ML20058M124
| ML20058M124 | |
| Person / Time | |
|---|---|
| Site: | 07000025 |
| Issue date: | 07/17/1990 |
| From: | Rutherford P ROCKWELL INTERNATIONAL CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20058M116 | List: |
| References | |
| NUDOCS 9008090368 | |
| Download: ML20058M124 (3) | |
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ypv Rocieldyhe O!vlelon Rockwell Intsen4po Cor Rockwell c Mc.@@porsuonE23International Telex 698478 ROCKETDfN CNPK July 17, 1990 In reply refer to 90RC08723 U. S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk
Subject:
NRC Inspection of the Santa Susana Field Laboratories, May 29 June 1, 1990.
Reply to a Notice of Violation.
Dear Sir:
Pursuant to the provisions of 10CFR2.201, Rockwell International Corporation hereby submits this written statement of explanation of Violation 90-01 01.
j liolation Part I, Section 2.8 of the SNM 21 license application requires thet quarterly reviews of the radiation safety program and the radiological environmental monitoring program be performed by the radiation safety manager or his designee.
Rockwell performed the required quarterly reviews for the first and second quarters of 1989. However, these reviews were cor.sidered by the inspector to be untimely since they had not been completed within the following quarter.
In addition, no such reviews had been performed f# the third and fourth
- quarters of 1989 at the time of the inspection.
Failure to conduct timely i
l reviews for the first and second quarters of 1989, and failure to perform the 1989 third and fourth quarter reviews, were identifiea as an apparent violation of License Condition 9 (70-25/90-01-01).
Reason for Violation The subject quarterly reviews are a self-audit process, which Rockwell committed to perform in our license application.
Such quarterly reviews are not mandated by the NRC in 10CFR20 or 10CFR70 and are not required to be sent to the NRC.
Furthermore, neither the license application nor the regulations specify any period by which the review reports must be completed. This j
inspection was the first at which the three-month reporting period was i
introduced by the NRC inspector.
Delaying of these internal reviews had been a conscious decision by management because of higher priority work created by high levels of media attention that l
has been directed at the SSFL since May 1989.
It is important to note, h
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90RC08723 July 17, 1990 Page 2 j
however, that the consequences of this delay (namely violation) were not L
recognized by management because no time limit had been assigned to these L
reviews before.
In fact, it was generally believed that, because of the low L
levels of radiation present at SSFL, the reviews could be deferred without b
incurring any real safety consequences.
If the NRC interpretation of the time
' limit for these reviews had been predicted, this would have affected the priority assignments of these tasks and they would not have been delayed.
1 Corrective Steos Taken ard Results Achieved Recently, three individuals have been loaned by other departments to provide short term suppo*t to the Radiation and Nuclear Safety unit (R&NS) for the understaffing situation.
In addition, this month a recent retiree (who had previously prepa7ed these reports) has returned as a part time employee and l
has been assigned the task completing the delinquent reviews.
Immediately after the exit briefing on June 1,1990, AI/ETEC QA was assigned oversight responsibility of the R&NS unit. One of the first actions by QA was to compile.a matrix of requirements to " implementing procedures." This will facilitate future audits of R&NS by QA.
Corrective action has~ also been implemented by establishing a database file of l
all license action in ETEC's Agreement and Commitment system.
The system issues monthly reports of upcoming, currently due and past due action items to regularly apprise management of our commitment status.
Requirements from our
)
implementing procedures, contracts, and licenses will be the subject of continuing QA surveillance.
]
[orrective Steos to be Taken to Avoid Further Violations While we recognize the value of preparing these reports as soon after the end of the quarter as practical, certain data, resulting from analyses performed by outside laboratories., such as bioassay, are not always available within three months of the end of the subject quarter. The NRC imposed three-month submission period is therefore not always achievable.
Nevertheless, given the l'
new requirement, once the backlog of reviews is completed, future reviews will be issued within the three-month period and revised later to incorporate any late data.
l Date When Full,Comoliance will be Achieved It is estimated that the overdue 1989 and the 1990 review reports will be completed br the following dates:
3rd quarter 1989 '
4th quarter 1989 September 1, 1990 1st quarter 1990 g
.v 4
90Lt08723 July 17, 1990 Page 3 2nd quarter 1990 October 15, 1990 Annual Review 1989 November 30, 1990 3rd quarter 1990 December 31, 1990 As.shown above, completing a backlog of three reports will result in a slight two week delay to desired schedule for the 2nd quarter,1990 report; however, the schedule should be fully caught up by the completion of the 3rd quarter report.
Rockwell reiterates its desire to work with the NRC t.s well as other regulatory agencies to ensure that it complies with regulations and maintains a good working relationship with open levels of comunication.
If you have any further questions, please do not hr:sitate to call me at (818) 718-3413.
Very truly yours, ROCKWELL INTERNATIONAL Rocketdyne Division V0 k-IhfA-d P. D. Rutherford, Manager Nuclear Safety & Reliability Engineering PDR:dr cc Regional Administrator NRC Region V Gregory P. Yuhas NRC-Region V I
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