ML20197A832

Insp Rept 70-0036/97-204 on 971215-19.No Violations Noted. Major Areas Inspected:Fire Protection Assessment,Fire Protection Sys,Fire Sys Insp & Testing,Fire Preventing & Emergency Response (Fire Safety)

ML20197A832
Person / Time
Site:	07000036
Issue date:	02/18/1998
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20197A818	List: ML20197A814 ML20197A832
References
70-0036-97-204, 70-36-97-204, NUDOCS 9803090392
Download: ML20197A832 (15)

Text

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1-U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Docket No. 70 36 License No. SNM 33 Report No. 70 36/97 204 Licensee: ABB Combustion Engineer;ig, Inc.

Location: Hematite, Missouri Inspection Dates: Decerr.ber 15-19,1997

Re-exit

February 4,1998 l Inspectors: Y. Chen, FCOB P. Lee, FCOB Approved By: Philip Ting, Chief Operations Branch Division c f Fuel Cycle Safety and Safeguards, NMSS Enclosure 9903090392 900219 PDR ADOCK 07000036 C PDR

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EXECUTIVE

SUMMARY

AB,' Combustion Engineering, Inc.

Inspection No. 70 36/97 204 4

The NRC performed a routine, announced fire safety inspection at the ABB Combustion Engineering facility located in Hematite, Missouri, on December 15 19,1997. to determine whether special nuclear material (SNM) and related safety controls (both hardware and human actions) required for the safe handling, processing and storage of SNM, were adequately protected from potential fire hazards. The areas examined during this inspection included: fire protection assessments, fire protection systems, fire system inspection and testing, fire prevention (combustible control), and emergency response (fire safety). Several fire protection performance weaknesses were identhi As a result, compliance with sarious commitments contained in Section 2 of the E', . rgency Plan could not be demonstrated.

Fire Protection Assessments A mechanism had not been established to assure that appropriate management review and disposition of life and fire safety issues, that interim compensa'ory measures were taken when required, and that corrective actions were completed in a timely manner (Details 1.b).

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No periodic audits were conducted to assess the effectiveness of the fire protection program, as recommended by industry standards and the NRC Branch Technical Position (Details 1.b).

Fire Protection Systenut

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A weakness was identified concerning maintenance of the design assumptions for the warehouse and storage area automatic sprinkler systems (Details 2.b).

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Various process area fire barriers have not been upgraded to limit tt e potential for a fire to spread between process areas and no formal schedule has been developed to assure the timely completion of this safety feature (Details 2.b).

Fire Protection System insoection. Testina. and Maintenance

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Procedures are being revised / upgraded to ensure the inspection, testing, and maintenance of fire alarn systems and suppression systems are consistent with industry standards and to ensure adequate documentatio, (Details 3.b).

A performance weakness was identified in that for a seven month period, an overheating problem with the single site tire pump was not corrected and appropriate compensatory measures were not provided (Details 3.b).

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, Fire Prevention (Combullible Control)

Procedures and controls were not established to control the storage of combustible materials to limit the severity and potential consequences of a fire (Details 4.b).

The criticality safety evaluation for the storage of filtrates erroneously assumed that a large fire was not credible due to the performance design criteria for the sprinkler ,

system (Details 4.b).

Emeroency Resoonse (Fire Safety)

Life safety requirements, such as adequate egress means for employees working on upper floors of the process bulk;ings, were not promptly addressed (Details 5.b).

• Management attention is required to assure that the commitments in Emergency Plan Section 2 have been developed, implemented, and maintained (Details 6).

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4 BEPORT DETAILS

. 1. Fire Protection Assessments

a. Snope '

The inspectors reviewed the licensee's quarterly inspection reports, annual audit reports, Safety Committee meeting minutes, and insurer's reports to determine whether facility fire safety-related issueh were being adequately managed,

b. Observations and Findinas

, Safety lasue ldahtification and Resolution The inspectors reviewed the fire protection issues and recommendations identified in the various licensee quarterly safety inspection reports, annual safety program audit reports, Safety Committee meeting minutes, and plant property / risk insurer's reports. In general, the progress status and/or closure of identified safety issues were being tracked through the reports or meeting minutes and not a centralized tracking system. However, the inspectors noted that several potentially significant issues identified by a plant insurer had not appeared to receive appropriate management attention. These srecific issues included: (1) Recommendation FR 90-6, isolation of the incinerator Room as one fire area, (2) Recommendation FR 95-4, fire wall upgrades, and (3) Recommendation FR 95-3, installation of sprinklers or detectors in currently non sprinkled areas. Discussions with the licensee's staff indicated that these issues were no

