Notice of Violation from Insp on 970422-0602.Violation Noted:Certificatee Did Not Immediately Begin to Monitor Temp & Pressure Hourly for Bldg C-310 Cascade Cells Containing UF6,enriched to 1.0 Wt Percent or GreaterML20148R772 |
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07007001 |
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07/02/1997 |
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NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
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Shared Package |
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ML20148R747 |
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70-7001-97-03, 70-7001-97-3, NUDOCS 9707080018 |
Download: ML20148R772 (4) |
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Category:NOTICE OF VIOLATION OF A REGULATION
MONTHYEARML20212K9161999-10-0404 October 1999 Notice of Violation from Insp on 990720-0907.Violation Noted:Between 990720 & 0907,plant Staff Granted Personnel Unescorted Access to Controlled Access Area That Had Not Received General Employee or site-specific Training ML20210P7521999-08-10010 August 1999 Notice of Violation from Insp on 990529-0719.Violation Noted:Between 990510 & 0601,plant Staff Did Not Promptly Notify Plant Shift Superintendent of Identified Problems & Conditions Associated with Process Bldg Fire Protection Sys ML20196K5851999-05-10010 May 1999 Notice of Violation from Insp on 990413-0528.Violation Noted:Corporation Did Not Report to NRC Operations Ctr, within 24 Hours After Discovery of Event in Which Process Gas Leak Detection Sys Failed to Function as Designed ML20207G2711999-03-0505 March 1999 Notice of Violation from Insp on 981201-990112.Violation Noted:Certificatee Permitted Individuals to Have Access to Document Revealing Confidential Restricted Data Without Having Q or L Access Authorization ML20198K9661998-12-28028 December 1998 Notice of Violation from Insp on 981015-1130.Violation Noted:Discharge Bellows Pressure for Number 1 Normetex Withdrawal Pump in Bldg C-315 Exceeded 45 Psia as Pump Transitioned from Mode 2 to Mode 3 ML20196C2311998-11-24024 November 1998 Notice of Violation from Insp on 980721-0901.Violation Noted:Discharge Bellows Pressure for 2 Normetex Withdrawal Pump in Bldg C-315 Exceeded 45 Psia as Pump Transitioned from Mode 2 Withdrawal to Mode 3 Standby ML20154P5141998-10-16016 October 1998 Notice of Violations from Insp on 980721-0901.Violations Noted:Corporation Failed to Incorporate ASME NQA-1-1989 Supplemental Requirements Associated with Design Control & Measuring & Test Equipment Into QAP ML20236Y1101998-08-0505 August 1998 Notice of Violation from Insp on 980609-0720.Violation Noted:As of 980627,Corporation Failed to Identify,Review & Translate Design Requirements,Associated W/Installation of Bldg C-710 Criticality Accident Alarm Sys ML20236F8221998-06-30030 June 1998 Notice of Violation from Insp on 980420-0608.Violation Noted:Between 980414 & 0513,Corporation Failed to Implement, as Soon as Practical,Interim Nuclear Criticality Safety Spacing Controls for Bldg C-333 Wet Air Pump Piping Elbows ML20249B0671998-06-15015 June 1998 Notice of Violation from Insp on 980518-22.Violation Noted: Design Analysis & Calculations Rept DAC-815-19938-0001,dtd 980120 Documented Existing Rail Stops on Levelator Would Not Prevent Rolling Scale Cart & Carried Cylinder Off End ML20216B6591998-04-0606 April 1998 Notice of Violation from Insp on 980120-0309.Violation Noted:Plant Shift Superintendent Did Not Implement Requirements of Procedure UE2-TO NS1032 for Inoperable UF6 Detection Sys in Building C-333A W/Autoclaves ML20217C0841998-03-24024 March 1998 Notice of Violation from NRC Review of Pgdp Certificate Amend Request - Update to Application