ML20199H645
| ML20199H645 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 11/20/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20199H615 | List: |
| References | |
| 70-7001-97-08, 70-7001-97-8, NUDOCS 9711260179 | |
| Download: ML20199H645 (3) | |
Text
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. United States Enrichment Corporation Docket No. 70-7001 Paducah Gaseous Diffusion Plant Certificate No. GDPsi-During an NRC inspection conducted from August 26 through October 7,1997, four 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 3.9.1 requires, in part, that procedures shall be implemented for activities described in Safety Analyd Report, Section 6.11, Appendix A.
Safety Analysis Report, Section 6.11, Appendix A identifies, in part, procedures management (use) as an activity that shall be performed in accordance with approved procedures.
Procedure CP2-PS-PS1038,"Use of Procedures at PGDP," requires, in part, that the first line manager must approve and cocument, in the logs, the reason for and the special entry and exit pc nts for use of a partial procedure.
Contrary to the above, on July 27,1997, the certificatee failed to document the reason for and the special entry and exit points for partial procedures used during restart of the purge cascada.
This is a Severity Level IV Violation (Supplement VI). (VlO 70-7001/97008-01) 2.
Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be maintained, and implemented for activities described in Safety Analysis Report, Section 6.11, Appendir A.
Safety Analysis Report, Section 6.11, Appendix A identifies, in part, operations, including system procedures addressing startup, shutdown, normal operation and abnormal operations as activities requiring written procedures.
Contrary to the above the certificatee failed to implement and maintain written procedures for operations, including system procedures addressing startup, shutdown, normal operations, and abnormal operations as described by the following examples:
A.
On September 2,1997, operations management used an outdated procedure, CE-16, " Emergency Operations in Building Fires," during their oversight of the response to a small fire in Building C-310.
B.
As of September 30,1997, numerous controlled manuals of plant procedures included canceled and outdated operations normal, off-normal, and emergency procedures.
This is a Severity Level IV Violation (Supplement VI). (VIO 70-7001/97008-02).
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3.
Technical Safety Requirement 3.9.1 requires, in part, that written procedures shall be preparec' and implemented to cover the activities described in Safety AnalysbReport, Section 6.11.4.1.
Section 6.11.4.1 of the Safety Analysis Report states, in part, that: "As a minimum, a procedure is required for any task that is described in, or implements a commitment that is described in, the Safety Analysis Report..."
Section 6.8.2.4 of the Safety Analysis Report, " Problem Reporting," states, in part, that:
"All plant employees have the responsibility to write problem reports on safety, operating, and noncompliance items... Corrective actions are tracked through the plant's corrective action program."
Procedure UE?-HR-Cl1030,
- PROBLEM REPORTING," Revision 0, dated April 10,1996, identifies " false alarms or false actuations related to safety system items" and
- violations
.)f, or deviations from, programs, policies, and procedures or deficiencies which could cause safety, operability, or reportability concems" as problems requiring a problem report (PR). Step 6.1.3C requires that the problem report form be delivered to the Plant Shift Superintendent as soon as practical, but always prior to the end of the shift.
Contrary to the above, the certificatee failed to deliver problem report forms to the plant shift superintendent by the end of the shifi for the following examples of problems (false alarms er deviations from policies and procedures):
A.
A false actuation of the high condensate safety system for the Building C-333A Position 4 South autoclave on September 19,1997.
B.
A deviation from the procedurally required criticality safety posting for a fissile vacuum and its hose in Building C-310 on September 23,1997.
C.
A deficient independent verification of assay form (missing originator signature) discovered in Building C-400 on September 24,1997.
I D.
The identification on Scotcmbcr 24,1997, that the certificatee had not performed load tests after modifi';.ations to two NCH-35 cylinder haulers were made in September and Octobsr 1996.
This is a Severity Level IV Violation (Supplement VI). (VIO 70-7001/97008-04) 4.
Title 10 of the Code of Federal Regulations, Part 76.68 (b) requires, in part, that the certificatee shall evaluate any as-found conditions that do not agree with the plant's programs, plans, policies, and operations in accordance with Part 76.68 (a).
Contrary to the above, between August 13 and September 5,1997, the certificatee fa!:ed to evaluate the safety impact of as-found nonconformances identified in the purge cascade, a system described in the Safety Analysis Report, plant programs, plans, and operations.
This is a Severity L2 vel IV Vic - on (Supplement VI). (VIO 70-7001/97008-08)
1
Pursuant to the prwisions of 10 CFR 76.70, 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 copy to the Regional Administrator, Region lit, and a copy to the NRC Resident inspector at Paducah, within 30 days of the date of the letter transmitting th's Notice of Violation (Notice). This repiy 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
- 2 achieved. Your response may reference or include previously docketed correspondence, if the correspondence adequately eddresses 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 ext"nt possible, it should not include any personal privacy, proprietary, or safeguards information =,0 that it can be placed in the PDR without redacCon, 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 respons.: that you seek to have withheld and provide in detail the bases for your claim of withholding (f( r 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 requ ist for withholding confidential commercial or iinancialinformation). If safeguards informatien is necessary to provide an acceptable response, please provide the level of protection describt d in 10 CFR 73.21.
Dated at Lisle, Illinois this 20th day of November 1997
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