NRC Generic Letter 1995-01: Difference between revisions
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==Purpose== | ==Purpose== | ||
The U.S. Nuclear Regulatory Commission is issuing this generic letter tonotify addressees about the need to implement a Fire Hazard Analysis and aPre-Fire Plan and require that all addressees provide the NRC a writtenresponse to this generic letter.BackgroundSection 70.22, Contents of Application, and Section 70.23, Requirements forthe Approval of Applications, of 10 CFR Part 70 require that equipment,facilities, and procedures that will be used by a licensee be adequate toprotect health and minimize danger to life or property. Similar requirementsare found in Part 40. After a January 1986 accident at Sequoyah FuelsCorporation's uranium hexafluoride conversion facility, the NRC formed aMaterials Safety Regulation Review Study Group (MSRRSG), which was tasked toreview the agency's licensing and regulatory program and recommend measures tostrengthen areas of weakness. One such area identified by the MSRRSG was fireprotection. On March 21, 1989, the NRC published in the Federal Register (54FR 11590-98) guidance to applicants and licensees for the preparation oflicense applications and conduct of operations. Public comments wererequested on the guidance, which was in the form of four draft TechnicalPositions in the areas of Management Controls/Quality Assurance, Requirementsfor Operation, Chemical Safety, and Fire Protection for Fuel Cycle Facilities.After consideration of the comments received and the experience gained inusing these draft Technical Positions, the NRC then revised and reissued theTechnical Position (TP) on Fire Protection for Fuel Cycle Facilities in theFederal Register (57 FR 35607-13) dated August 10, 1992.Apart from providing guidance on good industry practices and standards forbuildings, equipment, maintenance, and training, the TP introduced the conceptof a Fire Hazard Analysis (FHA) to identify deficiencies in the fireprotection program of a facility. It described FHA as a systematic study ofeach "fire area' of the facility, and of the facility as a whole, in order to9D50 120 o03 1 94ot M9501200194//z1Rr OAN GL 95-01January 26, 1995 identify and quantify all credible fire hazards that could affect thecontainment and safety of licensed radioactive materials, so that adequatecontrols can be provided to reduce those risks to acceptable levels. The TPalso stressed the importance of the Pre-Fire Plan to the preparedness of thefacility to meet all credible fire emergencies.On May 29, 1991, a potential criticality incident that developed at theGeneral Electric Nuclear Fuel and Component Manufacturing Facility (see NUREG-1450) once again raised generic safety concerns regarding the operation oflarge materials facilities. The NRC established a Materials Regulatory ReviewTask Force (MRRTF), which recommended a number of regulatory measures. Theconcept of an Integrated Safety Analysis (ISA) for the facilities, of whichFHA would be an integral part, was developed from those recommendations.Pursuant to the MRRTF report (NUREG-1324), the agency started work on arevision of the 10 CFR Part 70 rule, which is ongoing. The fuel cycleindustry has been consulted and informed of the agency's plan.DiscussionWhile neither of the two incidents cited above involved a fire, fire wasrecognized as a notable hazard at the conclusion of each review. Largequantities of flammable materials needed for the processes are stored at thesefacilities. Some of the fuel manufacturing processes themselves involve firerisk. While such risks cannot be completely eliminated, they should beminimized. The TP on fire protection provides guidance on ways to minimizesuch