ML20212D017
| ML20212D017 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, 07007001 |
| Issue date: | 10/27/1997 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Timbers W UNITED STATES ENRICHMENT CORP. (USEC) |
| References | |
| EA-97-447, EA-97-448, NUDOCS 9710300242 | |
| Download: ML20212D017 (7) | |
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.o y* 4 UNITED STATES D i*
NUCLEAR REGULATORY COMMISSION l WASHINGTON, D.C. 20566 0001 l k % * * * ,o October 27, 1997 EAs97-447 & 97-448 Mr. William H. Timbers
! President and Chief Executive Officer U. S. Enrichment Corporation 2 Democracy Center 6903 Rockledge Drive Bethesda, MD 20817
SUBJECT:
APPARENT VIOLATIONS CONCERNING PADUCAH AND PORTSMOUTH l C.ERTIFICATE AMENDMENT REQUESTS, DATED AUGUST 18,1997 -
UPDATE OF THE APPLICATION SAFETY ANALYSIS REPORT
Dear Mr. Timbers:
This Ictter concems the Nuclear Regulatory Commission's review of two certificate amendment requests submitted by United States Enrichment Corporation (USEC), dated August 18,1997, (Gaseous Diffusion Plant (GDP) 97-0147 and GDP 97-0148).
Based on our review of USEC's submittals, as described in Enclosure 1 to this letter, two apparent violations were identified at both the Paducah GDP and the Portsmouth GDP and are being considered for escalated enforcement action in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions' (Enforcement Policy), NUREG 1600.
The two appsrent violations involve failures by USEC to comply witis Condition 8 of the Paducah GDP and Portsmouth GD? Certificates of Compliance. Specifically, USEC failed to submit by August 17,1997, an amendment to the certification application, which includes information required by item 3 and item 4 in the Plar' of Action and Schedule (PAS) of Issue 2 in the " Plan for Achieving Comphance with NRC Regulations at the Paducah GDP, DOE /ORO-2026/R3" and " Plan for Achieving Compliance with NRC Regulations at the Portsmouth GDP, DOE /ORO-2027/K3"(Compliance Plans) submitted to and approved by the NRC, as described in Enclosure 1. No Notice of Violation is presently being issued for these findings. In addition, please be advised that the number and characterization of apparent violations described in the enclosed report may change as a result of further NRC review.
A transcribed, predecisional enforcement conference to discuss these apparent violations has been scheduled for 10:00 a.m. on December 1,1997, in Room T-8A1, at Two White Flint Nodh, }
11545 Rockville Pike, Rockwile, MD 20852-2738. The conference will be open to public observation in accordance with the Enforcement Policy. The decision to hold a predecisional enforcement conference does not mean that the NRC has determined that a violation has #h[
occurred or that enforcement action will be taken. This conference is being held to obtain information to enable NRC to make an enforcement decision, such as a common M)
CONTACT: Charles Cox, NMSS/FCSS/FSPB (301) 415-6755 l{' y dl l gg
' " Sit'03OO242 971027 ,
1 4 =
W. Tirpbers' 2 October 27, 1997
- understanding of the facts, root causes, missed opportunities to identify the apparent violation -
sooner, corrective actions, significance of the issues, and the need for lasting and s#ective !
corrective action. In particular, we expect you to address _the technical reviews required by 1
- item 2 in the PAS for issue 2 of the Compliance Plans _ and why these reviews were not adequate to prevent the current situation, and what steps are planned to achievS compliance ;
and to prevent recurrence of similar_ situations in the future. We will also expect you to provide .
1 any justification for continued operation you beliove mi 0 ht apply in the interim until full ' :
. compliance with NRC requirements is achievec.- In addition, this is an opportunity for you to l point out any errors you believe we have made in our review of your submittals, and for you to i provide your perspectives on: (1) the severity of the violations, (2) the application of the factors i that the NRC considers when it determines the amount of a civil penalty that may be assessed ,
- iri accordance with Section VI.B.2 of the Enforcement Policy, and (3) any other application of f the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll.
t in presentino your corrective action, you should be awarc that the promptness and ,
= comprehensiveness of your actions will be considered in assessing any civil penalty for the apparent violations. The guidance in the enclosed excerpt from NRC Information Notice 96-28, *
" Suggested Guidance Relating to Development and implementation of Corrective Action," may ,
be helpful. !