longer considered applicable because the plant had changed insurers. No other action i appeared to have been taken to assure that each item was evaluated and dispositioned by the plant staff, or that appropriate compensatory measures were taken. In addition, the inspectors determined that life-safety deficiencies (e.g., means of egress) known to the facility Safety Engineer had not been identified or discussed in any of the various reports or committee meeting minutes and no corrective actions or completion dates had been assigned by

management. Part of the licensee's responsibility to assure safe operation includes timely

identification and resolution of potential safety issues. The failure to establish a mechanism to assure that appropriate management review and disposition of identified fire and life safety-l related issues, that interim compensatory measures are taken when required, and that

, corrective actions are completed in a timely manner is considered a performance weakness and will be tracked as inspector Followup item (IFI) 70 36/97 204 01.

Safetv Related Audits The inspectors conducted discussions with licensee personnel and reviewed procedures to determine how the requirements of License Section 2.8, Audits and inspections, were met for the various facility safety programs. Section 2.8 states that " Audits and inspections shall be performed to determine if plant operations are conducted in accordance with applicable license conditions, C E policies, and written procedures. Audits shall apply to safety related and environmental prop" ms." Implementing procet .e RAAP-110, Rev. O,1nternal Audits and Inspections," pro > parallel wording. However, the inspectors noted that the audit scope guidance issued by tne Vice-President of Fuel Operations and the audit reports showed that the

5 annual audits emphasized only the criticality and radiological safety programs, and did not

, include the fire protection safety function.

Discussions with the licensee staff indicated that while their annual audit focused only on the criticality and radiological safety programs, their insurer's reports provided an independent audit that adequately covered the fire protection area. However, the inspectors noted that insurer reports generally concentrate on property protection and do not provide an evaluation of the overall program's adequacy. In addition, such life-safety issues as the means of egress for personnel from the multi-floor section of the main process facility are not typically addressed by the property insurer. The standard industry practice contained in National Fire Protection Association (NFPA) Code 801 is to conduct a periodical review of the fire protection program.

Further, NRC Branch Technical Position, Guidance for Fire Protection for Fuel Cycle Facilities (1992), recommended an annual audit of fire protection program. The licensee indicated that an industrial safety audit conducted in 1M4 had encompassed fire protection, and another one is planned for the first quarter of 1998. Review of the licensee's periodic audit to assess the effectiveness of the fire safety program will be tracked as IFl 70 36/97 204-02.

c. Conclusions The licensee had not established a system to assure ti,at life and fire safety issues received appropriate management attention, that interim compensatory measures were established as required, and that corrective actions were completed in a timely manner. Further, the licensee has not been conducting a periodic audit to assess the effectiveness of its fire protection program, as recommended by industry standards and the NRC Branch Technical Position.

2. Fire Protection Systems

a. Scope The inspectors interviewed the licensee's staff, reviewed fire protection system drawings, and performed a walk-through of the facility to verify that appropriately engineered fire protec' ion systems and features were 9rovided to mitigate potential fire hazards.

b. Observations and Findings Automatic Sucoression Systems The inspectors determined that the licensee provided wet pipe automatic sprinkler systems for the protection of the high fire hazard areas that included the storage and warehouse areas (Buildings 255-3,256-2, and 230), the laundry (Building 240-1), and the fire pump / emergency generator facility (Building 115). The sprinkler systems in the warehouses were designed to provide 0.18 gpm/sq. ft. over a 3000 sq. ft. area. This design criteria conforms to the industry standard specified in NFPA 13, Ordinary Hazard Group ll, for protection against a rapidly developing fire with a high rate of heat release in a storage area with a 12 foot height limit for combustible r..Jterial. The remaining areas were designed to provide 0.16 gpm/sq. ft. over a 1500 sq. ft. area in order to meet the hazard occupancy criteria for " Ordinary Hazard Group l."

6 The process areas of the facility were not protected by a sprinkler system due to nuclear

, criticality safety concerns.

