ML20198G459
| ML20198G459 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 08/27/1997 |
| From: | Allen J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-97-035, CON-NRC-97-35 70-1151-97-203, NUDOCS 9709040054 | |
| Download: ML20198G459 (16) | |
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g Westinghouse Commercial Nuclear 38* d Electric Corporation fue! Division fen'eysgm s
NRC-97-035 August 27,1997 U.S. Nuclear Regulatory Commission ATTN: Document Con *rol Desk Washington, DC 20555 Gentlemen:
SUBJECT:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
REPORT NO: 70-1151/97-203 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 July 28, 1997, regarding your special inspection of the Columbia Fuel Fabrication Facility (CFFF) conducted during the period of May 5-7,1997.
Appendix A provijes our response to the violations of NRC requirements identified in the Notice of Violation attached to the July 28 letter.
The information documented in the attached response was first presented to the NRC Staff at the July 9,1997 Enforcement Conference held in connection with Westinghouse's loss of current knowledge of the location of two uranium bearing fuel rods. At that time, we provided a detailed response to the incident giving rise to the findings in the NRC's Special Inspection Report No.
70 1151/97-203 and the instant Notice of Violation. Our response included Westinghouse's understanding of the seriousness of the incident and our continuing commitment to maintaining overall safety at the Columbia Fuel Fabrication Facility. Westinghouse also indicated that the NRC's observations and findings mirrored the results of our root cause investigation and analysis, and that we were in basic agreement with the violations as presented in the Special Inspection Report. As discussed at the Enforcement Conference, and as more fully described in Appendix A, Westinghouse believes that the comprehensive and lasting corrective actions it has taken in response to the incident fully and adequatelv address the violations contained in the Notice of Violation, as well as the concerns express:J in the NRC's July 28, 1997 letter transmitting the Notice of Violation, so as to prevent recurrence of such violations and to resolve such concerns.
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70-1151-97-203 August 27,1997 Page 2 of 3 Specifically, corrective actions have been taken in response to the NLC's expressed concern that the CFFF " staff had prior opportunities to identify the unaccounted for fuel rods", a fact which Westinghouse acknowledged during the Enforcement Conference. These corrective actions included the immediate retraining of personnel involved in ine incident. Long term corrective actions have also been taken to instill in CFFF personnel a high level of sensitivity to item control, including review of training records and strengthening of training as appropriate, and revision and strengthening of area manufacturing procedures to incorpcrate proper instructions related to the use of material accountability reports (i.e., "7-Day Reports"). New procedures and revisions to existing procedures also have been established to ensure that there is an appropriate identification and traceability system for so-called " replica" fuel rods and assemblies.
Westinghouse also acknowledges CFFF management's overall responsibility for the incident, and the need - for strengthening and maintaining proactive management oversight and involvement in the area of material control and accounting at CFFF. To address this need, Westinghouse's immediate corrective actions included stopping the shipment of all " replica" fuel assemblies and non-product fuel rods and requiring management approval for future manufacture or movement of such items. The CFFF Plant Manager at the time also held a mandatory all-management meeting to emphasize the importance of item control and to ensure that all managers and their employees understood applicable regulatory requirements. The individual managers, in turn, presented this information and the contents of an April 30,1997 letter from the (then) Plant Manager to their employees to ensure that employees understood their responsibility for item control. Management at all levels has also been involved in instilling a high level of wnsitivity to item control at CFFF, by participating in the training record reviews and training updating activities, and in the procedure reviews and revisions more fully described at the Enforcement Conference and in Appendix A.
To continue this aspect of our corrective actions, I have recently sent a letter, dated August 8, 1997, to all CFFF managers. This letter (Appendix B hereto) was issued to indicate my concurrence in the recommended removal of the restrictions on the movement of " replica" assemblies and non-fuel products based on the corrective actions taken to date. In addition, the letter again stresses to CFFF management an ongoing responsibility for oversight over the conduct of all licensed activities at CFFF in accordance with regulatory requirements, including for the control of materials and processes used.