You will be advised by separate correspondence of the results of our deliberations on this matter. No written response regarding these apparent violations is required at this time, in accordance with 10 CFR 2._790 of the NRC's " Rules of Practice," a copy of this letter and ,ts enclosbres will be placed in the NRC Public Document Room and in each of the Local Public Document Rooms for the GDP.-
Sincerely, -
-(Original signed by)
Carl J. Paperiello, Director Office of Nuclear Material Safety Dockets 70-7001,70-7002 Certificates GDP-1 and GDP-2
Enclosures:
1..-NRC Review of USEC Amendment Requests 2.~ NRC Information Notice 96-28 cc: Steven Toolle, USEC
- Randall DeVault, DOE DISTRIBUTION: (TAC Nos:- L32044, L32043)
Dockets 70-7001,70-7002 NRC File Center PuBLIC Rill . ^ NMSS Dir. Off. r# FCSS r/f K. O'arion. Rill P. Hitend, Rlli M. Horn Y. Feraz D. Persinko C. Cox N.Marvush,oE J.Lieberman,oE P. Ting = W. Schwink D. Hartland, Rlli SPS r/f
- See previous concurrence OP/PROOPED/OOTOBER SO,'1997 OPC 'SPS E 'SP8 E- *SPB 'FCSS *OE NidFr GM OMarenteilli DHoodley RPierson ETenEyck Jueberman
, DATE 1 10/7/97 10/7/97 - 10/10197 10/17/97 t 19 7 D /1~/197 10/17.]7
- otSEC,.nms.com . OFFICIAL RECORD COPY
W. Tirpbers 2 Onderstanding of the facts, root causes, missed opportunities to identify the apparent violation sooner, corrective actions, significance of the issues, and the need for lasting and effective corrective action. In particular, we expect you to address the technical reviews required by item 2 in the PAS for issue 2 of the Compliance Plans and why these reviews were not adequate to prevent the current situation, and what steps are planned to achieve compliance and to prevent recurrence of similar situations in the future. We will also expect you to provide any justification ik continued operation you believe might apply in the interiin until full compliance with NQC requirements is achieved. In addition, this is an opportunity for you to point out any errors you believe we have made in our review of your submittals, and for you to provide your perspectives on: (1) the severity of the violations, (2) the application of the factors that the NRC considefs when it determines the amount of a civil penalty that may be assessed in accordance with Sekion VI.B.2 of the Enforcement Policy, and (3) any other application of the Enforcement Policy to this case, including the exercise of discretion in accordance with Section Vll.
In presenting your correctivgaction, you should be aware that the promptness and comprehensiveness of your actions will be considered in assessing any civil penalty for the apparent violations. The guidance in the enclosed excerpt from NRC Information Notice 96-28,
" Suggested Guidance Relating i Development and implementation of Corrective Action," may be helpful.
You will be advised by separate correspondence of the results of our deliberations on this matter. No written response regardiny ese apparent violations is required at this time.
In accordance with 10 CFR 2.790 of the N,RC's " Rules of Practice," a copy of this letter and its enclosures will be placed in the NRC Publi' Document Room and in each of the Local Public Document Rooms for the GDP.
Si cerely, Ca . Paperiello, Director Offic of Nuclear Material Safety and feguards Dockets 70-7001,70-7002 Certificates GDP-1 and GDP-2
Enclosures:
- 1. NRC Review of USEC Amendment Re uests
- 2. NRC Information Notice 96-28 cc: Steven Toelle, USEC Randall DeVault, DOE DISTRIBUTION: (TAC Nos: L32044, L32043)
Dockets 70-7001,70-7002 NRC Frie Center PuBLIC Rlli N s Dir. off. r/f FCSS r/f l K. o'Bnen. Ritt P. Hiland. Rill M.Hom Y. Faraz D. .rsinko C.Cox !
N Mamish.oE J. Lieberman.oE P. Ting W. schwink D, H !and, Ritt sPB r/f
- See previous concurrence )
OFC *SP8 E *SPB E S@8 FCSS/ E NMSS NAME DMartin/abi) Deioadley rson ETe yck n CPacenello DATE to/7/97 10/7/97 h /97 lD / d/97 /d / / h 197 / 19 7 / 19 7 I GauSEC,,nms.com OFFICIAL R CO D COPY )
l0 $ ]
N- W. Timbers 2 situation, and what steps ar3 planned to achieve compliance and to prevent recurrence of similar ations in the future. We will also expect you to provide any justification for continued operation you believe might apply in the interim until full compliance with NRC requirements is achie d. In addition, this is an opportunity for you to point out any errors you believe we have made, a for you to provide your perspectives on: (1) the severity of the violations, (2) the application the factors that the NRC considers when it determines the amount of a civil penalty that may be a essed in accordance with Section VI.B.2 of the Enforcement Policy, and (3) any other application f the Enforcement Policy to this case, including the exercise of discretion in accordance with S tion Vil.
