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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.
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Sincerely,
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Original
Signed By: James L. Caldwell for
A. Bill Beach
Regional Administrator
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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.
NOTICE OF VIOLATION
AlliedSignal, Inc.
Metropolis, Illinois |
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Docket No. 040-03392
License No. SUB-526 |
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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
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September 6, 1996, states, in part, that plant operations
shall be conducted in accordance with written Standard Operating Procedure
Manuals.
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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.
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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.
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B. Section 2.6 of Chapter
2, "Operating Procedures," of the supplement dated
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September 6, 1996, states,
in part, that plant operations shall be conducted in accordance with
written Standard Operating Procedure Manuals.
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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.
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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.
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C. Section 5.5 of Chapter
5, "Standby Utilities," of the supplement dated |
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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.
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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.
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D. Section 2.8 of
Chapter 2, "Investigations and Reporting," of the application dated
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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.
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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.
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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.
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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.
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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.
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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:
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(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;
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(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,
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(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.
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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.
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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.
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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.
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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:
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(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;
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(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,
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(3) |
the assessment and its associated action plan were not
reviewed and approved by the Plant Manager.
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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).
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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.
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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.
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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.
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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.
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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.
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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
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