ML20216J425
| ML20216J425 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 04/17/1998 |
| From: | Allen J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-98-014, CON-NRC-98-14 07-1151-97-205, 7-1151-97-205, NUDOCS 9804210381 | |
| Download: ML20216J425 (5) | |
Text
l Westinghouse Commercial Nuclear Drawer R Electric Corporation Fuel Division fggy,aY6ga@na 29250 6
NRC-98-014 April 17,1998 U. S. NUCLEAR REGULATORY COMMISSION
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ATTN: Document Control Desk Washington, DC 20555 Gentlemen:
SUBJECT:
WESTINGHOUSE REPLY (NRC-98-004) TO A NOTICE OF VIOLATION DATED FEBRUARY 5,1998
REFERENCES:
- 1) NRC LETTER TO WESTINGHOUSE DATED MARCH 20,1998
- 2) NRC NOTICE OF VIOLATION - INSPECTION REPORT NO. 70-1151/97-205
- 3) WESTINGHOUSE LETTER (RA-WLG-97-057) TO NRC DATED DECEMBER 12,1997
- 4) NRC LICENSE SNM-1107/ DOCKET 70-Il51 l
Westinghouse herein provides a formal response to your letter v.ated March 20,1998, requesting supplemental information relative to our reply to a NotiFbf Violation dated February 5,1998.
Attachment I addresses appropriate subtasks and target completion dates for corrective actions, l
I identified in Item B.4 of our reply to the subject Notice of Violation, which are not scheduled to
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be completed within one (1) year. As the Criticality Safety Evaluations (CSEs) are upgraded to l
correct shortcomings pointed out by NRC Staff reviewers, a summary in the format of the
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License Annex (similar to that sent on March 27,1998 for Plant Ventilation Systems) will be submitted to NRC Staff. These summaries will be maintained as current documents. When Westinghouse makes a decision to change the License Annex, the NRC Licensing Project Manager will be apprised of the decision via e-mail or facsimile. Within 30-days of this apprisal, changed pages to update the License Annex will be submitted to NRC Staff. Structured Process Hazard Analyses (HAZOP or What-If/ Checklist) will be added to the upgraded Criticality Safety Evaluations (CSEs) as they are elevated to Integrated Safety Assessments (ISAs). 'lhe only other corrective action not scheduled to be completed within one (1) year is development of our Integrated Safety Assessment (" Final Design Safety Basis"), which remains unchanged from the schedule committed in our approved SNM 1107 License.
In regard to the item in your letter that requests identification of those actions that have been, or will be, taken to improve communications between the Westinghouse Staff and NRC Staff, the following information is provided. On Mar:n 31, 1998, the Westinghouse Columbia Fuel Fabrication Facility (CFFF) Plant Manager and members of his staff met with representatives of the NRC Fuel Cycl Safety and Safeguards Division's Licensing Branch to discuss Westinghouse's proposed revisions to its NRC incident notification criteria. As a result of that meeting, Westinghouse and NRC reached a tentative agreement regarding the incident notification 7[\\
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'NRC-98-014 Page 2 April 17,1998 criteria, which were subsequently formally submitted to NRC on April 3,1998 for inclusion in Chapter 3 of the Westinghouse SNM 1107 License.
It should be noted that the subject notification criteria included a Westinghouse commitment to provide infonnal apprisals of NRC Region II Staff, pertaining to matters that may be of regulatory interest, when formal notifications
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are not required. Furthermore, it should also be noted that our most. ent NRC Licensee i
Performance Review letter dated April 2, 1998, acknowledged e improvements in communications between Westinghouse Staff and NRC Staff.
In addition to the information specifically reques:ed above, Westinghouse is providing the information in Attachment II, pertaining to our onping Safety Margin Improvement Program (SMIP) initiatives, to promote NRC understandiaj and appreciation for the magnitude and comprehensiveness of our efforts with respect to full compliance with all SNM-Il07 License requirements at the CFFF. This information was presented to, and briefly discussed with, NRC offh:ials participating in the Westinghouse Licensee Performance Review (LPR) meeting conducted on April 16, 1998.
The target completion dates provided in these attachments supersede those provided in Item B.4 of our reply to the subject Notice of Violation, as well as, those provided in Item 1 of our letter identified in Reference No. 3 above.
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1 hereby affinn that the statements made in this response are true and correct to the best of my i
knowledge and belief. Should you have any questions or require additional information, please I
telephone Mr. Wilbur L. Goodwin of my Staff at (803) 776-2610 Ext. 3282.
Sincerely, 1
l WESTINGHOUSE ELECTRIC COMPANY Q h ha. _
l l
c B. Allen, Plant Manager Columbia Fuel Fabrication Facility Il.
Attachments:
J cc:
U. S. Nuclear Regulatory Commission ATTN: Director, Division of Fuel Cycle Safety & Safeguards Two White Flint North 11545 Rockville Pike -
J Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commisskm Regional Administrator, Region II Atlanta Federal Center 61 Forsyth Street, SW, Suite 23 i85 Atlanta, Georgia 30303-3415
NiiC-98-014 April 17,1998 ATTACIIMENT I CSA/CSE UPGRADE SCHEDULE TARGET COMPLETION DATE PROCESS SYSTEM 2Q98 UN Tanks
- 3Q98 ADU Conversion
- Rods (ADU & IFBA)
UF Cylinder Washing 4Q98 ADU Pelleting URRS Dissolver*
Powder Blending (ADU)*
l IQ99 Low-Level Waste Processing l
Hoods & Containment 2Q99 URRS Scrap Processing Solvent Extraction URRS Waste Treaunent 3Q99 Final Assembly Storage IFBA (Excluding Rods)
Laboratories I
- Will be done as ISAs (" Final Design Safety Basis")
, NilC-98-014 April 17,1998 ATTACHMENT II ONGOING SAFETY MARGIN IMPROVEMENT PROGRAM (SMIP) INITIATIVES TARGET INITIATIVE COMPLETION DATE Interim Design Safety Basis (CSAs/CSEs) 3Q99 e
Eight Tasks - Five Team Members Quality Assurance and Maintenance of Safety Controls 4Q98 e
Eight Tasks - Fourteen Team Members Management of Change 4Q98 e
Five Tasks - Seven Team Members Compliance Quality Assurance 4Q98 e
Twenty-five Tasks - Nineteen Team Members License Requirements in Policies and Procedures 4Q98 e
Six Tasks - Seven Team Members Incident Management and Notification 3Q98 l
Six Tasks - Six Team Members Recordkeeping and Document Control 3Q98 e
Four Tasks - Nine Team Members Final Design Safety Basis (ISA) 4Q02 Nine Tasks - Fourteen Team Members Management Oversight and Control 2Q98 e
Three Tasks - Eleven Team Members
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