ML20137D626
| ML20137D626 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 03/21/1997 |
| From: | Carr C FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| NUDOCS 9703260242 | |
| Download: ML20137D626 (14) | |
Text
8 PDK F R AM ATOM E C OG EM A F U E LS fgg l
March 21,1997 g
Mr. James Lieberman Director, Office of Enforcement United States Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, MD 20852-2738
Subject:
Reply to a Notice of Violation and Payment of Civil Penalty - NRC 1nspection Report No. 70-1201/96-202
References:
1.
Confirmatory Action Letter No. H-96-001; from Dr. Carl J. Paperiello, USNRC to Mr. Charles W. Carr, FCF; dated November 20,1996 2.
Framatome Cogema Fuels' Response to Confirmatory Action Letter No.
H-96-001; from Ms. G. F. Elliott, FCF to Mr. Philip Ting, USNRC; dated November 27,1996 3.
Addendum to Confirmatory Action Letter No. H-96-001 from Ms.
Elizabeth Q. Ten Eyck, USNRC to Mr. Charles W. Carr, FCF; dated December 3,1996 j
4.
Response to CAL No. H-06-001; Docket No. 70-1201; License No. SNM-
[
l168; Letter From C. W. Carr, FCF to Elizabeth Q. Ten Eyck, USNRC dated December 20,1996 5.
Notice of Violation and Proposed Imposition of Civil Penalty Letter from Elizabeth Q. Ten Eyck, USNRC, to C. W. Carr, FCF; dated March 4, 1997.
6.
Reply to Addendum of CAL No. H-96-001, Letter from Elizabeth Q.
Ten Eyck, USNRC, to C. W. Carr, FCF; Dated January 22,1997.
j
Dear Mr. Lieberman:
In response to your letter dated March 4,1997, Framatome Cogema Fuels (FCF) has addressed each of the five violations outlined in the Reference 5, Notice of Violation. Attachment I identifies each of the violations, addresses admission of each violation, describes the reasons for each 9703260242 970312 PDR ADOCK 0700 1
'/
//,,
~O'
llEl,El[E![QEllllllll,0.5 Frematome Cogema Fuela EC 4 OL0 E
Te ephon 0 832 5000 Fa 80 8 5167
violation, and further identifies corrective actions taken and corrective actions to be taken. The immediate results achieved from the corrective actions are the modification and improvement of administrative procedures which implement increased management oversight. The attitudes of management have been positively effected in the near term. Results in the long term will be assessed by continued self assessments and internal audits.
The civil penalty in the amount of $12,500 is paid herewith in accordance with the instructions referenced in the Notice of Violation.
1 The management of Framatome Cogema Fuels is extremely concerned about the violations of NRC requirements and the deficiencies cited in our various program areas. We have incorporated numerous improvements into our programs and are working proactively to assure a i
similar incident will not occur in the future. Although the inadvertent return of the assembly occurred during non-routine downloading operations, FCF is reviewing all program areas for identification ofweaknesses. The corrective actions discussed in Attachment 1 are essentially those included in Reference 4 and discussed at the Predecisional Enforcement Conference on January 27,1997. Specifically, our corrective actions included: (1) initiation of a management oversight team and a self assessment team to assure that effective investigation would be performed and comprehensive corrective actions taken;(2) institution of a formalized examination and modification of administrative controls, procedures, and methods with emphasis on evaluation of risk in situations where conditions are changing or are non-standard; (3) revision of employee training syllabus to emphasize the need and importance of adequate procedures and strict adherence to procedures; (4) e tablishment of procedural requirements through full authority and control of a quality assurance plan for all operations involving SNM; (5) revision of all procedures relating to the downloading operation, radiation protection and survey, and shipping oflicensed materials, to provide necessary details, independent verification, and sign-offs; and (6) revision of the Fundamental Nuclear Material Control Plan to correct deficiencies in the control program of SNM. FCF is committed to these improvements and to improved management oversight with i
proactive problem identification and resolution.
l As we go forward, the findings of the Self Assessment Teams, both internal and external, will be
(
incorporated into procedures and practices to further improve our performance with regulatory l
requirements.
