ML20217D771

Notice of Violation from Insp on 970721-25 & 970825-29. Violations Noted:Eoc & 300 Bldg Packets for Bldg 344 Did Not Have Info Concerning Criticality Safety Requirements for Firefighting

ML20217D771
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	09/29/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20217D764	List: ML20217D762 ML20217D765 ML20217D771
References
70-7002-97-206, NUDOCS 9710060129
Download: ML20217D771 (2)

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NOTICE OF VIOLATION United States Enrichment Corporation Docket No. 70-7002 Bethesda, Maryland Certificate No. GDP-2 During an NRC inspection conducted on July 21 to 25,1997, and August 25 to 29,1997, the following violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG 1600, the siolations are listed below:

1. 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 for the piotection of the public, plant employees, and the environment."

PORTS procedure XP2-EP-EP;049 requires the maintenance of Emergency Packets with complete infonnation at the Emergency Operations Center, the 300 building, and the affected facility.

Contrary to the above, on August 27,1997, the Emergency Operations Center and the 300 building packets for Building 344 did not have information concerning criticality safety requirements for firefighting.

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

11. S AR 5.2.2.3, Process Evaluation and Approval, states, in part, that "Each operation involving uranium. . is evaluated for NCS prior to initiation. The operation and related NCS requirements are documented in Part A and Part B of a NCSA. The evduation is documented in a NCSE ., The NCS evaluation process involves:. 3) development of the controls necessary to meet the double contingency principle, and 4) identification of the assum itions and equipment (i.e., physical controls) needed to ensure criticality safety."

NCSA PLANT 028 requires a 10-foot spacing between stored Planned Expeditious Handling (PEH) equipment.

Contrary to the above, as of July 25,1997, the technical basis for the 10-foot spacing between PEH equipment, an operation invohing uranium, was not evaluated. Specifically, no documented NCS evaluation prosided the basis for the assumption that the use of this physical control was sufficient to ensure criticality safety.

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

20 9710060129 970929 PDR ADOCK 07007002 C PDR

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Enclosure 2 Ill. TSR Section 3.11.5 requires, in pan, that "In those instances where double contingency is not met, TSRs shall be established, implemented, and maintained. "

Contrary to the above, as of August 29,1997, Nuclear Criticality Safety Evaluations for the Tails and Low Assay Withdrawal stations noted that these operations were singly contingent and no TSR had been established.

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

Pursuant to the provisions of 10 CFR 2.201, United States Enrichment Corporation (USEC)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 copies to the Regional Administrator, Region 111, and Chief, Fuel Cycle Operations Branch, Division of Fuel Cycle Safety and Safeguards, NMSS, within 30 days of the date of the letter transmitting tb" Notice of Violation (Notice). This reply should be clearly marked as " Reply to a Notice of Violation" and should include for each violation: (1) the reason for 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 nay 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 Demand for Information may be issued as to why the certificate of compliance 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 (PDit), 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 ofyour response that deletes such information. If you request withholding of such material, you mp3 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 _ day of September 1997 21

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