In presenting your corre 've action, you should be aware that the promptness and comprehensiveness of you 4ctions will be considered in assessing any civil penalty for the apparent violations. The guid(nce in the enclosed excerpt from NRC Information Notice 96-28,
" Suggested Guidance Relating tgDevelopment and implementation of Corrective Action," may be helpful.
This conference will be transcribed ano 'll also be open to public observation in accordance with the Commission's continuing trial pro am as discussed in the enclosed excerpt from the Enforcement Policy (Enclosure 3). Although ot required, we encourage you to provide your comments on how you believe holding this con ence open to public observation affected your presentation and your communications with the You will be advised by separate correspondence of tha sults of our deliberations on this matter.
No written response regarding these apparent violations is quired at this time, in accordance with 10 CFR 2.790 of the NRC's " Rules of Practi " a copy of this letter and its enclosures will be placed in the NRC Public Document Room and each M the Local Public Document Rooms for the GDP.
Sincerely, Carl J. Paperiello, Directo Office of Nuclear Material S ty and Safeguards Dockets 70-7001,70-7002 Certificates GDP-1 and GDP-2
Enclosures:
As stated cc: Steven Toelle, USEC Randall DeVault, DOE DISTRIBUTION: E '
Dockets 70-7001,70-7002 NRCb t , enter PUBLIC Rlli NMSS Dir. Off. r/f FCSS rn K. O'Brien, Rlli P. Hiland, Rlli M.Hom Y. Faraz D. Persinko C.Cox N. Mamish,OE J. Ueberman,OE K. Winsberg,OGC S. Treby, OGC P. Ting W. Schwink D. Hartland, Rlli SPB r/f G:\USECVIOL.dem OFC SPB .b SPB b SPB FCSS OE OGC NMSS NAME DNNI hoadley RPiersoa ETenEyck JLieberman STreby CPaperiello DATE /DI 7 /97 N /d /97 / /97 / /97 / /97 / /97 / /97 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY l
a Nuclear Regulatory Commission Review of Paducah
. and Portsmouth Certificate Amendment Requests Dated August 18,1997, - Update of the Application Safety Analysis Report
, NRQ Review Scooe:
The NRC conducted a review of the United States Enrichment Corporation's (USEC's) amendment requasts submitted on August 18,1997. The amendment requests involyr changes to Application Safety Analysis Report (SAR) Chapter 2, and new SAR Sections 4.1, 4.2.1, through 4.2.5,4.3.1, and 4.4, with certificate amendment requests to approve the updated SAR (GARUP) modifications, for the Paducah and Pc,,-tsmouth gaseous diffusion plants.
NRC Findinos:
In its August 18,1997, submittals, USEC identified October 31,1997, as the forecast-submittal date for certain SARUP sections, including the portion of Chapter 3 containing
" Boundary Definitions for Q and AQ SSCs," Section 4.2.6, " Hazard Analysis Results," Section 4.3.2, " Accident Analysis Results," Section 5.2, " Nuclear Criticality Safety Analysis," and the proposed modifications to the Technical Safety Requirements (TSRs). As bases for a new submittal date, USEC: (1) stated that it has identified errors contained in Application SAR Chapter 3 in the form of discrepancies from as-found conditions in the plants and that USEC's efforts to-date have not included a systematic review, update, and confirmation of the information contained in Application SAR Chapter 3; and (2) provided a commitment to complete such an effort and make necessary changes to the SARUP analyses and supporting documents no later than October 31, 2000.
However, the NRC has determined that the above schedule dates and comaitments are inconsistent with, and do not satisfy, USEC's current regulatory obligations for this information.
Specifically, Compliance Plan issue 2 required USEC to submit all proposed modifications to the Application SAR and TSRs by August 17,1997. The August 18,1997 USEC submittals do not satisfy that requirement in that they do not include al' proposed modifications to the Application SAR and TSRs. In addition, USEC has not substantiated and confirmed that an inadequate SAR Chapter 3 will not have an adverse safety impact on the safety findings of Chapter 4," Accident Analysis." Further, the extension of the schedule for submitting complete SARUP information to late in the year 2000 would mean the information would not i
be available to support recertification of the Gaseous Diffusion Plants (GDPs), when needed.
