ML20211D399

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Insp Rept 70-7001/97-207 on 970818-22.No Violations Noted. Major Areas Inspected:Training Program,Facility walk- Through,Tracking Sys,Sprinkler Sys Lines,Surveillance Requirements & Inspector follow-up Items
ML20211D399
Person / Time
Site: 07007001
Issue date: 09/17/1997
From:
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20211D380 List:
References
70-7001-97-207, NUDOCS 9709290123
Download: ML20211D399 (16)


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1 U.S. NUCLEAR REGULATORY COMMISSION f .; ,

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Inspection Report No. 70 7001/97-207 t

Docket No. .70 7001

[ Facility Operator: United States Enrichment Corporation

Facility Name
Paducah Gaseous Diffusion Plent c

Observations At: Paducah, KY -

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- inspection Conducted: August 18 ~ 22,1997 Inspectors: Yen-Ju Chen, FCOS Rex Wescott, FSPB

~ Paul Laini FCLB

. Approved By:_ Philip Ting;. Chief Operations Branch Division of Fuoi,CycW Safety and Safegtianto iNMSS 1

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Enclosure 9709290123-970917 PDR ADOCK 0700 001:

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9 EXECUTIVE

SUMMARY

PADUCAH GASEOUS DIFFUSION PLANT NRC INSPECTION REPORT 70 7001/97 207 Introduction NRC performed a f.,utine fire safety inspection of the U.S. Enrichment Corporation (USEC)

Paducah Gaseous Diffusion Plant (PGDP) at Paducah, KY, on August 18 - 22,1997. The inspection v. s performed by staff from NRC Headquarters. The focus of this inspection was to ensure compliance with the certificate holder's fire safety program commitments, in accordance with the transition schedule and actions stipulated in the PGDP Compliance Plan.

Major fire safety performance elements reviewed at PGDP included:

e Training program e Lightning protection

  • Portable fire extinguisher e- Tracking system e Sprinkler system iines e Surveillance requirements e Inspector Followup items (IFis)
  • Compliance Plan (CP) Issues Sionificant Findinas and Conclusiens e in general, the training ptogram for fire fighters, E squad, and Emergency Response Organization (ERO) members is appropriate. However, the frequency of hands-on training on portable fire extinguishers for fire fighters, E-squad, and fire watchers is inadequate. This will be tracked as an IFl (Details 1,0),

e ' - The facility's buildings do not have lightning protection but are heavily grounded, which is demonstrated by design drawings. However, the facility does not have a program for the inspection and maintenance of the grounding system. This will be tracked as an IFl (Details 2.0).

  • During a walk through, the inspectors identified several out-of date hydrostactic tests for carbon dioxide portable fire extinguisher cylinders. The facility had initiated an investigation and corrective actions prior to the inspection. However, at the time of inspection, there were still 479 extinguishers with out-of-date hydrostatic test. This will be tracked as an IFl (Details 2.0).

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- e The facility has a mechanism to track fire safety related commitments, such as

' corrective actions, audit comments and recommendationsiand event reports. A

package was prepared for each commitment to ensure appropriate closure. The i inspectors reviewed the tracking system process, and it appeared to be adequate (Details 3.0).

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e 'The inspectors reviewed seve'ral work packages for sprinkler system modifications and j considered _the packages adequate. As part of the modification, the fac!
;ty has

, prepared drawings detailing the "as-exists" and "to-be constructed" conditions. The I

inspectors considered it to be a good step in correcting deficiencies identified during -

i the previous inspection (Details 4.0).

t j e Based on a concern raised during Inspection 97-203, the facility revised a procedure j regaroing the flushing of sprinkler systems. The inspectors reviewed the revised -

l procedure and other planned actions and considered them to be adequate in addressing

! the concern (Details 4.0),

f j e As documented in inspection Report (IR)97-203, some of the facility's surveillance requirements did not meet the industry standards. The facility revised a procedure to

, address this issue. The inspectors reviewed the revised procedure and considered the -

4 revision sufficient to meet the intent of industry standards (Details 5.0),

e The inspectors reviewed the closure packages for IFis and closed four IFis. Three IFis f

still remain open pending the completion of corrective actions (Details 6.0).

i i e The inspectors reviewed the closure packages for Compliance Plan issues. The

{- inspectors closed part-1 of issue 14 and both parts of issue 17.

