ML20247A404

Notice of Guidance on Mgt Controls/Qa,Requirements for Operation,Chemical Safety & Fire Protection for Fuel Cycle Facilities

ML20247A404
Person / Time
Issue date:	03/14/1989
From:	Rouse L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
References
NUDOCS 8903290116
Download: ML20247A404 (30)

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U.S. NUCLEAR REGULATORY COMISSION GUIDANCE ON MANAGEMENT CONTROLS / QUALITY ASSURANCE, l REQUIREMENTS FOR OPERATION, CHEMICAL SAFETY, AND FIRE PROTECTION FOR FUEL CYCLE FACILITIES AGENCY: Nuclear Regulatory Comission (NRC) '

ACTION: Proposed guidance to applicants and licensees for preparation of applications for licenses and conduct of operations; public comment.

SUMARY: This notice proposes guidance in the form of four Branch Technical Positions on management controls / quality assurance, requirements for operation, chemical safety, and fire protection for fuel cycle facilities. The Branch Technical Positions will be administered by the Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, Office of Nuclear Material Safety and Safeguards.

DATES: Comments on the proposed guidance are encouraged. Such comments will be considered in finalizing the Branch Technical Positions. Comments are due gy 2 % $N NOTE - Comments received after the expiration date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments filed on or before that date.

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FOR FURTHER INFORMATION CONTACT: Leland C. Rouse, Chief, Fuel Cycle Safety Branch, Division of Industrial and Medical Nuclear Safety, Office of Nuclear Material Safety and Safeguards, Washi 9 qtgry D2.db5b, (301) 492-3328.

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SUPPLEMENTARY INFORMATION: Section 70.22 (Contents of Applications) and l Section 70.23 (Requirements for the Approval of Applications) of 10 CFR Part 70  ;

contain subsections which provide applicant information requirements and Commission approval requirements related to equipment, facilities, and procedures i that will be used to protect health and minimize danger to life or property.

(Similar provisions are contained in Parts 30, 40, and 72.) These requirements are necessarily general, for they must be applicable to a variety of nuclear 1 fuel cycle activities. Over the years, the Commission staff has developed different types of guidance to supplement the general requirements. These have taken the form of Regulatory Guides, Standard Format and Content documents, and Branch Technical Positions. In addition, applicants' and the staff's experience with applications and licenses has evolved into a reasonable understanding of what information should be provided and what will be approved.

Notwithstanding the supplementary guidance provided to expand and explain the general requirements, there have been certain topics for which guidance has not been provided at all, or provided in less than completely adequate form. The staff had been wnrking on numerous suggestions and recommendations, made both inside and outside of the Commission, for improving the regulation of radioactive materials, especially after the January 4, 1986 accident at the Sequoyah Fuels Corporation's uranium hexafluoride conversion facility. As one result of this accident, the NRC's Executive Director for Operations established the Materials Safety Regulation Review Study Group (MSRRSG) in May 1986. The MSRRSG recommendations covering the licensing and inspection program were not unique, and as mentioned above, were already in various stages of consideration or implementation.

One group of the MSRRSG recommendations dealt with administrative aspects of NRC operations, including organizational changes, training, procedures, and schedules. Most of these were addressed as a part of the NRC reorganization in April 1987. Others have been and are continuing to be pursued in the context of the new organization. The other group of MSRRSG recommendations related to radiation and industrial safety concerns, e.g., nonradiological l 1

hazards, emergency preparedness, and radiography safety. The last two have  !

been handled by separate rulemaking actions.  !

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l During the same period of time that the MSRRSG report was being prepared 1

and evaluated, the staff undertook a series of team assessments of operational safety at the major fuel facilities licensed by the NRC. These assessments were cosiducted by Regional and Headquarters NRC staff, as well as OSHA and EPA personnel in most cases, and FEMA in two of the assessments. The most important safety issues identified as needing attention by licensees were in the areas of fire protection, chemical hazards identification and mitigation, management controls / quality assurance, safety-related instrumentation and maintenance, and emergency preparedness. These findings contributed to and support the staff's position on the MSRRSG recommendations. Likewise, the recommendations contained in the Lessons Learned Report from the Sequoyah Fuels Corporation accident (NUREG-1198) and the U.S. House of Representatives'

' Committee on Government Operations report, "NRC's Regulation of Fuel Cycle Facilities: A Paper Tiger," were consistent with the findings.

As a first step toward making improvements in the identified areas of management controls / quality assurance, requirements for operation, chemical safety, and fire safety, Branch Technical Positions have been prepared for guidance. It is the NRC's intent that the guidance will later be incorporated, along with other topics, in license application standard format and content documents. These documents in turn would be used in the preparation of standard review plans for the safety of major fuel cycle facilities. Branch Technical Positions provide guidance to applicants and licensees for preparation of applications for licenses and conduct of operations and provide guidance for the staff in reviewing applications and inspecting facilities. However, Branch Technical Positions do not carry the force of regulation; and other equipment, facilities, and procedures may be acceptable for meeting regulatory requirements.

For each of the Branch Technical Positions which follow, the background of each issue is described, including a definition of the issue and its general applicability. A discussion section includes the objectives of the Branch Technical Position and the principles to be used. A position section describes specific guidance but not methods of implementation at this time. Finally, references used in development of the Branch Technical Position are listed.