Finally, other corrective actions either completed or currently :n process at CFFF are specifically ruponsive to the NRC's concern, as expressed in the Notice of Violation transmittal letter, that "given that the violations occurred during a non-routine operation, similar problents may occur in other non-routine activities." These actions have been undertaken to provide improved communications and implementation channels at CFFF for special or unusual requirements in a manner consistent with our existing formal systems, and to enhance configuration and control practices for production and inspection equipment to address instances where such equipment may handle both uranium and non-uranium bearing material in the CFFF mechanical 1
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70-1151-97-203 August 27, " 17 Page 3 of 3 manufacturing area. Given the nature of our business at CFFF to manufacture fuel rods and fuel assemblies, these corrective actions are direcad, in the first instance, at special or unusual requirements conceming such products, whether such products involve uranium or non-uranium bearing material. However, Westinghouse believes that these corrective actions together with the heightened sensitivity to item control that exists today at CFFF are broad enough to encompass the manufacture of other special products, or the conduct of other special or unusual activities in the future at CFFF.
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, Extension 3282.
Sincerely, WESTINGHOUSE ELECTRIC CORPORATION v d-Jack B. Allen, Plant Manager Columbia Fuel Fabrication Facility Attachments: Appendix A cc:
U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Regional Administrator, Region 11 Director, Office of Nuclear Mater:al Atlanta Federal Center
- Safety and Safeguards 61 Forsyth Street, SW, Suite 23T85 Washington, DC 10555 Atlanta, GA 30303
_70-1151-97-203, Appendix A August 27,1997 Page 1 of 13 APPENDIX A WESTINGHOUSE RESPONSE TO THE ITEMS OF NONCOMPLIANCE IDENTIFIED IN THE NRC NOTICE OF VIOLATION A.
The following information is provided in response to the Inspectors' observation of Westinghouse's failure to: "... implement proper notification procedures of the event to the NRC."
A.1 ACKNOWLEDGEMENT OF THE VIOLATION As stated at the July 9,1997 predecisional enforcement conference, Westinghouse is in basic agreement with the violation as presented in the Notice of Violation.
In accordance with the Fundamental Nuclear Material Control (FNMC) Plan and implementing Critical Procedure, had the Material Service Attendant (MSA) properly notifLd the MSA Team Manager of the two potentially missing fuel rods (as evidenced l
by the "7-Day Report") on October 16, 1996; and, had the MSA Team Manager properly conducted an item search on October 17-18,1996 and reported the inability to locate the two fuel rods in question to the Safeguards Coordinator, then the Plant Manager (or his designee) would have notified NRC Headquarters per plant procedure, and would have notified the NRC Operations Center within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if it was determined that the two fuel rods were, in fact, lost. Subsequently, the Plant Manager would have submitted a written report of the loss to NRC Headquarters within 30 days; that is, on or before November 20,1996.
A.2 - REASON FOR THE VIOLATION On October 16, 1996, the responsible MSA did not properly act upon the "7-Day Report," which included the two fuel rods in question; and, from October 16,1996 to March 20,1997, the MSA Team Manager neither required that the location of the fuel rods be determined, in accordance with the "7-Day Report" requirements, nor properly reported the status of the fuel rods as potentially missing to the Safeguards Coordinator, as required by the Plant FNMC Plan Critical Procedure. A root cause analysis of the incident disclosed a failure to: instill in Plant employees a high level of sensitivity to item control and accounting, provide adequate training, and implement adequate Material Control and Accounting procedures and practices, as reasons for the MSA and MSA Team Manager's inactions.
A.3 IMMEDMTE ACTION TAKEN AND THE RESULTS ACHIEVED Plant personnel did self-identify the loss of current knowledge of the two fuel rods in March 1997. Thereafter, Plant senier management immediately initiated investigations that eventually located the two missing fuel rods. Management also appointed a Root l
70-1151-97-203, Appendix A August 27,1997 Page 2 of 13 Cause Analy::is Team and an Independent Management Oversight Team to respond to the incident.
In addition, on May 1,1997, the Plant Manager held a mandatory all-management meeting to emphasize the importance of item control and to insure that all employees, through their managers, understood arglicable regulotory requirements. The Plant Manager administered a " Regulatory Training Quiz" which was signed by each manager, reviewed to ensure understanding, and submitted to the Plant Manager. He also distributed Section 5.0, " Safeguards," of the CFFF Regulatory Training Manual, and instructed everyone to read the balance of the material on " Measurement Control,"
" Uranium Accountability" and "SNM Inventory."
Finally, the Plant Manager distributed copies of a letter dated April 30, 1997, signed by him and entitled " Item Control of Nuclear Material," to be distributed and discussed by each manager with each of his/her employees. This letter was presented to each employee by his/her manager, either individually or through group meetings, to ensure that all employees recognized that " item control is a full-time responsibility - every hour of every day during the entire year."
