ML20198F708
| ML20198F708 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 08/05/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198F694 | List: |
| References | |
| 70-7001-97-04, 70-7001-97-4, NUDOCS 9708130126 | |
| Download: ML20198F708 (4) | |
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NOTICE OF VIOLATION United States Enrichment Corporatior.
Docket No. 70 7001 Paducah Gaseous Diffusion Plant Certificato No. GDP 1 During an NRC inspection conducted from June 3 to July 14,1997, violations of NRC requiroments worn identified in accordance with the "Gonoral Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violations are listed below:
1.
Technical Safety Requirement 3.4 requires, in part, that individuals relied upon to operato the plant in a safe manner are proporly trained.
Plant procedure CP3 CO C01003, " Organization and Administratwn," required that only qualified operators or trainees operate equipment or systems in Building C 310.
Contrary to the above, as of June 9,1997, Building C 310 operators, individuals relied upon to operate the plant in a safe manner, had not been trained on the design and normal and off normal operation of the recently installed sodium fluorido production oven. Specifically, management operated a sodium fluorido production oven in Building C 310 from March 3, through June 9,1997 without training building operators on those aspects of oven operations which required control to ensure that the plant was operated in a safe manner, This is a Severity Lovel IV violation (Supplernent VI).
2.
10 CFR 76.93, " Quality Assurance," requires,in part, that the certificatee shall establish and execute a Quality Assuranco Program.
Section 2.11 of the Ouality Assuranco Program, " Test Control," requires in part, that the test control system provide rNasures to ensure that tast proceduros include provisions establishing proroquisitos, such as appropriate equipment test conditicas.
Contrary to the above, on March 13,1997, the cortificatoo failed to establish appropriato test conditions, in that, preventivo maintenance adjustments woro mado to the autoclave head to shall alignment prior to the performance of the Technical Safety Requirement periodic surveillance test, This is a Soverity LevelIV violation (Supplement VI).
3.
Technical Safety Requirement 3.9 requires, in part, that written proceduros shall be developed, approved, implomonted, and maintained for activities described in the Safety Analysis Report. Section 6,11, Appendix A.
The Safety Analysis Report, Section 6.11, Appendix A describes changes to facilities and equipment and modification design control as activities requiring written proceduros.
9708130126 970005
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PDR ADOCK 07007001 C
e Notice of Violation 2-Contrary to the above, between March 3, and June 19,1997, activities were conducted to change or modify equipment using installation instructions and test
- plans which were not developed, approved, implemented, or maintained (changeu) in accordance with Technical Safety Requirement 3.9. Specifically: 1) the modification test plans were not r1 viewed and approved by the Plant Operations Review Committee, and; 2) changes to the modification installation instructions and test plans, including acceptance criteria, were not reviewed to determine if the changes required Plant Operations Review Committee approval.
This is a Severity Level IV violation (Supplement VI).
4.
10 CFR 76.68(a) provides, in part, that the certificatee may make changes to the plant's operations, as described in the Safety Analysis Report, without prior Commission approval providcd that the changes to the Safety Analyds Report do not decrease the effectiventss of the plant's safety, safeguards, or security programs or involve an "..,eviewed safety question.
10 CFR 76.4 defines, in part, an unreviewed safety question as a change which increases the probability of occurrence of a malfunction of equipment important to safety previously evaluated in the Safety Analysis Report.
Contrary to the above, on April 2 and June 20,1997, the certificatee made changes to the plant's operations, as described in the Safety Analysis Report, without prior Commission approval and without evaluating whether the changes decreased the effectiveness of the plant's safeguards program or involved an unreviewed safety question.- Specifically, on April 2,1997, the certificatee approved an increase in the possession limits of uranium which allowed possession of a Category 11 quantity of special nuclear material and did not evaluate the impact change on the effectiveness of the Category lli safeguards program. On June 20, 1997, the certificateo approved a change to delete the five year surveillance frequency for the cell trip function and did not evaluate whether the change increased the probability of occurrence of a malfunction of equipment important to safety, an unroviewed safety question.
This is a Severity Level IV violation (Supplement VI).
5.
Technical Safety Requirement 3.11.5 requires,in part, that the double contingency principle, as stated in the Safety Analysis Report, be used as the basis for the design and operation of processes using fissionable materials.
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O Notico of Violation 3-Section 5.2.2.3 of the Safety Analysis Report,
- Process Evaluation and Approval,"
defines the double contingency principio as follows:
- Process designs should, in general, incorporato suf ficient factors of safoty to require at least two unlikely, independent, and concurrent changes in process conc'itions before a criticality accident is possible. The PGDP (Paducah Gaseous Diffusion Plant) NCS Inuclear criticality safety) program applies this principle by implernenting controls either on two different paramotors or by implementing two controls on one parameter."
Contrary to the above, from March 3 through June 19,1997, the double contingoncy principle was not used as the basis for the operation of storing selected legacy process equipment containing fissionablo materials (fissile or potentially fissilo materials). Specifically, the certificatoo f ailed to implomont controls on two different paramoort, mass or enrichment (assay) and interaction (spacing), for scme 220 to 260 items of legacy process equipment with unknown mass or assay identified during a plant walkdown subsequent to Juno 19.
This is a Severity Level IV violation (Supplomont VI).
G.
Technical Safety Requirement 3.2.2.b requires, in part, that adrninistrative procedures shall be developed and imptomonted to limit the working hours of facility staff who perform safety functions.
Technical Safety Tablo 3.2.2.1, " Minimum Staffing Reauirements," specifies that four security guards shall be onsite at all times.
Contrary to the above, as of July 14,1997, management had neither developed nor implemented administrative procedures to limit the hours of work of security guards, individuals who perform safety functions.
This is a Severity Level IV violation (Supplement VI).
Putmant to the provisions of 10 CFR 2.201, United State Enrichment Corporation is hereby required to submit a written statement or explanation for the violations to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555 with a cony to the Regional Administrator, Region ill, and a copy to the NRC Resident inspector at Paducah, within 30 days of the dato 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 correctivo steps that have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the dato when full compliance will be achieved. Your responso may reference or include previously docketed correspondence, if the correspondenco adequately J
Notico of Violation 4-addressos the required responso. If an adequate reply is not rocoived within the timo specified in this Notico, an order or a Domand for Information may be issued as to why the Certificato should not be modiflod, suspended, or revoked, or why such other action as may be proper should not be taken. Whero good cause is shown, consideration will be given to extending the response timo.
Because your rosponso will be placed in the NRC Public Document Room (PDR), to tbo extent possible, it should not include any personal privacy, proprietary, or safoguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is nocessary to provido an acceptable responso, then please provido a bracketed copy of your responso that identifies the information that should be protected and a redacted copy of your response that dolotes such information, if you request withholding of such material, you mull specifically identify the portions of your responso that you sook to have withhold and provido in detail the bases for your claim of withholding (for examplo, explain why the disclosuro of information will cteato 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 sofoguards information is necessary to provido an acceptable responso, please provide the !avel of protection described in 10 CFR 73.21.
Dated at Lisle, Illinois this 5tiday of August 1997 e