ML20207A027
| ML20207A027 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 05/21/1999 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20207A014 | List: |
| References | |
| 70-7002-99-04, 70-7002-99-4, NUDOCS 9905260090 | |
| Download: ML20207A027 (4) | |
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. United States Enrichment Corporation Docket No. 070-7002 Portsmouth Gaseous Diffusion Plant Certificate No. GDP-2 l
During an NRC inspection conducted February 22 through March 12,1999, four 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:
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1.
. Technical Safety Requirement 3.11.1 requires, in part, that the nuclear criticality safety program shall be established, implemented, and maintained as described in the Safety
' Analysis Report and shall address process evaluations and approvals.
Safety Analysis Report Section 5.2.2.3," Process Evaluation and Approval," required, in part, that the nuclear criticality safety evaluation process shall include: 1) a
' determination of the credible process upsets which need to be considered; 2) the development of controls necessary to meet the double contingency principle; and 3) the identification of the assumptions and equipment needed to ensure nuclear criticality safety.
Contrary to the above, as of March 12,1999, the certificatee failed to determine all credible process upsets, develop controls necessary to meet the double contingency principle, and identify all of the assumptions and equipment needed to ensure nuclear criticality safety for Nuclear Criticality Safety Evaluation (NCSE) 0705-015 and Plant 079. Specifically, the certificatee did not:
a.
Identify the presence of and applicable controls for materials (e.g., Polyvinyl
- Chloride), involved with the operations, which could affect nuclear criticality safety (NCSE 0705-015);
b.
Perform and document reviews, for adequacy and applicability, of referenced
. and relied upon calculations and did not identify and document assumptions related to the fissile material operations (NCSE 0705-015 and Plant 079);
c.
Identify or document controls and justifications, in terms of the availability and reliability, necessary to support the use of "unlikely events" as a part of the double contingency principle (NCSE 0705-015);
This is a Severity Level IV violation (Supplement VI). (VIO 70-7002/99004-01a,b,c) 2.
Technical Safety Requirement 3.11.2 requires. In part, that all operations involving uranium enriched to 1.0 weight percent or higher uranium-235 and 15 grams or more of uranium-235 shall be based upon a documented nuclear criticality safety evaluation and shall be performed in accordance with a documented nuclear criticality safety approval.
990 6 990521 i
POR ADOCK 07007002 s
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Notice of Violation Contrary to the above, as of March 12,1999, the certificatee conducted laboratory activities, in support of NCSE 0705-015 which involved uranium enriched to greater than 1.0 weight percent uranium-235 and 15 grams or more of uranium-235, that were not based upon a documented nuclear criticality safety evaluation. Specifically, the laboratory staff:
a.
Conducted analyses of nuclear criticality safety-significant samples using a single laboratory technician to prepare samples for, and to perform, the wet chemistry process, with and without the use of the spectrophotometer instrument and with the mass spectrometer instrument, without an evaluation of the operation and without an identification of the required controls necessary to avoid a potentialloss of double contingency; and b.
Conducted analyses of nuclear criticality safety-significant samples using the mass spectrometer and spectrophotometer instruments, without an evaluation of the operation and without an identification of the required controls to ensure that any out-of-control measurements on the low side would be detected and evaluated in a timely manner to avoid a potentialloss of double contingency.
This is a Severity Level IV violation (Supplement VI). (VIO 70-7002/99004-02a,b) 3.
Technical Safety Requirement 3.11.1 requires, in part, that tha nuclear criticality safety program shall be established, implemented, and maintained as described in the Safety Analysis Report and shall address identification of safety system components and support systems necessary to meet the double contingency principle.
Safety Analysis Report Section 5.2.2.8, Change Control," required, in part, that functional and physical characteristics of operations controlled for nuclear criticality safety were described in nuclear criticality safety evaluations and approvals.
Components and features which were identified in the nuclear criticality safety evaluations and approvals were analyzed to determine the " boundary" of the system, encompassing those items that were essential to ensure operability. Structures, systems, and components which require configuration control were identified as quality (Q) or augmented quality (AQ)-NCS.
Contrary to the above, as of March 12,1999, the certificatee did not identify the filter press blank plate, a component relied upon for double contingency in Nuclear Criticality Safety Approval NCSA-0705-015.A09 and essential to ensure operability, as an item relied on for criticality safety in the Boundary Definition Manual and did not classify the filter press blank plate as an AQ-NCS item.
This is a Severity Level IV violation (Supplement VI). (VIO 70-7002/99004-03) l J
il Notice of Violation 4.
10 CFR 76.93, Quality Assurance, requires, in part, that the Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of American Society of Mechanical Engineers (ASME) NQA-1-1989,
" Quality Assurance Program Requirements for Nuclear Facilities."
Section 2.16, of the Quality Assurance Program, " Corrective Action," required, in part, that conditions adverse to quality shall be identified promptly and corrected as soon as practical. In the case of significant conditions adverse to quality, the cause of the condition'shall be determined and corrective actions taken to preclude recurrence.
Procedure XP2-BM-Cl1031," Corrective Actions Process," Revision 0, Change A, dated June 15,1998, Section 6.0, required, in part, that plant staff shall verify that changes to corrective actions plans for significant conditions adverse to quality: 1) were warranted;
- 2) would still fix the root or contributing causes, as originally determined; and 3) were reviewed and approved by the Corrective Action Review Board.
Contrary to the above, as of March 12,1999, the plant staff made changes to the corrective actions for a significant condition adverse to quality, as outlined in Problem Reports PR-PTS-97-08987 and NCSA-PRI-01 and as communicated to the NRC in a letter dated November ~i3,1998, which reduced the scope of Priority 2 and 3 nuclear criticality safety evaluation and approval reviews and upgrades without: 1) determining that the changes were warranted; 2) determining that the revised corrective action plans would still fix the root or contributing causes, as originally determined; and 3) having the changes reviewed and approved by the Corrective Action Review Board.
This is a Severity Level IV violation (Supplement VI). (VIO 70-7002/99004-05)
Pursuant to the provisions of 10 CFR 76.70, United States Enrichment Corporation is hereby required to submit a written statement or explanation 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 Portsmouth, 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.
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001.
-Notice of Violation
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i 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 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 response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by i
10 CFR 2.790(b) to support a request for withholding confidential commercial or financial
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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 19.11, you may be required to post this Notice within two working days.
Dated this 21 day of May 1999 1
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