EA-98-171 - AlliedSignal, Inc.

May 5, 1998

EA 98-171

Mr. Perry Gasperini
Acting Plant Manager
AlliedSignal, Inc.
Post Office Box 430
Metropolis, IL 62690

SUBJECT:

NOTICE OF VIOLATION (NRC Inspection Report 040-03392/98003 (DNMS))

Dear Mr. Gasperini:

This refers to the inspection conducted March 2 through 6, 1998, at the AlliedSignal Metropolis Works in Metropolis, Illinois. This inspection was conducted to review activities authorized under your license and to follow up on the Augmented Inspection Team's findings as a result of the January 1998 uranium hexafluoride release. During the inspection, several apparent violations of NRC requirements were identified and are discussed in the NRC inspection report transmitted by our letter dated March 31, 1998. A predecisional enforcement conference to discuss the apparent violations, their causes, and your corrective actions was held on

April 29, 1998 in the Region III office. A summary of this conference will be sent to you by separate correspondence.

Based on the information developed during the inspection and the information provided during the conference, the NRC has determined that violations of NRC requirements occurred. These violations are cited in the enclosed Notice of Violation (Notice) and the circumstances surrounding them are described in detail in the subject inspection report. Specifically the violations involve Allied's failure to: (1) evacuate the PP-5 line on the No. 2 low boiler condenser and close the appropriate valves; (2) shut down the Distillations Hastings Heater as required; (3) maintain a standby generator; (4) report the loss of the standby generator; (5) prohibit the release of items contaminated with natural uranium in levels exceeding license requirements; (6) calibrate radiation survey instruments at the required intervals; (7) comply with the requirements for performing a chemical hazard assessment; (8) execute the response measures for a uranium hexafluoride release; and (9) have a mechanical integrity program in place before beginning operation of the Deconversion of Uranium Hexafluoride Pilot plant.

Collectively, these violations are of significant concern to the NRC because they are indicative of inadequate management attention to many aspects of your NRC licensed program. The lack of management oversight is evidenced by the fact that procedural adherence was not clear and, in some cases, had been eroded through general acceptance of site practices that contradicted established, license referenced procedures. As a result, on January 27, 1998, workers were physically injured while performing tasks in a manner contrary to established procedures. Fortunately, the workers were not seriously injured and the incident did not cause members of the public to be unnecessarily exposed. It is essential that the NRC be able to maintain the highest confidence that licensees, such as AlliedSignal, Inc., that are entrusted with handling large quantities of source material will comply fully with applicable regulatory and license requirements. The potential hazard to public health and safety of this type of operation, as well as AlliedSignal's failure to identify these problems through its self assessment programs, further heightens the safety and regulatory significance of these violations. Despite the minimal safety consequence of the event, the violations demonstrate a significant lack of oversight and control of licensed activities. As such, the violations in the Notice have been classified in the aggregate 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 $5,500 is considered for a Severity Level III problem. Because your facility 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.B.2 of the Enforcement Policy. Based on the corrective actions taken following the inspection and those actions identified during the predecisional enforcement conference, credit for Corrective Action is warranted. Besides addressing each of the individual violations, the corrective actions planned and/or taken to address the root causes include: (1) re-instruction of the management and supervisory staff on license requirements; (2) review and revision of critical procedures following plant walkdowns; (3) specialized training for qualified operators to enhance the on-the-job training program; (4) addition of resources in the areas of management and engineering to enhance procedure development and adherence, and reduce competing production demands for key individuals; (5) development and implementation of checklists for critical procedures; (6) increasing the number of audits of high-risk activities focusing on actual in-field performance; (7) establishment of new policies for the performance of the process hazard analyses; and (8) conducting meetings with all plant staff prior to starting operations after the annual shutdown in May to communicate management's expectation for strict procedure adherence.

Therefore, to encourage prompt and comprehensive correction of violations and in recognition of the absence of previous escalated enforcement action, I have been authorized, not to propose a civil penalty in this case. However, the NRC is very concerned about the number of previous violations and releases documented in inspection reports dating from 1995 to the present which represent missed opportunities to address the root causes for the issues raised in our latest inspection report. The problem with procedure development and adherence was also addressed in the Licensee Performance Review conducted in June 1997. Because of the importance the NRC places on prompt identification of problems by licensees, the use of discretion to propose a civil penalty was considered. In the final analysis, the NRC concluded that your corrective actions identified above are comprehensive and, if fully implemented, should address the root causes of the violations. Nevertheless, you should be aware that issuance of this Severity Level III Notice constitutes escalated enforcement action and the NRC will closely monitor the progress of your corrective actions during future inspections. Any significant violations in the future could result in a civil penalty.

You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. The NRC will use your response, in part, to determine whether further enforcement action is necessary to ensure compliance with regulatory requirements.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response will be placed in the NRC Public Document Room.

