ML20209B800

Insp Rept 70-7002/99-203 on 990607-11.No Violations Noted. Major Areas Inspected:Hazard Identification & Assessment, Maintenance & Insp,Compliance Plan Issues,Conduct of Operations in X-705 & Audits & Insps

ML20209B800
Person / Time
Site:	Portsmouth Gaseous Diffusion Plant
Issue date:	07/01/1999
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20209B796	List: ML20209B791 ML20209B800
References
70-7002-99-203, NUDOCS 9907080138
Download: ML20209B800 (12)

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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Docket No: 70-7002 Certificate No: GDP-2 Inspection Report No: 70-7002/99-203 Certificate Holder: United States Enrichment Corporation Facility Name: Portsmouth Gaseous Diffusion Plant Location: 3930 U.S. Route 23 South P.O. Box 628 Piketon, OH Inspection Dates: June 7-11.,1999 Inspectors: W. Troskoski, Senior Chemical Engineer D. Piccirillo, Chemical Engineer i

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l 9907080138 990701 PDR ADOCK 07007002

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EXECUTIVE

SUMMARY

United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant NRC Inspection Report 70-7002/99-203 The Nuclear Regulatory Commission (NRC) conducted a risk-informed, performance-based, chemical safety inspection of the Portsmouth Gaseous Diffusion Plant from June 7-11,1999.  !

The areas reviewed during the inspection are identified below. Within these areas, the inspection consisted of facility walk-throughs, selective examinations of procedures and records, l and interviews with personnel. Based on the results of this inspection, no violation of NRC requirements was identified.

1 Hazard Identification and Assessment The Process Hazards Analyses (PHAs) for covered chemicals and systems were technically sound and up to date. While formal tracking of PHA recommendations was weak, the facility initiated immediate corrective actions to assure that none of the recommendations would be inadvertently dropped. The overall quality of the X-705 "what-if" and Failure Modes and Effects Analyses (referenced in SAR 4.3.1.1.2) was weak, and the 1981-1982 safety studies were not validated prior to submittal as part of the certification process. (Section 1)

Maintenance and inspection The maintenance backlog for PHA covered chemicals and systems was reasonable and no negative trends were apparent. However, there was a substantial backlog for the X-705 Decontamination Building that was clearly manifested in the poor overall material condition of the building systems as compared to other plant areas. (Section 2)  ;

Comoliance Plan issues l l

USEC satisfactorily addressed Compliance Plan issues: No. 4, X-705 Evaporator Heat Exchanger Modifications; No. 5, X-705 Isolation Valve Testing; and No. 20, DOE Chemical Safety and Third-Party Use of Hazardous Chemicals. (Section 3)

Conduct of Operations in X-705 General weaknesses were observed in adherence to Conduct of Operations procedures l pertaining to log-keeping and turnovers at building X-705. These performance weaknesses ,

were similar to those identified by the Independent Assessment Group during recent audits of l Cascade operations. (Section 4)

Audits and Inspections The chemical safety audits were technically sound and thorough. Use of counterpart personnel from the Paducah facility to provide a fresh perspective is a good practice. (Section 5) 2

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i REPORT DETAILS i

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1. Hazard identification & Analysis (88057)

a. Inspection Scope PHAs for covered chemicals and systems were reviewed to verify that they were technically adequate, being maintained up to date, and that any modifications made during the past two years were adequately enveloped by the safety analysis. The status of any resulting j PHA recommendations were also reviewed to assure that significant safety issues were j addressed in a timely manner, commensurate with their overall risk, In addition to the  !

PHA covered chemicals and systems, potentially high risk chemical operations in the I X-705 Decontamination Building were reviewed to assure that potential accident scenanos were identified and appropriate safety controls were implemented. 4

b. Observations and Findinas )

PHA Covered Chemicals and Systems The inspectors reviewed the four PHAs for covered systems which included:

X-742 Chlorine Trifluoride Storage Area, August 1998, Revision 1 X-330 & 333 Conditioning Gas System, August 1998, Revision 1 X-342 Fluorine Generation System, March 1998, Revision 0 X-611E Chlorination System, August 1998, Revision 1 The PHAs appeared technically sound. Inspector tours of the CIF3 storage area and fluorine generation facility found an overall good general material condition.

