ML20203E570

Insp Rept 70-1201/97-204 on 971117-18.No Violations Noted. Major Areas Inspected:Chemical Safety,Fire Protection Assessment & Sys & Testing & Emergency Response

ML20203E570
Person / Time
Site:	07001201
Issue date:	12/15/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20203E555	List: ML20203E551 ML20203E570
References
70-1201-97-204, NUDOCS 9712170095
Download: ML20203E570 (9)

Text

- - _ _ - _ _ - _ _ _ _ - _ - - - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ ______

U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUAD"S  ;

Docket No. 70-1201 l License No. SNM 1168 Report No. 70 1201/97 204 Licensee: Framatome Cogema Fuels -

Location: Lynchburg, VA 24506 Inspection Dates: November 1718,1997 4

Inspectors: G. Smith, FCOB Y. Chen FCOB P. Lee, FCOB S. Koenick, SPB Approved By: Philip Ting, Chief Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS l'

s Enclosure C pg - -

_-_ ~. ._ . _ _ . , _ . _ _ _ _ _ _ - , . _ _ . . . _ . _ . . .. ._

I 2

i EXECUTIVE

SUMMARY

Framatome Cogema Fuels inspection No. 70-1201/97-204 The NRC performed a routine announced combined chemical safety and fire safety inspection at Framatome Cogema Fuels (FCF) located in Lynchburg, Virginia, on November 17 and 18, 1997. The areas examined during this inspection included: chemical safety, fire protection assessments, fire protection systems, fire systems inspection and testing, and emergency response.

Chemical Safety The use of Hydrofluoric Acid (HF) and other hazardous chemicals in the cleaning room are adequately addressed in the facility's procedures. Personnel protective equipment was located in the area, and opeutions personnel were familiar with its use and location. The newly posted local safety rules are adequate.

The licensee has implemented a program to use calcium gluconate and/or zephiran for first aid treatment of HF exposures. Interviews with first aid responders indicated that they are knowledgeable with respect to first aid care for HF exposures. During the inspection, the licensee ordered more first aid chemicals to replace expired materials and committed to developing a program to ensure all HF first aid chemicals are replaced prior to expiration.

Eite Protection Assessments a

The facility has low fire risks, and the fire hazards in the facility are considered low. In general, the housekeeping in the facility is adequate. Combustible and flammable materials are appropriately controlled. The facility appeared to have an adequate process to review safety issues and perform pre operation evaluations. Recommendations from the Safety Review Board (SRB) and the American Nuclear Insurers' (ANI) inspections were appropriately responded to and addressed Fire Protection Systema Engineered fire protection systems are installed to provide early detection and/or suppression of a fire. The automatic sprinkler systems installed should provide adequate control or suppression of a fire within the sprinkler protected areas. Fire water supply at the facihty is considered reliable and should be sufficient to support the required fire flow for manual suppression of a major / catastrophic fire within the facility. Fire detection systems are installed in areas not equipped with sprinkler protection to provide reliable detection of a fire and initiate manual fire brigade or mutual aid fire department response.

w .- -

_. . _ _ _ . _ _ _ _ . -_..._ _ ._ -, m __ _.__ . _ -_. _._._. _ _-

, h 3

Fire Systems insoections. Testina. and Maintenance y Based on the observed conditions of the installed fire protection systems and the review d records of inspection, testing, end maintenance, the inspectors considered that a reasonable assurance for the reliable operation of fire protection systems has been provided at the facility.- ,

EmeroenGy Resoonse (Fire Safety)

The facility's emergency response team is trahed to respond to an event during the normal or off hour shift. The facility has a mutual aid agreement with local emergency organizations, which par'icipate in drills and receive training. It appeared that the facility's emergency response capacity is adequate for the type of hazards present.

REPORT DETAILS 4

1. Chemical Safety

a. Scope The inspectors reviewed the use of chemicals onsite. The focus of this review was the use of HF in the chemical cleaning area and included Standard Operating Procedure reviews and  !

operator interviews. Also, first aid responders were interviewed to discuss HF first aid,

b. Observations and Findings The inspectors toured the etching operations in the cleaning area to evaluate the use of hazardous chamicals. This process uses HF, nitric acid, and water to chemically clean metal components. The following procedures were reviewed for requirements that outline the safe handling of these hazardous chemicals: 1

- Procedure MA 548, " Control of Cleaning Processes at LMF," Revision 4, dated -

August 13,1997.

