ML20211F255
| ML20211F255 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 08/25/1999 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20211F252 | List: |
| References | |
| 70-1113-99-202, NUDOCS 9908300280 | |
| Download: ML20211F255 (15) | |
Text
i U.S. NUCLEAR REGULATORY COMMISSION l OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS Docket No: 70-1113 Licensee No: SNM-1097 Report No: 70-1113/99-202 Licensee: General Electric Nuclear Energy Facility: GE Nuclear Energy Production Location: Wilmington, NC 28402
. Inspection Dates: August 02 - 06,1999 )
l inspector Peter S. Lee, FCOB l l
- Approved By
- Philip Ting, Chief I Operations Branch Division of Fuel Cycle Safety and Safeguards, NMSS Enclosure 9908300200 990025 PDR ADOCK 07001113 l C PM i
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2 EXECUTIVE
SUMMARY
General Electric Nuclear Energy NRC Inspection Report 70-1113/99-202 The Nuclear Regulatory Commission (NRC) performed a routine, announced fire safety inspection at the General Electric Nuclear Energy (GE) facility in Wilmington, North Carolina, on August 2-6,1999. The inspection focused on the implementation of GE fire protection program commitments concerning safe plant operations. Major fire safety performance reviewed included: maintaining design bases of fire protection systems, assurance of availability and reliability of fire protection systems and components, adequacy of key administrative controls, manual fire suppression response capability, and adequacy of ISA controls for dry conversion process fire hazards.
Results and Conclusions The licensee has maintained an overalllevel of defense-in-depth fire protection for safe plant operations. The following findings resulted from the inspection:
The licensee has adequately maintained plant conditions within the original design bases of automatic sprinklers systems to assure adequate fire protection in the Fuel Manufacturing Operations (FMO), Fuel Manufacturing Operations Expansion (FMOX), and the Warehouse.
The licensee had also maintained adequate control of combustibles in the Dry Conversion Process Facility (DCPF), at a level significantly below that which would challenge the design capabilities of the facility's fire barriers.
The licensee has implemented adequate inspection, testing, and maintenance (ITM) to assure availability and reliability of fire suppression and detection systems in FMO, FMOX, Warehouse and DCPF. The licensee had implemented adequate ITM required for the plant's fire pump and water distribution systems, along with monitoring of the plant's water l supply, for fire protection.
- The licensee has provided adequate procedures, training, and a permit system for the control of hot work activities to minimize the occurrence of a fire during the performance of hot work activities.
The licensee has provided adequate control of combustibles in the FMO, FMOX, and ,
Warehouse to minimize potential fire severity and fire propagation throughout these facilities.
The control of combustibles in the DCPF was observed to be adequate and has been maintained at a minimum.
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The licensee has provided, through the combination of an on-site emergency response team and establishment of off-site fire department assistance, a reasonable assurance of an adequate and timely emergency response to a fire in th6 fuel manufacturing and support facilities.
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1 3 I The licensee has adequately identified the dominating fire and explosion risk associated the use of hydrogen in the DCPF and has provided and maintained appropriate engineered safety controls necessary to minimize the potential of a fire or explosion hazard.
The following weaknesses in the licensee's performance were identified- l l
Weaknesses were identified for the licensee's failure to perform required ITM of heat l detectors in the DCPF, the failure to include functional testing of DCPF fire dampers in the plant's Maintenance, Planning and Account Control (MPAC) system for scheduling and tracking, and the inadequate administrative closure of at least 63 open maintenance work I orders (dating back to 2/98) for performing routine ITM of fire protection systems. !
