ML20211C728

Notice of Violation from Insp on 970715-0912.Violations Noted:From 970303-0825,U Hexafluoride Cylinder Tare Weight Listings Used in Bldg C-310 Were Not Maintain in DCS to Ensure Current & Correct Info Available in Bldg C-310 Room

ML20211C728
Person / Time
Site:	07007001
Issue date:	09/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20211C717	List: ML20211C714 ML20211C728 ML20211C734
References
70-7001-97-07, 70-7001-97-7, NUDOCS 9709260288
Download: ML20211C728 (5)

Text

.

NOTICE OF VIOLATION United States Enrichment Corporation Docket No. 70-7001 Paducah Gaseous Diffusion Plant Certificate No. GDP 1 During an NRC inspection conducted from July 15 through September 12,1997, five 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. The regulations in 10 CFR 76.93 require, in part, that the certificatee shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NOA 1-1989.

Section 3.15 of the Safety Analysis Report, "O AND AO STRUCTURES, SYSTEMS, AND COMPONENTS," defined, in part, the systems or components used in the plant that have a "O" or "AO" function, i.e., a significant safety function requiring the system or cornponent to be covered by the Quality Assurance Program (OAP).

Section 3.15.1.3.13 of the Safety Analysis Report identified uranium hexafluoride cylinders, except 2S and 1-kilograrn cylinders, as having a "O" function for " safe containment of uranium hexafluoride during transport, sampling, feeding, filling, and storage and to prevent a release of liquid uranium hexafluoride."

4 action 2.6.1 of the Quality Assurance Program stated, in part, that: "A document control system is established for O items and related activities and services...This system ensures that documents defining the performance of quality-related activities are controlled so only current and correct information is available at the location where the activity is performed prior to commencing work."

Contrary to the above, from March 3 through August 25,1997, uranium hexafluoride cylinder tare weight listings used in Building C-310 were not maintained in the document control system to ensure that only current and correct information was available in the Building C-310 withdrawal room, a location were uranium hexafluoride cylinders were filled, a quality-related activity.

This is a Severity Level IV violation (Supplement VI). (V!O 70-7001/97007-02)

2. The regulations in 10 CFR 76.93 require, in part, that the certificatee shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NOA 1-1989.

Section 3.15 of the Safety Analysis Geport, "O AND AO STRUCTURES, SYSTEMS, AND COMPONENTS," defined, in part, the systems or components used in the plant that have a "O" or "AO' function, i.e., a significant safety function requiring the system or component to be covered by the Quality Assurance Program (OAP).

9709260288 970924 PDR ADOCK 07007001 C PDR

4 i

Notice of Violation j l

Sections 3,15 and 5.2 of the Safety Analysis Report identified the high pressure l fire wate system, the criticality accident alarm system, and nuclear criticality safety controls, as sytems, components, or controls having a "Q", "AQ" or a significant safety function.

The Quality Assurance Program, Section 2.5 and Appendix A Section 1, Element 1.5, required, in part, that activities affecting safety or quality are prescribed and performed in - cordance with documented procedures appropriate to the circumstances.

Contrary to the above, maintenance activities affecting safety or quality were not performed in accordance with documented procedures appropriate to the circumstances in the following examples:

a. On August 5,1997, maintenance and work control activities associated with replacement of high-pressure fire water sectional Valve HP-O 16-S-3 (Work Order Task R 9600735-01), were not prescribed or performed in accordance with procedures appropriate to the c.humstances in that Technical Safety Requirement 2.3.4.9 compensatory measures were not identified in the procedures or implemented within eight hours after the sectional valve for the Building C 315 high pressure fire protection system was closed,

b. On July 30,1997, maintenance and work control activities associated with replacement and cost-maintenance testing of the Building C 335 "C" criticality accident alarm system cluster (Work Order Task R 9705259 01) were not prescribed or performed in accordance with procedures appropriate to the circumstances in that proper system alignment and operability, following completion of the work, was not assured. As a result, on August 5,1997, the system nitrogen bottle valve was discovered closed, isolating the safety-related pressure source to the system horns,

c. On August 1 and 2,1997, maintenance staff did not perform criticality controls for system filters installed in a Building C-400 negative air machine in accordance with Procedure CP2 GP-MS2033, " Operation of 1000 and 2000CFM Nege"ve Air Machines." Specifically, the staff failed to remove the negative air rriachine from service and request an evaluation of the filters due to changes in the pressure drop across the filters in excess of the procedure specified acceptance criteria.