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BRANCH TECHNICAL POSITION ON MANAGEMENT CONTROLS / QUALITY ASSURANCE FOR FUEL CYCLE FACILITIES I. INTRODUCTION Team assessments of operational safety at major fuel cycle facilities, which were conducted following the accidental release of uranium hexafluoride at Sequoyah Fuels Corporation in January 1986, identified management controls as one of the most important issues needing attention by licensees. In the staff paper to the Commission (SECY-87-189), in which the team assessments were discussed, the staff concluded that fuel cycle licensees should specify.

management controls programs covering all aspects of facility operations including design and construction, procedures, maintenance, training, and audits. The purpose of this Branch Technical Position is to describe a management controls / quality assurance program which licensees should use to improve operational safety.

II. DISCUSSION The purpose of management controls is to provide confidence that measures taken to achieve safe, reliable facility operations remain effective and that operations remain safe.

This confidence will be obtained from a management controls program which:

o Provides methods for seeking out and identifying items and activities important to safety and recognizes their potential significant failures.

o Establishes procedures for tests and inspections, surveillance, and maintenance to provide protection against potential failures.

o Provides feedback to confirm and verify program achievement and evaluates and assesses program effectiveness.

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The'following are the essential items'that should be included in the management controls system. A. discussion of each is provided.

I A.. Organization j

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The organizational' structure established by management for fuel cycle

. facilities should provide for execution of.the management controls functions, i

B. Plant Safety' Committee .

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' Management should establish a plant safety committee (s) or equivalent function, whose duties and responsibilities include matters such as review and approval of operating plans and procedures, design changes,'nonconformances and corrective-actions, audits, and training programs.

(One of) the committees should have established procedures for systematic review of proposed changes to procedures, equipment, tests, or processes to determine that such changes can be made by the licensee or whether NRC approval is required.

C. Plant Procedures Licensees should have two basic types of procedures--administrative and general plant procedures. Administrative procedures address the process of planning, administrative controls, and document issuance; and provide rules and instructions on personnel conduct, preparation and retention of plant documents, and inter-faces among plant organizations. General plant procedures prescribe the actions required to achieve safe operation and provide instructions for the operation and maintenance of plant activities and support systems. General plant procedures should include measures for controlling chemical, radiological, nuclear criticality, and fire hazards. Licensees should provide management controls governing the establishment, maintenance, and use of all procedures.

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6 D. Tests and Inspections l

Surveillance, tests, and inspections of items and activities important to safety should be conducted in accordance with written procedures which identify i i

requirements and acceptable limits. Pre-operational tests demonstrate plant j operability and identify conditions adverse to safety. Tests during operations will verify and record the characteristics of various plant equipment and components. Surveillance, tests, and inspections, if required, should be performed to assure functionality of items and activities after modification or when corrective actions have been completed. Licensees should provide management controls governing the establishment, maintenance, and use of surveillance, tests, and inspections.

E. Audits Planned and scheduled internal and external audits should be performed to evaluate the application and effectiveness of management controls and implementation of programs related to activities significant to plant safety.

Audits should be conducted following approved procedures and instructions, and by qualified personnel who are not involved with the activity. The audit schedules and the audit personnel qualifications should be determined by management.

Audit results should be documented and then reviewed by designated management.

Deficient conditions requiring actions should be followed by management, and re-audited as necessary. Audit reports should be distributed to appropriate management and organizations for review and information. l F. Training Training programs help to assure that employees have the necessary skills and knowledge to perform the assigned duties safely. All employees should be trained in their areas of responsibility and as applicable, in management l controls, nuclear criticality safety, radiological safety, chemical safety, and fire protection. Effectiveness of the training programs should be evaluated periodically. f I

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III. POSITION

.To assure confidence in the safe operation of' fuel cycle facilities,.the following steps should be taken:

A. Licensees should establish an organization responsible for developing,

-implementing, and assessing the management controls program for assuring safe facility operation.

B. Licensees should establish a plant safety committee (s) to monitor and oversee:important plant activities and changes. The committee should include, as a minimum, management representatives from production, engineering, and safety functions.

C. Licensees should develop written administrative and general plant procedures, including procedures for evaluating changes to procedures, equipment, tests, and processes. Such procedures should be reviewed, approved, and documented in a manner approved by management.

D. Licensees should establish and implement a surveillance, test, and inspection program to assure satisfactory inservice performance of items and activities affecting safety. Procedures which set forth the specified standards or criteria and detailed testing steps should be developed.

E. Licensees should provide for periodic independent audits to determine the effectiveness of the management controls program. Management controls should provide for documentation of audit findings and implementation of corrective actions.

F. Licensees should establish and implement training programs to provide employees with the skills and knowledge to perform their jobs safely.

Management controls should provide for the evaluation of the effectiveness of training programs against predetermined objectives and criteria.

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IV. REFERENCES ANSI N299-1979, " Administrative and Managerial Controls.for.the Operation of Nuclear Fuel Reprocessing Plants."

Regulatory Guide' 3.52, " Standard Format and Content for the Health and Safety Sections of License Renewal Applications for Uranium Processing and Fuel-Fabrication." Revision 1, November 1986.

ANSI /ASME NQA-1 1986, " Quality Assurance Program' Requirements for Nuclear Facilities."

ANSI /ASME N45.2 1977, " Quality Assurance Program Requirements for Nuclear Facilities."

ANSI /ANS 3.2 1982, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants."

BRANCH TECHNICAL POSITION ON REQUIREMENTS FOR OPERATION FOR FUEL CYCLE FACILITIES I. INTRODUCTION The Materials Safety Regulation Review Study Group (MSRRSG) recommended that the NRC expand its licensing and inspection procedures to ensure a comprehensive review of all aspects of fuel cycle licensees' activities important to safety. The M3RRSG concluded that this review should cover the calibration, maintenance, and performance of all systems employed for achieving nuclear criticality safety, radiation safety, process safety, and confinement of radioactive or other hazardous materials.

