ML20043A589
| ML20043A589 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 04/19/1990 |
| From: | Bores R, Datta A, Roth J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20043A586 | List: |
| References | |
| 70-0371-90-01, 70-371-90-1, NUDOCS 9005220284 | |
| Download: ML20043A589 (16) | |
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U. S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-371/90-01 D'ocket No.70-371 License No. SNM-368 Priority 1 Category UHFF
' Licensee: UNC Naval Products
'67 Sandy Desert Road Uncasville, Connecticut 06382-0981 Facility Name:
UNC Naval products Inspection At: Montville, Connecticut i
Inspection Conducted: March 5-8, 1990 Inspectors:
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d J. Apth, ipr 6je'ct Engineer, Effluents Radiation
/#att Pr$tjection Section, Facilities Radiation Saff ty and Safeguards Branch (FRSSB), Division of Radiation Safety and Safeguards (DRSS)
A. Datta Fire Protection Engineer, Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, Nuclear Material Safety and Safeguards (NMSS)
Approved b.
P/9' O
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.13 ores, Chief, 'Ef fluents Radiation date Protection Section, FRSSB, DRSS Inspection Summary:
Inspection on March 5-8, 1990 (Inspection Report No. 70-371/90-01).
Areas Inspected:
Routine, unannounced inspection by one region-based inspector and one fire protection engineer, NMSS - HQ of:
operations, nuclear criti-l 1
cality safety, organization, transportation and licensee actions on previously identified enforcement items. A review of the licensee's fire protection program was also conducted.
Results: One apparent violation was identified. Violation:
failure to measure the quantity of U-235 present in an unlimited two-high array of drums containing waste (paragraph 3.3).
9005220284 900420
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e DETAILS 1.0 Individuals Contacted
- B. Andrews, President
- G. Waugh, Executive Operating Officer
- R. Gregg, Director, Technical Services
- T. Gutman, Criticality and Licensing Specialist
- E. Barton, Industrial Safety and Hygiene Specialist D. Luster, Radiological and Environmental Control Specialist
- D Birks, Criticality Safety Engineer
- Denotes those present at the exit interview.
Other employees were also r
i interviewed during the inspection.
2.0 Licensee Action on Previously Identified Enforcement Items (Closed) Inspector Followup Item (371/83-04-05):
Issue approved internal health physics procedures to technicians.
Through discussions with the health physics technicians and examination of available procedures, the inspector verified that each health physics technician had been issued a copy of management reviewed and approved procedures which were developed to provide instructions to the health physics technicians in the conduct of their work.
Licensee actions have been completed on this item.
(Closed) Deviation (371/83-08-09):
Failure to meet a commitment to maintain a listing of Nuclear and Industrial Safety (NIS) approved procedures as described in a March 9, 1979 letter to the NRC. Through a review of licensee records, the inspector determined that the licensee established an alternative method to assure that a list of all NIS approved procedures is maintained.
In this case personnel in the NIS group have established a log of all NIS-approved procedures. That log has been periodically audited by comparison with procedures in the manufacturing area to assure that all required procedures are listed.
Actions have been completed to correct this item.
(Closed) Inspector Followup Item (371/84.-02-03): Assure that specific Quality Instructions (QIs) and Manufacturing Operating Procedures (MOPS) are referenced in the Unit I cleanup route card. Through a review of licensee records, the inspector determined that the licensee had modified the Unit I cleanup route card (SP-146) on July 15, 1986 (Revision 4) to eliminate the requirement to reference QIs or MOPS.
Instead, additional detail was added to the route card to preclude the need for the references.
Licensee actions have been completed on this item.
(Closed) Inspector Followup Item (371/84-02-05):
Failure to collect and analyze well water samples for the fourth quarter of 1983. This was licensee identified and reported to the NRC. Through discussions with licensee representatives and review of licensee records, the inspector I
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determined that the failure to collect and analyze those well water samples was caused by a failure of the vehicle used to transport the sampling pump and other equipment from well to well.
The vehicle was subsequently replaced and placed on a preventive maintenance program to preclude failure in the future.
(Also see discussions for the following item.) The licensee has completed corrective actions on this item.