DETAILS i

i 1.0 Trainino Prooram F.

j a. Scooe '!

The inspectors reviewed the facility's fire safety training program for fire fighters,

l. E-squad, EROS and_all employees. The inspectors reviewed the training requirements,
training fregt.. icy, lesson plans for four training classes, and sample written exams for two training classes. The inspectors also reviewed the training records for ,

f 15 employees. l 4 l i.

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i j_ b'. Observations

) The inspectors reviewed the facility's fire safety training material for all employees in i the General Employee Training manual. The material provides generalinformation on fire prevention and the facility's fire hazards. The inspectors considered the materials adequate.

l The inspectors reviewed the Training Development Administrative Guide (TDAG) for.

Fire Services (FS), which outlines the training program for fire fighters, E squad, and l

. EROS. The TDAG describes the training program objectives, organization, test-out and training waiver requirements, and qualification and re-qualification for fire fighters, emergency medical technicians, fire officers, and E-squad. In general, the required training classes and training frequencies appeared adequate. However, the inspectors i noted that the frequency of hands-on training on portable fire extinguisher for fire fighters and fire watchers is inadequate. PGDP's training periodicity is every other year for E-squad, every third year for fire watchers, and none for firefighters after the initial qualification. The inspector noted that OSHA regulation,29 CFR 1910.157(g),

requires the employer to provide employees who have been designated to use fire fighting equipment with initial and annual training. As the result of the finding, the facility reviewed the OSHA requirements and immediately scheduled hands-on training for fire fighters on portable fire extinguishers. PGDP also supped all hot works pending the completion of hands-on training for fire watchers. This item will be tracked as IFl 97 207-01.

The inspectors reviewed the lesson plans for the following classes: Sprinklers, Fire Watch Training, Portable Fire Extinguishers, and Live Fire Training. The inspectors also reviewed the examinations for the first two classes. The lesson plans reviewed provide both classroom instruction and hands-on practice. The training material appeared adequate for the fire fighters and E-squad. The examinations were prepared from a commercial-available standardized exam pool and required the students satisf actorily complete both a written exam and hands-on demonstration. The inspectors considered the reviewed lesson plans and examinations adequate.

The inspectors reviewed training records for 15 employees, including 4 fire fighters, 1 fire major, and 10 E squad members, t he training record contained certificate of training, proof of training classes attendance, and exams. The inspectors reviewed the records to ensure each individual completed the required training within the required frequency. Based on the reviewed records, the inspectors determined the fire fighters and E-squad received adequate training with satisf actory results.

The inspectors also reviewed the training records for building custodians on building combustible loadings (Details 7.0) and training for fire fighters on nuclear criticality safety (NCS) information in pre-fire plan (Details 6.0). These records indicated the appropriate employees received the subject training and appeared adequate.

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c'. Conclusion The inspectors reviewed the facility's TDAG for FS and considered the program outline 1 and structure adequate. Based on the training materials reviewed, the 'nspectors considered the lesson plans adequate. However, the inspectors noted that the hands.

J on training frequency on portable fire extinguisher for fire fighters, E squad, and fire watctwrs is inadequate. This will be tracked as an IFl.

4 2.0 Facility Walk-Throuah i

a. Scope The inspectors conducted a walk through of the facility. In general, the housekeeping in these process buildings was adequato. During the walk-through, the inspectors evaluated the lobe oil systems, building lightning protection, and the condition of portab!e fire extinguishers.
b. Observations Lube Oil Svstems I The GDPs have a history of fires involving the gravity feed lube oil system. The new 4 high flash point tube oils have reduced the hazard, but large quantities of combustible fluids still exist.

The Inspectors walked through several tube oil storage rooms located either on or under the process building roof. The tanks were isolated from the facilities by non-combustible construction and were provided with sprinkler protection and heat detection. Drainage was provided for oil spills, and openings to the process areas were provided to keep the sprinkler systems from freezing. The tanks were labeled

" Chevron GST 68," and the National Fire Protection Association (NFPA) Diamond noted the flammability rating as "1." The inspectors requested the Ntaterial Safety Data Sheet (MSDS) for this oil, but the MSDS was not in the buildings' MSDS j notebook. The MSDS was available on-site, and a copy was prov ded to the buildings.

