ML20236U122
| ML20236U122 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 07/20/1998 |
| From: | Allen J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CON-NRC-98-025, CON-NRC-98-25 70-1151-98-04, 70-1151-98-4, NUDOCS 9807290317 | |
| Download: ML20236U122 (4) | |
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i Westinghouse Commercial Nuclear orawer a Electric Corporation Fuel Division fjn'e2eio***
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July 20,1998 U.S. NUCLEAR REGULATORY COMMISSION ATTN:
Document Control Desk Washington, DC 20555, Gentlemen:
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SUBJECT:
REPLY TO'A NOTICE OF VIOLATION
REFERENCE:
REPORT NO:70-1151/98-04 Pursuant to the prosisions delineated in Section 2.201 of the NRC's " Rules of Practice", Part 2, Title 10, Code of Federal Regulations, Westinghouse herein proviaes formal response to your letter of June 25, 1998, regarding your inspection of the Columbia Fuel Fabrication Facility (CFFF) conducted during the period of June 1-4,1998.
Appendix A of this document addresses the NRC concern expressed in the Notice of Violation cover letter that, "The violations are of concern because they reflect a lack of knowledge of commitments in your Physical Security Plan and your implementing procedures." Appendix B provides a response to the particular violations of NRC requirements specified in the Notice of f
Violation.
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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, Extension 3282.
y Sincerely, WESTINGHOUSE ELECTRIC COMPANY Jack B. Allen, Plant Manager Columbia Fuel Fabrication Facility Attachments:
Appendix A
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Appendix B cc:
U.S. Nuclear Regulatory Commission l
Regional Administrator, Region H Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-3415 9807290317 980720 F
PDR ADOCK 07001151 m C
i 70-1151/98-201 i
Page 1 of 3 I
July 20,1998 APPENDIX A
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WESTINGHOUSE RESPONSE TO COVER LETTER CONCERN The following information is provided in response to the concern expressed in the cover letter I
of the Notice of Violation that: "The violations are of concern because they reflect a lack of knowledge of commitments in ycur Physical Security Plan and your implementing 3
procedures".
1 During the period from June 29 to July 1,1998, the CNFD Safeguards Review Board (SRB)
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conducted an independent assessment of Columbia Plant Safeguards, including Physical Security. The assessment included a review of knowledge of commitments in the Physical Security Plan and Security Procedures. The SRB concluded that, although improvements could be made in oversight and visibility of commitment to meticulous compliance, there was good understanding of commitments in the Physical Security Plan and implementing procedures.
Notwithstanding this conclusion, to enhance the knowledge process, we have expanded an existing Safety Margin Improvement Program initiative to include a sub-task for documenting how all Physical Security Plan commitments are reflected in implementing procedures or other appropriate documents. This effort is in addition to that being developed for other documents such as the SNM-1107 License Application and the Fundamental Nuclear Material Control Plan. This sub-task is scheduled for completion by November 30,1998.
In further response to your concern regarding lack of knowledge of commitments in implementing procedures, all security personnel have been retrained on the importance of understanding and following procedures.
We believe that the above actions will address your concern, and will enhance knowledge of commitments in our Physical Security Plan and our implementing procedures.
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70-1151/98-201-Page 2 of 3
. July 20,1998 APPENDIX B WESTINGHOUSE RESPONSE TO NOTICE OF VIOLATION B.I' The following information is provided in response to Violation 98-04-03 for failure to properly escort a' commercial vehicle and its driver to and from the No. 2 Warehouse as required.
B.I.a ACKNOWLEDGEMENT OF THE VIOLATION The violation is correct as stated in the Notice of Violation.
~ B.I.b REASON FOR THE VIOLATION The violation resulted from poor judgment and inattention to detail on the part of security personnel for failure to verify that the driver / vehicle was being escorted by Warehouse personnel once the driver arrived at the Warehouse. The officer incorrectly assumed that Warehouse personnel would be available to provide follow-on escort.
B.1.c IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED The following actions have been completed: (1) Security personnel were immediately reinstructed as to the intent of Paragraph 4.1.3 of the Physical Security Plan and Security Procedure No. 304. in that escorted personnel must remain in view of Westinghouse personnel at all times while in the Controlled Access Area; and, that this must be accomplished either by physically escorting personnel and vehicles or by coordinating escort responsibilities with other departments, (2) On June 22,1998, a Manager's Workshop was conducted to reinstruct CFFF management in escort requirements, including the need to keep escort-required personnel in line of sight, (3)
The annual Employee Security Awareness and Responsibilities Workplace Script was revised to include additional instructions for personnel with escort responsibilities when there is a need to transfer escort responsibility to another person.
This resulted in compliance with Security Plan commitments.
B.1.d ACTIONS TO PREVENT RECURRENCE L
L The above actions, along with the enhancements described in Appendix A, are expected to prevent recurrence.
B.1.e DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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70-1151/98-201 Page 3 of 3 July 20,1998
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B.2 The'following information is provided in response to Violation 98-04-02 for failure of the Physical Security Plan to accurately reflect current conditions and practices such as "as built" installations.
B.2.a ACKNOWLEDGEMENT OF THE VIOLATION The violation is correct as stated in the Notice of Violation.
B.2.b REASON FOR THE VIOLATION The violation resulted from a lack of a formal process for routinely comparing commitments in the Physical Security Plan to actual practice and/or facilities.
B.2.c IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED The following actions have been completed: (1) All Controlled Access Area signs that were difficult to reau were replaced, (2) Signs were also placed on the UF6 storage fence line, (3) Barbed wire was placed on the ten inch length of fence identified in %
inspection report, and (4) A fence was installed at the South side of the Office Building where the Controlled Access Barrier meets the wall. In addition, the Physical Security Plan is being revised to address the specific concerns addressed in this violation and other issues in the Inspection Report (e.g., the presence of certain fence gates and access portals, a description of the "as built" Controlled Access Area fence line, and equipment issued to the security contractor). This revised Plan will be submitted to NRC Staff by July 31,1998.
Actions taken resulted in compliance with Security Plan conunitments.
i B.2.d ACTIONS TO PREVENT RECURRENCE A formal quarterly audit program is being initiated to inspect "as-built" installations and their conformance to Physical Security Plan commitments, in accordance with a
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written checklist. The initial audit will be completed by September 30, 1998. Any I
NRC Staff.
i identified discrepancies will result in revisions to the Plan, and applicable reporting to l
l This action, along with the enhancements described in Appendix A, is expected to prevent recurrence.
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B.2.e DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED I
l Full compliance has been achieved.