ML20216J695
| ML20216J695 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant |
| Issue date: | 09/11/1997 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20216J684 | List: |
| References | |
| 70-7002-97-207, NUDOCS 9709180036 | |
| Download: ML20216J695 (7) | |
Text
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4 U.S. NUCLEAR PEGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Inspection Report No.
70-7002/97 207 Docket No.
70 7002 Facility Operator:
United States Enrichment Corporation Facility Name:
Portsmouth Gaseous Diffusion Plant Observations at:
Piketon, OH Inspection Conducted:
August 11 15,1997 Inspector:
Garrett Smith, FCOB l
Approved By:
Philip Ting, Cl.ief Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS N[$$$$ko00 2
Enclosure C
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EXECl2 flVE
SUMMARY
PORTSMOUTH GASEOUS DIFFUSION PLANT NRC INSPECTION REPORT 70-7002/97-207 Introduction NRC performed a routine, announced chemical process safety inspection of the U.S.
Enrichment Corporation (USEC) Portsmouth Gaseous Diffusion Plant (PORTS) at Piketon, OH from August 1115,1997. The inspection was performed by staff from NRC Headquarters.
The focus of this inspection was the implementation of documented safety features f r the
- X 330 CIF, facility. During past inspections, plant management indicated that CIF was one of 3
the high risk chemical hazards on site. To focus on risk, the inspector performed a vertical slice of this system to evaluate several of its safety features. First, the inspector revicwed the existing safety systems that are relied on and discussed in the plant safety documentation (i.e.,
the Process Hazard Analysis (PHA) and the Safety Analysis Report (SAR)) to ensure that they were in place and provided an adequate safety envelope for the system. Next, the inspector i
reviewed the maintenance program that is in place to ensure that these safety features will be l
available and reliable in the future, l
l The inspection also addressed the completion of Compliance Plan issue 39,
- Chemical Safety l
Mechanicat integrity Program." USEC stated in e June 18,1997, letter to the NRC that this item was completed.
The portions of the chemical process safety,.cogram implementation which were reviewed during the inspection included; j
Process Safety Information Maintenance and Inspection Significant Findings and Conclusions For the X 330 CIF process, the controls relied on for safety (both engineered and 3
administrativo) appeared to be in place in the field and matched the documented safety basis in the PHA and the SAR. Additionally, the facility has adequately implemented a maintenance program for the X-330 CIF system. This system tests the safety features relied on in the safety 3
documentation at an appropriate frequency and has a mechanism in place to retest those features in the future.
Compliance Plan issue 39 required a Mechanical Integrity Program be implemented by May 26, 1997, Based on the inspector's review of the ' Chemical Safety MechanicalIntegrity Program,"
POEF-LMUS 90,-dated May 1997 and the vertical slice evaluation of its implementation with respect to the X-330 CIF system, it has been determined that this program is adequate in both 3
scope and implementation.
3 DETAILS 1.0 Process Safety Information (88056) a.
Imnection Scopa The inspector reviewed the X 330 facilities CIF Process Hazards Analysis (PHA) and 3
Safety Analysis Report (SAR) Section 3.1.1.6.8, " Conditioning Gas (CG) Storage Facilities and D:stribution Lines" to evaluate its implementation with respect to as-built conditions in the field, Specifically, engineered and administrative controls relied on for process safety called out in the safety documents were walked down to ensure that the field conditions matched the documented safety basis.
b.
Observations and Findinas Chlorine triflouride (CIF ) is used at the plant in a mixture as a conditioning gas in the 3
4 gaseous diffusion process. The CG is supplied to the process via the CG feed system, with storage and feed point in the X-330 and X 333 process building.
1 The X 330 CG storage facility (located on the ground floor of the X 330 building at the east wall, near the center of the building) contains a 2,000 ft' conditioning gas storage drum, CIF loading manifolds, instrumentation and alarms necessary for safe 3
operations, and the piping and valves that connect the storage drum unP. to the cascades. Storage racks are located in the CIF storage room to store empty and full 3
CIF cylinders to support operations.
3 Normally, the system will contain an inventory of between 150 and 360 pounds of CIF3 in the storage drum. Two cylinders of CIF are connected to the loading manifold 3
(approximately 150 lbs of CIF per cylinder) and as many as 6 full cylinders may be 3
stored in this area at any given time.
