ML20212C576

Responds to NRC Re Violations Noted in Insp. Corrective Actions:All Scheduled Tests,Calibrs & Maint Requirements Extracted & Written Into Computerized Calendar

ML20212C576
Person / Time
Site:	Aerotest
Issue date:	02/13/1987
From:	Newacheck R AEROTEST OPERATIONS, INC.
To:	Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20212C553	List: ML20212C550 ML20212C576
References
NUDOCS 8703030819
Download: ML20212C576 (3)

Text

{{#Wiki_filter:. OECEll'2[} I:13 T+ g AEROTEST 3455 FOSTORIA WAY . SANOPERATIONS,q)gC. RAMON, CALIFORNIA 94583 . (41% 1212 l~ (M p%.;yn, February 13, 1987 U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 ATTN: F.A. Wenslawski, Chief s RE: Your letter of 1/23/87 Notice of Violation Docket No. 50.228 Gentlemen: This letter is in response to the referenced NRC inspection report in accordance with the provisions of 10 CFR 2.201. INTRODUCTION Appendix A, paragraph A) and paragraph B), 1,2 and 3, of the refer-enced Notice, all relate to a similar problem; i.e., not performing a required action in the specified time period or interval. The specific actions cited involve four actions of the dozens of actions required routinely in the operation of our reactor facility. In fact, in way of taking corrective action to the violations, we have identified and abstracted over 50 separate, routine actions to be performed on various time schedules. Many of these included multi-ple accions and involve daily, monthly, quarterly, semiannual, annual, biennial and five year frequencies. We trust our detailed review has uncovered all of the routinely scheduled requirements. CORRECTIVE ACTIONS All of the scheduled tests, calibrations and maintenance require-ments have been extracted and written into a computerized calendar. The documents surveyed for this collection of commitments include Licenses, Plans, Procedures, NRC Inspection Reports and, of course, the Technical Specifications. At the start of each month, the printout for the second month ahead will be distributed to all personnel responsible for conducting actions. This month added to the current month will provide a one month minimum alert for those items requiring lead time, such as procedure reviews. In addition, a full year calendar of events has been distributed to all involved personnel. This will provide the necessary alert for longer lead items such as operators license renewals. The calendar has been prepared through the next five years. Items can be added or edited as necessary. A Master Calendar will be kept by the President of 0703030819 870224 PDR ADOCK 05000228 A SUBSIDI ARY OF G PDR l

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                    . items are completed.
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                                                                                        .s In all casesiof..omiss16n. cited by the NRC TNapector,-the cause can                                                                       5 be attributed.to either an oversight.as tolthe specific requirement
                    . schedule, or an oversight in performing the required action on                                                                                            %.

schedule. Exceptfortheitems-involvingthemonthlyalarmchecNy,allroubine

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maintenance items which have an established check list'have been ,, performed'ha scheduled. -This would suggest that1the planned cor-- ;1 1 rective action will result in an effective reminder'and control to [\ ~g

                    -make-certain all requirements are met'in a timely fashion.
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i SCHEDULE FOR CORRECTIVE ACTION -

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1.- The corrective action noted.above has been completed. , (Extracting all commitments, preparing and distributing '

                                                                                                                                                                         *w a computerized calendar)..

2. The Emergency Plan has been reviewed,' modified and was- h,'fl 3 q

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submitted to the NRC on January 21, 1987.-

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3. Emergency Procedure dr91niag was conducted on January ,,

27 and 28, and included hvery Aerotest employee. 'Sub- . jects covered and employ #e signatures of tho'se attending ~

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                             .the lecture.have been documented. A security training session was also conducted on January 27 and 28. All                                                       '"                                ,

4 Aerotest employees were. included. The items covered in1 .3 the lecture and the sigr.atures of the attending employ-ees are documented.

4. The monthly alarm checks were conducted on February 3, i

1987 for the month of February.per our prescribed. plan..t A drill 1was conducted in conjunction with the radiation alarm. All employees and one visitor were in the facil . ,, j ity at-the time of the unannounced test. Everyone re ,'.f y sponded in accordance with Emergency Procedures. 4 , 4 i These actions result in achieving full compliance of the items men- ! tioned in-the Notice of Violation. All were accomplished by 1, i r l- February 3, 1987. We expect that item-1, above, will prevent Any j further oversights of scheduled maintenance items. l Completion of item 2, above.-has resolved the Emergency P an dis-crepancies noted In' the detal; led NRC Inepection Report. Sn'yage 8

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and 9. In addition, t:he Maintenance Procedures, No. VIII[ will be changed at the regular review period, October,1987} to iricorporate the monthly alarm check form. (' g? g i S l l.. l s

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4 3 ,, . .i;: u' . We trust.the actions and infortnation noted herein satisfies the-requirements of~10 CFR 2.201. .Please contact the. undersigned if

                                                        .any further information is required.
                                                                                                                        .Yours very truly, j                                                                                                                                         j  '
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                                                                                                                          .ichard L. Newacheck-l' resident RLN/kb
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