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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217J8171999-10-14014 October 1999 Responds to NRC GL-98-03,completing Portion Which Applies to Safety & Process Control Activities of Y2K Readiness Program to Assure That Computer Sys Will Not Prevent or Degrade Safety Function of Structure,Sys or Component ML20217B7511999-10-11011 October 1999 Forwards Siemens Power Corp Responses to RAI in Ltr ML20217C7671999-10-0606 October 1999 Forwards Proprietary Rev 32 EMF-12(P), Nuclear Matls Safeguards Procedures Description for Fuels Fabrication Plants, Replacing Chapters 2 & 3 of Rev 32,dtd Jul 1999. Proprietary Info Withheld,Per 10CFR2.790(d) ML20217C5651999-10-0404 October 1999 Requests Addl Info Needed Before Action Can Be Taken on Siemens Application for Amend to License SNM-1227 to Authorize Activities with SNM in Fuel Services Bldg.Info Specified in Encl Should Be Provided within 10 Days of Ltr ML20216J5381999-09-30030 September 1999 Forwards RAI Per 990721 Application Requesting Amend to License SNM-1227 to Add Process Waste Storage Area Consisting of Four Tanks & Ion Exchange Column to Ammonia Recovery Facility as Part of Wastewater Treatment Process ML20212G3631999-09-21021 September 1999 Forwards Two Sheets from R Burklin Dose Calculations for Heather & Julie ML20212A1921999-09-10010 September 1999 Submits follow-up to NRC Operations Center Rept 36030 Re Bulletin 91-001 Rept on over-batching of Waste Drums Due to Inaccurate Determinations of U Contents ML20217B5621999-09-0202 September 1999 Ack Receipt of 990806 Application for Amend to License SNM-1227.Acceptance Review Completed & Identified No Administrative Omissions or Deficiencies.Formal Review Anticipated Completion Date of Dec 1999 ML20212G1281999-08-31031 August 1999 Informs That Corporation Is Expected to Produce Approx 40,000 Gallons of Ammonium hydroxide-ammonium Nitrate Solution Per Week.Unsold Solution Will Be Processed Through Arf for Recovery of Ammonia & Then Be Sent to Sewer ML20211G1681999-08-26026 August 1999 Ack Receipt of Transmitting Application for Amend to License SNM-1227 Re Addition to Ammonium Recovery Facility.Acceptance Review Has Identified No Administrative Errors of Omissions ML20211F5791999-08-25025 August 1999 Forwards Insp Rept 70-1257/99-201 on 990802-05.No Violation Noted.Proprietary Document Enclosed ML20211B9101999-08-19019 August 1999 Forwards Insp Rept 70-1257/99-202 on 990802-05.No Violations Noted ML20210R8961999-08-12012 August 1999 Forwards Insp Rept 70-1257/99-02 on 990712-16.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representatives Records,Interviews with Personnel & Observation of Activities in Progress ML20210T4811999-08-11011 August 1999 Informs That NRC Has Completed Acceptance Review of Application for Amend to License SNM-1227 & Have Identified No Administrative Omissions or Deficiencies.Nrc Anticipates Completing Formal Review by End of Oct 1999 ML20210U0561999-08-11011 August 1999 Responds to 990714 Correspondence,By Which Siemens Sent Revised Page Change to Table I-1.1, Authorized Activities. Since NRC Had Previously Authorized Activity Stated,Change to Application Is Administrative & No Action Is Required ML20210G0681999-07-28028 July 1999 Concludes That Proposed Additions to Chapter 15 of License Application Submitted by Listed Ltrs Demonstrate Applicant Adherence to Conditions in Part I of License Application & That No Amend to License Necessary ML20210F1431999-07-27027 July 1999 Forwards Rev 10 to EMF-1563, Consolidated License Application for Siemens Power Corp Model SP-1,SP-2 & SP-3 Shipping Containers, Incorporating New Criticality Safety Evaluation ML20210E9551999-07-26026 