The Overarching Root Cause discussed at the Predecisional Enforcement Conference, in response to Ms. Ten Eyck's letter, dated January 22,1997, was a deficiency in routine and special l
management oversight of operations including risk assessment and risk management. The key specific corrective action which addresses this issue is the change to administrative procedures and management follow-up which assure that all licensed activities are performed under the Quality Assurance Plan. Supporting that action are the administrative procedures which improve management involvement in planning and risk analysis for non-standard work which is executed in our facility. Management is also committed to being much more sensitive to perceptions of employees about the importance of certain non-standard jobs involving SNM.
2
- As discussed between G.F. Elliott, FCF and T.N. Pham, NRC, the follow-up inspection visit is scheduled for March 25th through March 27th.
Sh' uld you have any questions or comments, please feel free to contact me at (804) 832-5015.
o FRAMATOME COGEMA FUELS Lynchburg Manufacturing Facility Charles W. Carr Vice-President, Manufacturing &
Field Service cc:
Ms. E.Q. Ten Eyck - USNRC, Director, FCSS Mr. E.J. McAlpine - USNRC, Region II Mr. P.X. Ting - USNRC, Chief, Operations Branch Dr. C. A. Paperiello - USNRC, Director NMSS I
Attachment Encl..
l
)
i l
I I
l i
i '
4-J 3
1 4
l l
ATTACHMENT to Reply to a Notice of Violation l
NRC Inspection Report No. 70-1201/96-202 i
l Violation No. 96-201-01:
The licensee failed to follow its own procedures for the downloading operation.
Admission of the Violation:
i l
Framatome Cogema Fuels concurs with the facts contained in the NRC Notic; of l
Violation dated March 4,1997 Reason (s) for the Violation:
l l
1)
The Manufacturing Operator failed to follow the guidelines established in l
Procedure MA-587, Revision 0, " Handling of NUKEM Shipping Container" which l
stated to remove each assembly from the containers.
l t
2)
The Safety & Licensing Monitor failed to follow the guidelines established in Procedure RP-007, Revision 03, " Shipment and Receipt of Radioactive Materials",
which stated that smears must be performed on the inside of all containers.
3)
Lack of adequate formal training of the Manufacturing and Safety & Licensing Operators was a factor in improper implementation of the procedures.
l 4)
Unfamiliarity with container design contributed to leaving an assembly in the container.
5)
The use ofinexperienced employees unloading the containers contributed to the violation.
Corrective Action (s) Taken:
1)
The Manufacturing Operator and the Safety & Licensing Monitor involved in the j
event have been informed of their mistakes and re-instructed on the importance of l
following procedures.
2)
Re-training has been conducted on the following new or revised procedures and procedure compliance has been stressed with all personnel.
a)
Admin.. Proc.. 0310-47,0310-51,0310-52 b)
RP-007 and NM-1671 c)
MA-587 and MA-592 d)
Route Cards #11859 and #11876 4
I
l
'9 3)
Management will assure that adequately experienced personnel are used as shift leaders.
4)
Administrative Procedure 0310-51 has been implemented for Non-Standard contracts to incorporate the following: 1) Prior to starting work the managers of Manufacturing Engineering, Fuel Manufacturing, Quality, and Safety & Licensing shall review the requirements to determine the level of risk involved and the amount of management and supervisory oversight and coordination required. 2)
Written guidelines based on the job complexity are required to determine the required supervision. 3) Special responsibilities for supervisors / team leaders are identified.
5)
Administrative Procedure 0310-52 has been implemented to incorporate the following for each Non-Standard contract and project: 1) Pre-job meeting with the required personnel involved to discuss planning, procedures, and any concerns.