(Closed)UnresolvedItem(371/84-02-07):
Licensee to assure that well water samples will be taken quarterly in the future.
Through a review of licensee records, the inspector determined that the licensee had not missed the taking of quarterly well water samples since the concern was identified in the fourth quarter of 1983.
This item has been resolved.
(Closed) Violation (371/84-12-01):
Radioactive material transferred to a burial site in a form (liquid) which the burial site was not authorized to receive.
In response to this violation, the licensee established a procedure which required a check on each waste drum to assure that it did not contain free-standing liquid. The inspector verified that this procedure remained in place and that it had been expanded to include a process to assure that each drum of waste liquids was completely solidified as required.
Licensee actions have been completed on this violation.
(Closed) Violation (371/85-05-01): A drum of low level waste sent to an approved burial site was not a strong, sight container in that it was found to have a hole in it.
In response to this violation, the licensee established a waste packaging and shipment audit group whose functions included the review of all waste packaging and shipment procedures and systems.
In addition, only quality control inspected shipping containers were authorized for use and the packaging route card was modified to require additional inspection of the containers prior to release for shipment.
The inspector verified that these actions were still in use at this facility.
Licensee actions have been completed on this violation.
(Closed) Inspector Followup Item (371/85-06-05):
The licensee was to reevaluate the raw fuel storage vault vertical storage array to assure safe storage of full fuel cans in a solid array.
The licensee completed a criticality safety analysis using KENO methodology to show that fuel stacking one and one-half cans high (solid array) would be safe and would be within the maximum K-effective allowed by the facility license. This analysis remains current and in effect.
The inspector had no further questions on this issue.
(Closed) Violation (371/85-06-06): Modify license application pages to assure that the NRC-approved license application reflects the current organizational structure. By letter dated May 14, 1985, the licensee requested that the organizational structure as described in the
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NRC-approved license application be modified to reflect the organizational structure current at that time.
The NRC approved this modification of the i
organization structure through the issuance of Amendment No. I dated July 31, 1985. At that time, the facility organizational chart was moved from the criteria section of the license application (Part 1) to the descriptive part of the license application (Part 2).
The licensee on March 6, 1990 sent a letter to the NRC describing recent organizational changes. This letter was sent to the NRC "for information only" but is currently being reviewed by NRC-Nuclear Material Safety and Safeguards j
(NMSS) personnel.
(Closed) Inspector Followup Item (371/85-12-01): Assure that the licensee i
modifies the U.S. Department of Transportation reference in the shipping Bill of Lading from 49 CFR 173.392 (c)(9) to 49 CFR 173.425 (b)(9).
The inspector verified through examination of the licensee's current Bill of Lading that the incorrect reference to the Title 49 paragraph containing instructions for the maintenance of exclusive use controls had been deleted from the Bill of Lading. Appropriate instructions have been added to the Bill of Lading. Actions have been completed by the licensee on r
this item.
(Closed) Violation (371/86-02-01):
Failure to post a table located in the Building B-North electron beam welding room. The inspector verified that the licensee posted the table with criticality safety controls as required and initiated and conducts facility audits to assure appropriate posting of work stations througheet the facility.
No further actions sere required by the licensee.
(Closed) Inspector Followup Item (371/86-02-02):
Reevaluate the wording and criticality safety limits established on a fuel bearing component transfer cart.
The inspector verified that the licensee reevaluated the criticality safety limits established on a fuel bearing component transfer cart (NIS Authorization I-D-22). As a result of this reevaluation, the limit was changed from e specific number of fuel bearing components, which was difficult to audit, to the physical capacity of the cart which was evaluated and found to be safe and easy to audit, Adequate actions were taken to correct this item.
(Closed) Inspector Followup Item (371/86-02-03):
Excess quantity of solvents and paper in glove box enclosures associated with Unit 2.
The inspector verified that all excess flammable and combustible materials were removed from the glove box enclosures associated with Unit 2.
During this inspection, the inspector verified that storage of these materials had been minimized. The licensee has completed actions on this item.