- Procedure MA 525," Dispensing of Nitric Acid," Revision 0, dated May 26,1992.

~A General Requirement in both procedures was that operations should be performed in accordance with all local safaty rules. .These local safety rules included the personnel

- protective equipment requirements for handling HF. Plant policy is to post local safety rules in the areas where they are required. - In the cleaning room, tip inspectors noted that no local safety rules were posted.- Operators in the area indicated th '.( the rules were posted, but had fallen and been removed. Once plant management was notified of the missing document, a new set of local safety rules was generated and posted. .

_x _

M F% *r'W^ T"M*W-Mtt'**! '" r

$* tetri- -- ce - ei"m-i, -tw we w y w-rei-'=re'W9**'ewP--N -e V" av*!'"16m *D' N'W* W-D'e-*e --'v- " e'F--s-*-r-----'-*'-wwwNrN iv'T' '*- ' 'r-'r-v"n- '*

9 4

Based on an NRC observation from 1995, the licensee had purchased first aid chemicals to treat personnel for potential HF exposures. Training had been completed for first aid personnel.

The inspectors reviewed the inventory of these chemicals and discovered that the calcium gluconate get had expired in July 1997, and the zephiran will expire in April 1998. The Safety Licensing manager indicated that replacement gel will be ordered, and a program put in place to review the expiration date of these chemicals to ensure that no out dated material will be used.

c. Conclusions The use of HF and other hazardous chemicals in the cleaning room are adequately addressed in the facility's procedures. Personnel protective equipment are located in the area, and operations personnel are familiar with its use and location. The newly posted local safety rules are adequate.

The licensee has implemented a program to use calcium gluconate and/or zephiran for first aid treatment of HF burns. Interviews with first aid responders indicated that they are knowledgeable with respect to first aid care for HF burns. During the inspection, the licensee ordered more first aid chemicals to replace expired materials and committed to developing a prt u em to ensure all HF first aid chemicals are replaced pnor to expiration.

2. Fire Protection Asienm201Q

a. Scope The ins,0ctors walked through the facility to evaluate the potential fire hazards and fire risks at the facility. The inspectors also reviewed the insurer's inspection reports and the facility's SRB meeting minutes to evaluate the handling of chemical / fire safety related issues.

b. Obiervations and Findinas The inspectors walked through the facihty to evaluate the fire loadings and the type of fire hazards in the facility, in general, the facility's housekeeping was acceptable. The facility has established procedures and policies to control various combustible and flammable materials.

Based on the documents reviewed and the walkthrough, the inspectors considered that the procedares and the poiicies adequately addressed the type of combustible and flammable materials onsite, and the facihty had appropriately implemented those procedures and policies.

The inspectors reviewed the SRB meeting minutes for the past two years. It appeared that a process was established to review safety issues and perform pre-operation evaluations. Based on the information reviewed, the inspectors considered that the process is appropriate, and safety issues are appropriately discussed and addressed. The timeliness of issue dispos; tion will be evaluated in future inspections. The inspectors also reviewed the latest two inspection reports from the facility's insurer, ANI. ANI made several recommendations concerning the facility's fire safety program, and, in general, these recommendations were for program enhancement and do not have a major safety impact. FCF has appropriately responded to these recommendations and also discussed them in the SRB meetings for disposition.

1

t

, t

[

. i 5

c. Conclusions The facihty has low fire risks, and the fire hazards in the facihty are considered low. In general,

the housekeeping in the facihty is adequate. Combustible and flammable materials are . '

appropriately controlled. The facility appeared to have an adequate process to review safety Issues and perform pre operation evaluations. Recommendations from the SRB and insurer's inspections were appropriately responded to and addressed.

3. Fire Protestion Systemt  !

I

a. Ssope The inspectors conducted interviews with the licensee's staff, reviewed fire protection system drawings, and performed a walk through of major buildings to verify that adequately engineered fire protection systems are provided to mitigate potential fire hazards.

b Qhteyallons and Findings Automatic Suppression Systems l Wet pipe automatic sprinkler protection is provided throughout the main FCF facility, Service Equipment Refurbishment facility (SERF) No. 3 and No. 4, and Record Storage, except in the

~

moderation controlled areas. The Chemical Storage building is protected by a dry pipe i sprinkler system.