During the time that the MSRRSG report was being prepared, the staff conducted a number of team assessments of operational safety at the major fuel cycle facilities under NRC jurisdiction. These assessments identified safety-related instrumentation and maintenance as areas needing attention by licensees.

Based on the MSRRSG recommendation and team assessment findings, a Branch

. Technical Position on Requirements for Operation, which addresses instrumen-tation and controls and preventative maintenance and surveillance, has been

9 developed. This position applies to all facility activities where nuclear criticality safety, radiation safety, process safety, and confinement of both hazardous and radioactive materials must be assured.

Some licensees already utilize instrumentation and control systems and preventative maintenance and surveillance programs to help assure safe operations. The purpose of this Branch Technical Position is to address the use of these systems and programs and to assist all licensees in the development.of comprehensive Requirements for Operation.

II. DISCUSSION Requirements for Operation are defined as instrumentation and control systems and preventative maintenance and surveillance programs necessary for safe operation of a facility to protect workers, the public health and safety, and the environment. Safety analyses of facility operations can be performed to identify both potential hazards and limiting specifications for the appropriate parameters of those operations which must be controlled. Instrumentation and control systems and/or preventative maintenance and surveillance programs can then be provided, and these systems and programs become the Requirements for Operation for the facility.

Instrumentation and control systems provide the capability for monitoring operational parameters that are important to safety. All instruments and controls required for safe operation should be failure-indicating or should be backed up by other instruments and controls that can serve the same function.

These systems also may initiate actions to help assure that acceptable operating specifications are not exceeded. These actions may include automatic activation of alarms, valves, ventilation dampers, or other safety-related equipment.

Automatically activated systems should fail into a safe state.

I Preventative maintenance and surveillance programs provide means to monitor j operational parameters that are not suitable for direct co".P.rol by instrumen- I tation and control systems. Preventative maintenance and surveillance also are used to provide assurance that all instrumentation and control systems continue to function as required.

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.Several examples to illustrate the development of Requirements for Operation for typical facility operations and activities are described below. The examples include ~ use of both instrumentation and control systems and preventative maintenance and surveillance programs.

A. Process Systems A common process system is the conversion of low-enriched uranium hexafluoride

.(UF6 ) to uranyl fluoride (UO 22 F ) using steam. Two of the process safety controls are described as Requirements for Operation.

For purposes of nuclear criticality safety, the UO 22 F must remain essentially dry (moderation control). To maintain dry conditions, condensation of steam.in

.the presence of UO22 F must be prevented by introducing only superheated steam into-the preheated reaction vessel. Therefore, a Requirement for Operation is an instrumentation and control system to detect low steam or vessel temperature and to automatically _ terminate flow of UF and steam into the reaction vessel.

6 For environmental protection, the UF6 gas must be prevented from reaching and penetrating the process'off gas system (filters). To accomplish this, the UF 6

gas introduced into the process vessel must be completely converted to UO F 22 powder. Therefore, a Requirement for Operation is.an instrumentation and control system to detect a non-stoichiometric ratio of UF to steam flows and 6

to terminate flow of UF6 and steam into the reaction vessel if an unsafe ratio is detected.

B. Auxiliary Chemical Systems An example of an auxiliary chemical system is the storage of chemicals sufficiently close to operations to create an uninhabitable environment in the event of a tank rupture. To prevent tank rupture, the pressure of the tank must be controlled. Therefore, a Requirement for Operation is a pressure relief device to prevent rupture and/or to allow for controlled releases. If other means to prevent tank rupture are not used, redundant systems such as backup relief valves should be provided.

11 C. Fire Protection Systems Fire protection water should be available at all times to the facility. Both water pressure and flow are important to help assure that this water is provided. Therefore, the Requirements for Operation are a low pressure detection and alarm device and periodic water flow / pressure testing.

D. Ventilation and Effluent Control Systems Workers performing activities require protection against the inhalation of radioactive material (airborne contamination). For certain activities, a local-exhaust hood with a face velocity sufficient to confine the airborne contamination provides such protection. Requirements for Operation are periodic measurement of the hood face velocity and administrative suspension of the activity until the required face velocity is restored.

E. Utilities Power must be provided to certain safety systems at all times. An emergency generator is one way of assuring that power to the safety systems is maintained if primary power is lost. Therefore, Requirements for Operation are periodic startup tests and preventative maintenance of the emergency generator.

III. POSITION Licensees should perform safety analyses of facility operations to identify potential hazards, operational parameters, and limiting specifications for these parameters.

Based on the results of the safety analyses, licensees should establish and

document the basis for Requirements for Operation.

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4 12 Licensees should establish programs for testing, calibration, and inspection of all instrumentation and control systems to assure their reliability.

Licensees should establish management controls to establish and monitor the effectiveness of the Requirements for Operation programs.

BRANCH TECHNICAL POSITION ON CHEMICAL SAFETY FOR FUEL CYCLE FACILITIES I. INTRODUCTION Most NRC fuel cycle licensees possess materials that are chemically hazardous, that pose some sort of non-radiological risk. In the past, the NRC has been concerned mainly with radiological risks and has left the regulation of chemical risks to the Occupational Safety and Health Administration (OSHA),

the Environmental Protection Agency (EPA), and corresponding state-level authorities. While these agencies still have principal responsibility for chemical safety, several recent developments have led us to re-evaluate the boundary between chemical and radiological safety and to reconsider the reach of the NRC's regulatory activities into the area of chemical safety.

