ML20236Y607

Responds to NRC Re Violations Noted in Insp Rept 70-1151/98-203 on 980622-26.Corrective Actions:Ncs Staff Performed Review of All Unverified Calcnotes to Determine How Many Were Directly Referenced by Criticality SEs

ML20236Y607
Person / Time
Site:	Westinghouse
Issue date:	08/06/1998
From:	Allen J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-98-029, CON-NRC-98-29 70-1151-98-203, NUDOCS 9808120345
Download: ML20236Y607 (4)

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4 Westinghouse Commercial Nuclear Draws R Electric Corporation Fuel Division cenza soum caena 29250 (803)776 2610 NRC-98-029 August 6,1998 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 f

i Gentlemen:

j

SUBJECT:

REPLY TO A NOTICE OF VIOLATION l

REFERENCE:

REPORT NO: 70-1151/98-203 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 July 7,1998, regarding your inspection of the Columbia Fuel Fabrication Facility conducted during the period of June 22-26,1998.

Appendix A of this document addresses the NRC concern expressed in the Notice of Violation cover letter.

Appendix B provides a response to the particular violation of NRC requirements specified in the Notice of Violat!on.

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. Alien, Plant Manager Columbia Fuel Fabrication Facility Attachments:

Appendix A & Appendix B 3

cc:

U. S. Nuclear Regulatory Commission Regional Administrator, Region II CQ g

l Atlanta Federal Center

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61 Forsyth Street SW. Suke 23T85

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Atlanta. Georgia 30303-3415 9808120345 980806

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'- 70-1151/98-203 Page l of 3 August 6,1998 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 to the NRC because the independent verification process provides the appropriate level of atsurance that criticality safety limits have been adequately determined." Westinghouse acknowledges and shares your concern, and has eliminated the past practice of not consistently requiring that criticality safety calculations (i.e., CALCNOTES) be independently verified.

At the October 29,1997 pre-decisienal enforcement conference, Westinghouse presented a plan for implementing comprehensive and effective corrective actions related to the nuclear criticality safety (NCS) program. This plan addresses numerous facets of the NCS program such as criticality safety analysis and criticality safety evaluation (CSA/CSE) upgrades, development of integrated safety assessments (ISAs), " field and file" verificatHs, configuration change management, procedure revisions and training. The plan has been modifi'd to include a new subtask in an existing Safety Margin Improvement Program (SMIP) initiatise which will address the subject concern.

Westinghouse remains firmly committed to this plan, and is aggressively pursuing implementation of corrective actions consistent with its conunitments, in a methodical, highly structured and risk-informed manner. Furthermore, Westinghouse strongly belicves 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.

These actions should provide further assurance of the safety of plant operations.

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70-1151/98-203 Page 2 of 3 August 6,1998 APPENDIX B WESTINGHOUSE RESPONSE TO NOTICE OF VIOLATION B.1 The following information is provided in response to Violation 98-203-04 that: "... as of June 26, 1998, independent reviews of 11 criticality safety calculations used to support safety limits specified in CSEs and CSAs had not been performed."

j B.1.a ACKNOWLEDGMENT OF THE VIOLATION The violation is correct as. stated in the Notice of Violation.

2 B.I.b REASON FOR THE VIOLATION As discussed with your inspectors during the 98-203 inspection, the Licensee agrees that the violation occurred primarily due to a past practice of not consistently demanding that criticality safety calculations be independently verified. In years past, calculations were often performed as scoping, sensitivity, or confirmatory calculations, the results of which were not used for establishing criticality safety limits in an evaluation. However, the inconsistency in formally documenting calculations in CALCNOTEE, but not requiring that every CALCNOTE be independently technically verified, produced an error-likely situation, in which calculations whose results were used to establish limits were sometimes published as a CALCNOTE and not independently verified.

In addition, until last year, the CALCNOTE index did not clearly identify which CALCNOTES had been independently verified and were acceptable for use in establishing limits.

B.1.c ACTION TAKEN AND RESULTS ACHIEVED The following remedial actions have been implemented:

1. During the inspection, the NCS staff performed a review of all unverified CALCNOTES, to determine how many were directly referenced by criticality safety evaluations. It was determined that 11 unverified CALCNOTES are referenced.

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2. For the specific item of noncompliance noted in the inspection repart (i.e.,

tmreviewed calculations in support of the solvent extraction CSE), it was determined that "the k, results determined by the unverified calculations were

t 70-1151/98-203 Page 3 0f 3 August 6,1998 l

1 within the expected range for the geometry and material involved by comparison with accepted data in TID-7016, so that the issue has minor safety significance."

3. All unverified CALCNOTES were evaluated and dispositiored as (1) calculations which are directly or indirectly referenced by a CSE/CSA, and which require independent verification, or (2) scoping calculations which do not need verification.

Of the 86 unverified CALCNOTES, it was determined that 52 were scoping or sensitivity studies, not used in establishing safety limits in an evaluation. No verification is needed for these calculations. The remaining 34 were assessed as requiring indeMndent verification. These have been prioritized and assigned to the i

NCS specialists for verifi:ation.

l B.I.d ACTIONS TO PREVENT RECURRENCE The following prevenSve actions have been implemented:

1. Procedure F A-310, Regulatory Affairs Independent Technical

Reviews, promulgates the policy found in the License concerning verification of criticality safety calculations. As stated in the License, indeper. dent technical reviews of criticalit', safety assessments, criticality safety evaluations, or calculations in suppor'. of limits specified in CSAs or CSEs will be performed.

2. NCS analysts ensure that all CALCNOTES referenced in the CSEs and ISAs that are currently being developed or revised in support of NRC commitments have i

been independently verified.

3. The CALCNOTE index has been reformatted so that it clearly identifies which CALCNOTES are not to be used for establishing safety limits. The filing system will be modified so that the scoping CALCNOTES are clearly distinguishable from l

those which have been verified. Finally, newly produced CALCNOTES will not be I

filed until they have been verified.

B.1.e DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

1. Full compliance will be achieved by December 31, 1998, when all unverified CALCNOTES, not classified as scoping, wil! have been verified.

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