ML20212B668
| ML20212B668 | |
| Person / Time | |
|---|---|
| Site: | 07007001 |
| Issue date: | 09/15/1999 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20212B666 | List: |
| References | |
| 70-7001-99-202, NUDOCS 9909200196 | |
| Download: ML20212B668 (23) | |
Text
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U.S. NUCLEAR REGULATORY COMMiSGION l OFFICE OF NUCLEAR MATERIAL SAFETY AND SAF2 GUARDS l
Docket No: 70-7001 Certificate No. GDP-1 l
Report No: 70-7001/99-202 I l
Certificate Holder: United States Enrichment Corporation 1 Facility / Location: Paducah Gaseous Diffusion Plant P.O. Box 1410, l Paducah, KY 42001 l Inspection Dates: August 16-20,1999 Inspector: Peter S. Lee, Fuel Cycle Operations Branch !
l Approved By: Philip Ting, Chief l Operations Branch Division of Fuel Cycle Safety and Safegucrds, NMSS 1
Enclosure 9909200196 990915 PDR ADOCK 07007001 C PDR c,
2 EXECUTIVE
SUMMARY
United States Enrichment Corporation Paducah Gaseous Diffusion Plant inspection No. 70-7001/99-202 The Nuclear Regulatory Commission (NRC) performed a routine, announced fire protection inspection at the Paducah Gaseous Diffusion Plant (PGDP) in Paducah, Kentucky, on August 16-20,1999. The inspection focused on the implementation of PGDP fire protection program commitments concerning safe plant operations. Major fire safety performance reviewed included: maintenance of fire protection system design bases, assurance of availability and reliability of fire protection systems and components, adequacy of administrative fire prevention controls, manual fire suppression response capabilities, implementation of lessons learned from a Portsmouth fire, and actions taken to address sprinkler head corrosion.
Resul6s and Conclusions Enaineered Fire Protection Systems The certificate holder had provided an adequate level of assurance that the engineered fire protection systems in Buildings C-355, C-337, and C-337A would be able to perform their design-bases safety functions based on the following inspe.: tion results:
Plant conditions were adequately maintained within the original design base assumptions for the automatic sprinkler systems.
- An adequate inspection, testing, and maintenance (ITM) program was developed and implemented to assure the availability and reliability of fire suppression systems, the plant's fire pumps, and water distribution system.
- Technical Safety 4 quirements (TSR) Limiting Conditions of Operations (LCO) were adequately implemented for the corroded sprinkler heads, and appropriate actions were taken to assure that sprinkler system performance continues to meet its intended safety functions.
Implementation of Administrative Fire Prevention Controls A non-cited violation involving the failure to perform a 30-minute fire watch after the completion of a welding operation in Building 335 was identified during the inspection.
- Adequate combustible controls were implemented in Buildings C-335, C-337, and C-337A to rninimize potential fire severity and limit fire exposure hazards to the process buildings and to stored Uranium Hexafluoride cylinders.
Manual Fire Suporession Response Capabilities Adega i.aual fire response cf.pability was in place to mitigate a process building design basis fire ird ing tube or hydrauth oil based on:
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- ' TSR required staffing for the fire brigade and fire department was available for manual fire i suppression.
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Key firefighting equipment for manual fire suppression was adequately maintained and available. ,
Mutual aid agreements and letters of agreement were established with off-site fire departments to assist in the event of a major fire at the plant.
4 The Emergency Squad's performance was adequately maintained through a program of
' drills and exercises.
Imolementation of Lesson Leamed from the December 1998 Portsmouth Fire
- A majority of the Portsmouth lessons learned corrective actions in the areas related to fire protection and emergency preparedness have been implemented with the last two items
. pending completion near the end of September 1999. However, the corrective actions dio not consider the timely reconfiguration of the process building ventilation system in order to extend the time that process operators can remain in area control rooms to maintain process controls, and reduce the risk of worker exposure to smoke and toxic combustion products.
A non-cited violation was identified for not performing annual tests in accordance with CP4-CO-N6001 for lube and hydraulic oil systems in Buildings C-310, C-331, C-333, and C-337. = As a result, the availability or reliability of equipment important to remotely _ isolate
' various lube and hydraulic systems in the plant's main process buildings was not known until they were tested with positive results following the inspection.
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- 1 A potential generic concem was identified regarding maintaining the availability and reliability of equipment identified as "important to safety." !
Actions to Address Corroded Sprinkler Heads I An appropriate evaluation of the corroded sprinkler head is being conducted to determine the corrosion mechanism. Preliminary evidence points to microbiologicalinfluenced corrosion (MIC). The potential root cause appears to be associated with a change in water chemistry for the Recirculating Cooling Water (RCW) and High Pressure Fire Water System (HPFWS) and related treatment that occurred in 1987. The development of corrective actions is pending the
- results of additional sampling and testing of the sprinkler system water, scheduled for !
completion by the end of September 1999.
Attachments:
Partial Listing of Persons Contacted ;
- Inspection Procedure Used List of items Opened, Closed, and Discussed List of Acronyms 4
4 REPORT DETAILS
~1. Engineered Fire Protection Systems
- a. Scope The inspector reviewed and evaluated plant conditions to assure that they were within the original design bases and/or performance capabilities of autornatic sprinkler systems in Buildings C-335,' C337, and C337A.4 The inspector also reviewed the ITM for fire protection systems. The adequacy of fire protection systems to mitigate potential fire hazards and the certificate holder's adequate performance of ITM to assure the availability and reliability of ,
fire protection systems and components are necessary for safe plant operations. The
- lospector walked through process buildings, performed interviews, and reviewed related documentation and records.
- b. Observations and Findings j Maintainina Plant Conditions within Oriainal Desian Bases of Fire Protection Systems The certificate holder provided automatic sprinkler protection throughout Buildings C-335, t
C337, and C337A. The inspector performed walk-throughs to examine potential fire hazards (i.e., type of combustibles, storage configuration and potential fire hazards). The inspector determined that the combustible loading, storage configurations, and potential fire hazards were within the automatic sprinkler systems' design bases, and would not challenge the effectiveness or capability to contain a lube or hydraulic oil fire.