A fuller awareness has developed, particularly since the January 1986 accident at the Sequoyah Fuels Corporation, that chemical and radiological risks can compound one another and that in any case, many radioactive materials are l chemically hazardous. A chemical explosion in a fuel cycle facility could disperse radioactive material, just as the radiation environment could make it more difficult to respond to a hazardous chemical spill. In the Sequoyah accident, a uranium hexafluoride cylinder ruptured and exposed the cylinder's contents to water vapor in the air, leading to the release of clouds of hydrofluoric acid vapor and uranyl fluoride particulate. The uranium hexafluoride and uranyl fluoride were radioactive, but the most serious problem was the release of highly corrosive hydrofluoric acid which, in fact, killed one worker. This is the best example of the type of risk that this

( Branch Technical Position (BTP) aims to address.

13 It has become clear that other federal and state agencies, even when having legal jurisdiction over chemical. safety at fuel cycle facilities, are in practice inclined to 1(ave NRC licensees to the NRC. OSHA, for example, has responsibility for a huge number of workplaces but deploys only a modest number of inspectors. A draft Memorandum of Understanding between the NRC and OSHA recognizes this situation and makes provision for the NRC's inspectors, who visit all fuel cycle licensees regularly, to assume more responsibility for identifying unsafe working conditions and alerting the appropriate OSHA regional offices.

j A somewhat *imilar situation exists, with regard to toxic wastes, air pollutants, nd other environmentally-hazardous chemicals. EPA and its state-level counterparts have jurisdiction over these materials, but the NRC.

has more of a presence in fuel cycle facilities and can help to ensure that the many federal environmental regulations are followed. The Federal Water Pollution Control Act, the Clean Air Act, the Toxic Substances Control Act, the Comprehensive Environmental Response, Compensation and i.fability Act (aka "Superfund"), and the Emergency Planning and Community Right-To-Know Act have created a whole new framewark for regulating the environmental impact of fuel cycle facilities, going far beyond the concentration limits of 10 CFR Part 20 for radionuclides released to the environment.

In the aftermath of the Sequoyah accident, the Materials Safety Regulation Review Study Group recommended that the NRC evaluate the scope of its regulatory authority over chemically-hazardous substances and work with other responsible agencies to ensure that there are no regulatory gaps. Four categories of chemical risks were defined in order to clarify the NRC's ,

responsibilities. The categories are:

A. radiation risk posed by radioactive materials, 1

B. chemical risk posed by radioactive materials, C. plant conditions that may directly or indirectly affect I l

l radiation risk, and D. chemical risk posed by nonradioactive materials.

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14 The first three categories are the NRC's direct responsibility. NRC is not the primary responsible agency for the fourth category and has no intention of formulating regulations in this area, but will work with OSHA, EPA, and other agencies as appropriate, to help ensure that fuel cycle licensees conform to all federal regulations. The purpose of this BTP is to describe actions to control the first three categories of risks.

II. DISCUSSION The four basic categories of risks listed in the Introduction require some further definition, both to help licensees better understand the materials of concern in this BTP and to better match the risk categories with existing federal regulations. The general category of " chemical risk," for example, can cover the risks posed by many different types of hazards. Soms chemicals pose a risk to workers; others pose an environmental risk; some pose both.

Some chemical risks could have acute consequences, such as a worker dying in a fire or explosion. Others risks could have chronic consequences, such as a worker suffering health effects from long-term exposure to a carcinogenic material. The following paragraphs define categories of risks, surgest some practical examples from fuel cycle facilities, and identify applicable fed al regulations to which licensees are subject.

A. Radiation Risks Posed By Radioactive Materials N

These risks are already explicitly suoject to NRC regulation and are not a subject of this BTP.

B. Chemical Risks Posed by Radioactive Materials One type of chemical risk posed by radioactive materials is the risk that a radioactive material may be the cause o' a severe chemical accident. This would cover risks posed by radioactive materials that are explosive, flammable, highly reactive, or handled under high temperatures or pressures.

15 An example would be the risks involved in handling uranium hexafluoride cylinders. Uranium hexafluoride is a highly reactive chemical known to react '

rapidly with water, including the water vapor in normal air, to produce hazardous hydrofluoric acid vapors and uranyl fluoride particulate. An accidental release of uranium hexafluoride would pose an acute threat to the safety of nearby workers. Uranium hexafluoride is normally stored and transported in airtight cylinders. The tendency of uranium hexafluoride to expand dramatically when heated means that a cylinder. filled beyond normal limits poses a significant danger of rupture or explosion, which could cause direct injury to workers in addition to releasing hazardous gases.

Another radioactive material that could pose chemical risks of this type is uranyl nitrate. Uranyl nitrate is normally in a strong solution of nitric g acid, so a spill could cause serious acid burns nr, if a strong base is stored nearby, lead to violently exothermic reactions. Furthermore, when uranyl nitrate is overheated it can release toxic nitrogen oxides.

NRC is the principal agency responsible for the safety of radioactive materials handled in fuel cycle facilities, whether radiation safety or chemical safety.

But some existing federal regulations on chemical safety may be applicable to radioactive materials. OSHA regulations in 29 CFR Part 1910.101 .120 cover safety 1 procedures that should be followed in handling flammable liquids, compressed gases, and some other types of hazardous materials.

