ML20202E846

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

ML20202E846
Person / Time
Site:	07007001
Issue date:	11/28/1997
From:	NRC
To:
Shared Package
ML20202E843	List: ML20202E838 ML20202E846 ML20202E864 ML20202E882
References
70-7001-97-208, NUDOCS 9712080161
Download: ML20202E846 (3)

Text

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NOTICE OF VIOLATION United States Enrichment Corporation Docket No. 70-7001 Bethesda, Maryland Certificate No. GDP 1 During an NRC inspection conducted on September 15 - 19 and November 3 - 7,1997, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

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..."

1. SAR Section 5.2.3.2 requires, in part, that " Statistical analysis is employed to estimate the calculational bias, which includes the uncertainty in the bias and uncertainties due to extensions of the area of applicability, as well as the effective margin of suberiticality.. .

l The margin of suberiticality used at PGDP shall result in a k,y upper safety limit which I will ensure that there is 95 percent confidence that 99.9 percent of all future k,y values less than this value will be suberiticality... 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 November 7,1997, the calculations in NCSEs were observed to be based on an enrichment of 5.5wt% even though the experimental data only extended to 4.98wt%.

The validation report did not demonstrate that the data was normally distributed, as required by the method which determines the USL with 95% confidence that 99.9% of all future calculations with k,y < USL will be suberitical. The validation did not rigorously demonstrate that the above conditions could be met for enrichments of 5.5wt%.

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

II. SAR Section 6.11.1 requires, in part, that "USEC is committed to the use of approved and controlled written procedures to conduct nuclear safety, safeguards, and security activities...USEC's quality assurance commitments are described in the Quality Assurance Plan."

QAP Section 2.16.1 requires, in part, that "A corrective action system... establishes measures which ensure that conditions adverse to quality are identified and corrected as soon as practical.. "

Enclosure 1 9712090161 971128 PDR C ADOCK 07007001 1 PDR

i Contrary to the above, as of November 7,1997, incons stencies between operating procedures that could have permitted the assay limit on the C-360 surge drums to be exceeded during 2S cylinder refeed operations had been observed. The operation was restarted without taking prompt and corrective action to resolve the inconsistency, and the corrective action was inadequate to resolve the inconsistency.

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

Ill. SAP Section 5.2.2 requires, in part, that "The nuclear criticality safety (NCS) program, as defined in this section, is implemented by the plant NCS procedures."

Procedure CP4-EG-NSI 104, Rev. 0, " Nuclear Criticality Safety Engineer Response to Emergency, Off-Normal, and Process Upset Conditions," requires, in part, that the NCS Engineer " Evaluates potential criticality safety violations... responds and provides guidance during emergencies, off-normal, and process upset conditions with NCS significance..." and also must " Complete incident Report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> ofincident.. "

Contrary to the above, as of September 19,1997, three criticality control violations were identified in which the NCS Section was not notified or consulted, and thus did not provide the required evaluation and guidance or issue the Audit / Incident Reports within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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

Pursuant to the provisions of 10 CFR 76.60, USEC is hereby required to submit a written statement or explanation to the U.S. Nuclear Regulatory Commission, ATEN: Document Control Desk, Washington, D.C. 20555, with a copy to the Regional Administrator, Region Ill, and the Branch 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 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 previous docketed correspondence, if the correspondence adequately addresses the required response. If an adequate reply is not received within the time specified in the Notice, an order or 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 2

4 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 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 (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 28th day of November 1997 l

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