ML20236F822

Notice of Violation from Insp on 980420-0608.Violation Noted:Between 980414 & 0513,Corporation Failed to Implement, as Soon as Practical,Interim Nuclear Criticality Safety Spacing Controls for Bldg C-333 Wet Air Pump Piping Elbows

ML20236F822
Person / Time
Site:	07007001
Issue date:	06/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236F810	List: ML20236F808 ML20236F822 ML20236F824
References
70-7001-98-09, 70-7001-98-9, NUDOCS 9807020360
Download: ML20236F822 (3)

Text

_ _ _ _ _ _ _ _ _ _ _ - _ - - - -

l 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 April 20 through June 8,1998, three 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. Title 10 of the Code of Federal Regulations, Part 76.93, " Quality Assurance," requires, in l part, that the Corporation shall establish, implement, and maintain a Quality Assurance Program.

Section 2.16, of the Quality Assurance Program, " Corrective Action," required, in pad, that conditions adverse to quality shall be corrected as soon as practical. j Contrary to the above, between April 14 and May 13,1998, the Corporation failed to  ;

implement, as soon as practical, interim nuclear criticality safety spacing controls  !

(corrective actions) for the Building C-333 wet air pump piping elbows, previously removed from a cascade support system and stored on the cell floor without an approved nuclear criticality safety evaluation, a condition adverse to quality.

4 This is a Severity Level IV violation (Supplement VI). (VIO 70-7001/97009-01) i

2. Title 10 of the Code of Federal Regulations, Pad 76.93, " Quality Assurance," requires, in i part, that the Corporation shall establish, implement, and maintain a Quality Assurance Program.

Section 2.5, of the Quality Assurance Program, " Procedures," required, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings appropriate to the circumstances, and shall be accomplished in accordance with these documents.

Contrary to the above, on May 14,1998, testing of the Switchyard C-537 fire sprinkler system for Transformer No. 72, an activity which affected quality, was conducted without documentK instructions, procedures, or drawings appropriate to the circumstances.

Specifically, the task test package did not include documented instructions or procedures, as appropriate, to ensure a minimum water flow rate, from the common water supply header to both the fire sprinkler and plant air systems, for continuous operation of the plant air compressors at a level sufficient to provide the minimum system air capacity required for operability of the criticality accident alarm system homs.

This is a Severity Level IV violation (Supplement VI). (VIO 70-7001/97009-02)

3. Condition 8 of the Certificate of Compliance requires, in part, that the Corporation shall conduct operations in accordance with the Safety Analysis Report and the Compliance l

Plan.

Compliance Plan issue 2, required, in part, that the Corporation shall evaluate as-found conditions, identified as a part of the Safety Analysis Report upgrade process, that I represent risks more severe than described in the Safety Analysis Report in accordance with 10 CFR 76.68.

9907020360 990630 I PDR ADOCK 07007001  ;

C PDR n L__________-__-_________________________ __ ___

l Notice of Violation Title 10 of the Code of Federa' . regulations, Part 76.68(b), requires, in part, that the Corporation shall evaluate any as-found conditions that do not agree with the plant's programs, plans, policies, and operations as described in the Safety Analysis Report in accordance with Part 76.68(a).

Contrary to the above, between October 31,1997, and June 8,1998, the Corporation did not evaluate as-found conditions, identified during the Safety Analysis Report upgrade process, to determine if the risks of the as-found conditions were more severe than previously addressed in the Safety Analysis Report. In addition, the Corporation did not evaluate the as-found conditions, that did not agree with the plant's operations, as described in Safety Analysis Report, in accordance with 10 CFR 76.68(b). Specifically,

, the Corporation failed to perform risk and safety evaluations for the following as-found conditions:

a. The presence of uncontrolled keyed reset switches in the Building C-360 autoclave safety system actuation circuits which, if operated improperly, would cause the safety systems to be inoperable during normal and off-normal operations, without indication, and would result in significant increases in the Safety Analysis Report assumed accident releases.

l 1

b. An unanalyzed reliance on the nonsafety-related plant air system by some safety-related autoclave containment valves in Buildings C-333A and C-337A in order to ensure valve closure within the Safety Analysis Report accident analysis time limits,

c. An unanalyzed, unmonitored, and non-failsafe reliance on the nonsafety-related plant air system bf the Buildings C-310 and C-315 withdrawal pump safety systems M order to 6asure the Safety Analysis Report accident consequences were met. 1 This is a Severity Level IV violation (Supplement VI). (VIO 70-7001/97009-03)

Pursuant to the provisions of 10 CFR 76.70, United States Enrichment Corporation is hereby required to submit a written statement or explanation for the violations to the U.S. Nuclear i

RegulatoryCommission, 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 j 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 l- will be given to extending the response time.

l

Notice of Violation . If you contest this enforcement action, you should also provide a copy of your response to

' the Director, Office of Enforcement, U.S. 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 (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 i financialinformation). 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 30th day of June 1998 j

i l

1 l

i l

i I

_ _ _ - _ - - - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _