ML20236Q245
| ML20236Q245 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 07/14/1998 |
| From: | Allen J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-98-022, CON-NRC-98-22 70-1151-98-201, NUDOCS 9807200092 | |
| Download: ML20236Q245 (4) | |
Text
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We'stinghouse
. Commercial Nuclear Drawer R Electric Corporation Fuel Division fg@asgp9Mna 29250 g
NRC-98-022 July 14,1998
-. S. Nuclear Regulatory Commission
' ATTN: Document Control Desk Washington, DC 20555 Gentlemen:
SUBJECT:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
REPORTNO: 70-1151/98-201 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 June 10,1998, regarding your inspection of the Columbia Fuel Fabrication Facility conducted during the period of May 4-8, 1998.
Appendix A of this document addresses the NRC concern expressed in the Notice of Violation cover letter that the violation,... " indicates an incomplete understanding of licensee requirements to maintain current knowledge of items listed in the item control program. Current knowledge of items must be maintained to ensure the safeguards risk of material loss, theft, or diversion is adequately addressed."
Appendix B provides a response to the particular violation 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 Ext. 3282.
- Sincerely.
WESTINGHOUSE ELECTRIC COMPANY b.
JWk B. Allen,' Plant Manager l
Columbia Fuel Fabrication Facility l
l
' Attachments:
, Appendix A t o[/
l Appendix B '
U. S. Nuclear Regulatory Conunission cc:
Regional Administrator. Region II Atlanta Federal Center 61 Forsyth Street. SW. Suite 23T85 Atlarna. Georgia 30303-3415
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- 70-1151/98-201
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Page 1 of 3 July 14,1998 APPENDIX A WESTINGHOUSE RESPONSE TO COVER LETTER CONCERN The following information is provided in response to the concern expressed in the cover letter of the Notice of Violation that: "The violation is of concern because it indicates an incomplete understanding of licensee requirements to maintain current knowledge of items listed in the item control program.
Current knowledge of items must be maintained to ensure the safeguards risk of material loss, theft, or diversion is adequately addressed."
Westinghouse believes that the Plant framework of policies and procedures properly reflect our l
understanding of item control requirements as stated in the Fundamental Nuclear Material l
Control Plan and 10CFR74, and, of the need for meticulous compliance with such requirements. Detailed item control procedures are currently in effect which implement these requirements. However, we do concur that execution of the item control program must be o
1 strengthened to ensure that item control requirements are continually met. The specific actions detailed in Appendix B are intended to meet this need.
Because of importance that must be placed on item control responsibilities, and to take another comprehensive look at item control implementation upsets that have occurred at the facility over the past couple of years, the Plant Manager has augmented specific-cause actions with a broad-based review, by assembling a " Material Control and Accoun6 ig Risk Reduction i
Team," consisting of key management and professional personnel, to evaluate the total item control program and to make improvement recommendations to upper management for implementation as appropriate. The team is focusing on areas such as personnel training, implementing procedures, organization, item control compliance assurance audits, and control of " unique" processes.
The team is scheduled to complete its evaluations, and submit recommendations for management review, by September 30,1998.
These actions are intended to ensure that current knowledge of location of items is maintained, and to address the safeguards risk of licensed material loss, theft, or diversion.
I l
i
70-1151/98-201 Page 2 of 3 July 14,1998 APPENDIX B l
WESTINGHOUSE RESPONSE TO NOTICE OF VIOLATION B.1 The following information is provided in response to Violation 98-201-02 for failure to
... maintain current knowledge of a drum of contaminated fuel rod tubing from December 10,1997 until February 6,1998. The tubing was intentionally shipped from Westinghouse on December 10, 1997, but the drum was not removed from the item control record. On January 6,1998, the item appeared on the item control 7-day report for the first time. However, no one was notified that the item could not be located until February 6,1998."
B.I.a ACKNOWLEDGMENT OF THE VIOLATION l
l The violation is correct as stated in the Notice of Violation.
B.I.b REASON FOR THE VIOLATION The violation resulted from failure of operations personnel to adhere to relevant item control procedural requirements; and, failure of a management representative to promptly notify the Safeguards Coordinator within five working days of initial disclosure of a potentially missing item, in accordance with the approved procedure.
B.I.c IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED The following actions have been implemented:
(1) The drum was verified as being properly shipped (completed 2/16/98)
(2) The item control record for the drum was corrected (completed 2/20/98)
(3) The Safeguards Coordinator was notified and NRC Staff was apprised via telecon (completed 3/11/98)
(4) An independent verification of 7-day reports was performed (completed 3/12/98).
This resulted in full compliance.
. B.I.d ACTIONS TO PREVENT RECURRENCE The following additional actions have been implemented:
(1) All applicable Item Control System (ICS) operating procedures were revised to alternate operator responsibilities for performing 7-day summary audits, require operators to place a checkmark beside each item found on the 7-day report, perform the necessary ICS transactions to reflect the current status of the items, document on the 7-day report all transactions that had to be performed to correct the item L
70-1151/98-201-Page 3 of 3 July 14,1998
' control record, sign the report and the cover sheet (MA400-1) to indicate all items were physically located and item status updated to current status, and return the signed documents to the Area Team Manager (completed 4/30/98). Operator acknowledgment of these procedures constitutes training for these individuals.
(2) A ' signature form was created, and is now attached to each 7-day report, which certifies that individuals have physically verified (by personal viewing of the identification number) the presence of each i.em listed on the report; or, have promptly reported each item which could not be so verified (located) to the appropriate Team Manger. The form also documents that individuals have been properly trained to perform item control responsibilities, and the proper reporting to the Database Coordinator and the Safeguards Coordinator (completed 4/30/98).
(3) Procedure MA-400 was revised to provide for periodic independent overchecks of 7-day reports by the Uranium Programs Group (completed 4/30/98).
(4) Procedure COP-831010, " Shipping of Low Level Radioactive Waste", was revised to require proper ICS transactions for all applicable items (completed 4/30/98).
(5) URRS Operators were specifically retrained in the importance of following procedures, with emphasis on item control transactions, proper completion of the 7-day reports (including the importance of a " physical verification"), and prompt notifications of missing items (completed 4/1/98).
As stated in Appendix A, a Material Control and Accounting Risk Reduction Team has been formed to evaluate the total item control process and to make recommendations for any perceived needs for improvement.
The team is expected to publish its recommendations by September 30, 1998.
Management will then evaluate the recommendations in a timely manner and implement appropriate controls.
B.I.e DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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