A weakness was identified for the lack of administrative and/or engineered controls to l assure that combustibles are not stored in the proximity of UF, cylinders to limit potential fire exposures. l 1
Attachments: 1 Partial Listing of Persons Contacted l
Inspection Procedure Used l
List of items Opened, Closed, and Discussed List of Acronyms i
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1 4 j R_liPORT DETAILS
- 1. Engineered Fire Protection Systems
- a. Scope The inspector reviewed and evaluated plant conditions to assure that they were within the original design bases and/or performance capabilities of fire protection systems in the fuel manufacturing facilities. The inspector also reviewed the inspection, testing, and maintenance (ITM) of plant fire protection systems. The adequacy of fire protection systems to mitigate or limit fire hazards and the licensee's adequate performance of ITM to assure the availabi;;ty and reliability of safety equipment are necessary for safe plant operations.
The inspector walked through plant areas, performed interviews, and reviewed documentation and records associated with the areas identified in the scope.
- b. Observations and Findinas Maintainino Plant Conditions within Oriainal Desian Bases of Fire Protection Systems The licensee provided automatic sprinkler protection throughout the Fuel Manufacturing Operations (FMO), Fuel Manufacturing Operations Expansion (FMOX), and Warehouse, with the exception of areas when water, as a source of moderation, has been restricted due to nuclear criticality safety requirements. The inspector performed a walk-through of these facilities to examine potential fire hazards (e.g., type of combustibles, storage configuration, fire severity, etc.) to assure that plant conditions were within the original design bases of the existing automatic sprinkler systems. The inspector determined that the combustible loading, storage configurations, and potential fire hazards under the sprinkler protected areas in the FMO, FMOX, and Warehouse were within their design bases, and would not challenge the effectiveness or capability of automatic sprinkler systems to contain or supprest a fire.
The inspector noted that automatic sprinkler systems had not been provided in the Dry Conversion Process Facility (DPCF). This was due to a nuclear criticality safety concern for the fuel manufacturing processes. Instead, the fire protection of the DCPF relies on fire barriers to prevent and contain the spread of a fire. The inspector observed that the combustible loading in the facility was at a level significantly below the amount that would challenge the 2-hour fire resistance capabilities of the facility's fire barriers. The inspector determined that the combustible loading in DCPF was adequately maintained within capabilities of fire barriers.
Insoection. Testina. and Maintenance of Fire Protection Systems The licensee has incorporated required ITM for fire protection systems in the plant's Maintenance, Planning and Account Control (MPAC) system for scheduling and tracking of preventive and maintenance work activities. The inspector reviewed the licensee records and documentation for ITM of the following fire protection systems:
5 automatic sprinkler systems, hydrants, and control valves,
- plant fire pumps and water supply, plant and DCPF fire alarm system, and DCPF fire barriers.
The inspector also reviewed and examined a representative number of these systems during a walk-through of the plant areas and determined the following:
Automatic Sprinkler Systems. Hydrants and Control Valves: The inspector noted that the FMO, FMOX, and Warehouse automatic sprinkler systems, fire hydrants, and controls valves examined were operable. No obvious material condition of concerns were noted for the systems and components examined. The inspector determined that the ITM for automatic sprinkler systems, hydrants, and associated contro! valves had been adequately performed in accordance with requirements of the National Fire Protection Association (NFPA) standards (i.e., NFPA 25).
Plant Fire Pumps and Water Supolv: The inspector noted that annual fire pump tests for the plant's electric and diesel fire pumps were performed on 4/28/98 and 5/11/99. The inspector noted that the fire pump tests were witnessed and analyzed by the licensee's risk and property insurance technical representative, with no findings of concern. The inspector independently reviewed the results from fire pump tests and confirmed that they were adequate to provide the flow and pressure for water supply needed by automatic sprinkler systems and manual fire suppression. The inspector also noted that weekly fire pump inspection and startup bad been performed to assure the availability and reliability of the fire pumps. During the walk-through of the fire pump facilities, the inspector noted no obvious material condition of concern for the electric or diesel fire pumps. The inspector also noted that the water level in the elevated water tower has been adequately maintained and verified weekly to assure that at least 150,000 gallons dedicated for fire protection was maintained.
The inspector observed that the total water supply available for fire protection at the elevated water tower was near a full capacity of 300,000 gallons. The inspector noted that a secondary water supply of approximately 670,000 gallons was maintained in an open ground reservoir. The inspector determined that the plant's fire pumps and water supply were adequately maintained for fire protection.