Instrumentation is key to monitoring the status of the system. Locally mounted (on the storage drum and the cylinder feed lines) pressure instruments (indicator, transmitter and blind switch) are used to monitor the storage drum pressure to ensure it stays below 12 psia. The local pressure indicator directly monitors the tank pressure. The transmitter and blind switch monitor and actuate alarms, both at the Area Control Room (ACR) and locally when the pressure in the system reaches 12.0 psia. At 12.5. the system, among other actions, actuates another alarm and automatically closes the control valve to the loading manifoli Operating procedures used in this area indicate that two operations personnel are required to be present when any valving operation is performed in the CIF storage 3
drum room. One performs the operation while the other stands by, as backup. When cylinders are changed, the pigtail gaskets, flanges, and valves are chemically cleaned to remove any dirt, fingerprints, or other material prior to CIF coming in contact with them.
3 The operator involved is required to wear the appropriate protective equipment.
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c.
ConclusiDDS For the X-330 CIF process, the controls relied on for safety (both engineered and 3
administrative) appeared to be adequate and in place in the field and matched the documented safety basis in the PHA and the SAR.
2.0 Maintenance and Inspection (88062) a.
Scope The irispector reviewed the maintenance progrcm that is in place to ensure that the safety syMems relied on, and documented in the facilities safeN documentation, will be available and reliable in the future. Specifically, the X 330 CY system was reviewed, 3
b.
Observations and Findinas The CIF system relies on several safety features to ensure safe operation. These 3
features include the following:
3 Storage drum - this drum is a 2,000 ft horizontal cylindrical, heavy-gauge, SA 285 Grade 0, low carbon steel tank. The tank unit is pressure rated from 20 psia to 0.1 psia. Normal operations run the tank below 12 psia.
Pressure instrumentation arrny this equipment consists of pressure indication, transmitters, blind multipliers, alarms and annunciators. At 12 psia, in the storage drum, this system actuates an audible and visible alarm in the ACR. At 12.5 psia, the system actuates an additional alarm in the ACR, automatically closes the control valve to the loading manifold, actuates an alarm bell outside of the storage drum room, and de-energizes a light over the storage drum room entrance door, A separate alarm circuit associated with the cylinder feed pigtail lines will actuate an alarm and de-energi7e the light over the entrance door if the pressure reaches 12 psia.
System Piping and Valves - The 3-inch and 2-inch piping connecting the storage drum to the cascade is heavy-gauge, nickel lined steel pipe. The valves are either nickel-lined or money, Several maintenance and inspection activities are in place to ensure availability and reliability of these safety features. Operating procedure XP4-QA-Ol6926, ' Inspection of Unfired ASME Pressure Vessels," Rev. 2, dated February 10,1997, requires an annual external visual inspection, ultrasonic wall thickness testing every three years, and an internalinspection every 10 years of the storage drum. The inspector noted that the annual external inspection and the ultrasonic inspection were last completed on April 24,1997, and the internal inspection was completed on July 2,1993. These dates are within the acceptable frequency requirements outlined in the procedure,
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The pressure instrumentation array associated with this process had several functional tests and calibrations associated with its maintenance program. Specifically, qukrterly j
calibrations and monthly functional tests of the storage drum blind multiplier, and annual i
calibration of the blind multiplier for the cylinder feed pigtaillines are performed to 4
j ensure activation of the alarms and the system isolation features. Documentation provided by maintenance indicated all required tests and calibrations were successfully i
completed and up to date.
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The process piping and valves associated with this system, by procedure, receive both pre start and post maintenance inspections.
i All recurrent calibration, testing and functional tests sie tracked in the Computerized Maintenance Management System (CMMS) system. This system allows the actions to j
-- be monitored to help ensure that future actions will not be missed.
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c.
Conclusiom
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l The facility has adequately implemented a maintenance program of the X 330 CIF, system. This system tests the safety features relied on in the safety documentation at j
an appropriate frequency and has a mechanism in place to retest those features in the future.
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3.0 MechanicalIntegrating Program (88062) a.
Insoection Scaps i
On June 18,1997, USEC stated in correspondence to NRC that Portsmouth Compliance Plan issue 39 was complete. This item stated that USEC has not implemented all elements of a mechanicalintegrity program. The inspector reviewed this mechanical integrity program and its implementation.