The certificate holder indicated that MSDS information is accessible on computer for those employees with VAX account. The Chevron GST 68 MSDS indicated that this lube oil has a very high flash point (446*F), and the flammability was appropriately labeled on the storage tank.

Liahtnino Protection During the tour, the inspectors noted that the tube oil vent lines projected above the roof line and that lightning protection was not evident. The facility stated that lightning protection is not provided, but the buildings are heavily grounded. NFPA 780 requires the protection of structures likely to be damaged by lightning, except for 5

, grounded metal parts greater than 3/16 inch. The f acility provided documentation

. which demonstrated the grounding system to the building ventilators, the roofs' metal decking, and the lube oil system. This meets the SAR commitments on lightning protection, but the inspection and maintenance of the grounding system was not done.

NFPA 780 recommends an annual visualinspection for corrosion and a three to five year ma;ntenance interval of the grounding system. With the large quantity of lube oil in the process buildings, the inspectors considered the assurance of grounding system as very important. The facility acknowledged this finding and agreed to take appropriate actions. This item will be tracked as IFl 97 207 02.

Portable Fire Extinauishets During a tour of the facility, the inspectors noted that some carbon dioxide (CO,)

extinguisher cylinders had passed the date for hydrostatic testing (HST) by several years ~ NFPA 10 and OSHA 29 CFR 1910.157(f) require CO, extinguishers to be HST every five years. The inspectors noted that an internal audit report had raised a concern in November 1996 that the monthly inspection of portable fire extinguishers may not be effective in identifying cylinders with out-of-date HST. A problem report was prepared to address this concern and corrective actions were planned. As part of the corrective actions, Procedu CP4 SS-FS2200; " Portable Fire Extinguishers," was revised to start checking HST dates and would become effective on August 20,1997.

At the time of inspection, the facility's database identified that 479 extinguishers were behind in the HST requirements, and it expected up to 2000 more extinguishers may need the HST over the next two years. The certificate holder reported the on-site HST facility was no longer functioning, and the facility was awaiting funds to replace the past due cylinders. The facility contacted its off site service vendor and was advised by the vendor that there was no additional existing hazards as a result of exceeding tne HST date. Thus, the facility considered these extinguishers operable and is conducting an independent Engineering Safety Evaluation to document this consideration.

It appeared that the facility was taking actions to address the problem; however, there was no effective immediate actions to stop or correct the problem. The inspectors haue two major concerns: (1) the length of time for the facility to correct the problem, and (2) the current and anticipated number of portable fire extinguishers with out-of-date HST. The certificate holder recognized and acknowledged these concerns, and agreed to take appropriate actions. This item will be tracked as IFl 97 207 03.

c. .Qgnelusions in general, the housekeeping in process buildings appeared adequate. The inspectors raised concerns in grounding system inspec' n and maintenance and the out of-date HST for portable iire extinguishers. Both items will be tracked as IFis. The certificate holder acknowledged these findings and will take appropriate actions to correct these problems.

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, i 3.d Trackina Svstem

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l a. Scope

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i The inspectors reviewed the facility's mechanism for tracking fire safety related

[ commitments. The inspectors also reviewed several closure packages to ensure such commitm mts are appropriately closed.

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b.' Observations t

The inspectors reviewed the facility's system for tracking fire safety related

! commitments, such as corrective actions, audit comments an j recommendations, and j event reports. The inspectors discussed with the FS Problem Report Coordinator the j mechanism for ensuring such issues and concerns are entered into the facility's j tracking sustom, Business Prioritization System (BPS). The inspectors noted that a i problem report was prepared for all IFis and concerns and recommendations from building reappraisals and internal audits, and these problem reports were all entered

, into BPS for tracking purposes. A closure package was prepared for each problem

report to ensure proper closure.

The inspectors reviewed several closure packages for IFis (Details 6.0) and CP issues q . (Details 7.0), Each closure package contained the information on corrective actions, i the responsible parties, and the actions taken. Based on the review, the inspectors

] considered the process to be adequate.

3 i c. Conclusions 4

The inspectors reviewed the facility's mechanism for track'ng i fire safety related j commitments and several closure packages. Based on the information received and j packages reviewed, the inspectors considered the process adequate.

