ML20214P442
| ML20214P442 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 11/20/1986 |
| From: | Loch E WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8612040208 | |
| Download: ML20214P442 (3) | |
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v Westinghouse rd NOV ?.4 A10 : 3 i Naciear roei aivrsion Manmng Demment Electric Corporation Drawer R Columbia. South Carolina 29250 (803) 776 2610 November 20, 1986 U. S. Nuclear Regulatory Commission ATTN: Mr. J. Nelson Grace Regional Administrator Region II 101 Marietta Street, N.W., Suite 2900 Atlanta, Georgia 30323 RE: tRC Report No. 70-1151/86-11 Gentlemea:
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, in Appendix A, formal response to your letter of October 23, 1986, regarding your inspection of our facilities conducted during the period July 28 to August 1, 1986.
In the above referenced letter, you stated that failure to take full corrective actions on a
previous violation was a
serious matter.
Westinghouse also views this as a serious matter and has taken steps (Appendix A) to prevent a recurrence.
Should you have any questions or require 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, WESTINGHOUSE ELECTRIC CORPORATION
[
E. P. Loch, Manager Columbia Plant 10 WP0233E:3p.36 8612040208 861120 ^
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P' AGE: 10F3 APPENDIX A WESTItCHOUSE' RESPONSE T0 NRC NOTICE OF VIOLATION Violation 86-11-02:
Failure of Procedure No. - HP-01-025 to contain provisions for determining counter efficiency.
(1) Admission or denial of the violation:
While requirements of the FNMC Plan and Regulations are correct as stated in the content of-the Notice of Violation,-
the conclusion of non-compliance appears subject to interpretation.
(2) The reason for the violation if admitted:
Westingnouse believed it was in a state of compliance for the following reasons:
2.1 Section 3.1 of the FtNC Plan states; "As described in Chapter 4.0 of this Plan, only ~ ' key' measurement systems will be monitored by the measurement control program." ' Section 4.2 of the FNMC Plan defines standards and calibrations as part of this measurement control program.
The introduction to Chapter 4.0 of this ' Plan does not include gaseous effluents as a key system to be controlled by this measurement control program.
2.2 Section 3.5 of the F WC Plan states; " Calibration of instruments for analytical. determinations of gaseous and liquid-effluents is described in Appendix E of this Plan." Appendix E of the FtNC Plan discusses use of alpha standards to determine the appropriate counter efficiency. for use in measurement of gaseous samples.
0?. ailed methodology for calculating counter efficiencies is fully covered in documented Health Physics technician modules.
2.3,Although Procedure No.
HP-01-025, "Tennelec LB5100 Calibration Procedure," did not include an efficiency detennination, the instruments efficiencies were being determined routinely and were documented on "Tennelec Data Sheets." In addition, these forms were used for background and performance verifications in accordance with criteria developed oy Nuclear Materials Management.
The Health Physics Operations Manager naa the responsibility for administering this system.
As explained to the inspectors, Westinghouse believed that tnese-administrative controls had been effective in maintaining sound measurement practices for these instruments; ano no performance deficiencies were identified by the inspectors.
Furthermore, Proceoure No. HP-01-024, "Operat. ion of Tennelec Counter Model LB-5100," requires background and check source measurements to be made to assure that the counters are within the operating parameters.
- Again, tne "Tennelec Data Sheets" were used to implement these requirements.
PAGE: 2 0F 3 (3) During the inspection, Westinghouse technical personnel agreed that it might be prudent to revise the Health Physics operating procedures to incorporate specific references to the "Tennelec Data Sheets" and to be more explicit in the efficiency and performance determinations.
The following actions have been taken to address this issue:
(a) Procedure No.01-025, " Calibration of Tennelec LD5100 Automatic Sample Cnangers" has been revised to provide more detailed descriptions of plateau determinations (alpha and beta),
criteria for counter performance (alpha and beta),
detector efficiencies, and records maintenance; and (b) A new procedure,01-026, "Tennelec Background and Efficiency Operation," was written to outline the steps necessary to determine the background and efficiency of each of the automatic sample counters and to verify that the counters are operating in control.
(4) The revised proceoures should be effective in formalizing the calibration system and resolving inspectors' concerns.
(5)'These procedures were implemented by August 25, 1986.
Previous Violation 84-11-03 This violation resulted from a failure to take timely corrective actions when differential pressure readings exceeded eight inches during the month of September 1984.
In the Westinghouse response dated February 18, 1985, the following reasons and corrective actions were reported:
Item 2(2):
"The violation occurred during a period when the Maintenance group did not have a full complement of supervisors.
As a result,- data generated did not receive the proper reviews as to filter changing."
Item 2(3):
"To correct this problem, the logs of daily filter pressure drop readings are now routinely reviewed by a oesignated Maintenance Supervisor.
It will be his responsibility to assure that filters have been changed when required and equipment repaired when needed."
Item 2(4) stated:
"To avoid further violations, the Maintenance procedure for filter systems will be modified to document those changes.
When this last commitment [ Item 2(4)] was mace, it was Delieved that Procedure FP-330, " Changing Absolute HEPA Filters," required revision to incorporate the supervisor review requirements of Item 2(3).
In fact, a procedure already existed which implemented this requirement.
The failure to identify this procedure during the inspection was an oversight Oy Westinghouse personnel.
Consequently, the violation resulted from a failure to follow a procedure as opposed to a oeficient procedure.
To correct this problem, the Chemical Area Maintenance Manager issued a written letter dated January 4,
1985 which committed to these reviews and sign-offs.
These administrative controls have oeen effective in preventing recurrence as confirmed by the inspectors in their inspection report.
PAGE: 3 0F 3 We regret that this commitment was not fully reviewed and resolved during this inspection.
This oversight, however, was largely due to the fact that there were three concurrent regulatory inspections (2 NRC and 1 IAEA) in progress during that week.
We have initiated a computerized tracking system to document items identified during NRC inspections, including indiviauals responsible for corrective actions and required completion dates, to assure that these items are addressed and resolved in a timely manner.
We believe that this system will provide the administrative controls to preclude further problems.
Please rest assured that Westinghouse also views failure to take full corrective actions as a serious matter.
Furthermore, Westinghouse remains firmly committed to full compliance with all applicable regulatory requirements.
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