(Closed) Inspector Followup Item (371/86-02-04):
Excessive fire load in the Building M ventilation system mezzanine, the Building A basement and the East ~ Building low bay area third level. The inspector examined each of the identified areas and verified that the fire load had been
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significantly reduced and housekeeping practices had been significantly improved in each area. Appropriate corrective actions had been taken by the licensee.
(Closed) Violation (371/86-02-05):
Unauthorized use of two areas of the plant for the storage of special nuclear material. The inspector verified that the licensee requested and received an amendment to the facility license from NRC-NMSS to authorize the use and storage of special nuclear materials in the Building M extension component storage area and the Building M component inspection area. Amendment No. 10 issued by the NRC on February 9, 1987, corrected this violation.
(Closed) Violation (371/86-02-06):
Inadequate sampling of three stacks.
The inspector verified during examination of the facility that sampling locations for each of the three stacks had been modified to assure t
appropriate monitoring of effluents to comply with regulatory requirements. All. corrective actions have been completed by the licensee on this violation.
(Closed) Inspector Followup Item (371/86-07-01):
Emergency egress paths were blocked in Annex 3 because of poor housekeeping. During examination of Annex 3, The inspector determined that housekeeping in the facility had improved and that clear emergency egress paths were being maintained by the licensee.
Corrective actions have been completed on this item.
(Closed) Inspector Followup Item (371/86-07-02): Assure that the licensee informed NRC-NMSS of plans to build a new manufacturing facility to the south and west of Building B.
The inspector verified through a review of l
records that the licensee notified NRC-NMSS by letter dated August 26, 1986, of the intent to build a new manufacturing facility to the south and west of Building B.
NRC-NMSS authorized construction of this facility with Amendment No. 8 to the facility license, dated September 27, 1986. Actions on this item has been completed.
(Closed) Inspector Followup Item (371/86-07-03):
Unit 1 operators were to be retrained to assure that the quantity of residuals being transferred had not been removed from the log until the actual transfer occurred.
l Through a review of licensee records, the inspector determined that the Unit 1 operators were retrained on July 23, 1986 to assure that the quantity of residuals to be transferred was not removed from the area log until the actual transfer occur. red. The inspector examined the residual log for the time period July 1986 to January 1990, No inadequacies were identified in maintenance of the log.
(Closed) Violation (371/86-07-04):
Failure to maintain a record of nuclear safety inspections conducted during January, March and May, 1986.
The inspector verified through a review of licensee records, that the licensee had written, approved, and issued a procedure, NCS-001,
" Internal Nuclear Criticality Safety Inspections", which outlined requirements in the areas of inspection frequency, methods of recording
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identified deficiencies, and required followup to assure satisfactory correction of identified deficiencies. The inspector also examined the licensee's 1989 inspection records and found no inadequacies.
(Closed) Inspector Followup Item (371/86-07-05):
Licensee to evaluate secondary alarm station (SAS) escape routes to assure that personnel can safely evacuate the SAS during an emergency.
During Inspection No. 70-371/86-07, the inspector noted that all emergency routes out of the SAS were hazardous in that they consisted of steep stairs or rope ladders.
Subsequent to that inspection, as a result of NRC-required security program upgrades, the SAS was moved from the location observed during Inspection 70-371/86-07 to a more accessible location.
Egress from the new location was no longer hazardous to personnel staffing the
- station, i
(Closed) Inspector Followup Item (371/66-11-02):
Reevaluate the practice of storing, pending disposal, zircalloy machining wastes in 55 gallon containers, filled with argon gas, adjacent to the west end of Building B.
The inspector examined licenue records and determined that immediately following Inspection No. 70-371/86-11 the licensee moved the stored zircalloy machining waste away from the west end of Building B.
Subsequent to that inspection, the licensee modified the zircalloy disposa'l practices and reinitiated burning of these machining wastes.
The licensee continues to burn these machining wastes.
(Closed) Inspector Followup Item (371/86-11-04):
Provide additional and mandatory industrial safety training to supervisors. Through a review of licensee records and interviews with licensee personnel, the inspector determined that immediately following Inspection No. 70-371/86-11 the licensee provided mandatory industrial safety training to line supervisors and subsequent to that has provided those supervisors with annual retraining.