The inspectors also reviewed the current status and prioritization of PHA recommendations for the X-330/333 and Fluorination processes with the responsible plant staff to verify that the recommendations were being tracked and addressed in a timely manner commensurate with their importance to safety. While no significant safety recommendations resulted from the PHAs, which had just been completed or re-validated in the last year, completion of the recommendations was not being tracked as part of the plant's chemical safety program. The inspectors raised a concern that items could be inadvertently dropped without a formal tracking system. Plant management acknowledged the concerns and committed to initiating a problem report for each recommendation in order to enter them into the plant's centralized tracking system The inspectors determined that this action was acceptable.

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l X-705 Decontamination Operations The Safety Analysis Repart (SAR) Section 4.3.1.1.2, Identification of Potential Accidents, states that two basic techniques were employed to identify potential accidents in X-705: Surveys and Failure Mode and Effects Analysis (FMEA). The survey included a "what-if" type of analysis and each initiating event was evaluated for radiation, toxic material, criticality, fire, and explosion hazards. For more complex systems, a more detailed study was made that involved FMEAs.

In order to assure that no new or different hazards were introduced into the X-705 operations since initial certification and that adequate controls were implemented for the identified hazards, the inspectors requested copies of the surveys and FMEAs that were referenced in SAR 4.3.1.1.2. United States Enrichment Corporation (USEC) management provided copies of several 1981-1982 vintage Final Safety Analysis Report (FSAR) documents: GAT-976, FSAR Upgrade Uranium Recovery, September 1981; GAT-987, Safety Assessment of lon Exchange Facility X-705, August 1981 rand GAT-995, X-705 Decontamination Building Safety Study, April 1982. It was not clear that the safety studies reflected the current facility conditions and configuration. Although the criticality safety analyses were being updated as part of the certification process, there had not been any similar programs to consider changes to the potential hazards related to chemical and fire safety. The inspectors asked USEC whether these documents were' walked-down to assure that they were current and reflected actual plant conditions prior to completion of the certification process and were informed that no special building walk-down had been conducted to validate the 1981-1982 studies. The certificate holder assumed that the modification control process was sufficient to maintain the safety basis during the intervening

years. USEC management also acknowledged that the analyses contained in the 1981-1982 documents would not meet today's standards for a FMEA, although the older documents should have covered many of the elements.

The inspectors conducted several walk-downs of the X-705 processes and conducted discussions with operations management and process engineering staff to assure that there were no significant process changes or new processes added since 1982 that would present a new hazard not previously considered. None were identified.

In order to ensure that the SAR' accurately reflected the safety basis for the X-705 l operations, USEC management committed to revising SAR Section 4.3.1.1.2 during the next annual SAR update. The review and updating of SAR 4.3.1.1.2, Identification of Potential

, Accidents, for X-705 operations will be tracked as inspector Followup ltem (IFI) 70-7002/

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c. Conclusion

The overall quality of the PHAs for covered chemicals and systems was good and up to date. While formal tracking of the status of PHA recommendations was weak, the facility 4

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i initiated immediate corrective actions to assure that none of the recommendations would be inadvertently dropped. The overall quality of the X-705 "what-if" and Failure Modes and Effects Analyses was weak, and the 1981-1982 safety studies were not validated prior to submittal as part of the certification process.

2. Maintenance and Inspection (88062)

a. Insoection Scope The maintenance backlogs for PHA covered chemicals and system and the X-705 processes were reviewed to determine whether any negative pctfGmance trends were developing regarding the reliability of controls relied on for safety.

b. Observations and Findinos As of the date of the inspection, there were about 24 preventive maintenance and 86 corrective maintenance work orders outstanding for the PHA covered chemicals and systems. Discussions with plant staff indicated that the total number was within the normal fluctuation typically experienced. However, the X-705 building had a backlog of about 750 outstanding maintenance work orders. During tours of the building, the inspectors noted that the general material condition of the facility appeared weak when compared to other areas of the plant. There were water pipe leaks and systems that had been out of service for an extended period of time. Discussions with building management indicated that although they were aware of the problems, they were constrained by the availability of maintenance resources. The inspectors raised a concern regarding the possible development of a negative performance trend in this area. Facility management acknowledged the inspectors' concern and stated that they were monitoring the situation with regard to the number of outstanding safety related work orders.

c. Conclusion

The maintenance backlog for PHA covered chemicals and systems was reasonable, and no r.egative trends were apparent. However, there was a substantial backlog for the X-705 Decontamination Building that was clearly manifested in the poor overall material condition of the building systems. The inspectors did not identify any safety concems with regard to these material conditions.

