ML20202F094
| ML20202F094 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 01/29/1999 |
| From: | Allen J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-99-003, CON-NRC-99-3 70-1151-98-10, NUDOCS 9902030324 | |
| Download: ML20202F094 (7) | |
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Westinghouse Commercial Nuclear orawer n Electric Corporation Fuel Division
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NRC-99-003 January 29,1999 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Gentlemen:
SUBJECT:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
REPORT NO:70-1151/98-10 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 December 31, 1998, regarding your inspection of the Columbia Fuel Fabrication Facility (CFFF) conducted during the period of December 7-11,1998.
Appendix A of this document addresses the NRC concern expressed in the Notice of Violation cover letter that, "The violations are of concern because they indicate a continuing trend of inattentiveness to procedural requirements and details." Appendix B provides a response to the particular violations of NRC requirements specified in the Notice of Violation.
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 COMPANY
/
gd 8. k Tack B. Allen, Plant Manager Columbia Fuel Fabrication Facility
{ } Q()) d Attachments:
Apperalix A Apperxiix B cc:
U.S. Nuclear Regulatory Commission Regional Administrator, Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta. Georgia 30303-3415
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9902030324 990129 PDR ADOCK 070011510
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70-1151/98-10 Page 1 of 2 January 29,L1999 APPENDIX A
. ESTINGHOUSE RESPONSE TO COVER LETTER CONCERN W
1 The Notice of Violation dateil December 31,1998 states that "The violations are of concern because they indicate a continuing trend of inattentiveness to procedural requirements and details." This is our response to the strong enforcement language in the Notice of Violation.
In early September 1998, we accelerated our efforts to improve procedure compliance. The.
effort started with meetings with all Chemical Operations employees, introduced by the Plant Manager (or the Manufacturing Manager acting for the Plant Manager). The communications effort continued into the other areas of the plant beycnd Chemical Operations.
During these meetings, management stressed the need for procedure compliance and related it to recent incidents. It was also re-emphasized that whenever a step in a procedure cannot be followed, or if an operation is not covered by procedure, the employee is to stop and notify the Team Manager.
A major part of the procedure compliance improvement effort is a comprehensive review of all Chemical Operating Procedures (COPS). In November 1998, we initiated a major effort to reformat all 289 COPS. The new procedure format was designed with an intense focus on Human Factors considerations, learned from an outside consultant who is a leader in the field.
The process for reformatting the procedures starts with the Area Trainer, who takes the existing procedure and. rewrites it into. the new format. Then, operators on all three shifts critically review this draft procedure. The draft procedure is then returned to the Area Trainer
. who incorporates the operators' corr.ments, as appropriate. Next, the Area Engineer reviews the' draft procedure for technical sotmdness. If there is a significant difference between the Area Engineer and the operators with any step in the draft procedure, the two parties get together to resolve the difference. Finally, the draft procedure is entered into our electronic procedure system for official review and approval, i
Having 289 procedures to reformat via this process, we had to establish priorities. We chose to start with operations (and the cormsponding procedures) with the highest potential for a safety significant incident. In other wo ds, we took a " risk-based" approach.
Since the process is comprehensive, it's time-consuming. So it will likely take a few years to reformat all 289 COPS. In the meantime, we continue to enhance the existing procedures when we find the need to do so.
With this process, we are continually upgrading our procedures. The process itself nelps keep the procedure compliance improvement effort visible across the plant --
Management oversight and control at all levels maintains our focus on this effort.
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e We will continue with our " risk-based" approach until all COP procedures have been
. reformatted. Management will also continue to reinforce the importance of always following procedures, and_ stopping operations when a procedure cannot be followed or an operation is not covered by a procedure.
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70-1151/98-10 Page 1 of 4
' January 29,1999 APPENDIX B WESTINGHOUSE RESPONSE TO NOTICE OF VIOLATION 1
B.1 The following information is provided in response to Violation 98-10-02 for failure to conduct operations involving SNM (sample cups of material from polypaks in storage racks) without an approved procedure or proper nuclear criticality posting.
B.1.a ACKNOWLEDGMENT OF THE VIOLATION l
The violation is correct as stated in the Notice of Violation based upon the information presented to the inspectors during the visit.
B.1.b REASON FOR THE VIOLATION For the polypak storage rack in question, plant operations include the following:
1)
Questionable material oxidized in the Conversion Area Scrap Cage is j
temporarily stored in polypaks, in fixed (orange) storage racks, prior to proceeding to solvent extraction.
