ML20045E435
| ML20045E435 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 06/04/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20045E427 | List: |
| References | |
| 70-1151-93-03, 70-1151-93-3, NUDOCS 9307020108 | |
| Download: ML20045E435 (4) | |
Text
.
ENCLOSURE l-NOTICE OF VIOLATION Westinghouse Electric Corporation Docket No.:
70-1151 Columbia, South Carolina License No.:
SNM-1107 During an NRC inspection conducted on April 19-23 and May 3-7, 1993, violations of NRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedure for NRC Enforcement Actions,".the violations are listed below:
A.
Condition 9 of Special Nuclear Material License Number 1107 (SNM-1107):
requires that licensed material be used in accordance with statements, representations, and conditions contained in Chapters 2, 3, and 4 of the application dated March 26, 1984, and supplements thereto.
Chapter 2, Section 2.3.1.10 of the application states that when non-favorable geometry is used, Westinghouse shall establish appropriate administrative controls, take into consideration identified contributing causes of criticality accidents, demonstrate that such causes will be subject to administrative controls, and demonstrate compliance with the double contingency-principle.
Chapter 2, Section 2.3.1.5 of the license application states that all transfers of enriched uranium oxides from geometry c.ontrolled equipment -
or containers to moderation controlled equipment or containers shall require moisture analyses prior to the transfers.
Contrary to the above, the implemented controls associated with transfers of enriched uranium oxides from geometry controlled polypaks to a non-favorable geometry blender were not sufficient to comply with the double contingency principle in that only one adequate' nuclear criticality safety barrier was implemented. This one barrier involved the requirement to perform moisture analysis' prior to. the transfer.
The Nuclear Safety Analysis file for the transfer contained only calculational information which established the. percent moisture limit,.
and was deficient in that it did not contain documentation of consideration of contributing causes of criticality accidents, demonstrate that such causes will be subject to administrative controls, and demonstrate compliance with the double contingency principle. As.a result, the single barrier associated with the required moi ture analysis -
s failed when on or about October 23, 1992, enriched U 0a from geometry 3
controlled polypaks was introduced into a non-favorable geometry blender and on or about April 8, 1993, enriched U0(from geometry controlled' polypaks was administratively released to be introduced into a non-favorable geometry blender without the required moisture analyses being performed prior to the transfer.
This is a Severity Level IV violation (Supplement VI).
B.
Condition 9 of Special Nuclear Material License Number 1107 (SNM-1107) requires that licensed material be used in accordance with statements, 9307020108 930604 PDR ADOCK 07001151 C-PDR
~.
a Westinghouse Electric Corporation 2
Docket No.:
70-1151 Columbia, South Carolina.
License No.:
SNM-1107 representations, and conditions contained 'in. Chapters 2,. 3, 'and 4 of the application dated March 26,.1984, and supplements thereto.
Chapter 3, Sections 3.1.2.2 and 3.1.4.1 of the, license application state that operations shall be carried out in accordance with-internal operating procedures.
i Licensee procedures COP-814201 and CF-81-900 require operators to tumble a composite sample of U 0, to make the sample homogeneous. prior to its-3 submittal to a laboratory for moisture analysis.
Contrary to the above, on or about March 9,1993, an untumbled,-
unhomogeneous sample was submitted to the laboratory for analysis which resulted in an analytical result which was biased.
I This is a Severity Level IV ' violation (Supplement VI).
C.
Condition 9 of Special Nuclear Material LicenseL Number 1107 (SNM-1107) requires that licensed material be used in accordance with statements,.
representations, and conditions contained in Chapters 2, 3, and 4 of the.
application dated March 26,.1984, and supplements thereto.
Chapter 2, Section 2.2.14.1.(14) of the license application ' states that
. check hopper moisture analyzers shall be provided as.part of the IDR' conversion system.
Contrary to the above, on February 16,.1993 the licensee discovered that the moisture analyzers had been removed from-the check hopper. in the IDR conversion system at a point in time either prior to or soon after-startup of the processLin March 1985.