During a walk through of the warehouse and storage areas, the inspectors observed that the storage and rack configuration for combustible materials exceeded the maximum storage height criteria of 12 feet. Should a fire occur under those conditions, the sprinkler systems would not meet the original design criteria for area coverage, cha!!enging their ability to contain or extinguish a fire. A fire under those conditions could exceed the expected fire severity and may adversely affect the process areas adjacent to the warehouse storage areas. The licensee had assumed that any warehouse fire would be quickly controlled or extinguished by the actuation of the sprinkler system. Howevar, the licensee has not yet completed a fire hazard analysis, evaluated the increase in fire risk, or established a formal procedure to impleinent administrative controls to ensure that the storage of combustibles in the warehouses does not exceed the desigri capability of the existing automatic sprinkler systems. Maintenance of the design assumptions for fire protection features will be tracked as IFl 70 36/97 204 03.

The inspectors also observed that fire department connections were not installed on the sprinkler systems. In addition, the sprir.kler system risers lacked a check valve (or alarm check valve) necessary for the proper installation of a fire department connection. The current industry standard for automatic sprinkler systems requires the installation of fire department connections as a means to increase sprinkler system pressure and as an alternative means of providing water supply, if the primary water supply is interrupted on the system side of the site fire pump. However, the NFPA code allows the authority having jurisdiction to approve an alternative installation without a fire department connection. The sprinkler system designs at the ABB facGy were prepared by a commercial sprinkler system installation contractor licensed in the state of Missouri and was reviewed and approved by ABB's insurer. Under this condition, a greater reliance would be placed on manual fire fighting by the responding fire departments.

Water Sucoly The water source for process operations and fire protection is provided by an above ground 200,000-gallon storage tank, which is supplied ' rom a well with pumping rate of 161 gpm. The inspectors determined that the water source could provide 1500 gpm of water for about 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 25 minutes of fire suppression. In addition, an alternative means of water supply could be established through a hose relay from a nearby municipal fire hydrant (approximately 1300 feet) and the use of water tankers from the local fire departments. Based on a review cf records for water tanker shuttle exercises performed by several surrounding municipal fire departments, an additional 500 gpm of water could also be provided by the responding fire departments, for a total water flow rate of greater than 1000 gpm through the alternative water supply.

The elevation difference between the water storage tank and the site provides a pressure of approximately 50 psi on the site water distribution system. The site water distribution system piping is not looped, providing one directional water flow. A 1500-gpm diesel driven fire pump

- installed in Building 115 is available to increase pressure in the site water distribution system for fire protection (i.e., sprinkler systems and fire hydrants). The fire pump would actuate upon a large water flow resulting from the actuation of sprinklers or water flow from hydrants.

7 EinDetestion Systems Fire Alarm Systems. and Other Features i

The licensee has installed smoke detectors and/or heat detectors in the high efficiency particulate air filtered ventilation systems, which provide indirect detection coverage for most process areas as smoke or heat is transported into the ventilation system. Smoke detectors are also provided in other areas, such as the Oxide Conversion ecntrol room and computer rooms. Alarm indication devices are located throughout the facility to provide indication of a fire alarm. The fire alarm control panel monitoring the smoke detectors, heat detectors, and other fire alarm initiating or supervising devices throughout the site is located in Building 253.

Remote fire alarm annunciators are provided at the manned guard station and three other remote locations at the site. The fire alarm control panel is connected to manufacturer supplied batteries to meet NFPA minimum requirements for emergency power. It is also connected to the diesel powered emergency generator that provides backup emergency power for the site.

The fire alarm system wiring was installed in conduits to protect against accidental physical damoges. The fire alarm control panel, listed by Factory Mutual and Underwriter Laboratory, provides assurance for system performance and reliability. No apparent deficiency was abserved for the installation of the fire alarm systera.

The main process buildings (e.g., Buildings 254,255, etc.) are operated around the clock. The continuous presence of operators prorides means of early detection of a fire in the process areas. Manual pull stations are provided throughout the facility for actuation by site personnel in the event of a fire.