Appropriate management action aim was taken regarding specific personnel performance issues.
These actions were successful in promptly instilling in all employees a high level of sensitivity to item control and accounting.
(NOTE:
Corrective actions taken to provide adequate training and to implement adequate Material Control and Accounting procedures, and results achieved, are discussed in the response to Violations B and E.)
A.4 ACTIONS TO PREVENT RECURRENCE Area manufacturing procedures have been reviewed, revised, as necessary, to incorporate proper instructions related to using the "7-Day Report," approved and reissued. This will assure future timely notification to the Safeguards Coordinator when there is a potentially missing item.
Further, as a result of this incident, it has been recognized that certain language in the FNMC Plan was potentially subject to differing or unbiguous interpretation, which could preclude timely apprisal of NRC Staff. Therefore, the FNMC Plan has been revised, and submitted to NRC for acknowledgment, to clarify the ambiguous language and to add additional commitments for promptly informing the NRC Staff, in the future, should a potential safeguards incident be under investigation.
Also, a plan is being developed to provide an improved method to ensure a timely final accounting of fuel rods when a complete region of fuel has been fabricated and shipped. This action is scheduled to be completed by August 31,1997.
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- 70-11$1-97-203, Appeixlix ~A Aagust 27,1997 -
Page 3 of 13:
A.5 - DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED.
Full compliance has been achieved.
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70-1151-97-203, Appendix A August 27,1997 Page 4 of 13 B.
The following information is provided in response to the Inspectors' observation of 4
Westinghouse's failure to:... provide adequate training for certain employees that handled Special Nuclear Material (SNM)."
B.1 ACKNOWLEDGEMENT OF THE VIOLATION As stated at the July 9,1997 predecisional enforcement conference, Westinghouse is in basic agreement with the violation as presented in the Notice of Violation.
B.2 REASON F3R THE VIOLATION The involved MSA Team Manager was not effective in assuring that personnel reporting to him had an adequate understanding of their duties and responsibilities related to item control. The Manager's failure to follow, or to require the individual MSA to follow, proper procedures with respect to the 7-Day Report further contributed to the failure to properly implement the required training. A root cause analysis of the incident disclosed a failure to: instill in all employees a high level of sensitiviiy to item control and accounting, provide adequate training, and implement adequate Material Control and Accounting procedures and practices, as reasons for the MSA and MSA Team Manager's inaction. Failure to document the training the MSA had received when he first assumed that position was either an oversight by the Team Manager, or the documentation might have been completed and subsequently misplaced.
B.3 IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED Immediate retraining was conducted for the personnel involved in the incident, and training records and documentation were promptly updated. The actions taken to instill in employees a high level of sensitivity to item control, as discussed in the response to Violation A, resulted in the immediate sensitivity of all Plant employees to the applicable item control requirements.
B.4 ACTIONS TO PREVENT RECURRENCE All Manufacturing and Inspection Managers reviewed their employees' training records, and an isolated few were found to need updating. A Manufacturing training procedure also was revised to ensure that there is a clear definition of training update requirements.
Procedures were reviewed, and strengthened, to ensure item control requirements flow from Regulatory Affairs into Manufacturing Operating Procedures.
Area Manufacturing Procedures wer:: reviewed, revised to incorporate proper instructions related to use of the "7-Day Report," approved and reissued. Training, an integral part of the procedure revision process, was also conducted as required.
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- 70-1151-97-203, Appendix A August 27,1997 -
Page 5'of 13 '
A workplace_ meeting script was written and presented to all Fuel Rod Inspectors to emphasize the importance of ensuring that fuel rods are always segregated from replica rods.
- The involved MSA was placed on a documented performance improvement plan. This plan is scheduled to be completed by August 29,1997.
Also, a team was established to review configuration control practices in the Plant mechanical production areas. This action is to be completed by December 31,1997.
B.5 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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70-1151-97-203, Appendix A Angust 27,1997 Page 6 of 13 C.
The following information is provided in response to the Inspectors' observation of 1
Westinghouse's failure to: "... provide adequate procedures for handling and testing of lead-filled rods."