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

(VIO 70-7001/97007-05a,b,c)

Notice of Violation 3-

3. The regulations in 10 CFR 76.68 provide, in part, that the certificatee may make changes to the plant's operations, as described in the Safety Analysis Report, without prior Commission approval provided that a written safety evaluation is performed that demonstrates that the chango does not pose an undue risk to the public safety.

The Safety Analysis Report, Section 3. Section 3.2.4, " Piping and Valves," stated, in part, that all autoclave piping, out to the outside containment valve, was installed according to national standards and engineering piping specifications.

Engineering Specification 15137HP, "UF, Gas and Liquid Piping Systems," required, in part, the performance of a vacuum test at 0.5 pounds force per square inch absolute (psia), held for two hours with no noticeable rise in pressure.

Contrary to L v above, on July 7,1997, the certificatee authorized the performance of an acceptance vacuum test on uranium hexafluoride piping, modified by the instrument upgrade project, which was less stringent than that specified in Engineering Specification 15137HP without performing a safety evaluation of the change in the acceptance criteria. Specifically, Temporary Procedures CP2-EG EG6031.tmp through CP2-EG EG6033 tmp required the vacuum test to be performed at a pressure of less than 5.0 pounds force per square inch absolute for 10 minutes with b pressure rise of not more that 0.25 pounds force per square inch absolute.

This is a Severity Level IV violation (Supplement VI). (70-7001/97007 06)

4. Technical Safety Requirement 3.9, requires, in part, that written procedures shall be implemented for activities described in the Safety Analysis Report, Section 6.11, Appendix A.

Safety Analysis Report, Section 6.11, Appendix A, describes, in part, procedure control as an activity for which procedures shall be implemented.

Procedure CP2-PS-PS 1031, " Processing New Procedures and Deletions, Revision 0, defined, in part, the process for developing, approval, and maintenance of new procedures for activities described in the Appendix D.

Appendix D of Procedure CP2-PS-PS1031 identified, changes in equipment and facilities as activities requiring procedures.

Contrary to the above, between March 3 and July 15,1997, plent staff performed changes to me Building C 337A autoclaves using engineering instructions that were not developed, approved, and maintained in accordance with Procedure CP2-PS-PS1031. Specifically, the procedures were not cross-discipline reviewed, defined as either regulatory or non-regulatory, designated as inhand, generalintent, or administrative, or otherwise processed in accordance with the procedure.

i 4

Notice of Violation l l

This is a Severity LevelIV violation (Supplement VI). (VIO 70 7001/97007 07)

5. Technical Safety Requirement 3.9 requires, in part, that written procedures shall be prepared and implemented for the environmental protection program as specified in Technical Safety Requirement 3.16.-

Procedure CP4 EW EV1110, " Environmental Monitoring Notebooks," Section 6.2.5 required, in part, that if calculations were recorded in a notebook, at least ten percent of the calculations were to be reviewed by the supervisor or another technician, and the signature of the reviewer and review date were also to be logged in the notebook.

Contrary to the above, for the period March 3 to August 12,1997, the environmental monitoring group maintained two notebooks in which calculations were recorded that were not check in accordance with Procedure CP4-EW EV1110.

Specifically, notebooks which included American Sigma refrigerated composite sampler and flowmeter data and calculations were maintained but were not reviewed as required by CP4 EW EV1110, Rev. O.

This is a Severity Level IV violation (Supplement VI). (VIO 70 7001/97007-20)

Pursuant 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 copy to the Regional Administrator, Region lil, and a copy to the NRC Resident inspector at Paducah, 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.

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 er proprietary information is necessary to provide an acceptable response, then please

4 e

j -- Notice of Violation 5-4 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 1 response that you seek to have withheld and provide in detail the bases for your claim of

, withholding (for 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 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.

j Dated at Lisle, Illinois this 24 tday of September 1997 1

i 1

4 1

h 4

1 6

1 e

p . - - + -