Imoact on Sorinkler Systems Performance from Sorinkler Head Corrosion .
In the recent months, an increased number of events have been reported to the NRC j regarding corroded sprinkler heads in the process buildings. From the initial discovery of a j few corroded sprinkler heads in May 1997.to the time of this inspection, a total of 172 corroded sprinkler heads have been identified. The certificate holder estimated that there are approximately 90,000 sprinkler heads in the four major process buildings.
Approximately 60 percent of the corroded sprinkler heads had been replaced The inspector i noted that the certificate holder had declared the automatic sprinkler systems with corroded ;
sprinkler head (s) inoperable and had established required compensatory measures. The corroded sprinkler heads were .aplaced with new sprinkler heads prior to declaring an ,
automatic sprinkler system operable. The inspector determined that the actions taken upon the finding of corroded sprinkler heads were consistent with requirements in the LCO of the plant's TSR.
The inspector noted that the certificate holder and the sprinkler manufacturer had examined and evaluated the_ impact of the corrosion (i.e., extemal deposit and internal corrosion of the copper gasket) on the actuation of the sprinkler heads. The examination identified corrosion of a copper gasket inside, which allowed small leaks to occur. A white colored material was
- found on the corroded sprinkler heals due to residual mineral deposits (e.g., consisting of
l calcium, chloride, sodium, sulfur, etc.) from'the evaporation of the system's non-portable I water that leaked due to corroded copper gaskets. It was determined that all of the corroded sprinkler heads would actuate at or near the rated temperature of 212'F, in accordance with ,
standard industry tests, and that the corrosion did not significantly impact to the performance of the sprinkler heads' intended safety function. It was also determined that an increased pressure is required to actuate the corroded sprinkler heads. The increased pressure ranged from an average of 30 psi to a maximum of 60 psi, assuming a normal minimum operating pressure of 7 psi. The increase in pressure was attributed to scale buildup on the interior of the sprinkler head. Only one of the corroded sprinkler heads tested resulted in the high initial pressure of 60 psi. Additional tests are being conducted to throughly evaluate potential operability concerns associated with corroded sprinkler heads:
The inspector also noted that the certificate holder had developed criteria for determining i operability of a sprinkler system with corroded sprinkler head (s). The criteria for declaring a j system inoperable is the finding of two corroded sprinkler heads adjacent to each other or the finding of more than five corroded sprinkler heads. The inspector noted that the i operability criteria was sufficiently conservative and acceptable. The certificate holder's actions in determining the possible root cause(s) for the corroded sprinkler heads and actions taken to address the sprinkler corrosion issue is further discussed in Section 5.
Inspection. Testino. and Maintenance of Fire Protection Systems l
The certificate holder had incorporated various inspection, testing, maintenance (ITM) i activities for the fire protection systems in the Surveillance Requirements (SR) of the plant's TSR. The inspector reviewed implementation of the ITM activities required by the plant's TSR and procedures for the following fire protection systems:
- Building C-335, C-337, and C-337A automatic sprinkler systems,
- Building C-335, C-337, and C-337A fire hydrants and control valves, and
- HPFWS fire pumps and water supply.
Automatic Sorinkler Systems. Hydrants and Control Valves: The inspector noted that Building C-335, C-337, and C-337A automatic sprinkler systems, surrounding area fire hydrants, and control valves were operable, with exception of those automatic sprinkler systerns that had been declared inoperable due tc corroded sprinkler heads. The inspector ;
l noted that Building C-337 had two sprinkler systems that had been declared inoperable. No other obvious material condition of concern were noted for the fire protection systems and components examined during the inspection. The inspector determined that the ITM for automatic sprinkler systems, hydrants, and associated control valves had been adequately performed in accordance with the plant's TSR and procedure requirem ^nts.
Plant Fire Pumos and Water Sucolv: The inspector reviewed the annual fire pump test results for the plant's electric and diesel fire pumps (No. 2, 3, 5 and 6) on the HPFWS that were performed on December 8,1998, and June 23,1999. The test results had been reviewed by United States Enrichment Corporation (USEC) fire protection engineer, and no concerns were identified related to the pumps' performance. The inspector indepcMently reviewed the results from fire pump tests and confirmed that they were adequate to meet l
6 flows and pressures needed by automatic sprinkler systems and manual fire suppression operations. The inspector also noted that weekly and monthly fire pump inspections and startups had been performed to assure the availability and reliability of the plant's fire pumps. During the walk-throughs of the fire pump facilities, the inspector noted no obvious material condition of concern for the electric or diesel fire pumps. The inspector noted that the water level at the Cooling Tower C-631-2 recirculating cooling water basin was being verified at the beginning of each operation shift to assure that the water level was within 5 feet from the top of the basin. This level provides approximately four million gallons of water for fire protection, which exceeds the minimum 825,000 gallons estimated for a design basis fire involving a lube or hydraulic oil fire in a process building. The surveillance interval exceeded the monthly frequency required by the plant's TSR and was considered appropriate for assuring an adequate water supply for fire protection. The inspector determined that the plant's fire pumps and water supply were adequately maintained for fire protection.
c. Conclusion
The certificate holder had provided an adequate level of assurance that the engineered fire protection systems in Buildings C-355, C-337, and C-337A would be able to perform their design-bases safety functions based on the following inspection results:
Plant conditions were adequately maintained within the original design base assumptions for the automatic sprinkler systems.
An adequate inspection, testing, and maintenance (ITM) program was developed and implemented to assure the availability and reliability of fire suppression systems, the plant's fire pumps, and water distribution system.
Technical Safety Requirements (TSR) Limiting Conditions of Operations (LCO) were adequately implemented for the corroded sprinkler heads, and appropriate actions were taken to assure that sprinkler system performance continues to meet its intended safety functions.
