ML20148D371

Forwards 30-day Written Event Rept Covering Er 97-04 Which Updates & Revises Info Contained in Rept & Incorporates Total of 8 Addl Sprinkler Sys Events,Per 10CFR76.120(c)(I)

ML20148D371
Person / Time
Site:	Paducah Gaseous Diffusion Plant
Issue date:	05/16/1997
From:	Polston S UNITED STATES ENRICHMENT CORP. (USEC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
GDP-97-1007, NUDOCS 9705300179
Download: ML20148D371 (10)

Text

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e United States Enrichment Corswetion 6

Paducah Site OfYice P.O. Box 1410 Paducah, KY 42001 Tel: 502 44I.5803 Fat 502 441-5801 May 16,1997 1

i United States Nuclear Regulatory Commission SERIAL: GDP 97-1007 Attention: Document Control Desk Washington, DC 20555-001

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Paducah Gaseous Diffusion Plant (PGDP) - Docket No. 70-7001 - Event Report ER-97-04, Rev.1 i

l Pursuant to 10 CFR 76.120(c)(1), Enclosure 1 is the required 30-day written Event Report covering ER-97-04. This report updates and revises information contained in ER-97-04, which was forwarded to 4

Nuclear Regulatory Commission (NRC) on April 18,1997, and incorporates a total of eight additional l

sprinkler system events (see Enclosure 2). Information that has been updated or revised is annotated by a

" change bar" located to the right of the afTected information. The NRC was notified of each deficiency as required. Enclosure 3 is a list of commitments made in the report.

Should you require further information on this subject, please contact Bill Sykes at (502) 441-6796.

i Sincerely,

> w eve Polston General Manager Paducah Gaseous Diffusion Plant SP:WES:JLil:mel Enclosures (3) cc:

NRC Region 111 NRC Senior Resident inspector, PGDP

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i Docket No. 70-7001 Page 1 of 5 EVENT REPORT ER-97-04 (Rev.1)

BACKGROUND The Paducah Gaseous Diffusion Plant (PGDP) fire protection systems and equipment are designed to detect, contain, and suppress fires. The major process buildings at PGDP (C-331,

-333, -335, -337, -310, and -315) are constructed of unprotected steel frames, concrete floors, noncombustible exterior walls, and a built-up metal deck roof assembly. Fixed automatic fire suppression systems provide the means for the detection and control of fires at the plant. Each building is considered a single fire area. Sprinkler coverage is provided thrcughout the buildings, except for cell housings and surge drum rooms. There are no fire barriers between any units / areas in the process buildings. Combustible loading is low, except for lube oil, and the fire hazards are limited to normal industrial activities. Emergency response is provided by the on-site Fire Services Group and Emergency Squad. The plant has mutual aid agreements I

with other fire departments in the county.

As discussed in the SAR Accident Analysis (Sections 4.3.2.5.1 and 4.3.2.5.2), an unmitigated lube oil fire in the process lube oil pits, or on the cell floor, could cause failure of the structural steel followed by localized collapse cf the structure. This collapse could damage process piping allowing a release of UF. The sprinkler systems are designed to actuate in 6

sufficient time to prevent structural collapse and a potential release of UF.

6 DESCRIPTION OF EVENT On January 3,1997, a sprinkler system branch line in C-333 was discovered to be disconnected and its supply line plugged. This is the second occurrence of this nature discovered at PGDP. The first occurred on June 17,1996, and was investigated under event

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report PAD-1996-0031. A corrective action, involving a 40-sprinkler system limited scope l

l inspection, was initiated and no additional missing lines were discovered. The corrective action was closed on August 16,1996. The second occurrence (January 3,1997) was self-identified and reported as problem report PR-SF-97-0044. On January 9,1997, as a result of the second occurrence, sprinkler system walkdowns commenced in the process l

buildings. The walkdowns consisted of an examination of sprinkler systems that are visible I

and accessible from the floor. Areas in which major system modifications have been l

performed were also addressed in the walkdowns and included areas that are not visible from l

the floor. The walkdowns identified fire sprinkler systems that have disconnected / plugged l

lines or have other significant deficiencies. The walkdowns were completed on May 4,1997.