The inspectors reviewed the sprinkler system hydraulic data at the sprinkler system risers and/or design drawings to determine the adequacy of the system design to protect against potential fires. A summary of the observations is provided in the following table:

FCF Automatic Sprinkler Systems

. Type of Design National Fire Protection

- Facihty or Automatic Density Design Area Association (NFPA) ,

2 Area Name Sprinkler (gpm/ft') (ft ) Code 13 System Hazard Classification Main FCF Facility Wet Pipe 0.2 2000 Ordinary Hazard Group 2 SERF 3 Wet Pipe 0.15 1500 Ordinary Hazard Group 1 (addition)

SERF-4 Wet Pipe 0.15 1500 Ordinary Hazard Group 1 Chemical Dry Pipe 0.4 4000 Extra Hazard Group 2 Stora0e The sprinkler system shop drawings, the hydraulic calculations, and the installation of sprinkler systems at the FCF facihties were performed by a commercial sprinkler system installation

6 vendor in the Commonwealth of Virginia. The design and hydraulic calculations for the addition to the existing sprinkler system in SERF 3 were reviewed and approved by ANI, FCF's insurer.

The design density uf 0.15 to 0.2 provides suppression or confining capability fer a potential fire with a moderate to high rate of heat release. The 0.4 design density of the dry pipe sprinkler system is adequate to protect against a fire with a very high rate of heat release and a rapid fire development.

The inspectors walked through the facility and did not observe ani condition that would potentially exceed the capability of the sprinkler system design or overcome the systems' intended performance. A fire occurring within the sprinkler protected area should be suppressed and/or confined. No apparent non-compliance with NFPA requirements for installation of sprinkler systems was observed. All sprinkler systems were in operable condition, and no out of service conditions were observed.

Water Supply FCF purchases its water (fire protection water and service water) from the Naval Nuclear Fuel Division, BWX Technologies, Inc. (BWXT). The fire water supply is gravity fed from the storage tanks to the automatic sprinkler systems and fire hydrants through a loop water distribution system. Fire pumps (one electric and one diesel) are available to increase pressure within the water distribution piping. Both the water storage tanks and the fire pumps are maintained by BWXT. A distribution system of 10 inch piping forms the water supply loop. The loop configuration of the water distribution piping allows for two paths of water flow supplying the automatic sprinkler systems. Water supply valves are locked or tamper switch installed to prevent or detect inadvertent closure of valves. A loss or interruption of fire water supply from the BWXT could be detected by interruption of setvice water to facility equipment and building services. An attemative source of fire water supply is provided by a 6.4 million gallon fish pond located adjacent to thP facility's North Parking Lot. Based on review of the water supply loop tests conducted by the licensee, the water supply at the facility is adequate to meet the water demand required by the facility's automatic sprinkler systems.

Based on building construction, sprinkler protectir i >ccupancy fire hazard classification, separation distance, and expected fire departmem esponse, the inspectors considered that the water supply at the facility should be sufficient to meet the fire flows required to manually suppress a major or catastrophic fire on site.

Fire Detection and Manual Fire Alarm Svalems Smoke detectors, heat detectors, or special detection systems are provided in most areas where sprinklers are not provided. Manual pull stations are installed throughout the facility.

The fire alarm notification can be heard through the facility's public announcement system and/or fire alarm indication devices. Two fire alarm control panels (in the main FCF facility and SERF-4) provide controls for fire detection, initiation, and indication devices at the site. All fire alarms are transmitted to the guard house, which is manned around the clock by the security force. Calls to emergency responders can be miated from the guard house.

7 During the facility walkthrough, the inspectors did not observe any apparent deficiency with the fire alarm control panels. The fire alarm control panels were connected to the emergency backup batteries, which could provide power for a duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and could initiate alarms for a duration of 10 minutes. The fire alarm system wiring was installed in conduits to protect ogainst accidental physical damages; a break in wiring could initiate a system trouble signal.

The fire alarm control panels are approved and listed by Factory Mutual and Underwriter Laboratory, which assure system performance reliability. No apparent oeficiency was observed for the installation of fire alarm system.

C. Concluilons Engineered fire protection systems are installed to provide early detection and/or suppression of a fire. The automatic sprinkler systems installed should provide adequate control or suppression of a fire within the sprinkler protected areas. Fire water supply at the facility is considered reliable and should be sufficient to support the required fire fbw for manual suppression of a major / catastrophic fire within the facility. Fire detection systems are installed in areas not equipped with sprinkler protection to provide reliable detection of a fire and initiate manual fire brigade or mutual aid fire department response.