SAR Dtd 970818. Violation Noted:On 970817,USEC Did Not Submit Amend to Certification Application Which Includes Listed Info ML20217C1021998-03-24024 March 1998 Notice of Violation Re NRC Review of Ports Certificate Amend Request - Update to Application SAR .Violation Noted:On 970817 Usec Did Not Submit Amend to Certification Application Which Includes Listed Info ML20197A7721998-02-27027 February 1998 Notice of Violation from Insp on 980209-13.Violation Noted: as of 980213,three Operating procedures,CP4-CU-CH2103,Rev 1, CP4-CU-CH2105,Rev 0 & CP4-CU-CH2106,Rev 0,did Not Contain Nuclear Criticality Controls Re Vacuum Cleaner Spacing ML20202G2991998-02-12012 February 1998 Notice of Violation from Insp on 971125-980120.Violations Noted:Certificatee Conducted Operations Involving Unsafe Volume Drums for Storing Seal Parts,Contaminated W/U Enriched to Greater than 1.0 Weight Percent in U-235 ML20203E4901997-12-0909 December 1997 Notice of Violation from Insp on 971008-1124.Violation Noted:Investigation & Reporting Activities Were Not Performed in Accordance W/Written Procedures ML20203D4971997-12-0808 December 1997 Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000.Violation Noted:Certificatee Permitted Individuals to Have Access to Matter Revealing Confidential Restricted Data W/O Having Authorization ML20202E8461997-11-28028 November 1997 Notice of Violation from Insp on 970915-19 & 1103-07. Violations Noted:Ncs Section Was Not Notified or Consulted & Did Not Provide Required Evaluation & Guidance or Issue Audit/Incident Rept within 24 Hours ML20199K3021997-11-26026 November 1997 Notice of Violation from Insp on 971006-10.Violation Noted: Maintenance & Work Control Activities Not Performed in Accordance W/Documented Procedures Appropriate to Circumstances in Examples ML20199H6451997-11-20020 November 1997 Notice of Violation from Insp on 970826-1007.Violations Noted:Certificatee Failed to Implement & Maintain Written Procedures for Operations,Including Sys Procedures Addressing Startup,Shutdown,Normal Operations ML20211Q7971997-10-17017 October 1997 Notice of Violation from Insp on 970908-12.Violations Noted:Certificatee Failed to Store Quality Assurance Records (Drawings) in Vault W/Min of 6 Inches of Clearance to Bottom of First Shelf Drawer from 970303-0910 ML20211C7281997-09-24024 September 1997 Notice of Violation from Insp on 970715-0912.Violations Noted:From 970303-0825,U Hexafluoride Cylinder Tare Weight Listings Used in Bldg C-310 Were Not Maintain in DCS to Ensure Current & Correct Info Available in Bldg C-310 Room ML20211H3341997-09-22022 September 1997 Notice of Violation from Insp on 970505-09.Violation Noted: on 960531,US Enrichment Corp Failed to Provide Commission Complete & Accurate Info in Matl Aspects Re Security Plan for Protection of Classified Matter ML20198F7081997-08-0505 August 1997 Notice of Violation from Insp on 970603-0714.Violation Noted:Bldg Operators,Individuals Relied Upon to Operate Plant in Safe Manner,Had Not Been Trained on Design & Normal off-normal Operation of Recently Installed Production Oven ML20148R7721997-07-0202 July 1997 Notice of Violation from Insp on 970422-0602.Violation Noted:Certificatee Did Not Immediately Begin to Monitor Temp & Pressure Hourly for Bldg C-310 Cascade Cells Containing UF6,enriched to 1.0 Wt Percent or Greater ML20148F8121997-05-30030 May 1997 Notice of Violation from Insp on 970303-0421.Violation Noted:Bldg 360 Operators Returned Autoclave Number 1 to Svc, Following Actuations of Water Inventory Control Sys,W/O Determining or Correcting Cause of Alarm ML20141F4161997-05-16016 May 1997 Notice of Violation from Insp on 970317-21 & 0331-0404. Violations Noted:Used NAM & Fixed HEPA Filters Containing U Enriched to 1 Wt% or Higher of U-235 & 15 Grams or More of U-235 Stored in 3X4 Array,Not Documented in NCS Evaluation ML20138C4721997-04-25025 April 1997 Notice of Violation from Insp on 970324-27.Violation Noted: Section of Missing Pipe in Fire Protection Sprinkler Sys of Process Bldg C-331 Which Rendered Portion of Sys Inoperable 1999-08-10
