ML20212H255

Submits Response to Violations Noted in Unresolved Item Insp Rept 70-0036/97-204.Corrective Actions:Emergency Alarm Sys, Smoke Detectors,Heat Detectors & Associated Relays Serviced & Tested at Least Annually by Contractor

ML20212H255
Person / Time
Site:	07000036
Issue date:	03/27/1998
From:	Sharkey R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
70-0036-97-204, 70-36-97-204, NUDOCS 9804010236
Download: ML20212H255 (10)

Text

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March 27,1998 Docket No. 70-3 License No. SNM-33 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Attn: Document Control Desk i

Washington, D.C. 20555

Subject:

Response to Unresolved Item 70-36/97-204-09 t

Gentlemen:

NRC Ileadquarters staff recently conducted a fire protection inspection at Combustion Engineering's Hematite, MO, nuclear fuel manufacturing facility. The report for that inspection, number 70-36/97-204 dated February 18,1998, establishes Unresolved Item (URI) 70-36/97-204-009 regarding potential performance weaknesses related to the implementation of l

commitments contained in Sections 2.1.6 and 2.1.7 of our Emergency Plan (EP). The report requests our response to the URI, specifically including: (1) identification of the extensive engineered safeguards used to control fire and explosion; (2) how those safeguards, including the fixed fire extinguishing equipment, are maintained available and reliable; (3) the identification of administrative controls for combustibles; (4) the performance of fire hazard inspections and audits, and; (5) actions taken or planned to assure that fire and life-safety issues receive prompt management review and timely disposition, including implementation of any compensatory measures needed to assure adequate safety until final corrective actions can be completed.

Enclosed is our response to the URI. Additional information is provided regarding our fire pump and combustible loading in the cantilever rack and filtrate storage areas. After closer review, it is clear that there was no impairment of the fire pump, and that storage in the cantilever rack and filtrate areas is consistent with NFPA recommendations.

We are in compliance with Section 2 of our EP. However, we recognize that improvements can be made, and we will submit changes to the EP regarding the extensive engineered controls. A schedule is provided in the enclosure. Fire safety improvements, both engineered and programmatic, have been ongoing for several years, and will continue. At this point, we have not identified areas where compensatory measures are warranted.

I 9804010236 980327 IT

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PDR ADOCK 07000036H C

PDR i p

ABB CENO Fuel Operations Cornbushon Engineenng inc 33CO State Road P Telepnone (314) 937-469i Post Omce Box 107 St Lou >s (314) 2%5640 HemaMe. Mssoun ti3047 Fai (314) 937-7355

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I hereby affirm that the statements made in this response are true and correct to the best of my knowledge and belief. If you have any questions or need further information, please contact me or Kevin Ilayes of my staff at (314)937-4691.

Sincerely, COMBUSTION ENGINEERING, INC.

/ turok 27, /T 76 t

y Robert W. Sharkey Director, Regulatory Affairs cc:

Pat Ililand, NRC Region III Enclosures RA98/704

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Response to URI 70-36/97-204-09 Page 2 of 2

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' Combustion Engineering, Inc.

Docket 70-36

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License No. SNM-33 RESPONSE TO AN UNRESOLVED ITEM INSPECTION REPORT 70-36/97-204 (1) Identification Of The Extensive Engineered Safeguards Used To Control Fire And Explosion.

Sections 2.1.6 and 2.1.7 of the Emergency Plan (EP) provide a brief description of postulated fire or explosion incidents that potentially could release uranium to the atmosphere, and our engineered safeguards for those postulated accidents. The engineered safeguards described in Section 2.1.6 are used to prevent or mitigate the release of uranium from a minor fire, and include: (1) IIEPA filtered ventilation system in the buildings; (2) smoke detectors in the ventilation systems; (3) the size of the fuel fabrication buildings, and; (4) availability of fixed and portable fire extinguishing equipment.

The engineered safeguards described in Section 2.1.7 are used to prevent or mitigate a fire or explosion that could cause radioactive material to spread beyond the area of origin. Such an incident is postulated to require a large driving force, such as flammable solvents, flammable wastes, explosive liquids or gases, or other chemicals that support fires and/or explosions. Two postulated situations are evaluated in that section for the purpose of including events that would involve evacuating the facility. Based on existing safeguards described in the EP, the probability of either event actually occurring is considered remote. The first situation considered a major fire or explosion that destroys major portions of the facility, including HEPA ventilation systems. The primary source of such an explosion is identified as hydrogen. flydrogen is not stored on site, but is used as it is generated. In addition to those previously listed, the engineered safeguards to prevent or mitigate this scenario include: (5) flow controllers; (6) emergency cutoffs; (7) use of non-combustible and fire resistant material; (8) fire resistant filters; (9) infrared furnace pilot light monitors, and; (10) zonal heat rise detectors.