July 1999 Forwards Amend 17 to License SNM-1227,allowing Storage of Moderated Uranium Compounds in sea-land Containers.Safety Condition S-1 Has Also Been Revised to Include Date of 990527.Safety Evaluation Rept,Encl ML20210F1791999-07-23023 July 1999 Forwards Proprietary Rev 32 to EMF-12(P), Nuclear Matls Safeguards Procedures Description for Fuel Fabrication Plants, Replacing All Sections of Existing Plan.Proprietary Encl Withheld ML20216D4351999-07-21021 July 1999 Provides Description of Modifications That Will Be Made to Ammonia Recovery Facility.Wastewater Flowsheet Encl ML20210C2071999-07-19019 July 1999 Requests Registration as User of Models SP-1 & SP-2 Packaging ML20209H5361999-07-15015 July 1999 Ack Receipt of 990519 Application for Amend to License SNM-1227 Re Sale of Ammonium Nitrate/Ammonium Hydroxide Solution Fertilizer.Initial Review of Application Has Identified No Administrative Omissions or Deficiencies ML20209G2561999-07-12012 July 1999 Informs That Staff Has No Comments on Siemens Power Corp Ammonium Recovery Facility - Sepa Determination of non-significance in Response to ML20209D8121999-07-0606 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/99-01. Corrective Actions Will Be Reviewed During Future Insp to Determine That Full Compliance Has Been Achieved ML20196H0021999-06-23023 June 1999 Submits Response to NRC GL 98-03 for Y2K.Upgraded Y2K Ready Primary Control Sys Will Be Installed & Tested in July 1999 ML20196A0931999-06-15015 June 1999 Responds to NRC Re Violations Noted in Insp Rept 70-1257/99-01.Corrective Actions:Info Requested by NRC Is Fully Available in Previously Docketed Correspondence ML20209C2711999-06-11011 June 1999 Requests Review & Comment on Encl Sepa Checklist & Other Info on File with City,By 990625 ML20195F9401999-06-0707 June 1999 Concurs That 990331 Proposed Changes to Richland Facility Emergency Plan Do Not Decrease Effectiveness of Plan.Nrc Will Amend License,Within Next Six Months,To Ensure Latest Rev to Plan Is Reflected ML20207B3681999-05-21021 May 1999 Forwards Insp Rept 70-1257/99-01 on 990322-26,0514 & 21 & Nov.Three Violations Identified Involving Two Examples of Using Transport Containers Which Did Not Meet Terms & Conditions of Applicable Certificate of Compliance ML20206L5371999-05-11011 May 1999 Forwards Amend 16 to License SNM-1227,allowing Storage of Moderated Special Nuclear Matl in sea-land Containers.Ser Also Encl ML20206J8091999-05-10010 May 1999 Informs That NRC Has Identified Deficiency in Application Dtd 990412,requesting Amend of Coc 9248.Application Does Not Include Complete Criticality Analysis for Category 2 FA Identified in App 6H.Info Should Be Provided within 14 Days ML20207M0151999-03-11011 March 1999 Informs That Encl Ltr Dtd 950622,explains How NRC Staff Plans to Institute Round Robin Sample Exchange Program Administered by Nbl for Verifying Quality of Licensee U Destructive Measurement Systems.Invoice FL0236-99 Encl ML20207J7221999-02-24024 February 1999 Ack Receipt of 980121 Application for Amend to License SNM-1227.Completed Initial Review with No Administrative Omissions or Deficiencies Identified.Anticipates Technical Review Will Be Completed by First Week in April ML20203G2191999-02-16016 February 1999 Responds to Which Expressed Concerns Re USNRC Plans to Distribute 981221 SRM Re SECY-98-232 & Commission Paper to All Agreement States.Informs That NRC Does Not Plan to Delay Implementation of Actions Specified in SRM ML20202E4141999-01-29029 January 1999 Ack Receipt of 990122 Response to Violations Noted in Insp Rept 70-1257/98-204.Implementation of Licensee Corrective Actions Will Be Reviewed During Future Insps ML20202H6241999-01-29029 January 1999 Forwards Siemens