ML20198G501

Insp Rept 70-7001/97-206 on 970721-25.No Violations Noted. Major Areas Inspected:Chemical Process Safety Program Requirements

ML20198G501
Person / Time
Site:	07007001
Issue date:	08/21/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20198G500	List: ML20198G496 ML20198G501
References
70-7001-97-206, NUDOCS 9709040121
Download: ML20198G501 (10)

Text

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U.S. NUCLEAR REGULATOP,f COMMISSION C

2 Inspection Report No. 70-7001/97-206 Docket No. 70-7001 Facility Operator: _ United States Enrichment Corporation Facility Name: Paducah Gaseous Diffusion Plant Observations At* LPaducah,KY Inspection Conducted: July 21-25,1997 Inspector: William Troskoski, FCOB Approved By: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety

. and Safeguards, NMSS ,

Enclosure 9709040121 970821 PDR ADOCK 07007001 C. PDR a

2 EXECUTIVE

SUMMARY

PADUCAH GASEOUS DIFFUSION PLANT NRC INSPECTION REPORT 70 7001/97-206 hkcduction NRC performed a routine, announced chemical process safety inspection of the U.S.

Enrichment Corporation (USEC) Paducah Gaseous Diffusion Plant (PGDP) at Paducah, KY, from July 2125,1997. The broad objective of this inspection was to ensure that the chemical process safety program requirements contained in the certificate were being effectively implemented to control chemical hazards at PGDP. Major programmatic elements reviewed included:

- Process Safety Information

. Hazard Identification & Assessment

. Auctit and Inspections

. Chemical Safety Mechanical Integrity Program

. Third-Party Use of Hazardous Chemicals

. Recommissioning inactive Equipment Summarv

1. Process Safety Information (PSI) was complete and well organized. However, items identified in the PSI Safety Limits and Safety Component sections had riot been systematically included in various facility maintenance and inspection programs, due in part to the "AQ' nature of their classification. Facility response was timely.

2. The conduct and content of the Process Hazards Analysis (PHA) appeared adequate and covered the required hazardous chemicals. However, not all of the PHA identified i preventive measurn were identified as e,ch in the preventive maintenance schedu6.

3. Audit plans for the comprehensive triennial audit of the chemical safety program appear to be comprehensive.

4. A comprehensive mechanical integrity program has been established for the required systems and confirmed an adequate margin of safety for the confinement systems.

5. An appropriate mechanism has been established to inform USEC of all current and future uses of hazardous chemicals so that the impact on nuclear operational safety can be evaluated.

G. There does not appear to be an established mechanism for the formal deactivation and reactivation of components.

3 DETAILS 1.0 Process Safety Information (88056)

a. Inspection Scope The inspector reviewed the facility system for the development and maintenance of process safety information (PSI), including methods for the identification of potential hazards requiring detailed hazard assessments. Document reviews and discussions with responsible personnel were conducted to verify that descriptions of the physical and chemical hazards of materials used in the process had been developed and maintained up-to-date, safety-related equipment information was complete, and safe operating limits for process parameters existed. Documents reviewed included:

. CP2-SH-IS1061, Process Safety Management of Highly Hazardous Chemicals, Revision 0, effective March 25,1997.

. KY/S 257 PGDP Process Safety Information for the Water Treatment Plant, Pump House Chlorination Systems, and Cl2 Container Storage Yards, Revision 1, dated March 24,1997.

. Process Safety Information for the Fluorine System, dated April 25,1997.

. Process Safety information for the Chlorine Trifluoride System, dated April 25, 1997.

b. Observations and Findings in general, the inspector noted the above PSis appeared to be well organized and complete Walkdowns of selected portions of each of the three chemical systems identified no inadequacies with the information identified in each PSI. Specific inspector observations related to each of the PSis are as follows:

Chlorine (Cl2) System 4 Section 3.5 of the Cl2 PSI identified various container and process

• safety limits" related to the process safety management of this hazardous material system. The inspector conducted discussions with responsible plant personnel to verify that each of the specified safety limits had been adequately addressed in applicable operating, maintenance; or test procedures. The design and fabrication specifications for the Cl2 cylinders were developed from Department of Transportation's (DOT) Specification 106A500X. A review of vendor contracts determined that this standard was a referenced requirement.

