ML20196A093
| ML20196A093 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 06/15/1999 |
| From: | Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 70-1257-99-01, 70-1257-99-1, LJM:99:058, LJM:99:58, NUDOCS 9906220123 | |
| Download: ML20196A093 (4) | |
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SIEMENS-l June 15,1999 LJM:99:058 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen :
Subject:
Reply to a Notice of Violation (License No. SNM-1227; Docket No. 70-1257)
Ref.: 1. - Letter, Dwight D. Chamberlain (USNRC) to B.N. Femreite (SPC), "NRC Inspection Report 70-1257/99-G1 and Notice of Violation," dated May 21,1999.
Ref.: 2. Letter, L.J. Maas (SPC) to NRC Document Control Desk, "Suppleme.ntal Information to Siemens Power Corporation-(SPC) 10 CFR 71.95 Notification Reports Filed April 16, 1999 (Docket No. 71-6581) and April 30,1999 (Docket No. 71 9217), dated May 21, 1999.
l Attached is Siemens Power Corporation's (SPC's) reply to the Notice of Violation accompanying k
the referenced NRC letter. As indicated in our attached reply, the information requested by the NRC is fully available in previously docketed correspondence. If you have questions regarding this reply or require more information, pleasi contact me at (509) 375 8537.
Very truly yours, b
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- L. J. Maas, Manager Regulatorv Compliance
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' Enclosures -
I E. W. Merscho'f_f, Regional Administrator
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Region IV d
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-Siemens P'ower Ccrporation Y
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2101 Hom Rapids Road Tel:
(509) 375 8100 RicNond, WA ' 99352 Fax:
(509) 375 8402
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Attachment j
Violations A.
10 CFR 71.12 states, in part, that a general license to transport licensed material, or to deliver licensed material to a carrier for transport, applies only to a licensee who complies with the terms and conditions of the certificate.
1.
Section 4,." Conditions," of Certificate of Compliance No. 9248 requires each user j
of this certificate to fulfill the requirements of 10 CFR Part 71, as applicable, and the conditions specified in the certificate.
Condition 5 (a)(3) " Drawings," of Certificate of Compliance No. 9248 requires that the packaging be fabricated in accordance with the referenced SPC drawings.
Contrary to the above, on February 25,1998, the licensee delivered licensed material to a carrier for transport under the general license pursuant to 10 CFR 71.12, and the licensee did not comply with the terms and conditions of the certificate in that the weld configurations for lugs used to close the SP-1 inner l
container did not exist as specified in the drawings referenced in Certificate of Compliance 9248, 2.
Section 4," Conditions" of Certificate of Compliance No. 6581 requires each user of this certificate to fulfill the requirements of 10 CFR Part 71, as applicable, and the conditions specified in the certificate.
Condition 5 (a)(3) " Drawings" of Certificate of Compliance No. 6581 requires that the packaging be fabricated in accordance with the referenced SPC drawings.
Contrary to the above, on April 16,1999, the licensee reported that it had transported licensed material under the general license pursuant to 10 CFR 71.12, and the licensee did not comply with the terms and conditions of the certificate in that the packages had multiple welds located on the strongback and outer container shell that did not conform to the drawings referenced in Certificate of Compliance No. 6581.
D.
10 CFR 71.85 (c) states that before the first use of any packaging for the shipment of licensed material, the licensee shall conspicuously and durably mark the packaging with its model number, serial number, gross weight, and a package identification number assigned by NRC. Before applying the model number, the licensee shall determine that the packaging has been fabricated in accordance with the design approved by the Commission.
Contrary to the above, on February 25,1998, the licensee did not determine that the packaging had been fabricated in accordance with the design approved by the
e Commission before applying the model number, in that the licensee delivered licensed material to a carrier for transport in packaging with a model number applied that was not fabricated in accordance with the design approved by the Commission in Certificate of Compliance No. 9248.
C.
10 CFR 71.133 states, in part, the licensee shall establish measures to assure that conditions adverse to quality such as nonconformances are promptly identified and corrected.
1.