(Closed) Inspector Followup Item (371/86-11-05): Adjust calibration schedule for high range radiation detection instruments to ensure that sufficient instruments are available at all times. The inspector verified through a review of licensee records that the calibration schedule for high range instruments was modified shortly following Inspection No. 70-371/86-11 to assure that not all high range instruments were sent out for calibration at one time.
Licensee records indicate that several of these instruments were available at all times for emergency purposes.
Licensee actions have been completed on this item.
(0 pen) Inspector Followup Item (371/86-11-06):
Establish a program to assure that reviews and audits are conducted by persons not associated with the operations.
The inspector verified through a review of licensee records that the licensee has contracted with persons not associated with
7 the operations to conduct reviews and audits in the areas of health physics and criticality control practices. However, the licensee has not initiated or completed actions to have persons r.ot associated with operations conduct reviews and/or audits of the emergency planning pogram.
Licensee actions have not been completed on this item.
(Closed) Inspector Followup Item (371/86-11-07): Assure that management is informed on the results of nuclear criticality safety inspections, that records are maintained., corrective actions followed and that a nuclear criticality safety committee is established.
The inspector
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verified that the licensee established an executive safety committee in accordance with Organization and Policy Statement 15.08-0, dated April 15, 1987. This committee was made responsible for overview and coordination of the Division's safety programs including ir,dustrial safety, nuclear criticality safety, and radiation safety. Meetings are held at least once each quarter and topics such as, unu;ual occurrence reports, inspection reports, management awareness reports, status of the self-initiated improvement program and self-identified violations of nuclear criticality safety requirements, are reviewed. The licensee has completed appropriate actions on this item.
(Closed) Inspector Followup Item (371/86-11-08):
Conduct an audit or review of all documents not in the site document control system and establish more effective methods for the control of these documents.
Through discussions with licensee representatives and a review of licensee records, the inspector determined that the licensee conducts a review of all safety related procedures not covered by the site document control system on an annual cycle.
Through this review, the licensee has assured that the content of these documents remains current.
Most of the procedures reviewed during this audit were related to criticality safety instructions. The licensee has taken appropriate action on this item.
1 (Closed) Inspector Followup Item (371/86-11-09):
Standardize the format and content of route cards to assure that all required information is consistently presented. The inspector examined several route cards during the course of this inspection and determined that the licensee has established a standard format for the presentation of safety-related information on each route card.
For example, nuclear criticality safety information is presented at the top of each page and specific safety-related instructions are specified in the first paragraph of the route card instructions.
Corrective actions have been completed on this item.
(Closed) Inspector Followup Item (371/86-11-11):
Include a description of nuclear criticality safety controls in use at the facility in the employee indoctrination training session.
During Inspection No.
70-371/88-11 the inspector attended an employee indoctrination training session for the purpose of obtaining an onsite picture badge.
During that training session, licensee personnel provided an adequate description of the nuclear criticality safety controls in use at the facility.
The training was detailed sufficiently for employees to become familiar with 1
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the controls and the facility requirement to assure verbatim compliance with posted signs.
Corrective actions have been completed on this item.
(Closed) Inspector Followup Item (371/86-11-15): Assure that visitors entering the unciad fuel processing area receive adequate emergency training. The inspector verified through a review of licensee documents that the licensee modified the unclad fuel processing area entrance request form to contain emergency instructions to visitors (i.e.,
emergency egress routes). These instructions must be reviewed and acknowledged by signature prior to the visitor entering the area.
Appropriate actions have been completed on this item.
(Closed) Inspector Followup Item (371/86-11-17): Assure that hydrogen in all forms has been considered during the conduct of nuclear criticality safety analyses.
Through a review of licensee procedures, the inspector determined that the licensee had revised those procedures to assure that nuclear criticality safety evaluations consider moderation by hydrogen in various forms as required by operational conditions.
Hydrogen in the gaseous form, in water and in various types of plastics is now considered, as appropriate, in the evaluations conducted.
3.0 Review of Operations The inspector examined all areas of the plant to observe operations and activities in progress, to inspect the nuclear safety aspects of operations and to check the general status of cleanliness, housekeeping, and adherence to fire protection rules.