- 2) A pre-job check list. This willinclude approved procedures, adequate documentation, training, hardware configuration and will recognize the coordination of the involved departments. 3) A follow-up meeting to examine process improvement after the first complete download sequence of assemblies (including planning, procedures, training, documentation, inter-departmental coordination, and hardware configuration). 4) Close-out meetings at project completion concerning lessons learned.
6)
Route Card #11876, Route Card # 11859, and Procedures MA-587 and MA-592, were revised or written to include work sequencing steps, independent
)
verifications, details of the unloading process, signatures and dates for each
]
completion ofindividual steps, and reference Route Card steps to the appropriate procedures.
j 7)
The general employee training syllabus was revised to emphasize the importance of procedures, why they are necessary, and consequences of noncompliance.
8)
Supervisors / team leaders will be trained on an on-going basis in accordance with basic supervision skills determined by management.
9)
The availability of procedures on the shop floor will be improved for all operations on an on-going basis.
Full Compliance Date Full compliance was achieved March 21,1997 including initial implementation of those items which will remain on-going.
2
I t-l Violation No. %202-02:
The licensee failed to provide adequate and detailed procedures for the downloading operation.
Admission of the Violation:
Framatome Cogema Fuels concurs with the facts contained in the NRC Notice of Violation dated March 4,1997.
]
l:
l Reason (s) for the Violation:
1)
The VVER downloading job was based on FCFs experience with five previous downloading jobs where the assemblies were already at the facility or were received in familiar containers. Individuals involved with the work on the plant l
' floor did not recognize the potential for leaving an assembly in this shipping container.
2)
The Quality Assurance Program was not applied to this operation.
t-l 3)
There were no independent verification steps provided in the routing document, l
Route Card #11876, Revision 0, to verify the removal of the assembly from the l
container.
4)
. The Manufacturing Procedure, MA-587, Revision 0, " Handling ofNUKEM i
Shipping Container", provided inadequate detail to ensure that operator error would not result in an inadvertent shipment of an assembly, 5)
The Safety & Licensing Procedure, RP-007, Revision 03, " Shipment and Receipt L
of Radioactive Materials", provided inadequate detail on what to do if the empty l
' container limits are exceeded.
l 6)
Procedures did not require a log in of the assembly at the point of storage.
- 7) -
Storage in the rack was not originally part of the plan for this download job. The need to remove and store the assemblies was created by a change in plans which i
j was driven by the schedule. A review of the procedures and methods was not made when plans char.ged.
i i
3
=. - - - -
Violation No. 96-202-02 (Continued):
Corrective Action (s) Taken:
1 1)
Release Authorization 100-000879-00 was revised to specifically involve all applicable Quality Assurance Plan elements on the VVER download process.
2)
Procedure 0310-47, " Sales Orders / Release Authorizations" was revised to require that all operations with SNM be classified as Safety Related.
3)
~ Manufacturing Engineering Administrative Procedures were revised to state that Manufacturing Engineering will not release final Route Cards or Procedures until the Release Authorization is received and reviewed.
i 4)
Route Card #11876, Route Card # 11859, and Procedures MA-587 and MA-592, were revised or written to include work sequencing steps, independent verifications, details of the unloading process, signatures and oates for each completion ofindividual steps, and reference Route Card steps to the appropriate procedures.
5)
. Safety & Licensing Procedure, RP-007, was revised to define the actions to be taken'when the surveys determine containers exceed the specified radiological on limits.
6)
Training has been conducted on the revised Procedures and Route Cards.
Procedure compliance has been stressed with all personnel.
7)
Nuclear Material Control procedure NM-1671 has been implemented to require a log and location system for SNM in the fuel assembly storage rack as a primary i
control.
8)
Administrative Procedure 0310-51 has been implemented for Non-Standard contracts to incorporate the following: 1) Prior to starting work the managers of Manufacturing Engineering, Fuel Manufacturing, Quality, and Safety & Licensing will review the requirements to determine the level of risk involved and the a
amount ofmanagement and supervisory oversight and coordination required. 2)
Written guidelines based on the job complexity are required to determine the required supervision. 3) Special responsibilities for supervisors / team leaders are identified.