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!- - 4.0 Sorinkler Svstem Lines l

a. Scong

, During Inspection 97-203, the inspectors raised several concerns regarding the sprinkler systems. The significant concerns were tracked as IFis; the minor concerns,-

with little or no safety impacts, were documented in IR 97-203 but were not tracked.

However, the certificate holder prepared problem reports for these minor concerns and entered them into the BPS. The inspectors reviewed the closure packages for these concerns to evaluate the certificate holder's corrective actions.

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b', Observations Baseline drawina of the Sorinkler Svstems In IR 97 203, the inspectors expressed a concern with the lack of "as exists" drawings for the existing sprinkler systems and noted that it may have contributed to the violation noticed in the inspection report.

The certificate holder recently identified in process buildings C-315 and C-333 several problems which required engineering design rnodifications to correct. The inspectors evaluated the work packages for these modifications or design changes. The inspectors noted that, as part of the certificate holder's evaluation and corrective actions, detailed drawings of the "as exists" and "to be-constructed" conditions were prepared. The existing site drawings were revised to include or reference these new drawings. These new drawings were included in a centralized plant drawing database.

The inspectors considered that the observed deficiency in up-to-date drawings is being properly addressed.

Flushina of the Sorinkler System lines During inspection 97-203, the inspectors raised a concern about flushing of the sprinkler system lines. As the result, the certificate holder prepared problem report PR-NR 97 3924 on March 27,1997. On May 12,1997, the certificate holder prepared problem report PR EN 97 2527 concerning foreign material found in a sprinkler system pipe drop in the ductwork. Consequently, the certificate holder removed five pendant sprinkler heads and checked for debris. Some debris was found in the pulled heads, and the lines were flushed locally. The facility also performed a test on one of the partially plugged sprinklers and determined that the system pressure would have cleared the heads in the event of sprinkler activation. It should be noted that only the ductwork is protected by the pendant heads involved, and a fire which escapes the ductwork would be controlled by sprinkler heads above and below the ductwcrk.

As the result of the above obsarvations end the discussions during Inspection 97-203, the certificate holder developed a management response for these problems. The management response, dated August 19,1997, contained an action plan to install valves and flushing connections to a minimum of four locations on each system.

Gages and a flow meter will be installed to calculate a representative Hazen-Williams C-factor for hydraulic analysis of the present system. Based on the initial flushing and C-factor analysis, Procedure FS-FPE-113 will be revised to set up a periodic flushing program for all Augmented Quality (AQ) sprinkler systems at PGDP. The inspectors considered this action plan to be an adequate response to these problem reports.

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c. Conclusions The inspectors reviewed two closure packages related to sprinkler systems. The packages outlined corrective actions to address the concerns and described the actions taken. The inspectors noted the certificate holder is taking appropriate actions to correct the deficiencies w;th sprinkler systems and will review the facility's implementation of the action pbn in future inspections.

5.0 Surveillance Reauirements

a. Scope in IR 97-203, selected surveillance requirements of fire suppression systems were compared against the Safety Analysis Report (SAR) and the criteria of NFPA 25

" Standards for the Inspection. Testing, and Maintenance of Water Based Fire Protection Systems." Although the facility is not committed 'n NFPA 25, adherence to the industry standard could have prevented some of the deficiencies noted in IR 97-203. The inspectors reviewed a revised procedure and other olanned actions to address this concern,

b. Observations The inspectors reviewed the revised Procedure CP4 SS-FS6111, "TSR Surveillance, inspection, and Testing of Wet Pipe Sprinkler Systems," which requires that all visible sprinkler heads from the floor be visually inspected on an annual basis. This visual inspection specifically includes:

corrosion, foreign materials, paint, physical damage, and missing pipe;

  • proper orientation; mechanical damage, feakage, and corrosion of pipes and fittings;
  • materials resting on or hung from pipes; and
  • hangers.

The facility's inspection procedure requires an average of six systems in the large process buildings and an average of three systems in the smaller buildings to be inspected monthly so that all sprinkler systems will be completed on the last day of each calendar year beginning in 1998. The revised procedure is in accordance with the requirements of NFPA 25 in regard to annual surveillance of sprinklers.