Fire extinguishers are provided and distributed throughout the facility for incipient fire fighting by

..perators or the site emergency responders. The licensee has identFied one-hour fire barriers for limiting fire propagation between process areas in the main facility. Various upgrades, such as replacement of fire doors and sealing of penetrations, have been performed. However, not all of the required upgrades have been completed and no schedule has been developed to establish functioning fire barriers. The progress on upgrades will be reviewed along with IFl 70-36/97-204-01, regarding the appropriate management review and disposition of firo-safety related issues.

c. Conclusions in general, the licensee has provided appropriately engineered fire protection systems and features to mitigate the fire hazards found at the site. However, a weakness was identified concerning the control of combustible materials, particularly in the warehouse and storage areas. As a result, the design assumptions for the automatic sprinkler system were exceeded, which degraded the capability of this safety feature to perform its design function in the warehouse areas located adjacent to the main process areas. Further, various process area fire barriers have not yet been upgraded to limit the potential for a fire to spread between process areas, and no formal schedule has been developed to assure the timely completion of this safety feature.

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3. Fire Protection System Insoection. Testing. and.MaiDienance

. a. Sogge The inspectors conducted interviews with the licensee's staff and reviewed the intpection and

' testing records for fire protection systems to verify that adequate inspections, testing, and maintenance were performed to ensuse system reliability.

b. QbaqIYallonp and Findings 1

Fire Alarm System '

The review of service records performed by the off-site fire alarm system service contrrctor on the fire alarm system indicated that inspections, testing, and maintenance activities were performed annually. The services encompassed the requirements established by industry standard NFPA 72, National Fire Alarm Code. The quarterly inspection and testing for the initiating and supervisory devices on the automatic sprinkler systems were conducted by the off site sprinkler system service contractor. However the monthly and semi annual visual inspections of the fire alarm system were not documented when they were performed by on site staff. Visualinspections would allow detection of changes to the physical condition of the device or physical changes surrounding the devices that may impact their performance.

A change control management process has been established to ensure appropriate reviews of proposed activit!ss or physical changes within the ABB facility. This provides control over fire protection s,ystem changes in the facility that could affect performance of fire alarm system and components. The licensee is currently in the process of upgrading the fire protection system inspection and testing procedures to ensure that applicable monthly or semiannual fire alarm system inspections are incorporated for in-house inspection. The comprehensive annual inspection, testing, and maintenance of the fire alarm system and components is expected to be continued with the use of an off site fire alarm system service contractor. Fire alarm system trouble conditions were promptly addressed by the Safety Engineer through service requests to the eff-site contractor.

Fire Suooression Systems The review of service records indicated that an off site sprinkler services contractor provided inspection, testing, and maintenance of automatio sprinkler systems on a quarterly basis. The ,

general requirements for inspection, testing, and maintenance of automatic sprinkler systems (e.g, water flow alarms, supervisory alarm devices, control valve operations, main drain tests, etc.) were performed as required. However, the inspection of control valves (weekly / month!y) '

and gauges (monthly) were not documented when they were performed by on-site staff. The lic ensee is currently in the pmcess of revising and developing procedures to allow in-house

' inspections and testing of the automatic sprinkler systems and to ensure cons;stency with applicable requirements of NFPA 25. The procedure revision / upgrade for both fire alarm system and suppression systems will be tracked as IFl 70 36/97 204-04.

9 Fire Pump

. The inspection of the site fire pump in generalis consistent with established industry practice of weekly checks of the facility systems and components and start up with no flow. During a y review of pump test results, the inspectors noted that the licensee ide.atified an overheating problem during the annual fire pump test in September 1996. However, the required maintenance was not performed until April 1997. The cause of the pump overheatirig was subsequendy determined to be the presence of two rocks in the fire pump assembly dur, to the failure to property clean ar.d flush the underground piping following installation. The fire pump is a critical component for fire protection because it ensures that adequate flow and pressure is available to the facility sprinkler systems. The inspectors determined that the seven month duration between the identification and correction of a performance problem for an important safety componem to be excessive. In addition, no suitable compensatory measures were implemented to provide adequate protection while the degraded condition existed. The licensee's failure to promptly address the potential degradation of a critical fire safety component or provide appropriate compensatory measures is a performance weakness. The licensee's actions to identify the root cause of this failure and take appropriate correction actions will be tracked as IFl 70 36/97 204-05.  ;

c. Conclusion

in general, the licensee provided reasonable assurance that the installed fire protection systems could reliably perform their safety function. The licensee is currently revising and developing procedures to be r,onsistent with the industry practices specified in the NFPA codes to improve the imp;amentation and documentation of a comprehensive inspection, testing, and maintenance program. However, the seven-month failure to identify and correct an overheating problem with the single site fire pump or to provide appropriate compensatory measures is a performance weakness.