- 2. Implementation of Administrative Fire Prevention Controls
- a. Scope The inspector reviewed two key administrative controls used to minimize the occurrence, severity, and spread of a fire in Buildings C-335, C-337, and C-337A: control of hot work activities and control of combustibles and flammable liquids. The inspector walked-through process buildings and plant areas, interviewed plant employees, and reviewed documentation and records.
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- b. Observations and Findings
~ Control of Cuttina[Weldina. and Hot Work Activities The inspector reviewed the hot work permit program for the implementation of fire prevention controls to minimize the occurrence of fire from cutting, welding, and hot work operations.
The permit program requirements are established in Procedure CP2-SS-FS1031, " Welding,
. Buming, and Hotwork Permit." The inspector determined that the procedure was consistent with the industry practices described in National Fire Protection Association (NFPA) 51B, Fire Prevention in Use of Cutting and Welding Processes, and was adequate to address the -
, ' concerns and precautions necessary for fire safety.
However, the inspector identified a failure of a fire watch to follow the requirements of
_' Procedure CP2-SS-FS1301. Section 6.1.6 of the procedure required that the " fire watcher shall remain for at least half hour after completion of welding / hot work operations." Contrary to the requirement, on August 17,1999, during welding operations to add structural support for a seismic upgrade between columns T-18 and S-18 in Building C-335, the inspector and
' the USEC Fire Protection Engineer (FPE) observed that a fire watcher had left prior to completing the required half hour fire watch. The inspector and USEC FPE observed that the welding operations at that location ended at 8:55 a.m. and the fire watcher had left the area prior to 9:17 am A fire watch following welding, cutting or hot work operations is l required to be performed to observe and mitigate potentialignition of combustible material that could result in a fire. The failure to follow plant safety procedures resulted in inadequate implementation of PGDP - Safety Analysis Report (SAR), commitments in accordance with Section 5.4.8.7, Hot Work Permit Program.
Immediately following the identification of the finding, the certificate holder established a fire watch to assure fire safety at the welding site, and the certificate holder took actions to stop '
all hot work activities related to the seismic upgrade project in Building C-335. The certificate holder reemphasized the need to follow plant procedures to the USEC subcontractor performing the welding operations and reviewed training for subcontractor's p'
fire watchers. The certificate holder noted no inadequacy in training and noted that the fire watcher involved was current on fire watch training. The failure to perform an adequate fire
- watch was attributed to human error. To prevent the reoccurrence of the specific failure of the fire watcher to remain in the welding area for the required half hour, the certificate holder established an interim action that required the subcontractor to notify a USEC construction
- project manager or representative at the completion of each welding activity. The fire watcher would be required to have approval from a USEC employee prior to leaving the welding site. The inspector determined that the certificate holder's interim actions were acceptable. The certificate holder also indicated that long term actions to address the root cause (i.e., the inadequate implementation by USEC subcontractor personnel) had been planned, and was currently in the process of being implemented to improve the implementation and oversight of the hot work permit program at the plant.
The inspector noted the availability of the building automatic sprinkler system and adequate control of combustibles at the location of the welding operations. The inspector determined
- that the observed failure to follow Procedure CP2-SS-FS1301 did not result in a significant
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degradation of fire protection in Building C-335. Therefore, the inspector determined that the failure of a fire watcher to follow the plant procedure requirement to perform a 30-minute fire watch after the completion of welding operations in Building C-335 was a violation of minor safety significance, which is not subject to formal enforcement actions and does not require a formal response.
Controls of Combustibles The inspector reviewed the control of combustibles in Buildings C-335, C-337, and C-337A. I Procedure CP2-SS-FS1038, Combustible Storage in Process Buildings, established I guidance and limitations for permanent storage areas based on a combustible fire loading evaluation and sprinkler system assessment for the process buildings. The inspector noted that Procedure CP2-SS-FS1033, " Control of Flammable / Combustible Liquids," was established to control the use and storage of flammable and combustible liquids. The storage of combustible material, the incidental storage of combustibles or flammable liquids, and the bulk storage of lube and hydraulic oil were adequate to minimize the potential severity and rapid propagation of a fire inside the process buildings. The amount of ordinary combustible found in the buildings was determined to be below a quantity that could lead to a severe fire or the occurrence of a condition of flashover (i.e., ignition of all corhbustibles within a fire area). The inspector also reviewed the potential for exterior fire exposures to Buildings C-335, C-337, and C-337A and noted that the surrounding areas were maintained I free of combustibles that could present a potential fire exposure hazard. The inspector determined that the certificate holder had adequately controlled combustibles in and around Buildings C-335, C-337, and C-337A to minimize potential fire hazards.
Control of Combustibles in Proximity of Uranium Hexaflouride (UFA Cylinders The inspector reviewed the storage of full UF. (uranium hexafluoride) cylinders at Buildings C-310, C-315, C-333A, C-337A, and C-400. The inspector observed that the areas in the proximity of UF cylinders were generally free of combustibles, and no conditions were identified that could posed a potential fire exposure hazard to stored UF.
cylinders. However, the inspector observed that process building tube oil system refilling stations for Buildings C-333 and C-337 were located near UF. cylinders storage areas at Buildings C-333A and C-337A, respectively. The certificate holder indicated that refilling operations were infrequent, occurring once a year. The certificate holder also indicated that prior to filling operations, a verification of operability of at least one nearby fire hydrant would be performed and firefighters would standby with fire hoses during the refilling operation.
The inspector observed that there was an adequate separation distance between the nearest UF cylinder storage location and the oil refilling station, to minimize the potential of a significant fire exposure hazard. In addition, the elevation differences between the truck alleyways and the UF cylinders storage location prevented the potential spillover of a combustible liquid pool fire. The inspector determined that the certificate holder had provided an adequate level of control of combustibles in the proximity of UF cylinders.
