ML20244C463
| ML20244C463 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 06/06/1989 |
| From: | Trent L BABCOCK & WILCOX CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906140323 | |
| Download: ML20244C463 (8) | |
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Babcock & Wilcox unronessanentasonarony a McDermott company P.O. B)x 11165 Lynchburg, VA 24506 1165 (804) 522 6000
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U.S. Nuclear Regulatory Comission Attn:- Document Control Desk Washington D.C.
20555
Reference:
Notice Of Violation (NRC Inspection Report No. 70-824/89-02), dated May 10, 1989.
Gentlemen:
The - Babcock a.Wilcox Company, Naval Nuclear Fuel Division Research Laboratory (S:FD-RL), is providing the attached reply to the referenced notice of violation in accordance with 10 CFR 2.201.
If'you should hhve any further questions, please feel free to contact me.
Sincerely, W
L. K. Trent, Manager Safety & Safeguards Attachment cc:
U.S.
Nuclear Regulatory Comission Attn: Stewart Ebneter, Regional Administrator 101 Marietta ST., N.W.
Atlanta GA 30323 l
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REPLY TO A NOTICE OF VIOLATION The following response is NNFD-RL's reply to the notice of violation which was issued as part of Inspection Report No. 70-824/89-12.
Violation A The Licensee failed to perform tronthly inspections of NNFD-RL portable fire extinguishers during December 1988 and January 1989 as required by Administrative Procedure No.19.3 of the Industrial Safety Manual.
1.
Admission or denial that the violation occurred:
The violation did not occur as stated.
Inspections of the site's fire extinguishers had occurred for December 1988 and January 1989, but records were not available at the time of the inspection.
2.
The reason for the violation if admitted:
The method used for documenting a fire extinguisher inspection was
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for the Industrial Safety Officer to (a) perform the inspection, (b) initial and date the fire extinguisher tags, (c) enter the information onto a computer file, and (d) keep a printed record of the inspection in a notebook.
The Industrial Safety Officer had parformed the December 1988 and January 1989 inspections and had initialed and dated the tags, but had not entered the information into the computer nor printed a record of the inspections for these two months before he retired from the company on February 1.
An attempt was made to retrieve the tags from the site's fire extinguishers as proof of the inspections. Coincidentally with the NRC inspection, Fire & Safety Equipment Company of Concord, VA. was performing an annual inspection of the fire extinguishers. Most of the tags had been removed and destroyed, but five were salvaged from trash receptacles. Copies of these five tags are provided in an attachment.
3.
The corrective steps which have been taken and the results achieved:
Since it vould not truly correct the problem, the previous records will not be changed to show inspections for these two months.
Procedure RL-TP-62, NNFD-RL Portable Fire Extinguisher inspection Procedure, has been revfsed. Page 6, parai 7h 8.3 adds additional record requirernents to ensure over check os che monthly and annual inspections by the Manager, Kaalth & Safety (NHFD), the NNFD-RL Emergency Officer, and the Health Physics Records Administrator. _-
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Violation' AI(Cont'd)
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- 4. ' The corrective steps which will be.taken to-avoid further I
violations:
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, The-corrective actions discussed above are directed at preventing.
recurrence.. No other corrective actions are planned at this time.
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The date when full compliance will be achieved:
. NNFD-RL is now in full compliance with the' requirement.
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Violation B The Licensee had not conducted quarterly fire and rescue team training during the period of October 1988 thru March 1989 as required by Section 7.2 of the Radiological Contingency Plan (RCP).
1.
Admission or denial that the violation occurred:
The violation occurred for the first quarter of 1989, but not for the fourth quarter of 1988.
Fire and rescue team training was performed-for the fourth quarter of 1988, but no copy of this training was available at the time of the inspection.
A copy of the training record was obtained from the former Industrial Safety Officer / Emergency Response Officer af ter the inspector left the site. A copy of this record is attached.
2.
The reason for the violation if admitted:
The Industrial Safety Officer / Emergency Response Officer retired from the company on February 1,1989. The individuals appointed to act for the Industrial Safety Officer and for the Emergency Response Officer failed to note the requirement for quarterly fire and rescue team training.
Consequently, no training was performed in the first quarter of 1989, 3.
The corrective steps which have been taken and the results achieved:
Training has been planned for the second quarter of 1989 and will be completed by June 30, 1989.
4.
The corrective steps which will be taken to avoid further viola-tions:
All Emergency Response Team training, including quarterly training will be documented. The records of the training will be maintained by the Emergency Response Officer with copies sent to the Emergency Officer and the Health Physics Records Administrator to ensure over check.
5.
The date when full compliance will be achieved:
Full compliance will be achieved by June 30, 1989.
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