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{ is a list of additional sprinkler systems that have been identified as deficient i

during the period March 12,1997, to May 4,1997, declared events and reported to NRC, and l

included in this investigation report.

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Docket Nd. 70-7001

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Page 2 of 5 On March 18, 1997, the first report of a sprinkler system deficiency was transmitted to NRC l

(Enclosure 2). As additional deficiencies were determined to exist, the systems were declared l

inoperable. Additionally, fire patrols were initiated and at least one high pressure fire water hydrant was confirmed to be operable adjacent to the affected buildings as required by j

Technical Safety Requirements (TSRs) 2.4.4.5. The NRC-HQ Operations Office was notified of each deficiency as required by 10 CFR 76.120 (c)(2)(I). March 12,1997 was the actual date of discovery of the first sprinkler system deficiency considered in this report. A l

disconnected sprinkler branch pipe was self-identified in C-331 and a Problem Report l

initiated; however, an initial determination was made that this was not reportable to NRC.

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Subsequent evaluation determined that the deficiency was reportable and NRC was notified on l

March 27,1997.

l The sprinkler system deficiencies are attributed to lack of configuration control.

l Procedures which have been implemented provide guidance and requirements for initiating, controlling, implementing, and closing out plant modifications. Additionally, a configuration management program includes organizations, administrative process and assessments to ensure an accurate, current design documentation that matches the plant's physical configuration, while complying with applicable requirements. A work control program and procedure prescribes the methods and responsibilities for the administrative control of maintenance and modification work to "Q", "AQ-NCS", and "AQ" systems, structures, and components (SSCs).

Repairs have been initiated to have the sprinkler systems conform to configurations shown on I

existing installation drawings when appropriate. In other cases, drawing revisions and system l

modifications have been required. An Engineering Service Order (ESO) was initiated on l

March 6,1997, to restore the function of the other systems which have been impaired by the installation of systems, structures, and components (SSCs) that have obstructed, relocated, and/or eliminated sprinkler heads. The ESO will make modifications to the high pressure fire water (HPFW) sprinkler systems classified as "AQ" which are located in C-310, -315, -331,

-333, -335, and -337 buildings. Fire sprinkler heads which are incorrectly located will be restored / replaced to properly locate those sprinkler heads for correct actuation and spray pattern. Adultional heads may be required in some systems to restore the spray pattern due to obstructions. As sprinkler systems are identified which require an engineering correction, the systems will be included in the ESO to bring the sprinkler system into compliance.

During the investigation a review of randomly selected Fire Services' monthly sprinkler system inspection sheets generated during the period January 1997, to March 1997, was conducted. The review found that none of the deficiencies discovered during the current walkdown (Enclosure 2) were noted during the monthly Fire Services inspections. This may

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Docket.No. 70-7001 Page 3 of 5 be attributed, in part, to the wording contained in procedure CP4-SS-FS6111. "TSR Surveillance, Inspection, and Testing Of Wet Pipe Sprinkler Systems." Section 8.1.2 states,

" observe sprinkler heads that are accessible (without a permit) for obvious damage (such as leaking) or obstructions." Section 8.1.3 states, " observe sprinkler piping that is accessible (without a permit) for sagging or broken hangers." The Fire Services Authority Having Jurisdiction (AHJ) indicated the monthly sprinkler syst m inspections are not intended to be as rigorous as the current walkdown, and thus did not uncover the sprinkler deficiencies.

ESO, Z98400 will correct the legacy sprinkler system deficiencies which have existed for l

many years. Further, the possibility of similar events, such as those in Enclosure 2, recurring in the future has been eliminated because of the implementation of the Configuration l

Management and Work Control Programs.

CAUSES OF EVENT A. Direct Cause The direct cause of this event was the result of a failure of past construction, modincation, and l

initial installation projects to adequately regulate system modiScations due to a lack of configuration control.