4. Fire Prevention (Combustible Contron

a. Scope The inspectors interviewed the licensee's staff, reviewed availabin procedures, and performed facility walk-throughs to veiify that adequate administrative contro!s were established and implemented for comoustible materials and hot work activities.

b. Observations and Findinas Process Areas During plant walk throughs, the inspectors observed little raccumulatLa of combustibles that could pose a significant fire hazard in the process areas. In general, precautions had been taken by the licensee to use non combustible containers for storage of transient combustibles and for disposal of trash. Combustible and flammable liquids were typically used in srnall

- quantities and were stored in flammable material storage cabinets at designated locations in the process areas, laboratory, or the warehouse. Flammable material storags cabinets wero

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generally located an appropriate distance away from existing heat sources, such as the process furnaces. The licensee's procedure adequately addressed the storage and handling of

. flammable and combustible liquids, incinerator Room The accumulation of combustible materials on wooden pallets awaiting incineration was observed in the incinerator Room in Building 240 of the main facility. Fixed large metal bins with covers were provided in the storage room for material awaitir.g incineration. The licensee stated that the accumulation or the quantity of combustibles allowed is limited by administrative controls. However, the administrative controls (e.g., quantity, designated locations, separation between pallets, etc.) were not formally established in the existing procedures for the storage of combustibles, such as those on pallets in the incinerator area. The control of combustib'es is a

. primary fire prevention measure to minimize the potential fire severity in the non sprinkled process areas. The occurrence of flashover in the incinerator Room could result in a fully developed room fire and the propagation of fire into adjacent process areas.

4 Warehouses As discussed in Details 2.b of this inspection report, the licensee has not yet completed a fire hazard analysis, or evaluated the increase in fire risk, or established a formal procedure to implement administrative controls to ensure that the storage of combustibles in the warehouse does not exceed the automatic sprinkler design. The lack of guidance for allowable storage (e.g., material, quantity, etc.) could resu't in a tire that would not be adequately controlled or suppressed by the existing sprinkler system.

Also, based on the interview with ABB's criticality safety engineer, it was noted that the criticality safety evaluation for the storage of filtrates (e.g., less than 3 grams / liter concentration of uranium) in containers in Building 230 warehouse assumed that a large fire was not credible due to the performance of the sprinklers. Therefore, an upset condition of the container failure

! from a fire exposure was not analyzed as an upset condition in the existing criticality safety evaluation. The current storage configuration of filtrates and combustibles in the warehouse may impact the assumptions of the existing criticality safety evaluation.

i in summary, the combustible control program is not adequately developed to ensure the implementation of required controls at the site. The licensee has not preformed appropriate fire protection analysic (the licensee has committed to include the performance in the integrated safety assessments) to determine the required controls of combustibles within facilities. The development of appropriate combustible material controls, will be tracked as IFl 70 36/

97-204-06. Updating the applicable criticelity safety evaluations for the storage of filtrctes in warehouse will be tracked as IFl 70-36/97-204-07.

Hot Work Procedure A fire occurred during the installation of additional lightir g for a down draft table in the process areas in 1996. It was determined that the root cause was the operator's failure to follow hot work procedures. Additional training (individual and general) was provided as the corrective

i lI action. The inspectors reviewed the licensee's Procedure O.S. 4001.00, Rev.1, ' Hot Work Operations,' and found that it was generally consistent with established industry practices regarding fire prevention for hot work activities (e.g., NFPA 51B).

! Areas Outside of Buildir"It

The inspection cf arese surrounding the buildings indicated that appropriate control of weeds and natural growtc %.'ited the potential for brush fires. Combustibles that would present a fire exposure potential were not stored around UF. cylindert. However, UF, cyliriders were stored -

on combustible wood cradlet. Section 6.5 of the License explicitly states, 'no combustibles shall be stored on the concrete pad.' The proposed replacement of wood with plastic composite cradles needs to be thoruughly evaluated by a fire hazard analysis to ensure that it does not pose a higher fire exposure potential to UF, cylinders.

