2011 Fuel Cycle Facilities
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On November 14, 2011, the NRC issued a Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $17,500 to Global Nuclear Fuel-Americas, LLC for a Severity Level (SL) III problem involving the failure to maintain the double contingency principle as it was compromised during the operation of the sinter test grinder and the risk of a high consequence event (criticality accident) increased. The NRC determined that five violations of NRC requirements directly related to the root causes that allowed the event occurred. Specifically, (1) on March 1, 2011, the licensee failed to ensure that a process design incorporated sufficient margins of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident was possible; (2) on March 1, 2011, the licensee failed to apply sufficient controls to the extent needed to reduce the likelihood of occurrence of a criticality, high consequence event, in the sinter test grinder HEPA filter enclosure so that, upon implementation of such controls, the event was highly unlikely; (3) on February 4, 2009, the licensee failed to verify as part of the change process that the controls selected and installed for the sinter test grinder HEPA enclosure would limit the UO2 holdup to less than 25 kgs by controlling a differential pressure across the ventilation housing to 4-inches of water or less; (4) on February 18, 2009, the licensee failed to conduct a criticality safety analysis (CSA) on the Sinter Test Grinder; and (5) on August 1, 2010, and January 23, 2011, the licensee failed to notify HVAC and the area manager and request a clean out of the effected Sinter Test Grinder Primary HEPA Filter housing transition when the survey results for the transition exceeded the action limit of 0.5 mr/hr above background.
On August 17, 2011, the NRC issued a Confirmatory Order (effective immediately) to the United States Enrichment Corporation (USEC), to confirm commitments made as a result of an Alternative Dispute Resolution (ADR) settlement agreement. During an investigation NRC identified a violation involving an incident in which an operator deliberately violated applicable radiation protection procedures. Specifically, the violation involved the failure to adhere to the requirements of a USEC Paducah procedure that requires personnel to perform a whole body frisk when exiting from areas controlled for removable contamination. In response, the USEC requested ADR in an attempt to resolve the enforcement matter. USEC agreed to take a number of actions as part of this Confirmatory Order. These actions included a prompt investigation into the incident, the conduct of multiple staff briefings by USEC-Paducah management, procedural reviews and revisions as warranted, appropriate retraining and communication of lessons learned to staff, a review of the circumstances that took place during the routine operational activities that resulted in the existence of contaminated material, and disciplinary action for the employee involved in the incident. In addition, USEC committed to enhancing new employee orientation and General Employee Training at Paducah to ensure that personnel clearly understand the consequences of deliberate acts of non-compliance with regulations or procedures, and expanding its independent, Safety Conscious Work Environment assessment to include an assessment of the safety culture components of decision making and work practices. In recognition of USEC’s proposed extensive corrective actions, in addition to corrective actions already taken, the NRC agreed to not issue a Notice of Violation, and refrain from proposing a civil penalty for this matter.
On February 25, 2011, a Notice of Violation was issued to Westinghouse Electric Company, Commercial Nuclear Fuel Division, for a Severity Level III problem which existed on and before July 23, 2010, involving three violations associated with the Integral Fuel Burnable Absorber (IFBA) Filter Press used in the waste water handling system. Specifically, the violations involved (1) the failure to establish double contingency for the IFBA filter press to protect against an inadvertent criticality as required by License Condition 6.1.1, (2) the failure to designate items relied on for safety (IROFS) to limit the risk of a high consequence event as required by 10CFR70.61(e), and (3) the failure to designate the passive engineered controls of the IFBA filter press as an IROFS as required by the license and license application based on the conclusion that the accident scenario was not credible. In addition, two Severity Level IV violations were issued involving the failure to establish adequate operating procedures for the filter press and the failure to make a change to facility equipment in accordance with approved procedures.