C.1 ACKNOWLEDGEMENT OF THE VIOLATION As stated at the July 9,1997 predecisional enforcement conference, Westinghouse is in basic agreement with the violation as presented in the Notice of Violation.
- C.2 REASON FOR THE VIOLATION Lead-filled rods are frequently used for testing, either as rods, or as " replica" assemblies, which in turn are tested. Typically, over the years, such lead-filled rods have not received weld inspections.
However, as the lead-filled rods that were involved in the incident giving rise to the Notice of Violation had the potential to be used for in-reactor testing at the Temelin Plant in the Czech Republic, they were weld-inspected. This new step in the process of making the Temelin replica assemblies was discussed verbally with Fuel Rod Inspectors involved in the weld inspection, but the potential problems that could result from adding the weld inspection step to the replica assembly manufacturing process were not adequately recognized; and therefore, the procedures were not adequately detailed.
C.3 IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED The CFFF Plant Manager, Product Assurance Manager and Regulatory Affairs Manager issued a joint letter on April 24,1997 that prohibited shipment of all replica fuel assemblies and non-product fuel rods; and, required their approval for future manufacture or movement / transfer of all such items.
Confidence was provided to the Product Assurance Manager that the incident in question was, in fact, an isolated occurrence, and that there was no concern for any other prior replica or non-product shipments, or for ongoing shipments of uranium-bearing fuel rods or fuel assemblies.
C.4 ACTIONS TO PREVENT RECURRENCE A new Manufacturing Procedure was established for the manufacture and movement / transfer of replica rods and assemblies. The Procedure ensures proper identification of such rods and assemblies during prccessing, and requires a radiation survey of the replica rods or assemblies by Regulatory Engineering and Operations prior to shipping.
A Regulatory Affairs Procedure was modified to include requireraents for performing radiation surveys to verify the absence of special nuclear material in replica rods or assemblies.
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70-1151-97-203, Appendix A August 27,1997 Page 7 of 13 A new Procedure was established to instruct Transportation and Shipping personnel that an encapsulated rod of any length, or any type, must have either a QC Release, or a completely signed cff special routing, before shipment.
A workplace meeting script was written and preseraed to all Fuel Rod Inspectors to emphasize the importar.ce of ensuring that fuel rods are always segregated from replica rods.
Instructions have been provided to the Rod Area QC Team Manager and Product Assurance Engineer to ensure that application of inspection requirements, including special instructions, are specified on all special routings.
A Regulatory Affairs Procedure was modified to provide guidance to ensure that item control requirements are properiy incorporated into manufacturing procedures.
Area Manufacturing Procedures were reviewed and revised to incorporate proper instructions related to using the "7-Day Report."
Ten procedures were revised, reviewed, approved and reissued.
Special routing instructions end procedure references were clarified.
A CFFF Team was established to c.asure applicable requirements are incorporated into region orders, and are followed through to certification.
This action is to be completed by September 30, 1997. Another CFFF Team was established to review configuration control practices in the Mechanical Production Areas. This action is to be completed by December 31,1997.
~.5 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
70-1151-97-203, Appendix A August 27,1997 Page 8 of 13 D.
The following information is provided in response to the Inspectors' observation of Westinghouse's failure to:... comply with rnmerous Department of Transportation (DOT) requirements."
7 D.1 ACKNOWLEDGEMENT OF THE VIOLATION As stated at the July 9,1997 predecisional enforcement conference, Westinghouse is in basic agreement with the violation as presented in the Notice of Violation.
D.2 REASON FOR THE VIOLATION Westinghouse is fully committed to complying with all regulations, including 1)OT regulations that apply to shipping of licensed material. The subject violations were incurred simply because Westinghouse was not aware of the presence of licensed material in the " replica" assembly that was being shipped.
D.3 IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED The CFFF Plant Manager, Product Assurance Manager and Regulatory Affairs Manager issued a letter on April 24,1997 that prohibited shipment of all replica fuel assemblies and non-product fuel rods; and, required their approval for future manufacture or movement / transfer ?f all such items. (NOTE: On August 8,1997, the CFFF Plant Manager issued a letter to all CFFF managers, removing restrictions on j
the manufacture, movement / transfer and shipment of replica assemblies and non-fuel products baud on the corrective actions taken to date.)
Confidence was provided to the Product Assurance Manager that the incident in question was, in fact, an isolated occurrence, and that there was no concern for any other prior replica or non-product shipments, or for ongoing shipments of uranium-bearing fuel rods or fuel assemblies.