Power Corp Best Estimate of Upcoming Work Which Will Require NRC Licensing Actions ML20199K9571999-01-19019 January 1999 Informs of Listed New Address,For Docket 7106851,for Siemens Power Corp,Effective 990101.Postcard with New Address,Encl ML20199F3741999-01-12012 January 1999 Responds to NRC Re Violations Noted in Insp Rept 70-1257/98-204.Corrective Actions:All Work on Line 1 Ammonium Diuranate (Adu) Project Was Stopped Until Incident Could Be Fully Investigated & Necessary Actions Implemented ML20206R9451999-01-0707 January 1999 Forwards Pages 15-159 Through 15-174 to Include in Chapter 15 of Siemens Power Corp License Application.Pages Provide Summary of Criticality Safety Analysis for Processes Carried Out in Lagoon U Recovery & Solids Processing ML20198P0991998-12-30030 December 1998 Submits Response to GL 98-03 Re Program Set Forth in EMF-2097, Siemens Power Corp Yr 2000 Readiness & Administered by Yr 2000 Project Team ML20198M8901998-12-23023 December 1998 Forwards Amend 15 to License SNM-1227,amended to Allow Processing of TVA Lead Test Assembly Fuel ML20198A9651998-12-15015 December 1998 Submits Addl Info to Support Request to Amend Limit for transuranic-related Activity in Feedstock for License SNM-1227.Revised License Pages 1-5 & 1-6,correcting Inadvertent Omission of Section 1.6.12,encl ML20198F5701998-12-15015 December 1998 Forwards Insp Rept 70-1257/98-05 on 981026-30.No Violations Noted.Areas Examined During Insp Were Operational Safety & Event Review Feedback & Mgt Organization & Controls ML20198B4041998-12-14014 December 1998 Forwards Insp Rept 70-1257/98-204 on 981109-13 & Notice of Violation Involving Failure to Control Decommissioning Operations So That Operators Would Verify That Disassembled Equipment Free from Visible U Deposits ML20154S1881998-10-20020 October 1998 Submits follow-up to NRC Operations Ctr Rept 34819 Bulletin 91-001 on Failure to Remove Accumulated Solids from Dismantled Ductwork ML20155A5371998-10-0909 October 1998 Informs That NRC Has Reviewed Changes to Part II of Application for License SNM-1227.Administrative Error Re Three 500 Kw Generators Was Noted.Nrc Would Like to Be Informed as to Whether Interpretation Is Correct ML20153C3091998-09-18018 September 1998 Submits Response to GL 98-03,re Year 2000 Readiness Program 1999-09-30
[Table view] Category:OUTGOING CORRESPONDENCE
MONTHYEARML20217C5651999-10-0404 October 1999 Requests Addl Info Needed Before Action Can Be Taken on Siemens Application for Amend to License SNM-1227 to Authorize Activities with SNM in Fuel Services Bldg.Info Specified in Encl Should Be Provided within 10 Days of Ltr ML20216J5381999-09-30030 September 1999 Forwards RAI Per 990721 Application Requesting Amend to License SNM-1227 to Add Process Waste Storage Area Consisting of Four Tanks & Ion Exchange Column to Ammonia Recovery Facility as Part of Wastewater Treatment Process ML20217B5621999-09-0202 September 1999 Ack Receipt of 990806 Application for Amend to License SNM-1227.Acceptance Review Completed & Identified No Administrative Omissions or Deficiencies.Formal Review Anticipated Completion Date of Dec 1999 ML20211G1681999-08-26026 August 1999 Ack Receipt of Transmitting Application for Amend to License SNM-1227 Re Addition to Ammonium Recovery Facility.Acceptance Review Has Identified No Administrative Errors of Omissions ML20211F5791999-08-25025 August 1999 Forwards Insp Rept 70-1257/99-201 on 990802-05.No Violation Noted.Proprietary Document Enclosed ML20211B9101999-08-19019 August 1999 Forwards Insp Rept 70-1257/99-202 on 990802-05.No Violations Noted ML20210R8961999-08-12012 August 1999 Forwards Insp Rept 70-1257/99-02 on 990712-16.No Violations Noted.Insp Consisted of Selective Exam