2)
A 10 gram sam'ple of material is removed from each polypak, placed into a small plastic cup, and temporarily kept in the storage rack with the parent polypak until all polypaks in a sample group are sampled.
3)
Other sample material is not kept in the rack, i.e., the cup remains in the rack with the parent polypak.
4)
The 10 gram individual samples are taken to a hood for preparation of a composite sample for analysis of a batch of polypaks.
5)
The composite sample - for the batch is taken to the Analytical Services-Laboratory for analysis.
6)
After sample results are determined, the polypaks are transferred to solvent extraction as needed.
These sample cups in the rack were not specifically addressed by the respective criticality postings. During the inspection, the inspectors were incorrectly told that placing the cups with 10 gram samples into the storage racks was not covered by procedure. Subsequent to the close of the inspection, however, it was determined that there is an operating procedure (COP-815002, Revision 23, 8/1/97) that specifically addresses this. Section 5.2 states: "Put a 10-gm sample in a dixie cup. Label sample with polypak number and store with the polypak in orange output rack."
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70-1151/98-10 Page 2 of 4 January 29,1999 B.1.c IMM5?DIATE ACTION TAKEN AND RESULTS ACHIEVED When the question arose, the inspectors were presented with information demonstrating that there was no criticality concern. Specific conservatisms in the analyses for the rack were identified that more than compensated for small amounts of material from the polypaks being stored anywhere in the rack.
1 An evaluation was made immediately to determine if there were any other racks in the same situation. It was determined that the orange racks in question are the only racks in which sample cups are routinely stored. Therefore, the criticality posting for the rack was changed to specifically allow sample cups of material from the polypaks in the racks to be stored anywhere in the rack. This change was made on the day before the final day of the inspection.
B.I.d ACTIONS TO PREVENT RECURRENCE In addition to the routine storage of sample cups in the orange racks, it was determined that there was the possibility of temporary storage of sample cups in other polypak j
racks just prior to annual SNM inventory. A complete review was conducted of all polypak storage racks, resulting in recommendations for revised criticality postings.
L These recommendations are in the process of being evaluated by Management and the l
Product / Process Improvement Teams (PPIT) for each area of the plant.
Implementation is scheduled by February 16,1999.
The above actions, along with the enhancements described in Appendix A, are expected to improve the sample storage process.
B.1.e DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED February 16,1999
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70-l151/98-10 Page 3 of 4
. January 29,1999
. B.2 The following information is provided in response to Violation 98-10-03 for failure to follow procedure and remove cracked pellet sintering boats from service.
B.2.a ACKNOWLEDGMENT OF THE VIOLATION i
The violation is correct as stated in the Notice of Violation.
B.2.b REASON FOR THE VIOLATION Operating Procedure COP-822522 Revision 3 dated 9/21/95 is titled " Repair of Pellet Sintering Boats". Paragraph 7.1 states, " Identify and collect sintering boats for repair.
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Place boats that will not pass through boat measuring gage or cracked / broken boats on
. side of "A" furnace in each line. (See Sketch No. 822522-1)."
4 The sketch referred to above shows rejectable and acceptable conditions for " warped" moly boats.
The sketch does-~not show rejectable and acceptable conditions for
" cracked" moly boats. We rely on the extensive experience of our Pellet Operators to 4'
. determine when a crack in a boat is severe enough to require repair. This has been very successful for us, and in fact, we had no " furnace jams" in 1998 due to cracked boats, warped boats, etc. Our performance in this area was exceptional.
In November 1998, we initiated a major effort to reformat and revise all 289 of our Chemical Operating Procedures (COPS), including the 63 Pellet Area COPS. We chose operations with the highest potential for a safety significant incident, and started revising the procedures related to those operations first. In other words, we took a
" risk-based" approach. The procedure mentioned above was not part of an operation with the highest potential for a safety significant incident; therefore it had not yet gone through the extensive critical review and reforma: process.
B.2.c IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED After discussing this with the Inspector during the visit, it was determined that no immediate action was required as this was determined to be not safety significant.
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- 70-1151/98-10 Page 4 of 4 January 29,1999 B.2.d ACTIONS TO PREVENT RECURRENCE Operating Procedure COP-822522 Revision 3 dated 9/21/95 titled " Repair of Pellet
- Sintering Boats" is being revised to modify the requirement for dispositioning cracked moly boats. Removal of cracked boats from operation will continue to be decided by and based on the experienced Pellet Operators and Team Managers.
The above actions, along with the enhancements described in Appendix A, are expected to prevent recurrence.
B.2.e DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance, that is, revision to COP-822522, will be achieved by February 16, 1999.
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