ML20196G743

Notice of Violation from Insp on 970428-0502 & 970527-30. Violations Noted:Failure to Label Contents & Enrichment in Container Used to Store U Bearing Matls & Failure to Place DAW Containers & Bags at Least Two Feet from U Bearing Matl

ML20196G743
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	06/27/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20196G735	List: ML20196G732 ML20196G737 ML20196G743
References
70-7002-97-203, NUDOCS 9707220383
Download: ML20196G743 (3)

Text

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United States Enrichment Corporation D'ocket No. 70-7002

~ Bethesda, Maryland . Certificate No. GDP-2' During an NRC inspection conducted on April 28,1997 to May 2,1997, and May 27 to 30, 1997, the following violations of NRC requirements were identified. In accordance with the -

" General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the.-

i violations are listed below:

1. TSR Section 3.11.2 requires, in part, that "All operations involving uranium enriched to 1.0 wt.% or higher U-235 and 15 g or more of U-235 shall be . . . performed in >

accordance with a nuclear criticality safety approval [NCSA)."

NCSA PLANT-045, Item 7, requires that "Any limited safe volume containers that are used to store (either permanently or temporarily) uranium-bearing materials shall be labeled as to their contents and enrichment."

NCSA-PLANT-018.A01, item 5, requires that " DAW [ Dry Active Waste) containers and  ;

bags shall be spaced at least two feet edge-to-edge from uranium-bearing equipment or other types of uranium bearing material."

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NCSA-PLANT-018.A01, Item 17, requires that "B-25 boxes containing DAW material shall be spaced at least two feet edge-to-edge from uranium-bearing equipment or other uranium bearing material."

Contrary to the above:

A. On April 30,1997, a limited safe volume cot iner that was used to store uranium-bearing materials was not labeled as to the contents and enrichment. Specifically, a one-gallon bucket containing autoclave valve internals contaminated with uranium enriched to 1.0 wt.% or higher of U-235 was observed by NRC inspectors on the floor in the X-344 facility near the autoclaves without an identification label on the bucket showing the enrichment.

B. On May 1,1997, DAW containers and bags were spaced less than two feet edge-to-edge from other types of uranium bearing material. Specifically, a plastic bag containing wet / oily / sludgy material and visible liquid was observed by NRC inspectors to be stored directly adjacent to a DAW drum on the second floor of building X-330 which is a process b ailding where operations involve uranium enriched to 1.0 wt.% or higher U-235.

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IC. On May 13,1997, a B-25 box containing DAW material was spaced less than two feet

- edge-to-edge from other uranium-bearing material. - Specifically, a drum containing other uranium-bearing waste material was observed by NRC inspectors, near building 6619, in temporary' storage less than two feet from a B-25 Box containing DAW.

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l This is a Severity Level IV. violation (Supplement VI). .

II. TSR Section 3.11.1 requires, in part, that "A Criticality _ Safety Program shall be

. established, implemented, and maintained as described in the Safety Analysis  !

Report . . . " l

, SAR Section 5.2.3.2 requires, in part, that "When NCS is based on computer code calculations of k,y, controls and limits are established to ensure that the maximum k,y complies with the applicable code validation for that type of system being evaluated."

Contrary to the above, as of May 't0,1997, three Nuclear Criticality Safety calculations, l NCS-CALC-97-009, NCS-CALC-97-010, and NCS-CALC-97-012, were observed to be based upon an enrichment of 20%, without justification that the results are bounded by . ,

the validation report.

1 This is a Severity Level IV violation (Supplement VI). I Ill. Title 10 Code of Federal Regulation (CFR) 76.93, " Quality Assurance," requires that the Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NQA-1-1989, " Quality Assurance Program Requirements for Nuclear Facilities." i H

ASME NQA-1-1989," Quality Assurance Program Requirements for Nuclear Facilities,"

Basic Requirement 8, " Identification and Control ofItems," states that controls shall be established to assure that only correct and accepted items are used or installed.

Portsmouth Quality Assurance Program, Appendix A, Section 1.8,"AQ-Nuclear Criticality Safety Identification and Control ofitems," states that ASME NQA-1-1989 Basic Requirement 8 shall be applied to those SSCs identified in NCSAs/NCSEs required to meet the double contingency principle.

Contrary to the above, ASME NQA-1-1989 Basic Requirement 8 was not applied to SSCs identified in NCSA-PLANT-028 and NCSA-330-013, as required to meet the l double contingency principle. Specifically, as of May 30,1997, the metal cover plates l ' and associated systems, which are designed to prevent the introduction of moderator into l PEH equipment, were not identified as AQ-NCS.

This is a Severity Level IV violation (Supplement VI).

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P Pursuant to the provisions of 10 CFR 2.201, United States Enrichment Corporation'(USEC) is hereby required to submit a written statement or explanation to tne U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.,20555 with ' copies to the Regional Administrator, Region III, and Chief, Fuel Cycle Operations Branch, Division of Fuel Cycle Safety and Safeguards, NMSS, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as " Reply to a Notice of l . Violation" and'should include for each violation: (1) the reason for 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 Notice, an order or Demand for Information may be issued as to why the Certificate of Compliance should not be modified, l

suspended, or revoked, or why such other action as may be proper should not be taken. Where

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gobd cabse 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 provi@ n ayeptable response, then please provide a bracketed copy of your response that identifies the informatica that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material,'you musi l- specifically identify the' portions of your response that you seek to have withheld, and provide in detail the bases for your clah.g f whhholding (e.g., explain _why the disclosure ofinformation 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 level of protection described in 10 CFR 73.21.

Dated at Rockville, Maryland

this 22. day of June 1997 L 3 o

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