4 i
a i*
i
- Violation No. 96-202-02 (Continued):
9)
- Administrative Procedure 0310-52 has been implemented to incorporate the.
following for each Non-Standard contract and project: 1) Pre-job meeting with 4
the required personnel involved to discuss planning, procedures, and any concerns.
- 2) A pre-job check list. This willinclude approved procedures, adequate documentation, training, hardware configuration and 'will recognize the coordination of the involved departments. 3) A follow-up meeting to examine process improvement aRer the first complete download sequence of assemblies (including planning, procedures, training, documentation, inter-departmental coordination, and hardware configuration). 4) Close-out meetings at project j
completion concerning lessons learned.
j 10)
Supervisors / team leaders will be trained in accordance with basic supervision skills determined by management.
Full Compliance Date:
Full compliance was achieved March 21,1997 including initial impleme s.tation of those items w~hich will remain on-going.
)
i 5
i Violation No. 96-202-03:
The licensee failed to adequately evaluate the results of the radiological survey of container #440/70-30.
Admission of the Violation:
Framatome Cogema Fuels concurs with the facts contained in the NRC Notice of Violation dated March 4,1997.
Reason (s) for the Violation:
1)
The Safety & Licensing Procedure, RP-007, Revision 3, " Shipment and Receipt of Radioactive Materials", was not detailed enough to address wiiat to do if the empty container limits are exceeded.
2)
Upon notification by the Safety and Licensing Monitor to the Health Physicist that the external surveys exceeded the limits established for an empty container, the Health Physicist did not ensure that all containers were opened and surveyed in accordance with Procedure RP-007, Revision 3, " Shipment and Receipt of Radioactive Materials" 3)
Unfamiliarity with container #440/70 resulted in not adequately assuring the container was properly surveyed.
Corrective Action (s) Taken:
1)
Safety & Licensing Procedure, RP-007, was revised to further define the actions to be taken when the surveys determine that empty containers exceed the specified radiological limits. Also incorporated in this procedure are precautions to take for unique containers.
2)
Safety & Licensing Monitors and Health Physicists have been informed on the importance of stopping work iflimits are exceeded until the events are resolved.
3)
The Safety & Licensing organization has been changed to provide for clear responsibility to assure that qualified personnel review all surveys and shipping documentation prior to release for shipment.
4)
Plant Health Physicist personnel have been trained on applicable Department of Transportation (DOT) requirements.
6
l l
Violation No. 96-202-03 (Continued):
5)
Administrative Procedure 0310-51 has been implemented for Non-Standard contracts to incorporate the following: 1) Prior to staning work the managers of Manufacturing Engineering, Fuel Manufacturing, Quality, and Safety & Licensing shall review the requirements to determine the level of risk involved and the amount of management and supervisory oversight and coordination required.
- 2) Written guidelines based on the job complexity are required to determine the required supervision. 3) Special responsibilities for supervisors / team leaders are identified.
6)
Safety and Licensing Procedures will be implemented to address requirements of 10 CFR 70 and 71 and how the requirements are incorporated into the applicable procedures. The Procedures will also address the documentation of management review of changes made to the applicable regulations.
Full Ccmpliance Date:
Full compliance was achieved MarcF 'i 1,1997 with the exception of Safety and Licensing procedures which will be implemented by April 30,1997.
1 7
Violation No. 96-202-04:
The licensee failed to comply with numerous requirements of the shipment oflicensed material.
Admission of the Violation:
Framatome Cogema Fuels concurs with the facts contained in the NRC Notice of
. Violation dated March 4,1997.
. Reason (s) for the Violation:
1).
Manufacturing Operator failed to remove the assembly from the container per the -
manufacturing procedure which ultimately resulted in the assembly remaining in the container and subsequently being shipped as free released.
2)
The Safety & Licensing Monitor failed to survey the internals of each empty container per the requirements of RP-007, Revision 3, " Shipment and Receipt of Radioactive Materials", which resulted in the assembly remaining in the container.