The second situation postulates a worst case explosion at a furnace after assuming that all precautionary steps fail. This includes failure of a passive engineered safeguard: (11) entrance and exit doors that are designed to relieve pressure in the event of an explosion. In this very conservative assumption, the maximum postulated dose to the nearest resident is projected to be 1.9 mrem. This is well below the annual operating limit of 100 mrem per year, or the i rem accident limit in 10 CFR 10.22(i)(1)(i).

Significant facility changes had recently been made at the time the EP was drafted. Many of those changes were directly related to upgraded fire safety, including the installation of a 200,000 gallon gravity dual-use water tank, a 1,500 gpm diesel fire pump, a 600 kW diesel emergency power generator, a replacement criticality alarm system, and a new emergency alarm system. When considering these and other improvements, by relative terms the safeguards are extensive. A submittal revising the sections referring to extensive engineered safeguards will be made to the NRC.

(2) llow Those Safeguards, Including The Fixed Fire Extinguishing Equipment, Are Maintained Available And Reliable.

Each of the engineered safeguards is maintained available and reliable in part by management of change. Change to the facility, its processes, and safety-related equipment requires management review and approval, including a review to determine whether fire safety evaluations are required. Significant changes require a Plant Safety Committee review, and may require review and approval by an authority having jurisdiction, such as the Jefferson County Building Commission, our insurer, and the NRC.

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Response to URI 70-36/97-204-09

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RA98/7(M, Page 1 of 5

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Combustion Engineering, Inc.

Docket 70-36 License No. SNM-33 j

Inspections and tests of engineered safeguards are periodically performed by employees and/or contractors. The fire pump, for example, is checked and started every week by maintenance personnel.

The fire pump and sprinkler systems are checked and tested quarterly by a fire system engineering and service contractor, who also performs our annual fire pump test. Our emergency alarm system, smoke detectors, heat detectors, and associated relays are serviced and tested at least annually by a contractor.

Fire prevention and protection issues are also an element of the quarterly facility inspections required by our License. Safeguard numbers 5,6,9, and 11 noted in item 1 of our response are specifically associated with our dewaxing and sintering furnaces. Operaiion of the furnaces is associated with operation of safeguards 5,6, and 9, i.e. the furnace will either shut down or will not cycle if the safeguards are not working. Their condition is checked during each operating shift by Operators and QC Technicians using written procedures.

(3) The Identification Of Administrative Controls For Combustibles.

Procedure NIS 215, Fire Protection, establishes a general requirement to minimize combustible loading at all times in any area. Procedure NIS 213, llazardous Materials Management, establishes limits on the storage of flammable liquids in the facility. Individual Operation Sheets may contain additional precautions that are specific to a process. The inspection report indicates that we have met the requirements of those procedures throughout the process areas, except for combustible loading in the incinerator room and a warehouse. We disagree with the findings regarding the warehouse, as described Items 7 and 8 of this response. Internal reviews had already identified opportunities to strengthen our procedures concerning fire safety, and we are in the process of revising those procedures at this time. Comments received from the NRC and other sources are being considered during the revision process. Additional controls will be based on applicable recommendations from integrated safety assessments in progress for the facility.

(4) The Performance Of Fire liazard Inspections And Audits.

We historically have considered the loss prevention surveys performed by our fire insurer to constitute an audit. Our perspective was reinforced by the broad scope of their activities, and the fact that they frequently went beyond the scope of national consensus standards. Each recommendation or concern erablished as a result of those audits was subject to management review and response. The status of each item was then updated in subsequent audits. We should note that we recently changed insurance providers. Our new insurer has concluded that there are no fire protection issues which they believe require corrective action. This effectively closes any open or contended issues from our former insurer. An audit of the facility was also conducted this past February by a certified fire marshal. A schedule that explicitly includes such audits has been generated as part of our self assessment program.

Facility condition and fire protection equipment operability inspections are periodically performed by employees and/or contractors. Our quarterly inspection report, for example, includes information regarding sprinkler flow alarm tests, tamper switch tests, inspections of sprinkler and control valves, inspection of hydrants, and fire pump operability. As we continue to revise our self assessment program, we have drafted maintenance and llealth Physics procedures that more formally document these inspection activities.

