ML20148B491
ML20148B491 | |
Person / Time | |
---|---|
Site: | 07001201 |
Issue date: | 05/02/1997 |
From: | Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | Carr C FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
Shared Package | |
ML19317C305 | List: |
References | |
70-1201-97-03, NUDOCS 9705130116 | |
Download: ML20148B491 (3) | |
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f je DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED '
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May 2. 1997 B&W Fuel Company ATTN: Mr. C. W. Carr Plant Manager I Commercial Nuclear Fuel Plant l P. O. Box 11646 Lynchburg, VA 24506 1646 I
SUBJECT:
NRC INSPECTION REPORT NO. 70 1201/97 03 AND NOTICES OF VIOLATION i
Dear Mr. Carr:
This refers to the inspection conducted on March 31 through A3ril 3, 1997, at the Commercial Nuclear Fuel Plant facility. The purpose of tle inspection was to determine whether activities authorized by the license were conducted safely and in accordance with NRC requirements. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the report.
Areas examined during the inspection are identified in the report. Within 1 these areas, the inspection consisted of selective examinations of procedures
- and representative records, interviews with personnel, and observation of
- activities in progress. !
Based on the results of this inspection, certain of your activities a?peared l 1 to be in violation of NRC requirements, as specified in the enclosed lotices j of Violation (Notices).
I You are required to respond to this letter and should follow the instructions a
specified in the enclosed Notices when preparing your response. In your .
response, you should document the specific actions taken and any additional {
actions you plan to prevent recurrence. After reviewing your response to l
, these Notices, including your proposed corrective actions and the results of '
future inspections, the NRC will determine whether further NRC enforcement j action is necessary to ensure compliance with NRC regulatory requirements, i i ,
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i 300005 DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED i
DOCUMENT TRANSHITTED HEREWITH CONTAINS 2.790 INFORMATION l
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B&W CNFP
- - In accordance with 10 CFR 2.790, of the NRC's " Rules of Practice," a copy of this letter and Enclosures 1 and 2 will be placed in the NRC Public Document.
Room. Under the provisions of Section 2.790(d), reports containing infor ttion related to a licensee's MC&A program are exempt from public disc' Pre. Accordingly, Enclosures 3 and 4 will not be placed in the Public Doct a ' Room.
Should you have any questions concerning this letter, please contact us.
Sincerely,
/s/
)
Edward J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety Docket No. 70 1201 License No. SNM 1168
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Enclosures:
- 1. Notice of Violation #1
- 2. NRC Inspection Report Details #1
- 3. Notice of Violation #2 (2.790(d))
- 4. NRC Inspection Report Details #2 (2.790(d))
cc w/encis:
Gayle F. Elliott, Manager Safety and Licensing Framatome Cogema Fuels Lynchburg Manufacturing Facility P. O. Box 11646 Lynchburg, VA 24506 1646 cc w/o encls 3 and 4:
Leslie P. Foldesi, Director Bureau of Radiological Health Division of Health Hazards Control Department of Health 109 Governor Street, Room 916 Richmond, VA 23219 Distribution w/encls: (See page 3)
DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED DOCUMENT TRANSMITTED HEREWITH CONTAINS 2.790 INFORMATION s
DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED 1
B&W CNFP 3 i Djistribution w/o encis'3 and 4:
PUBLIC Distribution w/encls: i U.S. Nuclear Regulatory Commission ATTN: NRC Resident Inspector Mail Code 42 P. O. Box 785 Lynchburg, VA 24505 0785
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E. McAlpine, RII G. Troup, RII G. Shear. RIII C. Cain. RIV F. Wenslawski, RIV Distribution w/o encls:
License Fee Management Branch i
Y" 2 (VFfCF PIf ONUS Pt! DNws SIGNATURE
- c. On9 l NAME % res CBassett tJMSb DATE 05 / L / 97 05 / & / 97 05 / 7-- / 97 05 / / 97 05 / / 97 05 / / 97 COPY? gS) NO [y(k NO YES NO YES NO YES NO YES NO OttlCIAL RECURO COPY 'DUCUMthi MMt: 7:\f f BilWEPLMI5\BWCil/03 i
l DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED DOCUMENT TRANSMITTED HEREWITH CONTAINS 2.790 INFORMATION
DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED NOTICE OF VIOLATION #1 Framatome Cogema Fuels Docket No. 70-1201
, , Lynchburg Manufacturin'g Facility License No. SNM 1168 During an NRC inspection conducted on March 31 through April 3, 1997, violations or iNC requirements were identified. In accordance with the
" General Statemect of Policy and Procedures for NRC Enforcement Action,"
NUREG-1600, the violations are listed below:
A. License Condition No. S 1 of Special Nuclear Material License Number 1168 (SNH 1168) requires the licensee to comply with statements, representations, and conditions contained in Part I of the License Application dated June 22, 1990, and supplements thereto.