3.1 Contamination Control During examination of the Unit 2 facilities, the inspector noted that there was no step-off pad associated with the change line in the Unit 2 change room. This was identified as an inconsistency in the site-wide contamination control program in that step-off pads were provided for all other change lines including the Unit 3 vault, the Unit I change room, the Sectioning change room and the entry to the contaminated waste processing area of the Building B-South basement.
Licensee representatives stated that this inconsistency would be reevaluated and corrected as appropriate.
3.2 Housekeeping During a tour of the licensee's facilities, the inspector observed that there was a significant improvement in housekeeping associated with the storage of materials in Annex 3.
It was noted that the stored materials were appropriately stacked and that emergency egress routes were available and open. However, such was not the case in the Building B-North materials storage area located near Door 28.
In that location, materials were not properly stacked and
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packing materials were strewn throughout the area although egress routes were open.
Licensee management stated that appropriate actions would be immediately taken to clean up this area.
3.3 Storage of Unmeasured Quantities of U-235 During examination of the waste processing and storage area of Building B-south, the inspector noted that unsafe-by geometry drums of waste were being stored in two types of arrays. One array was based on an established transport index (TI) for each container with a maximum of 100 TI units in the array.
In the other array, each container was to be limited to a maximum of 50 grams V-235. With this uranium content, each container could be classified non-fissile, L
low specific activity, which would allow storage of an unlimited quantity of unsafe-by geometry containers in a two-high array, However, through discussions with licensee representatives the inspector determined that the U-235 content of an unknown number of the drums in this array was unmeasured and could be in excess of the i
50 gram V-235 limit.
Licensee representatives stated that a nuclear safety evaluation had been conducted to show that, based on a knowledge of facility processing information, no drum should contain in excess of about 25 grams of U-235.
Licensee representatives could not locate a copy of this evaluation during the course of this inspection or subsequent to this inspection.
The inspector stated that, although helpful, such an evaluation, based on historical-data alone, would not preclude drums from containing in excess of 50 grams of U-235 and, therefore, failure to measure the quantity of uranium-235 in each unsafe-by geometry drum prior to placement into the unlimited two-high array was identified as an apparent violation of license conditions (371/90-01-01),
3.4 Facility Modifications The inspector examined Building L to determine the status of installation of Unit 3.
It was noted that installation of storage facilities and special nuclear material handling devices had been completed in the Unit 3 vault and that the installation of major pieces of processing equipment and robotic material handling devices had been initiated in the processing area.
Some of this equipment was being tested prior to final installation.
4.0 Criticality Safety 4.1 Residual Analysis The inspector reviewed Shop Procedure SP-121, Revision 1, dated October 10, 1983, " Residual Testing and Storage". The procedure
10 provides the instructions required to analyze and properly store residuals generated in the fabrication process.
Between August 1,1989 and February 19, 1990, residual samples were analyzed and no rejects were identified. A reject is defined as any sample with a gamma radiation level in excess of a predetermined value.
4.2 Internal Reviews and Audits The inspector questioned licensee representatives regarding the conduct of internal reviews and audits from January 3, 1989 through November 30, 1989.
The licensee has placed records of these reviews and audits into a computer.
Each of the Nuclear and Industrial Safety (NIS) Authorizations posted throughout the facility designates a storage location, work station or transfer cart, the date that each Authorization was examined, the work shift during that 24-hour period, whether any violations were identified, and can also be displayed by the computer system. A hard copy of each violation identified, the corrective action taken, and the completion date is maintained separately by the licensee. The inspector reviewed the computer records of all inspections which were conducted during this time period. These inspections covered the nuclear safety aspects of operations during regular and off-shift hours.
The inspector verified-through the examination of licensee written records that corrective actions had been taken or initiated for each violation identified.
5.0 Organization Subsequent to the last inspection, the licensee modified the facility organizational structure and made cuts in staffing.
Mr. G. Waugh was previously the Executive Vice President and is now the Executive Operating Officer. The Vice President Quality Assurance now reports directly to the Executive Operating Officer and not the President, but has retained direct access to the President. Just prior to this inspection, the company announced plans to reduce the work force because of a reduction in expected business. The inspector determined that there was no impact on material control and accounting or safety personnel as a result of this reduction.
