931122 PDR ADOCK 07001171 i
j C
PDR j
i
APPENDIX A RESPONSE TO CONCEILN In this Appendix, Westinghouse addresses the NRC concern that the corrective actions for the first event involving an accumulation of powder were not sufficient to prevent another such event less than a month later.
In the first event, a thorough root cause evaluation was conducted using a formal root cause analysis methodology. The causal factors and corrective actions are correct as summarized in the NRC Inspection Report. After the causal factors were determined, the root cause analysis report was turned over to the Pellet Area. Quality Action Group to determine al propriate restart, short term. and long term corrective aedons. These actions are correctly summarized in the NRC Inspection Report. The corrective actions were reviewed with cognizant Columbia Plant staff and area managcrs. The adequacy of tl e recommendations to correct the pellet enclosure problem was confirmed, and approval for restart was granted. At that time, management did not formally question whether a similar accumulation of powder could occu-in enclosures in other areas of the plant, and, if so, whether similar procedural, training, and preventive maintenance deficiencies existed. This faiture to question was in part due to the recognition that improvements to training, procedures, and preventive maintenance were already underway as part of the Criticality Safety Margin Improvemant Program (CSMIP). Had the questioning been done, the procedure inadequacies related to the inspection of the Fitzmill enclosure might have been uncovered prior to the second incident.
Area and staff managers are now more aware of the need to look beyond the specific equipment involved in an incident, and subsequent management reviews of root cause analyses have been conducted using a broader plant perspective.
A new procedure, RA-303, NUCLEAR l
CRITICALITY SAFETY SIGNIFICANT INCIDENT INVESTIGATIONS, which is currently routing for approvals, will further aid in assuring that precursor events are recognized.
l Immediately after the second incident (involving the powder accumulation in the Fitzmill l
enclosure), in addition to the root cause team, management commissioned a survey of all similar enclosures in the plant. The adequacy of the controls for these systems was ascertained and they are being strengthened where necessary. It should be noted that at this time, there is a heavy reliance on administrative controls to monitor these systems.
Until equipment integrity initiatives have been fully implemented and all practicable engireered I
controls have been installed, it will continue to be necessary to utilize administrative controls, such as effective operator inspections for accumulations of Special Nuclear Materials in i
unwanted locations, as a supplement to gaskets, seals, and engineered controls. In such cases, we will take rigorous measures to ensure that procedures and training are fully effective in providing operators the precise information they need to execute the administrative actions in i
a total quality manner.
l l
i C:\\WPDOC\\93-06RES.NOV l
l i
i l
i
l
\\
~
APPENDIX B WESTINGIIOUSE RESPONSE TO NOTICE OF VIOLATION 93-06 VIOLATION A:
The following information is provided in response to the Inspector's observation that "a Pellet Area operator was not adequately trained in that, on July 20,1993, the operator failed to realize that checking tne Line 3 Bulk Container Enclosure for accumulation of powder was a criticality safety control".
1.
The observation is correct as stated in the Notice of Violation.
l 2.
The reasoc for the observation was a failure to follow the provision of Section 3.2.5.5 i
of Ucenw SNM-1107 which states, " training shall be provided by the Radiation l
Protection component or line management to maintain a constant awareness by the employee of the necessity for radiation protection and nuclear criticality safety requirements and applicable portions of 10 CFR 19 and 20".
3.
Immediate actions to correct the observation, and results achieved, included:
Pellet Area personnel immediately shut down Line 3 and reported the accumulation.
It was verified and reported that there was no moderator present in the enclosure.
The powder accumulation was promptly removed.
A formal root cause investigation was conducted.
Appropriate restart, short-term, and long-term corrective actions were developed by the Pellet area Quality Action Group and approved by area and staff managers.
Restart actions were implemented, including training given to ADU Pellet Area personnel on August 12 and 13 addressing the visual inspection of the bulk container enclosure for UO2 Powder accumulation and emphasizing that the visual inspection of the enclosures is a nuclear criticality safety control.
4.
Actions taken, or planned, to prevent recurrence of events of the type observed include:
Complete implementation of the " Nuclear Criticality Safety (NCS) Training Program Overhaul" and " Plant Personnel NCS Training" initiatives outlined in the Columbia Plant Criticality Safety Margin Improvement Program, as discussed l
with NRC Region II and Headquarters representatives at our November 5,1993, l
Management Meeting.
1 5.
Full compliance was achieved on August 13,1993.
C:\\WPDOC\\934RES.NOV
~
VIOLATION B:
The following information is provided in response to the Inspector's observation that "during an approximately 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> period from third shift on August 11 through 4:00 a.m. on August 13, y
1993, opentors did not check for powder and water leaks several times during each shift inside the Fitzmill enclosure of ADU Conversion Line 5".
1.
The observation is correct as stated in the Notice of Violation.
2.
A Root Cause Analysis of the incident determined that the reason for the observation was a failure to follow the provision of Chapter 2, Section 2.6, of License SNM-1107 which states, "Special nuclear material processing shall be conducted in accordance with approved written procedures or instructions" provision of Chapter 2, Section 2.6 of License SNM-1107, due to uncertainty in procedural requirements.
3.
Immediate actions to correct the observation, and results achieved, included:
ADU Conversion Area personnel immediately shut down the line and reported the accumulation.
It was verified and reported that there was no moderator present in the enclosure.
l The powder accumulation was promptly removed.
A formal root cause investigation was conducted.
Appropriate restart, short-term, and long-term corrective actions were developed
[
by the Conversion area Quality Action Group and approved by area and staff l
managers.
l Restart actions were implemented, including, on August 13, issuance of a Supplementary Operating Instruction (SOI) to clarify inspection methods and specify the inspection frequency for the Fitzmill enclosures.
l 4.
Action taken, or planned, to prevent recurrence of events of the type observed include:
On August 22, the Fitzmill Operating Procedure was revised to include the new inspection requirements and issued along with a Controlled Form for logging inspections.
On August 23 and September 1, ADU Conversion Operators received training on the new inspection requirements and the Criticality Safety Significance of the i
inspections.
Complete implementation of the " Procedure Upgrades" initiatives outlined in the Columbia Plant Criticality Safety Margin Improvement Program, as discussed with NRC Region Il and Headquarters representatives at our November 5,1993, Management Meeting.
5.
Full compliance was achieved on August 13, 1993.
l C:\\WPDOC\\93-06RES.NOV l
u
-