The PSI stated that 'the gaseous withdrawal rate from one container (cylinder) should not exceed 450 pounds per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 900 pounds per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from two containers feeding in parallel." Review of plant operating procedures revealed that this limit was

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incorporated into CP4-CU UW2420 for the Building 611 chlorinators, but not into CP4 -

CO-CA2018 for the pump house chlorinators. Subsequent investigation by facility personnel determined that the current pump i ouse chlorinator ccqfigurations were only capade of feeding about 350 pounds per day. The limit was determined to have been an operational restriction as opposed to a true safety limit. The inspector was subsequently informed that the operational restriction would be added to CP4-CO-CA2018, because a future modification was planned that could increase the chlorinator capacity.

The PSI also indicated that "the pressure-vacuum relief valve, which is a primary compe lent of both the V-75 and V-800 Chlorinators, is designed to open and vent to the atm . here at: 35-40 inches water vacuum, and 1-2 inches of water pressure."

Discussions with plant personnelindicated that the relief valves had not been functionally tested or calibrated. The inspector was subsequently informed ; hat the relief valves would be added to the preventive maintenance (PM) program and incorporateo into the mechanicalintegrity program, and that the pressure regulators would also be added to the PM program.

Fluorine (F2) System The inspector reviewed the items identified as " Safety Systems" in Section 4.8 of the PSI and conducted a system walkdown with plant personnel to verify that the equipment was installed and functional. The rupture discs at tanks FE 375-A, B and -C were found to be installed, and the isolation valves were opened with seals installed as an administrative control. All but one disc had a tab indicating that its burst pressure was consistent with the 80 pound limit. A subsequent record review verified that the one disc with the missing tab had come from the same lot and had been installed at the same time as the other rupture discs. Facility personnelindicated that the tab would be replaced.

The inspector also verified that the "T" handle lazy rods were installed at C-410-D and that the remote cylinder valve operators were in place at C-410-K.

Section 4.8.6 of the PSI states that " valve CV-30 is a piloted, pneumatically operated safety valve. When the pressure in the west tank is greater than 12.5 psia, a pressure switch opens... which in turn causes valve CV-30 to close. This action prevents further introduction of gas into the west tank." When questioned as to haw the plant demonstrated the operability of this component, the inspector was informed that an

" informal" functional test had been performed about 18 months earlier, but that there was no approved functional test procedure.

. Chlorine Trifluoride (CIF3) System Section 4.8.4 of the CIF3 PSI states that " valve CV-5 is a piloted, pneumatically operated safety valve. When the pressure in the east tank is greater than 12.5 psia, a pressure switch opens... which in turn causes valve CV-5 to close. This action prevents further introduction of gas into the east tank." The inspector was informed that this l

5 valvo had Wso received an

• informal" functional test about 18 months earlier, but there was no approved functional testing procedure to periodically demonstrate operability.

As plant management was planning to bring the C-350 Building processes, which include the F2 and CIF3 systems, off line for about two days in the near future in order to complete a modification, the inspector requested that an evaluation be conducted to determine the need for conducting an approved functional test of the CV-5 and CV-30 valves prior to restart of the F2 and CIF3 systems. Plt.nt management acknowledged the inspector's concern at the exit meeting. During a subsequent telephone call on August 14,1997, the inspector was informed that both CV 5 and CV-30 would be functionally tested prior to restart of the 350 Building, and a poriodic functional test established. This action was being taken notwithstanding the fact that these components were considered to be "AQ" items nder the Compliance Plan and not formally scheduled to be added to the various plant programs until 1998.

c. Conclusions The PSI documents reviewed appeared to be well organized and complete. However, items identified in the PSI Safety Limits and Safety Component sections had not been systematically included in the various facility maintenance and inspections programs prior to the inspection. Subsequent facility follow up appeared responsive and timely.

2.0 Hazard identification & Assessment

a. Inspection Scope .

The inspector reviewed the facility system for managing chemical hazards under the Process Safety Management (PSM) and the Industrial Safety and Health programs to ensure that all materials with a catastrophic potential were identified and analyzed.

Process Hazards Analyses (PHA) for covered chemicata were reviewed for technical content and to ensure that the PHA reflected current plant conditions. Documents reviewed included:

KY/S-263, PGDP Process Hazard Analysis for Water Treatment Plant and Pump House Chlorination Systems, Revision 1, dated May 1996.