A second type of chemical risk could be posed by the chemical toxicity of some radioactive materials. The concern of this BTP is the possibility that some radioactive compounds may be more toxic because of their non-radioactive components than because of the radioactivity. For example, 10 CFR Part 20  ;

limits for soluble natural uranium are based on its chemical toxicity.

Insoluble . natural uranium is less toxic chemically, and the 10 CF9 Part 20 exposure limits for insoluble natural uranium are based on its radiation hazards.

Many chemicals are more hazardous than insoluble uranium as airborne toxins, and a few are more hazardous even than soluble uranium. If these chemicals were present in radioactive compounds, the airborne exposure limits of 10 CFR Part 20 could well be less stringent than existing federal regulations on occupational exposure to airborne chemicals, such as 29 CFR Part 1910.1000.

16 A third type of chemical risk would be the risk to the environment or to public health and safety posed by a large, accidental release of a radioactive material with dangerous chemical properties. The radiation hazards arising from an accidental release of radioactive material are covered by existing NRC regulations, but in some cases, the chemical properties of the released substance may pose more of a risk than its radiation properties. For example, an accidental release of uranium hexafluoride would generate a plume of hydrofluoric acid when the uranium hexafluoride reacts with airborne water vapor. The hydrofluoric acid would probably be a greater hazard to nearby residents than uranyl fluoride, the radioactive byproduct of the accident.

As another example, a spill of solvent extraction organic (normally a solution of tri-butyl phosphate in dodecane) could cause serious local water pollution unrelated to the amount of uranium it contains.

Existing EPA regulations would apply to an accidental release of chemically hazardous radioactive materials. 40 CFR Parts 116-117, derived from the Federal Water Pollution Control Act of 1978, identifies chemicals that can be hazardous water pollutants and establishes requirements for reporting releases to the EPA. The Toxic Substances Control Act regulations, 40 CFR Parts 702-799, would govern licensees handling certain types of toxic chemicals.

C. Plant Conditions Which May Directly Or Indirectly Affect Radiation Risk This category of risk covers plant conditions related to the presence of hazardous chemicals on or near a fuel cycle site that could affect radiation safety. One concern would be the risk posed by the presence of flammable or explosive chemicals near radioactive materials or near essential facilities for the control and containment of radioactive materials. If a flammable or explosive chemical were involved in an accident under these circumstances, the dispersal of radioactive material or loss of control over radioactive material could make the accident much more serious than would otherwise be the case.

This concern would apply not only to flammable or explosive chemicals that are possessed by the fuel cycle licensee, but also to such chemicals in the possession of others that are located sufficiently close to the fuel cycle facility, such that a major fire or explosion could affect the safety of licensed material.

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l l The safety regulations of 29 CFR Part 1910 would apply to the storage and l handling of flammable or explosive materials, but the possibility that radioactive materials could be involved in a fire or explosion would have to be reflected in a fuel cycle licensee's emergency plan and operator training procedures.

Risks may also be posed by the proximity of toxic chemicals or inert gases to essential areas of a fuel cycle facility. Accidental release of such chemicals could render the control room, the emergency operations center, or other essential areas uninhabitable. NRC Regulatory Guide 1.78 discusses the precautions that would be appropriate for protecting a reactor control room from hazardous chemical fumes. Similar considerations should be applied to fuel cycle licensees.

D. Chemical Risks Posed by Nonradioactive Materials Chemical risks at fuel cycle facilities that do not involve radioactive materials either directly or indirectly are strictly considered to be subject to EPA or OSHA regulations, not NRC regulations. These hazards are not the subject of this BTP. The Memorandum of Understanding with OSHA indicates that, in the future, NRC inspectors will make more of an effort than previously to astyss licensee compliance w'th OSHA regulations and to inform OSHA of possible incidences of noncompliance.

III. POSITION To help ensure that chemical hazards do not endanger the safety of workers or members of the general public, the following steps should be taken by fuel cycle facility licensees:

A. Licensees should identify all chemical risks of the types discussed in Sections II. B and C above, which are posed by materials in their facilities or in the vicinity of their facilities. Licensees should determine the quantities of all the chemicals identified.

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.4 18 For purposes of making a complete identification, hazardous chemicals should be considered to be any included in the following sources:

29 CFR Part 1910.101 .120 for flammable and explosive materials, 29 CFR Part 1910.1000 .1500 for occupational toxins, 40 CFR Parts 116-117 for substances hazardous if accidentally released into the environment, 40 CFR Parts 702-799 for toxic substances subject to the 1982 Toxic Substances Control Act, 40 CFR Parts 261.31 .33 for hazardous wastes, and Material Safety Data Sheets.

B. Licensees should determine that proper facilities, equipment, and procedures are employed for the safe storage and handling of all hazardous chemicals in their possession. All operators should be trained in procedures for the safe handling and disposal of hazardous chemicals in the licensee's possession.

C. Licensees should determine that proper procedures are in place and proper facilities and equipment are available for measuring the extent of, mitigating the consequences of, and otherwise dealing with any potential accidental release of hazardous chemicals. These procedures, facilities, and equipment should be described in the licensee's emergency plan. Procedures should be in place for notifying the EPA and any responsible state or local agencies of such a release. All operators should be trained in procedures for responding to an emergency involving hazardous chemicals. Licensees should determine that proper procedures are in place and that proper facilities and equipment are available for dealing with a release cf radioactive material caused by fire, explosion, or other accident with nonradioactive materials. These procedures, facilities, and equipment should be described in the licensee's emergency plan.