Part I, Chapter 4, Section 4.1 Administrative Conditions Step 4.1.5 Postinas states that nuclear safety postings approved by Health Safety shall be maintained specifying nuclear safety parameters that are subject to procedural controls.
j Licensee nuclear safety posting approved by Health Safety for the Fuel Assembly Storage Area stated, " Moderating material (plastics, liquids, etc.) HUST NOT be stored in the fuel assembly storage area...."
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Contrary to the above, on April 2,1997, a) proximately one hundred (100) ;
nylon straps (a moderating material) were aeing temporarily stored in ;
the fuel assembly storage area in anticipation of future usage. !
This is a Severity IV violation (Supplement VI).
B. License Condition No. S-1 of Special Nuclear Material License Number 1168 (SNM 1168) requires the licensee to comply with the statements, representations, and conditions contained in Part I of the License Application dated June 22, 1990, and supplements thereto.
Part I, Chapter 2. Section 2.7 of the Application, requires that independent auditors shall conduct, as a minimum, semi annually nuclear safety, fire safety, and health physics inspections at the CNFP.
Procedure No. RP-000, " Radiation Protection Program Definitions," ;
Revision 1 dated January 31, 1996, which is applicable to the plant Safety and Licensing Department, defines " semi annual" in Section 4.24 as being at least once every six (6) calendar months +25% (45 days).
Enclosure 1 DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED DOCUMENT TRANSMITTED HEREWITH CONTAINS 2.790 INFORMATION
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DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED Notice of Violation #1 2
. Contrary to the above, on April 2,1997, semi annual safety audits were not being performed in the required frequency as the time lapse between the audits of October 6,1995, and August 26, 1996, exceeded the defined semi annual limit.
This is a Severity IV violation (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201, B&W Fuel Company is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, AlTN: Document Control Desk Washington, D.C. 20555 with a copy to the Regional Administrator, Region II, and a copy to the Chief, fuel Facilities Branch, Region II, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation, or, if contested, the basis for disputing the violation (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your .
response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required res mnse. If an adecuate reply is not received within the time specified in t11s Notice, an orcer or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be 3 roper should not be taken. Where good cause is shown, consideration will ae given to extending the response time.
Dated at Atlanta, Georgia this 2nd day of May, 1997 DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED DOCUMENT TRANSMITTED HEREWITH CONTAINS 2.790 INFORMATION l
DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED 0.' S. NUCLEAR REGULATORY COMMISSION REGION II Docket No.: 70 1201 License No.: SNM-1168 Report No.: 70 1201/97 03 Licensee: Framatome Cogema Fuels Facility: Lynchburg Manufacturing Facility Location: Lynchburg, VA Dates: March 31 through April 3, 1997 Inspectors: C. Bassett. Senior Radiation Specialist D. Ayres, Fuel Facilities Inspector l
Approved by: E. J. McAlpine, Chief Fuel Facilities Branch l 1
Division of Nuclear Materials Safety j
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4 EXECUTIVE SU';;;'TJ 4
. . Framatome Cogema Fuels
- NRC Inspection Report No. 70 1201/97 03 1
l The primary focus of this inspection was the observation and evaluation of the l 4
licensee's programs for operational safety, configuration management, and l maintenance of safety controls. The report includes inspection efforts of two ]
regional inspectors. The inspection identified the following aspects of the j licensee programs as outlined below.