. K/GDP/SAR/SUB-23, PHA for PGDP - USEC Balance of Plant Facilities (F2, CIF3), dated March 1996.

b. Observations and Findings SAR 5.6.13.3, Chemicals Addressed by Process Safety Management, identifies three -

chemicals on-site that are listed under the OSHA PSM standard: chlorine (Cl2),

fluorine (F2), and chloride trifluoride (CIF3). Of these chemicals, only Cl2 is currently above the process safety management threshold value that requires a formal PSA. The other two chemicals are under the threshold quantities.

6 Review of the Cl2 PHA content identified no concerns with the structure or content.

Table A-1 identified various release mechanisms and prevention criteria that were generally consistent with the information in the PSIs. The inspector did note that in addition to the various components identified as having a safety function in the PSI, the PHA also required periodic inspections of hoists and lifting fixtures used to tr.ove the Cl2 cylinders. Review of the periodic test reports and PM data packs revealed that the two-ton monorail cranes used in the C-611 S and C-611-B buildings were past their annual inspection. Facility personnel initiated a problem report and tagged the cranes out-of-service. Subsequent review determined that although the two crane PMs were still within a 25% grace period for performing the annualinspection, the _ inspection had been missed because it had not been identified as being required by either the TSRs or the PSM program. The inspector was informed on August 14,1997, that the inspections had now been added to the data base.

The PHA noted that a number of recommendations were made following a 1995 system walkdown that had not been implemented by the time a 1996 system walkdown was conducted. Discussions with plant personnelindicated that each item was either being actively tracked by engineering and compensatory measures taken, or had been corrected.

With regard to the F2 and CIF3 systems, the inspector was informed that plans were under development to add these systems to the formal PSM program in order to remove the inventory restrictions and provide for greater operational flexibility in the future. In preparation for this action, an cutside contractor conducted a preliminary review and one modification was identified as being needed to complete the conversion since all of the applicable administrative programs and controls had been established.

c. Conclusions The conduct and content of the completed PHAs appeared to be adequate and covered the required hazardous chemicals. However, not allidentified preventive measures ware identified as PSM requirements in the PM schedules.

3.0 Audit and Inspection

a. Inspection Scope The facility audit and inspection program was reviewed to determine whether an adequate management system had been developed and implemented to assure that chemical safety procedures and practices were being followed and maintained.

b. Observations and Findings SAR 5.6.9 commits to including the chemical safety function under the audit and assessment program described in Section 6.8. This section in turn commits to completing a comprehensive program oversight at least once every three years, which is consistent with the OSHA PSM rule. The inspector requested a copy of the latest

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7 audit used to meet the SAR commitment and was provided with KP-ES 96-A136, dated February 6,1997. Review of this audit indicated that it was limited to the performance and effectiveness of the Chemical Safety and Hazard Communication Program and did not include any of the program elements referenced in Section 5.6. Subsequent discussions determined that as of the date of this inspection, the Independent Assessments Group was '.n the process of planning for their first comprehensive chemical safety program audit (KP-ES-97-A150) to meet the three year frequency. The inspector reviewed the 37 page checklist plan and found it to be comprehensive, addressing each major program element. No concerns were identified.

c. Conclusions The facihty has included the chemical safety program elements within the establisi ted

. audit and assessment program. Plans for the three year audit appeared comprehensive.

4.0 Chemical Safety Mechanical Integrity Program (Compliance Plan issue 40)

a. Scope The rnechanical integrity program for highly hazardous chemicals was reviewed to verify that the facility has developed and implemented appropriate actions to provide reasonable assurance that the integrity of the confinement systems will be maintained.

b. Observations Compliance Plan issue 40, Chemical Safety Mechanical Integrity Program, addresses those hazardous enemicals defined by 29 CFR 1910.119 and SAR 5.6.13.3, and was scheduled to be implemented by May 26,1997. Through discussions with the systems >

process engineer, the inspector determined that the facility had brought all three highly hazardous chemical systems (Cl2, F2, and CIF3) under the mechanical integrity program. This PSM element had been audited by an outsioe contractor in April 1997.

The audit report idenufied a number of plant procedures that addressed the various aspects of mechanicalintegrity including: piping, unfired pressure vesselinspection, rupture disc inspections, pressure relief valve inspections, and qualification of nondestructive test personnel. In addition to the above, the inspector determined that responsibility for the formal PSM program was brought under the Department of Environmental, Health and Safety's jurisdiction. Maintenance requirements were established by Engineering, procedures for process system maintenance were established by Maintenance, process system inspection procedures were developed by Production Support, the Safety, Safeguards & Quality Department included PSM in their audit and surveillance program, and training modules were developed and training conducted for maintenance and quality control personnel.

