ML20005F333

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/89-03.NRC Encouraged That Licensee Plan to Define Plant Emergency Response Team Training Program in More Detail

ML20005F333
Person / Time
Site:	Framatome ANP Richland
Issue date:	01/02/1990
From:	Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Malody C SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
References
NUDOCS 9001160188
Download: ML20005F333 (1)

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H Docket No. 70-1257 JAN - 2 10M a

H Advanced Nuclear fuels, Inc.

'2101~ Horn: Rapids Road P.'O.-Box 130

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Richland, Washington 99352 Attention: Mr. Charles W. Malody, Manager i

Corporate Licensing'

Gentlemen:

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Thank you for your letter dated December 18,'1989, in response to our Notice-of Violation and Inspection Re? ort No. 70-1257/89-03, dated November 8, 1989, i

informing us of the steps.you~1 ave:taken to correct the items which we brought s

to your attention.

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- The findings identified in the inspection report substantiated the Lviolation.

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We are encouraged that you ' plan to define your Piant Emergnecy Response Team training program in more detail to ensure'that an adequate' number of personnel' 1

.'are trained. -In regard to your response with our. concern of the excessive

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amount of combustible materials in the south end of.the Packaged Radioactive-n e

. Materials Warehouse, the July 31, 1990, goal to significantly reduce the

,e amount of combustibles appears acceptable.

Your corrective actions will be verified during a future inspection.

1 LYour cooperation with us is appreciated.

l Sincerely, g d e T Le b y $ P. Yuhas, Chie'f Gregor H

Emergency Preparedness and Radiological Protection Branch i

CC:

G.-H. Bidinger,-NMSS, HQ-O. W.f Malody, L ANF Corporation State of Washington bec w/ copy'of letter dated 12/18/89:

docket ~ file B. ' Faul kenberry J.. Martin bec w/o copy of letter dated 12/18/89:

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ADVAiJCED NUCLEAR FUELS CORPORATION I

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December 18, 1989 CWM:89:136 co.

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MS.NuclearzRegulatoryCommission O-1

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< 0 License No. SNM-1227 s.,

Docket No. 70-1257

-.a Gentlemen:

REPLY TO A NOTICE OF VIOLATION

.A' Notice of Violation was included as Appendix A to Inspection Report No. 70-11257/89-03 dated November 8, 1989, following an-inspection conducted on

' September 25-29, 1989 by NRC-RV..The violation was cited as follows:

" Condition 9 of License No. SNM-1227 authorizes, in part, the.use of

-licensed l materials in 'accordance with statements,' representations L

and. conditions coritained in Part I of thei Application dated July 1987 and supplements dated April 1,1989 (submitted by letter. dated March 30, L1989), 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

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-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.

1 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 I

the Plan, referenced above in the quoted citation, is stated as follows:

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D'ocument Control: Clerk.

CWM:89:136

' December 18,-1989-H

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F_ ire Extinouishers 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 fire extinguishers is also scheduled on an annual basis."

The statement addresses both em training in. identical language. ployee fire extinguisher ~ training and; PERT The words were not intended to convey that 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

. 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 ~ id, or ' radiation monitoring.

A PERT is composed of four a

l 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.

The. possibility for misinterpretation of the training requirements for PERT members-is acknowledged, and the Plan will be revised to remedy any misinter-protation. - In addition (beginning in 1990), records of the training each PERT member receives, along with a certification of any special-qualifications, will be< kept on file by' the Supervisor, Radiological and Industrial Safety.

The maintenance :of such recordsishall be a requirement of the Plan.

Plan revisions discussed above will be issued by January 31, 1990.

i The letter transmitting the subject audit report also requested certain information concerning used HEPA filter storage.

This request is quoted below.

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"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

-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 p

completion, and what compensatory measures could be taken until the amount of combustible material is reduced to an acceptable level."

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D'ocument Control Clerk CWM:89:136 i

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~ 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 UO 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 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 5/8-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 O

personnel also believe the filter storage to be adequate.

Certain facts which L

support this belief are listed below.

The south end of the warehouse is dead 1

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, i

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 NUREG-1140.

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."

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Document Control: Clerk-

'CWM:89:136

: - December-18,-1989 Page 4 In -summary, the lack of findings, comments, or observations by local fire 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 call.

Very truly yours, C. W. Malody, Manage Regulatory Complianc CWM:jrs cc: -John B. Martin, NRC-RV

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