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c. Conclusion
A non-cited violation involving the failure to perform a 30-minute fire watch after the completion of a welding operation in Building 335 was identified during the inspection.
i Adequate combustible controls were implemented in Buildings C-335, C-337, and I C-337A to minimize potential fire severity and limit fire exposure hazards to the process l buildings and to stered Uranium Hexafluoride cylinders.
- 3. Manual Fire Suppression Response Capabilities
- a. Scope The inspector reviewed the staffing and the availability of the onsite firefighters and fire brigade members to respond to a fire. The inspector also reviewed the availability and reliability of key firefighting equipment necessary to address a design basis fire involving lube or hydraulic oil in a process building, and the availability of off-site fire departments' assistance during plant emergencies.
- b. Observations and Findinas Emeroency Sauad Staffina for On-Site Fire Response The certificate holder had established an on-site emergency squad (E-Squad) to respond to j fires and other emergencies. The E-Squad includes full time firefighters and volunteer fire j brigade members. The certificate holder had provided a minimum level of training '
necessary to perform interior structural firefighting by the plant fire brigade. The inspector j reviewed the fire department's staffing schedules for firefighters and noted that the typical number of firefighters available was 5-6 during each shift, consistent with NFPA 1500, i Standard on Fire Department Occupational Safety and Health Program for safety of firefighters and effective fire ground operations. The TSR requirement for a minimum staffing of four firefighters was being met. The certificate holder had also provided a total staff of 42 firefighters and officers for the coverage of expected absences (i.e., training, personal leave, illness, etc.) and minimized the use of overtime that could result in performance concerns for firefighters.
Based on review of a fire brigade membership list dated August 17,1999, the inspector determined that the total number of fire brigade members in the E-Squad was approximately
- 83. The number of fire brigade members available during each shift ranged between 17-30.83. The inspector also noted that the availability of fire brigade members in the plant was monitored by the PSS office at the beginning of each shift to assure that a minimum staffing of four was maintained on the plant site at all times. The inspector determined that the certificate holder has provided a level of staffing for the fire brigade and fire department to perform manual fire suppression of a major fire at the plant.
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10 Availability and Maintenance of Kev Firefiahtina Eauioment Fire Department Firefiahtina ADoaratus and Fire Hoses The inspector reviewed the availability and maintenance of firefighting apparatus (i.e., a pumper truck and a ladder truck) that would be used to respond to a design basis fire involving a lube or hydraulic oil fire in a process building. The inspector noted that the fire trucks were in good condition. Daily equipment inspections, annual pump tests, testing of fire hoses, and other routine maintenance were provided to assure readiness of the fire trucks. The inspector determined that the certificate holder had provided adequate assurance for the availability and reliability of equipment important to fire suppression.
The inspector also reviewed maintenance of fire hoses to support manual fire suppression operations. The certificate holder had established and annually performed service tests of fire hoses to assure hose integrity under maximum working pressures. Fire hoses ranging from 1-1/2 to 6 inches were provided on the fire trucks for fire ground operations with additional reserve fire hoses located at the plant fire station and in the process buildings.
The inspector determined that the use of standard fire ground operations to connect and lay fire hoses from the fire apparatus (i.e., pumps) should overcome potential concerns for pressure losses due the use of long lengths of 1-1/2 or 1-3/4 inch fire hoses. The standard practice also provided adequate pressures necessary for the application of foam for suppressing a lube or hydraulic oil fire. The inspector determined that the firefighting equipment needed for manual fire suppression of a lube or hydraulic oil fire in a process building was adequately maintained and available.
Firefichtina Foam Aoplication Eauioment and Supolv The inspector noted that an eductor (i.e., equipment for the application of foam to suppress a lube or hydraulic oil fire) and a supply of light water aqueous film forming foam (AFFF) are stored on each of the fire trucks. Five - 5 gallon buckets of AFFF were stored on the pumper truck and three - 5 gallon buckets were available on the ladder truck. An additional forty-one
- 5 gallon buckets and five - 55 gallon drum of AFFF were stored in Building C-721. The inspector determined that the certificate holder had appropriately stored the AFFF within the manufacturer's recommended storage temperature of 35"F to 120*F. The inspector verified that the supply of AFFF did not have a shelf life that could adversely impact the physical or chemical characteristic of appropriate foam solutions for effective fire suppression. The inspector determined that an appropriue supply of AFFF was available for firefighting operations related to suppression of a combustible or flammable liquid pool fire.
Mutual Aid and Letters of Aareements for Off-Site Fire Department Assistance The inspector reviewed mutual aid agreements and letters of agreement between the certificate holder and off-site fire departments (i.e., West McCracken County Fire District, (WMCFD) Paducah Fire Department, and Lone Oak Fire District) to assure that formal agreements had been established and maintained for assistance during plant fire emergencies. Also, letters of agreement were established with West Paducah and McCracken County fire districts for equipment and personnel assistance in the event of a
~11 major fire at the plant. The agreements had been updated August 1997, and remain in effect until the year 2001. The inspector determined that the certificate holder had adequately established contacts with off-site fire departments to assist in the event of a major fire at the plant, and has met a commitment indicated in the plant's emergency plan.
Estimated Off-Site Fire Department Response Time and Drills and Exercises The inspector reviewed the off-site fire department response capability after a notification for assistance. The certificate holder indicated that the average response time from the nearest
- off-site fire department, WMCFD, located approximately 5 miles from the plant was within -
~ 5 to 10 minutes. The inspector confirmed the estimated average response time with the fire chief of the WMCFD.
The inspector also reviewed drills and exercises conducted by the plant's emergency preparedness organization that involved the plant's E-Squad and off-site fire departments.