Contrary to the above, established. measures did not ensure that identified nonconformances were promptly corrected in that weld configurations specified in the Certificate of Compliance No. 9248 drawings for the Model SP-1 transportation package were identified as nonconforming by SPC on November 7, 1994, and again on April 7,1997, but the recommended corrective actions were not completed by SPC at the time of the NRC inspection in February 1998.
2.
Contrary to the above, established measures did not ensure that conditions adverse to quality such as nonconformances were promptly identified between March and June 1998. Specifically, nonconforming welds on several Model 51032-1 transportation packages were not identified by the licensee when these l
packages were inspected between March and June 1998. A subsequent i
inspection conducted during March 1999 identified that most packages of this model, including those previously inspected, contained welds whict1 did not conform to Certificate of Compliance No. 6521 drawings.
SPC Resoonse to Violations A.1, B. and C.1 Violations A.1, B, and C.1 relate to SPC's usage of non-conforming SP-1 shipping containers, an issue identified as an unrosolved item in NRC Inspection Report 710003/98-203 (June 2, 1998). Per the Reference 1 letter, the NRC has concluded that SPC has adequately responded to the violations associated with the SP-1 non-compliance issue via correspondence previously submitted to the NRC. The dates and general content of this correspondence are as follows:
March 9,1998; B.N.
This correspondence outlined SPC's initial corrective actions subsequent Femreite to P.L. Eng to the NRC shipping container QA inspection of February 23 27,1998, including SPC's compensatory shipping container inspection program.
June 25,1998; J.H.
This correspondence provided SPC's response to the confirmatory action Nordahl to Dr. S.F.
totter (CAL No. NMSS-98-8 002) that resulted from the February 1998 Shankman NRC shipping container QA inspection.
' ' July 1,1998; J.H.
This correspondence provided SPC's responses to the non-conformances Nordahl to USNRC identified in NRC Inspection Report No. 71-0003/98-203 (June 2, 1998).
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October 29,1998; This correspondence outlined SPC's comprehensive corrective action j
J.H. Nordahl to Dr.
program developed in response to the NRC-identified non-conformances, S.F. Shankman SPC's internal self-assessments, and an independent external root cause f
evaluation.
t December 23,1998; - This correspondence conveyed, for NRC's review and approval, SPC's C.M. Powers to consolidated 10 CFR 50 Appendix B and 10 CFR 71 Subpart H quality USNRC assurance program (EMF 1, Revision 30).
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April 26,1999; This correspondence provided the status of commitments made in SPC's i
C.M. Powers to Dr.
letter of October 29,1998, in response to the non-conformances and l
S.F. Shankman the Confirmatory Action Letter.
l SPC Resoonse to Violations A.2 and C.2 Violations A.2 and C.2 relate to SPC's use of Model 51032-1 containers that had certain welds that did not conform to the applicable license drawings. These discrepancies were not l
identified in the compensatory container inspections conducted between March and. lune 1998.
L Their eventual discovery in March of 1999 was reported to the NRC on April 16,1999 per the requirements of 10 CFR 71.95(c).
On May 21,1999 (Reference 2), SPC conveyed to the NRC supplemental information related to the 51032-1 weld non-conformances. This correspondence provided the NRC with information relating to the discovery of the weld discrepancies, the immediate actions taken by SPC after discovery of the discrepancies, the results of SPC's generic implications inspection of other l
SPC-owned shipping containers, the results of SPC's self assessment as to why the l
discrepancies were not discovered via SPC's initial compensatory inspections, and the l
corrective actions identified to preclude recurrence of similar shortcomings in future container inspections, i
i We believe that the information provided in Reference 2 is fully responsive to the NRC's expectations concerning Violations A.2 and C.2. In addition, SPC has reinspected its entire j
51032-1 container fleet using the enhanced inspection protocols identified in Reference 2. All containers have either been reworked to achieve full compliance with license drawings or, for a l
limited number of containers, removed from serv!ce. Therefore, full compliance has been achieved relative to SPC's usage of its 51032-1 container fleet.
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