ML20246H782
| ML20246H782 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 05/04/1989 |
| From: | Loch E WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8905160198 | |
| Download: ML20246H782 (2) | |
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Westinghouse Commercial Nucleai Daw R l
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e May 4, 1989 I
U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Dear Sirs:
REFERENCE:
.NRC Inspection Report No. 70-1151/89-01 Reply to a " Notice of Violation" Pursuant to the NRC's " Rules of Practice" provisions in 10CFR2.201, Westinghouse : hereby provides, in Appendix A formal response to your April 6, 1989 " Notice of ' Violation" letter pertaining to Mr. G. B. Kuzo's inspection conducted January 30 - February 3, 1989 and February 9, 1989.
Should ycu have any questions regarding our response, or require additional information, please contact me at (803) 776-2610.
I hereby affirm that the statements made in this response are true and
.j correct to the best of my knowledge and belief.
Sincerely, WESTINGHOUSE ELECTRIC CORPORATION E. Paul Loch, Manager i
Columbia Nuclear Fuel Fabrication Facility 1m WP2973E:3p.9 Attachments: Appendix' cc:
U. S. Nuclear Regulatory Commission Region II I
ATTN: Regional Administrator l-101 Marietta Street, N. W., Suite 2900 Atlanta, GA 30323 4
8905160198 890504 PDR ADOCK 07001151
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- The l%sthghouse CommerchlNuclearFue/
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- 7021151/89-01 May 4.,
1989 i
APPENDIX A WESTINGHOUSE REPLY TO AN NRC NOTICE OF VIOLATION A.
Concerning the citation for failure to perform adequate surveys of nonroutine conditions in the Manufacturing Automation Process (MAP)
Area, the following comments are provided:
i 1.
The citation is correct as stated in the Notice of Violation.
2.
The Columbia Plant ALARA program utilizes a multiparametric approach to identifying potential areas of concern -- for the purpose of implementing appropriate corrective actions.
Controlled parameters include contamination control, airborne radioactivity measurements, personnel exposure assessments, bioassay, and unusual incidents.
This approach, when properly implemented, has always been effective in minimizing airborne radioactivity concentrations, and subsequent personnel j
exposures, in accordance with the ALARA philosophy.
During
- 1987, this philosophy was the driving force in identifying and correcting airborne levels and exposure problems in the recently commissioned MAP Line.
However, as stated by the Inspector, for "non-routine" sources of the type which existed in the MAP Area during this start-up period, the ALARA program was not sufficiently sensitive to such conditions. This resulted in surveys being inadequate.
3.
A detailed evaluation was performed to establish additional parameters for incorporation into the ALARA program, to assure that "non-routine" situations are identified in a timely manner, and that root cause(s) can be ascertained and promptly corrected.
In addition, control limits have been established for each of these parameters, to give "early warning" when an area exceeds the control limits.
This has substantially upgraded the sensitivity of the ALARA program.
4.
A modified ALARA program, including the identified parameters and control limits, will be in place for the next ALARA reporting period -- which begins July 1, 1989.
l If control limits are exceeded, an evaluation will be performed i
to determine what additional surveys are required to better define the root cause(s) and required corrective actions.
Such actions will include a
determination of air sampling representativeness, if appropriate.
These additional controls will prevent recurrence of an inadequate survey situation of the type cited.
5.
Full compliance will be achieved for the six month ALARA reporting period ending June 30, 1989.
WP2973E:3p.10
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