4. Fire Systems inspections. Tesitng and Maintenance

a. Scope The inspectors discussed with the facility staff and reviewed the inspection and testing records for fire protection systems to verify that adequate inspection and testing are performed to ensure reliable systems.

b. QbieIYations and Findings The inspectors reviewed the inspection and testing records for sprinkler systems, fire alarm systems, fire hydrants, valves, and other components of fire protection equipment. The type and frequency of the inspections, testing, and maintenance performed are consistent with the minimum requirements established in NFPA 13A and 72H. However, the current editions of NFPA 25 and NFPA 72 identify a comprehensive list of inspection, testing, and maintenance requirements for water-based fire suppression systems and fire alarm systems. The current facihty records and procedures are not consistent with the current editions of NFPA 25 or NFPA 72. Procedure AS 116,'LMF Fire Protection Equipment Control," Revision 15,is currently being updated. Appropriate review for consistency with the current NFPA requirement is expected during the update process.

NFPA 25 requires that water flow test (i.e., flow and pressure of underground piping) for the water distribution system should be conducted at a minimum of a 5-year frequency. Annual hydrant flow tests were also conducted for the determination of a single hydrant's fire flow capability for fire department operations. During the inspection, the facihty was unable to locate the records for the annual hydrant flow tests. Subsequent to the irssoed.icn, the licensee located and submitted the records for NRC review.

e e

8

c. Conclusiors Based cn the observed conditions of the installed fire protection systems and the review of records of inspection, testing, and maintenance, the inspectors considered that a reasonable assurance for the reliable operations of fire protection systems had been provided at the facility.

5. Emergency Response (Fire Safetv)

a. Snope The inspectors interviewed the emergency response personnel to determine the capability of the facility's emergency response during normal and off-hour shifts.

b. QbleIyations and Findings The inspectors interviewed the Emergency Team Captain to leam the emergency response organization. The fire brigade consists of seven members. The inspectors reviewed the quahfication of fire brigade members, all members are qualified fire fighters in the Commonwealth of Virginia. The facility conducts quarterly training for different shifts, which includes drills and annual exercise. The facility has mutual aid agreement with local emergency response organization, such as the Concord Fire Department. The Concord Fire Department has participated in some of the drills and received frequent training to become familiar with the facihty and potential on site fire hazards.

The inspectors also examined emergency equipment for fire fighters. The fire fighting equipment, along *vith an emergency response vehicle with hoses and other equipment, is stored in the Eme gency Equipment Building. The fire fighting equipment includes personnel turnout gear and self-contained breathing apparatus (SCBA) for fire fighting, Spare SCBA bottles are available for replacement of the depleted SCBA bottles from fire fighting operatl9ns.

The equipment is inspected monthly by fire fighters and appears to be adequate for the intended purpose.

The facility's Pre-Fire Plans are maintained in a binder by both the Emergency Team Captain and the Regulatory Compliance Officer. The inspectors reviewed the Pre-Fire Plans and determined that they contain sufficient information concerning fire fighting during an emergency.

c. Conclusions The facility's emergency response team is trained to respond to an event during the normal or off-hour shifts. The facility has a mutual aid agreement with local emergency organizations, which participate in drills and receive training. It appeared that the facility's emergency response capacity is adequate for the type of hazards presented.

6. Exit Meetina Summary The inspectors presented the inspection scope and findings to members of licensee staff during the conclusion of the inspection on November 18,1997. The licensee acknowledged the findings presented, l

I

)

. I l

l 9

PartiaLList of Personn Contacted Licenten Gayle Elliott Manager, Safety and Licensing Al McKim Manager, Quality, H/S and Licensing Darryl Gordon Senior Health Physicist David Driscoll Regulatory Compliance Officer John Matheson Vice President, Operations Gerald Lindsey Health Physicist Ronald Joseph Electrical Maintenance Supervisor Carroll Vandegrift Mechanic Maintenance Supervisor

, List of Acronyms and Abbreviations ANI American Nuclear Insurers BWXT BWX Technologies, Inc.

FCF Framatome Cogema Fuels HF Hydroflouric Acid NFPA National Fire Protection Association SCBA Self Contained Breathing Apparatus SERF Service Equipment Refurbishment Facility SRB Safety Review Board O