Subsequent to this inspection, the licensee announced that all operations at the facility would be terminated over the next two years and that the facility would be decontaminated for unrestricted use. The immediate impact on licensee staffing continues to be evaluated.
6.0 Fire Protection During this inspection, the licensee's fire protection program was reviewed by a fire protection engineer assigned to the NRC Office of Nuclear Material Safety and Safeguards (NMSS), Fuel Cycle Facilities Branch.
Following are the results of that review.
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11 The fire protection program of the facility was measured against the s
requirements of the recently published Branch Technical Position on fire
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protection, as well as relevant industry standards, including the National Fire Protection Association codes.
In performing the assessment, the fire protection engineer toured all the buildings and adjacent outdoor storage, materials handling, and equipment areas which house or support licensed activities. Documents and computerized data were examined for the purpose of assessing the licensee's commitment to the fire protection program and actual performance of procedures. The assessment method also included examination of randomly selected portable extinguishers, and installed fire protection equipment, process equipment, and past inspection reports of American Nuclear Insurers (ANI).
Several facility employees were also i
interviewed.
6.1 Building Fire Safety The manufacturing processes of the facility are contained in a cluster of buildings, which are interconnected and have fire-doors between each building.
The buildings consist of steel structures supporting built-up roofs on metal decks, concrete floors, and cast concrete or concrete block walls.
The construction is thus of noncombustible materials, however, the details of roof construction were not available and, therefore, the type of construction could not-be ascertained in accordance with the classificatior scheme of NFPA 220, " Standard on Types of Building Construction". All of the buildings, with the exception of the East Building, Annex III, and moderation-controlled areas, such as the raw fuel storage vaults in the other buildings, were protected by sprinkler systems.
These non-sprinklered areas were protected by portable extinguishers.
The auxiliary R, S and T Buildings contain non-fuel storage.
These buildings were detached from the process buildings and were sprinklered.
The fire sprinkler protection of the process buildings was determined to be adequate for the building structures and was in accordance with NFPA guidance.
The unsprinklered areas containing light combustible loading were also considered to be adequately protected by portable extinguishers of suitable types and capacities.
However, fire protection of the high-bay area of Annex III was found to be uncertain. This area, principally used for storage and which contained a moderate to heavy combustible loading, was protected.by heat and smoke detectors and portable extinguishers.
Because of the uncertainties in the evaluation of this area, the fire protection engineer requested the licensee to perform an evaluation of the fire hazard of this area, the adequacy of the existing protection measures, and the advisability of installing an automatic fire suppression system in the area. This was identified as an Inspector Followup Item (371/90-01-02).
Licensee representatives stated that this evaluation would be conducted.
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The fire protection engineer noted that areas where sprirklers were not installed because of special considerations, such as *.or criticality concerns, should have combustible loadings restricted to the absolute minimum. This principle seems to have been overlooked in certain rooms adjacent to the high bay area of the East Building, where formica-like plastic wall coverings and ceiling tiles have been installed. This material, as well as the glue used to attach it to the concrete wall were found to be combustible.
The fire protection engineer also noted that a tool room had been constructed in the East Building, adjacent to the Building-M Annex.
The walls and roof of that room were constructed of plywood.
This room, had an installed sprinkler system but was located in an area that was otherwise unsprinklered.
Providing sprinklers to a cubicle in an area where water suppression is excluded by design was determined to be questionable. As a result, the fire protection engineer requested the licensee to evaluate the fire hazards involved and include the results of that evaluation in the previously requested evaluation (371/90-01-02).
During examination of outside areas of the facility, the fire protection engineer observed that there were flammable and corrosive liquid storage bunkers attached to the south side of the Building-A.
These bunkers, which share the south outside wall of Building-A, have a wooden roof.
Since this is not in accordance with the pro-visions of NFPA 30, " Flammable and Combustible liquids Code", Section 4-4.2, " Cutoff Rooms and Attached Buildings", the bunkers should be reviewed for fire protection and brought into conformity with the NFPA Code, as necessary. This was identified as an Inspector Followup Item (371/90-01-03).