PLANT OPERATIONS 1
- Criticality safety postings and safety rules were properly issued and 1
conspicuously posted. However, some of the posted instructions were found i
to be confusing or ambiguous. The postings were also widely issued !
! without an indication on them as to management approval and may be i susceptible to producing conflicts with approved procedures or document 1
control problems.
$ e Despite recent retraining efforts and emphasis on rocedural compliance, the licensee's adherence to approved procedures and postings was found to i, be less than adequate. A violation of required procedures and postings in i
the plant operations realm was identified by the inspectors (VIO 97 03-
' 01). Although the inspectors found no immediate hazards, improvements in the licensee's content of and conformity to safety related instructions i are necessary for continued assurance of safety.
- An unresolved item (URI 97 03-02) was identified concerning an unanalyzed ;
j condition regarding moderating materials in the fuel assembly storage j j area. j i
e The licensee's Configuration Control Program was found to have a detailed, programmatic method for reviewing, approving, and implementing facility modifications. However, the licensee's implementation of this program and i the maintaining of the required document trail were found to be incomplete, although adequate safety reviews were performed. The incomplete document trail is another example of failure to follow procedures and is noted as a non cited violation (NCV 97 03 03).
MANAGEMENT ORGANIZATION AND CONTROLS
- No problems were noted with the recent changes that had been made in the licensee's organization and the individuals were aware of their responsibilities with respect to nuclear criticality safety.
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DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED e The inspectors concTuded that qualified personnel were conducting the audits, that issues were being identified that required corrective actions, and that the audit findings were being forwarded to and reviewed by management. One audit item concerning NCS postings on scrap pellet storage trailers was noted by the inspectors as a non cited violation (NCV 97-03 04),
e The ir.ttrvals between safety audits were such that the licensee did not adequately fulfill the semi annual audit requirements. A violation was cited by the insaectors (VIO 97 03 05) for failure to adhere to the commitments in t1e license application concerning audit frequency.
MATERIAL CONTROL AND ACCOUNTING e A violation of internal procedure for failure to control access to tamper-safing devices was identified and is described in Enclosures 3 and 4 (VIO 97 03 06).
Attachment:
Persons Contacted Inspection Procedures Used List of Items Closed and Opened i
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Report Details #1 I I. Safety Doerations A. Plant Operations (03) (88020)
- 1. Conduct of Operations (03.01)
- a. Inspection Scoce The inspectors conducted plant tours of various facility areas to confirm that operations were being performed as described in written procedures and in accordance with posted instructions to assure safe operations of the facility processes.
- b. Observations and Findinas The inspectors were initially given a tour of the Lynchburg ,
Manufacturing Facility and observed material handling activities in the '
pellet loading room (observed through a window from a "non controlled" i area); fuel rod fabrication area; and fuel bundle assembly, storage, and ;
shipping areas. The inspectors also toured areas which routinely involve radioactive material handling, but in which material handling activities were not being performed at the time of the tour. These i areas included the pellet receiving room, and two of the Service !
Equipment Reconditioning Facilities (SERF-1 and SERF-4). Criticality safety postings and other posted safety related instructions were observed at various locations throughout the facility. The inspectors found most of the postings to be framed and neatly dis) layed and easily recognizable. However, the inspectors found some of t1e instructions confusing or too ambiguous to be clearly understood by someone who is not already familiar with the intent of the instructions. Examples include maintaining a 12 foot separation between different accumulations of SNM (with no indication as to what constitutes "different accumulations") and limiting pellets to a 4 inch slab height configuration exce)t when transferring fuel from the shipping container to a conveyor (wit 1 no indication as to the limits during this transfer). These observations were shared with the licensee's Safety and Licensing support staff.
During the facility tour, the inspectors observed two slightly different sets of safety instructions posted in the same part of the pellet receiving area. The inspectors informed the licensee of the discrepancy and the licensee subsequently removed the outdated posting. Although not specifically required by NRC regulations, the inspectors also identified that none of the postings were marked with any type of indicators for-document control nor for management approval. These DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED
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2 indicators (which can include a document or form number, a revision number, copy number, and a management contact reference) are typically !
useful for maintaining control of posted instructions. A system for l controlling safety and licensing documents already exists for procedures and forms (in the licensee's procedure SL-1000), and could be similarly applied to safety postings. The inspectors identified this potential problem area to the licensee's Safety and Licensing support staff.