D.4 ACTIONS TO PREVENT RECURRENCE A new Procedure was established for manufacture and movement / transfer of replica rods and assemblies.
The Procedure ensures proper identification of such rods and assemblies during processing, and require., a radiation survey of the replica rods or assemblies by Regulatory Engineering and Operations prior to shipping.
A Regulatory Affairs Procedure was modified to include requirements for performing radiation surveys to verify the absence of special nuclear material in replica rods or assemblies.
A new Procedure was established to instruct Transportation and Shipping personnel that an encapsulated rod of any length, or any type, must have either a QC Release, or a completely signed off special routing, before shipment.
70-1151-97-203, Appendix A August 27,1997 Page 9 of 13 D.5 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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'.70-1151-97-203, Appendix A'
- August 27,1997 -
Page 10 of 13 E.
The following information is provided in response to the Inspectors' observation of Westinghouse's failure to: "... adequately implement Westinghouse's Material Control and Accounting (MC&A) program."
E.1 ACKNOWLEDGEMENT OF THE VIOLATION As stated at the July 9,1997 predecisional enforcement conference, Westinghouse is in basic agreement with the violation as presented in the Notice of Violation.
E.2 -
REASON FOR THE VIOLATION i
On October 10,1996, two uranium bearing fuel rods were inadvertently placed into the l
same cart as non-uranium bearing lead-filled rods for a " replica" assembly. These two fuel rods were not noticeably different from the lead-filled rods in appearance and were subsequently loaded into the replica fuel assembly.
On October 16,1996, the i
responsible MSA did not act upon the "7-day report," which identified the two fuel rods in question; and from October 16, 1996 to March 20, 1997, the MSA Team Manager neither required that the location of the two fuel rods be determined, in accordance with the "7-Day Report" re.quirements, nor reported the status of the' fuel rods to the Safeguards Coordinator, as required by procedures. A root cause analysis of the incident disclosed an inadequate system of identification and traceability for such replica rods, which, because they do not contain licensed material, did not, at the time, come under item control requirements. The then existing system allowed the lead-filled rods for the replica assemblies to be inspected by the same equipment as uranium bearing fuel rods, with no means to clearly distinguish between the two. This resulted in CFFF personnel inadvertently handling the two uranium bearing fuel rods in the same manner as the lead-filled rods.
The root cause analysis performed for the incident disclosed a failure to: instill in all employees a high level of sensitivity to item control and accounting, provide adequate training, and implement adequate Material Control and Accounting procedures and practices, as reasons the item control system did not function in the intended way to identify and resolve the occurrence of the two potentially missing uranium-bearing rods in a timely manner.
E.3 IMMEDIATE ACTION TAKEN AND THE RESULTS ACHIEVED The CFFF Plant - Manager, Product Assurance Manager and Regulatory Affairs Manager issued a joint letter on April 24,1997 that prohibited shipment of all replica fuel assembles and non-product fuel rods; and, required their approval for future manufacture or movement / transfer of all such items.
Confidence was provided to the Product Assurance Manager that the incident in question was, in fact, an isolated occurrence, and that there was no concet'n for any other prior replica or non-product shipments, or for ongoing shipments of uranium-bearing fuel rods or fuel assemblies.
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70-1151-97-203, Appendix A August 27,1997 Page 11 of 13 The Plant Manager held a mandatory all-management meeting on May 1,1997 to emphasize the importance of item control and to ensure that all managers and their employees, through their managers, understood applicable regulatory requirements.
The Plant Manager's April 30,1997 letter, distributed to all managers at the May 1 all-management meeting, was presented to each employee by his/her manager, either individually or through group meetings, to ensure that all employees recognized that
" item control is a full-time responsibility - every hour of every day during the entire year."
Inunediate retraining was conducted for personnel involved in the incident; and training records and documentation were updated. Appropriate management action was taken regarding personnel performance issues for employees involved in the incident.
E.4 ACTIONS TO PREVENT RECURRENCE A new procedure was established for manufacture and movement / transfer of replica rods and assemblies. The procedure ensures proper identification of such rods and assemblies during processing and requires a radiation survey of the replica rods or assemblies by Regulatory Engineering and Operations prior to shipping.
A new procedure was established to instruct transportation and shipping personnel that an encapsulated rod of any length or any type must have either a QC ' Release or a completely signed off Special Routing before shipment.
