EA-01-285 - United States Enrichment Corporation
January 17, 2002
Mr. J. Morris Brown
Vice President - Operations
United States Enrichment Corporation
Two Democracy Center
6903 Rockledge Drive
Bethesda, MD 20187
|SUBJECT: ||NOTICE OF VIOLATION (NRC ROUTINE INSPECTION REPORT NO. 07007002/2001-008(DNMS) (PORTSMOUTH GASEOUS DIFFUSION PLANT) |
Dear Mr. Brown:
This refers to the inspection completed on October 22, 2001, at the Portsmouth Gaseous Diffusion Plant. This was a routine resident inspection to determine whether authorized activities were conducted safely and in accordance with the NRC's rules and regulations and with the conditions of your certificate. Based on the results of the inspection, we identified apparent violations involving the loss of criticality control for a large fissile material deposit which was greater than safe mass and greater than critical mass. The inspection report was issued to you in a November 16, 2001, letter. On December 14, 2001, a predecisional enforcement conference was conducted in the Region III office with you and members of your staff to discuss the apparent violations, their significance, their root causes, and your corrective actions.
Based on the information developed during the inspection and the information that you provided during the conference, the NRC has determined that violations of NRC requirements occurred. The violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report. On May 26, 2001, the plant staff established a dry air buffer greater than 14 pounds per square inch absolute (psia) on a greater than safe mass deposit in piping associated with shutdown Cell 31-5-8. The involved piping had been isolated along with shutdown Cell 31-5-8 with the buffer pressure monitored from the Cell. On September 22, 2001, plant staff identified the loss of the dry air buffer in the involved piping and thus the loss of the only criticality control for the greater than safe mass of fissile material. The pressure in the piping decreased below the required 14 psia after valves, which allowed monitoring of the mass, were inappropriately closed. The violations involved the failure to perform an adequate surveillance of the dry air buffer covering the deposit and the failure to establish and maintain configuration control of cascade cell block valves.
During the conference, you agreed with the violations as discussed in the inspection report and provided information that indicated that the root causes for these violations included the failure to ensure that adequate controls were in place to maintain valve positions and to meet surveillance requirements. In addition, based on your analysis of the greater than safe mass deposit, you determined that the deposit was greater than critical mass and that criticality was not possible in the as-found configuration.
The violations are significant because the Technical Safety Requirement (TSR) for maintaining criticality control was not met. Specifically, the surveillances conducted were inadequate to monitor the system pressure, since valve configuration was not maintained due to an inadequate valving procedure. Therefore, these violations have been categorized in accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions" (Enforcement Policy), NUREG-1600 as a Severity Level III problem.
In accordance with the Enforcement Policy, a base civil penalty in the amount of $60,000 is considered for a Severity Level III problem. Because Portsmouth has not been the subject of escalated enforcement actions within the last two years, the NRC considered whether credit was warranted for Corrective Action in accordance with the civil penalty assessment process in Section VI.C.2 of the Enforcement Policy. Credit was warranted for corrective actions that included: (1) immediately reestablishing the required dry air buffer; (2) verifying that other deposits were in compliance with the applicable TSR; (3) briefing personnel on the event and lessons learned; (4) revising several procedures to include guidance for controlling valve alignments and conducting training on valving orders; and (5) developing additional conduct of operations training to be provided to operations personnel on performing nuclear safety activities.
Therefore, to encourage prompt and comprehensive correction of violations, and in recognition of the absence of previous escalated enforcement action, I have been authorized, after consultation with the Director, Office of Enforcement, not to propose a civil penalty in this case. However, significant violations in the future could result in a civil penalty.
The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence, and the date when full compliance will be achieved, is already adequately addressed on the docket in our conference summary letter, dated December 19, 2001. Therefore, you are not required to respond to this letter unless the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to provide additional information, you should follow the instructions specified in the enclosed Notice.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response, if any, will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at the Public NRC Library.
| ||Sincerely, |
| ||/RA/ |
| ||J. E. Dyer |
Docket No. 070-07002
License No. GDP-2
Enclosure: Notice of Violation
NOTICE OF VIOLATION
|United States Enrichment Corporation Portsmouth GDP ||Docket No. 070-07002 |
License No. GDP-2
During an NRC inspection completed on October 22, 2001, 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. ||TSR 184.108.40.206, "Moderation Control," Condition B, requires, in part, that the certificatee establish a dry cover gas blanket at greater than or equal to 14 psia for a U02F2 deposit greater than safe mass with the deposit not in a fluorinating environment. |
TSR 220.127.116.11, Surveillance Requirements, requires, in part, that the certificatee monitor the system pressure and adjust the pressure to greater than or equal to 14 psia each shift when a dry cover gas blanket is required by Condition B.
Contrary to the above, sometime between May 26, 2001, and September 22, 2001, the certificatee failed to maintain the system pressure greater than or equal to 14 psia for a greater than safe mass deposit of UO2F2 and the deposit was not in a fluorinating environment. Further, surveillances conducted during the period were inadequate to monitor the system pressure and adjust the pressure to greater than or equal to 14 psia. Specifically, at an indeterminate time after May 26, 2001, certificatee personnel closed Valves 8AB1 and 8AB2 resulting in the failure to identify that the pressure decreased below 14 psia until September 22, 2001.
|2. ||10 CFR 76.93, requires, in part, that the Corporation establish, maintain, and execute a quality assurance program satisfying each of the applicable requirements of ASME NQA-1-1989, "Quality Assurance Program Requirements for Nuclear Facilities." The Corporation executes the criteria in a graded approach to an extent that is commensurate with the importance to safety. |
ASME NQA-1-1989, Section 5, "Instructions, Procedures, and Drawings," requires, in part, that activities affecting quality be prescribed by and performed in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above, as of September 22, 2001, the licensee failed to prescribe activities affecting quality in a documented procedure appropriate to the circumstances. Specifically, Procedure XP4-CO-CA2228, Revision 2, "Valving Orders," failed to adequately describe establishing and maintaining configuration control of cascade cell block valves.
This is a Severity Level III problem (Supplement VI).
The NRC has concluded that information regarding the reason for the violations, the corrective actions taken and planned to correct the violations and prevent recurrence, and the date when full compliance will be achieved, is already adequately addressed on the docket in our conference summary letter, dated December 19, 2001. However, you are required to submit a written statement or explanation pursuant to 10 CFR 2.201 if the description therein does not accurately reflect your corrective actions or your position. In that case, or if you choose to respond, clearly mark your response as a "Reply to a Notice of Violation," and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001 with a copy to the Regional Administrator, Region III, 801 Warrenville Road, Lisle, IL 60532-4351 and a copy to the NRC Resident Inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice).
If you contest this enforcement action, you should also provide a copy of your response, with the basis for your denial, to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001.
If you choose to respond, your response will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Web site at the Public NRC Library. Therefore, to the extent possible, the response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
In accordance with 10 CFR 19.11, you may be required to post this Notice within two working days.
Dated this 17th day of January 2002.
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