ML20128D724
| ML20128D724 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 11/30/1992 |
| From: | Carr C FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9212070362 | |
| Download: ML20128D724 (4) | |
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(")B&W FUEL COMPANY ON
%b An Anecan Conveny wth Woddwede Restwres PO Das11640 tynchburg VA 245001640 Telephore BO4 522-G000 November 30, 1992 U.S.
Nuclear Regulatory Commission ATTH:
Document Control Dook Washington D.C.
20555 REFEREllCE:
NRC Inspection Report 110. 70-1201/92-201, Reply to a Notice of Violation.
Gentlemen Thin letter provides the written explanation and correctivo action taken for the two violations that resulted from Inspection No. 70-1201/92-201.
Attachment I addronnon the violations in detail.
If questions should arico during your review, ploaan fool froo to contact either Kathryn Knapp (304-522-6202) or myaolf.
Slncor,'y, D&W FUEL COMPANY
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C.
W. Carr, Manager Commercial Nuclear Frol Plant cc:
Stewart D.
Ebneter Regional Administrator, Region II USNRC l
101 Mariotta Street, N.W.
l_
Atlanta, Georgia 30323 l
QP 1
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9212070362 921130 PDR ADOCK 07001201 C
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s ATTACHMENT I 1.
VIOLATION #92-201-03 Section 5.9.7 of the licensoo's FHMC plan requires audits to be performed on a quarterly baals to vorify the proper storago, application, documenta-tion and destruction of tamperscals.
In addition, r
procoduro HM-1611, "Tamporuafing of SNM," requires that a lint of qualified tamperocal applicatora be maintained by the NMC Tamporocal Custodjan to doolgnato thoso personnel authorized to apply tamporneals.
Contrary to thoso requiremontal (a) the liconoco failed to perform three audits for the 1991 calendar year and (b) six staff members have applied tamparcoals regularly thin year without being qualified (authorized) to do so.
RESPONDE:
Admipolon or Denial _of tho_ Allo _ god Vinlation We acknowledge the validity-of the facto contained in the notico of violation.
Rengon for Violation Duo to the death of the former Accountability Representativo, thoro wan not an adoquato tranal-tion period to train his replacement thorofore those items of responsibility woro not proporly transferred to the now Accountability Roprosenta-tivo.
Entroctive Steps Taken and Results Achieved The tamperseal audito are now scheduled-to' coin-cide with quarterly accountability recordo recon-ciliation.
Individuals authorized to apply noals have all boon qualified and properly documented.
.A list of qualified individuals has boon _ issued to nupervision instructing them that only personnel on the lint are authorized to apply tamporacals.
Corrective Stens tha_t_W11.1 be Taken and_R_o_aults Antti.ny.ed Hono.
{
e The Date of rutt Compliante Wo are in compliance at this timo.
2.
VIOLATION #92-201-04:
Section 7.2.5 of the licensoo's FNHC Plan speci-fios areas which are to be reviewed as a part of the biennial indopondent assessmont of the licens-co's MC&A program required by 10 CFR 74.31(c) (8).
Furthermore, Section 7.2.7 of the Plan requiron final writton report of the assessment to be sont to management within 60 calendar days of the com-plation of the assessment (october 18, 1991).
contrary to those requirements:
(a) the nuoPc report did not addrean all of the 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.
R:CSPONSE:
Admission or Denial of the Alleged Violation We acknowledge the validity of the facts contained in the notice of violation.
Reason for Violation Prior to the NRC violation, we had decided that-the quality and performanco-of the bionnial indo-pondent assessment that our-contractor had boon conducting on our program could be significantly improved.
To_alloviate our concerns,-we had opted to discontinuo using Ernest and' Young and contract Babcock & Wilcox to conduct the audit. -Porsonnel from their Nuclear Materials. Control department-mot with us and agreed to perform the audits for-us.
We believe that NNFD is Letter. qualified and.
more capable of conducting a thorough assessment.
In regards to the report dato, there was a misun-darstanding of-the audit completion date=which initiates the clock for the 60 day critorja.
Ernest and Young did not fool-that the completion dato-was when they left CNFP but rather when they concluded:the audit at:their home offico.
The completion dato is not clearly defined within the FNMU Plan.
After discussing this issue in the NRC inspection exit mooting, we agroo that Ernest and Young's definition is inconsistent with the Plan, t
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co r r e c t i v e S t en_.Taken_and_Ren111trLAchiavril As discussed above, we have changed contractors to conduct the audit and we will ensure that all innuen are reviewed and that the report is re-coived within tho 60 day critoria.
CD r r e c t i y o Etcpn,._tlla t w ill_hD_l'a hen _aDILne n u 1 t n AclllRYeil liono.
Ille J2 ate of Pul1 Comp 11nac.e The next biennial indopondent announment will be conducted in accordance with the critoria not forth in the Plan.
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