Response to URI 70-36/97-204-09 RA98/7N, Page 2 of 5

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Combustion Engineering, Inc.

Docket 70-36 License No. SNM-33 (5) Acti,ons Taken Or Planned To Assure That Fire And Life-Safety Issues Receive Prompt Management Review And Timely Disposition, Including Implementation Of Any Compensatory Measures Needed To Assure Adequate Safety Until Final Corrective Actions Can Be Completed.

Issues related to external sources or agencies are tracked in the Regulatory Affairs Commitment Tracking Database. External feedback typically comes to management attention through exit meetings, inspection or audit reports, and review of existing commitments. Issues resulting from internal activities, such as safety committees and quarterly inspections, are tracked in the minutes or reports associated with those activities. Those documents are distributed for management information and consideration. The facility is also subject to constant surveillance by Regulatory Affairs personnel, from which any problems are communicated to the cognizant professional (s) for evaluation and action.

Issues requiring compensatory measures or corrective action are brought to raanagement's attention.

We are not aware of any fire or life-safety issues requiring compensatory measures at this time.

SUPPLEMENTAL INFORMATION REGARDING TIIE SITE FIRE PUMP AND WAREIIOUSE SPRINKLER SYSTEM INSPECTION REPORT 70-36/97-204 (6) Impairment Of The Site Fire Pump, IFI 70-36/97-204-05.

This item is established to track alleged failure to promptly address potential degradation of the site's fire pump, or to prov'ide appropriate compensatory measures during the seven months of that alleged degradation. The basis for this allegation is a pump test on September 26,1996, that was aborted when the diesel engine overheated during the 150% run. The report states that this problem was not abated, and that its cause was not identified, until a subsequent pump test on April 11, 1997.

The pump coolant inlet strainers were promptly checked by the inspector from our service contractor when the diesel engine overheated during the September test. The inspector found that pebbles had obstructed the strainers. He removed the pebbles, then restarted and monitored the pump to ensure that the problem was eliminated. The inspector believed that the pebbles came from a break that occurred years earlier during installation of the 10-inch pipe from our gravity tank. Review of our weekly test and quarterly inspection records shows that no further coolant flow problems were encountered during the period of alleged degradation. The fire pump and backflow preventers were dismantled and checked in April, and the second pump test was successfully performed. Only one pebble was found in, and removed from, an outer vane of the pump impeller. No actual damage was found in the pump or check valves.

The fire pump was not impaired for seven months as alleged in the inspection report. The cause of the September overheating problem was immediately identified and corrected. The effectiveness of the corrective action was successfully tested, and was subject to frequent surveillance. Compensatory measures were therefore not required between these pump tests.

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Response to URI 70-36/97-204-09 RA98/704, Page 3 of 5

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Combustion Engineering, Inc.

Docket 70-36 o

License No. SNM-33 (7) Maintenance Of Warehouse Sprinkler System Design Criteria, IFI 70-36/97-204-03.

This item relates to the inspector's concern that storage and rack configuration exceeds a sprinkler j

system's design criteria for a maximum height of 12 feet. We conclude that the report is referring to I

our cantilever rack in the Building 230 warehouse, where the storage height is typically up to 15 feet.

The top cantilever of the rack is approximately 12 feet high. The rack has been used in this manner since the building opened in 1993. Storage height in the rest of the facility is at or below 12 feet.

The sprinkler system in question was designed to conform with Ordinary llazard Group 3 of NFPA 13, I

Standard for the Installation of Sprinkler Systems,1989 Edition. Within that standard, the design basis assigns a general storage height limit of 12 feet. The cantilever rack represents a specific hazard because it clearly exceeds the general storage height limit. NFPA 231C, Standard for Rack Storage of Materials, which is referenced in NFPA 13, is the standard that must be used to determine whether the rack's configuration is within the design criteria of the existing sprinkler system.