The revised procedure also includes a requirement that when the inspector test valves were opened for the alarm test on a wet pipe riser system, the surveillance team would ensure a flow restricting orifice is place. Event reports had been prepared as l

the result of missing flow restricting orifices because the resulting surveillances were l considered deficient.

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, The revised procedure also requires a calibrated gage be installed on one riser in each 1

process building. These gages will be shop calibrated at 52 week intervals and used i

to check the accuracy of the other riser gage in each process building. At five year

, intervals, the calibrated gages and the gage errors will be recorded. Gage errors

exceeding 13% of full scale will be identified for corrective action. The inspectors j considered this planned action sufficient to meet the intent of NFPA 25 requirement ;

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c. Conclusions l Based on the review of the revised procedure and the planned actions, the inspectors i considered them to be a significant step in helping the certificate holder to correct '
previously. observed repetitive problems at the facility.-

i j- 6.0 Insoector Followuo items

! IFl No. 97 203 01. During inspection 97 203, the inspectors were not able to review

{ the hydrauli: calculations for the process building sprinkler systems. Prior to l Inspection 97-207, the staff reviewed the hydraulic calculations performed by Arthur

G. McKee Company in 1958 for the U.S. Atomic Energy Commission. The inspectors

, concluded that the system hydraulic design met the area-density requirements of i NFPA 13. During this inspection, the inspectors reviewed a Science Applications

! International Corporation (SAIC) report No. 5049 8450-100-02, " Combustible Fire l- Loading and Sprinkler System Assessment," dated June 1997, and a Professional Loss i Control (PLC) report, " Accident \nalysis of Process Building Lubricating Oil and j Hydraulic Oil Systems," dated 1981. The SAIC report cited calculations from the PLC i report, which analyzed two fire scenarios (a fire at a tube oil pit and a tube oil fire on

the cell floor) from the standpoint of coverage on the operat.ng floor and coverage on.

the cell floor. The SAIC report concluded that the installed sprinkler systems in the

process buildings at PGDP are adequate, by a substantial margin, to control a fire and to prevent structural collapse. Based on the SAIC report and the inspectors' evaluations, the inspectors concluded that the hydraulic design of the process bu!iding sprinkler systems is adequate and in conformance with NFPA 13. This IFl was closed.
IFl No.97-203 02. PGDP's pre-fire plan did not have adequate information or MCS for fire fighting purposes. The facility has' revised its pre fire plans based on , dattelle l report, "Use of Water in Fire Fighting." Fire fighters and E-Squad were trained on this subject during their annual HAZMAT refresher training in April 1997. The inspectors j reviewed the revised pre-fire plans, the Battelle report, and the training records and j concluded the revised pre-fire plans adequately addressed NCS. This IFl was closed.

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, Violation No. 97 203-03. During Inspection 97-203, the inspectors identified a section of missing sprinkler piping and associated sprinklers. This deficiency had been identified by the certificate holder during a walkdown of the process building sprinkler systems, but had been inadvertently closed out. The inspectors reviewed the certificate holder's written response to the violation and determined the stated corrective actions to be adequate. Some of the long term corrective actions had not been corr;!eted and implemented at the time of the inspection.

The inspectors toured the process buildings and inspected numerous sprinkler system repairs, including the missing branch line identified in the violation. Some new deficiencies were identified on the sprinkler systems protecting the bridge between buildings. Tt.e facility prepared problem reports for these deficiencies and initiated work packages. This violation will remain open until the long term corrective actions for the violation have been completed, and the newly identified deficiencies have been corrected.

IFl No. 97 203-04. During Inspection 97-203, the inspectors identified that the distance for fire extinguishers and fire alarm pull boxes on the bridge between buildings did not meet the requirements. PG'P reported that the extinguishers have been installed, but the targets identifying tl location and the alarm pull boxes had not. The inspectors walked through severa oridges and verified the installation of the extinguishers. This IFl will romain open unt" the corrective actions are completed.