The inspector reviewed various data packages that covered the storage tanks, piping, and pressure relief devices for the three chemical systems. Inspection methods appeared appropriate and the data demonstrated that significant margins of safety were

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built into each system. No degradation of the confinement barriers was apparent, and the facility was maintaining the systems as evidenced by the re;ent replacement of fluorine piping in the C-410 buildings about two years ago. Discussions with the system engineer indicated that reasonable engineering judgement and operating experience were used to establish the inspection frequencies, which were entered into the PM data base.

c. Conclusions The facility has established a mechanicalintegrity program covenng the three hazardous chemical systems that appears to be comprehensive and in accordance with Compliance Plan commitments. The program has established that there is an adequate safety margin for the hazardous chemical confinement systems.

5.0 DOE Chemical Safety and Third-Party use of Hazardous Chemicals (Compliance Plan issue 43)

a. Scope The inspector reviewed the method by which USEC would be notified of DOE or third-party use of hazardous chemicals that could impact the safety of PGDP nuclear operations.

b. Observations Through a review of the Compliance Plan file for this issue, the inspector determined that DOE provided USEC with a detailed listing of the hazardous chemicals used on-site. None of the chemicals were in excess of the PSM threshold values. Further, DOE issued a directive to all site tenants requiring an annualinventory of site chemical usage for review under this Compliance Plan issue. Through discussions with facility personnel, the inspector determined that a procedure, PMPI-1500, Shared Gite issues, had been developed for DOE third-part tenants. This procedure provides a mechanism by which USEC would be periodically notified of any changes to the use of hazardous materials on site.

c. Conclusions A mechanism hcs been established to assure that USEC is notified of changes to third-party usage of hazardous chemicals so that the impact on nuclear operational safety can be appropriately evaluated. Chemicals in current use have been identified by DOE and evaluated by USEC.

9 6.0 Recommissioning of Retired Plant Equipment

a. Scope Facility controls for recommissioning plant equipment that had been placed in a retired or inactive status for an extended period of time were reviewed to assure that appropriate engineering and operational evaluations were conducted prior to restart of the inactive component.

b. Observations During a tour of the chlorine system in the pump houses and water treatment plant, the inspector noted severalinstruments that were no longer used. When questioned as to the status of those components, facility personnel indicated that they had been left in place in case a future need should arise, such as the failure of the current operating

, instrumentation / component. During a subsequent tour of the C-410-D Fluorine Storage Building, the inspector noted the presence of an evacuation pump that was tied into the fluorine system (and shown on the process & instrumentation diagram). When questioned as to its purpose, facility personnel stated that it had not been used for at least 4 5 years.

The inspector raised a concern as to: (1) how long a component would be left in the field before being formally deactivated (and possibly decontaminated), and (2) what actions would be required before returning an inactive component to service (engineering and hazard analysis reviews, operational approval, maintenance checkouts, procedure and training updates, etc.). At the exit meeting, plant management stated that this item would be reviewed to determine whether there were existing management controls to cover this potential situation or if such controls had to be developed. This item will be tracked as inspector Follow item No. 70-7001/97-206-01.

c. Conclusions Then did not appear to be an establishe ' mechanism for the formal deactivauon of components or for the return to servi:e of inactive components.

7.0 Exit Meeting Summary The inspector presented the preliminary findings to members of the plant's management at the conclusion of We inspection on July 25,1997.

10 Kgy1_ELSONNEL CONTACTED USEC L. Albritton* Nuclear Regulatory Affairs S. Chappelle Independent Assessments Group R. Edwards' Chemical Operations S. Gunn* Cascade Operations K. Porter

• Industrial Health & Safety H. Pully* LMUS/USEC S. Skaggs System Engineering D. Sno.v' Industrial Health & Safety NRC K. O'Brien* NRC Senior Resident Inspector

• denotes those present at the exit meeting. _

ACRONYMS USED PHA Process Hazards Analysis PSA Process Safety Analysis PSI Process Safety Information PSM Process Safety Management DOE Department of Energy OSHA Occupational Safety and Health Administration i

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