.3)
The Safety & Licensing Procedure, RP-007, Revision 3, " Shipment and Receipt of Radioactive Materials", did not provide adequate details to address what to do if the radiological limits are exceeded.
4)
Unfamiliarity with container design contributed to leaving an assembly in the container.
5)
Shipping papers were not released by the Health Physicist.
6)
Subsequent to notifying the Safety & Licensing Monitor to perform the surveys, Manufacturing assumed the surveys were complete and adequate and therefore notified Production and Inventory Control to ship the container.
Corrective Action (s) Taken:
1)
Safety & Licensing Procedure, RP-007, was revised to further define the actions to be taken when the surveys determine empty containers exceed the specified radiologicallimits.
8
L Violation No. 96-202-04 (Continued):
' 2)
The routing document, RC #11876, was revised to incorporate Safety & Licensing
. steps into the process for sign-off prior to release of the containers for shipment by the Health Physicist.
3)
The Safety & Licensing procedures have been changed to assure qualified
~
personnel review all suiveys and shipping documentation prior to release for-shipment.
4)
Plant Health Physicist personnel have been trained on applicable Department of
- Transportation (DOT) requirements.
5)'
A Self-Assessment Team was established to review nuclear materials control criteria and verify.the incorporation of the requirements into applicable procedures.
The effort has been completed and a report submitted to management.
6)
Procedures for Radiation Protection and shipping oflicensed material were revised to verify proper handling and marking.
7)
Administrative Procedure 0310-51 has been implemented for Non-Standard contracts to incorporate the following: 1) Prior to starting work the managers of Ma'nufacturing Engineering, Fuel Manufacturing, Quality, and Safety & Licensing shall review the requirements to determine the level of risk involved and the -
amount of management and supervisory oversight and coordination required. 2)
Written guidelines based on thejob complexity are required to determine the required supervision. 3) Special responsibilities for supervisors / team leaders are identified.
^
8)-
Safety and Licensing Procedures will be implemented to address requirements of 10 CFR 70 and 71 and 49 and describe how the requirements are incorporated into the applicable procedures. The procedures will also address the documentation of management review of changes made to the applicable regulations.
Full Compliance Date:
i Full compliance will be achieved May 31,1997.
i 9
i
I Violation No. 96-202-05:
The licensee failed to implement adequate MC&A procedures and practices to verify the presence offuel assembly #31908.
Admission of the Violation:
Framatome Cogema Fuels concurs with the facts contained in the Report Details of the NRC Notice of Violation dated March 4,1997.
Reason (s) for the Violation:
1)
Inadequate management oversight contributed to the violation.
2)
The item control program as described in the Fundamental Nuclear Materials Control Plan failed to detect the assembly as missing.
3)
There were no routine item audits or item verifications checks conducted during the course of the downloading operations.
Corrective Action (s) Taken:
1)
An independent outside consultant has reviewed the MC&A program to determine weaknesses not previously identified and provide recommendations.
2)
A Self-Assessment Team was established to review nuclear materials control criteria and verify the incorporation of the requirements into applicable procedures.
The effort has been completed and a report submitted to management.
3)
Nuclear Material Control procedure NM-1671 has been implemented to require a log and location system for SNM in the fuel assembly storage rack as a primary control.
Corrective Action (s) to be Taken:
l.
Comments and observations resulting from the Self-Assessment Report will be incorporated into the applicable documents.
2.
Comments and observations resulting from the Outside Independent Assessment will be incorporated into the applicable documents.
10
Violation No. 96-202-05 (Continued):
3)
The scope of the required biennial audit, due this year, willinclude reviewing the MC&A program for adequacy in non-routine operations as well as the normal fuel operations.
Full Compliance Date:
1 Full compliance will be achieved July 31,1997 for Corrective Actions I and 2. Corrective Action 3 completion is scheduled for the third quarter of 1997.
i 11 l
\\
.