The certificate holder indicated that drills and exercises involving the E-squad averaged about 20 each year, with approximately 30 or more actual E-squad responses to various types of actual plant emergencies. ' The inspector noted that a full participation exercise, involving off-site fire departments and other emergency response organizations, was conducted on April 1; 1998,~ and Portsmouth lessons leamed fire drills for each shift were conducted shortly after the occurrence of the Portsmouth fire. The inspector determined that the certificate holder had provided adequate emergency response capability by the plant's E-squad through performance of drills and exercises.
c. Conclusion
Adequate manual fire response capability was in placed to mitigate a process building
- design basis fire involving lube or hydraulic oil based on:
= . TSR required staffing for fire brigade and fire department was available for manual fire suppression '
- Key firefighting equipment for manual fire suppression was adequately maintained and available.
- Mutual aid agreements and letters of agreement were established with off-site fire departments to assist in the event of a major fire at the plant.
- The Emergency Squad's performance was adequately maintained through a program of drills and exercises.
- 4. Implementation of Lesson Learned from December 1998 Portsmouth Fire
- a. Scope The inspector reviewed the adequacy of the Portsmouth lessons learned corrective actions to improve the plant's preparedness and emergency response capability to quickly mitigate a
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12 process building lube or hydraulic oil fire. The inspector also reviewed the adequacy of key process controls and the maintenance of equipment to promptly isolate lube or hydraulic oil in the event of a fire.
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- b. Observations and Findinas lmolementation of Corrective Actions from Portsmouth Fire Lessons Learned The inspector noted that the certificate holder had established 14 corrective actions related
- to lessons learned from the Portsmouth fire on December 9,1998. The corrective actions were identified and tracked by the plant's Business Prioritization System (BPS) to assure completion. The inspector noted the following corrective actions were related to assuring the preparedness and effective emergency response to a fire involving lube or hydraulic oil in a process building:
Update and revise operation procedures to incorporate lessons leamed for prevention, containment, and control of potentially destructive cell reactions and to assure clear guidance for valving off the hydraulic oil in the event of a fire, Develop new procedures for guidance to the PSS for fire emergencies,
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Modify emergency classificatiori procedures to provide clear guidance to the PSS for
- activation of the emergency operations center and off-site notificatiori, .
Conduct process building drills on response to fires, Conduct E-Squad drills on response to destructive reactions, Evaluate Area Control Room (ACR) evacuation methods and ACR ventilation modification,
- Revise pre-fire plans and/or supplement for process buildings, .
=
lasue lesson plan for the use portable foam equipment for combustible liquid firefighting,
- Conduct briefing on lessons learned from the Portsmouth fire, Conduct hands-on training for deployment of fire hoses or firefighting operations in process buildings,
- Conduct classroom and hands-on training on the use of hand carried portable ,
foam equipment, i
Develop or revise procedure for guidance to plant personnel on fire emergencies, and
- Evaluate remote stopping capability for hydraulic pumps from the C-300.
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The inspector noted that a majority of the above corrective actions had been completed, with two items pending completion near the end of September 1999.
Lessons Learned to Address Buildina Ventilation Controls to Limit Scread of Smoke The inspector noted that the corrective actions resulting from the Portsmouth fire lessons leamed did not include the evaluation or specific updates of procedures or building pre-fire i plans to address the recenfiguration of process building ventilation systems. The I appropriate reconfiguration of the process building ventilation systems in a timely manner )
could limit propagation of smoke from the cell floor to the process floor or to ventilate smoke !
from the process floor. The inspector noted on the time line of events from the Fortsmouth l fire that the spread of smoke forced the evacuation of operators from ACR-6 after 9 minutes '
from the time that the lube and hydraulic oil fire became fully developed on the cell floor.
The timely reconfiguration of the process building ventilation system could extend the time of process operators in the ACR to maintained process controls and reduce the risk to i personnel exposure to smoke and toxic combustion products.
The inspector also noted that SAR, Section 3.3.5.11.6, Emergency Operations, assumes the capability to reconfigure the building ventilation to purge a UF, release or any similar situation detrimental to employee health and safety (e.g., smoke and toxic combustion product) through damper realignment to provide a maximum air flow. However, the incorporation of the SAR assumption was not apparent in the process building pre-fire plans and may not be specifically addressed in implementing procedures.
The certificate holder acknowledged that the pre-fire plans for process buildings did not include discussions of the ventilation system reconfiguration to limit smoke propagation, and it had not been considered among the lessons learned related to process building ventilation (i.e., affect of roof vents on sprinkler actuation time, and ventilation for the ACR have been evaluated). The certificate holder plans to further review and revise appropriate pre-fire plans and/or procedures to address the assumptions of the SAR. An assessment and tracking report (ATR), ATRC No. 99-3270 was established and entered into the plant's corrective action program. Updating pre-fire plans and/or procedures to address process building ventilation system controls (including the availabi!ity and reliability of equipment) to include the assumptions in Section 3.3.5.11.6, will be tracked as inspector Followup Item (IFI) 70-7001/99-202-01.
Assurance of Availability and Reliability of Eauioment important to Safety A key lesson teamed from the Portsmouth fire on December 9,1997, was the need to promptly isolate the flow of both lube and hydraulic oil to eliminate the fuel feeding the fire.
As a result of the lessons learned, the certificate holder had revised or rewritten at least three plant procedures (i.e., CP4-CO-ON3005, CP4-CO-ON3016c, and CP4-CO-ON3033) to address isolation of the lube and hydraulic oilin the event of a fire. The inspector noted that the certificate holder had provided and taken credit for the ability to remotely isolate or divert the lube and hydraulic oil flow in SAR Section 3.3.7.3 (i.e., start and stop of pumps and/or opening or closing of valves from the process building's ACR and the shutdown capability of tube oil pumps and closing or opening of valves from the Central Control Facility (CCF) at Building 300).
14 The inspector identified that the certificate holder had also established procedure CP4-CO-N6001b, " Annual Lube Oil Alarm Check," that required annual testing and verification of equipment and capabilities for isolating tube and hydraulic oil pumps and supply and drain block valves remotely from the ACR and the CCF. The implementation of testing and verification activities (or resulting maintenance) in accordance with established plant procedures would provide an adequate level of assurance that the equipment important to safety would be available and reliable.
