ML20137G844
| ML20137G844 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 03/27/1997 |
| From: | Fici J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-97-013, CON-NRC-97-13 NUDOCS 9704010543 | |
| Download: ML20137G844 (7) | |
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W85tingh0USS Commercial Nuclear Fuel Division i
h@@tl0D Drawer R Columbia South Carolina 29250 i
i March 27, 1997 5803> 776 2610 l
NRC-97-013 U.S. NUCLEAR REGULATORY COMMISSION ATTN:
Document Control Desk Washington, DC 20555 Gentlemen:
SUBJECT:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
REPORT NO: 70-1151/97-01 i
Pursuant to the provisions delineated in Section 2.201 of the NRC's " Rules of Practice",
Part 2,
Title 10, Code of Federal Regulations, Westinghouse herein provides formal response to your l
letter of March 6, 1997, regarding your inspection of the Columbia l
Fuel Fabrication Facility conducted during the period of February, 3-6, 1997.
Appendix A provides our responses to the violations of NRC i
requirements identified in the Notice of Violation.
Appendix B provides information regarding the statements in your letter regarding effective corrective actions and failures to follow l
procedures concerning the discovery of gum and candy wrappers; and the lack of oversight of regulatory requirements concerning shipping container inspections.
I hereby affirm that the statements made in this response are true and correct to the best of my knowledge and belief.
Should you i
have any questions or require additional information, please
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l telephone Mr. Wilbur L.
Goodwin of my Staff at (803) 776-2610 i
j Ext. 3282.
i Sincerely, I
l WESTINGHOUSE ELECTRIC CORPORATION i
es A.
Fici, Plant Manager Columbia Fuel Fabrication Facility i
Attachments:
Appendix A Appendix B 1
/
cc:
U.S. Nuclear Regulatory Commission
(
Regional Administrator 101 Marietta Street, NW Atlanta, GA 30323 9704010543 970327 PDR ADOCK 07001151 C
()]
APPENDIX A WESTINGHOUSE RESPONSE TO NOTICE OF VIOIATION A.
The following information is provided in response to the Inspector's observations that "... chewing gum and food products were used in the chemical area as evidenced b) discarded chewing gum and candy wrappers found in the ch W cal area on February 4, 1997."
A.1 ACKNOWLEDGEMENT OF THE VIOLATION Westinghouse disputes the violation as stated in the Notice of Violation.
A.2 REASON FOR DISPUTING THE VIOLATION Westinghouse disputes this violation, because Procedure RA-203, " General HP Rules and Recommendations", prohibits use of chewing gum, food products, etc., and use was not observed by the inspectors.
The Columbia Plant has a formal internal inspection and audit program performed in accordance with Section 3.6.1 of License SNM-1107.
During these inspections and audits, gum and candy l
wrappers (and one instance of an individual chewing gum in the Chemical Area) have been observed, and promptly reported to Plant Management for corrective actions.
For the majority of the Westinghouse findings, only evidence of eating, drinking and chewing in the Chemical Area is found, and actual use is not observed.
The majority of such findings has occurred in and around the change rooms.
This indicates that these materials could be discarded by. individuals as they leave the change rooms and before they enter the Chemical Area.
- Further, the occurrences of eating, drinking and i
chewing are probably very infrequent, as evidenced from the paucity of observations of personnel actually eating, drinking and chewing in the Chemical Area.
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The individual who was observed chewing gum in the Chemical Area received appropriate, documented disciplinary action by has manager.
Since this disciplinary action was taken, there has been no recurrence of this problem.
This demonstrates that Management is serious about compliance with Procedure RA-203.
l-Workplace meetings have been held with Chemical Area Manufacturing personnel, emphasizing the importance of adhering to Procedure RA-203 as follows: December 18-19, 1996 (URRS), January 15-16, 1997 (Conversion) and February 11-12, i
' 1997 (Pelleting).
These meetings were conducted in the presence of the Columbia Plant Chemical Operations Manager and, in some cases, the Columbia Plant Manufacturing Manager.
These meetings were effective in emphasizing management's expectations in this important area.
Consequently, Plant Management has been effective in implementing corrective actions to attain compliance with this procedure; and the infrequent observations of personnel actually violating this procedure supports the fact that individuals are complying with Management's expectations.
A.3 IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED The Workplace Meetings and Management's decisive actions described above have been effective in promoting compliance with Procedure RA-203.
A.4 ACTIONS TO IMPROVE THE PROGRAM On March 18, 1997, the Columbia Plant Manager sent a letter and Workplace Meeting Script to all Columbia Plant Mar.agement, requesting that the Script be presented to all employees by April 18, 1997.
The Script reiterates the requirements 'of Procedure RA-203, discusses the exposure potential of violating this procedure, restates Management's expectations, and insists on strict compliance with the procedure.