B. Root Cause The root cause of these events was a failure to have effective programs in place relative to configuration management and work control. Existing procedures will preclude similar events l

in the future.

C. Contributing Cause A contributing cause was a failure to have an effective program to self-identify, report, and repair problems, such as safety equipment deficiencies.

CORRECTIVE ACTIONS A. Completed Corrective Actions

1. From January 9,1997, to February 13, 1997, Fire Services personnel received additional training relative to the sprinkler systems, including proper methods of walkdown inspection. The training included a tour of the process buildings to view the sprinkler systems and to reinforce classroom discussions.

2. On March 27,1997, corrective actions for the deficient systems were certified for construction under ESO Z98400.

.p' Docket No. 70-7001 Page 4 of 5

3. On May 4,1997, Fire Services completed walkdowns of sprinkler systems that are l

visible and accessible from the Door. Areas in which major modifications have been l

performed were also addressed in the walkdowns and included areas that are not visible l

from the floor.

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4. On May 15,1997, the results of the walkdown were documented.

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5. Effective March 31,1997, procedure UE2-EG-CF1032, " Configuration Management Program" was implemented.

6. Effective October 31,1995, procedure UE2-TO-EG1031, " Modification Design Control" was implemented.

7. Effective April 1,1996, procedure UE2-HR-CIl030, " Problem Reporting" was implemented.

8. Effective December 11,1996, procedure CP2-GP-GP1032, Rev.1, " Work Control Process" was implemented.

NOTE: The procedures listed above are intended to reflect the latest editions, not necessarily the first date of publication.

B. Planned Corrective Actions

1. By December 12,1997, sprinkler system deficiencies will be identified and l

appropriately dispositioned.

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2. By July 1,1997, Engineering will update modification drawings affected by required l

medifications as a result of sprinkler system deficiencies corrected under ESO Z98400.

The drawings will be "as built" to reflect true field configuration in accordance with approved plant procedures.

3. By August 25,1997, procedure CP4-SS-FS6111, "TSR Surveillance, Inspection, and Testing of Wet Pipe Sprinkler Systems," will be revised to include more detailed inspection criteria. Included will be a requirement to look for missing sprinkler piping, as well as damaged or incorrectly oriented sprinkler heads. Lessons learned as a result of the current walkdown effort will be included in the procedure revision.

I Docket No. 70-7001 Page 5 of 5 l

i LESSONS LEARNED Installation or modif'ication to equipment / machinery, or construction in the vicinity of safety j

equipment, can adversely impact the ability of the safety system to perform its intended function. This potential for safety system degradation, or failure, must be considered and thoroughly coordinated prior to initiating the intended project.

EXTENT OF EXPOSURE OF INDIVIDUALS TO RADIATION OR TO RADIOACTIVE MATERIALS None.

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.l Docket No. 70-7001 Page 1 of 3 i

SPRINKLER SYSTEM DEFICIENCIES (AS OF MAY 4,1997) 4 t

. NRC EVENT EVENT PROBLEM LOCATION j

_E(L DATE i

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l Not Assigned 3/12/97 Sprinkler system 33 branch line C-331 l

l not connected to main header.

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I 31972 3/18/97 Sprinkler system C-2 head C-337 l

obstructed by steel beams.

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32002 3/22/97 Sprinkler system 21 heads C-331 l

l on a branch line installed l

incorrectly (45 degrees l

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from vertical) and one head was j

obstructed by a light fixture.

l Sprinkler System 29 head obstructed l

by utility piping system.

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32012 3/24/97 Sprinkler system C-10 heads C-337 l

on a branch line incorrectly l

spaced.

l Sprinkler system B-16 branch C-337 l

line did not provide adequate l

coverage.

l Sprinkler system C-2 branch C-333 l

line did not provide adequate l

coverage.

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i 32026 3/26/97 Sprinkler system 17 missing C-331 l

branch line.

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32080 4/3/97 Sprinkler system B-9 branch C-333 l

line disconnected.

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32148 4/14/97 Sprinkler system A-5 branch C-337 l

line not connected.