However, contrary to plant procedure CP-CO-N6001b, the inspector identified that the certificate holder had not performed annual tests in accordance with CP4-CO-N6001 for tube and hydraulic oil systems No. 2,3, and 6 in Building C-333 in 1998. The inspector subsequently determined that the inadequacy noted was not limited to one process building, but involved a majority of the process buildings (i.e., lube and hydraulic oil system No.1,3, and 6 in Building C-337, No. 2 and 3 in Building C-331 and the system in Building C-310).
The exception to the above was Building C-335, where all systems had been tested in 1998 and the 1999 testing was scheduled for the month of October. As a result, the availability and reliability of equipment needed to remotely isolate various process building lube and hydraulic systems was indeterminent.
In addition, the inspector raised a generic concern regarding similar equipment not classified as safety related but that is important to safety. The inspector noted the need to assure availability and reliability tube oil pit sump pumps (Section 3.3.5.10.1), emergency ventilation purge controls (Section 3.3.5.11.6), and the pressure indicator for the detection of hydraulic line rupture (Section 5.4.1.1) as some examples of other equipment that are important to safety.
The certificate holder acknowledged the concern and planned to perform testing and verification in accordance with the plant procedures for the tube and hydraulic oil systems discussed above, Subsequent to the inspection, the certificate holder provided the lube and hydraulic oil systems test results, and no operability concerns were identified. Other actions taken by the certificate holder included entering the inspector finding into the plant's corrective action program by establishing ATR, Nos. ATRC-99-4921,4926,24897, and 4890, for each failure to follow plant procedures. The certificate holder indicated that the determination of the root cause(s) and implementation of corrective actions to prevent future reoccurrence would be addressed through the requirements of the plant's corrective actions tracking program. The certificate holder has also initiated ATRC No. 99-5151, to address tho generic implication related to equipment important to safety.
Based on consideration of the certificate holder's prompt corrective actions, the test results, the entry of the inspector findings into the plant's corrective action program, and the minimum impact on the overall margin of safety and fire protection defense-in-depth, the inspector determined that the finding resulted in a violation of minor safety significance.
The certificate holder's adequate assessment and implementation of corrective actions for the potential generic implication of the inspector finding regarding the maintenance of the availability and reliability of other enuipment important to safety will be tracked as IFl 70-7001/99-202-02.
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- c. Conclusion
- - A majority of the Portsmouth lessons learned corrective actions in the areas related to
, fire protection and emergency preparedness have been implemented with the last two items pending completion near the end of September 1999. However, the corrective actions did not consider the timely reconfiguration of the process building ventilation ;
system in order to extend the time that process operators can remain in area control I rooms to maintain process controls, and reduce the risk of worker exposure to smoke l and toxic combustion products. l l
-- A non-cited violation was identified for not performing annual tests in accordance with j CP4-CO-N6001 for lube and hydraulic oil systems in Buildings C-310, C-331, C-333, and l C-337. As a result, the availability or reliability of equipment important to remotely isolate 1 various lube and hydraulic systems in the plant's main process buildings was not known {
until they were tested with positive results following the inspection. l l
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A potential generic concern was identified regarding maintaining the availability and )
reliability of equipment identified as "important to safety."
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- 5. Actions to Address Corroded Sprinkler Heads !
- a. Scope The inspector reviewed the certificate holder's assessment and progress in the l determination of possible root cause(s) for the corroded sprinkler heads and corrective actions to correct and mitigate the corrosion.
- b. Observations and Findinos '
Assessment of the Corroded Sorinkler Heads and Possible Root Cause Section 1 of the inspection report discussed corroded sprinkler heads and actions taken !
regarding concerns of operability of process buildings' automatic sprinkler systems. The certificate holder, along with an onsite testing laboratory, had enlisted outside experts (i.e.,
water treatment and quality experts, the sprinkler manufacturer, and an independent testing laboratory) to test and analyze the corroded sprinkler heads.
At the time of the inspection, the certificate holder had concluded that the likely cause of the corrosion was due to MIC of the copper metal gasket. No apparent pitting corrosion of the interior of sprinkler piping or development of tubercles (mounds of localized corrosion) that coukt reduce the internal diameters of sprinkler piping were noted. The certificate holder had noted the following:
. The corrosion was internally caused and was not caused externally,
- Corroded sprinklers were randomly located on the operations floors and lower portions of cell floors, i
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- No cell floor ceiling sprinkler heads were found to be corroded,
- There was an apparent temperature dependence for locations of corrosion,
- Trace sulfur was found in the corrosion deposits, and
- The water was not fully treated and in a stagnant condition.
Based on the information above, the certificate holder was confident that the corrosion was associated with the water quality of the plant's RCWS and HPFWS. The certificate holder had noted from the key observations and findings above that the possible cause(s) was likely to be an anaerobic and/or aerobic bacteria caused MIC. Other classic characteristics such as pinhole leaks in piping with dark brown or rust color slime typical of MIC had not been identified at this time. Therefore, the certificate holder continued to perform sampling and testing of the sprinkler system water to conclusively determine the exact mechanism (s) {
and/or the type (s) of bacteria that may be causing the MIC. However, other possible causes had not been ruled out, such as contaminants, in-appropriate chemicals in the sprinkler system water or some metallurgical characteristic of the copper gaskets.
The inspector noted that MIC was a rear occurrence in the fire protection industry. The I concerns of MIC for sprinklers first began to appear in the late 1980s with an increased number of cases being reported in the mid-1990s. Relatively little is known about MIC in sprinkler systems. The certificate holder indicated that the plar' vitched to more !
environmentally friendly chemicals (i.e., phosphate-based, a copper corrosion inhibitor, and a biocide in lieu of using chromate) to treat non-portable water to inhibit corrosion and biological control in the plant's RCWS in 1987. The plant RCWS is the source of water i supply for the HPFWS and the fire suppression systems in the process buildings. The j
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inspector noted that the treatment of the RCWS water to inhibit corrosion and biological control was discussed in the SAR, Section 3.9.2.4, " Plant Water /RCW System." Based on information available at the time of the inspection, the inspector determined that the possible root cause of the corroded sprinkler could be associated with the change in water chemistry for the RCWS and HPFWS and related treatment, which resulted or allowed MIC of sprinkler heads.
