ML20148F812
| ML20148F812 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 05/30/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20148F792 | List: |
| References | |
| 70-7001-97-02, 70-7001-97-2, NUDOCS 9706050051 | |
| Download: ML20148F812 (5) | |
Text
7 NOTICE OF VIOLATION United States Enrichment Corporation Docket No. 70-7001 Paducah Gaseous Diffusion Plant Certificate No. GDP-1 During an NRC inspection conducted from March 3 to April 21,1997, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
1.
Technical Safety Requirement 3.2.2.a. requires, in part, that: Minimum staffing requirements for each facility are as shown in Technical Safety Requirement Table 3.2.2-1.
Technical Safety Requirement Table 3.2.2-1 defines the minimum staffing requirements for Building C-360 during Mode 7 (sampling) operations as: "At least one person in the laboratory. One person in the facility or immediately surrounding grounds to include the guard station and the cylinder yard."
Procedure, OPS-11, Rev. 2, Change D, dated March 3,1997, " Shift Turnover,"
step 6.2, requires, in part, that: "The shift operating personnel shall not leave their work area until they are satisfied that their relief is fully aware of existing conditions."
Procedure, OPS 8, Rev. O, Change G, dated March 3,1997, " Shift Routines and Operating Practices," step 5.4.1, requires, in part, that operators: " Exhibit professional conduct and good watch standing practices to assure proper attention to plant conditions."
Procedure CP2-TR-TR1030, Rev.1, Change A, dated February 28,1997, " Required Reading," steps 6.4 and 6.7, require, in part, that: personnel review, initial, and date the immediate Required Reading file prior to performing tasks and/or duties to which the material applies by reading the material within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of assignment.
Contrary to the above, on April 14,1997, between 6:30 a.m. and 7:00 a.m., only one operator was in the Building 360 Laboratory, facility, or immediately surrounding grounds while the facility operated in Mode 7. Specifically, one of the i
two required Building 360 operators: (1) left the assigned work area without being relieved: (2) returned to the assigned work area attired in personal clothing which
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precluded normal access and proper attention to plant conditions controlled from or l
displayed in portions of the routine work area; and, (3) assumed watch standing I
responsibilities without reviewing, initialing, or dating immediate required reading files, which included materials issued since March 3,1997, that applied to the normal tasks and duties of the Building 360 operator.
This is a Severity Level IV violation (Supplement VI).
9706050051 970530 PDR ADOCK 07007001 C
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i Notice of Violation 2.
Technical Safety Requirement 3.2.2.b. requires, in part, that: administrative procedures be implemented to limit the working hours of facility staff who perform safety functions such that an individual should not be permitted to work more than 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> in any 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period.
Procedure CP2-HR-LR1030, " LIMITATIONS ON HOURS OF WORK," step 6.3.4, requires, in part, that: "a person shall not be permitted to work more than 16 consecutive hours, excluding shift turnover time, without preauthorized approval from the general manager or designee."
Contrary to the above, on March 5,1997, two instrument mechanics performing safety functions (work on criticality accident alarm cluster V"in Building C-337 and the associated required documentation) worked more than 16 consecutive j
hours, excluding shift turnover time, without preauthorized approval from the general manager or designee.
This is a Severity Level IV violation (Supplement VI).
3.
Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be implemented to cover the activities described in Safety Analysis Report, Section 6.11.4.1 and listed in Safety Analysis Report, Section 6.11, Appendix A.
Safety Analysis Report, Section 6.11, Appendix A lists Operations activities (including alarm response) as activities requiring written procedures.
Alarm Response Procedure CP4-CO-AR8360-7, "HIGH LEVEL DRAIN D101,"
Rev. O, dated July 31,1995, step 9 requires, in part, that following actuation of the water inventory control system (drain level probes), operators mav return the autoclave to service: When...cause of alarm has been determined and corrected."
Contrary to the above, on April 9,1997, Building 360 operators returned autoclave number 1 to service, following actuations of the water inventory control system, without determining or correcting the cause of the alarm.
This is a Severity Level IV violation (Supplement VI).
4.
Technical Safety Requirement 2.2.4.3.a and Technical Safety Requirement 2.4.4.2.a require that criticality accident detection shall be operable in areas, equipment, or processes which contain greater than 700 grams of uranium-235 at an enrichment greater than or equal to 1.0 weight percent uranium-235.
Contrary to the above, on March 4,1997, Building 337, criticality accident detection cluster "V" and, on March 18,1997, Building 337A criticality accident detection cluster "N" were inoperable for areas which contained greater than 700 grams of uranium-235 at an enrichment greater than or equal to 1.0 weight percent uranium-235.
r Notice of Violation This is a Severity Level IV violation (Supplement VI).
5.
Technical Safety Requirement 3.11.1 requires, in part, that a Criticality Safety Program be implemented as described in the Safety Analysis Report.
Safety Analysis Report, Section 5.2.2.6 states, in part, that: Operations to which NCS [ nuclear criticality safety] pertains shall be governed by written procedures.
These procedures contain the appropriate NCS controls for processing, storing, and handling of fissile material."