[Table view] Category:TEXT-INSPECTION & AUDIT & I&E CIRCULARS
MONTHYEARML20217B3271999-10-0606 October 1999 Insp Rept 70-7001/99-203 on 990921-23.No Violations Noted. Major Areas Inspected:Paducah Gaseous Diffusion Plant Y2K Program,Including Mgt Planning,Implementation,Qa,Regulatory Considerations & Documentation,Per GL 98-03 ML20212K9301999-10-0404 October 1999 Insp Rept 70-7001/99-10 on 990720-0907.Violations Noted. Major Areas Inspected:Plant Operations,Maint,Engineering & Plant Support ML20212K9161999-10-0404 October 1999 Notice of Violation from Insp on 990720-0907.Violation Noted:Between 990720 & 0907,plant Staff Granted Personnel Unescorted Access to Controlled Access Area That Had Not Received General Employee or site-specific Training ML20212F1181999-09-22022 September 1999 Insp Rept 70-7001/99-12 on 990830-0902.No Violations Noted. Major Areas Inspected:Security Insp Including Physical, Storage & Control of Classified Matter,Classification, Communications Security & Computer Security ML20212B6681999-09-15015 September 1999 Insp Rept 70-7001/99-202 on 990816-20.No Violations Noted. Major Areas Inspected:Engineered Fire Protection Sys, Implementation of Administrative Fire Prevention Controls & Manual Fire Suppression Response Capabilities ML20211L8981999-09-0202 September 1999 Insp Rept 70-7001/99-11 on 990802-06.No Violations Noted. Major Areas Inspected:Selective Exam of Procedures & Representative Records,Interviews with Personnel & Observations of Activities in Progress ML20210P7521999-08-10010 August 1999 Notice of Violation from Insp on 990529-0719.Violation Noted:Between 990510 & 0601,plant Staff Did Not Promptly Notify Plant Shift Superintendent of Identified Problems & Conditions Associated with Process Bldg Fire Protection Sys ML20210P7671999-08-10010 August 1999 Insp Rept 70-7001/99-08 on 990529-0719.Violations Noted. Major Areas Inspected:Plant Operations,Engineering & Plant Support ML20209F0741999-07-0909 July 1999 Insp Rept 70-7001/99-09 on 990621-25.No Violations Noted. Major Areas Inspected:Insp Noted That Operators Response to Small UF6 Release in Building C-337A Was Effective & Consistent with Guidance Provided in Alarm Response ML20196K1051999-07-0101 July 1999 Insp Rept 70-7001/99-07 on 990413-0528.Violations Noted. Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering & Plant Support ML20196K5851999-05-10010 May 1999 Notice of Violation from Insp on 990413-0528.Violation Noted:Corporation Did Not Report to NRC Operations Ctr, within 24 Hours After Discovery of Event in Which Process Gas Leak Detection Sys Failed to Function as Designed ML20206E6591999-04-29029 April 1999 Insp Rept 70-7001/99-04 on 990224-0412.No Violations Noted. Major Areas Inspected:Plant Staff Took Appropriate Actions to Trip Process Motors for Cell Involved with Motor Fire Due to Failed motor-to speed-increaser Coupling ML20205R8141999-04-20020 April 1999 Partially Withheld Insp Rept 70-7001/99-201 on 990322-26. Details Withheld ML20205J3091999-04-0202 April 1999 Insp Rept 70-7001/99-05 on 990322-25.No Violations Noted. Major Areas Inspected:Compliance with Certificate Holder Approved Physical Security Plan for Protection of Special Nuclear Matl of Low Strategic Significance ML20207K3091999-03-11011 March 1999 Insp Rept 70-7001/99-01 on 990113-0223.No Violations Noted. Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering & Plant Support ML20207G2711999-03-0505 March 1999 Notice of Violation from Insp on 981201-990112.Violation Noted:Certificatee Permitted Individuals to Have Access to Document Revealing Confidential Restricted Data Without Having Q or L Access Authorization ML20203G4231999-02-0909 February 1999 Insp Rept 70-7001/99-02 on 990125-29.No Violations Noted. Major Areas Inspected:Plant Support ML20198K9661998-12-28028 December 1998 Notice of Violation from Insp on 981015-1130.Violation Noted:Discharge Bellows Pressure for Number 1 Normetex Withdrawal Pump in Bldg C-315 Exceeded 45 Psia as Pump Transitioned from Mode 2 to Mode 3 ML20198H8891998-12-21021 December 1998 Insp Rept 70-7001/98-17 on 981015-1130.Violations Noted. Major Areas Inspected:Plant Operations,Maint & Surveillance, Engineering & Plant Support ML20196C2311998-11-24024 November 1998 Notice of Violation from Insp on 980721-0901.Violation Noted:Discharge Bellows Pressure for 2 Normetex Withdrawal Pump in Bldg C-315 Exceeded 45 Psia as Pump Transitioned from Mode 2 Withdrawal to Mode 3 Standby ML20203B7561998-11-17017 November 1998 EN-98-066:informs Commission That Staff Intends to Exercise Enforcement Discretion by Refraining from Issuance of Proposed Civil Penalty to Us Enrichment Corp for Violation Involving Failure to Limit Discharge Below Pressure ML20154R1421998-10-22022 October 1998 Partially Withheld Insp Rept 70-7001/98-206 on 980928-1002. Details Withheld,Per 10CFR2.790 ML20155A4341998-10-22022 October 1998 Insp Rept 70-7001/98-205 on 980915-18.No Violations Noted. Major Areas Inspected:Paducah Gaseous Diffusion Plant High Risk Chemical Release Possibilities That May Occur as Result of Seismic Initiating Event ML20154R8351998-10-21021 October 1998 Insp Rept 70-7001/98-16 on 980902-1014.No Violations Noted. Major Areas Inspected:Operations,Maint,Engineering & Plant Support ML20154P5181998-10-16016 October 1998 Insp Rept 70-7001/98-13 on 980721-0901.Violations Noted. Major Areas Inspected:Plant Operations,Main Surveillance, Engineering & Plant Support ML20154P5141998-10-16016 October 1998 Notice of Violations from Insp on 980721-0901.Violations Noted:Corporation Failed to Incorporate ASME NQA-1-1989 Supplemental Requirements Associated with Design Control & Measuring & Test Equipment Into QAP ML20195D4511998-10-16016 October 1998 EN-98-060B:staff Advised Commission of Intent to Exercise Enforcement Discretion Per Section VII.B.6 of Enforcement Policy & Not Issue Nov.Decision Is Based On,Among Other Reasons,Certificate Holder Corrective Action ML20154J7571998-10-0909 October 1998 Insp Rept 70-7001/98-15 on 980908-11.No Violations Noted. Major Areas Inspected:Maint & Surveillance & Plant Support ML20195D2531998-09-23023 September 1998 EN-98-060A:staff Advised Commission of Intent to Exercise Enforcement Discretion Per Section VII.B.6 of Enforcement Policy & Not Issue Nov.Staff Decided to Defer Issuing Action Until Action Verified ML20153B3451998-09-16016 September 1998 Insp Rept 70-7001/98-204 on 980831-0903.No Violations Noted. Major Areas Inspected:Ncs Related Open Items,Corrective Actions & Corrective Action Tracking,Criticality Safety & Plant Operations ML20195C6631998-09-11011 September 1998 EN-98-060:informing That on 980918 NRC Intends to Exercise Enforcement Discretion Per Section VII.B.6 of Enforcement Policy & Not Issue NOV or Propose CP for Severity Level III Problem Re Nonconservative Assumption in SAR ML20237E6031998-08-27027 August 1998 Insp Rept 70-7001/98-14 on 980803-07.No Violations Noted. Major Areas Inspected:Plant Operations,Maint & Engineering ML20236Y1151998-08-0505 August 1998 Insp Rept 70-7001/98-11 on 980609-0720.Violations Noted. Major Areas Inspected:Operations,Maintenance,Engineering & Plant Support ML20236Y1101998-08-0505 August 1998 Notice of Violation from Insp on 980609-0720.Violation Noted:As of 980627,Corporation Failed to Identify,Review & Translate Design Requirements,Associated W/Installation of Bldg C-710 Criticality Accident Alarm Sys ML20236R2261998-07-14014 July 1998 Insp Rept 70-7001/98-12 on 980622-26.No Violations Noted. Major Areas Inspected:Operation,Maint & Surveillance & Plant Support ML20236F8241998-06-30030 June 1998 Insp Rept 70-7001/98-09 on 980420-0608.Violations Noted. Major Areas Inspected:Plant Operations,Maintenance & Surveillance,Engineering & Plant Support ML20236F8221998-06-30030 June 1998 Notice of Violation from Insp on 980420-0608.Violation Noted:Between 980414 & 0513,Corporation Failed to Implement, as Soon as Practical,Interim Nuclear Criticality Safety Spacing Controls for Bldg C-333 Wet Air Pump Piping Elbows ML20249B0671998-06-15015 June 1998 Notice of Violation from Insp on 980518-22.Violation Noted: Design Analysis & Calculations Rept DAC-815-19938-0001,dtd 980120 Documented Existing Rail Stops on Levelator Would Not Prevent Rolling Scale Cart & Carried Cylinder Off End ML20249B0681998-06-15015 June 1998 Insp Rept 70-7001/98-10 on 980518-22.Violation Noted. Major Areas Inspected:Maint & Plant Support ML20216B9231998-05-0707 May 1998 Insp Rept 70-7001/98-06 on 980310-0420.Violation Noted.Major Areas Inspected:Operations,Maint & Surveillance,Engineering & Plant Support PNO-III-98-029, on 980428,empty UF6 Cylinder Arrived from Starmet of Sc with Radioactive Contamination on Surface of Cylinder.Certificatee Decontaminated Cylinder1998-04-30030 April 1998 PNO-III-98-029:on 980428,empty UF6 Cylinder Arrived from Starmet of Sc with Radioactive Contamination on Surface of Cylinder.Certificatee Decontaminated Cylinder ML20217L8551998-04-28028 April 1998 Insp Rept 70-7001/98-203 on 980330-0403.No Violations Noted. Major Areas Inspected:Chemical Process Safety Insp of Paducah Gaseous Diffusion Plant,In Paducah,Ky on 980330-0403 ML20217D9071998-04-22022 April 1998 Insp Rept 70-7001/98-08 on 980331-0402.No Violations Noted. Major Areas Inspected:Evaluation of Certificatee Performance During Plant Biennial Exercise of Emergency Plan ML20216B0491998-04-0808 April 1998 Insp Rept 70-7001/98-07 on 980316-20.No Violations Noted. Major Areas Inspected:Operations & Training ML20216B6591998-04-0606 April 1998 Notice of Violation from Insp on 980120-0309.Violation Noted:Plant Shift Superintendent Did Not Implement Requirements of Procedure UE2-TO NS1032 for Inoperable UF6 Detection Sys in Building C-333A W/Autoclaves ML20216B6671998-04-0606 April 1998 Insp Rept 70-7001/98-03 on 980120-0309.Violations Noted. Major Areas Inspected:Plant Operations,Maint,Surveillance & Engineering ML20217G7901998-03-27027 March 1998 Insp Rept 70-7001/98-04 on 980223-27.No Violations Noted. Major Areas Inspected:Provided follow-up on 970505-09 Security Insp Findings at Paducah Plant That Resulted in Escalated Enforcement & Review of Physical Security Plan ML20217G7331998-03-27027 March 1998 Insp Rept 70-7001/97-10 on 970919-980216.No Violations Noted.Major Areas Inspected:Operational Controls,Maint Programs,Engineering Design,Event Root Cause Evaluation & Classification & Reporting of Event ML20217F2261998-03-26026 March 1998 Partially Withheld Insp Rept 70-7001/98-202 (Ref 10CFR2.790) on 980302-06.No Violations Noted.Details Withheld ML20217C0841998-03-24024 March 1998 Notice of Violation from NRC Review of Pgdp Certificate Amend Request - Update to Application SAR Dtd 970818. Violation Noted:On 970817,USEC Did Not Submit Amend to Certification Application Which Includes Listed Info 1999-09-22
[Table view] |
Text
. . - . - .
l NOTICE OF VIOLATION i
United States Enrichment Corporation Docket No. 70-7001 ;
Paducah Gaseous Diffusion Plant Certificate No. GDP-1 !