risks from fire.Inside facility buildings, fire hazard exists not only in the various fuelmanufacturing processes, but also in construction materials, equipment,maintenance operations, and storage and transfer of combustible materials. Itis important to safety to know what fire protection equipment is appropriatefor a given application. The FHA is the tool that enables such importantsafety-related decisions. It forms the basis for effective fire protectionmeasures that reduce accident risk and enhance safety.The TP advises that the facilities should have Pre-Fire Plans. A Pre-FirePlan contains information to assist a fire fighting team in an actualemergency situation. It is recommended that the plan be prepared inconsultation with the local fire department, where such offsite assistance isrelied upon. The importance to safety of a Pre-Fire Plan cannot be over-emphasized. The fire fighters' ability to promptly locate ordinary installedhardware, such as a compatible connection for delivery of water or a sectionalvalve, may be critical in an emergency situation. The purpose of a Pre-FirePlan is to provide exactly such information. The Pre-Fire Plan should also bea training tool for both the facility's emergency response team and theoffsite fire department that is expected to assist the facility in | The U.S. Nuclear Regulatory Commission is issuing this generic letter tonotify addressees about the need to implement a Fire Hazard Analysis and aPre-Fire Plan and require that all addressees provide the NRC a writtenresponse to this generic letter.BackgroundSection 70.22, Contents of Application, and Section 70.23, Requirements forthe Approval of Applications, of 10 CFR Part 70 require that equipment,facilities, and procedures that will be used by a licensee be adequate toprotect health and minimize danger to life or property. Similar requirementsare found in Part 40. After a January 1986 accident at Sequoyah FuelsCorporation's uranium hexafluoride conversion facility, the NRC formed aMaterials Safety Regulation Review Study Group (MSRRSG), which was tasked toreview the agency's licensing and regulatory program and recommend measures tostrengthen areas of weakness. One such area identified by the MSRRSG was fireprotection. On March 21, 1989, the NRC published in the Federal Register (54FR 11590-98) guidance to applicants and licensees for the preparation oflicense applications and conduct of operations. Public comments wererequested on the guidance, which was in the form of four draft TechnicalPositions in the areas of Management Controls/Quality Assurance, Requirementsfor Operation, Chemical Safety, and Fire Protection for Fuel Cycle Facilities.After consideration of the comments received and the experience gained inusing these draft Technical Positions, the NRC then revised and reissued theTechnical Position (TP) on Fire Protection for Fuel Cycle Facilities in theFederal Register (57 FR 35607-13) dated August 10, 1992.Apart from providing guidance on good industry practices and standards forbuildings, equipment, maintenance, and training, the TP introduced the conceptof a Fire Hazard Analysis (FHA) to identify deficiencies in the fireprotection program of a facility. It described FHA as a systematic study ofeach "fire area' of the facility, and of the facility as a whole, in order to9D50 120 o03 1 94ot M9501200194//z1Rr OAN | ||