USEC's application for recertification is due April 15,1998. This issue will need to be considered in determining whether or not to renew the certificates, or in deciding the term of any renewed certificates that might bo issued.
! The NRC recognizes that on July 18,1997, USEC submitted certificate amendment requests, for both the Paducah Gaseous Diffusion Plant (PGDP) and the Portsmouth Gaseous Diffusion Plant (PORTS), to extend the August 17,1997 deadline to October 31,1997, stating that insufficient time had been allowed to prepare the submittal and additional time would be required to complete various pre-submittal reviews. However, the staff has not yet approved this request, leaving the existing August 17,1997 required submittal date unchanged.
ENCLOSURE 1 l
4 e
2 NRC Peauirements:
Condition No. B of Certificates of Compliance GDP-1 and GDP-2 for PGDP and PORTS, respectively, requires, in part, that USEC conduct its operations in accordance with the Compliance Plan submitted July 12,1996, July 15,1996, July 18,1996, and the revision submitted August 1,1996, and for the PGDP facility, as modified by letter dated March 4, 1997.
Item 3 of the Plan of Action and Schedule, in Compliance Plan Issue 2 for both sites, requires that:
- 3. By no later than August 17,1997, USEC shall submit an amendment to their Certification Application which includes:
a) identification of all information, findings, and recommendations which indicate differences between the DOE sito-wide Safety Analysis Report
_ and the USEC Application for Certification; b) an evaluation of the effects of those differences on the safety of workers, and off site members of the public; and c) proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and TSRs.
Item 4 of the Plan of Action and Schedule, in Compliance Plan issue 2 for both sites, requires that:
- 4. At the same time the Application amendment is due, USEC shall also submit for NRC approval, its proposed resolution of matters contained in the DOE-approved site-wide SAR not incorporated by USEC in its request for amendment of their Application for Certification.
NRC
Conclusion:
Based on its review, the NRC has determined that USEC apparently failed to meet:
- 1. Item 3 of the Plan of Action and Schedule in Compliance Plan for issue 2, in that USEC filed by August 17,1997, the amendment to its certification application for each PGDP and PORTS, but it did not include: a) identification of allinformation, findings, and recommendations indicating differences between the DOE site-wide Safety Analysis Report and the USEC Application for Certification; b) an evaluation of the effects of those differences on the safety of workers, and off-site members of the public; and c) proposed modifications to the compliance certificate and/or facility, including proposed modifications to the Application SAR and TSRs.
en .
' 3
- 2. Item 4 of the Plan of Action and Schedule in Compliance Plan for issue 2, in that USEC filed by August 17,1997, the amendment to its certification application for each PGDP ,.
and POhTS, but it did not propose resolution of matters contained in the DOE-approved i ite wide SAR not incorporated by USEC in its request for amendment.
4 The failure te submit the above information for PGDP are two apparent violations of Condition-No. 8 of Certificate of Compliance GDP-1, The failure to submit the above information for PORTS are two apparent violations Condition No. 8 of Certificate of Compliance GDP-2.
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UNITED STATES .
.F. . .
NUCLEAR REGULATORY-COMMISSION-
-0FFICE-0F NUCLEAR MATERIAL SAFETY AND SAFEGUARDS WASHINGTON D.C. 20555
~
May 1. 1996-NRC INFORMATION; NOTICE 96-28: SUGGESTED GUIDANCE RELATING TO DEVELOPMENT AND :
=!*
) IMPLEMENTATION _0F CORRECTIVE ACTION Addressees j o All' material and fuel- cycle licensees. -[
g Puroose 3 The U.S. Nuclear Regulatory Commission (NRC) is issuing this information
- notice to provide addressees with guidance relating to development and i implementation of corrective actions that should be considered after
- identification of violation (s) of NRC requirements. It is expected that ...
recipients will~ review-this information for applicability to their facilities-
' and consider actions.- as a)propriate, to avoid similar problems. However, suggestions contained in t11s information notice are not new NRC requirements:
1 therefore, no specific action nor written response is required.
Backaround On June 30, 1995. NRC. revised its Enforcement Policy (NUREG-1600)' 60 FR.
34381. to clarify the enforcement program's'4cus by, in part. em)hasizing the importance of identifying problems before events occur. .and of ta cing prompt.
