ML20127L048
| ML20127L048 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 01/22/1993 |
| From: | Carr C FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9301260316 | |
| Download: ML20127L048 (4) | |
Text
,Y BSW FUEL COMPANY ON I
An American Company with Worldwiss Resources P.O. Box 11646 Lynchburg. VA 24506-1646 Telephone: 804-522-6000 January 22, 1993 U.S.
Nuclear Regulatcry Commission ATTN:
Document Control Desk Washington D.C.
20555
REFERENCE:
NRC Inspection Report No. 70-1201/92-201, Reply to a Notice of Violation.
Gentlemen:
B&W Fuel Company drafted a written explanation and corrective action taken for the two violations that resulted from Inspection No. 70-1201/92-201.
However, the response was misplaced during the review process and was not mailed within the allotted 30 day response period.
Please accept my apology for any inconvenience that this may have caused you.
Attachment I addresses the violations in detail.
If questions should arise during your review, please feel free to contact either Kathryn Knapp (804-522-6202) or myself.
Sincerely, B&W FUEL COMPANY b
W C.
W.
Carr, Manager Commercial Nuclear Fuel Plant cc:
Stewart D.
Ebneter Regional Administrator, Region II USNRC 101 Marietta Street, N.W.
Atlanta, Georgia 30323 n
s 9301260316 930122 j/
l PDR ADOCK 07001201 L
C pgg
-. -~
t l a l
(
ATTACHMCNT I-l 1.
VIOLATION #92-201-03:
Section 5.9.7 of the licensee's FNMC Plan requires audits to be performed on a quarterly basis to-i verify the proper storage, application, documenta-tionfand destruction-of tamperseals.
In addition, procedure NM-1611, "Tampersafing of SNM," requires that a list of qualified tamperseal applicators be i
maintained by the NMC Tamperseal Custodian to-designate those personnel authorized to apply tamperseals.
Contrary to these requirements:
l (a) the licensee failed to perform three audits for the 1991 calendar year and
}
(b) six staff members have applied tamperseals regularly this year without being qualified j
(authorized) to do so.
f
RESPONSE
Admission or' Denial of the Alleaed Violation We acknowledge the validity of the facts contained in the notice of violation.
I Feason for Violation Due to the death of the.former Accountability j
Representative, there was-not an adequate transi-i tion period to train his' replacement therefore these items of responsicility_were not properly transferred to the new-Accountability Representa-l
- tive, i
Corrective _pteos Taken and Results Achieved The tamperseal audits are-now' scheduled to coin-1 cide with quarterly accountability records recon-I ciliation.
Individuals authorized to apply seals have'all been' qualified and properly documented.
A list of qualified individuals has beenLissued to i
supervision instructing _them that only personnel j
on the-list are authorized to applyLtamperseals.
i Corrective Steos that will be Taken and Results Achigyed l
j None.
b i
i
)
1
o i
The Date of Full Compliance We are in compliance at this time.
2.
VIOLATION #92-201-04:
Section 7.2.5 of the licensee's FNMC Plan speci-fies areas which are to be reviewed as a part of the biennial independent assessment of the licens-ee's MC&A program required by 10 CFR 74.31(c) (8).
Furthermore, Section 7.2.7 of the Plan requires final written report of the assessment to be sent to management within 60 calendar days of the com-pletion of the assessment (October 18, 1991).
contrary to these requirements:
(a) the audit report did not address all of the l
areas stipulated in Section 7.2.5 of the Plan, and (b) the final report (dated December 20, 1991) was not received within the 60 day critoria.
RESPONSE
Admission or Denial of the Alleced Violation i
We acknowledge the validity of the facts contained j
in the notice of violaticn.
Reason for Violation Prior to the NRC violation, we had decided that the quality and performance of the biennial inde-pendent assessment that our contractor had been conducting on nur program could be significantly improved.
To alleviate our concerns, we had opted to discontinue using Ernest and Young and contract Babcock & Wilcox to conduct the audit.
Personnel from their Nuclear Materials Control department met with us and agreed to perform the audits for us.
We believe that NNFD is better qualified and moro capable of conducting a thorough assessment.
In regards to the report date, there was a misun-derstanding of the audit completion date which initiates the clock for the 60 day criteria.
Ernest and Young did not feel that the completion date was when they left CNFP but rather when they concluded the audit at their home office.
The completion date is not clearly defined within the FNMC Plan.
After discussing this issue in the NRC inspection exit meeting, we agree that Ernest and Young's definition is inconsistent with the Plan.
l Corrective Steps Taken and Results Achieved As discussed above, we have changed contractors to conduct the audit and we will ensure that all issues are reviewed and that the report is re-ceived within the 60 day criteria.
Corrective Steos that will be Taken and Results Achieved None.
The Date of Full Compliance The next biennial independent assessment will be conducted in accordance with the criteria set forth in the Plan.
I r
4 4
4 d
h