ML20199K302
| ML20199K302 | |
| Person / Time | |
|---|---|
| Site: | Paducah Gaseous Diffusion Plant |
| Issue date: | 11/26/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20199K285 | List: |
| References | |
| 70-7001-97-12, NUDOCS 9712010075 | |
| Download: ML20199K302 (2) | |
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United States Enrichment (;orporation Docket No. 70 7001 Paducah Gaseous Diffusion Plant Certificate No GDP.1 During an NRC inspection conducted from October 6 to October 10,1997, one violation of NRC requirements was identified, in accordance with the
- General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG 1600, the violation is listed below:
Technical Safety Requirement 3.9, requires, in part, that written procedures shall be implemented for activities described in the Safety Analysis Report, Section 6.11.4, and listed in Appendix A to Section 6.11.
Safety Analysis Report, Section 6.11, Appendix A, describes a partiallist of activities that shall be covered by wsitten procedures including work control, management control, chemict.; safety, and radiation protection.
Procedure CP2-SH-SH1031, " Confined Space Program," required, in part, that work activities conducted in confined spaces, shall be conducted in accordance with an approved and issued confined space or confined space downgrade certificate. Confined space downgrade Certificate Number 97 335-18 required the buddy system, an employee stationed outside the confined space, be implemented for work activities in Building C-335, Un!t 4, Cell 8. In addition, if a worker stationed outside the confined space was not in visual contact with the entrants, one of the entrants had to heve a plant radio.
Procedure CP2 GP-GP1032,
- Maintenance Work Activities," required, in part, that maintenance work packages undergo a management review prior to release for maintenance work activities to ensure the maintenance work package instructions were adequate.
Procedure CP2 SH-lH1036,
- Respiratory Protection Program," required, in part, that if respiratory protection equipment allowed, the respirator wearer performed a negative and positive pressure fit check for 10-seconds each, to verify the respirator seal each time the respirator is donned or adjusted.
Contrary to the above, maintenance and work control activities were not performed in accordance with documented procedures appropriate to the circumstances in the following examples:
a.
On October 7,1997, engineering troubleshooting activities in Building C-335 Unit 4 Cell 8, were performed in a downgraded confined space without having an employee stationed outside the downgraded confined space entry. The entrants into the downgraded confined space were also out of visual contact and did not take a plant radio into the downgraded confined space, b.
On October 10,1997, Maintenance Work Package (MWP) No. R9702287, for installing Building C-360 autoclave conductivity cell time delays, was available for maintenance work and did not reference an appropriate test and acceptance criteria procedure for the post maintenance test of the 30 second time delay modification.
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The MWP had been reviewed by management and was issued with inadequate instructions for the post maintenance testing of the autoclave modificationc l
c.
On October 7 and 8,1997, workers did not perform a 10-second positive and negative pressure fit check on respiratory protective equipment prior to perfomiing i
maintenance and work activities. The respiratory protection equipment being used j
would have allowed the fit checks to be performed.
This is a Severity Level IV violation (Supplement VI).
(VIO 70 7001/97012 02a,b,c)
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 Ill, 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 cleady 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 previously 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 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 (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 infomiation that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you gLugl specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (for example, 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 financialinformation). 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, lhmois this 26 day of November 1997
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