GL 95-01January 26, 1995 identify and quantify all credible fire hazards that could affect thecontainment and safety of licensed radioactive materials, so that adequatecontrols can be provided to reduce those risks to acceptable levels. The TPalso stressed the importance of the Pre-Fire Plan to the preparedness of thefacility to meet all credible fire emergencies.On May 29, 1991, a potential criticality incident that developed at theGeneral Electric Nuclear Fuel and Component Manufacturing Facility (see NUREG-1450) once again raised generic safety concerns regarding the operation oflarge materials facilities. The NRC established a Materials Regulatory ReviewTask Force (MRRTF), which recommended a number of regulatory measures. Theconcept of an Integrated Safety Analysis (ISA) for the facilities, of whichFHA would be an integral part, was developed from those recommendations.Pursuant to the MRRTF report (NUREG-1324), the agency started work on arevision of the 10 CFR Part 70 rule, which is ongoing. The fuel cycleindustry has been consulted and informed of the agency's plan.DiscussionWhile neither of the two incidents cited above involved a fire, fire wasrecognized as a notable hazard at the conclusion of each review. Largequantities of flammable materials needed for the processes are stored at thesefacilities. Some of the fuel manufacturing processes themselves involve firerisk. While such risks cannot be completely eliminated, they should beminimized. The TP on fire protection provides guidance on ways to minimizesuch risks from fire.Inside facility buildings, fire hazard exists not only in the various fuelmanufacturing processes, but also in construction materials, equipment,maintenance operations, and storage and transfer of combustible materials. Itis important to safety to know what fire protection equipment is appropriatefor a given application. The FHA is the tool that enables such importantsafety-related decisions. It forms the basis for effective fire protectionmeasures that reduce accident risk and enhance safety.The TP advises that the facilities should have Pre-Fire Plans. A Pre-FirePlan contains information to assist a fire fighting team in an actualemergency situation. It is recommended that the plan be prepared inconsultation with the local fire department, where such offsite assistance isrelied upon. The importance to safety of a Pre-Fire Plan cannot be over-emphasized. The fire fighters' ability to promptly locate ordinary installedhardware, such as a compatible connection for delivery of water or a sectionalvalve, may be critical in an emergency situation. The purpose of a Pre-FirePlan is to provide exactly such information. The Pre-Fire Plan should also bea training tool for both the facility's emergency response team and theoffsite fire department that is expected to assist the facility in anemergency. | |||
GL 95-01January 26, 1995 Reguested ActionPursuant to 10 CFR 40.31(b) or 70.22(d), as appropriate, each addressee shallprepare a statement on how it will implement the guidance of Position 9, FireHazard Analysis, and Position 10, Pre-Fire Plan, of the Technical Position onFire Protection for Fuel Cycle Facilities, published in the Federal Register(57 FR 35607-13) dated August 10, 1992.Reauired ResponseWithin 30 days from the date of this generic letter, each addressee shallsubmit a complete statement on how it will implement the referenced guidance.Please address the required written statement signed by a responsible officerto the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,Washington, DC 20555. In addition, please submit a copy to the appropriateRegional Administrator.Related Generic CommunicationsNRC Information Notice 92-14, "Uranium Oxide Fires at Fuel Cycle Facilities,"issued February 21, 1992.PaDerwork Reduction Act StatementThe statement is covered by the Office of Management and Budget clearancenumbers 3150-0020 (10 CFR 40.8) and 3150-0009 (10 CFR 70.8). The estimatedaverage number of burden hours to comply with the reporting request is 40person-hours per licensee response, including