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Docket No. 70-7001 Page 2 of 3 j

NRC EVENT EVENT PROBLEM LOCATION j

NO.

DATE i

32162 4/15/97 Sprinkler systems D-1, D-5, B-1, C-337 l

I D-9, D-13, B-13, B-9, B-5, B-4, l

4 C-1, C-5, C-9, C-13, branch lines l

installed, but never connected to l

ll fire water supply.

l Sprinkler systems A-1, A-5, A-9, C-333 l

q A-5, A-13, C-13, B-9, B-5, B-1, l

j branch lines, installed, but never l

connected to fire water supply.

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j 32170 4/16/97 Sprinkler systems 31 and C-331 l

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3 branch lines not connected l

to water supply.

l Sprinkler systems A-1, A-5, C-337 l

l A-9, and A-13, branch lines l

I not connected to water supply.

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l 32215 4/23/97 Sprinkler system B-4 branch C-333 l

I line missing.

l Sprinkler system A-4 excessive C-333 l

l number of heads; too close l

l together; upright sprinkler heads l

not installed with frames parallel l

to their branch line; two upright l

sprinkler heads installed at an I

angle to their required vertical l

positions; sprinkler head missing; l

5 three pendent sprinkler heads in l

3 upright position.

I Sprinkler system C-5 sprinkler C-333 l

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head missing; three sprinkler l

heads too close together; one l

head is an upright sprinkler installed l

in a horizontal position.

l l-Sprinkler system coverage is C-333 l

not provided in a display cell l

l observation room; display cell l

enclosure; health physics trailer; I

maintenance trailer; under equipment l

l access platform with grating deck (3).

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- Docket No. 70-7001 l

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NRC EVENT EVENT PROBLEM LOCATION l

M DATE l

l 32222 4/24/97 Sprinkler system coverage is C-337 l

1 not provided in conference l

room vestibule; health I

physics trailer; maintenance l

I trailer; under equipment access l

platforms (8); under wire mesh l

roof of storage cages (3).

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32231 4/27/97 Sprinkler system 1 branch line C-315 l

has three sprinkler heads missing, l

and another branch line has all I

sprinkler heads installed too far i

from the ceiling.

I Sprinkler system A-5 did not have C-337 l

flow restricting orifices on an l

inspector test connection.

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32252 4/30/97 A majority of the sprinkler system C-315 l

heads installed on the second floor l

of the building were located too far l

from the ceiling.

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32268 5/1/97 Sprinkler system 3 branch line C-331 l

missing; sprinkler system 31 had i

three upright sprinkler heads installed l

approximately 60 degrees from vertical.

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Sprinkler system 27 not providing C-335 l

j protection under a process gas piping l

enclosure.

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32278 5/4/97 Sprinkler system I heads in the C-315 l

ground floor withdrawal room l

obstructed. Ventilation duct is over l

4 feet wide and requires a sprinkler i

head below the duct; Sprinkler system l

l 1 heads obstructed above lube oil l

drain tank on ground floor; required l

sprinkler system protection not provided l

under stairs on second floor; Sprinkler l

system I heads area coverage reduced l

by office partitions in ACR.

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Docket No. 70-7001

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EncJosure 3 i

Page1of1 l

Event Report ER-97-04 (Rev.1)

List Of Commitments

1. By December 12,1997, sprinklet system deficiencies will be identified and appropriately l

dispositioned.

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2. By July 1,1997, Engineering will update modification drawings affected by required l

modifications as a result of sprinkler system deficiencies corrected under ESO Z98400.

The drawings will be "as built" to reflect true field configuration in accordarre with approved plant procedures.

3. By August 25,1997, procedure CP4-SS-FS6111, "TSR Surveillance, Inspection, and Testing of Wet Pipe Sprinkler Systems" will be revised to include more detailed inspection criteria. Included will be a requirement to look for missing sprinkler piping, as well as damaged or incorrectly oriented sprinkler heads. Lessons learned as a result of the current walkdown effort will be included in the procedure revision.

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