 

	Sincerely,
	Original Signed By: James L. Caldwell for A. Bill Beach Regional Administrator

 

Docket No. 040-03392
License No. SUB-526
Enclosure: Notice of Violation

cc w/encl: William Murrell, President
AlliedSignal Energy Services

SLO:RIII
PAO:RIII
DNMS (3)
OCFO/LFARB w/o encl.

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NOTICE OF VIOLATION

AlliedSignal, Inc. Metropolis, Illinois		Docket No. 040-03392 License No. SUB-526
		EA 98-171

 

During an NRC inspection conducted on March 2 through 6, 1998, 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:

Condition 10 of Materials License SUB-526 requires that licensed material be used in accordance with statements, representations, and conditions in Chapters 1 through 7 of the application dated July 11, 1994, and specified supplements and letters.

 

A.  Section 2.6 of Chapter 2, "Operating Procedures," of the supplement dated
	September 6, 1996, states, in part, that plant operations shall be conducted in accordance with written Standard Operating Procedure Manuals.
	Section 10.4.9(5) of the Vessel Washing Procedure in the Distillation Manual, a standard operating procedure manual, requires, in part, in preparation for removing the blank, the inboard valve on the PP-5 line on the "on-line condenser" be closed and evacuated for approximately 15 to 20 minutes to assure UF6 evacuation. Then, open the inboard and outboard valve on the PP-5 on the condenser to be hooked up and evacuate for approximately 10 to 15 minutes, then close the inboard and outboard [valves] on the condenser to be hooked up.
	Contrary to the above, on January 27, 1998, operations personnel failed to evacuate the PP-5 line on the "on-line condenser" for 15-20 minutes; failed to evacuate the PP-5 line on the Number 2 Low Boiler Condenser for the 10-15 minutes; and, failed to close the inboard and outboard valves prior to opening the flange to remove the blank. Specifically, each PP-5 line was evacuated for no more than five minutes and both the inboard and outboard valves were left partially open.
B. Section 2.6 of Chapter 2, "Operating Procedures," of the supplement dated
	September 6, 1996, states, in part, that plant operations shall be conducted in accordance with written Standard Operating Procedure Manuals.
	Section 10.4.2 of the Distillation Manual, a standard operating procedure manual, requires, in part, the Distillations Hastings Heater to be shut down during line openings on the UF6 low boiler condensers on the sixth floor of the Feed Materials Building.
	Contrary to the above, on January 27, 1998, during a line opening for the blank removal from the Number 2 Low Boiler Condenser on the sixth floor of the Feed Materials Building, operations personnel did not shut down the Distillation Hastings Heater.
C. Section 5.5 of Chapter 5, "Standby Utilities," of the supplement dated
	September 6, 1996, requires, in part, that standby utilities are maintained in order to facilitate a safe and orderly shutdown of the process units during a complete power failure. Standby electrical power is provided by an electrical generator located in the Powerhouse building.
	Contrary to the above, between approximately 12:10 a.m. CST on March 1, 1998, until approximately 8:00 a.m. CST on March 2, 1998, standby utilities were not maintained in that the standby electrical generator was not available to facilitate a safe and orderly shutdown of the distillation and fluorination processes. Specifically, the standby generator failed during a complete power failure on February 28, 1998, and was not replaced until March 2, 1998.
D.  Section 2.8 of Chapter 2, "Investigations and Reporting," of the application dated
	July 11, 1994, requires, in part, the Plant Manager or his designee to report incidents which are reportable to the NRC in accordance with the Health Physics Procedure.
	Section 3.2.2 of the Health Physics Procedure, "Procedure for Reporting Radioactive Materials Incidents to the Nuclear Regulatory Commission," requires that a failure of the plant emergency generator be reported to NRC via telephone within 24 hours of discovery of such an event.
	Contrary to the above, a failure of the plant emergency generator occurred and was not reported to NRC via telephone within 24 hours of discovery of such an event. Specifically, the plant staff discovered that the emergency generator failed at approximately 12:10 a.m. CST on March 1, 1998, following an interruption in the electrical power to the distillation and fluorination plants, and notification to the NRC was not made until 4:17 p.m. CST on March 3, 1998.
E.	Section 1.6.3 of Chapter 1 of application dated July 11, 1994, requires, in part, that release of equipment or packages from the plant site shall be in accordance with "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated April 1993.
	Table 1 of the "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," specifies that the acceptable surface contamination levels for equipment contaminated with natural uranium and associated decay products are: (a) a maximum of 15,000 disintegrations per minute per 100 square centimeters or less for total alpha or beta-gamma contamination; and (b) a maximum of 1,000 disintegrations per minute per 100 square centimeters or less for removable alpha or beta-gamma contamination.
	Contrary to the above, on February 18, 1998, the licensee released equipment from the plant site that was not in accordance with "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material," dated April 1993. Specifically, pigtail gaskets contaminated with natural uranium were released on two separate shipments to the Paducah Gaseous Diffusion Plant which exceeded the maximum levels of total or removable beta-gamma contamination in the following examples:
	(1)	A gasket containing total beta-gamma contamination of 35,000 disintegrations per minute per 100 square centimeters or less (exceeding the limit of 15,000) was released;
	(2)	A gasket containing removable beta-gamma contamination of 10,500 disintegrations per minute per 100 square centimeters or less (exceeding the limit of 1,000) was released; and,
	(3)	A gasket containing removable beta-gamma contamination of 8,400 disintegrations per minute per 100 square centimeters or less (exceeding the limit of 1,000) was released.
F.	Section 3.2.4 of Chapter 3, "Radioactivity Measurement Instrumentation," of the supplement dated September 6, 1996, requires, in part, that Geiger-Counter instruments routinely used in radiation surveys be calibrated on a quarterly frequency or immediately before use. In addition, appropriate check sources are available to monitor instrument response during use.
	Contrary to the above, as of March 4, 1998, certain Geiger-Counter instruments were not calibrated on a quarterly frequency or immediately before use as required. Specifically, a Victoreen 190, Serial Number 2034 Geiger-Counter routinely used to perform radiation surveys for contaminated tank entries, had not been calibrated since July 31, 1996. In addition, no check source was available or in use to monitor instrument response for an Eberline 600, Serial Number 891 Geiger-Counter routinely used since November 1997 to perform radiation surveys of ore concentrates shipments.
G.	Section 5.4 of Chapter 5, "Chemical Safety Plan (CSP)," of the supplement dated September 6, 1996, requires the plant (AlliedSignal Metropolis Plant) to comply with the specific elements of the CSP as described in Chapter 13.4. Section 13.4.2 of Chapter 13.4, "Chemical Hazard Assessment," states, in part, that the plant hazard assessment team is composed of an engineer (usually the team leader) from the Technical area who is trained in and has experience in the "What If" methodology. The results of the assessment (Action Plan) are reviewed by the Process Safety Management Steering Committee to assure that plant policy was followed in the completion of the document. The assessment with action plan is reviewed and approved by the Plant Manager.
	Contrary to the above, as of March 5, 1998, the licensee did not comply with all of the elements of the CSP for performing a plant hazards assessment for the Uranium Hexafluoride Deconversion Pilot Plant in the following examples:
	(1)	the plant hazard assessment team for the Deconversion Pilot Plant did not have anyone who was trained in or had experience in performing chemical hazard assessments on it;
	(2)	the results of this preliminary chemical hazard assessment were not reviewed by the Process Safety Management Steering Committee to assure that plant policy was followed; and,
	(3)	the assessment and its associated action plan were not reviewed and approved by the Plant Manager.
H.	Condition 11 of License No. SUB-526 requires, in part, that the licensee maintain and execute the response measures in the Radiological Contingency Plan (Emergency Plan) dated August 15, 1993, or as provided by the licensee consistent with 10 CFR 40.35(f).
	Appendix A, Step 3 of the revised Radiological Contingency Plan dated June 1996, requires the Control Room Officer to ensure that all the items on the Instructions for UF6 Release Control have been completed.
	The "Instructions for UF6 Release Control" dated June 6, 1991, requires, in part, that the following measures be completed in response to a release: activate the fire and disaster alarm; shut down the Distillation Exhaust Fan (SW-28); shut down the building [Feed Materials Building] exhaust fans; and, shut down the mudball feed and water supply.
	Contrary to the above, on January 27, 1998, the Control Room Officer did not ensure that all items listed in the Instructions for UF6 Release Control were completed. Specifically, the fire and disaster alarm was not activated; the Distillation Exhaust Fan (SW-28) was not shut down; the building exhaust fans were not shut down; and the mudball feed and water supply was not shut down in response to a release of UF6.
I.	Condition 15 of License No. SUB-526 requires that the Metropolis Works PSM (Process Safety Management) mechanical integrity program be in place before the Uranium Hexafluoride Deconversion Pilot Plant begins operation.
	Contrary to the above, the Metropolis Works PSM mechanical integrity program was not in place before the Uranium Hexafluoride Deconversion Pilot Plant began operation on February 27, 1998.

These violations represent a Severity Level III problem (Supplement VI).

Pursuant to the provisions of 10 CFR 2.201, AlliedSignal, Inc. 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 III, and a copy to the Fuel Cycle Operations Branch Chief, 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 have been taken and the results achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Your response may reference 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 this Notice, an order or a Demand for Information may be issued as to why the license 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.

Under the authority of Section 182 of the Act, 42 U.S,C. 2232, this response shall be submitted under oath or affirmation.

If you contest this enforcement action, you should also provide a copy of your response to the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, D.C. 20555-0001.

Because your response will be placed 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 identifies 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 5th day of May 1998