of Procedures & Representatives Records,Interviews with Personnel & Observation of Activities in Progress ML20210U0561999-08-11011 August 1999 Responds to 990714 Correspondence,By Which Siemens Sent Revised Page Change to Table I-1.1, Authorized Activities. Since NRC Had Previously Authorized Activity Stated,Change to Application Is Administrative & No Action Is Required ML20210T4811999-08-11011 August 1999 Informs That NRC Has Completed Acceptance Review of Application for Amend to License SNM-1227 & Have Identified No Administrative Omissions or Deficiencies.Nrc Anticipates Completing Formal Review by End of Oct 1999 ML20210G0681999-07-28028 July 1999 Concludes That Proposed Additions to Chapter 15 of License Application Submitted by Listed Ltrs Demonstrate Applicant Adherence to Conditions in Part I of License Application & That No Amend to License Necessary ML20210E9551999-07-26026 July 1999 Forwards Amend 17 to License SNM-1227,allowing Storage of Moderated Uranium Compounds in sea-land Containers.Safety Condition S-1 Has Also Been Revised to Include Date of 990527.Safety Evaluation Rept,Encl ML20209H5361999-07-15015 July 1999 Ack Receipt of 990519 Application for Amend to License SNM-1227 Re Sale of Ammonium Nitrate/Ammonium Hydroxide Solution Fertilizer.Initial Review of Application Has Identified No Administrative Omissions or Deficiencies ML20209G2561999-07-12012 July 1999 Informs That Staff Has No Comments on Siemens Power Corp Ammonium Recovery Facility - Sepa Determination of non-significance in Response to ML20209D8121999-07-0606 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/99-01. Corrective Actions Will Be Reviewed During Future Insp to Determine That Full Compliance Has Been Achieved ML20195F9401999-06-0707 June 1999 Concurs That 990331 Proposed Changes to Richland Facility Emergency Plan Do Not Decrease Effectiveness of Plan.Nrc Will Amend License,Within Next Six Months,To Ensure Latest Rev to Plan Is Reflected ML20207B3681999-05-21021 May 1999 Forwards Insp Rept 70-1257/99-01 on 990322-26,0514 & 21 & Nov.Three Violations Identified Involving Two Examples of Using Transport Containers Which Did Not Meet Terms & Conditions of Applicable Certificate of Compliance ML20206L5371999-05-11011 May 1999 Forwards Amend 16 to License SNM-1227,allowing Storage of Moderated Special Nuclear Matl in sea-land Containers.Ser Also Encl ML20206J8091999-05-10010 May 1999 Informs That NRC Has Identified Deficiency in Application Dtd 990412,requesting Amend of Coc 9248.Application Does Not Include Complete Criticality Analysis for Category 2 FA Identified in App 6H.Info Should Be Provided within 14 Days ML20207M0151999-03-11011 March 1999 Informs That Encl Ltr Dtd 950622,explains How NRC Staff Plans to Institute Round Robin Sample Exchange Program Administered by Nbl for Verifying Quality of Licensee U Destructive Measurement Systems.Invoice FL0236-99 Encl ML20207J7221999-02-24024 February 1999 Ack Receipt of 980121 Application for Amend to License SNM-1227.Completed Initial Review with No Administrative Omissions or Deficiencies Identified.Anticipates Technical Review Will Be Completed by First Week in April ML20203G2191999-02-16016 February 1999 Responds to Which Expressed Concerns Re USNRC Plans to Distribute 981221 SRM Re SECY-98-232 & Commission Paper to All Agreement States.Informs That NRC Does Not Plan to Delay Implementation of Actions Specified in SRM ML20202E4141999-01-29029 January 1999 Ack Receipt of 990122 Response to Violations Noted in Insp Rept 70-1257/98-204.Implementation of Licensee Corrective Actions Will Be Reviewed During Future Insps ML20198M8901998-12-23023 December 1998 Forwards Amend 15 to License SNM-1227,amended to Allow