ML20203A082

Notice of Violation from Insp on 971103-07.Violation Noted: Health Physics Audit Conducted 970128-0203 Only Included Review of RP Procedures in Context of Impact on EP & Did Not Consist of Review of Effectiveness of Procedural Controls

ML20203A082
Person / Time
Site:	07001201
Issue date:	12/05/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203A076	List: ML20203A072 ML20203A082 ML20203A089
References
70-1201-97-06, 70-1201-97-6, NUDOCS 9712110274
Download: ML20203A082 (2)

Text

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NOTICE OF VIOLATION Framatome Cogema Fuels Docket No. 70-1201 Lynchburg Manufacturing Facility License No, SNM-1168 During an NP,C inspection conducted on November 3 through 7, 1997, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Action." NUREG-1600, the violation is listed below:

License Condition No, S-1 of Special Nuclear Material License No. 1168 (SNM-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, Cnapter 2. Section 2.7 Audits and Insoections, Subsection on Indeoendent Audits states that independent nuclear safety, fire safety, and health physics audits shall consist of a review of the effectiveness of procedural controls; audits of operating records: review and evaluation of contamination survey data: and ascertaining the overall performance of plant functions in providing adecuate controls, surveillance, and follow-up to assure safety anc license compliance, Licensee procedure SL-1150 Rev. O Health-Safety Audits reiterates the above requirements and states that the audit report shall be subaitted to the Plant Manager for review.

Contrary to the above, independent safety audits conducted in 1997 were not adequately conducted in that:

1. The Health Physics audit conducted January 28 through February 3, 1997, only included a review of radiological protection procedures in the context of their impact on emergency preparedness, and did not consist of a review of the effectiveness of procedural controls; audits of operating records: a review and evaluation of contamination survey data: and ascertaining the overall performance of plant functions in providing adecuate controls, surveillance, and-follow-up to assure safety anc license compliance.

2. The Nuclear Criticality Safety audit conducted April 30, 1997, only included checklists of items that provided a snapshot of the operation on the day of the audit by checking operator com311ance with safety postings, and did not consist of a review of t7e effectiveness of procedural controls; audits of operating records:

and ascertaining the overall providing adequate controls,surveillance, performanceand of plant functions follow-up in to assure safety and license compliance.

3. The Health Physics and Nuclear Criticality Safety audits conducted Enclosure 1 9712110274 9712GS PDR C ADOCK 07001201 PDR

j Notice of Violation 2 June 30 through July 3. 1997, did not include evaluations of the effectiveness of procedural controls, nor an overall assessment of plant functions in providing adequate controls, surveillance, and follow-up to assure safety and license compliance. Also, as of November 7, 1997, reports for these audits had not been submitted to the Plant Manager for review.

This is a Severity IV violation (Supplement VI).

Pursuant to the provisions of 10 CFR 2.201. Framatome Cogema Fuels is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission. ATTN: 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 re marked as a " Reply to a Notice of Violation" and shoul; include ply should be clearly 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, end (4) the date when full compliance will be achieved. Your response may ceference or include previously docketed correspondence, if the correspondence adequately addresses the required res)onse. If an adecuate reply is not received within the time specified in t1is 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 3e given to extending the response time.

Because your res)onse will be placed in the NRC Public Document Room (PDR). to the extent possi)le, it should not include any personal privacy. 3roprietary, or safeguards information so that it can be placed in the PDR witlout redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your-

' response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must s)ecifically identify the portions of your response that you seek to have withleld, and 3rovide in detail the-bases for your claim of withholding (e.g. , explain why t1e disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta. Georgia this 5th day of December, 1997

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