ML20044C418
| ML20044C418 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 02/18/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20044C414 | List: |
| References | |
| 70-0734-93-01, 70-734-93-1, NUDOCS 9303230010 | |
| Download: ML20044C418 (4) | |
Text
r i-NOTICE OF VIOLATION
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Docket No.70-734 General Atomics License No. SNM-696
- San Diego, California During an NRC inspection conducted on January 11-15 and 21-22, 1993, four violations of NRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C, the violations are listed below:
Condition No. 9 of License No. SNM-695 authorizes the use of licensed A.
materials in accordance with the. statements, representations, and conditions contained in Part II," License Specifications," dated July 24, 1981, and supplements dated March 16, 1982, through June 19, 1992.
Section.5.0, " Nuclear Safety - Technical Requirements," Part II of the-license specifications, states:
- The continued nuclear safety of the licensee's operations shall be assured by limits and procedures documented in accordance with the specifications contained in the following sections:
"5.2, Basic Assumptions "The basic assumptions that shall be utilized in arriving at particular criticality limits are as follows:
" Accident - At least two unlikely, accidental, concurrent, and independent events must occur before a criticality hazard could exist.
"5.4.3.d. The geometrical safe limits shall apply to units meeting the following criteria:
The unit shall be evaluated for all possible credible ii.
accident conditions to assure that the safety margin (difference between critical and safc limits) is not exceeded.
"5.4.4. "All geometries analyzed by hand calculations shall have a K,, of 0.90 or less."
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i Contrary to the above:
(a)
As of January 21, 1993, Criticality Safety Analyses (CSAs) i
" Casting Mold" dated September 8,1976, and " Melting Furnace,"
dated December 27,1972, (for the TRIGA Fuel Fabrication 1
Facility's induction furnace), were not adequate to determine that i
criticality safety criteria were satisfied, in that the CSAs failed to adequately evaluate all credible accident conditions, l
e.g., flooding of the induction furnace and spilling of enriched uranium-zirconium metal at the same time. On January 11, 1993, such an event occurred when a water leak occurred in the induction furnace, resulting in molten enriched uranium-zirconium metal a
spilling from its favorable geometry crucible into the unfavorable geometry cavity of the furnace.
(b)
As of January 21, 1993, the CSAs did not provide the calculated i
K.,, for geometries of the cylinders analyzed by hand calculations l
a to demonstrate that they were critically safe vessels.
j This is a Severity Level IV violation (Supplement VI).
i B.
Section 3.2.2 " Compliance Functions," Part II of the license specifications, states
- t "All functions responsible for assuring compliance with applicable i
license requirements and controlling the radiological and nuclear i
safety and safeguards of licensed material are part of the Human Pesources Organization of General Atomics. Namely, these functions are: Nuclear Safety, Licensing, Safety and Nuclear Compliance, Nuclear Material Accountability, Statistics &
Measurement Control, Security, and Health Physics."
"The Director of Human Resources, or his designee, will establish the necessary policies of operation, cause them to be published in company-wide guides and manuals, and coordinate related activities with operating groups to assure compliance with related policies, procedures, regulations and license conditions...."
l Section 3.4.1., " Definitions", of the licensee's Nuclear Safety Guide, i
i defines " Parameter" as "A characteristic of a system which must be controlled for the purposes of criticality safety, e.g., mass, geometry, concentration and moderation."
Section 3.4.2, " Criteria for Reporting," of the licensee's Nuclear Safety Guide states, in part.
" Situations, events or items such as the following are to be reported to management and Nuclear Safety for evaluation when
[the) quantity of SNM i:; greater than an ever-safe mass.
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- 1. Procedure cannot be followed as written...."
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3 Section 3.4.3, " Criteria for Action," of the licensee's Nuclear Safety Guide states, in part:
"Upon becoming aware of a situation, event, or item such as the above, Nuclear Safety, with the assistance from additional specialists as necessary, will evaluate and assess the safety significance of the occurrence. Nuclear Safety will also assess for adequacy, the corrective actions taken, and/or planned.
"Further, Nuclear Safety will consult with and advise Licensing, Safety and Nuclear Compliance with regard to proper reporting, both internally and externally. Reports to the NRC Operations Center will also be reported to the appropriate Regional Administrator.
"The criticality safety event reporting criteria and appropriate response actions are given in Table 3.4-1."
Table 3.4-1 requires, when there is substantial degradation or loss of a control parameter resulting in only one parameter remaining under control:
"b. Notif[ication of the] NRC as soon as possible within four (4) hours of discovery."
Contrary to the above, at about 1:10 pm on January 11, 1993, while melting low enriched uranium-zirconium alloy of more than an ever-safe mass of U-235, an operator and the TFFF's QC inspector became aware of a significant process upset that resulted in termination of the operation in progress; shortly after the event, at about 1:30 pm, the TFFF's manager became aware of the event; the event resulted in an unusual condition that prevented completion of the process in accordance with the established operating procedure, " Induction Melting and Pouring of U/Zr and U/ZR/Er Alloy;" but this event was not reported to the NRC until 1:04 pm on January 12, 1993, a period exceeding four hours.
This is a Severity Level IV violation (Supplement VI).
C.
Condition No. 11 of License No. SNM-696 states, in part:
" Records of all safety-related reports and analyses shall be retained as follows:
Copies of criticality and radiation safety analyses shall be i
a.
J retained for at least 2 years or 6 months after a project is terminated, whichever is longer."
Section 3.7.5.3, Demonstration Volume I, stated in part that the crucible used to melt enriched uranium-zirconium alloy in the TRIGA fuel i
Fabrication Facility's induction furnace had been analyzed-for criticality safety in a manner similar to that for the casting mold.
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4 21,_1993, the licensee had no.
Contrary to the' above, as of January record of a criticality safety analyses specific to the crucible.
l-This is:a Severity Level'V violation (Supplement VI).
Pursuant to the provisions _of 10 CFR 2.201, General Atomics is hereby required to submit a written statement or explanation to the' U.S. Nuclear Regulatory-Commission,' ATTN:~ Document Control Desk, Washington, D.C. 20555, with-a copy to the Regional Administrator, Region V, within 30 days of_.the date of the l
I.'
letter transmitting this Notice. This reply should be clearly marked as a-
" Reply to a Notice of Violation" and should include:
(1).the reason for the violation, or, if contested, the basis. for disputing the violation,- (2). the
- the corrective. steps that have been taken and the results achieved, (3)d:(4) the corrective steps that will be taken to avoid further violations,'an l
If an-adequate reply is not date when full compliance will be achieved.
L received within the time specified in this Notice, the Commission may issue an-order or a demand for information as to why the-license should not be modified,~ suspended,,or revoked or why such'other action as may be proper should not be taken. Where good'cause is shown, consideration will be given-to extending the response time.
Dated at Walnut Creek, California this IS"' day of fhag 1993
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