IFl No. 97 203 05. In IR 97-203, the inspectors noted that there appeared to be a weakness in the reporting and followup corrective actions for out-of spec surveillance data in the fire protection area. This was noted in regard to out-of-spec sprinkler riser pressure gage readings. During this inspection, the inspectors reviewed the revised Procedure CP4-SS-FS6111, "TSR Surveillance, Inspection, and Testing of Wet Pipe Sprinkler Systems." This revised procedure includes instructions for immediate relief of pressure in a sprinkler system when a riser gage provides an out-of-spec (too high) reading. The revised procedure also requires that the shift fire officer in charge is informed of any out-of-spec observation. In addition, surveillance steps that support TSR requirements are flagged in the margin of the procedure. During the inspection, the certificate holder added a requirement that surveillance data sheets should be independently verified and that ot*-of-spec data (even if corrected) should be recordad.

The inspectors concluded that the weakness in the reporting and followup correctis e actions for out-of-epec curveillance data had been corrected. This IFl was closed IFl No. 97-203-06. PGDP's building reappraisals did not provide adequate fire safety information, and the format of reappraisals were inconsistent. In addition, the reappraisals were not upJated annually, as committed. At the time of this !.1spection, the f acility had prepared a schedule for updating building reappraisals, and the reappraisals for major process buildings has been updated. The facility also provided copies of the original building appraisals as the baseline for evaluation. The inspectors reviewed the original building appraisals, the revised reappraisals, and the schedule, and determined them to be adequate. This IFl was closed.

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_, IFl No. 97 203 07. During inspection 97 203, the inspectors raised concerns about a cooling tower fire event and requested a review of the final event investigation report, when available. During this inspection, the inspectors reviewed the final event investigation report and discussed the report with FS staff. The inspectors noted that this report did not go through peer review, and there seemed to be disagreements among FS staff in the conclusion of the report. This IFl will remain open pending the resolution of the disagreements.

7.0 Cnmoliance Plan issues Compliance Plan issue '4. The first part of Issue 14 required the two electric fire pumps in pump house C-631-3 be refurbished or replaced to add reliability to the High Pressure Fire Water System (HPFWS). In April 1996, the pumps were refurbished and

[ new controllers, instrumentation, and wiring were installed with the pumps. Post l modification acceptance testing was completed on November 14,1996. Surveillance

! testing on the syetem was completed on November 19,1996. The pumps were I- declared operable on November 20,1996. The inspectors reviewed the closure package for this part and considered it adequate. The first part of CP issue 14 was closed.

The second part of issue 14 required the connection of the sprinkler system in process Building C 315 to the HPFWS, The inspectors inspected the riser and fire main modifications for Building C 315 (located in Building C-620) and determined that the modifications were completed, and the system was in operation (supply and system gages read 130 psiindicating HPFWS system pressure). . During this inspection, the inspectors found that a drip valve appeared to be missing from a fitting on the fire department connection in addition, there was a fire department connection for the transformer deluge system (connected to the Sanitary and Fire Water System) around the corner of the building in close proximity to the fire department connection for the C-315 building sprinkler system. Neither fire department connection was labeled.

Because the fitting for the drip valve appeared to be lef t open, the inspectors questioned whether full acceptance testing in accordance with NFPA 13 had been performed. NFPA 13 requires pressurizing and flushing the fire department connection as part of the acceptance testing procedure. The certificate holder committed to NFPA 13 for modifications to the plant. 9ubsequent to the insMction, the certificate holder informed the inspectors that the automatic drip valve was, in fact, connected as part of the installed fitting and was operable. The certificate holder also stated that a flush of the fire department connection was performed. The inspectors concluded that this part of CP lssue 14 should remain open pending the review of the modification acceptance testing and correction of the noted deficiencies.

Compliance Plan issue 17. The first part of issue 17 required existing pre-fire plans to be updated to reflect current facility configurations and conditions. The pre-fire plans were reviewed during Inspection 97-203, and IFl 97 203-02 was identified. This IFl w as appropriately corrected.

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l-i , During this inspection, the inspectors reviewed the pre fire plans for process buildings

- C-331, C 333, C-335, C 337 and found generic deficiencies in the descriptions of the bridges between buildings and the descriptions of combustibles within the buildings.

The pre fire plans were revised during the inspection to address these generic deficiencies. The first part of Issue 17 was closed.