Accidents involving hazardous nonradioactive materials located or transported ne eby but not on the fuel cycle site should also be considered, even if such materials are not in the possession of the licensee. The proximity of major depots of hazardous chemicals should be considered in evaluating the possible impact of hazardous chemicals on the safe operation of the fuel cycle facility.

i 19 The management controls, conditions required for operation, and fire protection measures discussed in other BTPs may be used to help accomplish these chemical safety' goals.

BRANCH TECHNICAL POSITION ON FIRE PROTECTION FOR FUEL CYCLE FACILITIES I. INTRODUCTION Any application for a license to possess and use licensed materials in a fuel cycle facility must provide information showing that the' applicant's proposed equipment, facilities, and procedures are adequate to protect health and  ;

minimize danger to life or property. In the area of fire protection, the staff has in the past generally accepted compliance with local building codes and proof of insurance as sufficient fire protection information for approval of license applications. In addition, ad hoc measures have been taken in response to the staff's inspection findings relating to specific facilities.

Following the January 4,1986, accident at the Sequoyah Fuels Corporation uranium hexafluoride conversion facility, however, the NRC undertook a major review of the operational safety of fuel cycle facilities. Both the recommendations of the Materials Safety Regulation Review Study Group and the independent staff action to assess operational safety at each of 12 major fuel cycle facilities licensed by the NRC led the staff to the finding that fire protection is one of the most important safety concerns.

This finding, coupled with the experience of the applicants and the staff in their respective roles of operation and of regulation of fuel cycle facilities, permits the formulation of this Branch Technical Position (BTP),

which should provide guidance to the applicants on meeting the approval requirements of NRC regulations insofar as fire protection is concerned.

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I l 20 l 1 l l The objective of this BTP is to provide guidelines for a fire protection program at each fuel cycle facility that would be acceptable to the staff as having the necessary elements to ensure protection of health and to minimize l danger to life and property. These guidelines should not be considered all-inclusive, and nothing should preclude a licensee from adopting a program that is prudent and employs the latest techniques of fire protection that meet or exceed the guidance in this BTP. .l II. DISCUSSION A. Fire Protection Concept Accidental fires and consequent explosions, apart from being threats to health, life, and property by themselves, are potential causes of unplanned radioactive releases at a fuel cycle facility. The concept of fire protection presented by this BTP consists of implementing measures to achieve a balance among the following desired results:

Prevention of fires; Detection of fires; and Containment and suppression of fires.

A discussion of these three levels of fire protection follows:

1. Fire Prevention: Fire prevention measures at a fuel cycle facility should start with the design of the buildings, structures, systems, components, and processes involved in the storage, handling, and processing of the radioactive materials and chemicals used in the processes. The processes should be designed and physically laid out so as to minimize the possibility of over-heating, over pressurization, and leakage; and the confluence of combustibles and ignition sources except by design. Even with the most well-designed facility, prevention of fires depends to a great extent on following good housekeeping practices i.nd operating personnel scrupulously following safety instructions.

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2. Fire Detection: The best fire prevention measures may occasionally fail, in which case an effective fire detection system should detect the occurrence of fire and activate alarm systems so that personnel evacuation and fire containment and suppression measures may start promptly. The type and location of the detectors depends on the type of ha.ard.

3. Containment and Suppression of Fire: Containment of fire in its area of origin and prevention of its spread to new areas and new combustibles is the first step to be ta5#: upon detection of a fire. This is achieved by acti-vating systems such as barriers, ventilation dampers, exhaust fans, and drainage pumps to prevent migration of gases, hot combustion products, and flammable liquids to new areas. Fire suppression activity should start at the same time as barrier systems are activated. The media employed in the suppression and the means of their delivery to the fire source and to heated areas and substances depends on the plant area and the processes and equipment protected. The concerns for nuclear criticality safety, chemical safety, and the danger to personnel from non-life supporting extinguishing media such as carbon dioxide, should all be taken into account in planning a fire suppression system.

B. Building Construction Buildings, structures, components, and processes in a fuel cycle facility should be designed to protect the health of plant personnel and the public and minimize the danger to life and property during normal operation, as well as during abnormal situations such as fires and explosions. The following discussion lists desirable features in the design and construction of a facility.

It is recognized, however, that a number of fuel cycle facilities already exist and are in operation, and these facilities may not have all of the desirable design and construction features.

1. The buildings should be designed and constructed using components of noncombustible and heat and fire resistant materials, as far as practicable.

Assuming failure of a fixed fire suppression system, the structural barriers (including walls, roofs, floors, doors, and penetrations) surrounding a plant

o 22 area of high hazard of fire should be constructed so as to confine the effluents of fire for a sufficient duration for fire suppression measures to be applied. Such structural barriers should also possess adequate fire ratings so as not to propagata fire to adjoining areas. ASTM Standard E-119, " Fire Test' of Building Construction and Materials," which defines fire ratings, ASTM Standard E-84, " Surface Burning Characteristics of Building Materials," and local and national building codes may be consulted.

2. Suspended ceilings and their supperts, insulation for pipes and ducts, and sound-attenuating materials should be non-combustible and should not hinder effective functioning of the fire suppression system. Concealed spaces should be devoid of combustibles, as far as practicable.

3. Electrical wiring and their supporting components such as conduits and cable trays, servicing essential components, including fire protection systems, should be protected against fire. Non-fire propagating insulated electrical cables should be used in areas of high fire hazard, as far as practicable.

4. Provision should be made for protection of the plant from lightning damage.

5. Exits from the various plant areas should be strategically located so as to facilitate orderly evacuation of personnel, with minimum exposure to fire products and radioactive releases.