those needed to assess the newrecommendations, search data sources, gather and analyze the data, and preparethe required response. This estimate of the average number of burden hourspertains only to the identified response and not to the time needed toimplement any actions discussed in the responses. Send comments regardingthis burden estimate or any other aspect of this collection of information,including suggestions for reducing this burden, to the Information and RecordsManagement Branch, Division of Information Support Services, Office of GL 95-01January 26, 1995 Information Resources Management, U.S. Nuclear Regulatory Commission,Washington, DC 20555, and to the Paperwork Reduction Project (3150-0020 and3150-0009), Office of Information and Regulatory Affairs, NEOB-3019, Office ofManagement and Budget, Washington, DC 20503.If you have any questions about this matter, please contact the technicalcontact listed below or the appropriate regional office.Robert F. Burnett, DirectorDivision of Fuel Cycle Safetyand SafeguardsOffice of Nuclear Material Safetyand SafeguardsTechnical contact: A. Datta, NMSS301-415-8109Attachment: st o'Hf Recently Issued NRC Generic Letters AttachmentGL 95-01January 26, 1995 LIST OF RECENTLY ISSUED NRC GENERIC LETTERSGenericI _44-Date ofT c en is neC..k 4-4LTeciiad TnLC l.e tUUIl v ;F %4§ ak Luau .94-0494-03VOLUNTARY REPORTING OFADDITIONAL OCCUPATIONALRADIATION EXPOSURE DATAINTERGRANULAR STRESSCORROSION CRACKING OF CORESHROUDS IN BOILING WATERLONG-TERM SOLUTIONS ANDUPGRADE OF INTERIMOPERATING RECOMMENDATIONSFOR THERMAL-HYDRAULICINSTABILITIES IN BOILINGWATER REACTORSREMOVAL OF ACCELERATEDTESTING AND SPECIAL RE-PORTING REQUIREMENTS FOREMERGENCY DIESEL GENERATORSFIRE ENDURANCE TESTACCEPTANCE CRITERIA FORFIRE BARRIER SYSTEMS USEDTO SEPARATE REDUNDANTSAFE SHUTDOWN TRAINS WITHINTHE SAME FIRE AREA (SUPP. 1 TOGL 86-10, "IMPLEMENTATION OFFIRE PROTECTION REQUIREMENTS")09/02/9407/22/9407/11/9405/31/9403/25/94ALL HOLDERS OF OLs OR CPsFOR NPRs, RADIOGRAPHYLICENSEES, FUEL PROCES-SING LICENSEES, FABRICA-TING & REPROCESSINGLICENSEES, MANUFACTURERS& DISTRIBUTORS OF BY-PRODUCT MAT'L, INDEPEND-DENT SPENT FUEL STORAGEINSTALLATIONS, FACILITIESFOR LAND DISPOSAL OF LOW-LEVEL WASTE, & GEOLOGICREPOSITORIES FOR HIGH-LEVEL WASTE.ALL HOLDERS OF OLs OR CPsFOR BOILING WATERREACTORS EXCEPT FOR BIGROCK POINT, WHICH DOESNOT HAVE A CORE SHROUD.ALL HOLDERS OF OLs FORBOILING WATER REACTORSEXCEPT BIG ROCK POINTALL HOLDERS OF OLs FORNPRsALL HOLDERS OF OLs OR CPsFOR NPRs94-0294-0186-10,SUPP. 1OL -OPERATING LICENSECP = CONSTRUCTION PERMITNPR -NUCLEAR POWER REACTORS | |||
st o'Hf Recently Issued NRC Generic Letters AttachmentGL 95-01January 26, 1995 LIST OF RECENTLY ISSUED NRC GENERIC LETTERSGenericI _44-Date ofT c en is neC..k 4-4LTeciiad TnLC l.e tUUIl v ;F %4§ ak Luau .94-0494-03VOLUNTARY REPORTING OFADDITIONAL OCCUPATIONALRADIATION EXPOSURE DATAINTERGRANULAR STRESSCORROSION CRACKING OF CORESHROUDS IN BOILING WATERLONG-TERM SOLUTIONS ANDUPGRADE OF INTERIMOPERATING RECOMMENDATIONSFOR THERMAL-HYDRAULICINSTABILITIES IN BOILINGWATER REACTORSREMOVAL OF ACCELERATEDTESTING AND SPECIAL RE-PORTING REQUIREMENTS FOREMERGENCY DIESEL GENERATORSFIRE ENDURANCE TESTACCEPTANCE CRITERIA FORFIRE BARRIER SYSTEMS USEDTO SEPARATE REDUNDANTSAFE SHUTDOWN TRAINS WITHINTHE SAME FIRE AREA (SUPP. 1 TOGL 86-10, "IMPLEMENTATION OFFIRE PROTECTION REQUIREMENTS")09/02/9407/22/9407/11/9405/31/9403/25/94ALL HOLDERS OF OLs OR CPsFOR NPRs, RADIOGRAPHYLICENSEES, FUEL PROCES-SING LICENSEES, FABRICA-TING & REPROCESSINGLICENSEES, MANUFACTURERS& DISTRIBUTORS OF BY-PRODUCT MAT'L, INDEPEND-DENT SPENT FUEL STORAGEINSTALLATIONS, FACILITIESFOR LAND DISPOSAL OF LOW-LEVEL WASTE, & GEOLOGICREPOSITORIES FOR HIGH-LEVEL WASTE.ALL HOLDERS OF OLs OR CPsFOR BOILING WATERREACTORS EXCEPT FOR BIGROCK POINT, WHICH DOESNOT HAVE A CORE SHROUD.ALL HOLDERS OF OLs FORBOILING WATER REACTORSEXCEPT BIG ROCK POINTALL HOLDERS OF OLs FORNPRsALL HOLDERS OF OLs OR CPsFOR NPRs94-0294-0186-10,SUPP. 1OL -OPERATING LICENSECP = CONSTRUCTION PERMITNPR -NUCLEAR POWER REACTORS GENERIC LETTER 95-01ACTION | GENERIC LETTER 95-01ACTION | ||