Site-Wide and DCPF Fire Alarm System: The inspector examined the operability status fire alarm control panels (FACP) providing fire alarm functions plant wide and locally in the DCPF. The site-wide FACP, located in the Emergency Control Center (ECC), monitored and controlled fire protection systems equipment and local facility FACP throughout the GE-Wilmington site, including the fuel manufacturing facilities. A local facility FACP was provided in the DCP Control Room to monitor and control fire protection systems and components within the DCPF. The inspector observed that both FACP indicated a normal operation status, without any trouble or alarm conditions related to fire suppression or fire alarm systems and components in the FMO, FMOX, Warehouse and DCPF. The inspector also determined that the annual ITM required for fire alarm systems and components had been adequately performed, with an exception noted for heat detectors in the DCPF (see discussion below).
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The inspector observed that both the site-wide and the DCPF fire alarm systems had been provided with stand-alone batteries within the FACP enclosure as a secondary power supply. The licensee indicated that the batteries were sized for up to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, which was consistent with NFPA standard requirements. The licensee indicated that the backup batteries had been scheduled for replacement every three years, and were due to be replaced in the year 2000. The inspector observed no apparent material condition of concern for the back-up batteries in both FACP. The licensee also indicated that ECC and the DCPF Control Room equipment had been provided with separate sources of backup electrical power supply from an uninterruptible power supply system and diesel generators in the event of a loss of plant off-site electrical power. The inspector noted that this provided additional reliability for the electrical power supply to both FACP to continue their fire protection functions. The inspector determined that the site-wide and DCPF fire alarm systems had adequate provisions for secondary power supply.
DCP Fire Barriers: The inspector performed a walk-through of the DCPF, and noted that the integrity of the fire barriers (i.e., walls, floors and ceiling) appeared to be adequately maintained. No obvious unprotected openings or penetrations were noted for the facility's fire barriers. Fire dampers were provided at heating and ventilation air conditioning (HVAC) ducts penetrating fire barrier walls. The !nspector observed that fire doors were properly maintained in a closed position and appeared to be in good condition. The licensee indicated that roll-type fire doors were functionally tested annually by an outside fire door vendor. The inspector reviewed records of 1998 annual testing of roll-type fire doors for the DCPF and noted that they performed as intended. The plant MPAC system has scheduled the 1999 functional testing of roII-type fire doors for the last calendar quarter of 1999. The inspector determined that the integrity of DCPF fire barriers and fire doors were adequately maintained to meet intended fire separations of process areas.
Inspection. Testina, and Maintenance items of Weaknesses Overall, the inspector determined that the licensee had provided adequate ITM of fire protection systems,in accordance with industry standards. However, the following i weaknesses were identified for some of the items reviewed: l
- Fire Dampers: Industry standards require the functional testing of fire dampers at a minirnum of once overy four years. (i.e., NFPA 90A, Standard for Air Conditioning and Ventilation Systems, Chapter 3.4.7). The fire dampers in DCPF were acceptance tested between 2/21/97 and 3/12/97. Although the functional testing of fire dampers were not due at the present time, the inspector noted that ITM of fire dampers had not been included in the plant's MPAC system. The inspector noted this as a weakness due to the licensee staff's apparent lack of awareness of the requirement until it was brought to their attention during this inspection. The licensee acknowledged the need to perform a functional test of fire dampers and incorporated the requirements into the plant's MPAC system to assure routine performance of ITM in the future.
- Heat Detectors: NFPA 72, National Fire Alarm Code, (Chapter 7.3) requires an annual functional testing of heat detectors to assure their performance to meet intended safety
7 functions. The inspector noted that the licensee had not met this requirement in the DCPF. The heat detectors in the DCPF had not been tested since their initial acceptance test (between 2/21/97 and 3/12/97). In addition, there was an apparent confusion between the licensee's Facility Maintenance and FMO HVAC Maintenance organizations as to who would test the heat detectors that automatically actuate fire dampers. The licensee acknowledged the need to test heat detectors and indicated that all heat detectors in DCPF would be included in scheduled annual testing of smoke and heat detectors during the last quarter of calendar year 1999.
