ML20236Q944

Notice of Violation & Proposed Imposition of Civil Penalty in Amount of $55,000.Violation Noted:Prior to 980409, Autoclave Numbers 1-5 in Bldg X-343,operated W/Autoclave Shells High Pressure Sys,Incapable of Performing Function

ML20236Q944
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	07/14/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236Q941	List: ML20236Q939 ML20236Q944
References
EA-98-249, EA-98-250, EA-98-251, NUDOCS 9807210143
Download: ML20236Q944 (5)

Text

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NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF civil PENALTY United States Enrichment Corporation Docket No. 70-7002 Portsmouth Gaseous Diffusion Plant Certificate No. GDP-2 Piketon, Ohio EAs98-249; 250; 251 l

During an NRC inspection conducted March 9,1998 through May 8,1998, violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (Enforcement Policy), NUREG-1600, the NRC proposes to impose a civil penalty pursuant to Section 234 of the Atomic Energy Act of 1954, as amended (ACT),42 U.S.C. 2282, and 10 CFR 2.205. The violations and associated civil penalty are set forth below; i

1. Violation Assessed a Civil Penalty Technical Safety Requirement Section 2.1.3.5 titled, " Autoclave Shell High Pressure i

Containment Shutdown," requires that the autoclave shell high pressure containment l system shall be operable.

1 Technical Safety Requirement Section 1.2.13, requires, in part, that a safety system l

component shall be operable or have operability when it is capable of performing its specified function (s), and when other auxiliary equipment that are required for the safety system component to perform its specified function (s) are also capable of perform!ng their related support function (s).

Contrary to the above, prior to April 9,1998, Autoclave Numbers 1,2,3,4, and 5 in l

Building X-343 were operated with an autoclave shell high pressure containment safety system component incapable of performing a specified safety function. Specifically,  ;

as-found testing conducted April 10 through April 21,1998, of the air-to-close autoclave i

containment valves for Autoclaves 1,2,3,4, and 5 in Building X-343, demonstrated that i 7 of 25 of the air-to-close containment valves failed the test acceptance criteria and I were not capable of performing the related support function. (01013)

This is a Severity Level lli violation (Supplement VI).  ;

Civil Penalty $55,000  !

II. Vicistions Not Assessed a Civil Penalty' A. Technical Safety Requirement Section 2.1.3.5 titled, " Autoclave Shell High Pressure Containment Shutdown,' requires that the autoclave shell high pressure containment system shall be operable.

Technical Safety Requirement Section 1.2.13, requires, in part, that a safety system component shall be operable or have operability when it is capable of performing its specified function (s), and when other auxiliary equipment that are required for the safety system component to perform its specified function (s) are also capable of performing their related support function (s).

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9807210143 980714 PDR ADOCK 07007002 C PDR

[____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ._ _ _ _ _ _ _ _ _ _ - _ _ _ __

Notice of Violation and Proposed 2 Imposition of Civil Penalty Contrary to the above, from March 25 through March 27,1998, Autoclave Number 4 in Building X-343 was operated with an autoclave shell high pressure containment safety system component incapable of performing a specified safety function. Specifically, on March 24,1998, a containment valve actuator was incorrectly installed, causing the FV-416X containment valve to work

" backwards" while the autoclave was operated for two heating and feeding cycles. (02014)

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

B. Technical Safety Requirement 2.2.3.15,

• Moderation Control," limiting ccadition for operation requires, in part, for cascade operational modes I, ll, Ill, IV, V and VI, that moderation control shall be maintained when the UO,F,(uranyl fluoride) mass is greater than safe mass.

Action B.1 of Technical Safety Requirement 2.2.3.15, requires, in part, that-equipment containing UO 2F, deposits greater than safe mass not in a fluorinating environment and in Mode VI, to be pressurized with plant air or N2 (nitrogen) to greater than or equal to 14 psia within eight hours after a UF, (uranium hexafluoride) negative was obtained in the system.

Contrary to the above, from March 31,1998 through April 8,1998, Cell 29-5-2 contained a UO,F, deposit with an enrichment of 5.5 percent of approximately .

6238 grams (+/- 3119 grams) of uranium-235, a deposit greater than safe mass,

, was not in a fluorinating environment and in Mode VI, and was not pressurized with plant air or N, to greater than or equal to 14 psia within eight hours as required. (03014)

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

C. Technical Safety Requirement Section 3.9.1, requires, in part, that written procedures shall be implemented for the activities described in Safety Analysis Report (SAR) Section 6.11.4.1 and listed in Appendix A to SAR Section 6.11.

Appendix A to SAR Section 6.11 requires communication activities to be covered

. by written procedures.

Section 6.4 of written Procedure XP2-TS-TS1032 Revision 0, dated September 11,1996, titled " Communications with Cascade Operations," l requires, in part, that process services staff shall report sample results j l (requested by the Cascade Controller) to the Cascade Controller as the sample j results become available. l l

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I Notice of Violation and Proposed 3 Imposition of Civil Penalty Contrary to the above, process services staff failed to report sample results (requested by the Cascade Controller) to the Cascade Controller as the sample results became available for Cell 29-5-2 on March 31,1998. (02034)

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

D. Technical Safety Requirement Section 3.9.1, requires, in part, that written procedures shall be implemented for activities described in Safety Analysis ,

l Report (SAR), Section 6.11.4.1, and listed in Appendix A to SAR Section 6.11. l l

Appendix A to SAR Section 6.11 requires maintenance activities to be covered I by written procedures.

