ML20154P514

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

ML20154P514
Person / Time
Site:	07007001
Issue date:	10/16/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20154P513	List: ML20154P510 ML20154P514 ML20154P518
References
70-7001-98-13, NUDOCS 9810230004
Download: ML20154P514 (3)

Text

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G J 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 July 21 through September 1,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, Revision 1, the violations are listed below-

1. Title 10 of the Code of Federal Regulations, Part 76.68(a), " Plant Changes," requires, in part, that the Corporation may make changes to the plant's operations as described in the Safety Analysis Report provided the Corporation shall conduct a written safety analysis which demonstrates that the changes would not result in undue risk to public health and safety.

Section 4.3.3.1.1 of the Safety Analysis Report states, in part, that if the pump discharge valve failed closed on an on-stream pump, the discharge pressure would rise quite rapidly and could conceivably rupture the pump discharge bellows. To prevent this type l of accident, dual high pressure shut-down instrumentation is installed as a safety i system on the pump discharge. The high discharge pressure safety system will trip the l pump at 42 psia to prevent exceeding the 45 psia pressure rating of the discharge j bellows. l Centrary to the above, on August 27,1998, the Corporation made changes to the plant's operations as described in the Safety Analysis Report without conducting a written safety analysis. Specifically, the Plant Operations Review Committee approved changes to Procedures CP4-CO-CN2021A, " Operation of the C-310 Normetex Pump,"

and CP4-CO-CN2021B, " Operation of the C-315 Normetex Pump," which added operator actions to ensure the pressure rating (Safety Limit 2.3.2.1) of 45 psia for the pump discharge bellows would not be exceeded because the high discharge pressure safety system was nonconforming (could not be relied upon). The reliance on operator action was a change to operations as described in Section 4.3.3.1.1 of the Safety Analysis Report which described the automatic action of the high discharge pressure safety system as the sole means relied upon to prevent the safety limit from being exceeded in the event the discharge valve failed closed.

This is a Severity Level IV violation (Supplement VI). (VIO 70-7001/98013-02)

2. Title 10 of the Code of Federal Regulations, Part 76.93, " Quality Assurance," requires, in part, that the Corporation shall establish a quality assurance program satisfying each 4 of the requirements of the American Society of Mechanical Engineers (ASME) Standard NQA-1-1989, ' Quality Assurance Program Requirements for Nuclear Facilities," or  ;

acceptable alternatives.

Contrary to the above, as of February 1,1998, the Corporation failed to establish a Quality Assurance Plan (QAP) that incorporated all ASME NQA-1-1989 supplemental ,

9810230004 990916 PDR ADOCK 07007001 C PDR

J Notice of Violation requirements. Specifically, the Corporation failed to incorporate ASME NOA-1-1989 supplemental requirements associated with design control and measuring and test equipment into the QAP.

This is a Severity Level IV violation (Supplement VI). (VIO 70-7001/98013-03)

Pursuant to the provisions of 10 CFR 76.70, United States Enrichment Corporation is hereby required to submit a written statement or explanation for Violation 70-7001/98013-02 to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.

20555, with a 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 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 addresses 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.

The NRC has concluded that information regarding the reasons for Violation 70-7001/98013-03, the corrective actions taken and planned to correct the violation and prevent recurrence, and the date when full compliance will be achieved is already adequately addressed in Inspection Reports 70-7001/97009,70-7001/98002, and 70-7001/98013. Therefore, a specific

response to Violation 70-7001/98013-03 is not required. However, you are required to submit a written statement or explanation, pursuant to 10 CFR 76.70, if the description therein does not accurately reflect your corrective actions or your position, in that case, or if you choose to respond, clearly mark your response as a " Reply to a Notice of Violation," and send it to the address identified above within 30 days of the date of this letter transmitting this Notice.

l if you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C.

20555-0001.

l- 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 bracket-d copy of your response that identifies the information that should be protected and a redacted copy of your i

response that deletes such information. If you request withholding of such material, you musi

! specifically identify the portions of your response that you seek to have withheld and provide in I 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 i

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i Notice of Violation p financial information).- If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

In accordance with 10 CFR 19.'1, you may be required to post this Notice within two working days.

Dated this 16th day of October 1998 L

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