A.5 DATE WHEN FULL COMPLIANCE WAS ACHIEVED Not applicable.
B.
The following information is provided in response to the Inspector's observations that "two model MCC fuel shipping containers (M140 and M230) were used to ship unirradiated fuel and the containers had not been reinspected within the past five years in accordance with the Maintenance Program".
B.1 ACKNOWLEDGMENT OF THE VIOLATION The violation is correct as stated in the Notice of Violation.
B.2 REASON FOR THE VIOLATION In May 1996, plans were made to phase out the detailed periodic re-inspection program in favor of a more robust routine refurbishment program.
A decision was made that the proposal to make the transition would be included in the License Renewal Application, which was to be submitted in October 1996.
The transition would occur when the Application was approved and a new Certificate issued.
On October 1, 1996, Westinghouse submitted an Application of Renewal and Change to the MCC Certificate of Compliance USA /9239/AF.
On October 3, 1996, NRC acknowledged receipt of the Application, and, since it had been received at least 30 l
days prior to the expiration of the Certificate of Compliance, NRC granted an extension of the Certificate until the Application could be reviewed and approved.
In December 1996, the periodic re-inspection program was eliminated and replaced by the refurbishment program.
This was done without full realization that the existing Certificate was extended based on timely renewal, and that all provisions of the "old" Certificate remained in effect.
Shipping containers which came due for their periodic (five year) re-inspection remained in service because it was thought that the re-inspection program was no longer in effect.
On February 3,
- 1997, the two subject containers (M140 and M230) were included in a fuel shipment.
On February 18, 1997, the two shipping containers were returned empty to the site.
B.3 IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED l
On February 18, 1997, the Container Preparation and Packing l
Team Manager was directed to expedite identification of all shipping containers that had, or were about to, exceed the five year re-inspection period, take them out of service, and positively identify them as not usable.
The periodic re-inspection program was re-instituted for all applicable shipping containers.
These actions have been effective in preventing any further unauthorized shipments.
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- B.4' ACTIONS TO PREVENT RECURRENCE Additional shipping containers are to be removed from service as their five year certification expires until this matter is fully resolved via the Certificate renewal process.
B.5 DATE WHEN FULL COMPLIANCE WAS ACHIEVED Compliance was achieved on February 21,
- 1997, when the Container Preparation and Packing Team Manager reported i
completion of the task.
He had identified 17 shipping containers that'had, or would exceed their five year " window" imminently, and had them taken out of service and tagged out.
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APPENDIX B ADDITIONAL INFORMATION-i This information responds to the statements in the March'6, 1997 NRC letter, as follows: "The first violation is of concern because effective corrective action to preclude recurrence was not taken following discovery by your internal audit function.
Al'
- he failure to follow approved Regulatory Affairs Procedures _
minimizing personnel contamination and exposure increases tue potential for' loose contamination ingestion and thus unnecessary dose or other hazardous conditions.
The second violation is also of concern because it reflects a lack of oversight of regulatory requirements".
When violations are discovered by our internal inspection and audit program, the violations are acknowledged by the cognizant manager of the area being inspected.
This acknowledgment implies that the manager will take appropriate actions (s) to prevent recurrence.
In the March 18, 1997 letter from the Columola Plant Manager, described in our response to the Notice of Violation, this responsibility was re-stated to all management as follows:
"Also, I continue to expect all management to be observant of any evidence cf chewing, eating, drinking, or smoking in the Chemical Area, and to take appropriate remedial measures, including disciplinary actions, to prevent recurrence."
The internal inspection and audit program will continue to audit this important area.
We agree that the use of food products in the Chemical Area could lead to " unnecessary doses or other hazardous conditions".
We submit, however, that, based upon internal observations by the Regulatory Component and Plant Management, there are not widespread violations of Procedure RA-203.
This appears to be substantiated by your inspectors who stated in the Inspection Report, " Actual consumption or chewing was not observed",
"... numerous examples were not observed", and "During the performance of surveys discussed above, the inspector did not identify any significant weaknesses in the licensee's program to maintain and control radioactive materials, nor with area postings."
As previously stated, we will continue to be diligent in auditing this program.
In summary, the Columbia Plant has in place a formal program to ensure compliance with internal procedures, including (1) management oversight of procedural compliance, (2) internal inspections and audits, (3) reinstruction and training of personnel, (4) initiation of corrective actions, where applicable, and (5) a formal, progressive, disciplinary action program for l
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failures to comply with Plant procedures and policies.
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l Regarding the NRC comment concerning a " lack of oversight of regulatory requirements", the following information is submitted.
As stated in our response to the Notice of Violation, there was an inadvertent misunderstanding by personnel responsible for the shipping container program as to when the new Certificate requirements would become effective.
To address this concern, the Manager, Planning & Services is issuing a letter to cognizant personnel, emphasizing the need for strict compliance with existing regulatory requirements.
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