The inspectors performed numerous reviews to confirm the licensee's compliance with approved procedures and postings in its conduct of operations. A review of a recent process equipment change prompted the !
inspectors to examine posted instructions for the operation and '
inspection of a vacuum cleaner used to remove SNM residues from a downdraft table in the pellet loading room. As part of the new l installation, the vacuu' mcleaner bag casing was modified to limit the ;
size of the filter bag and to restrict the volume of SNH accumulating within the casing. The posting included an instruction for a daily I visual inspection of the filter bag inside the vacuum cleaner to verify the integrity of the bag, and thus to verify that criticality safety controls remain intact. A logsheet was also provided to document these inspections. The inspectors found that in the previous six months, the filter bag inspections were not being documented except when the filter bag was changed (once or twice a month). Interviews with operations aersonnel indicated that these inspections were being performed daily.
iowever, the documentation of safety related inspections are important for confirming that safety requirements are being met by the licensee.
The licensee's internal Health Safety inspection program is maintained to provide assurance that plant activities are conducted safely and in accordance with license specifications. This internal program should have been able to detect the lack of documentation of required safety-related inspections, and is an example of the ongoing problems the licensee has experienced with adherence to procedures.
During an inspection of the fuel assembly storage area on April 2,1997, the inspectors observed a large collection of nylon straps (aparoximately 100) within the designated storage area. The straps were eac1 aaproximately 5 cm wide and 1 meter in length. About 60 straps were o) served to be neatly coiled into individual bundles and placed in various locations along the catwalks between rows of storage racks.
Another collection of about 40 straps were loosely piled at the end of one of the catwalks next to a wall. These straps were found to have been placed in the area in anticipation of their use in securing NUKEM fuel assemblies into the storage racks. The inspectors found the accumulation of nylon straps to be in contradiction with the posted criticality limits in the area which stated, " Moderating material (plastics, liquids, etc.) MUST NOT be stored in the fuel assembly storage area...." The as-found condition of the storage racks was such DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED
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. . 3 that fuel assemblies containing SNM were not present in the vicinity of the moderating materials. However, the lack of control of unanalyzed moderating materials in a SNM storage area can result in a situation in which acceptable safety margins are compromised. Even though the as-found condition did not directly affect fuel assemblies containing SNM, strict adherence to criticality safety rules is expected. Due to its potential safety risk, this issue is cited as a violation for failure to follow posted safety instructions (VIO 70 1201/97 03-01).
Additionally, the use of nylon straps to secure NUKEM fuel assemblies into the racks was found to have not been fully analyzed as to their effect on the k,y value of the storage array, but had been deemed insignificant by the licensee. Further discussions with licensee management revealed that the effects of other plastics used for protecting fuel assemblies from damage had not been fully analyzed. The inspectors could not assess the significance of the effects of these unanalyzed moderating materials, and this issue will be referred to NRC Headquarters for further evaluation and is identified as an unresolved item (URI 70 1201/97 03 02).
- c. Conclusions The licensee's adherence to ap3 roved arocedures and postings was found to be less than adequate. Altlough t1e inspectors found no immediate hazards, improvements in the licensee's content of and conformity to safety related instructions are necessary for continued assurance of safety.
- 2. Facility Modifications and Configuration Controls (03.02)
- a. Inspection Scoce The licensee's Configuration Control Program was reviewed to confirm that any recent changes or modifications to the facility with nuclear criticality safety implications were reviewed, approved, and implemented as required by procedure,
- b. Observations and Findings The licensee's Configuration Control Program was outlined in procedure AS 1120. "CNFP Safety Review Board," Revision 5, dated December 8, 1993.
The inspectors reviewed the procedure and noted that, even though a modification could be reviewed, ap) roved, and completed, the procedure did not specifically address how t1e modification could affect and cause a need for revisions to the affected piping and instrumentation diagrams DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED
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(P& ids) or revisions to the maintenance program. However, the inspectors confirmed that appropriate controls for implementing the actual changes and modifications were established to meet the intent of the license.