- b.
ObieIYations and Findinat Section 1.0 and 2.0 of this inspection report describes the features relied on for safety and the maintenance program that ensures that these features are available and reliable in the future. The " Chemical Safety Mechanical Integrity Program," PO3F LMUS 90, dated May 1997 documents these programs.
This program documents the actions used to ensure the on-going integrity of the process equipment ' associated with the chemical systems regulated under 29 CFR 1910.119,' Process Safety Management of Highly Hazardous Chemicals." At the Portsmouth GDP, that includes the highest risk chemical systems:
1.
The X 330/X 333 Chlorine Triflouride Feed Systems.
2.
The X-342 Fluorine Generation System 3.
The Chlorine System at the X-611E Water Treatment Plant i
6 a
in general, the Mechanical Integrity Program formalizes the process that the plant uses to ensure the on going integrity of the process equipment in the systems listed above.
These systems have been identified as Augmented Quality (AQ) and therefore, the elements of a Configuration Management (CM) program apply. Basically, these elements include:
Identification of boundaries for each of the systems so that operating and maintenance personnel are aware that the system they are operating or maintaining requires special controls.
Design controls which ensure that the design basis of each system is maintained.
Procurement controls which ensure that only Engineering approved components are purchased and installed in the systems. Procurement controls include the activities from the development cf a specification through acceptance by receipt inspection.
Additionally, the covered chemical process systems involve routine, periodic connections to DOT approved cylinders. These cylinders provide the containment of high pressure gas and are connected to the process systems via a pigtail. Normal operating procedures and practices are in place to requite an inspection of the connectors and venfication that the connection is leak tight. Any deficienc:et noted during these preoperational checks are documented and corrective actions taken prior to putting the system in operation. These inspections are performed by Operations personnel.
Procedures are also in place to define both the corrective and preventive maintenance programs. When the requirement to perform a maintenance activity is identified, a Work Request is initiated. Because these chemical systems are designated 'AQ,' an AQ Work Package is developed for the maintenance activity, The use of an AQ Work Package requires that a maintenance procedure or work instructions be used for the perforniance of the maintenance activity. Additionally, an AQ Work (Mckage provides assurance that the correct repair part is used and that appropriate post maintenance testing is performed.
Finally, the mechanicalintegrity program defines the required periodic inspecilons and testing requirements for the covered processes. Section 2.0 of this inspection report documents the vertical slice evaluation that was used to ensure adequate implementation of these requirements for the X 330 C;F system, as noted before this 3
system was adequately implemented.
c.
ConclusiOD Compliance Plan issue 39 required a Mechanical Integrity Program be implemented by May 26,1997. Based on the inspector's review of " Chemical Safety Mechanical Integrity Program," POEF LMUS 90, dated May 1997 and the vertical slice evaluation of its implementation with respect to the X 330 CIF system, it has been determined that 3
this program is adequate in both scope and implementation.
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a g,
4 Follow up on Previously Identified items a.
? 37-204-0T (Closed) g,.-
f This item involved the disposition process used to address concerns identified in tne
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PHAs. Discussions with plant chemical safety personnel indicated that the latest
(
" vision of procedure UE2-HR Cl 1030
- Problem Reportinq' would be used to address
[
these types of concerns.
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Tne inspector reviewed this procedure, and this item will be cloceo.
h MANAGEMENT MEETINGS Inspectors : net with PORTS management representatives throughout the inspection. The exit meeting was held on August 15,1997. No classified or proprietary information was identified.
The following is a list of exit meeting attendees:
D. Allen USEC S. Martin, USEC R. Gaston, USEC L. Fink, USEC D. Ruggles, USEC M. Hasty, USEC T. Hester, USEC D. Rogers, USEC N. Stepp, U3EC C. Gamm, USEC G. Workman, USEC G. Salyers, USEC G. Smith, NRC D. Hurtlano, NRC LIST OF ACRONYMS AND ABBREVIATIONS USEC United States Enrichment Corporation PORTS Ponsmouth Gasec,Js Diffusion Plant PHA Process Hazard Analysis SAR Safety Analyuis Report CIF Chlorine Trifluoride 3
CG Conditioning Gas CMMS Computerized Maintenance Management System AQ Augmented Quality CM Configuration Management IFl inspector Follow Up ' tem
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