ML20206C795

Responds to NRC Re Violations Noted in Insp Rept 70-1151/88-13 on 880829-0902.Corrective Actions:Trailers Posted Per 10CFR20.203(e) by 880902 & Locks Placed on Trailers W/Keys Controlled by Cognizant Individuals

ML20206C795
Person / Time
Site:	Westinghouse
Issue date:	11/08/1988
From:	Loch E WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8811160406
Download: ML20206C795 (4)

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203 176200 November 8, 1988 U. S. Nuclear Regulatory Comission ATTN Document Control Desk Washington, DC 20555 Dear Sir RETERENCE:

NRC Inspection Report No. 70-1151/88-13 Reply to a Notice of Violation Pursuant to the provisions delineated in 10CFR2.201 of the NRC's "Rules of Practice," Westinghouse herein provides, in Appendix A, formal response to your letter f October 12, 1988, regarding the inspection of our facilities by your Mr. M. T. Lauer conducted during the period of August 29 - September 2, 1988.

Should you have any questions or reqLire additional information, please telephone me at (803)776-2610.

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

Sincerely, VE3TINCHOUSE ELECTRIC CORPORATION 97}$a])l%L E. Paul Loc, Manager Columbia ruel Fabrication racility Attachments: Appendix A 1m WP2812E:3p.11 cci U. S. Nuclear Regulatory Comission, Region II Regional Adminstrator 101 Marietta Street, N. W.

Atlanta, GA 30323 8911160406 831103

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70-1151/88-13 November 8, 1988 t

APPENDIX A WESTINGHOUSE RESPONSE TO NRC NOTICE OF VIOLATION A.

Concerning the citation for failure to post storage trailers in accordance with 10CFR20.203(e), the following comments are provided:

1.

The citation is correct as stated in the Notice of Violation.

2.

In implementing Section 3.2.2.4 of License SNM-1107, we previously considered the trailers as "containers" as used in this Section.

Af ter further review, however, we agree with the inspector that storage of radioactive materials in trailers should be subject to the posting requirements of 10CFR20.203(e).

3.

The following actions have been taken (a) The trailers were posted in accordance with 10CTR20.203(e) by September 2, 19888 (b)

Locks were placed nn the trailers, with the keys controlled by cognizant individuals, by September 2,

19888 (c) Regulatory Affaire Procedure RA-102, "Plant Inspection Program for Regulatory Compliance," was revised to include trailer posting and locking in the inspection check list.

Routine audits are being performed to verify compliance. This was completed by November 3, 1988.

These actions have been effective in maintaining compliance.

4 Regulatory Affairs Procedure 402, "Material Transfers to Storage l

Areas outside Manufacturing Buildings" was revised to augment l

management concrols for movement of radioactive materials outside of manufacturing buildingst (a) Coordination responsibilities are defined, (b) Storage areas are delineated, (c) Locking, posting and key controls are specified, and (d) Contamination control l

criteris are included.

l Furthermore, Health Physics Operating Procedure 05-015, "Abandonment or Disposition of Material or Equipment " was revised to provide improved guidance to Regulatory Operations personnel when releasing radioactive materials from the Contamination Controlled Areas.

In addition to the changes to RA-102 described in Item A.3(c) above, this procedure was also modified to provide audits for 11htr outside storage areas to assure that posting, labeling and contamination control criteria are appropriate.

5.

Full compliance has been achieved.

B.

Concerning the citation for failure to follow procedures regarding dispersion of radioactive material, the following comments are provided:

1.

The citation is correct as stated in the Notice of Violation.

1

70-1151/88-13 N:vember 8, 1988

'Pcge 2 2.

Some of the equipment and materials released to the trailers were originally bagged in accordance with Health Physics Operating Procedure 05-015 to prevent dispersion of radioactive materials.

Bag deterioration resulted in the conditions observed on August 31, 1988 as described in the NRC Inspection Report.

This condition was not identified as a concern since the trailers were considered as secondary containment.

The effectiveness of the trailers as a containment barrier was verified by contamination surveys.

We believe that the degree of containment and contamination control criteria should be consistent with both the environmental conditions and storage location, and the corrective actions given below are intended to clarify these points in the procedures and to previde additional conttols for materials in storage.

J 3.

The following a c t ion.- have been takent (a) Regulatory Affairs l

Procedure RA-402 was revised to clarify the types of containment generally deemed acceptable for storage outside the manufacturing building.

(Nots the additional changes to this procedure outlined i

in Item A.4 above.) This revision requires containment consistent

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with storage conditions, (b) Health Physics Operating Procedure 05-015, "Abandonment and Disposition of Material or Equipment,"

q was revised to provide additional guidance for Health Physics i

Technicians when surveying equipment and materials to assure that j

they are properly contained and tagged, and (c) A Radiation Work Permit has been written to control access to trailers from a f

radiation protection standpoint.

j In summary, additional management controls have been placed on movement of radioactive materials outside manufacturing buildings j

(degree of containment and storage location), additional controis j

have been instituted for materials in storage (security and 1

contamination control), and the audit pra;. m (RA-102) has been j

enhanced to inspect for compliance.

I 4

The audit program revision described in Item A.3(c) should be J

effective in assuring continued compliance.

5.

Full compliance has been achieved.

C.

Concerning the citation for failure to perform weekly contamination surveys in the Expansion Decontamination Area, the following comments i

are provided:

i i

1.

The citation is correct as stated in the Notice of Violation.

The area in question was approved for operation in January 1988.

.i Regulatory Affairs Procedure RA-104, "Regulatory Affairs Review

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Requests," is used as the control document for reviewing and

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approving additions or modifications to the facility.

In addition

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to providing the mechanism for revieving new or modified equipment or facilities, the procedure also provides follovup to verify compliance with the review request requirements.

The folle.rup form, however, was not specific to contamination control.

This contributed to a failure to include this area in the routine contamination surveillance program.

70-1151/88-13 i

6 N;vember 8, 1988

~Page 3 3.

Contamination surveys were performed immediately in the Expansion Decc.'tamination Area.

This area was also included in the contamination surveillance

program, and routine contamination surveys are now being taken in accordance with procedure, effective September 6, 1988.

4.

Regulatory Affairs Procedure RA-104 was revised effective September 30, 1988 to include a "checklist" of items requiring

follovup, including contamination control.

As new areas and equipment are approved, this checklist vill be used to verify implementation of requirements.

A review vas performed of the contamination surveillance of other areas of the Columbia Plant to assure that appropriate surveys are being taken.

5.

l'ull coc:pliance has been achieved.

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