3. Compliance Plan issues

a. Insoection Scope Selected Compliance Plan issues related to chemical safety were reviewed to independently confirm that USEC had adequately implemented the required safety commitments.

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b. Observations and Findinas Compliance Plan issue No. 4 - X-705 Evaporator Heat Exchanger Modifications issue No. 4 addressed two concerns regarding: (1) a possible tube failure in either the pre-

! or post-uranium evaporator heat exchangers which could result in concentrated uranium-bearing solution being discharged into an unfavorable geometry through the steam condensate drain piping, and (2) a tube failure coincident with a *U feed solution concentration greater then 60% and a high feed solution level which could result in uranium bearing solution being introduced into an unfavorable geometry in the heat exchanger l l expansion joint. The plan of action called for (1) the installation of instrumentation and l system modifications in the steam condensate drain piping from the evaporator heat i exchangers to provide double contingency for criticality safety, and (2) replacement of the j evaporator heat exchanger unfavorable geometry expansion joints. l The inspectors waked-down the X-705 evaporator systems and venfied that condensate l l detectors (CE-1707 A, B & C) were installed in the drain pipes from the evaporator heat ,

exchangers. A high signal of greater then 15 ppm uranium would actuate flow diversion valves (FV-1707 A & 8). The inspectors also reviewed procedure XP4-CU-CH2804, Leak Test of the Recovery Condensate Flow Diversion Valves, Revision 0, and confirmed that the ,

acceptance criteria of 7.2 ml/5 minutes was in accordance with the criticality safety criteria. '

The inspectors also verified that the evaporator heat exchanger expansion joints were replaced with ones of a favorable geometry (nominal 5 inch diameter). These actions satisfactory close Compliance Plan issue No. 4.

Compliance Plan issue No. 5 - X-705 Isolation Valve Testing Issue No. 5 addressed the testing of isolation valves to assure that leakage would not exceed criticality safety criteria for: (1) the uranyl nitrate feed line isolation valve upstream of the X-705 calciner feed pump, and (2) the isolation valves between the microfiltration unit bag filters and the effluent storage tank. The plan of action called for the installation of block

. valves, test traps, and a valve leak test cart to allow periodic leak rate testing.

I The inspectors walked-down applicable portions of the systems and verified that appropriate block valves and test traps had been installed and that a test cart was available to conduct periodic leak rate testing. Review of past test data indicated that the leak rates were within

! acceptable limito. As of the date of the inspection, the calciner had been out of service for an extended period of time due to maintenance and design problems. Discussions with facility management indicated that the leak rate tests were scheduled to be reperformed l prior to retuming the system to service. The inspectors identified no concerns and this closes Compliance Plan issue No. 5.

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l Compliance Plan issue No. 20 - DOE Chemical Safety and Third-Party Use of Hazardous l l Chemicals . i 1

Issue No. 20 addressed the establbum9nt of communication channels from the Department of Energy (DOE) to USEC regar6ng the use of hazardous chemicals by DOE and other third  ;

parties present at the PORTS site that could impact nuclear operations. The plan of action I called for the development and implementation of a DOE directive to provide USEC with a  ;

detailed description of any hazardous materials used or stored onsite and to periodically I l update the list to reflect changes to third party activities. l This issue was last reviewed in NRC Inspection Report 70-7002/98-201, and was left open l pending fullimplementation of SSI/PO-P001, Administration of Shared Site issues. The l- inspectors reviewed a memorandum from J. Parker to R. Gaston dated January 15,1998, which addressed the issue of third party use of hazardous chemicals and verified that SSI/PO-P001 was in place, that Plant Operations Review Committee reviews were conducted prior to authorizing work in leased spaces involving the use of hazardous i