A Regulatory Affairs Procedure was modified to include requirements for performing radiation surveys to verify the absence of SNM in replica rods or assemblies.
A Regulatory Affairs Procedure was modified to provide guidance to ensure that item control requirements are properly incorporated in Manufacturing Procedures.
Area Manufacturing Procedures were reviewed to incorporate proper instructions related to using the 7-Day Report. Ten procedures were revised, reviewed, approved and issued.
Instructions have been provided to the Rod Area QC Team Manager and Product Assurance Engineer to ensure that applicable inspection requirements, including special instructions, are specified on all Special Routings.
Awareness of item control requirements, by all employees, has been heightened through meetings and formal training.
In addition, the CFFF Fundamental Nuclear Material Control (FNMC) Plan has been revised, and submitted to the NRC for acknowledgment, to clarify ambiguous language and to add additional commitments for promptly informing the NRC Staff in the future,
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170-1151-97-203, Appendix A
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- August 27,1997 Page 12 of 13 sbould a potential safeguards incident be under investigation.~ All plant procedures that describe item control requirements have been reviewed and revised, as appropriate, to 4
reflect requirements specified in the FNMC Plan.
Assessment of each area's item control performance has become a part of the self-assessment procedure. A plan is being developed to provide an improved method to ensure timely final accounting of all fuel rods when a region of fuel has been fabricated 4
and shipped. This action is to be completed by August 31,1997.
LA CFFF Team was established to ensure applicable requirements are incorporated into region orders, and are followed through to certification.
This action is to be completed by September 30, 1997,. Another CFFF Team' was established to review -
configuration control practices in the Mechanical Production Areas. This action is to
' be completed by December 31,1997.
l E.5 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED.
Full compliance has been achieved, i
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70-1151-97-203, Appendix B August 27,1997 Page 13 of 13 APPENDIX B From CNFD. Columbia. South Caroline Win 426-3300 Deqe t
August g,1997 Subject t Removal of"Renlica" Assembiv RestrictinDE To Columbia Plant Management oc L Fiel M. Mutysle W. Whitehead in April,1997, fbliowing discovery of the medvertent shipment of uranium bearing fbel rods to Temelin in a " replica" assembly, Messrs. W. Goodwin, E. Keelen and J. Flca issued a letter restricting the shipment, manufacture, assembly / disassembly and intamal transfer of" replica" assemblies and non-product Ebel rods.
Following a tremendous effort by many people end ofMcLal reviews by senior Westinghouse management, our Corrective Action Commmes, a specially appointed Root Cause Analysis Team and the NRC, the Condition Adverse to Quality (97 03, "Less of Current Knowledge of Location of CZAF-70 Rods") is recomrnended to be concluded and the restrictions on " replica" assemblies and non product fuel rods lifted.
Much credit goes to the many folks who fullowed through on the problem solving and sorrective actions.
As we prepare to move forward with the new pacticos, we all need to think about what has just taken place.
We publicly embarrassed and penalized our customer and ourselves by not 6dentify6ng the problem swthly, as called for in our operstmg procedures, and by escalating this 6ssue to corporate management and the NRC. All of this because we failed to do what we said we should normally do 6n control of the materials and processes we use. The NRC expressed strong concern for snadequate mariagement attention and oversight toward our licensed activitiew The situation caused us to pay Czech Customs' fines, spend precious resources on problem solving and procedurst changes, and will place Columbia under heightened scrutiny by the NRC during nature compliance inspections.
Fusthermore, any additional escaLted enforcement action teken by the NRC in the near future will most assuredly subject us to a civil penalty.
Thba la not the way we went to be recognized.
f The Columbia Plant is a great operation because of very capable people We know and do ourjobs well it is imperative that each of un not only do the job in accordance with procedures, but it'at we also think about the intent of w5st we are doing and the possible other things that might happen because of things going on around us.
IIach of us has the responsibility to look for better ways of doing things and preventing problems. Regulatory compliance and safety happen because of the attention and concem of every one of us, at all times.
We must reinforse the importance of following procedures and meeting customer exp=actations.
I accept the Corrective Action Committee recommendation to resume operations on " replica" assemblies and non product fuel rods in accordance with the rev6 sed procedures. All operations may proceed under the denned procedures. Let's do them well.
Jack D. Allen Cotumbia Plant Manager
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