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The general conditions observed for combustible control in the process areas of the plant t

appeared acceptable. However, procedures and controls were not established to ensure that

the combustible storage configurations in the warehouses are within the design capability of the automatic sprinklers systems. The existing procedures do not comprehensively address all

typs of combustibles present at the facility, such as combustible material staged for

. incineration. Formal controls for the storage of combustibles are needed to lirit the severity I and potential consequences of a fire and to ensure that the storage of combustibles does not

exceed the design capability of the existing fire protection system .

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5. Emergency Resoonse (Fire Safetv) 1

a. Scgon l

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The inspectors interviewed the licensee's Emergency Director to evaluate the facility's i

emergency recponse capacity during both normal- and off shift hours. The adequacy of the on-site emergency response center and available equipment for on-site emergency response

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were reviewed. The inspectors also evaluated the facility's life safety features. A tour of the Hematite Volunteer Fire Department was performed during the inspection.

l b. Observations and Findings

The inspectors interviewed the Emergency Director to learn the licensee's emergency response i organization. ApproximaWly 30 employees are assigned the responsibility of emergency 4-responders. The records showed that their training was up to-date in the following 9 areas: ,

hazardous operations, first aid, CPR, fire extinguisher, confined space entry, confined space rescue, emergency plan implemerting procedures, emergency shutoff, and self contained

breathing apparatus. The emergency responders are spread out among the three shifts, so 4

that each shift is staffed with an Emergency Director or alternato and the adequate number of emergency responders. ~

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The inspectors examined the on site emergency equipment and emergency response center, i

which appeared to be adequately equipped to meet the expected functions. The licensee relies on and closely coordinates with off site emergency responders. The primary off site mutual aid responder is the Hematite Volunteer Fire Department. The Hematite Volunteer Fire Department has established mutual aid agreements with other area fire districts, and assistance to the ABB facility could be expected from all surrounding fire departments. The inspectors visited the Hamatite Fire Volunteer Department to review its fire fighting equipment and apparatus. A full scale exercise was conducted in April 1996, and a fire incident occurred in August 1996. Appropriate fire department responses were provided in both cases.

The inspectors reviewed the licensee's Pre Fire Plan and determined that it contained sufficient information concerning fire fighting during an emergency. The Pre Fire Plan established the protocol for the coordination between the responding fire department and ABB's Emergency Director for fire fighting. Fire fighting in the process areas for nuclear criticahty safety is limited to non-aqueous fire suppressants (e.g., dry chemical, CO,, etc.). The use of water is clearly restricted in the areas wiB nuclear criticaPty concerns.

The inspectors r0 Viewed the facility's life safety featuros for emergency egress. The facility's emergency lighting is provided by the facility's back up electrical power. The emergency power generator is checked weekly. The operability of emergency lighting is randornly checked every year during unplanned power outage due to interruption of the primary electrical power supply.

Process areas in Buildings 254 and 260 contain several floors above the level of egress.

During regular shifts, at least two workers are expected to be on the upper floors to check on-going processes. The means of egress from the level above ground had been identified by the licensee Safety Engineer as not meeting the minimum requirements for egress specified in NFPA Life Safety Code. A minimum of two means of egress is required. The licensee's actions to correct this life safety deficiency will be tracked as IFl 70 36/97 204 08,

c. Conclusions in general, the licensee's emergency response capacity appeared adequt te. The licensee's emergency response for fire fighting and other hazardous material emergency relied primarily on off site responders. Both on site and off site emergency responders received training regarding on-site hazards. The Pre-Fire Plan appeared sufficient for fire fighting purposes, The licensee needs to ensure that life safety requirements, such as adequate egress means for employees working on upper floors of the process buildings, are promptly addressed.

6. Emergency Plan Commitments

a. Saggit The inspectors reviewed the Hematite Emergency Plan (E; , Ation 2, Types of Accidents, effective June 6,1994, to determine whether any changes were made to the facility that decreased the program's effectiveness.

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b. Observations EP Section 2.1.0, Minor Fire involving Uranium Bearing Me% rial, states that a significant release of uranium contamination to the environment is unlikely due to, among other th!ngs, the availability of fixed fire extinguishing equipment. Section 2,1.7, Major Fire or Explosion states that a major fire or explosion that could release significant amounts of uranium oxid; .n the form of powder or fragments into the atmosphere is very remote due to the extensive engineered features in the facility. Further, engineered safeguards are also incorporated to minimize the probability of explosion through the use of, among other things, control of combustible materials. ~ Additionally, routine inspections and audits are conducted to check for fire hazards.

