ML20203E490

Notice of Violation from Insp on 971008-1124.Violation Noted:Investigation & Reporting Activities Were Not Performed in Accordance W/Written Procedures

ML20203E490
Person / Time
Site:	07007001
Issue date:	12/09/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20203E451	List: IR 07100008/2011024 ML20203E447 ML20203E490
References
70-7001-97-11, NUDOCS 9712170076
Download: ML20203E490 (3)

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L i-NOTICE OF VIOLATION' ,

United States Enrichment Corporation __ Docket No. 70-7001 Paducah Gaseous Diffusion Plant - Certificate No GDP >

During an NRC inspection conducted from October 8 through November 24,1997, 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-4 1. Technical Safety Require nent 3.9.1 requires, in part, that written procedures be prepared and implemented to cover the activities described in Safety Anahsis Repor1 (SAR) ,

- Sechon 6.11.4.1 and listed in Appendix A to SAR Section 6.11.

Appendix A to SAR Section 6.11 identifies " investigations and reporting" as an activity requiring an administrative procedure. ,

Step 6.1.2 of Procedure UE2-RA-RE1030, " NUCLEAR REGULATORY EVENT -

o REPORTING," Revision 2, dated February 28,1997, requires that the plant shift i superintendent (PSS) review problens reports and determine reportability of the event or condition using Appendix D. Step 6.2.1E of the procedure requires that the PSS verbally l notify the appropriate NRC office within the time requirements shown in Appendix D.

Appendix D,"NRC REPORTING CRITERIA," of Procedure UE2-RA-RE1030, specifes '

. the criteria and reporting time for events and conditions. Specifically, the following criteria and reporting times are identified:

Criterion J.1.s requires, in part, a 24-hour report for an event in which equipment is disabled or fails to function when it is required by Technical Safety Requirement (TSR) to mitigate the consequences of an accident; is required by TSR to be available ano operable and either should have been operating or should have

. operated on demand; and no redundant equipment is available and operable to perform the required safety function.

Criterion A.2.c requires, in part, a four-hour report for operations that comply with l

the double contingency principle in which moderation is used as the primary criticality control and where it is determined that a crit;cality safety analysis was

- deficient and the necessary controlled parameters were not established or maintained.

Criterion L.4 requires, in part, an immediate report (within one hour) for any infractions, losses, compromises, or possible compromise of classified information or c;assified documents.

h Contrary to the above, investigation and reporting activities were not performed in i

y accordance with the written procedure, Specifically, the certificatee failed to determine l

. .the reportability of the event and notify the appropriate NRC office within the time L l requirement shown in Appendix D in the following examples- i 4

9712170076 971209

- PDR ADOCK 07007001

-C PDR

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m Notice of Violation 2 1

A. On October 17,1997, an event occurred causing a loss of power (tripped breaker) ,

for the Building C-310 high-voltage process gas leak detection system alarms -

required by TSR 2.3.4.4 to be operable and available to mitigate the consequences i - of an accident (release) and for which there was no redundant equipment. The - '

certificate did not report the event until October 20,1997, a period exceeding the 24-hour reporting requirement of Cdterion J.1.a.

I On October 18,1997, an event occurred causing a loss of power (tripped breaker):

for the Building C 310 high-voltage process gas leak detection system alarms required by TSR 2.3.4,4 to be operable and evalfable to mitigate the consequences of an accident (release) and for which there was no rotundant equipment. The certificate did not report the event until October 21,1997, a period exceeding the .

24-hour reporting requirement of Criterion J.1.a B. On November 10,1997, the certificatee discovered that the criticality safety ,

l analysis for the Freon and uranium hexafluoride separation system, an operation l (hat complies with the double contingency principle and in which moderation is used as the primary criticality control, was deficient in that it did not establish the i

controlled parameters for the holding drums associated with the system. The certificateo did not report the condition until November 19,1997, a period exceeding the four-hour reporting requirement of Criterion A.2.c.

- C. On November 18,1997, at approximately 5:15 p.m., the certificateo discovered an infraction of classified information controls in that a classified document was improperty_ shredded in an unapproved device. The certificatee did not repost the infraction until approximately six hours later, a period exceeding the one-hour reporting requirement of Criterion L.4.

l This is a Severity Level IV violation (Supplement VI). (VIO 70-7001/97011-01a,b,c) i 2. Technical Safety Requirement 3.10.5 requires, in part, that the Plant Operations Review Committee be used to conduct reviews of all nuclear criticality safety evaluations and approvals.

! Contrary to the above, as of November 7,1997, the Plant Operations Review Committee was not used to conduct a review of a change causing a decrease in the approved -

l margin of safety documented in the nuclear criticality safety evaluations for use of fissile

- waste drums, due to approval of drum wall thicknesses less than the minimum value .

- previously assumed by the nuclear criticality safety staff. (VIO 70 7001/9701106)

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3. - Technical Safety Requirement 3.11.2, requires, in part, that all operations involving uranium enriched to 1.0 weight percent or higher and 15 grams or more of uranium-235 be based upon a documented nuclear criticality safety evaluation and performed in

accordance with a documented nuclear critic.ality safety approval.

Contrary to the above, from March 3 through November 19,1997, operation of the -

Building C 335 Freon and uranium hexaflouride system holding drums in a standby mode, L

- while containing Freon and uranium hexafluoride enriched to greater than one weight l

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i Notice of Vioiction 3

. percent in uranium 235, was performed without a documented criticalety safety evaluation or approval. (VIO 70 7001/9701107) i! 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 -

, _ Regulatory Commission, 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 clearty marked as a " Reply to a Notice of Vdation" 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 victations, and (4) the date when full compliance will be achieved. Your response may reference or include previously docketed correspondence, if the L 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

, 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 will be given to extending the response time, Because your response will be placed in the NRC Public Document Room (POR), 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 piease provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your q response that deletes such information, if you request withholding of such material, you mMal specifically identify the portions of your response that'/ou seek to have withheld and provide in detail the bases for your claim of withholding (for exernple, explain why the disclosure of -

p information will create an unwarranted invasion of pe,'sonal privacy or provide the information required by 10 CFR 2.79C(b) to support a request fot withholding confidential commercial or financial information). If safeguards information is nacessary to provide an acceptable response, c please provide the level of protection described in 10 CFR 73.21.

Dated at Lisle, Illinois i this 9th day of December 1997 i

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