ML19354D579
| ML19354D579 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 12/18/1989 |
| From: | Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| CWM:89:136, NUDOCS 8912280117 | |
| Download: ML19354D579 (4) | |
Text
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-+ C ADuhNCEDNUCLEARFlMLS CORPORATION
[N> ' 05YEl?ON * "** "' "
0 December 18, 1989 CWM:89:136 l
U.S. Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop P1 37 r
Washington, DC 20555 License No. SNM 1227 Docket No. 70 1257 Gentlemen:
REPLY TO A NOTICE OF VIOLATION A Notice of Violation was included as Appendix A to inspection Report No. 70-1257/89 03 dated November 8,
1989, following an inspection conducted on September 25 29, 1989 by NRC-RV.
The violation was cited as follows:
t
" Condition 9 of License No. SNM-1227 authorizes, in part, the use of licensed materials in accordance with statements, representations e
and conditions contained in Part I of the Application dated July 1987 and supplements dated April 1, 1989 (submitted by letter dated March 30, 1989), which included the licensee's Emergency Plan, ANF-32, Revision 14.
ANF-32, Revision 14, and the previous revision (13) dated 1985 require specific training for the Plant Emergency Response Team (PERT).
Section 8 of the licensee's Emergency Plan (Revisions 13 and 14) requires that the PERT receive annual training in the use of portable fire extinguishers.
Contrary to the above, only 21 of 41 listed on the PERT attended the annual fire extinguisher training conducted in 1987, and only nine of 44 members of the PERT attended fire extinguisher training in 1988 "
Response
The currently approved Emergency Plan is ANF-32, Revision 14.
Section 8(e) of the Plan, referenced above in the quoted citation, is stated as follows:
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Document Control Clerk CWM:89:136 i
December 18, 1989 Page 2 l
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Fire Extinauishers i
Training in the use of portable fire extinguishers is scheduled on an annual basis for all employees.
Plant Emergency Response Team training in the use of portable l
fire extinguishers is also scheduled on an annual basis."
L The statement addresses both employee fire extinguisher training and PERT training in identical language.
The words were not intended to convey that r
all PERT members must receive training with fire extinguishers, anymore than that All employees must receive training with fire extinguishers, it has always been the ANF position that the PERT is a volunteer group and that all L
members are not necessarily trained in all activities.
There are normally 40+
members of the PERT, all of whom are not trained in SCBA, or fire extinguish-ment, or first aid, or radiation monitoring.
A PERT is composed of four members, one in each discipline, including a shift supervisor.
Four shifts can be covered with 16 members such that 40+ members provide significant backup, particularly in view of the fact that all four shifts are not normally staffed.
ANF has taken this position in good part due to the fact that professional fire protection and ambulance service by the City of Richland Fire Department is only minutes away, and they are, in turn, backed up by the Department of Energy fire Department, also nearby.
1 The possibility for misinterpretation of the training requirements for PERT members is acknowledged, and the Plan will be revised to remedy any misinter-pretation, in addition member receives, along (with a certification of any special qualifications,beginnin e
will-be kept on file by the Supervisor, Radiological and Industrial Safety.
The maintenance of such records shall be a requirement of the Plan.
Plan revisions discussed above will be issued by January 31, 1990.
The letter transmitting the subject audit report also requested certain information concerning used HEPA filter storage.
This request is quoted below.
i "Your attention is also directed to paragraph 5 of the enclosed
- report, which describes the excessive amount of combustible materials (filters) located in the south end of the Packaged Radioactive Materials Warehouse.
This matter is of concern to us because no fire protection system is provided in this area and special nuclear materials are being stored in an adjacent area in i
the same building.
We also understand that you have plans for the disposal of the vast number of used filters stored in this area.
In addition to the response to the violation, please describe your schedule for the removal of the filters, the expected date of completion, and what compensatory measures could be taken until the amount of combustible material is reduced to an acceptable level."
.s
' Document Control Clerk CWM:89:136 December 18, 1989 Page 3 Equipment has been designed and constructed to cut the noncombustible filter media from the wooden framing, and to compact the media into a 55 gallon drum.
The wooden framing will be subsequently incinerated, and the compacted media will be transferred to shallow land disposal.
The equipment is currently being installed in the U0 Building, with installation being scheduled for completion by December 31,2 1989.
Testing is scheduled to begin in January 1990, followed by routine operation beginning in April 1990.
The system is believed to be capable of handling 30 filters per day following the break-in and training period.
This equipment will first process currently replaced r
filters, and then process the backlog.
It is estimated that the inventory currently in the south end of the Radioactive Materials Warehouse will be significantly depleted by July 31, 1990.
The south end (25% of warehouse total floor space) of the all metal building where the filters are stored is separated from the remainder by a fire barrier consisting of four S/8 inch sheets of Fire X dry wall supported on metal
- studs, The filter cores are noncombustible, and the wooden frames are fire-resistant.
The center section of the warehouse (-50% of floor space) contains no significant combustible loading.
Storage is primarily for uranium oxide product in metal containers on metal pallets, or on steel shelving.
The temporary plastic partition at the north end of the center section mentioned in your report has been replaced with dry wall on metal studs.
Fire professionals from both the City of Richland and American Nuclear Insurers (ANI) have inspected this warehouse in its current condition and have not commented adversely or voiced concern.
The last inspection of ANF facilities by ANI was as recent as April 1989.
Certain findings from that inspection are mentioned in other sections of your report.
ANF fire safety personnel also believe the filter storage to be adequate.
Certain facts which support this belief are listed below.
The south end of the warehouse is dead storage with access control by a single custodian and safety personnel.
There is no ignition source in that section of the building, and it is posted as a "No Smoking" area; therefore, a credible mechanism for igniting the filter storage array is lacking, it is not considered credible that the center section of the warehouse, which contains the bulk of the uranium inventory, could become involved in a fire of any significance.
If a fire were to occur, it would be expected to have little consequence with regard to personnel exposure or ground contamination either on-or off-site, based on past history within the fuel fabrication industry as reported in NVREG-ll40.
Of the various fires and explosions reported in NUREG-1140 involving fuel fabrication facilities, it is stated that, "what is noteworthy is that these fires have had little consequence with regard to either personnel exposure or ground contamination.
Reported off-site contamination levels were generally below the levels that the NRC allows on equipment to be released for unrestricted use."
r Document Control Clerk CWM:89:136
. c December 18, 1989 Page 4-i In summary, the lack of findings, comments, or observations by local fire i
personnel and ANI, the lack of a credible ignition source in the filter storage area, the lack of significant combustible loading in other areas of the warehouse coupled with a history (NUREG 1140) of little consequence from fires under similar circumstances, cause us to believe that the safety measures taken to date are adequate to protect employees, the public, and the environment.
It is= our belief that the above information and proposed actions adequately answers your concerns.
If additional information is needed, feel free to L
call.
Very truly yours, F'
C. W. Malody, Manage Regulatory Complianc CWM:jrs cc:' John B. Martin, NRC RV I
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