ML20248H729

Notice of Violation from Insp on 980427-0501.Violations Noted:Sys,Structures & Components Relied on in NCSE-0326 013.E04 & NCSE-0326 024.E04 for Double Contingency,Were Not Identified as Components Relied on for Criticality Safety

ML20248H729
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	06/02/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20248H711	List: ML20248H708 ML20248H729 ML20248H738
References
70-7002-98-206, NUDOCS 9806080228
Download: ML20248H729 (3)

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's NOTICE OF VIOLATION United States Enrichment Corporation Docket No. 70-7002 ,

Piketon, Ohio Certificate No. GDP-2 During a Nuclear Regulatory Commission (NRC) inspection conducted April 27 - May 1,1998, three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedures for NRC Enforcement Actions," NUREG-1600, the violations are listed below:

1. Safety Analysis Report (SAR) Section 6.3.5.1.1 states, in part, that "The CM Program has been developed and documented in a site procedure and is implemented to ensure that changes from the plant baseline configuration are controlled to prevent degradation of safety or safeguards."

SAR Section 5.2.2.8 states, in part, that " Functional and physical characteristics of operations controlled for NCS are described in NCSAs and NCSEs. These components and features which are identified in the NCSAs and NCSEs are analyzed to determine the " boundary" of the system, encompassing those items that are essential to ensure operability....These components and features are documented in a manual for each facility....lf an item is relied on for the criticality safety of an operation, it will be identified through the work control process as an NCS SSC....The systems which require configuration control are identified as Q or AQ-NCS."

The Configuration Management Program Manual defines AQ-NCS items as "SSCs identified in NCSAs/NCSEs as required to meet the double contingency principle."

Contrary to the ak .e, as of May 1,1998, systems, structures, and components (SSCs) j relied on in NCSE-0326_013.E04, " Cascade Operations in the X-326 Building," and i NCSE-0326_024.E04, " Feeding of 5-inch,8-inch, and 12-inch Cylinders in the X-326 j Product Withdrawal Area," for double contingency were not identified as components relied on for criticality safety in the Boundary Definition Manual or classified as AQ-NCS items.

This is a Severity Level IV Violation.

l ll. SAR Section 6.9.2 states, in part, that "The PSS assesses and categorizes abnormal events or conditions using the notification and reporting criteria set forth in 10 CFR 76 and the other applicable regulations referenced in 10 CFR 70.60. Table 6.9-1 provides a list of the initial event notification and reporting criteria."

SAR Table 6.9.-1, paragraph 2.c.(3), states that "Any case where it is determined that a criticality safety analysis was deficient and where the necessary controlled parameters were not established or maintained" is a 4-hour reportable event.

l 9006000228 990602 PDR ADOCK 07007002.-

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l l Contrary to the above, as of May 1,1998, no event notification was made following the

! discovery on August 29,1997, that double contingency had not been established for tae l Tails and LAW withdrawal stations. l This is a Severity Level IV Violation.

111. 10 CFR 76.93 states, in part, that "The Corporation shall establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NOA-1-1989...or satisfying acceptable alternatives to the applicable l requirements."

.I Quality Assurance Program (QAP), Section 2.16.3, states, in part, that " Procedures for the corrective action process are established to ensure the following...For significant conditions adverse to quality, the cause of the condition is determined and corrective action is taken to preclude recurrence."

Contrary to the above, as of May 1,1998, adequate corrective actions had not been j taken to preclude recurrence of VIO 70-7002/97-206-06 in the ERP withdrawal station.

NCSE-0326_015.E02, " Extended Range Product (ERP) Withdrawal Station," did not demonstrate double contingency for this operation, and no TSR had been established in accordance with TSR 3.11.5.

This is a Severity Level IV Violation.

Pursuant to the provisions of 10 CFR 76.60, 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 a copy to the Regional Administrator, Region ill, and the Branch Chief Fuel Cycle Operations Branch, Division of Fuel Cycle Safety and Safeguards, NMSS, 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 hm been taken and the results achieved, (3) the corrective steps that will be taken to avoid fu r .er violations, and (4) the date when full compliance will be achieved. Your response may n tence 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 the Notice, an order or Demand for I Information may be issued as to why the certificate should not be modified, suspended, or I revoked, or why such other action as may be proper should not be taken. Where good cause is {

shown, consideratic,n will be given to extending the response time.  ;

Because your response will be placed in the NRC Public Document Room (PDR), to the extent l I

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 i 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 such material, you must specifically identify the portions of your response that you seek to have withheld and provide in  ;

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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, clease provide the level of protection described in 10 CFR 73.21.

Dated at Rockville, Maryland this 2nd day of June 1998 l

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