==ADDRESSEES== | ==ADDRESSEES== | ||
Mr. M. 0. Kosmider, Plant ManagerAllied-Signal, Inc.P.O. Box 430Metropolis, IL 62960Mr. Arne F. Olsen, Licensing OfficerBabcock & Wilcox CompanyNaval Nuclear Fuel DivisionP.O. Box 785Lynchburg, VA 24505-0785Ms. Kathryn S. KnappManager, Safety and LicensingB&W Fuel CompanyCommercial Nuclear Fuel PlantP.O. Box 11646Lynchburg, VA 24506-1646Docket 40-3392Docket 70-27Docket 70-1201Mr. Robert W. Sharkey, ManagerRegulatory ComplianceCombustion Engineering, Inc.Hematite Nuclear Fuel Manufacturing3300 State Road PHematite, Missouri 63047Mr. John F. Conant, Facilities ManagerCombustion Engineering, Inc.Windsor Nuclear Fuel Manufacturing1000 Prospect Hill RoadWindsor, CT 06095-0500Mr. Keith E. Asmussen, DirectorLicensing, Safety, andNuclear ComplianceGeneral AtomicsP.O. Box 85608San Diego, CA 92186-9784Docket 70-36Docket 70-1100Docket 70-734 Mr. James F. Klapproth, ManagerFuels and Facilities LicensingGeneral Electric CompanyNuclear Energy ProductionP.O. Box 780, MC J26Wilmington, NC 28402Docket 70-1113Mr. Andrew M. MaxinActing Vice PresidentSafety and Regulatory ManagementNuclear Fuel Services, Inc.P.O. Box 337, MS 123Erwin, TN 37650-9718Docket 70-143Docket 70-1257Mr. L. J. Maas, ManagerRegulatory ComplianceSiemens Power Corporation2101 Horn Rapids RoadRichland, WA 99352-0130Mr. Robert A. Williams, Project ManagerWestinghouse Electric CorporationDrawer RColumbia, SC 29250Docket 70-1151 GL 95-01January 26, 1995 | Mr. M. 0. Kosmider, Plant ManagerAllied-Signal, Inc.P.O. Box 430Metropolis, IL 62960Mr. Arne F. Olsen, Licensing OfficerBabcock & Wilcox CompanyNaval Nuclear Fuel DivisionP.O. Box 785Lynchburg, VA 24505-0785Ms. Kathryn S. KnappManager, Safety and LicensingB&W Fuel CompanyCommercial Nuclear Fuel PlantP.O. Box 11646Lynchburg, VA 24506-1646Docket 40-3392Docket 70-27Docket 70-1201Mr. Robert W. Sharkey, ManagerRegulatory ComplianceCombustion Engineering, Inc.Hematite Nuclear Fuel Manufacturing3300 State Road PHematite, Missouri 63047Mr. John F. Conant, Facilities ManagerCombustion Engineering, Inc.Windsor Nuclear Fuel Manufacturing1000 Prospect Hill RoadWindsor, CT 06095-0500Mr. Keith E. Asmussen, DirectorLicensing, Safety, andNuclear ComplianceGeneral AtomicsP.O. Box 85608San Diego, CA 92186-9784Docket 70-36Docket 70-1100Docket 70-734 Mr. James F. Klapproth, ManagerFuels and Facilities LicensingGeneral Electric CompanyNuclear Energy ProductionP.O. Box 780, MC J26Wilmington, NC 28402Docket 70-1113Mr. Andrew M. MaxinActing Vice PresidentSafety and Regulatory ManagementNuclear Fuel Services, Inc.P.O. Box 337, MS 123Erwin, TN 37650-9718Docket 70-143Docket 70-1257Mr. L. J. Maas, ManagerRegulatory ComplianceSiemens Power Corporation2101 Horn Rapids RoadRichland, WA 99352-0130Mr. Robert A. Williams, Project ManagerWestinghouse Electric CorporationDrawer RColumbia, SC 29250Docket 70-1151 GL 95-01January 26, 1995 re = nu Our I | ||
GL 95-XXJanuary XX, 1995 GL 94-XXDecember XX, 1994 GL 94-XXDecember XX, 1994 n = nu sureI | |||