Processing of TVA Lead Test Assembly Fuel ML20198F5701998-12-15015 December 1998 Forwards Insp Rept 70-1257/98-05 on 981026-30.No Violations Noted.Areas Examined During Insp Were Operational Safety & Event Review Feedback & Mgt Organization & Controls ML20198B4041998-12-14014 December 1998 Forwards Insp Rept 70-1257/98-204 on 981109-13 & Notice of Violation Involving Failure to Control Decommissioning Operations So That Operators Would Verify That Disassembled Equipment Free from Visible U Deposits ML20155A5371998-10-0909 October 1998 Informs That NRC Has Reviewed Changes to Part II of Application for License SNM-1227.Administrative Error Re Three 500 Kw Generators Was Noted.Nrc Would Like to Be Informed as to Whether Interpretation Is Correct ML20151X0591998-09-11011 September 1998 Forwards Insp Rept 70-1257/98-04 on 980810-14.No Violations Noted.During Insp,Licensee Conduct of Activities at Siemens Facility Was Generally Characterized by Effective Implementation of Operational Safety,Maint & Surveillance ML20239A5221998-09-0202 September 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/98-03 on 980717 ML20151W9751998-09-0202 September 1998 Forwards Amend to License SNM-1227,revising to Incorporate Fundamental Nuclear Matl Control Plan.Revised License & Evaluation Rept,Encl ML20151W9951998-09-0101 September 1998 Forwards Amend 13 to License SNM-1227 to Reflect Correct Location of UF6 Cylinder Storage,Adding Filter Presses to Table I-4.1 & Sale of Ammonium Hydroxide for Fertilizer ML20236R2661998-07-17017 July 1998 Forwards Insp Rept 70-1257/98-03 on 980615-19 & Notice of Violation Re Lack of Rigor in Implementation of Std Operating Procedures Used in Segregation of Hazardous Wastes Onsite & Rework of Fuel Cladding ML20236P2141998-06-26026 June 1998 Forwards Proprietary Request for Addl Info Identified in Encl to Ltr Re Revs to Fundamental Nuclear Matl Control Plan.Proprietary Encl Withheld (Ref 10CFR2.790(d)) ML20249A7211998-06-15015 June 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/98-202 ML20249A9691998-06-15015 June 1998 Refers to 980610 Meeting Conducted at Richland,Wa Re NRC Review of Performance Related to NRC Licensed Activities. List of Attendees & Slides Encl ML20249A2331998-06-11011 June 1998 Informs That QA Program Description Is Acceptable,Based on Review of Organizational Changes Described in Submittals & Addressing of NRC Comments in 980527 Submittal ML20249B2151998-06-0808 June 1998 Discusses Nrc'S Plans to Develop Emergency Response Technical Manual (Rtm) Supplements for Licensee Facility. Copy of Draft Outline for Rtm Supplements,Encl.W/O Encl ML20248J9831998-06-0202 June 1998 Forwards Insp Rept 70-1257/98-02 on 980413-17 & 980504-08.No Violations Noted.Insp Included Review of Circumstances Involved W/Fire That Occurred in Waste Handling Facility on 980415 Acceptable ML20248D8441998-05-21021 May 1998 Forwards Amend 12 to License SNM-1227,adding Operation of Solids Processing Facility as Authorized Location for Uranium Recovery.Safety Condition S-1 Revised to Include Dates of 960730 & 970128.Safety Evaluation Rept,Encl ML20248E0791998-05-18018 May 1998 Forwards Amend 11 to License SNM-1227,reflecting New Location for Liquid Effluent Sampling & Flow Measurements. Safety Condition S-1 & Safeguards Condition SG-2.1 Have Been Revised.Ser & Safeguards Evaluation Rept,Encl ML20247F6201998-05-12012 May 1998 Notification of Registration as User of Certificate of Compliance 6581,in Response to 980416 Request ML20247D7051998-05-0808 May 1998 Discusses NRC Performance Review of Licensed Activities on 961231-980101.Concludes That NRC Decided to Increase Insp Effort in Packaging & Shipping of Nuclear Fuel & Seek to Reduce Level of Insp in