Licensee representatives stated that this construction will be reevaluated.
6.2 Process Fire Safety The fire protection engineer examined the manufacturing processes for fire hazards.
The hexane used in a process in Unit 2 in the Building B-South involves an obvious fire hazard.
This area is protected by a halon system, and lower explosive limit (LEL) monitors were installed with sensors located at several points throughout the facility. This system would sound an alarm if the hexane vapor to air ratio in the environment approached the lower explosive limit.
No deficiencies were found in this area.
The pit areas of Units 1 and 2 are protected by carbon dioxide extinguishing systems. No deficiencies were found in this area.
The fire protection engineer toured Building-L, examined the fire protection systems already installed, and discussed with facility personnel their plans for those systems that will be installed. Of particular interest were the plans for protection against fire
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13 occurring from an accidental spill from a possible rupture of a joint in high pressure piping containing flammable fluids. The licensee plans to install a dedicated, automatic sprinkler system in the immediate area around and below these facilities.
The Building-L Control Room / Computer Room was protected by a halon extinguishing system, which has halon discharge nozzles installed both in the room and below the floor-boards. The "De-Sac" room, which will contain processes utilizing octane, is adequately protected by sprinklers.
No deficiencies were noted in the new Building L facilities.
The handling and disposal of zircalloy scrap, a substantial quantity of which is generated in the machining process, were identified as potential fire protection concerns.
The fire protection engineer observed as workers collected the scrap and stored it under water in drums equipped with fire-arresting lids. The fire protection engineer was informed by licensee representatives that these drums were emptied daily and the scrap was incinerated on site. As a result, the licensee no longer stores significant quantities of zircalloy scrap for long periods of time.
No deficiencies were found in the zircalloy scrap handling process.
1 The fire protection engineer also examined the Buildings-A and M metal processing areas and associated acid storage and transfer equipment. No deficiencies were identified.
6.3 Fire protection Equipment The facility is equipped with a fire water system consisting of a 10" fire main, supplied by the Montville, Connecticut water system, 22 dry-barrel fire hydrants, a diesel-driven fire pump, a jockey pump, and a 300,000 gallon fire water storage tank.
The fire pump was started at the request of the fire protection engineer.' The no-flow delivery head was determined to be adequate.
However the fire protection engineer's request to observe a pump start (the jockey pump first and then the fire pump) by reducing the pressure in the fire main could not be complied with, since there was no test drain associated with the system. As a result, the fire protection engineer suggested that the licensee consider modifying this equipment so that the reduced pressure test could be conducted.
Licensee representatives stated that this modification would be examined for applicability to their system.
The fire protection engineer also determined through discussions with licensee repre-sentatives that the flywheel on the Cummins diesel engine driving the 4
L fire pump, had been replaced as recommended in the October 1986 Operational Safety Assessment report.
The facility possesses a 1250 gallon pumper truck and an emergency response vehicle.
The fire protection engineer toured the fire house and inspected the pumper and the equipment carried on it.
No deficiencies were identified.
p 14 In addition to the fixed fire suppression equipment discussed above, portable fire extinguishers are deployed at appropriate locations throughout the facility.
The fire protection engineer randomly checked several of these extinguishers. The type and capacity of the extinguishers appeared to be appropriate and monthly inspection tags were up-to-date.
No deficiencies were found in the fire suppression equipment.
Fire protection equipment maintenance records were examined by the fire protection engineer to ensure that inspection and maintenance of the equipment were timely. While the maintenance of fire equipment was satisfactory, there was no evidence that the diesel fire pump had t-ever been flow-tested.
Licensee personnel stated that such tests had never been conducted.
The fire protection engineer stated that annual fire pump tests were required by NFPA 20, " Standard for the Installation of Centrifugal Fire Pumps", Section 11-3.
The pump
" operating characteristics" obtained as a result of these tests should be compared with those supplied by the manufacturer, and any significant departures from the characteristics should be corrected.
Licensee representative stated that this test would be conducted.
This was identified as an Inspector Followup Item (371/90-01-04).