Procedure, CP2-TS TS2030, Rev. O, dated December 10,1996, " HANDLING AND STORAGE OF LEGACY PROCESS EQUIPMENT," is a procedure for handling fissile material which implements the controls for the Criticality Safety Program for handling legacy equipment with unknown amounts of potentially fissile material.
Procedure CP2-TS-TS2030, step 8.2.1, requires, in part, that personnel: " mark / rope off equipment and tag with a Legacy Process Equipment Tag."
Contrary to the above, from March 3 through April 15,1997, legacy process equipment on the cell floor in Building 335 (compressors and a G-17 valve), was tagged with a Legacy Process Equipment Tag, identifying the equipment as containing unknown amounts of potentially fissile material, but had not been marked or roped off.
This is a Severity Level IV violation (Supplement VI).
6.
10 CFR 76.120(c)(2) requires the+ ne certificatee notify the NRC Operations Center within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovary of an event in which equipment is disabled or fails to function as designed when: (I) the equipment is required by a Technical Safety Requirement to mitigate the consequences of an accident; (2) the equipment is required by a Technical Safety Requirement to be available and operable and either should have been operating or should have operated on demand; and (3) no redundant equipment is available and operable to perform the required safety function.
Technical Safety Requirement 2.4.4.5 requires that the fire protection sprinkler systems in process Buildings C-331, C-333, C-335, and C-337 be operable in modes Cascade 1 through Cascade 3, except when the lube oil is valved off or removed from the cells covered by a specific sprinkler system.
Contrary to the above, as of 9:30 a.m., on March 13,1997, the certificatee had not notified the NRC Operations center 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery, on March 12 at 9:30 a.m., of a disabled sprinkler system required to be operable by Technical Safety Requirement 2.4.4.5. Specifically, numerous cells within Building C-331 l
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Notice of Violation were operating in modes Cascade 1 through Cascade 3, and no redundant equipment providing an equivalent fire-mitigating safety function was available, when sprinkler system 33, between columns V-33 and W-33 of Building C-331, was declared inoperable. The certificatee notified the NRC Operations Center on March 27,1997.
This is a Severity Level IV violation (Supplement VI).
7.
10 CFR 95.35(a) requires, in part, that no person subject to the regulations in this part may receive or may permit any individual to have access to matter revealing Confidential Restricted Data unless the individual has a "Q" or "L" access authorization.
Contrary to the above, from March 3 through April 15,1997, the certificatee, a person subject to the regulations in Part 95, permitted individuals who did not have "O" or "L" access authorizations to have access to drawings revealing Confidential Restricted Data.
This is a Severity Level IV violation (Supplement VI).
8.
10 CFR 76.60(g) requires that the certificatee comply with the applicable provisions of 10 CFR Part 71.
10 CFR 71.5(a) requires, in part, that the certificatee shall comply with Dopartment of Transportation requirements in 49 CFR 170 through 189 for shipments of licensed material outside of the plant boundaries.
10 CFR 71.12 states that a general license is issued to any licensee to transport, or deliver to a carrier for transport, licensed material in a package for which a license, certificate of compliance, or other approval is issued by the NRC.10 CFR 71.12 requires that the licensee comply with the terms and conditions of the certificate.
49 CFR 173.420(a)(2)(1) requires, in part, uranium hexafluoride must be e 'ared for transportation in packages (cylinders) marked in accordarice with American National Standards Institute Standard N14.1.
Condition 6 of Certificate of Compliance No. 6553, Revision 10, for the Paducah tiger overpack, required that each 48X cylinder be inspected, tested, maintained, assembled, and used in accordance with American National Standards Institute Standard N14.1-1990.
American National Standards Institute Standard N14.1-1990, Sections 6, requires, in part, that cylinder valve and plug threads are tinned with a thin uniform coating of ASTM B32 alloy 50A solder. Section 6 also requires that cylinder name plates are stamped with the cylinder tare weight in pounds.
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r Contrary to the above, from March 3 through April 21,1997, the certificatee delivered cylinders to carriers for transport, outside the plant boundaries, that were p
not assembled and maintained in accordance with American National Standards Institute Standard N14.1. Specifically, cylinder valve and plug threads were not 4
' tinned with ASTM B32 alloy 50A solder and revised tare weights, determined i
during'5-year hydrostatic tests, ware not stamped on the cylinder name plates.
i This is a Severity Level IV violation (Supplement V).
i Pursuant to the provisions of 10 CFR 2.201, United State Enrichment Corporation is l
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 l'
copy to the Regional Administrator, Region Ill, and a copy to the NRC Resident inspector
. at Paducah, 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-i should include for'cach violation: (1) the reason for the violation, or, if contested, the l
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. Your response may reference or include previously docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in this j.
Notice, an order or a' Demand for Information may be issued as to why the Certificate
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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, i
Because your response will be placed in the NRC Public Document Room (PDR), to the extent possible, it should not include any personal privacy, proprietary, or safeguards
. information so that it can be placed in the POR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please
- provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you mail specifically identify the portions of your.
response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the I
level of protection described in 10 CFR 73.21.
Dated at Lisle, Illinois this 30tday of May 1997 l
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