Area of Safeguards ML20247N1791998-05-0808 May 1998 Ack Receipt of ,Which Transmitted Rev 15 to Physical Protection Plan Entitled, Physical Protection Plan for SNM of Low Strategic Significance. Review of Changes Were Found to Be Consistent w/10CFR70.32(e) ML20248J0271998-05-0808 May 1998 Forwards Outline of NRC Review of Licensee Performance in Areas of Safety Operations,Safeguards,Radiological Controls, Facility Support & Licensing Activities ML20217Q9501998-05-0404 May 1998 Forwards Proprietary NOV & Insp Rept 70-1257/98-202 for Insp Conducted on 980406-10.Violation Involved Failure to Maintain Current Knowledge of Special Nuclear Matl Bearing Items.Nov & Insp Rept Withheld,Per 10CFR2.790 ML20216H6381998-04-15015 April 1998 Responds to & Affidavit Signed by Re Vaughan on 980316,requesting That Certain Info in Response to RAI Be Withheld Per 10CFR2.790.Determined That Info Sought to Be Withheld Contains Proprietary Info & Will Be Withheld ML20217J8541998-04-0101 April 1998 Forwards Insp Rept 70-1257/98-201 on 980313-19 on Nov. Violations Re Use of Unapproved Procedures & Operator Aids. Corrective Actions Taken by Staff ML20217A9071998-03-17017 March 1998 Forwards Amended License SNM-1227 & SER Re Authorization of Low Level Radioactive Waste Shredding & Uranium from LLRW in Modular Unit ML20217Q5141998-03-0505 March 1998 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/97-07 ML20203K3581998-02-24024 February 1998 Forwards Insp Rept 70-1257/98-01 on 980126-30.No Violations Noted.Inspector Noted That Staff Had Implemented Effective Programs in Mgt Organization & Controls,Operational Event Review & Feedback & Operator Training & Requalification ML20203A4081998-02-0303 February 1998 Informs That Project Management for Facility Has Been Changed Due to Reorganization of Staff.P Lain Will Be Project Manager Effective 980217 1999-09-30
[Table view] |
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s g* "84 UNITED STATES l p 4 NUCLEAR REGULATORY COMMISSION
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[ 611 RYAN PLAZA DRIVE, sulTE 400 g ARLINGTON, TEXAS 76011-8064 July 6, 1999 EA 99-085 l
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B. N. Femreite, Vice President ,
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l Siemens Power Corporation 2101 Horn Rapids Road Richland, WA 99352
SUBJECT:
RESPONSE TO NRC INSPECTION REPORT NO. 070-1257/99-01
Dear Mr. Femreite:
Thank you for your letter of June 15,1999, in response to our May 21,1999, letter and Notice of Violation concerning noncompliance issues with certificates of compliance for transportation packaging. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sincerely, Dwigh D. Chamberlain, Director Division of Nuclear Materials Safety Docket Nos.: 70-1257; 71-6581;71-9248 License No.: SNM-1227 Certificate of Compliance Nos.: 6581; 9248 cc:
L. J. Maas, Manager Regulatory Compliance Siemens Power Corporation l 2101 Horn Rapids Road Richland, Washington 99352 f
1 Washington Radiation Control Program Director ,
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DOCUMENT NAME: draft:s:\dnms\fcdb\wlb\90125701.ack.ftm final:r:\._dnms\901257ak.wlb To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:DNMS:FCDB NMSS:SPFO C:DNMS l TA:DNMS q \ D:DNMfd97 WLBritz:wsw4%/4 PLEng 6 l DBSpitzbergMtLHowell M
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U.S. Nuclear Regulatory Commission -
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L Gentlemen : l 1
Subject:
Reply to a Notice of Violation (License No. SNM-1227; Docket No. 70-1257) l Ref.: 1. Letter, Dwight D. Chamberlain (USNRC) to B.N. Femreite (SPC), "NRC Inspection Report 70-1257/99-01 and Notice of Violation," dated May 21,1999.
