ML20125D794
| ML20125D794 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 12/11/1992 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9212160037 | |
| Download: ML20125D794 (4) | |
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December 11,1992 i
U.S. Nuclear Regulatory Commission Document Control Desk i
Washington, D.C. 20555 -
Subject:
REPLY TO NOTICE OF VIOIATION
References:
(1) NRC License SNM-1097, Docket 70-1113 l
(2) NRC Inspection Report 70-1113/92-16 dtd 11/13/92 i
GE Nuclear Energy is responding to the Notice of Violation resulting from the inspection conducted at our licensed fuel fabrication plant by.
l Mr. G. L. Troup of your office October 12-16, 1992.
i Our reply to the items of apparent noncompliance with NRC requirements -
is given in the attachment to this letter. In addition, our response j
describes particular actions taken and planned to further improve and j
place a high level of management attention on " criticality safety -
requirements" identified in our procedures.-
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The inspection report comments and suggestions are helpful to us in our constant efforts to improve our programs, ensure the continued health -
and safety of plant personnel, and ensure our compliance with NRC t
L regulations and license conditions.
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-Your inspection report referred to above does not contain information which we believe to be proprietary.
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L-We welcome further discussions.with you or your staff on our reply, if l
appropriate.
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Sincerely, i
GE NUCLEAR ENERGY W
Akm L
150093 T. Preston winslow, Manager Licensing & Nuclear Materials Management eI 1/sbm cc:
Stewart D. Ebneter, Region II g
TPW-92-160 9212160037 921211-
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U.S. Nuclear Regulatory Commission Document Control Desk December 11,1992 Page 1 of 3 ATI'ACHMENT 1 The information given below refers to items in Enclosure 1, " Notice of i
Violation", from NRC Inspection Report 70-1113/92-16 dated November 13, 1992.
License Condition Number (No.) 9 of Special Nuclear Materials (SNM)
License No. SNM-1097 requires that licensed material be used in accordance with statements, representations, and conditions of Part I of the application dated October 23,1987, and supplements thereto.
Part I, Chapter 2, Section 2.7 of the application requires that licensed material processing be conducted in accordance with the properly issued procedures or instructions.
Contrary to the above, the following examples of failure to conduct surveillances and inspections in accordance with the requirements of approved procedures were identified.
1.
The Vessel Off Gas (VOG) was not inspected for solids accumulation as required by PROD 102.08, during the months of May and September
.1992.
2.
The Nitrate Waste Permeate Tank was not sampled for the presence of organic solvents as required by PROD 80.77 during the months of May and September 1992.
3.
The VOG condenser gas exit temperature was not recorded during each shift sa required by PROD 102.08 during the period July 7 - October 13,1992.
4.
The Aqueous Waste Quarantine Tanks were not drained and Inspected for organic solvent as required by PROD 103.07 during the period
.. aptember 20 - October 14,1992.
This is a Severity Level IV violation (Supplement VI).
GE Response For the cited examples, operators failed to document log entries for j
Nuclear Safety Release / Requirements (NSR/R) due to responsibility l
assignments and system follow-up being inadequately clear for the volume j
and complexity of these tasks.
U.S. Nuclear Regulatory Commission Document Control Desk December 11,1992 Page 2 of 3 Based on our mode of operation and a review of the complexity oflogging/
recording requirements, we determined that an. automated database was needed as the key correcuve action to support and improve management control in this area. Operations and Criticality Safety personnel performed an extensive review to develop the database for NSR/R logging, data recording, inspection, and/or recordkeeping requirements. ne database, sorted by area, will be distributed to the responsible managers and supervision to serve as a checklist and self audit tool by the shop __
operational units.~ The results of the shop operation self audits will be '
reported through the management chain with a monthly summary distributed to other management functions. The database has been established and the initial self audits have been started. The requirements for maintenance -
of the database, sh_op operation self audit, and distribution of routine reports will be formalized in our internal procedures by January 31, 1993.
In addition to the "NSR/R Requirements" database feature described, the following actions have been taken to improve management controls:
1)
The manager of Fuel Chemical Manufacturing conducted meetings with
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his managers, area coordinators and individual contributors to emphasize the seriousness and needs for strict adherence' to procedural requirements. He also discussed the internal and external consequences for failure to follow procedures.
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2)
Effective November 2,1992, a Compliance Auditing function was established within the Regulatory Compliance organization. Th_e -
l function is staffed by three fully qualified auditors with more than l
60 years nuclear experience.
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Weir responsibiliues are to conduct programmatic, system audits for L
the various criticality, radiological, and environmental programs
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initially concentrating on verification of procedural conformance.
l 3)
Effective November 9,1992, the Area Manager responsibilities for the-
- Fuel Chemical' area were appointed to the operational managers of 4
Powder Production, URLS Operation Environmental Programs and-Technical Resources. The reassignments will provide for a narrower scope of responsibility and more effective execution of their-management control responsibility for the assigned operations.
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9 U.S. Nuclear Regulatory Commission Document Control Desk -
December 11,1992 Page 3 of 3 4)
Effective November 2,1992, the Manager, Reclaim and Support'was given a temporary assignment to accelerate our process established in the PIP for procedure simplification and new training programs for -
operators. We Program Manager, Compliance Improvement was also assigned to assist in this effort.
These actions will be completed to further ensure full comp _11ance by 1/31/93.
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