Status of Corrective Actions or Plans to Address Root Cause The corrective actions for addressing the root cause(s) of the sprinkler head corrosion had not been developed. The certificate holder had determined that the likely cause of the corrosion inside the sprinkler heads was due to MIC. However, further sampling and testing of sprinkler system water to conclusively determine the exact mechanism (s) causing the corrosion was being performed, and would not be completed by outside experts, until the end of September 1999. The certificate holder indicated that after the determination of the l
cause(s), appropriate corrective actions necessary to thoroughly treat and eliminate the
! cause(s) of the corrosion would be developed.
The inspector noted that the inappropriate treatment could cause increased MIC by other new forms or increase existing colonies of bacteria. Therefore, the certificate holder's precautions to determine the exact cause(s) prior to developing and implementing treatment
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17 l was acceptable. The inspector noted that the available options for treating the MIC included i system flushing with biocide treated water, pipe cleaning, and/or replacement of affected pipe and sprinkler heads. The certificate holder's assessment, analysis, and corrective l actions to address the root cause of the corrosion will be tracked as IFl 70-7001/99-202-03.
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- c. Conclusion I The certificate holder had taken appropriate actions to determine the cause(s) of the I corroded sprinkler heads, with evidence pointing to the likelihood of MIC. The potential root cause of the corroded sprinkler appeared to be associated with the change in water l chemistry for the RCW and HPFWS and related treatment since 1987 that resulted or allowed the development of MIC in the process buildings' automatic sprinkler systems. The development of the corrective actions to treat the root cause is pending results from additional testing and analysis of automatic sprinkler system water, scheduled to be completed by the end of September 1999. j
- 6. Inspector FollowupItems VIO 70-7001/97-203-03: The violation addressed the missing piping and sprinkler heads identified by the certificate holder, but was inadvertently closed out prior to c trection of the deficiency. The deficiency located on Sprinkler System 17 in C-331 was id lied on March 26,1997, when an 18-foot section and 2 sprinkler heads were fount. .issing. On May 4,1997, a 100-percent, comprehensive, walkdown was completed in the process building. A revision of CP4-SS-FS611, "TSR Surveillance, inspection, and Testing of Wet Pipe Sprinkler Systems," was provided on June 24,1997. No further issues were identified; therefore, VIO No. 70-7001/97-203-03 was closed.
IFl 70-7001/97-203-04: The IFl was related to certificate holder's corrective actions for accessibility to fire extinguishers and fire alarm pull boxes on the walkways that connect process buildings. The inspector verified that fire extinguishers had been provided for the walkway connecting Building C-335 and Building C-337. The inspector verified that the certificate holder's formal closure documentation regarding the tasks to install fire extinguishers between walkways connecting Building C- 331 and Buildings C-333 and C-310 were adequate. The inspector noted that corrective actions to address the addition of fire alarm pull boxes had been entered into the plant's corrective actions and tracking system i.e., BPS. An engineering service order, No. Z98830, was issued on June 10,1999, for the design. The certificate holder indicated that the tasks to install the fire alarm pull boxes will be completed prior to August 2000. The inspector noted that an appropriate priority had been provided, based on a low safety significance associated with the conditions of code non-compliance. However, since the installation of fire alarm pull boxes had not been completed, this IFl remains open.
IFl 70-7001/97-203-07: The IFl was related to the review of a final investigation report for the C-637-2B cooling tower fire that occurred on September 23,1997. Two fires occurred during the demolition of the 637-2B cooling tower. The final investigation report concluded that the first fire resulted from the use of a faulty electrical extension cord and a second fire, approximately two hours later, resulted from use of a cutting torch to remove bolts. The lessons learned resulting from the investigations were training for the certificate holder's
l 18 contractor on fire prevention and safe performance of hot work activities, increased fire prevention inspections, and increased construction project oversight to prevent reoccurrence. The corrective actions were implemented and no further fires resulted from the demolition of the cooling tower. The investigation report was formally issued on October 29,1998, and was adequate. No further issues were identified; therefore, this IFl was closed.
IFl 70-7001/97-207-01: The inspectors identified that the certificate holder had not provided annual hands-on training of individuals expected to use fire extinguishers for manual fire suppression based on job assignments. The certificate holder completed training of all required individuals on November 16,1997. The plant's training and qualification tracking system was used to track and monitor the training requirements. The system provides a reasonable assurance that employee training will be maintained up to date. The inspector reviewed training records for firefighters and E-squad members, and noted that they were current. No further issues were identified, therefore, the IFl was closed.
IFl 70-7001/97-207-02: The IFl was related to the certificate holder's inspection and maintenance of facility grounding systems. The certificate holder evaluated the need to perform inspection and maintenance of the facility grounding systems in Engineering Evaluation No. EV-C-822-98-001, Rev. O, dated January 11,1998. The evaluation concluded that the grounding system configuration and the protection by a cathodic system assure performance and protection against corrosion. The certificate holder indicated that the grounding wiring was generally not exposed to the environment and encased in the concrete of the process buildings foundations. The certificate holder determined that NFPA 780 requirements for periodical inspections were not applicable. No further issues were identified; therefore, the IFl was closed.
IFl 70-7001/97-207-03: The IFl concerned the lack of hydrostatic testing and internal examination of portable fire extinguishers, as required by NFPA 10, Standard for Portable Fire Extinguishers. In addressing the IFl, the certificate holder identified an additional issue that was a significant condition adverse to cuality for portable fire extinguishers plant wide.