4 comprehensive corrective action when problems are identified.. Consistent with
~ the_ revised Enforcement Policy. NRC encourages and expects identification and prompt. comprehensive correction _of violations.
l In many cases, licensees who identify and promptly _ correct non-recurring c -Severity Level IV violations. without NRC involvement, will nottbe subject to
- formal enforcement action.- Such violations will be characterized as "non-cited" violations:as provided in Section VII.B.1 of the Enforcement Policy.
- Minor violations are not subject to formal enforcement action, Nevertheless.
the root cause(s) of minor violations must be identified and appropriate
- -corrective action must be taken to prevent recurrence.-
4
-If violations of more than a minor concern are identified by the-NRC during an inspection, licensees will be subject to a Notice of Violation and may need to provide a written response, as required by 10 CFR 2.201, addressing the causes ~
- - of the~ violations.and corrective actions taken- to prevent recurrence. In some
~
cases, such violations are documented on Form 591 (for materials licensees)
%~
7 I9604290193
.' Copies of NUREG-1600 can be obtained by calling the contacts listed at
- the end of the Information Notice.
g7g Enclosure 2
& T IN.96-28 4
May 1. 1996 Page 2 of 6 .
Thich constitutesLa notice of. violation that requires corrective action but does not require a written response. If alsignificant violation is involved, a
-a predecisional enforcement conference may be held to discuss those actions.
The quality-of a licensee's root cause analysis and plans-for' corrective '
tactions may affect the NRC's decision regarding-both the need to hold a predecisional enforcement conference with the licensee and the level of 1
-sanction proposed or imposed.
Discussion Comprehensive corrective action is required for all violations. In most-cases.-NRC-does not propos_e im)osition of a civil penalty where the licensee '
promptly. identifies and compre1ensively corrects violations. -However, a
-Sever".y Level III violation will almost always-result in a civil penalty if a licensee does not take prompt and comprehensive corrective actions to address the violation.
It is important for licensees, upon identification of a violation, to take the.
!_ -necessary corrective action to' address the noncompliant condition and to
- 3revent recurrence of the violation and the occurrence of similar violations.
, Prompt comarehensive' action'to improve safety is not only in the public.
interest. )ut is'also in the interest of. licensees and their employees. In
- addition. it will lessen the likelihood offreceiving-a civil penalty. Compre-
=hensive corrective action cannot be developed without a full understanding of 4
[ the root causes of the violation.
Therefore, to assist licensees the NRC staff has prepared the following
, guidance, that may be used for developing and im)lementing corrective action.
i . Corrective action _should be_ appropriately compre1ensive to not only prevent-i recurrence of the violation at issue but also to prevent occurrence of-similar violations. The guidance should help.in- focusing corrective actions broadly to the general area of concern rather than narrowly to the specific .
violations. The actions that need to be taken are-dependent on the facts and '
, circumstances' of. the particular case, b^ -The corrective action process should involve the'following three steps:
! : 1.- Conduct'a comolete and thorouah review of the circumstances that led to the violation. Typically, such reviews include:
Interviews with-individuals who are either directly or indirectly ^
involved :in the violation, including management personnel and those L responsible for training or arocedure development / guidance.
Particular attention'should Je. paid to lines:of communication i between supervisors and workers.
e
[
- 1
- IN 96-28 May 1, 1996 Page 3 of 6 Tours and observations of the area where the violation occurred, particularly when those reviewing the incident do not have day to-day contact with the o)eration under review. During the tour, individuals should loot for items that may have contributed to the violation as well as those items that may result in future violations. Reenactments (without use of radiation sources, if they were involved in the original incident) may be warranted to better understand what actually occurred.
Review of programs, procedures, audits, and records that relate
, directly or indirectly to the violation. The program should be reviewed to ensure that its overall objectives and requirements are clearly stated and implemented. Procedures should be reviewed to determine whether they are com)lete, logical, understandable, and meet their objectives (i.e., t1ey should ensure compliance with the current requirements). Records should be reviewed to determine whether there is sufficient documentation of necessary tasks to provide an auditable record and to determine whether similar
, violations have occurred previously. Particular attention should be paid to training and qualification records of individuals involved with the violation.
- 2. Identify the root cause of the violation.