The inspector determined that the inadvertent increased time between functional testing of heat detectors did not result in a degradation fire protection in the DCPF. This was due to the availability of smoke detectors (that were functionally tested annually) throughout all areas of the DCPF and the availability of a fusible link at each fire damper j to automatically close dampers and stop the propagation of a fire through the HVAC ducts penetrating fire barriers.
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+ Closecut of Maintenance Work Orders for Routine ITM: The inspector reviewed open I maintenance orders related to ITM of fire protection systems. The inspector identified j that approximately 63 items (with some items dating back to 2/98) were open on the l plant's MPAC system under Cost Center 1265. The inspector also noted that two I maintenance work orders (No. 98-32653 and 98-32654) for testing of smoke and heat detectors in 1998 had not been closed. The licensee indicated that the actual work related to these items had been completed, but had not been administratively closed out.
The inspector reviewed a sample of ITM records for fire protection systems (between January-August 1999) and the records for smoke and heat detectors testing from 1998.
The inspector determined, with a reasonable assurance, that the actual work associated with open maintenance work orders had been completed. The licensee recognized the vulnerability in the lack of management oversight and acknowledged the need to provide appropriate monitoring of the plant's MPAC system open maintenance work orders. The licensee committed to periodically (i.e., a monthly) review open maintenance work orders to assure a timely close out and monitor potential overdue items. The inspector considered this acceptable. The inspector determined that the inadequate administrative closure of maintenance work orders was isolated to one organization and did not appear to be a systematic problem with the use and implementation of the plant's MPAC system by other organizations in the area of fire protection.
Areas Needina Manaaement Attention The inspector noted that some of the weaknesses discussed above were similar to a previously identified inspector followup item (IFI) in NRC inspection report No. 70-1113/
98-202. The resulting IFi, No. 70-1113/98-202-02, identified that the ITM of various water based fire protections systems (i.e., fire pumps, calibration of gauges, main drain test) had not been adequately performed in accordance with requirements of NFPA standards.
Similar to that, during this inspection, weaknesses were noted for heat detectors and fire dampers in the DCPF. Although, they did not result in a significant safety impact, these weaknesses represented precursors that could lead to an impact to safety and support the need for management attention in the following areas:
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8 the use of NFPA standards (i.e., as indicated in License, Chapter 8. Fire Safety) to perform minimum ITM required to assure availability and reliability of all fire protection l systems, and l
- the self monitoring and self assessment of the quality and completeness in the performance of ITM (actual and administrative) for fire protection systems.
l c. Conclusion The licensee has adequately maintained plant conditions within the original design bases of automatic sprinklers systems to assure adequate fire protection in the FMO, FMOX and Warehouse. The licensee has also maintained adequate control of combustibles in the DCPF to a level significantly below that which would challenge the capability of the facility's fire barriers.
. The licensee has implemented adequate ITM program to assure availability and reliability of fire suppression and detection systems in FMO, FMOX, Warehouse and DCPF. The licensee has implemented adequate ITM required for the plant's fire pump and water distribution systems, along with monitoring of plant's water supply, for fire protection.
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- Weaknesses were identified for the licensee's failure to perform required ITM of heat detectors in the DCPF, the failure to include functional testing of DCPF fire dampers in l the plant's MPAC system for scheduling and tracking, and the inadequate administrative closure of open maintenance 63 open (dating back to 2/98) maintenance work orders for performing routine iTM of fire protection systems.