l Ref.: 2. Letter, L J. Maas (SPC) to NRC Document Control Desk, " Supplemental Information to Siemens Power Corporation (SPC) 10 CFR 71.95 Notification Reports Filed April 16, 1999 (Docket No. 71-6581) and April 30,1999 (Docket No. 71-9217), dated May 21, 1999.
Attached is Siemens Power Corporation's (SPC's) reply to the Notice of Violation accompanying the referenced NRC letter. As indicated in our attached reply, the information requested by the NRC is fully available in previously docketed correspondence. If you have questions regarding this reply or require more information, please contact me at (509) 375 8537.
Very truly yours, b m OW~ M~
L. J. Maas, Manager Regulatory Compliance
/pg Enclosures
! cc: E. W. Merschoff, Regional Administrator Region IV Siemens Power Corporation
! 2101 rlom Rapids Road Tel: (509) 375-8100 l Richland. WA 99352 Fax: (509) 375-8402 ,l k &Y l
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Attachment ,
Violations A. '10 CFR 71.12 states, in part, that a general license to transport licensed material, or to )
deliver licensed material to a carrier for transport, applies only to a licensee who '
complies with the terms and conditions of the certificate.
1.- Section 4, " Conditions," of Certificate of Compliance No. 9248 requires each user of this certificate to fulfill the requirements of 10 CFR Part 71, as applicable, and the conditions specified in the certificate.
Condition 5 (a)(3) " Drawings," of Certificate of Compliance No. 9248 requires that h the packaging be fabricated in accordance with the referenced SPC drawings.
Contrary to the above, on February 25,1998, the licensee delivered licensed material to a carrier for transport under the general license pursuant to 10 CFR 71.12, and the licensee did not comply with the terms and conditions of the certificate in that the weld configurations for lugs used to close the SP-1 inner container did not exist as specified in the drawings referenced in Certificate of Compliance 9248,
- 2. Section 4," Conditions" of Certificate of Compliance No. 6581 requires each user I of this cedificate to fulfill the requirements of 10 CFR Part 71, as applicable, and the conditions specified in the certificate.
Condition 5 (a)(3) " Drawings" of Certificate of Compliance No. 6581 requires that the packaging be fabricated in accordance with the referenced SPC drawings.
Contrary to the above, on April 16,1999, the licensee reported that it had transported licensed material under the general license pursuant to 10 CFR 71.12, and the licensee did not comply with the terms and conditions of the certificate in that the packages had multiple welds located on the strongback and outer container shell that did not conform to the drawings referenced in Certificate of Compliance No. 6581.
B. 10 CFR 71.85 (c) states that before the first use of any packaging for the shipment of licensed material, the licensee shall conspicuously and durably mark the packaging with its model number, serial number, gross weight, and a package identification n' umber assigned by NRC. Before applying the model number, the licensee shall determine that the packaging h been fabricated in accordance with the design approved by the l Commission. '
1 Contrary to the above, on February 25,1998, the licensee did not determine that the l packaging had been fabricated in accordance with the design approved by the
\
Commission before applying the model number, in that the licensee delivered licensed material to a carrier for transport in packaging with a model number applied that was not fabricated in accordance with the design approved by the Commission in Certificate of Compliance No. 9248.
C. 10 CFR 71.133 states, in part, the licensee shall establish eneasures to assure that conditions adverse to quality such as nonconformances are promptly identified and corrected.