Our storage rack is a double-row rack as defined by NFPA 213C,1995 Edition. The nature of the material being stored on it, usually boxes of empty fuel rod tubing, meets the definition for non-encapsulated Commodity Class 11. There are 8-foot aisles on three sides of the rack; the fourth side abuts the building wall. The sprinkler system in question uses 165 F heads only at the ceiling; in-rack sprinklers are not provided. Review of Chapter 6 and Table 6-12 (see Enclosure 2) reveals that the required ceiling sprinkler density for this configuration can be detennined by using Figure 6-12(b),

2 2

Curve F (see Enclosure 2). That curve specifies a density of 0.37 gpm/ft over the 2,100 ft or application affected by the rack. That density may be modified in accordance with Figure 6-9.2 (see ) to reDect actual storage heights. A 40% reduction in density is allowed for storage of up to 15 feet, which is our practice. Thus, the sprinkler design criteria for the cantilever storage rack is 2

2 0.22 gpm/ ft over 2,100 ft, which equates to a demand of 470 gpm at the sprinkler riser.

Flow tests on February 24 and 25,1998, demonstrated an available flow of 790 gpm at the Building 230 sprinkler riser with the fire pump bypassed (impaired), and 1,680 gpm with the fire pump running.

Under NFPA 231C, the existing sprinkler configuration and available flow under normal conditions i

would allow a storage height of up to 20 feet. This clearly demonstrates that the cantilever rack's fire load is well within the capability of the existing sprinkler system, the design criteria of which has not been exceeded.

(8) Storage of Filtrates, IFI 70-36/97-204-07.

The context of the inspection report indicates a misconception that a problem with coverage by the cantilever rack means that coverage for other areas, specifically the filtrate storage area, is reduced.

This premise could be true only if the system were designed to operate in the deluge mode, which it is not. Furthermore, the cantilever rack and filtrate storage areas are separated by approximately 100 feet The inspection report makes no mention of any concenu with combustible matenal storage within that separation. There is no credible accidental ignition source in the warehouse that could cause concurrent and widely separated points of fire origin, and there is no requirement to consider that scenario for this occupancy. These areas are considered remote to each other for the purpose of designing sprinkler coverage, which is adequate for the occupancy.

Enclosure i Response to URI 70-36/97-204-09 RA98/704, Page 4 of 5

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Combustion Engineering, Inc.

Docket 70-36 License No. SNM-33 (9) Schedule 0,f Actions

- A revision of the EP sections discussed in item I will be submitted to the NRC by August,1998.

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The procedural revision process discussed in Items 3 and 4 will be complete by May,1998.

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i integrated Safety Assessments discussed in item 3 have been scheduled in correspondence to the NRC i

- on October 23,1996. Fire safety is an element of these assessments.

i Response to URI 70-36/97-204-09 RA98/704, Page 5 of 5

r-Colnbustion Engineering, Inc.

Docket 70-36 License No. SNM-33 cciu=f Prinkler WWer Demiand N

y,g, (ft)

Sprinklers With In. Rack Sprinklere without lo-Rack Sprinklers Ceaunoslity Emcap.

(4 4,1)

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Apply Fig.

licight Class sulasesi (54 11.2)

In Rack Fig.

Curves 69.2 Fig.

Curves 6-9.2 No 4

No 412(a)

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G&ll Yes 8

A&B E&F Yes 4

No 012(e)

C&l) 612(c)

G&ll Yes 4:

8 AkB F&F No 4

No 612(b)

C&D 6-12(b)

G&H Yes j

,y g

8 A&ll E&F c5 Yes 4

No 6-12(c)

C&D 612(e)

G&H Yes E.8 j H

A&ll E&F b:

No 4

No li-12(c)

C&D 412k) G&ll Yes al 8

A&B E&F j

Yes 4

1 Level ti.12(f)

CkD a

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No 4

No 612(d)

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Yes i

l inel 6-12(c)

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A&ll E&f g g, Yes 4

1 1.evel fi-12(g)

C&D 8

A&B No 4

No fi-12(a)

C&D 6-12(a)

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A&B F&F Yes 4

1 inel 6-12(e)

C&D e

8 A&B p)

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No 612(b)

C&D lbl2(b)

G&H Yes 8

A&ll E&F

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11.evel 612(c)

C&D N

M A&Il gg t-No 4

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e Yes 4

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8 A&B 1

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6-12(d)

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612(g)

C&D 8

Akil Foi Et umsw I h o.sotti ai Table 6-12 Single-or Double-Row Racks. Storage lleight up to and including 25 ft, Aisles Wider than 4 ft, without Solid Shelves.

Response to URI 70-36/97-2N-09 RA98/7M, Page 1 of 2

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4 Combustion Engineering, Inc.

Docket 70-36 License No. SNM-33 a

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Figure 6-9.2 Ceiling sprinkler density vs. storage height Response to URI 70-36/97-204-09 RA98/704, Page 2 of 2