AttachmentGL 95-01January 26, 1995 I Tev nr nrfruTIv TecIIpF UDrCFNFRjr IETTFRSL14l Yu nIvLuLn I hv; An I ~ zz" -._,GenericDate ofTI---lTecur&A TnLetter SUDject ImUaITC -94-0494-0394-0294-0186-10,SUPP. 1VOLUNTARY REPORTING OFADDITIONAL OCCUPATIONALRADIATION EXPOSURE DATAINTERGRANULAR STRESSCORROSION CRACKING OF CORESHROUDS IN BOILING WATERLONG-TERM SOLUTIONS ANDUPGRADE OF INTERIMOPERATING RECOMMENDATIONSFOR THERMAL-HYDRAULICINSTABILITIES IN BOILINGWATER REACTORSREMOVAL OF ACCELERATEDTESTING AND SPECIAL RE-PORTING REQUIREMENTS FOREMERGENCY DIESEL GENERATORSFIRE ENDURANCE TESTACCEPTANCE CRITERIA FORFIRE BARRIER SYSTEMS USEDTO SEPARATE REDUNDANTSAFE SHUTDOWN TRAINS WITHINTHE SAME FIRE AREA (SUPP. I TOGL 86-10, "IMPLEMENTATION OFFIRE PROTECTION REQUIREMENTS-)09/02/9407/22/9407/11/9405/31/9403/25/94ALL HOLDERS OF OLs OR CPsFOR NPRs, RADIOGRAPHYLICENSEES, FUEL PROCES-SING LICENSEES, FABRICA-TING & REPROCESSINGLICENSEES, MANUFACTURERS& DISTRIBUTORS OF BY-PRODUCT MAT'L, INDEPEND-DENT SPENT FUEL STORAGEINSTALLATIONS, FACILITIESFOR LAND DISPOSAL OF LOW-LEVEL WASTE, & GEOLOGICREPOSITORIES FOR HIGH-LEVEL WASTE.ALL HOLDERS OF OLs OR CPsFOR BOILING WATERREACTORS EXCEPT FOR BIGROCK POINT, WHICH DOESNOT HAVE A CORE SHROUD.ALL HOLDERS OF OLs FORBOILING WATER REACTORSEXCEPT BIG ROCK POINTALL HOLDERS OF OLs FORNPRsALL HOLDERS OF OLs OR CPsFOR NPRsA. ..aN .Tr rUL =CP =NPR =UF'LAIlNU LILtNbtCONSTRUCTION PERMITNUCLEAR POWER REACTORS | |||
GENERIC LETTER 95-01ACTION | |||
==ADDRESSEES== | ==ADDRESSEES== | ||
Mr. M. D. Kosmider, Plant ManagerAllied-Signal, Inc.P.O. Box 430Metropolis, IL 62960Mr. Arne F. Olsen, Licensing OfficerBabcock & Wilcox CompanyNaval Nuclear Fuel DivisionP.O. Box 785Lynchburg, VA 24505-0785Docket 40-3392Docket 70-27Ms. Kathryn S. Knapp Docket 70-1201Manager, Safety and LicensingB&W Fuel CompanyCommercial Nuclear Fuel PlantP.O. Box 11646Lynchburg, VA 24506-1646Mr. Robert W. Sharkey, ManagerRegulatory ComplianceCombustion Engineering, Inc.Hematite Nuclear Fuel Manufacturing3300 State Road PHematite, Missouri 63047Mr. John F. Conant, Facilities ManagerCombustion Engineering, Inc.Windsor Nuclear Fuel Manufacturing1000 Prospect Hill RoadWindsor, CT 06095-0500Mr. Keith E. Asmussen, DirectorLicensing, Safety, andNuclear ComplianceGeneral AtomicsP.O. Box 85608San Diego, CA 92186-9784Docket 70-36Docket 70-1100Docket 70-734 Mr. James F. Klapproth, ManagerFuels and Facilities LicensingGeneral Electric CompanyNuclear Energy ProductionP.O. Box 780, MC J26Wilmington, NC 28402Docket 70-1113Mr. Andrew M. MaxinActing Vice PresidentSafety and Regulatory ManagementNuclear Fuel Services, Inc.P.O. Box 337, MS 123Erwin, TN 37650-9718Docket 70-143Mr. L. J. Maas, ManagerRegulatory ComplianceSiemens Power Corporation2101 Horn Rapids RoadRichland, WA 99352-0130Docket 70-1257Mr. Robert A. Williams, Project ManagerWestinghouse Electric CorporationDrawer RColumbia, SC 29250Docket 70-1151}} | Mr. M. D. Kosmider, Plant ManagerAllied-Signal, Inc.P.O. Box 430Metropolis, IL 62960Mr. Arne F. Olsen, Licensing OfficerBabcock & Wilcox CompanyNaval Nuclear Fuel DivisionP.O. Box 785Lynchburg, VA 24505-0785Docket 40-3392Docket 70-27Ms. Kathryn S. Knapp Docket 70-1201Manager, Safety and LicensingB&W Fuel CompanyCommercial Nuclear Fuel PlantP.O. Box 11646Lynchburg, VA 24506-1646Mr. Robert W. Sharkey, ManagerRegulatory ComplianceCombustion Engineering, Inc.Hematite Nuclear Fuel Manufacturing3300 State Road PHematite, Missouri 63047Mr. John F. Conant, Facilities ManagerCombustion Engineering, Inc.Windsor Nuclear Fuel Manufacturing1000 Prospect Hill RoadWindsor, CT 06095-0500Mr. Keith E. Asmussen, DirectorLicensing, Safety, andNuclear ComplianceGeneral AtomicsP.O. Box 85608San Diego, CA 92186-9784Docket 70-36Docket 70-1100Docket 70-734 Mr. James F. Klapproth, ManagerFuels and Facilities LicensingGeneral Electric CompanyNuclear Energy ProductionP.O. Box 780, MC J26Wilmington, NC 28402Docket 70-1113Mr. Andrew M. MaxinActing Vice PresidentSafety and Regulatory ManagementNuclear Fuel Services, Inc.P.O. Box 337, MS 123Erwin, TN 37650-9718Docket 70-143Mr. L. J. Maas, ManagerRegulatory ComplianceSiemens Power Corporation2101 Horn Rapids RoadRichland, WA 99352-0130Docket 70-1257Mr. Robert A. Williams, Project ManagerWestinghouse Electric CorporationDrawer RColumbia, SC 29250Docket 70-1151 | ||