The inspectors also reviewed the forms completed by the licensee to document the implementation of the modifications and the controls s)ecified or required by such changes. The inspectors determined that t1e documentation was not always complete. Nine project packages for facility modifications dating back over the past three years were reviewed for compliance with the program outlined in procedure AS-1120.
The ins]ectors identified deficiencies in the completion of the prescri 3ed forms for eight of these projects. Auxiliary documents (memos, analyses, etc.) confirmed that adequate reviews by the safety functions had been performed, but the intent of the completion of the prescribed forms was to provide an easily recognizable status of the safety requirements associated with a process modification. The deficiencies in the completion of the forms prescribed in procedure AS-1120 was found to be a violation of the license application. However, adequate safety reviews had been performed and corrective actions were being implemented to address a previous similar violation. Therefore, this NRC identified violation is not being cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied (NCV 70-1201/97-03-03).
- c. Conclusions The licensee's Configuration Control Program was found to have a detailed, programmatic method for reviewing, approving, and implementing facility modifications. The licensee's implementation of this program and the maintaining of the required document trail were found to be ;
incomplete, although adequate safety reviews were performed. '
B. Management Organization and Controls (05) (88020)
- 1. Orqanizational Structure (05.01)
- a. InsDection Scope The inspectors reviewed the licensee's organizational structure to determine whether changes had been made since the last inspection at the facility.
- b. Observations and Findings l
During the inspection, the inspectors were provided with a copy of the facility organizational structure. It was noted that changes had been ,
made to the organization since the last Region II inspection. The DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED
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l persons filling the positions of Manufacturing Engineering and Fuel i
' Manufacturing were new to those positions but not new to the company or I the facility. Through discussions with those individuals the inspectors determined that they were aware of and understood their responsibilities ,
concerning nuclear criticality safety as well as their other responsibilities for production and safety in general.
- c. Conclusions No problems were noted with the recent changes that had been made in the licensee's organization and the individuals were aware of their responsibilities with respect to nuclear criticality safety.
- 2. Internal Reviews and Audits (05.03)
- a. Insoection Scope l
The inspectors reviewed recent audits to ensure that the audits were being conducted by the appropriate staff as required by the license '
a) plication and in accordance with applicable procedures and to ensure t1at procedural violations and equipment or system failures related to ;
NCS were being identified and reported. l
- b. Observations and Findings l
The inspectors reviewed the most recent semi arnual audits in the area of nuclear criticality safety. The inspectors noted that the audits had been conducted and reviewed by personnel from the nuclear criticality staff and the results had been forwarded to the Manager of Safety and Licensing, as well as the Plant Manager. The inspectors noted that two audits were conducted each year and included a review of the activities in the various receiving, manufacturing, and storage areas of the plant.
When an audit identified items that needed to be corrected, a response was generated and corrective actions were initiated by the licensee.
One of the audit findings noted by the licensee's auditors during December 1996 was that some trailers used to store U0 scrap material did not have criticality safety signs affixed to the krailer doors indicating the presence of the SNM material inside. The auditors noted that the failure to post the trailers was an apparent violation of License Condition 10 of Materials License SNM 1168 which recuires the licensee to comply with all listed conditions in Safety Concitions.
Safety Condition S-1 requires the licensee to comply with the statements, representations, and conditions in Part I of the License A) plication dated June 22, 1990, and supplements thereto. Part I, Clapter 4 Section 4.1.5 of the Apalication, requires that nuclear safety postings, approved by Healti Safety, shall be maintained specifying nuclear safety parameters that are subject to procedural DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED
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6 controls. Secti~on 4.1.5 also stipulates that o specific (dedicated) controls are applicable sh$erations for which 11 be individually I posted. In response to this audit, the licensee posted each trailer containing U0g scrap material with signs designating that SNM was stored inside and stipulating the Criticality Safety Limits for the trailers, The licensee also submitted all the criticality safety postings to.the nuclear criticality safety group for review and revision as necessary.
