ML20198F833

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1151/97-03 on 970527-30

ML20198F833
Person / Time
Site:	Westinghouse
Issue date:	08/04/1997
From:	Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Fici J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
70-1151-97-03, 70-1151-97-3, NUDOCS 9708130156
Download: ML20198F833 (2)

Text

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l August 4, 1997 Westinghouse Electric Corporation ATTN: Mr. J. A. Fici, Manager Columbia Plant Commercial Nuclear Fuel Division Drawer R Columbia, SC 29250

SUBJECT:

NRC INSPECTION REPORT NO. 70 1151/97 03

Dear Mr. Fici:

Thank you for your response of July 23, 1997, to our Notice of Violation, issued on June 24, 1997, concerning activities conducted at your Commercial Nuclear Fuel Division. We have evaluated your response and found that it meets the requirements of 10 CFR 2.201. We will examine the implementation of your corrective actions during future inspections.

We appreciate your cooperation in this matter.

Sincerely, (original signed by E. J. McAlpine)

Edward J.

McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety cc:

Wilbur Goodwin, Manager Regulatory Affairs Westinghouse Electric Corporation Commercial Nuclear Fuel Division Drawer R Columbia, SC 29250 Max Batavia, Chief Bureau of Radiological Health S. C. Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 1

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i rI(I W85tlngt10USe Cominercial Nuclear Fuel Dmsion Electric Corporation o,,,, n Columtna Sou;a Carolma 29250 NRC-97-030 (803 776 2610 July 23, 1997 U.S.

NUCLEAR REGULATORY COMMISSION ATTN:

Document Control Desk Washington, DC 20555 Gentlemen:

SUBJECT:

REPLY TO A NOTICE OF VIOLATION

REFERENCE:

REPORT NO: 70-1151/97-03 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 letter of June 24, 1997, regarding your inspection of the Columbia Fuel Fab _ication Facility conducted during the period of May 27-30, 1997..

l Appendix A

provides our response to the violation of NRC

/

requirements identified in the Notice of Violation.

f I hereby affirm that the statements made in this response are true and correct to the best of my knowledge and belief.

Should you have any questions or require additional information, please telephone Mr. Wilbur L.

Goodwin of my Staff at (803) 776-2610 Ext. 3282.

i Sincerely, WESTINGHOUSE ELECTRIC CORPORATION k b M' Jack B. Allen, Plant Manag r Columbia Fuel Fabrication Facility Attachments:

Appendix A cc:

U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303 nWnt c;

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s License SNM-1107 Docket 70-1151 July 23, 1997 APPENDIX A WESTINGHOUSE RESPONSE TO NOTICE OF VIOII. TION A.

The following information is provided in response to the Inspector's observation that "...the Configuration Control forms (TAF-500-1 forms) with Docket Numbers95-135, 96-042, and 96-191 had been signed at being completed indicating that all the documentation associated with the forms had been updated but the documentation had not been revised in that various drcwings, loop sheets, and schematics had not been

-updated as required by procedure".

A.1 ACKNOWLEDGEMENT OF THE VIOLATION The violation is correct as stated in the Notice of Violation with one minor exception:

For Configuration Change Control (CCC) Docket No. 95135, the project engineer was out of the Plant during the NRC inspection and was not available for questioning by the NRC inspectors.

References-to several drawings are made-on this TAF-500-1 Form.

However, drawings listed in this section of the form are only a preliminary judgment of documentation that will be impacted.

During the course of the project, the correct drawings were identified 1

and modified by the project engineer.

In this instance, two electrical drawings were indicated on the TAF-500-1 Form (500F03ELO6-1 and 500F03EL10-1).

However,- the following 1

drawings-were used to actually implement -

theanti'oroject (338F01EL43-1,2 and 338F01EL10).

It was also cipated that P&ID Drawing No. 500F03PIO6 would be used, but was not.

All other documents were found to be in order.

Based upon an evaluation of this documentation, it was concluded that the TAF-500-1 Form provided sufficient information for project planning and control purposes, but additional controls were needed for project closure documentation.

This issue is further addressed below, A.2 REASON FOR THE VIOLATION There was a lack of "at' tion to detail" on the part of cognizant project enginA during the project close-out a

phase, in that they prematurely signed the Configuration Change Control TAF-500-1 Forms prior to completing all "as built" documentation; and, there was a need for additional documentation to assist the project engineer in completing the project.

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,4 A.3 IMMEDIATE ACTIOh TAKEN AND RESULTS ACHIEVED The following actions were taken to address CCC Docket No's.

96191 and 96042 (Note that CCC Docket No. 95135 has already been completed as described above):

CCC Docket No. 96191: The project engineer terminated his employment with Westinghouse and closed out the project prematurely.

This project was re-assigned, and drawing revisions were properly completed for the "as-built" condition.

CCC Docket No. 96042; The project engineer responsible for this change completed proper updating of the construction drawing documentation to the "as-built" condition.

Drawings were clearly marked " inactive" and were moved from the " active" file to the " inactive" file.

A.4 ACTIONS TO PREVENT RECURRENCE Documents listed on the TAF-500-1 Forms do not always comprise a complete or accurate list.

This part of the form is only intended to stimulate the project engineer into evaluating what impact the project will have and the types of documer.ts that might be affected.

However, we do concur that the closed-out document should be accurate.

To assist the project engineers in closing out projects, the following is planned:

To further emphasize the importance of completing all phases of the project, the next revision of TA-500 will include the requirement that the responsible project engineer provide a working list of documents and drawings, that have actually been affected by a modification, at project closure.

The list will be a prerequisite to applying a close-out signature to the TAF-500-1 Form.

Check-off blocks will be provided on the

list, requiring the responsible project engineer's confirmation that the following have been completed as required: training; procedures; removal of "For Construction" drawings from the file; preventive maintenance; instrument calibration procedures; and, MAPCON (e.g.,

computer) parts updated.

This revision will be completed by August 31, 1997.

A.5 DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance has been achieved.