During an NRC inspection conducted from April 22 to June 2,1997, violations of NRC ,
requirements were identified. In accordance with the " General Statement of Policy and j Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
- 1. Technical Safety Requirement 2.4.4.2b, Action Statement A.1.2 requires, in part, that in areas without an audible criticality accident alarm and where the maximum foreseeable absorbed dose in free air exceeds 12 rad, the certificatee shall immediately [begin tol monitor temperatures and pressures hourly in cascade cells containing uranium hexafluoride, enriched to 1.0 weight percent or greater. l Safety Analysis Report, Chapter 4, Appendix A, Table 2.51, " Criticality Clusters and Building Alarms," specifies,in part, that criticality accident alarm system local clusters G and H and building horns provide the criticality detection and accident alarms for Building C-310.
Yechnical Safety Requirement 1.2.8 defines "immediately" as: " required action shall be pursued without delay and in a controlled manner."
Contrary to the above, on May 8,1997, the certificatee did not immediately begin to monitor temperatures and pressures hourly for Building C-310 cascade cells containing uranium hexafluoride, enriched to 1.0 weight percent or greater, when the area did not have an audible criticality accident alarm because clusters G and H had been removed from service. Specifically, Building C-310 cluster G was declared inoperable at 9:00 a.m., and cluster H was declared inoperable at i' 10:20 a.m., and the initial rounds to monitor temperatures and pressures in the cells were not initiated until 12:00 noon, a period of time exceeding Technical Safety Requirement 2.4.4.2b, Action Statement A.1.2 surveillance requirement. l This is a Severity Level IV violation (Supplement VI).
- 2. Technical Safety Requirement 2.3.4.7, Action Statements A.2.1, A.2.2, and A.3, and Technical Safety Requirement 2.4.4.2, Action Staternents A.2.1, A.2.2, and A.3 require for areas not covered by criticality accident detection, that: 1) the area be evacuated immediately; 2) access to the evacuated area be restricted; and
- 3) personnel, allowed into the restricted area, be provided with an alternate means of criticality alarm notification, such as a device that will alarm on sensing a 10 millirem per hour dose rate.
9707000018 PDR 970702 C ADOCK 07007001 pg
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, . - --, .- . .- - . .- - - .- - - . . -~ - -
i 7 ;
1 .
l Notice of Violation : -
, l Procedure CP2-CO-CA1030, Revision 0, " OPERATION OF THE CRITICALITY. l 2 ACCIDENT ALARM SYSTEM (CAAS)," dated March 3,1997, step 6.2.38 states . .i that upon loss of CAAS coverage: " Access control consists of posting signs, traffic .i
- _ cones, or other type barriers around the perimeter of the affected area that informs i personnel of the LCO [ Limiting Condition of Operation) boundary and that access is 1
not allowed unless authorized by the PSS/MIC Iplant shift superintendent or manager in charge] and proper dosimetry (for detection and audibility) or a radio (for i audibility.only) is worn."
1.
- l. Contrary to the above, on April 28, May 8, and May 14,1997, seven perscnnel, on
- six separate occasions, entered evacuated, restricted, and posted areas, around j Buildings C-310 and C-337, which were not covered by criticality accident L detection: 1) without authorization by the plant shift superintendent or manager in
- j. charge; and 2) without proper dosimetry or a radio.
This is a Severity Level IV violation (Supplement VI).
- . 3. Technical Safety Requirements 2.3.4.7b and 2.4.4.2b require that the criticality .
' accident alarm shall be operable (audible) in areas where the maximum foreseeable -
- absorbed dose in free air exceeds 12 rad. )
l l Safety Analysis Report, Chapter 4, Appendix A, Table 2.5-1, " Criticality Clusters and Building Alarms," specifies, in part, that criticality accident alarm system local clusters G and H and building horns provide the criticality accident alarms for -
Building C-310. ;
[
)! Contrary to the above, on May 18,1997, between 6:25 and'7:50 p.m., the j Building C-310 criticality accident alarm system building horns were not operable in the areas where the maximum foreseeable dose in free air exceeds 12 rad.