The inspectors informed the licensee that this licensee identified and corrected violation was not being cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied (NCV 70-1201/97 03 04).
The ins)ectors reviewed the timeliness of the audits. It was noted that
- audits lad been conducted as follows
- December 13, 1994, July 20, 1995, October 6, 1995, August 26, 1996, and December 16, 1996. The inspectors noted that the time span between the inspectior in October 1995 and August 1996 appeared to be in violation of License Condition 10 of
- Haterials License SNM 1168 which recuires the licensee to comply with all listed conditions in Safety Concitions. Safety Condition S-1 4
recuires the licensee to comply with the statements, representations, anc conditions in Part I of the License Application dated June 22, 1990, and supplements thereto. Part I, Chapter 2. Section 2.7 of the i Application, requires that independent auditors shall conduct, as a minimum, semi annually nuclear safety, fire safety, and health physics
- inspections at the CNFP. Procedure No. RP 000. " Radiation Protection 2; Program Definitions " Revision 1, dated January 31, 1996, which is applicable to the plant Safety and Licensing Department, defines " semi-annual" in Section 4.24 as being at least once every six (6) calendar months +25% (45 days). The licensee was informed that the failure to ,
complete a semi annual audit of the nuclear safety program within the required time frame was cited as a violation for failure to follow procedures (VIO 70 1201/97 03 05).
- c. Conclusions
- The inspectors concluded that qualified personnel were conducting the audits, that issues were being identified that required corrective
.i actions, and that the audit findings were being forwarded to and
- reviewed by management. However, the intervals between audits were such that the licensee did not adequately fulfill the semi annual audit l frequency requirement.
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II. Manaaement Meetinas l 1
1 A. Exit Interview (M1)
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On April 3, 1997, the inspection scope.and results were summarized with l licensee representatives. The inspectors discussed in detail the i routine program areas inspected, and the findings, including violations. 1 No dissenting comments were expressed by the licensee.
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- The licensee did not identify any of the materials provided during the j inspection as proprietary.
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DECONTROLLED WHEN 2.790 INFORMATION IS REMOVED ATTACHMENT
- 1. PERSONS CONTACTED Licensee Personnel
- T. Allsep, Health Physicist i *C. Carr, Vice President, Manufacturing and Services 1 *G. Elliott, Manager, Safety and Licensing
- R. Gardner, Manager Quality, FCF
! *D. Gordon, Sr. Health Physicist
- G. Lindsey, Health Physicist i
, *F. Masseth, Manager, Operations and Resource Control
- D. Hinor, Manager, Manufacturing Engineering j *T. Wilkerson, Manager, Nuclear Fuel Manufacturing Other licensee employees contacted included engineers, technicians, security, and office personnel.
- Denotes those present at the exit meeting on April 3, 1997. I
- 2. INSPECTION PROCEDURE USED IP 88020 Regional Nuclear Criticality Safety Inspection Program i
- 3. LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status Descriotion 70 1201/97 03 01 Open VIO Failure to comply with posted NCS recuirements concerning storage of mocerating materials in the fuel assembly storage area.
70 1201/97 03 02 Open URI Plastic materials used in the fuel assembly storage area have not been fully analyzed for their effect on k,,r.
70 1201/97 03 03 Closed NCV Failure to comply with documentation requirements of the licensee's Safety Review Board procedure (AS 1120).
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70 1201/97 03-04' Closed NCV Failure to properly post storage trailers containing unirradiated scrap fuel pellets per the approved license l
application.
I 70-1201/97 03-05 Open VIO Failure to comply with the timeliness requirements of semi-annual safety audits per the approved license application and the Radiation Protection Program Definitions procedure (RP-000).
- 70 1201/97 03 06 Open VIO Failure to control access to tamperseals per FNMC Plan.
)~ 4. LIST OF ACRONYMS
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CNFP Commercial Nuclear Fuel Plant FCF Framatome Cogema Fuels FNMC Fundamental Nuclear Materials Control IP Insm ction Procedure NCS Nuclear Criticality Safety NCV Non Cited Violation i SERF Service Equipment Reconditioning Facility !
SNM Special Nuclear Material '
URI Unresolved Item VIO Violation i
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