- 2. Implementation of Administrative Controls
- a. Scope The inspector reviewed the licensee's control of hot work activities and control of combustibles and flammable liquids to minimize the occurrence, severity, and spread of a l fire in the fuel manufacturing facilities and selected plant areas. The inspector walked-l through the process and plant areas, performed interviews with plant employees, and l reviewed documentation and records for the examination of the administrative controls associated within the areas identified in the scope. l
- b. Observations and Findinas Control of Hot Works l I The inspector reviewed the licensee's control of hot work activities in accordance with plant procedure F-1, Hot Work, to minimize the potential for the occurrence of a fire. The j inspector reviewed plant procedure F-1 (a revision of procedure No. 503) and found it j consistent with industry practices described in NFPA 518, Fire Prevention in Use of Cutting l
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9 and Welding Processes. The inspector noted that the hot work permit procedure required physical verification of the work area for fire safety prior to the performance of a hot work activity, and the permits issued were effective for only one working shift. Also, the hot work permits are required to be issued by an individual trained on the plant procedure and precautions for fire safety. The inspector noted the revised plant procedure was adequate.
The inspector noted that training had been provided to select supervisors, managers, planners or safety personnel to issue hot work permits. The inspector reviewed lesson plans related to training (Course IS349, Cutting / Welding Permit). The training plan included a review of procedure F-1 (or No.503) for cutting and welding permits, fire watch requirements .
and responsibilities, and precautions and safeguards, fire hazards, following procedure, and case study - Oak Ride Fatality, training video. The inspector noted that the training material was appropriate in addressing fire prevention concerns and controls required for hot work activities.
The inspector noted that no hot work activities were being performed or planned in the fuel manufacturing facilities during the time of this inspection. The inspector reviewed, at random,40 site records of hot work permits issued between 2/5/99 and 5/21/99. The inspector noted that the hot work permits were limited to a duration of one working shift.
They were signed by individuals that were authorized and trained to issue hot work permits, indicatin;; safety visits to the work sites prior to performance of the hot work activity. The inspector reviewed the licensee's unusual incident reports and noted that no incident related l to hot work had occurred in the fuel manufacturing facilities during tne past three months. l The inspector determined that hot work permits had been appropriately issued in accordance with plant procedures.
Control of Combustibles The inspector examined the control of combustibles for the moderation restricted areas (i.e.,
areas not protected by automatic sprinklers) of FMO and FMOX facilities and observed that they were adequately implemented. The incidental storage of combustibles were adequately managed to limit the potential severity or propagation of a fire. The amount of combustibles noted during the inspector's walk-through were generally below that required to cause damage to building structure steel or conditions that could lead to a flashover (i.e., ignition of all combustibles within the fire compartment). The inspector noted that the control of combustibles in the DCPF was adequate, resulting in a minimum of concern for fire hazards throughout the facility.
The inspector also reviewed the potential for exterior fire exposures to the fuel manufacturing facilities (e.g., FMO, FMOX, Warehouse, and DCPF). The inspector noted that areas surrounding these facilities were generally maintained free of combustibles that could present a potential fire exposure hazard to the fuel manufacturing facilities. The inspector determined that the licensee had adequately controlled combustibles throughout the fuel manufacturing facility to minimize the potential and consequences of a severe fire.
l Control of Combustibles in Proximity of UF, Cylinders The inspector noted a weakness during a review of combustibles control at the UF. cylinder storage yard. The inspector noted that the control of combustibles within the fenced UF,
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cylinder storage yard had been adequately controlled, with no accumulation of combustibles. However, the inspector noted that seven empty plywood waste crates had been stored immediate adjacent the fence, near the entrance to the UF cylinder storage yard. The inspector determined that the licensee had provided guidance and requirements (including using only propane driven fork-lifts for cylinder movements) to minimize the presence of combustibles inside the UF cylinder storage yard, but had not considered any l restriction or limitation for the accumulation of combustibles on the perimeter of the fenced I storage yard. The empty plywood waste crates found in the proximity (3-4 feet) of UF. l cylinders could present an exposure hazard in the event of a fire, resulting in radiant heating of exposed UF. cylinders. The inspector noted this as a weakness in the control of combustibles to assure that exposure hazards do not result from storage of combustible or flammable material or other liquid fuel operated vehicles in the proximity of UF cylinders. l Based on the risk assignment matrix from the ISA discussion of the License, Chapter 4.0, !