6. The plant areas should be designed so that fire fighting personnel along with their equipment may access them with minimum hindrance.

C. Ventilation System The ventilation system should be designed to isolate affected areas during fire accidents and to provide channels for exhausting fire products, through filters if necessary, to outside the plant. NFPA Standard 90-A, " Air Conditioning and Ventilation Systems," may be consulted on ventilation design for fire protection.

s 23 Where a ventilation system is required to prevent the release of radioactive material to the atmosphere, all materials of construction and all filters for the system should be fire resistant. High efficiency HEPA filters should conform with Underwriters' Laboratories Standard UL-560, also designated ANSI B 132.1.

If a heat removal system such as a water spray system is required for the final filter plenum, it should operate automatically (with manual override) upon abnormal rise of the effluent temperature. The water distribution system for the water spray system should be in addition to and separate from the fire water distribution system. Provision should be made for periodic operational performance checks of such systems.

D. Fire Detection and Alarm Systems

1. Provision should be made for fire detection and alarm systems consisting of fire and smoke detectors, signalling devices, and audible and visible indicators of fire at various appropriate locations in the plant, as well as at a central constantly attended monitoring station. Such monitoring stations should constantly have available information on the status and functioning of the fire detection and alarm systems and of the installed fire suppression systems, including a zone indication of the origin of an alarm. Provision should be made for the periodic testing of these systems. Fire detection systems should comply with the requirements of Class A systems as defined in NFPA 720, " Standard for the Installation, Maintenance, and Use of Proprietary Protective Signalling Systems," and NFPA 72E, " Automatic Fire Detectors."

2. Manual fire alarm actuators should be installed throughout the plant at locations which are readily accessible, including exit passageways.

3. Actuation of any fire suppression system, such as flow through a sprinkler, should initiate visual and audible alarms.

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24 E. Fire Suppression Systems Manually actuated or automatic fire suppression systems should be installed in all plant areas having significant fire hazard. The selection of a specific type of system should take into account the severity of the hazard, type of  !

activity performed in the area, nuclear criticality concerns, consequences of fire (e.g. , risk of radioactive release), and consequences of spurious actuation of the suppression system. Provisions should be made for the periodic testing of the systems. The following subsections provide general guidance on the selection of a system:

1. Automatic water sprinkler coverage should be provided in areas of significant fire hazard, except where nuclear criticality or other hazards specifically obviate their use. NFPA 13, Installation of Sprinkler Systems, provides guidance for selection and design of sprinkler systems.

2. Plant areas having significant fire hazard and not protected by automatic water sprinkler systems should be protected by other systems employing fire suppression agents such as inert gases, carbon dioxide, halogenated hydrocarbon gases, and high-expansion foam. Guidance on carbon dioxide and halon systems are provided in NFPA 12 and 12A, respectively. Guidance on the selection and design of foam systems are provided in NFPA 11 and 11A.

3. Selection of all gaseous suppression systems should take into account protection of personnel, possible pressurization of the enclosure protected, and possible adverse reaction with pyrophoric materials.

F. Manual Fire Fighting Equipment

1. Portable fire extinguishers, suitable in capacity and in the type of suppression agent used, should be available throughout the plant where specific types of fire hazards exist. The number of such extinguishers and their location should be guided by the severity of the hazard, the occupancy of the plant area, and ready access in an emergency. Guidance on the selection and use of portable fire extinguishers is provided in NFPA 10.

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2. Standpipe and hose systems should be provided for the protection of all process and non process areas. The hose outlet locations should be readily accessible. Guidance on standpipe and hose systems is provided in NFPA 14.

G. Fire Protection Water System

1. Adequate supply of water for the installed fire protection systems should be assured. Additional supply of fire fighting water that may be needed by an

.outside fire department should be planned for in consultation with them.

Compatible connections should be provided for outside fire department use. The fire water distribution system should be designed and constructed for high reliability. NFPA 24, Standard for the Installation of Private Fire Service Mains and Their Appurtenances, should be used for guidance. -

2. A collection system should be provided for the drainage of water used in fire suppression and fire fighting. Nuclear criticality concerns, sampling, confinement, and retrievability of the drainage should be taken into account in the design and construction of the system.

H. Emergency Lighting and Communications

1. To facilitate evacuation and fire fighting in the event of a power failure, provision should be made for emergency lighting powered by an alternate source.

2. An emergency communication system, including portable transceivers, should be provided. j

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I. Trainitig In order to extract maximum benefit from a well-designed fire protection i system, the personnel monitoring and operating the system should be trained.

The training for non-fire fighting personnel usually takes the form of drills to ensure orderly evacuation, use of hand-held fire extinguishers and fire alarm devices, and the importance of good housekeeping. Facility employees l

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l 26 assigned fire fighting duties, such as members of an organized fire brigade, should receive appropriate training. NFPA 1001, Fire Fighter Professional Qualifications, may be consulted for guidance as to the elements of the.

training. Local fire department personnel who may be summoned to fight fires in the facility should be provided orientation training on-the facility and its processes. Whenever practicable, facility fire fighting personnel also should receive training with the local fire department in fire fighting methods.

J. Fire Emergency Plans Fire emergency plans should be drawn up in consultation with the local fire departments, taking into account those departments' ;,isting equipment, distances from the plant, and their training in fighting fires involving radioactive materials and chemicals in the facility.

