ML20217G661

Notice of Violation from Insp on 980302-06.Violation Noted: on 980305,during Performance of in-hand Procedure XP4-CU-IM6100,work Group Did Not Stop Work When Section 8.3.12 of Procedure Could Not Be Performed as Written

ML20217G661
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	03/27/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20217G652	List: ML20217G648 ML20217G661 ML20217G672
References
70-7002-98-04, 70-7002-98-4, NUDOCS 9804020487
Download: ML20217G661 (3)

Text

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NOTICE OF VIOLATION -

United States Enrichment Corporation Docket No. 70-7002 Portsmouth Gaseous Diffusion Plant Certificate No. GDP-2 During an NRC inspection conducted from March 2 through March 6,1998, two 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 written procedures shall be implemented for activities described in Safety Analysis Report, Section 6.11.4.1, and -

listed in Appendix A, to Safety Analysis Report, Section 6.11.

' Appendix A, to Safety Analysis Report, Section 6.11 requires, in part, that procedure management activities shall be covered by written procedures.

Procedure UE2-PS-PS1034,"Use of Procedures," Revision 1, Change B, Section 6.2 requires, in part, that each procedure step in an in-Hand procedure is performed as written. . If the activity cannot be performed as described, the following actions must be performed: stop the work activity; place the system in a safe condition; mark procedure step last performed; notify the appropriate manager for direction; and, if necessary, request or initiate procedure change or revision according to UE2-PS-PS1031.

Contrary to the above, on March 5,1998, during the performance of in-Hand Procedure XP4-CU-lM6100, *X-705 Test and Calibration of Calciners High-High Temperature Shutdown," the work group did not stop work when Section 8.3.12 of Procedure XP4-CU-lM6100 could not be performed as wntten. Specifically, Section 8.3.12 of Procedure XP4-CU-lM6100 required the work group to verify the volt / ohm-milliammeter indicated 80 to 120-volts AC. The volt / ohm-milliammeter indicated 124-volts AC during the completion of Section 8.3.12 of Procedure XP4-CU-lM6100, and the work group did not stop work and continued to progress through the action steps of the procedure.

This is a Severity Level IV violation (Supplement VI). (VIO 70-7002/98004-01)

-2. Technical Safety Requirement 3.9.1, requires, in part, that written procedures shall be implemented for activities described in Safety Analysis Report, 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," requires, 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 UE2-HR-Cl1030, " Problem Reporting," Revision 0, Change E, dated April 1, 1996, Secton 2.0, " Applicability," requires, in part, "That if there is any question as to whether or not to initiate a Problem Report (PR) for a given situation, a PR shall be initiated. : Examples of problems include, but are not limited to violations of, or deviations from, programs, policies, and procedures or deficiencies which could cause safety, 9904020487'990327' PDR ADOCK 07007002 C 'DR

Notice of Violation operability, or reportability concerns." Step 6.1.3.A 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, from September 9,1997 through March 5,1998, the certificant did not initiate and deliver problem report forms to the plant shift superintendent by the end of the shift for the following examples of problems (Violations of, or deviations from, programs, policies, and procedures or deficiencies which could cause safety, operability, or reportability concems):

a. Plant staff did not initiate problem reports for deviations of the required quarterly face velocity measurement tests for laboratory fume hoods utilized for various operations in the Building X-710 Laboratory upon initial discovery. Problem reports were filed after questions were raised by the NRC inspectors.

b. A transportation violation was identified on September 9,1997, by a Paducah transportation specialist regarding a shipment of cylinders with residual uranium hexafluoride originating from the Portsmouth Gaseous Diffusion Plant. Portsmecth Packaging and Transportation staff were notified of the non-compliance and were faxed information regarding the transportation violation.

c. A transportation violation was identified on December 16,1997, by a Paducah Transportation specialist receiving an " excepted package-empty packaging" shipment from the Portsmouth Gaseous Diffusion Plant. Portsmouth Packaging and Transportation and Plant Shift Superintendent staff were notified of the non-compliance and were faxed information regarding the transportation violation.

d. A transportation violation was identified on January 23,1998, by a Paducah Transportation specialist regarding a shipment of cylinders with residual uranium hexafluoride originating from the Portsmouth Gaseous Diffusion Plant. Portsmouth Packaging and Transportation staff were notified of the non-compliance and were faxed information regarding the transportation violation.

This is a Severity Level IV violation (Supplement VI). (VIO 70-7002/98004-02a,b,c,d)

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 111, 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 or severity level, (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 this Notice, an order or a Demand for

~ Notice of Violation ~

. Information may be issued as to why the certificate should not be modified, suspsnded, 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 to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

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 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 Lisle, Illinois this 27 tesy of March 1998

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