the inspector noted that the condition observed would be considered a moderate to low I level risk. The licensee acknowledged that the storage of the empty plywood crates did not present a gocr si'aty posture for addressing control of combustible in the proximity of UF, cylinders, e mmediately moved the wooder, crates to a safe storage location. The licensee also e - m edged the need to evaluate and establish appropriate robust administrative wic.is around the perimeter of the the UF. cylinder storage yard. The licensee committed to developing appropriate controls based on evaluation and l
establishment of sound technical bases for safe separation distance to limit fire exposure. In I the mean time, the licensee has committed to controlling storage of combustibles within l close proximity of the UF. cylinder storage yard through required review and approval from an area support organization manager. The inspector considered this acceptable. Although the conditions the inspector observed and brought to the attention of the licensee did not present a serious safety significance concern, it was considered a precursor of potential safety significance. Therefore, the adequate establishment of robust administrative and/or i engineered controls and the implementation of the controls to address combustibles in the proximity of UF. cylinder yard will be tracked as Inspector Followup Item (IFI)
No. 70-1113/99-202-01.
- c. Conclusion l
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The licensee has provided adequate procedures, training, and a permit system for the control of hot work activities to minimize the occurrence of a fue during the performance of hot work activities.
The licensee has provided adequate control of combustibles in the FMO, FMOX, and Warehouse to minimize potential fire severity and fire propagation throughout these facilities. The control of combustibles in the DCPF was observed to be very good and has been maintained at a minimum.
i A weakness was identified in the lack of administrative and/or engineered controls to assure that combustibles are not stored in the proximity of UF. cylinders to limit potential fire exposures.
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- 3. Manual Fire Suppression Response
- a. Scope The inspector reviewed the availability and staffing of the onsite emergency response team (ERT) to respond to a fire. The inspector also reviewed the maintenance of off-site fire departments for assistance during plant emergencies. The availability of manual fire
- suppression to mitigate a fire provides the final line of defense against potential consequences that could impact the health and safety of workers, the public and the ,
environment or impact safety systems, components, and controls relied on for safe plant l operations. The inspector performed interviews with plant employees, local fire department !
staff, and reviewed documentation and records to determine the adequacy of areas identified in the scope.
- b. Observations and Findinas l ERT Staffino for On-Site Fire Resoonse The licensee had established an on-site ERT to respond to fires and other emergencies.
The membership of the ERT is based on volunteers throughout the GE-Wilmington site. The inspector determined that the typical numbers of ERT members available ranged from 3-31 ;
during day shift (7am - 3pm), 2-22 back shift (3pm - 12am), and 1-16 during off-shift (12 -
7am). The licensee indicated that the lower numbers during each shift were typically associated with the weekends, where a substantial number of the work force would not be onsite, due to limited operations throughout the site. The licensee acknowledged this as a weakness that was being addressed by efforts in recruiting new volunteers for the ERT. The licensee indicated when there is not a minimum number (e.g.,4-5) of ERT members to safely perform interior firefighting operations, the assistance from an off-site fire department would be relied on for fire emergencies. The licensee indicated that the availability of ERT members onsite is verified at the beginning of each shift by security guards at the ECC. The i inspector noted that the licensee was taking appropriate measures to improve the depth of l ERT member coverage during the weekends. l Notification of Off-Site Fire Department for Assistance The inspector reviewed the licensee's process for notification of off-site fire departments for assistance. The licensee notification of the off-site fire department for assistance is typically
, performed by the Shift Security Supervisor. The inspector noted that the security procedure, Security Post Order No.100, had been established with instructions for notification of off-sits fire department (s). The site fire alarm system at the ECC provides additionalinformation to assist in a proper response by security guards. The ERT members had been instructed through ERT training to immediately notify the shift superintendent or security supervisor to request off-site fire department assistance (i.e., Castle Hayne Volunteer Fire Department) in various circumstances, including inadequate staffing to support fire-ground operations. The inspector noted that appropriate preparation had been taken to provide a timely notification to the off-site fire department for assistance in the evont of inadequate number of ERT members during the weekends.
