ML20126B331

Notice of Violation from Insp on 921015-17 & 29.Violation Noted:Licensee Personnel Did Not Immediately Rept to Safety, Security & Licensing Abnormal Conditions Where U Accumulated in Unsafe Geometry Vessel

ML20126B331
Person / Time
Site:	Framatome ANP Richland
Issue date:	12/04/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20126B320	List: ML20126B317 ML20126B331 ML20126B345
References
70-1257-92-08, 70-1257-92-8, NUDOCS 9212220058
Download: ML20126B331 (4)

Text

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NOTICE OF VIOLATION Siemens Power Corporation Docket No. 70-1257 Richland, Washington License No. SNM-1227 During an NRC inspection conducted on October 15-17 and 29, 1992, two 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:

1. Violation - Response Reouired License Condition No. 9 of License No. SNM-1227 authorizes the use of licensed materials in accordance with the stattments, representations, and conditions contained in Part I of the licensee's application dated July 1987, and supplements dated November 12, 1987, through March 25, 1992.

Section 2.5 " Operating Procedures, Standards and Guides", Part I of the license application, states in part that the licensee conducts its business in accordance with a system of Standard Operating Procedures, Company Standards, and Policy Guides.

Section 4.1.1, " Process Analysis (Criticality Safety Determinations),"

Part I of the license application, states in part:

"Before any operation with special nuclear material is begun or changed, it is determined that the entire process will be subtritical under both normal and credible abnormal conditiont.,

and within the technical requirements specified in Section 4.2.

Criticality safety analyses [CSAs] are performad on all applicable processes...."

Section 4.2.1, " Double Contingency Policy," of the license application, states:

" Process and equipment designs and operating procedures incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent errors, accidents,-

equipinent malfunctions, or changes in process conditions before a criticality accident is possible."

Section 4.1, " Purpose and Scope," Chapter 3, " Nuclear Criticality Safety Standards," of the licensee's Safety Manual (EMF-30), states:

"The CSA is a study of equipment / operations involving fissile material at normal conditions and at credible accident conditions to determine if the criticality safety criteria are satisfied."

Section 4.3, " Criticality Safety Criteria" Chapter 3 " Nuclear Criticality Safety Standards," states in paragraph 4.3.2:

9212220058 921204 PDR .ADOCK 07001257 C PDR

4 "No single credible accident condition shall be capable of causing an accidental criticality."

Contrary to the above, as of October 1992, CSA U-1.2, dated August 1973 (for the Line 1 vaporization chests), was not adequate to determine that criticality safety criteria were satisfied, in that the CSA-failed to incorporate all credible accident conditions, thus failing to adequately determine that no single condition was capable of causing an accidental criticality. Specifically, flooding of uranium hexafluoride vaporization chests (unfavorable geometry vessels), with uranium-bearing solutions from process systems that vented to the connecting process off-gas (P0G) system was a credible accident condition that was not analyzed in the CSA. On October 13, 1992, such an event occurred when a process tank containing low enriched (4.0 percent U-235) uranyl fluoride.

overflowed to the P0G system and into an unfavorable geometry vaporization chest, a credible accident.

II. Violation - No Response Reauired License Condition No. 9 of License No. SNM-1227 authorizes the use of licensed materials in accordance with the statements, representations, and conditions contained in Part I of the licensee's application dated July 1987, and supplements dated November 12, 1987, through March 25, 1992.

Section 2.5 " Operating Procedures, Standards ar.d Guides", Part 1 of the-license application, states in part that the licensee conducts its business in accordance with a system of Standard Operating Procedures, Company Standards, and Policy Guides.

Section 11.1.1, Responsibilities," under Section 11.1, " Reporting of Incidents," Chapter 3.0, " Nuclear Criticality Safety Standards," of the licensee's Safety Manual (EMF-30), states in part:

"All Employees: It is the responsibility of each empicyee to immediately report to his or her immediate supervisor any incident or off standard condition related to criticality safety.

Supervision: It is the responsibility of the first line supervisor to document all reported criticality safety related incidents or conditions. The supervisor is also responsible to ensure the reported incident or condition is evaluated and reported to [ Safety, Security and Licensing] as required by this procedure.

Safety. Security and licensina: It is the responsibility of Safety, Security and Licensing to make the final determination of whether or not an incident or condition is reportable to the NRC."

Section 11.1.2, " Evaluation," requires the supervisor to immediately conduct an evaluation to determine if an incident or condition may be reportable to the NRC using the criteria in Section 11.2; if, after completing the evaluation, the responsible supervisor determines that

9 the incident may be reportable to the NRC or is not sure, he or she shall immediately report the incident to Safety, Security and Licensing SS&L). This Section further requires that if an incident or condition is determined to be reportable to the NRC, the report must be made within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of discovery.

Section 11.2, item 5, " Criterion, An unusual event cr condition for which the severity and remedy are not readily determined," provides an example of a reportable event:

"An unexpected accumulation of large amounts of uranium in an unfavorable geometry process system such as ventilation duct work."

EMF-30 Items 6 and 7 of Appendix 5, specify conditions which require

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reporting to SS&L:

" Conditions occur in the process, which are not controlled by the procedere."

"An abnormal situation is discovered where uranium has accumulated in or has been released to unsafe geometry ducts, lines, or tanks."

Contrary to the above, licensee personnel did not immediately report to Safety, Security c.nd Licensing abnormal conditions 1) where there was a condition not controlled by procedure, and 2) where uranium had accumulated in an unsafe geometry ve',sel. Specifically at about 2:30 -

2:45 am on October 13, 1992, a shift supervisor (SS) on the night shift learned of a process upset involving an overflow of a significant amount of low enriched uranium liquid solution (uranyl fluoride - UO 2F ) from a process vessel via an exhaust vent system to a room at a lower bevel of the facility, a condition not controlled by procedure, but did not report the event to SS&L. Further, the General Supervisor and the Manager of Plant Operations were informed of the incident at 6:10 am and 7:00 am, respectively, but they also failed to report the incident.

Subsequently, between 8:00 - 8:30 am on October 13, 1992, the day SS learned that an unknown amount of UOjF 2 solution was observed in an unfavorable geometry vessel (vaporization chest), but SS&L was not informed of these conditions until 12:15 pm on October 13, 1992.

1 This is a Severity-Level IV violation (Supplement _VI}.

Pursuant to the provisions of 10 CFR 2.201, Siemens Power Corporation is hereby. required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission, ATTN: Document _ Control Desk, Washin;; ton, D.C.

20555, with a copy to the Regional Administrator, Region V, within 30 days of the date of the 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 corrective steps that have been taken and the results achieved, (3) the corrective steps that 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 time specified in this Notice, the s .

4 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 responso time.

Dated at Walnut Creek, California this N day of Deuer1992 ki 4

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