III. POSITION A. Fire Protection Program Licensees should establish and maintain a fire protection program for the facility. The overall management of the program should be under the direction of a senior level individual, who has been given the authority and staff assistance to implement measures relating to fire protection throughout the facility. The program should include provisions for audits of the effectiveness l

l of the program.

I B. Fire Protection Equipment l

l The selection, installation, and use of the fire protection equipment and systems should be appropriate for the plant area protected and should conform with or exceed the requirements of NFPA and other national codes and standards cited above (see B. Discussion) and also those cited in the references. The equipment should be maintained and tested periodically, as appropriate, to ensure reliability of operation in an emergency.

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27 C. Fire Hazard Analysis For both existing and new facilities, licensees should perform a fire hazard analysis for each plant area and for the facility as a whole. This analysis should account for the combustible and the radioactive materials in the area, their heat content, the processes performed in the areas that have potential for fire or explosion, and the potential sources of ignition. It should con-sider credible scenarios by which a fire can occur and.the capabilities of installed fire suppression systems, portable extinguishers, and other fire fighting measures that the management may summon (e.g., outside fire depart-ments). The objective of a fire hazard analysis would be to detect deficiencies in the fire protection program or otherwise to demonstrate that the facility has in operation fire protection systems that can handle all credible fire scenarios. The fire hazard analysis should be periodically reviewed and updated as necessary. Any deficiencies identified as a result of an analysis should be corrected by a judicious balance of facility modification and enhanced fire protection measures, D. Fire Emergency Plans Licensees should establish fire emergency plans for each area of the facility.

Such plans assign responsibilities to individuals and include measures to ensure orderly evacuation of personnel, shutting down operations, activating barrier systems, summoning fire fighters, controlling small fires, and controlling reitese of radioactive material.

E. Training Licensees should have a training program for an adequate number of personnel to perform assigned duties during a fire emergency. This program also should provide for periodic retraining and drills. Evacuation drills should be conducted for all facility personnel.

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L F.. Administrative Cdntrois-L.

Licensees should establish fire safety procedures' aimed at minimizing fire hazards such as for transit and storage of combustibles in the plant',-general housekeeping, and maintenance work such as welding and torch cutting.

IV. REFERENCES l

A. National Fire Protection Association Codes and Standards NFPA 4, " Organization of Fire Services."

NFPA 4A', " Fire. Department Organization."

NFPA 6, " Industrial Fire Loss Prevention."

NFPA 7, " Fire Emergencies Management."

NFPA 8, " Effects of Fire on Operations, Management Responsibility."

NFPA 10, " Portable Fire Extinguishers, Installation, Maintenance, and Use."

NFPA 11, " Foam Extinguishing Systems."

NFPA 11A, "High Expansion Foam System."

NFPA'118, " Synthetic Foam and Combined Agent Systems."

NFPA 12, " Carbon Dioxide Systems."

NFPA 12A, "Halon 1301 Systems."

NFPA 128, "Halon 1211 Systems."

NFPA 13. " Sprinkler Systems."

NFPA 14, " Standpipe and Hose Systems."

NFPA 15, " Water Spray Fixed Systems."

NFPA 16, " Foam-Water Sprinkler and Spray Systems."

NFPA 20, " Centrifugal Fire Pumps."

NFPA 24, "Outside Protection."

NFPA 26, " Supervision of Valves."

NFPA 27, " Private tire Brigade."

NFPA 30, "Flammabit Combustible Liquids Code."

NFPA SIB, "Cuttin and Welding Processes."

NFPA 68, "Explosi n Venting."

NFPA 69, " Explosion Prevention Systems."

NFPA 70, " National Electrical Code."

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29 NFPA 720, " Proprietary Protective Signaling Systems."

NFPA 72E, " Automatic Fire Detectors."

NFPA 80, " Fire Doors and Windows."

NFPA 92M, " Waterproofing and Draining of. Floors."

NFPA 197, " Initial Fire Attack Training."

NFPA 204, " Smoke and Heat Venting Guide."

NFPA 220, " Types of Building Construction."

NFPA 251, " Fire Tests, Building Construction and Materials."

NFPA 259, " Test Method for Potential Heat of Building Materials."

NFPA 802, " Recommended Fire Protection Practice for Nuclear Reactors."

8. U. S. Nuclear Regulatory Commission Documents NUREG-0800, Standard Review Plan 9.5.1 " Guidelines for Fire Protection for Nuclear Power Plants," Revision 2, July 1981.

'C. Other Documents ANSI Standard B31.1-1973, " Power Piping."

ASTM D-3286, " Test for Gross Calorific Value of Solid Fuel by the Isothermal -

Jacket Bomb Calorimeter (1973)."

ASTM E-84, " Surface Burning Characteristics of Building Materials (1976)." i ASTM E-119, " Fire Test of Building Construction and Materials (1976)."

Factory Mutual System Approval Guide - Equipment, Materials, Services for Conservation of Property.

NFPA Fire Protection Handbook.

Underwriters Laboratories Rating List.

Underwriters Laboratories, " Building Materials Directory."

" International Guidelines for Fire Protection at Nuclear Installations including Nuclear Fuel Plants, Nuclear Fuel Stores, Teaching Reactors and Research Establishments," 1987 Edition.

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American National Standard Institute (ANSI) N655-1985, " Fire Protection for LWR Fuel Fabrication Facilities," dated April 2, 1985.

Dated at Rockville, Maryland, this ly ay of March, 1989.

FOR THE NUCLEAR REGULATORY COMMISSION Leland C. Rouse, Chief Fuel Cycle Safety Branch Division of Industrial and Medical Nuclear Safety, NMSS k

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