12 Estimated Fire Department Response Time The in,spector further reviewed the off-site fire department response capability after l notification for assistance. The licensee indicated that the average response time from the I nearest off-site fire department (i.e., Castle Hayne Fire Department) was within 5 minutes.
The inspector noted that this was an improvement from previous average response time of approximately 10 minutes. The inspector interviewed the fire chief for the Castle Hayne Volunteer Fire Department and determined that the improvement was due to addition of paid !
firefighters, previously an all volunteer firefighters, that continuously manned the fire stations in the areas. The inspector determined that the availability of the nearest off-site fire department response was adequate to compensated for the lack of ERT members during weekends.
Letters of Aoreement for Off-Sit'e Fire Department Assistance The inspector reviewed letters of agreements between the licensee and off-site fire :
departments to assure that formal agreements for assistance had been maintained to meet the commitment of the plant's Emergency Plan. The inspector noted that letters of agreement between GE-Wilmington and off-site fire departments (i.e., Castle Hayne, Wrightsborough, Ogden, and Winterpark), dated December 1996 remains in affect until December 2000.
c. Conclusion
The licensee has provided, through the combination of an on-site ERT and establishment of off-site fire department assistance, a reasonable assurance of an adequate and timely emergency response to a fire in the fuel manufacturing facilities.
- 3. Integrated Safety Analysis (ISA) for Dry Conversion Process
- a. Scope The inspector reviewed the adequacy of the integrated safety analysis (ISA) prepared for the DCPF to assure it had adequately analyzed the fire hazards associated with the fuel manufacturing process. The inspector also reviewed the adequacy of resulting safety controls and the maintenance of required controls to mitigate the highest fire or explosion risks. The inspector walked-through the DCPF, performed interviews with operations personnel, and reviewed documentation and records to determined the adequacy of the ISA and the implementation of required safety controls.
- b. Observations and Findinas Hich-Risk Safety Controls Acainst Process Fire or Explosion The inspector noted that the ISA identified the use of hydrogen in the DCPF as the highest fire and explosion risk at the facility. The ISA identifies the hydrogen detection in the procesc rooms to shut off the hydrogen supply valve as a "high-level risk safeguards," to
13 limit $3 hydrogen leak into the room and prevent the potential for explosion hazards. Based on a walk-through of the DCPF, the inspector noted that the ISA appropriately characterized the high-risk fire or explosion hazard for the DCP and the facility. Hydrogen detectors had been provided within process rooms and appropriate corridors throughout the DCPF where hydrogen is used or transferred through piping.
The inspector noted tnat maintenance work orders, through the Plant's MPAC system, are issued monthly to inspect and calibrate hydrogen detectors throughout the DCPF. The tasks performed included the calibration of a hydrogen detector at the lower set point of 20% of the Lower Explosive Limit (LEL) and upper set point of 50% of the LEL for hydrogen and the transmission and receipt of alarm signal to the ECC and the DCP Control Room. The inspector's review of test records indicated that monthly inspection and calibration checks had been provided. The inspector also noted that the hydrogen supply valve to the DCP would shutoff upon the activatio'n of process hydrogen detectors. The inspector noted that required functional testing of automatic shutting of the hydrogen supply valve for DCP lines No.1,2, and 3 had been performed for 1998 and 1999. The inspector determined that availability and reliability of equipment identified as high-risk safeguards against fire or explosion hazards, associated with the use of hydrogen, in the DCPF had been adequately maintained.
l Medium Risk Safety Controls Acainst Process Fire or Exolosion The inspector noted that smoke and heat detectors in process areas were identified as
" medium level risk safeguards," and an administrative control to alert and initiate response to abnormal conditions (e.g., fire or particulate release - UF6 release). The DCPF containment (fire barriers interior and exterior walls, roof and ceilings) was identified as passive controls and was considered " medium level risk safeguards." The inspector determined that the ISA results were adequate based on minimum combustible / flammable material or liquids used in the manufacturing processes. The adequacy oflicensee maintenance of safety controls or safeguards (smoke and heat detectors, fire barriers and open protection) resulting from the ISA was discussed in Section 1 of this inspection report.