Corrective action is not comprehensive unless it addresses the root cause(s) of the violation. It is essential, therefore, that the root cause(c) of a violation be identified so that appropriate action can be taken to prevent further noncompliance in this area, as well as other potentially affected areas. Violations typically have direct and indirect cause(s). As each cause is identified, ask what other factors could have contributed to the cause. When it is no longer possible to identify other contributing factors, the root causes probably have been identi fied. For example, the direct cause of a violation may be a failure to follow procedures; the indirect causes may. be inadequate training lack of attention to detail, and inadequate time to carry out an activity. These factors may have been caused by a lack of staff resources that, in turn, are indicative of lack of management support.
Each of these factors must be addressed before corrective action is considered to be comprehensive.
,' IN 96-28 May 1. 1996 Page 4 of 6
- 3. Take cromot and comorehensive corrective action that will address the immediate concerns and orevent recurrence of the violation.
It is important to take immediate corrective action to address the specific findings of the violation. For example, if the violation was issued because radioactive material was found in an unrestricted area,
'immediate corrective action must be taken to place the material under Licensee control in authorized locations. After the imediate safety concerns have been addressed, timely action must be taken to prevent future recurrence of the violation. Corrective action is sufficiently coniprehensive when corrective action is broad enough to reasonably prevent recurrence of the specific violation as well as prevent similar violations.
In evaluating the root causes of a violation and developing effective corrective action, consider the following:
- 1. Has management been informed of the violation (s)?
- 2. Have the pregrammatic implications of the cited violation (s) and the i potential presence of similar weaknesses in other program areas been l considered in formulating corrective actions so that both areas are l
adequately addressed?
- 3. Have precursor events been considered and factored into the corrective actions?
- 4. In the event of loss of radioactive material, should security of radioactive material be enhanced?
- 5. Has your staff been adequately trained on the applicable requirements?
6 Should personnel be re-tested to determine whether re-training should be emphasized for a g:ven area? Is testing adequate to ensure understanding of requirements and procedures?
- 7. Has your staff been notified of the violation and of the applicable corrective action?
- 8. Are audits sufficiently detailed and frecuently performed? Should the frequency of periodic audits be increasec?
+
IN 96 f*/' '
May 1, 1996 e Page 5 o' 6-
' 9,:
~
ils2there'aineed{for: retaining an independent technical consultant to p Laudit:the area-of concern-or revise your procedures?
110. Arefthe procedures consistent-with-current NRC requirements, should they:
- be clarified, or should new" procedures be developed? ,
L 11. Isla system:in place for keeping abreast of new or modified NRC ,
p requirements?
o l
- 12. Does:your staff appreciate the need to consider safety in approaching
' daily assignments?
13; .Are resources adequate to perform, and maintain control over. the e licensed activities? Has the radiation safety officer been provided.
. sufficient time and resources to perform his or her oversight duties?
l F 14,- Have work hours affected the employees' ability to safely perform the job? . .
F :
i: 15. 'Should organizational changes be made (e.g.. changing the reporting _
relationship of the radiation safety officer to provide increased i independence)?
r
- 16, Are management and the radiation safety officer:adequatelyLinvolved_in oversight and implementation of the licensed activities? .Do supervisors
, adequately observe new employees ~and_ difficult, unique, or new operations?
- 17. Has management established a work environment'that encourages employees l to raise safety and compliance concerns?
g 18. Has management placed a premium on production over compliance and-
- . _ safety? Does management demonstrate a commitment to compliance and l- safety?
- -19. Has; management communicated its expectations for
- safety and. compliance?
p 20, - Is there a published discipline policy for; safety violations, and are
- employees aware of it? LIs it being followed? -
Ei i
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t
E. IN 96-28
-** May 1. 1996-Page 6 of 6
'This information notice requires no specific action nor written response. If you have any questions about the information in this notice, please contact
, one of the technical contacts listed below.
Elizabeth 0. Ten Eyck. Director Donald A. Cool. Director Division-of Fuel Cycle Safety Division of Industrial and Safeguards and Medical Safety Office of Nuclear Material Safety Office of Nuclear Material Safety and Safeguards and Safeguards Technical contacts: Nader L. Mamish. OE Daniel J. Holody, RI (301) 415-2740 (610) 337-5312 Internet:nlm@nrc. gov Internet:djh@nrc. gov Bruno Uryc. Jr., RII Bruce L. Burgess. RIII (404) 331-5505 (708) 829-9666 Internet:bxu@nrc. gov Internet: bib @nrc. gov
~
Gary F. Sanborn RIV (817) 860-8222 Internet:gfs@nrc. gov Attachments:
- 1. List of Recentl Issued NMSS Information Notices 1 2. List of Recentl Issued NRC Information Notices 1