- 1. Contrary to the above, established measures did not ensure that identified nonconformances were promptly corrected in that weld configurations specified in the Certificate of Compliance No. 9248 drawings for the Model SP-1 transportation package were identified as nonconforming by SPC on November 7, 1994, and again on April 7,1997, but the recommended corrective actions were not completed by SPC at the time of the NRC inspection in February 1998.
- 2. Contrary to the above, established measures did not ensure that conditions adverse to quality such as nonconformances were promptly identified between March and June 1998. Specifically, nonconforming welds on several Model 51032-1 transportation packages were not identified by the licensee when these packages were inspected between March and June 1998. A subsequent inspection conducted during March 1999 identified that most packages of this model, including those previously inspected, contained welds which did not conform to Certificate of Compliance No. 6521 drawings.
SPC Resoonse to V olations A.1. B. and C.1 Violations A.1, B, and C.1 relate to SPC's usage of non-conforming SP-1 shipping containers, an issue identified as an unresolved item in NRC Inspection Report 71-0003/98-203 (June 2, 1998). Per the Reference 1 letter, the NRC has concluded that SPC has adequately responded to the violations associated with the SP-1 non-compliance issue via correspondence previously submitted to the NRC. The dates and general content of this correspondence are as follows:
March 9,1998; B.N. This correspondence outlined SPC's initial corrective actions subsequent Femreite to P.L. Eng to the NRC shipping container QA inspection of February 23-27,1998, including SPC's compensatory shipping container inspection program.
June 25,1998; J.H. This correspondence provided SPC's response to the confirmatory action Nordahl to Dr. S.F. letter (CAL No. NMSS-98 8-002) that resulted from the February 1998 :
Shankman NRC shipping container QA inspection.
- July 1,1998; J.H. This correspondence provided SPC's responses to the non-conformances Nordahl to USNRC identified in NRC Inspection Report No. 71-0003/98-203 (June 2, 1998).
4
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October 29,1998: This correspondence outlined SPC's comprehensive corrective action J.H. Nordahl to Dr. program developed in response to the NRC-identified non-conformances, C.F. Shankman SPC's internal self-assessments, and an independent external root cause evaluation.
I I
December 23,1998; This correspondence conveyed, for NRC's review and approval, SPC's C.M. Powers to consolidated 10 CFR 50 Appendix B and 10 CFR 71 Subpart H quality USNRC assurance program (EMF-1, Revision 30).
April 26,1999; This correspondence provided the status of commitments made in SPC's C.M. Powers to Dr. letter of October 29,1998, in response to the non-conformances and S.F. Shankman the Confirmatory Action Letter.
SPC Resoonse to Violations A.2 and C.2 Violations A.2 and C.2 relate to SPC's use of Model 510321 containere that had ceitain welds that did not conform to the applicable license drawings. These discrepancies were not !
. identified in the compensatory container inspections conducted between March and June 1998.
Their eventual discovery in March of.1999 was reported to the NRC on April 16,1999 per the ;
requirements of 10 CFR 71.95(c). '
On May 21,1999 (Reference 2), SPC conveyed to the NRC supplemental information related to the 51032-1 weld non-conformances. This correspondence provided the NRC with information relating to the discovery of the weld discrepancies, the immediate actions taken by SPC after discovery of the discrepancies, the results of SPC's generic implications inspection of other SPC-owned shipping containers, the results of SPC's self-assessment as to why the ;
discrepancies were not discovered via SPC's initial compensatory inspections, and the corrective actions identified to preclude recurrence of similar shortcomings in future container inspections.
l We believe that the information provided in Reference 2 is fully responsive to the NRC's expectations concerning Violations A.2 and C.2. In addition, SPC has reinspected its entire 51032-1 container fleet using the enhanced inspect loa protocols identified in Reference 2. All containers have either been reworked to achieve fu'.I compliance with license drawings or, for a limited number of containers, removed from service. Therefore, full compliance has been achieved relative to SPC's usage of its 51032-1 container fleet.
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