, materials, that a current inventory of hazardous materials has been kept in the Emergency l l Operations Center, and that a current copy is now also kept in the X-300 building. This closes IFl 70-7002/98-201-01 and Compliance Plan Issue No. 20.  ;

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c. Conclusion'-

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l: USEC satisfactorily addressed Compliance Plan issues: No. 4, X-705 Evaporator Heat l Exchanger Modifications; No. 5, X-705 Isolation Valve Testing; and No. 20, DOE Chemical Safety and Third-Party Use of Hazardous Chemicals. Therefore, these issues were closed.

4. . Conduct of Operations

a. Inspection Scooe The primary objective of the inspection was to verify that the certificate holder was implementing Conduct of Operations procedures (COP) as required by the SAR and the 1 Technical Safety Requirements (TSR) for the Decontamination and Recovery Facility, X-705 l and the Fluorine Generation Facility, X-342. These procedures are necessary to ensure the safety of operating personnel to prevent accidents that might threaten the workers or the general public, and to contribute to the safety basis of these facilities.

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b. Observaiions and Findinas The following observations and findings are based on interviews of facility personnel, review of documentation and logs, performance-based observations of operational activities, and a review of previous Operational Audits performed by the Independent Assessment Group  ;

(IAG).

The inspectors interviewed the Facility Coordinator, First Line Supervisor, and a randomly selected qualified operator in Building X-705. The questions and discussions during the interviews focused on subjects such as operations during normal and emergency conditions, log-keeping, operator rounds, shift turnovers, required reading, and safety practices. In addition, the inspectors performed walk-downs of the Recovery System with the First Line Manager and the operator. The inspectors main focus was the Solvent Extraction Process and calciners due to the risk significance of those systems. The interviewees

• knowledge of the systems and procedures observed were adequate with respect to their positions. No deficiencies were identified. l l

Interviews with the System Engineer, First Line Manager and an operator were also '

performed at the Fluorine Generatic.. Facility, X-342. Facility personnel performed system walk-downs of the anhydrous hydrogen fluoride storage and transfer system and the fluorine generation and storage system with the inspectors. The interviewees' knowledge of the facility was satisfactory, and no deficiencies were identified.

l The inspectors reviewed the sections of the PORTS SAR and TSR applicable to conduct of operations. The following sections of the Standard Practice Procedure Manual (XP2) and COP were also reviewed:

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• COP-2, Shift Routines, XP2-US-F01102, o COP-5, Required Reading, XP2-US-FO1104, o COP-6, Policies and Instructions, XP2-US-FO1105, o COP-7, Operating Area Logs, XP2-US-FO1106, o COP-8, Pre Job Briefings, XP2-US- FO1107, o COP-9, Control of Operator Aids, XP2-US-FO1109, o COP-3, Control Room Activities, XP2-US-FO1201, and a UE2-OP-OP1030 l

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4 These documents provide adequate guidance for site personnel to safely operate the PORTS facility with minimal risk. PORTS procedures explicitly state that personnel are to conduct activities in accordance with these documents.

Finally, the inspectors reviewed the logs, round-sheets, and checklists for buildings X-705 and X-342. The logs for building X-342 provided adequate documentation of activities that occur during the shift. However, a review of building X-705 logs showed an insufficient level of reporting of Recovery activities. For example, there were no entries in the logbook to indicate that an operator had assumed the watch, or that the off-going operator had been relieved. In addition, there were numerous instances in the Recovery Walk-through Checklist where routine weekly checks were not initialed off.

The inspectors' discussions with the LAG and review of their last two quarterly audit reports showed the same general observations regarding the conduct of operations had also been identified in the cascade facilities, and that development of corrective actions was underway.

