ML20236U290
| ML20236U290 | |
| 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-98-028, CON-NRC-98-28 70-1151-98-202, IEB-91-001, IEB-91-1, NUDOCS 9807300008 | |
| Download: ML20236U290 (4) | |
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7-l Wditinghouse Commercial Nuclear Drawed Electric Corporation Fuel Division fgn8sgcaena29250 g2 NRC-98-028 July 14,1998 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
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Gentlemen:
SUBJECT:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
REPORT NO: 70-1151/98-202 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 26,1998, regarding your inspection of the Columkh Fuel Fabrication Facility conducted during the period of April 27-May 1,1998.
. Appendix. A of this document addresses the NRC concern expressed in the Notice of Violation cover letter
-I that the violation,... "is of concern to the NRC because the inoperability of the control was not recognized until the condition was identified by the NRC inspectors. In addition, it raises concern over the assumptions expressed to the NRC during the pre-decisional enforcement conference concerning the interim safety of plant operations during the time that NCS corrective actions are being implemented."
Appendix B provides a response to the panicular 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,
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WESTINGHOUSE ELECTRIC COMPANY
/
b N
y B Allen, Plant Manager Columbia Fuel Fabrication Pacilirj Attachments Apperulix A & Appendix B r
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U. S. Nuclear Regulatory Commission Regioral Administrator, Region II Atlanta Federal Center 61 Forsyth Street, SW. Suite 23T85 l,
Atlanta. Georgia 30303-3415 9907300006 990714e' PDR ADOCK 07001L51 C
PER L -
e 70-1151/98-202 Page 1 of 3 July 24,1998 c
s APPENDIX A WESTINGHOUSE RESPONSE TO COVER LETTER CONCERNS The following information is provided in response to the concerns expressed in the cover letter of the Notice of Violation that: "The violation is of concern to the NkC because the inoperability of the control was not recognized until the condition was identified by'the NRC inspectors. In addition, it raises concern over the assumptions expressed to the NRC during the pre-decisional enforcement conference concerning the interim safety of plant operations during the time that NCS corrective actions are being implemented."
We acknowledge the fact that the inoperability of the controls was not recognized until the condition was identified by the NRC inspectors. As stated in our response to the Notice of Violation, however, the subject controls were not necessary to ensure safety nor required to demonstrate double contingency protection for the equipment in question.
At the October 29,1997 predecisional enforcement conference, Westinghouse presented a plan for imple nenting comprehensive and effective corrective actions related to the nuclear criticality aafety (NCS) program. This plan addresses numerous facets of the NCS program such as C5A/CSE upgrades, development of integrated safety assessments (ISA's), " field and file" verifications, configuration change management, procedure revisions and training.
Westinghouse remains firmly committed to this plan, and is aggressively pursuing implementation of corrective actions consistent with its commitments, in a methodical, highly structured and risk informed manner. Furthermore, Westinghouse strongly believes that, by continuing to work its plan, the interim safety of plant operations will be assured during the
. time that NCS corrective actions are being implemented.
We also are aware of the inspectors' concern that "the large involvement of the NCS staff in completing these initiatives has resulted in much less floor time for these engineers which could impact the safety of plant operations." To address this concern, we have reviewed and evaluated the effectiveness of the current organization structure and staffing relative to ongoing regulatory compliance initiatives, current workload, and assigned functional responsibilities (SMIP Item 5-GN0200).
This review and evaluation are complete, and any subsequent modifications should be in place by July 31.
These changes should provide further assurance of the safety of plant operations.
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70-1151/98-202 Page 2 of 3 July 24,1998 s
APPENDIX B WESTINGHOUSE RESPONSE TO NOTICE OF VIOLATION B.1 The following information is provided in response to Violation 98-202-04 that: "as of April 30,1998, continued compliance was not assure:1 for a nuclear criticality safety control as employed and documented within a nuclear criticality safety evaluation, in that, the 1008 Ammonia Sembber was operated since May 1997 with an inoperable nuclear criticality safety control."
B.1.a ACKNOWLEDGMENT OF THE VIOLATION The violation is correct as stated in the Notice of Violation, except that: "The S-1008 scrubber was operated between May 1997 and March 31, 1998, with an inoperable nuclear criticality safety control" (as stated on page 11 of NRC Inspection Report No.98-202).
B.I b REASON FOR THE VIOLATION The subject control consisted of two separate differential pressure (DP) gages, which were included at scrubber installation to monitor differential pressures 1) across the packing section of the scrubber vessel, and 2) across the discharge end of the scrubber vessel, to ensure no plugging. These gages were being monitored every shift, and the data was being recorded on Controlled Form CF-81-924.
The governing procedure and controlled form were subsequently revised, deleting the requirements for monitoring the gages and recording the data. The administrative control was improperly allowed to be deleted because:
1.
The analysis for the scrubber in place at the time did not clearly identify the controls as safety significant. (In such early criticality safety analyses, before development of the current Criticality Safety Evaluation (CSE) / Integrated Safety Assessment (ISA) process, controls were merely listed under the different barriers with no distinction made between " safety significant" controls and " process controls." The de-facto assumption, therefore should have been that all controls listed were safety significant, even though this was not necessarily the case.
2.
The subject controls were in no other way clearly identified as " safety significant," either to the NCS function or the area engineers.
3.
The procedure change protocol did not require that deleted steps, along with a justification for deletion, be listed in full in the description of change section.
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70-1151/98-202 Page 3 of 3 July 24,1998 B.Lc IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED The following remedial actions have been implemented:
During the inspection, Westinghouse made a NRC Bulletin 91-01 notification for a
- deficient analysis of the subject system. This led to a detailed revision of the system and the efficacy of in-place controls to ensure the system's safety.
On March 31, 1998, a Plant Ventilation System Integrated Safety Assessment was subsequently issued which determined the subject controls not to be necessary to ensure safety and not required to demonstrate double contingency protection.
Full compliance was achieved by these actions.
B.1.d ACTIONS TO PREVENT RECURRENCE The following preventive actions have been implemented:
The current ISA format includes a section which clearly identifies safety-related controls. Safety-significant controls are also listed in the License Annex summarizing the ISA.
Procedure RA-108 is being revised as part of an ongoing Safety Margin Improvement Program (SMIP) initiative to clearly document all safety controls associated with each plant system or component. This revision is scheduled for completion by September 30,1998.
B.I.e DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
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