The certificate holder identified the potential cross contamination of two different types of dry chemical agents that may have occurred during fire extinguisher recharging between 1984 and 1994. The resulting cross contamination could have affected the fire extinguisher's ability to control fires, reacted chemically to produce ammonia and carbon dioxide gases that could over-pressurize the fire extinguisher cylinder, or produce chemical reactions that could result in caking of agents and corrosion of the metal fire extinguisher cylinders. The corrective action taken was to replace all dry chemical fire extinguishers. The certificate holder indicateJ that the corrective action was completed on January 31,1998, for the process buildings and February 2,1998, for the balance of the plant. All other types of fire extinguishers had been hydrostatic tested and inspected in accordance with requirements of industry standard. The inspector randomly reviewed a sample of carbon-dioxide fire extinguishers in Building C-337 and noted that they had been hydrostatically tested in 1998.
No further issues were identified. The IFl was closed.
19 Compliance Plan issue 14, Part 2: A portion of compliance plan issue No.14 remained l open pending the re-acceptance of the sprinkler system modification in Building C-315 (located at Building C-620) and appropriate labeling of the connection. The certificate holder l
indicated that a ball drip valve on the fire department connection had been provided and the fire department connections had been appropriately labeled. The inspector noted that corrective action was complete during plant walkthroughs, and no further issues were identified. The part 2 of the Compliance Plan Issue 14 was closed. j
- 7. Exit Meeting Summary The inspector communicated observations and findings to the certificate holder throughout the inspection and presented the final results to certificate holder management during an exit meeting held on August 20,1999. The certificate holder acknowledged the findings presented and committed to addressing them as discussed in the inspection report.
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i 20 Partial Listina of Persons Contacted '
i United States Enrichment Corporation M. Boren Nuclear Regulator Affairs, Event Report Manager R. Boudreaux Building C-335, Facility Manager M. Buckner - Operations, Manager L Calhoun : Fire Services, Firefighter-S.Cowne Nuclear Regulatory Affairs, Senior Engineer G. Corrigan Safety, Safeguards, and Quality, independent Assessments D. Elrod Emergency Management Manager J. Eastes USEC Subcontractor.
S. Gibson Fire Services, Training Officer A. Gilbert Building C -337, Facility Manager C. Hicks Site and Facilities, Manager
- L. Jackson Nuclear Regulatory Affairs, Manager J. Mansfield Emergency Management Specialist
- C.Page Shift Operations, Manager C. Randolph Service Supervisor, Subcontractor Seismic Upgrade Project
- S. Penrod Enrichment Plant Manager
- *A. Sevi Upper Cascade Maintenance, Manager
- D. Stadler . Nuclear Regulatory Affairs, Regulatory Compliance Engineer
- R. Starkey Plant Training, Manager M. Tailey - Recirculating Cooling Water Operations, Maintenance Manager J. Thompson . Operations, Cascade Coordinator D. Qugiley Building C -337A, Facility Manager
- B. Wimbrow Fire Services, Manager U.S. Nuclear Reaulatory Commission
- J. Jacobson USNRC Resident inspector
- K. O'Brien USNRC, Senior Resident - PGDP
- Indicates those attending the exit meeting on August 5,1999 Inspection Procedure Used
' IP 88055 Fire Protection i
21 List of items ODened. Closed. or Discussed Opened 70-7001/99-202-01 IFl The certificate holder's revisit of Portsmouth lessons leamed corrective actions to include update of pre-fire plans and/or procedures to address process building ventilation system controls (including the availability and reliability of equipment) to implement the assumptions of SAR, Section 3.3.5.11.6.
70-7001/99-202-02 IFl The certificate holder's adequate assessment and implementation of corrective actions for the potential generic implication of the inspector finding regarding the maintenance of the availability and reliability of equipment important to safety.
70-7001/99-202-03 IFl The certificate holder assessment, analysis, and corrective actions to address the root cause(s) for the corrosion of sprinkler heads or sprinkler piping and components of fire protection systems.
Closed 70-7001/97-203-03 VIO The violation addressed the missing piping and sprinkler heads identified by the certificate holder, but was inadvertently closed out prior to correction of the deficiency.
70-7001/97-203-07 IFl Review of a final investigation report for the C-637-2B cooling tower fire that occurred on September 23,1997.
70-7001/97-207-01 IFl The certificate holder had not provided hand-on training for individuals expected to use fire extinguishers for manual fire suppression based on job assignments.
I 70-7001/97-207-02 IFl The certificate holder's requirements for inspection and maintenance of facility's grounding systems.
l 70-7001/97-207-03 IFl The inadequate performance of hydrostatic test and internal examination of portable fire extinguishers as required by NFPA 10, Standard for Portable Fire Exti.1guishers.
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22 Compliance Plan issue The portion of compliance plan issue no.14 remained ;
14 Part 2 opened pending the re-acceptance of the sprinkler system !
modification in Building C-315 (located at Building C-620) and appropriate labeling of sprinkler system's fire department connection, j Discussed 70-7001/97-203-04 IFl Certificate holder's corrective actions for accessibility to fire extinguishers and fire alarm pull boxes on the walkways that connect process buildings ;
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23 List of Acronyms Used ACR Area Control Room
-AFFF Aqueous Film Forming Foam ATR Assessment and Tracking Report BPS Business Prioritization System CCF Central Control Facility FPE Fire Protection Engineer HPFWS High Pressure Fire Water System IFl Inspector Followup Item ITM Inspection, Testing, and Maintenance LCO Limiting Conditions of Operations MIC Microbiological influenced Corrosion NFPA National Fire Protection Association NRC Nuclear Regulatory Commission PGDP Paducah Gaseous Diffusion Plant .
PSI Pound per Square Inch PSS Plant Shift Superintendent RCW Recirculating Cooling Water RCWS Recirculating Cooling Water System SAR Safety Analysis Report SR Surveillance Requirements TSR Technical Safety Requirements UF. Uranium hexaflouride USEC United States Enrichment Corporation WMCFD West McCracken County Fire District.
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