The inspectors raised a concern that the conduct of operations issues identified in the X-705 building, while of limited individual safety significance, were an indication that there could be wider performance problems in areas other than cascade operations. Discussions with facility management indicated that the IAG would review the conduct of operations on a wider scale during the next year and that corrective actions coming out of the last IAG audits would be reviewed for a more generic plant wide application. USEC actions to review the conduct of operations in the cascade and other facilities to assure that operations are being conducted in accordance with the management expectations outlined in the COP will be t7cked as (IFI) 70-7002/99-203-02.

c. Conclusion

There are no immediate safety concerns identified by the inspectors with regard to conduct of operations for the facilities observed. However, the inspectors observed that there were weaknesses in conduct of operations pertaining to log-keeping and turnovers at building X-705. The IAG indicated that they will follow-up with an audit in the near future.

5. Audits and Inspections (88066)

a. Inspection Scooe The inspectors reviewed the most recent audits related to chemicM safety that are required j by SAR Section 5.6.9 to verify that management was adequately monitoring the I

effectiveness of their chemical safety program and addressing identified problems in a timely manner.

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b. Observations and Findinas i The most recent overview of the program was conducted over a two week period with ,

personnel from the PORTS Industrial Hygiene and Safety group. The audit covered all of the major performance elements and provided a good overview of the program. Findings by the group were appropriately addressed. The inspectors noted that the use of counterpart personnel from the Paducah facility provided a fresh set of eyes and was a good practice.

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c. Conclusion

The chemical safety audits are technically sound and thorough. Use of counterpart personnel from the other GDP facility to provide a fresh perspective is a good practice.

6. Exit Meeting The inspectors presented the inspection results to members of the facility management on June 11,1999. The facility staff acknowledged the findings and concurred with the presented facts. No proprietary information was identified.

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, i PARTIAL LIST OF PERSONS CONTACTED I i

USEC

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• S. Casto, Work Control Manager l

• D. Fogel, Nuclear Regulatory Affairs  ;

• R. Helme, Acting Engineering Manager  !

• P. Musser, Enrichment Plant Manager ]

• P. O'Neill, Industrial Hygiene and Safety i

• J. Oppy, Shift Operations Manager j

• H. R. Potter, PACE Safety Representative j

• P. Potter, Chemical Operations j

• D. Ruggler, industrial Hygiene ayd Safety  :

• G. Salyer, Industrial Hygiene ar.d Safety i'

• T. Sensue, Nuclear Regulatory Affairs

• C. Slifko-Moore, Materials Management Manager  !

• K. Tomko, Environmental, Safety and Health Manager l

• M. Wayland, Maintenance Manager  ;

• J. Woodard, X-705 Facility Custodian i NRC D. Hartland, PORTS Senior Resident inspector  !

• C. Blanchard, PORTS Resident inspector

(* denotes Exit Meeting Attendees) l l

Inspection Procedures Used IP 88057: Hazard Identification ,

IP 88062: Maintenance and Inspection j IP 88066: Audits and Inspections  !

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i items Opened, Closed, and Discussed Opened 70-7002/99-203-01 IFl The review and update of SAR Section 4.3.1.1.2, Identification of Potential Accidents, for X-705 operations will be tracked.

70-7002/99-203-02 IFl USEC to review the conduct of operations in Cascade and other facilities to assure that operations are conducted in accordance l with the management expectations outlined in the COP will be tracked.

Closed 70-7002/ Compliance Plan Issue #4 X-705 Evaporator Heat Exchanger Modifications 70-7002/ Compliance Plan issue #5 X-'705 Isolation Valve Testing to assJre that leakage would not exceed criticality safety criteria 70-7002/ Compliance Plan issue #20 DOE Chemical Safety and Third Party use of Hazardous Chemicals 70-7002/98-201-01 IFl Requirements of Administration of Shared Site issues Procedure SSI/PO-P001 were not fully implemented.

Discussed None List of Acronyms Used -

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l COP Conduct of Operations Procedures l

DOE Department of Energy l FMEA Failure Mode and Effects Analysis FSAR Final Safety Analysis Report LAG Independent Assessment Group IFl inspector Followup Item j NRC Nuclear Regulatory Commission l PHA Process Hazards Analysis l PORTS Portsmouth Gaseous Diffusion Plant SAR Safety Analysis Report TSR Technical Safety Requirements USEC- United States Enrichment Corporation 12 i