Section 8.2.12 of written Procedure XP4-TE-MM4104, Revision 0, Change C, dated January 15,1997, titled, " Valve Actuator Removal, Replacement and installation," requires, in part, that the maintenance staff performing the work activity ensure that each of the following has a "V" stamped on it: valve end of the torque shaft; valve side of the actuator housing; and, valve end of the coupling between the torque shaft and the valve stem. In addition, Section 8.2.24 directs the maintenance staff performing the work activity to request Operations personnel to perform an operational check.

Contrary to the above, on March 24,1998, maintenance staff performing an actuator replacement on autoclave containment valve FV-416X did not ensure that a "V" was stamped on the valve end of the torque shaft, the valve side of the actuator housing, and the valve end of the coupling between the torque shaft and the valve stem. Further, maintenance staff did not request that an operational check be performed on the repaired actuator. (04014)

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

E. 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 ASME NQA-1-1989," Quality Assurance Program l Requirements for Nuclear Facilities." l Section 2.11 of the Quality Assurance Program titled, " Test Control," requires, in !

part, that the test control system for "Q" items, is planned and executed to assure that testing is pelformed to demonstrate that safety system components j will perform satisfactorily in service. I 4

l i Notice of Violation and Proposed 4 Imposition of Civil Penalty Contrary to the above, on March 24,1998, the post-maintenance test planned and executed for Work Order Number R9811626-01, failed to demonstrate that the "Q" safety system component, autoclave containment valve FV-4166X, would perform satisfactorily in service by closing upon a containment signal.

(05014)

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

Pursuant to the provisions of 10 CFR 76.70, the United States Enrichment Corporation (Certificate) is hereby required to submit a written statement or explanation to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, within 30 days of the date of this Notice of Violation and Proposed imposition of Civil Penalty (Notice). This reply should be cleariy marked as a " Reply to a Notice of Violation" and should include for each alleged violation: (1) admission or denial of the alleged violation, (2) the reasons for the violation if admitted, and if denied, the reasons why, (3) the corrective steps that have been taken and the results achieved, (4) the corrective steps that will be taken to avoid further violations, and (5) the date when full compliance will be achieved. 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 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. Consideration may be given to extending the response time for good cause shown. Under the authority of Section 182 of the Act,42 U.S.C.

2232, this response shall be submitted under oath or affirmation.

Within the same time as provided for the response required above under 10 CFR 76.70, the Certificate may pay the civil penalty by letter addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, with a check, draft, money order, or electronic transfer payable to the Treasurer of the United States in the amount of the civil penalty proposed above, or the cumulative amount of the civil penalties if more than one civil penalty is proposed, or may l protest imposition of the civil penalty in whole or in part, by a written answer addressed to the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission. Should the Certificate fail to answer within the time specified, an order imposing the civil penalty will be issued. ,

Should the Certificate elect to file an answer in accordance with 10 CFR 2.205 protesting the '

civil penalty, in whole or in part, such answer should be clearly marked as an " Answer to a .

Notice of Violation" and may: (1) deny the violation listed in this Notice, in whole or in part, (2) demonstrate extenuating circumstances, (3) show error in this Notice, or (4) show other ,

reasons why the penalty should not be imposed. In addition to protesting the civil penalty in )

l whole or in part, such answer may request remission or mitigation of the penalty  !

In requesting mitigation of the proposed penalty, the factors addressed in Section VI.B.2 of the Enforcement Policy should be addressed. Any written answer in accordance with 10 CFR 2.205 should be set forth separately from the statement or explanation in reply pursuant to 1 10 CFR 76.70, but may incorporate parts of the 10 CFR 76.70 reply by specific teference

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Notice of Violation and Proposed 5 Imposition of Civil Penalty (e.g., citing page and paragraph numbers) to avoid repetition. The attention of the Certificate is directed to the other provisions of 10 CFR 2.205, regarding the procedure for imposing a civil penalty.-

Upon failure to pay any civil penalty due which subsequently has been determined in accordance with the applicable provisions of 10 CFR 2.205, this matter may be referred to the Attomey General, and the penalty, unless compromised, remitted, or mitigated, may be collected by civil action pursuant to Section 234c of the Act,42 U.S.C. 2282c.

The response noted above (Reply to Notice of Violation, letter with payment of civil penalty, and Answer to a Notice of Violation) should be addressed to: James Lieberman, Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, One White Flint North,11555 Rockville Pike, Rockville, MD 20852-2738, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission, Region Ill,801 Warrenville Road, Lisle, Illinois 60532 and a copy to the NRC Resident inspector at the facility that is the subject of this Notice.

Because your response will be plamd 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 identities 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 14th day of July 1998 l