ML20140C971
| ML20140C971 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 05/27/1997 |
| From: | Elliott G FRAMATOME |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-1201-97-03, 70-1201-97-3, NUDOCS 9706100165 | |
| Download: ML20140C971 (6) | |
Text
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o F RAM ATOME COG EMA FU ELS May 27,1997 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555
SUBJECT:
REPLY TO NRC INSPECTION REPORT NO. 70-1201/97-03 AND NOTICES OF VIOLATION
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Gentlemen:
This letter is in response to inspection Report No. 70-1201/97-03 and Notices of Violation dated May 2,1997. Framatome Cogema Fuels (FCF) has addressed each of the three violations as outlined in the Notices of Violation. Attachment I l
identifies each of the violations, addresses admission of each violation and describes the reasons for each violation. Attachment I further identifies corrective actions which have been taken and the results achieved, corrective actions yet to be taken and the date when full compliance will be achieved, j
j The management of Framatome Cogema Fuels is extremely concerned about the violations of NRC requirements and the deficiencies cited. We have established and incorporated corrective actions into our programs and are working proactively I
to assure similar incidents do not occur. FCF is committed to improvements in our program and to improved management oversight with proactive problem identification and resolution. The corrective actions noted herein will ensure i
license and procedural adherence.
l Should you have any questions or comments, please feel free to contact me at (804) 832-5202.
i FRAMATOME COGEMA FUELS
]g Lynchbur Manufacturing Facility g
Y 9706100165 970527.
Gayle F. Mou PDR ADOCK 07001201 Manager, Safety & Licensing C
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lilllOlllOlllllOOllilOlllllllOllll Frematome Cogema Fuels EC oL0G E To phon 804 832-5000 x: 80 8 2 5167
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Regional Administrato.r, Region ll U.S. Nuclear Regulatory Commission Atlanta Federal Center C1 Forsyth Street, SW Suite 23T85 Atlanta, GA 30303
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Chief, Fuel Facilities Branch, Region ll U.S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, SW 1
Suite 23T85 Atlanta, GA 30303 A.D. McKim, Manager, Quality 1
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ATTACHMENTI l
Violation No. 97-03-01:
The Licensee failed to comply with posted Nuclear Criticality Safety requirements concerning storage of moderating materials in the fuel assembly storage area.
Admission of the Violation:
Framatome Cogema Fuels concurs with the facts contained in the NRC Notice of Violation dated May 2,1997.
Reason (s) for the Violation:
1)
The manufacturing organization failed to follow the nuclear safety posting approved by Health-Safety which specified that storage of moderating materials was prohibited.
2)
The Safety & Licensing organization failed to adequately audit and provide the required oversight of the area to ensure strict compliance with the nuclear safety posting.
3)
Lack of formal training on identification and knowledge of moderating materials was a factor in noncompliance with the nuclear safety posting.
Corrective Action (s) Taken:
1)
Personnel have been informed that nylon straps 6re a moderating material and may not be stored in the fuel assembly area. This corrective action resulted in (a) a heightened awareness of the importance of posting compliance and (b) the knowledge that nylon is a moderating material and must not be stored, even temporarily, in the fuel assembly storage area.
2)
The Safety & Licensing Monitor involved in the event has been notified that moderating materials cannot be stored in the identified areas. This corrective action resulted in the identification of expectations to the monitor on the importance of compliance with nuclear safety postings and the importance of the organization to provide the oversight for compliance with the postings.
i ATTACHMENT I Violation No. 97-03-01 (Continued):
Corrective' Action (s) to be Taken:
1)
A weekly inspection will be required by all radiation technicians of all posted areas to ensure all employees are in compliance with nuclear safety postings. This corrective action will ensure parameters established in the nuclear safety postings throughout the facility have j
the appropriate oversight necessary to ensure compliance.
)
2)
Identification and information on moderating materials will be added to the General Employee Training. This annual training is mandatory for all employees. This corrective action will ensure all employees are knowledgeable of and can identify moderating materials.
Full compliance will be achieved June 30,1997.
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1 ATTACHMENT I 1
Violation No. 97-03-05:
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The Licensee failed to comply with the timeliness requirements of semi-annual safety audits.
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Admission of the Violation:
i Framatome Cogema Fuels concurs with the facts contained in the NRC j
Notice of Violation dated May 2,1997.
Reason (s) for the Violation:
1)
Inadequate management oversight of the audits resulted in the failure to comply with the timeliness requirements of semi-annual safety audits per the license application and the Radiation Protection i
Program Definitions procedure (RP-000).
2)
Inconsistent interpretation of the semi-annual requirements was a factor in noncompliance with the requirement.
j Corrective Action (s) Taken:
1)
The Safety & Licensing organization has been restructured to identify ownership of all areas for which Safety & Licensing is responsible.
This corrective action will provide ownership of the necessary audits to ensure all audits are performed as required.
Corrective Action (s) to be Taken:
1)
Procedure RP-000, " Radiation Protection Program Definitions" will be revised to clarify the definition of " semi-annual." This corrective action will ensure consistent interpretation of the semi-annual requirement.
Full compliance will be achieved June 30,1997.
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ATTACHMENTI 1
Violation No. 97-03-06:
The Licensee failed to control access to tamperseals per FNMC Plan.
Admission of the Violation:
Framat'ome Cogema Fuels concurs with the facts contained in the NRC Notice of Violation dated May 2,1997.
1 Reason (s) for the Violation:
i 1)
Failure of the manufacturing operator to comply with procedure NM-1 1611, "Tampersafing of SNM".
j 2)
Inadequate training on the tampersafing program.
Corrective Action (s) Taken:
J 1)
The Manufacturing Operator involved in the event has been notified of i
his mistake and informed on the importance of following procedures.
This corrective action resulted in increasing awareness of the importance of procedure compliance.
2)
The Manufacturing Operator involved in the event has been retrained on NM-1611, "Tampersafing of SNM."
Corrective Action (s) to be Taken:
1)
The Safety Review Board is presently evaluating training methods to determine how to improve the training of plant personnel. The result of this corrective action will be a more effective training program, increased knowledge of procedural contents by plant employees and procedure compliance.
Full compliance will be achieved December 31,1997.
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