This is a Severity Level IV violation (Supplement V1).
D.
Condition 9 of License SNM-1107 requires that. licensed material be used in accordance with statements, representations,.and conditions contained in Chapters 2, 3, and 4 of the license appl-ication dated March 26, 1984, and supplements thereto.
Chapter 2, Section 2.6 of the license application requires that special nuclear material processing be conducted in accordance with approved written procedures or instructions.
Regulatory Affairs Procedure, RA-302, ' Criticality Signs," Revision 6, dated April 1, 1993, states in Section 6 that' area supervision is responsible to ensure compliance with criticality control parameters and instructions on criticality signs.
The Criticality Sign posted on the ventilation hood near the Solvent-Extraction Control Room specified a limit of three polypaks could be
. located inside the hood and that twelve inches should be maintained between the'polypaks.
3:
i E
. Westinghouse Electric Corporation 3
' Docket No.:
70-1151 Columbia, South Carolina License No.: 'SNM-1107 The Criticality Sign posted on one storage r'ack in the Solvent Extraction area stipulated that the material-authorized to be stored in the rack was-i incinerator ash in ammo cans or polypacks.
j Chemical Operating Procedure, COP-841000, " Low-Level Radioactive Scrap Handling," Revision 5, dated February 26, 1993, states in Section 7.1.3 2
that containers for-combustible scrap must meet factory mutual 4
requirements (e.g., metal container with fire safe lid).
Revision 6 of.
j COP-841000, dated April 22, 1993, states in Section 7.1.9(B) that, for combustible trash, there must be at least twelve inches of space q
maintained between all trash cans and/or trash bags.
Contrary to the criticality sign on the hood, the criticality sign 'on the ~
storage rack, and the. procedure concerning handling scrap, the licensee i
failed to follow instructions and procedures in that:
1)
On April 21,-1993,-four polypaks were noted inside the hood located by the Solvent Extraction Control Room.and three of the polypaks were spaced within 6 to 8 inches of each other.
2)
On April 21,'1993, polypaks containing materials such as press cake, sludge, and torit (bag filter) fines were noted to be stored on a i
storage rack in the Solvent Extraction area which was not authorized i
by the posted criticality sign.
j i
3)
On April 21, 1993, at approximately 11:00 a.m., three plastic bags 1
containing dirty rags were noted on the floor in the general area of
-l Conversion Line No. 5 across from the Stratification Blender where
.i repair work was being performed on a pellet press. One bag was laying beside a red 5-gallon -scrap can, one bag was laying approximately three feet from a red 5-gallon scrap can, and the i
third bag was near the pellet press. At approximately 6:15 p.m.
that evening, two bags containing dirt rags and a dirty rag were laying on the floor next to a red 5-gallon scrap can and a wet, dirty mop head was laying on the floor approximately six feet' away, These items were in the same locations at.approximately 7:15 p.m.
At approximately 8:15 a.m. on April 22, 1993, the two bags containing dirty rags and the dirty rag were still laying on the-
,I floor against the red 5-gallon ~ scrap can'.
This is a Severity Level IV violation (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201,' Westinghouse Electric Corporation is hereby required to submit a written. statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN:. Document Control Desk, Washington, D.C..
1 20555 with a copy to the Regional Administrator, Region-II,~ within 30. days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:
(1) the reason for the violation,- or, if j
contested, the basis for disputing the violation, (2)'the corrective steps that have been taken and the results achieved, (3) the corrective steps:that i
will be taken to avoid further violations, and (4) the date when full compliance will be achieved.
If an adequate reply is not received within the i
E l
Westinghouse Electric Corporation 4
Docket No.:
70-1151 Columbia, South Carolina License No.:
SNM-1107 time specified in this Notice, an order or Demand for Information may be issued 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 Atlanta, Georgia thisj'dayofJune1993 4
aQh6
)
l l
e l
l l
l l
l l
l 1
l