ML20151U562

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp of License SNM-21 on 880516-19

ML20151U562
Person / Time
Site:	07000025
Issue date:	08/10/1988
From:	Jonathan Montgomery NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Remley M ROCKWELL INTERNATIONAL CORP.
References
NUDOCS 8808190175
Download: ML20151U562 (1)

Text

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I AUG 101988 License No. SNM-21 '

i Atomics International Rocketdyne Division Rockwell International Corporation l 6633 Canoga Avenue  !

Canoga Park, California 91304 Attention: M. E. Remley, Director Nuclear Safety and Licensing Gentlemen:

1 Thank you for your letter dated July 14, 1988 informing us.of the steps you l have taken to correct the items which we brought to your attention in our.' i letter dated June 23, 1988. Your corrective actions will be verified during our next inspection.

Your cooperation with us is appreciated. i l

Si':erely, <

J)r CAICu voJ2 M;nd 7JamesthMontgomery,Chidf l Nuclear Materials Safety and Safeguards Branch bec w/ copy of letter dated 7/14/88:

docket file j B. Faulkenberry .

1 A. Johnson J. Martin State of California J. Zollicoffer M. Smith 1

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I July 14, 1988 In reply refer to 88RC08427 4 M.

U.S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Document Control Desk

Subject:

Reply to a Notice of Violation Docket 70-25, license No. SNM-21 Gentlemen:

We are in receipt of the report on the routine safety inspection con-ducted by Messrs. R. D. Thomas, B. L. Brock, and K. M. Prendergast of the Region V office on May 16-19, 1988, of activities authorized by NRC License No. SNM-21. The report indicated that, during the inspec-tion, it was found that certain of our activities appeared to be in violation of NRC requirements.

This response to the Notice of Violation is submitted in accordance with the provisions of 10 CFR 2.201 as directed in the Notice. The violations are identified in the same manner as in the Notice.

Violation A

1. Aeason for the Violation The citation indicates that personnel assigned responsibilities for radiological emergency service had not been given training specific to the Radiological Contingency Plan. In addition, the training program had not been audited by the Quality Assurance organization as required in the plan. While the citation is accepted as presented in the Notice, it should be pointed out that Rocketdyne has a Master Emergency Plan which includes the response actions to all types of emergencies which might occur during the division's various activities. Included in that plan is the response to a radiological emergency, but the plan does not include explicitly all the requirements for accident classi-fication, accident assessment, and radiation dose assessment  !

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4 88KC08427 July 14, 1988 l

Page 2 Rocktvell International l

calle'd out specifically in the Radiological Contingency Plan. I The Master Emergency Plan has been subjected to annual reviews and updating, personnel with assigned responsibilities for emer-gency response have been subjected to training together with annual retraining, and annual exercises and drills have been con-  ;

ducted as are required by the Radiological Contingency Plan, as discussed in the inspection report. Thus, only a few special subject areas of the Radiological Contingency Plan (RCP) were not covered in the emergency training, and the RCP training program had not been audited by Quality Assurance.

2. Corrective Steps That Have 8een Taken and Results Achieved As also indicated in the inspection report, the Radiological Con-tingency Plan is out of date with a number of changes which have occurred since original publication in 1982. A letter of commit-ment to update the plan as necessary to apply accurately to the activities currently authorized by License No. SNM-21 has been submitted to the Region V office. This commitment includes revi-sion of the Radiological Contingency Plan and submission of copies to NRC headquarters and the Region V office by August 31, 1988. A preliminary draft of the updated plan has been completed and is being reviewed prior to publication in final form. In addition, the training of the emergency response staff for imple-mentation of the Rocketdyne Master Emergency Plan is continuing as required.

3. Corrective Steps That Will be Taken to Avoid Further Violations A training program is being developed to include the requirements associated with the updated Radiological Contingency Plan. This program will be given to personnel assigned to the licensed facility together with the support people from Health, Safety and Environment and the Protective Services organizations who have responsibility for radiological e.mergency service and constitute the emergency response teams. This updated training program will be audited annually by the Quality Assurance organization.

4. Date When Full Compliance Will be Achieved Completion of the training program with instruction to the appro-priate staff will be completed so that full compliance will be achieved by the end of October 1988. ]

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88RC08427 July 14, 1988 i Page 3 Rockwell International Violation B

1. Reason for the Violation j This violation resulted from an incdvertent oversight by the Health Physicist assigned to support the Rockwell International Hot Laboratory activities.

2. Corrective Steps That Have Been Taken and Results Achieved The requirement to complete the restricted area work permit with the necessary and appropriate approvals has been reemphasized to all the Health Physics staff. This has resulted in increased attention to accurate completion of the work permits.

3. Corrective Steps That Will be Taken to Avoid Further Violations A review of all completed restricted access area permits has been initiated in the internal reviews of licensed activities.

4. Date When Full Compliance Will be Achieved The above actions have resulted in full compliance at the present time.

Violation C

1. Reason for +5e Violation i 1

The radiation surveys necessary for radiological protection had ,

been made, but all documentation had not been completed. )

2. Corrective Steps That Have Been Taken and the Results Achieved All the currently required surveys were made and documented imme-diately following the inspection in May. This resulted in com- I pliance with the survey requirements in the Radiation Safety Plan l for the Hot Laboratory. l

3. Corrective Steps That Will be Taken to Avoid Further Violations The Radiation Safety Plan for the Rockwell International Hot l Laboratory has been revised to require appropriate radiation sur-veys complete with documentation, which will be retained 'or a period of 5 years.

88RC08427 July 14,1988 Page 4 Rockwell International

4. f. ate When Full Compliance Will be Achieved

'he activities are currently in full compliance.

If there are questions or you require further information, please contact me on (818) 718-3403.

Sincerely ,

M. E. Rem ey Director Nuclear Safety and Licensing  ;

Rocketdyne Division 1308A/bes i i

cc: John B. Martin l Regional Administrator Region V Office 05470RC

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