1
- This is a Severity Level IV violation (Supplement VI). ;
- 4. Technical Safety Requirement 2.2.4.12,." Scales," requires that the scales (scale ~
identification numbers 19 and 21) used for verification of cylinder weight per Technical Safety Requirement 2.2.4.4., " Cylinder Heating - Cylinder Accountability
- Weight," shall be operable. t I Technical Safety Requirement 2.2.4.4, " Cylinder Heating - Cylinder Accountability j Weight," Surveillance Requirement 2.2.4.4-1 requires'that the cylinder accountability weight is verified prior to first entry into Mode 5 [ heating) of each operating cycle lin Buildings 333A and 337A).
l Contrary to the above, from March 3 through May 21,1997, the certificatee did
- not verify the cylinder accountability weight, using scales 19 and 21, prior to first
- j. entry into Mode 5 of each operating cycle initiated in Buildings 333A and 337A.
This is a Severity Level IV violation (Supplement VI).
1
)
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1 1
l Notice of Vio!ation l l
- 5. 10 CFR 76.93, " Quality Assurance," requires, in part, that the certificatee shall establish and execute a quality assurance program.
The Quality Assurance Program, Section 2.5, states, in part, that: 1) "O" activities l affecting safety or quality are prescribed and performed in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances; and 2) these documents include or reference appropriate quantitative or qualitative acceptance criteria for determining that prescribed activities are satisfactorily performed.
Safety Analysis Report, Section 3.15, "O AND AO STRUCTURES, SYSTEMS, AND COMPONENTS," specifies the criticality accident alarm system as a "O" system, including building / slave lights and horns for Buildings C-333, C-333A, C-337, and C-337 A.
Procedure CP4-GP-lM6209, " CRITICALITY ACCIDENT ALARM SYSTEM FUNCTIONAL TESTS," Revisions 1 and 2, stated purpose was to: " provide instructions to functionally check the criticality accident alarm system (CAAS)."
Contrary to the above, from March 3 through April 23,1997, the certificatee performed post maintenance functional tests of the criticality accident alarm systems for Buildings C-333, C-333A, C 337, and C-337A ushg a procedure which did not include appropriate acceptance criteria for determining that the prescribed activities were satisfactorily performed. Specifically, Procedure CP4-GP lM6209 did not include acceptance criteria to ensure that all of the slave horns associated with Buildings C-333, C-333A, C-337, and C-337A criticality accident alarm system clusters sounded upon an actuation signal.
This is a Severity Level IV violation (Supplement VI).
- 6. 10 CFR 76.93, " Quality Assurance," requires, in part, that the certificatee shall establish and execute a quality assurance program.
The Quality Assurance Program, Section 2.16, " Corrective Action," requires, in part, that for significant conditions adverse to quality, the cause of the condition is determined and corrective action is taken to preclude recurrence.
Procedure UE2-HR-C11031, Revision 0, dated August 31,1996, " CORRECTIVE i ACTIONS," defined, in part, that a significant condition adverse to quality included: l
- 1) unauthorized changes to attributes of a procedure that implernents nuclear ]
criticality safety requirements; and 2) problem trends that have a strong potential to i lead to issues of significance.
I I
i
Notice of Violation Contrary to the above, from March 3 through May 6,1997, the certificatee did not determine the cause for or take corrective action to preclude recurrence of a significant condition adverse to quality. Specifically, the certificateo did not:
- 1) identify that a March 3,1997, internal memorandum made an unauthorized change to a procedure which implemented nuclear criticality safety approval, GEN 27; and 2) determine the root cause for and take corrective actions to preclude the recurrence of violations of nuclear criticality safety approval GEN-27 in Building C-720.
This is a Severity Level IV violation (Supplement VI).
Pursuant to the provisions of 10 CFR 2.201, United State Enrichment Corporation is hereby required to submit a written statement or explanation for violations 1,2,3,5 and 6 to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region 111, 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 should include for each violation: (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. Your response may reference or include previously docketed correspondence, if the correspondence adequately cddresses the required response. If an adequate reply is not received within the time specified in this Notice, an order or a Demand for information may be issued as to why the Certificate 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.
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 PDR 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 must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (for example, 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 acceptabie response, please provide the level of protection described in 10 CFR 73.21.
Dated at Lisle, Illinois this 2nd day of July 1997