The ISA also identified the design of hydrogen piping system, the hydrogen supply excess '
flow valve, and high hydrogen flow alarms as " medium level risk safeguards." The licensee indicated that the design of hydrogen piping used welded connections to minimize potential leaks in piping connections and had been hydrostatically leak tested prior to p! acing it in service. The inspector noted that an excess flow valve had been provided at the roof for the DCPF which would automatically shut off the main supply of hydrogen into the DCPF in the event of a low flow pressure (i.e., high flow resulting in a drop in system pressure). The inspector also noted that the licensee had provided hydrogen piping system isolation outside of each of the DCP process lines, at locations outside of the DCPF. The licensee indicated that additional hydrogen supply isolation capabilities are also provided at the supply tank and supply piping. The inspector determined that an adequate number of independently located controls for isolating the supply of hydrogen had been provided in the event of a leak inside of the DCPF.
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c. Conclusion
The licensee has adequately identified dominating fire and explosion risk associated the use of hydrogen in the DCPF and has provided and maintained appropriate engineered safety controls necessary to minimize the potential of a fire or explosion hazards.
- 4. Inspector Followup Items IFl 70-1113/98-202-02: This IFl addressed the licensee's commitment to improve ITM of water based fire protection systems to include all applicable requirements in industry standards. The specific items noted during the NRC inspection were the annual performance testing of the plant's fire pumps, the calibration of gauges on fire protection systems, and the performance of a system (i.e.,2 inch) drain test on automatic sprinkler systems. The inspector determined that the licensee had incorporated appropriate additional ITM requirements into plant procedures and had adequately implemented the new ITM requirements. No further issues were identified; therefore, IFl No. 70-1113/98-202-02 was closed.
- 5. Exit Meeting Summary The inspector communicated observations and findings to the licensee throughout the inspection and presented the final results to licensee management during an exit meeting held on August 5,1999. The licensee acknowledged the findings presented and committed to addressing them as discussed in the inspection report. The inspection was concluded on I the morning of August 6,1999, with no additional findings. '
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15 Partial Listina of Persons Contacted
- G. Allen Facility Engineer
- R. Bragg URU Team' Leader l l
- D. Brown Environmental Program Leader
- R. Crate Safety Manager T. Davis DCP Operations Supervisor
- D. Dowker Chemical Production
- T. Draffen DCP Area Manager l
- P. Godwin ERC/ Site Fire Chief J. Goodson Facility Maintenance R. Hardin Maintenance' Planner i
- D. Hassler HVAC Maintenance l
'R.Keenan Manager, Safety, Security, and Emergency Preparedness I
- J. Kline Manager, GE Nuclear Energy Production
- G. Luciano Field Support & Waste Treatment Team Leder
- C. Monetta Manager GE Nuclear Energy Environment, Safety & Health
- M. Moser DCP Technical Support
- S. Murray Regulatory Compliance Manager
- L. Paulson Nuclear Safety l J. Reeves Fuel Fabrication Production R. Schaeffer Facility Administration
'G. Smith FMO Maintenance Leader
- D. Tuner Training
- C. Vaughan Facility Licensing Manager
- Indicates those attending the exit meeting on August 5,1999 Inspection Procedure Used IP 88055 Fire Protection List of items Opened. Closed, or Discussed Opened IFl 70-1113/99-202-01 The establishment and implementation of adequate and robust administrative and/or engineered controls to address combustibles in the proximity of UF. cylinder yard, to limit potential fire exposure.
Closed IFl 70-1113/98-202-02 Licensee commitment to improve testing of fire protection systems to be consistent with industry standards.