Based on the findings regarding (1) the fire pump (Details 3.b), (2) the sprinkler system (Details

?.b), (3) combustible control (Details 4.b), and (4) inspections and auyts (Details 1.b), the inspectors determined that the EP commitments may not ha,1 been adequately developed, implemented, or maintained. This will be tracked as Unresolved item (URI) 70 36197 204-09.

c. Co0 dull 0D At the end of this inspection, the inspectors could not conclude that the licensee had adequately developed, implemented, and maintained EP commitments. The adequacy of the licensee's compliance to the EP commitments is considered an URI pending the inspectors' review of the licensee's required , 1ponse to this inspection report.

7. Exit Meetina Summary The inspectors presented the inspection scope and findings to members of the licensoe staff during the conclusion of the inspection on December 19,1997. The licensee staff acknowledged the findings presented, A re-exit conference call was conducted on February 4,1998, to acquire additional information.

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14 ITEMS OPENED. CLOSED. AND DISCUSSED

, Optattd 70 36/97-204 01 IFl The establishment of a mechanism to ensure appropriate identification and manag. ment commitment for the evaluation and disposition of fire and life safety related issues.

70 36/97 204 02 IFl The review of the licensee's safety audit to assess the effectiveness of the fire safety program.

70 36/97 204 03 IFl Ucensee's actions to ensure that the design criteria of the facliity's fire safety features are maintained.

70 36/97 204-04 IFl The completion and implementation of procedures to improve the implementation and documentation c' a comprehensive nspections, tecting, and maintenance of fire protection systems.

70 3P/97 204 05 IF: The determin:: tion of root causes and corrective actions for the licensee's failure to promptly address the potential degradation of a critical fire safety component.

70-36/97 204-06 IFl The establishment of appropriate combustible controls.

70 36/97 204 07

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lFl Update the applicable criticality safety evaluation for the storage of filtrates in wareheuse.

70-36/97 204-08 lFl Appropriate actions to address an identified life safety deficiency, e.g., egress means in the process buildings.

70-36/97 204-09 URI Development, implementation and maintenance of commitments referenced in Emergency Plan Section 2.

PARTIAL LIST OF PERSONS CONTACTED Licenten M. Eastburn' Criticality Specialist R. Freeman Criticality Specialist R. Griscom*

K. Hayes

• Safety Engineer B. Kaiser Fuel Operations Vice President A, Noack' Maintenance Manager G. Page' Director, Uranium Operations R. Sharkey* Director, Regulatory Affairs D. Stokes Total Quality D. Underwood*

S. Weich'

• Denotes exit meeting attendees.

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9 15 PARTIAL LIST OF DOCUMENTS REVIEWED

. Procedure O.S. 203, "Indut'.ry Safety'-

Procedure O.S. 860.00, " Incinerator Operating Procedure,' dated October 2,1997 Procedure O.S. 4001.00, Rev.1,

• Hot Work Operations' Procedure RAAP 105, Rev. O, ' Abnormal Event / Occurrence Reporting" Procedure RAAP.110, Rev. O, ' internal Audits and Inspections"

- Procedures EPIP 100s, Site Emergency Response Organizations and Notification Procedures EPIP 200s, Emergency Assessment, Classification, and Regulatory Notification Procedures EPIP 300s, Fire and Explosions Procedure NIS 213.00, ' Hazardous Material Management

• Procedure NIS 215.00, ' Fire Protection' Procedure NIS 216.00," Hazard Evaluations' Procedure QCP 5002.04, ' Change Control Management' ANI Fire /All Risk lnsurance Inspection Reports Annual Nuclear Criticality and Radiological Safety Audit Reports Rafety Committees meeting minutes LIST OF ACRONYMS AND ABBREVIATIONS ABB ABB Combustion Engineering, Inc.

EP Emergency Plan gpm Gallons Per Minute IFl Inspector Followup ltem NFPA National Fire Protection Association SNM Special Nuclear Material sq. ft. Aquare Feet URI Jnresolved item

_ =