6.4 Fire Emergency Planning The fire protection engineer examined the licensee's Emergency Manual, which details the licensee's plans for responding to all emergencies, including those caused by fire. The manual details the functions of an Emergency Director, lists the personnel on the Fire Brigade on each of the three shifts and those on <5e medical assistance team, and the " call sequence" for summoning facility personrel and offsite help.
Specifically, for a fire emergency, the procetres require all fires to be reported by dialing "333" on the telephone and suppression of small fires to be attempted by workers in the area, using portable extinguishers.
The Emergency Director's functions include making decisions on calling the offsite fire department for help and on whether to order evacuation of areas of the facility. The procedures provide for fuel movement in an emergency only under the guidance of a criticality specialist.
Nuclear and fire emergency drills are performed annually. A more extensive emergency drill which included participation by offsite fire departments, law enforcement authorities, and medical personnel is condu:ted less frequently, the last one being held in December 1988, i
Although a separate fire emergency plan does not exist, the fire protection engineer determined that the elements of such a plan exist in the Emergency Manual examined.
No deficiencies were found in the area of emergency preparedness. However, the fire protection engineer stated that the licensee should consider the conduct of
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. f, 15 joint emergency response drills with offsite agencies at more frequent intervals.
Licensee representatives stated that this will be considered.
6.5 Administrative Controls The fire protection engineer examined the following licensee documents in order to gauge the extent of administrative control exerted over the movement and use of flammable materials; hazardous operations, such as welding; housekeeping; and safety audits.
6.5.1 Safety and Health Information System:
details procedures for handling hazardous materials, including flammable liquids.
6.5.2 Safety and Health Procedures:
details administrative procedures for issuance of " Safe Working Permits," including welding and other " hot working permits", and the conditions for issuance of such permits. Maintenance of a fire watch was one of the conditions which must be included for issuance of welding permits.
6.5.3 Safety Committee Inspection tours:
Contains reports on bi-monthly audits performed by in plant safety committees and records followup actions for the correction of safety deficiencies reported by the committees. The Emergency Director and the licensee's Fire Safety Engineer are members of these committees.
No deficiencies were found in the documentation. However, the fire protection engineer was concerned about the effectiveness of the administrative controls, as a result of the observation of certain practices during a tour of the facility.
In one instance, the fire protection engineer found isopropyl alcohol stored in two unapproved containers in the immediate vicinity of an autoclave in the Sectioning
-Area of Building B-South. The fire protection engineer noted that an identical hazard was identified in the same area, during the October 1986 Operational Safety Assessment and the practice continues. A licensee representative immediately had workers available in the area remove the containers and then instructed them on the hazard of such practices.
In another instance, combustible substances, including paper and plastic materials, were found stored on shelves in a designated flammable liquids storage area associated with the Metallurgical Laboratory. This was in a small room, in which flammable liquids were stored in approved containers and were apparently regularly dispensed into smaller vessels for laboratory use.
Storage of flammable liquids and other combustibles in
.the same area is hazardous. The fire protection engineer suggested that the licensee consider removal of all combustibles from the area.
Licensee representatives stated that removal of combustibles from this area will be considered.
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16 6.6 Training The facility Fire Brigade is composed of 26 fire and rescue personnel and eight paramedics.
Seven of the fire and rescue personnel were-State of Connecticut-certified fire fighters or fire instructors.
The fire protection engineer examined records showing training subjects, schedules and completion of courses by individual members of the brigade. The training subjects included hands-on fire fighting. The Fire Brigade members wear uniforms, indicative of a disciplined group. They also perform and maintain records of maintenance of fire protection equipment. The state certification documents of the instructors were examined and found to be in order.
The fire protection engineer stated that the Fire Brigade training program was excellent.
7.0 Exit Interview The inspector met with the licensee representatives (denoted in Paragraph
') at the conclusion of the inspection on March 8, 1990.
The inspector presented the scope and findings of the inspection. The inspector also held a pre-exit discussion on March 7, 1990 with the Director, Technical-Services prior to the exit interview.
The licensee was informed by a telephone call to the facility Criticality Safety Specialist on April 12, 1990, that failure to measure the uranium-235 content of waste drums stored in an array in the Waste Storage Area was a violation.
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