3-l The second part of Issue 17 required an analysis to be conducted to detcrmine the maximum allowable combustible loadings within the process buildings. The inspectors reviewed the SAIC report, and the recommendations in the report will be implemented i

in Procedure CP2 SS-FS1038, " Combustible Storage in Process Buildings," which was-

, scheduled to be effective on August 25,1997. This procedure, which was reviewed by the inspectors, was derived from NFPA 30 criteria, PLC report analyses, and the i SAIC report recommendations. This procedure specified a criteria for quantities, locations, storage conditions, and separation distances for combustible storage. It did f not specify maximum allowable quantities of combustibles for any of the process

buildings, it did, however, note that combustibles are not to be introduced into the
process buildings unless they are required to support plant operations. Training

! records indicated that process building custodians and facility managers had been j trained on this procedure. The inspectors noted that the inventory of waste combustibles stored within the process buildings should be periodically monitored.

4 Preferably, the overall combustible loadings within the process buildings will decrease, l or as a minimum, the facility should take positive steps to assure that the loadings do 4

not increase. This part of CP issue 17 was closed.

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ITEMS OPENED. CLOSED. AND DISCUSSED Ooened 97 207-01 IFl Inadequate hands on training frequency on portable fire extinguishers for fire fighters, E-squad, and fire watchers, 97-207-02 IFl Inspection and maintenance of f acility's grounding systems.

97-207-03 IFl Portable fire extinguishers with out-of-date HST.

C10 Sad 97 203-01 IFl Evaluate the facility's hydraulic calculations for the process building sprinkler systems.

97-203-02 IFl Inadequate nuclear criticality safety information in the facility's pre-fire plans.

97-203-05 IFl Weakness in the reporting and followup corrective actions for our of-spec surveillance data.

97-203-06 IFl Facility's building reappraisals did not provide adequate fire safety information and were not updated annually.

CP lssue 14 Pt1 The refurbishment of two electric motors in building C-631-3 was completed.

CP issue 17 Part one regarding existing pre fire plans in process buildings was closed.

Part two regarding analysis to determino maximum allowable combustion loadings was closed.

Discussed 97-203-03 VIO NRC inspectors identified a section of missing piping and associated sprinklers. This deficiency was identified by the certificate holder, but was inadvertently closed out.

97-203-04 IFl Distance for fire extinguishers and fire alarm pull boxes on the bridges between buildings did not meet the requirements.97-203 07 IFl Review and evaluate an investigation report for a cooling tower fire.

CP issue 14 Pt2 The issue regarding the sprinkler systems in building C 315 remains open pending the review of the modification acceptance testing and correction of the noted deficiencies.

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MANAGEMENT MEETINGS Exit Meetina Summarv inspectors met with PGDP management representatives throughout the inspection. The exit meeting was held on August 22,1997. No classified or proprietary information was identified. At the exit meeting, PGDP management and staff acknowledged the potential violation and other deficiencies, and agreed to take appropriate actions. The following is a list of exit meeting attendees:

H. Pulley, USEC W. Sykes, USEC G. Corrigan, SS&Q A. Sei. USEC J. Sm"5, Jr., USEC D. Stadler, USEC R. Wehat, USEC R. Wimbrow, USEC C. Hicks, USEC M. Fletcher, USEC G. Bazzell, DOE /SSR Y. Chen, NRC/NMSS R. Wescott, NRC/NMSS P. Lain, NRC/NMSS K. O'Brien, NRC/SRl/PGDP J. Jacobson, NRC/Rl/PGDP 15

LIST OF ACRONYMS USED AQ Augmented Quality BPS Business Prioritization System d

CO 2 Carbon Dioxide i

CFR Code of Federal Regulations

CP. Compliance Plan EMT Emergency Medical Technician ERO . Emergency Response Organization FS Firo Services GDP Gaseous Diffusion Plant HAZMAT Hazardous Materials HPFWS High cressure Fire Water System 4

HST Hydrostatic Testing IFl inspector Follow-up Item IR Inspection Report MSDS Material Safety Data Sheet NCS Nuclear Criticality Safety NFPA National Fire Protection Association j OSHA Occupational Safety and Health Act PGDP Paducah Gaseous Diffusion Plant PLC Professional Loss Control SAIC Science Applications International Corporation SAR Safety Analysis Report t

TDAG Training Development Administrative Guide USEC United States Enrichment Corporation i

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