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Revision as of 18:21, 6 April 2018
UNITED STATESNUCLEAR REGULATORY COMMISSIONOFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDSWASHINGTON, DC 20555January 26, 1995NRC GENERIC LETTER 95-01: NRC STAFF TECHNICAL POSITION ON FIRE PROTECTION FORFUEL CYCLE FACILITIES
Addressees
All current licensees and applicants for uranium conversion and fuelfabrication facilities.
Purpose
The U.S. Nuclear Regulatory Commission is issuing this generic letter tonotify addressees about the need to implement a Fire Hazard Analysis and aPre-Fire Plan and require that all addressees provide the NRC a writtenresponse to this generic letter.BackgroundSection 70.22, Contents of Application, and Section 70.23, Requirements forthe Approval of Applications, of 10 CFR Part 70 require that equipment,facilities, and procedures that will be used by a licensee be adequate toprotect health and minimize danger to life or property. Similar requirementsare found in Part 40. After a January 1986 accident at Sequoyah FuelsCorporation's uranium hexafluoride conversion facility, the NRC formed aMaterials Safety Regulation Review Study Group (MSRRSG), which was tasked toreview the agency's licensing and regulatory program and recommend measures tostrengthen areas of weakness. One such area identified by the MSRRSG was fireprotection. On March 21, 1989, the NRC published in the Federal Register (54FR 11590-98) guidance to applicants and licensees for the preparation oflicense applications and conduct of operations. Public comments wererequested on the guidance, which was in the form of four draft TechnicalPositions in the areas of Management Controls/Quality Assurance, Requirementsfor Operation, Chemical Safety, and Fire Protection for Fuel Cycle Facilities.After consideration of the comments received and the experience gained inusing these draft Technical Positions, the NRC then revised and reissued theTechnical Position (TP) on Fire Protection for Fuel Cycle Facilities in theFederal Register (57 FR 35607-13) dated August 10, 1992.Apart from providing guidance on good industry practices and standards forbuildings, equipment, maintenance, and training, the TP introduced the conceptof a Fire Hazard Analysis (FHA) to identify deficiencies in the fireprotection program of a facility. It described FHA as a systematic study ofeach "fire area' of the facility, and of the facility as a whole, in order to9D50 120 o03 1 94ot M9501200194//z1Rr OAN
GL 95-01January 26, 1995 identify and quantify all credible fire hazards that could affect thecontainment and safety of licensed radioactive materials, so that adequatecontrols can be provided to reduce those risks to acceptable levels. The TPalso stressed the importance of the Pre-Fire Plan to the preparedness of thefacility to meet all credible fire emergencies.On May 29, 1991, a potential criticality incident that developed at theGeneral Electric Nuclear Fuel and Component Manufacturing Facility (see NUREG-1450) once again raised generic safety concerns regarding the operation oflarge materials facilities. The NRC established a Materials Regulatory ReviewTask Force (MRRTF), which recommended a number of regulatory measures. Theconcept of an Integrated Safety Analysis (ISA) for the facilities, of whichFHA would be an integral part, was developed from those recommendations.Pursuant to the MRRTF report (NUREG-1324), the agency started work on arevision of the 10 CFR Part 70 rule, which is ongoing. The fuel cycleindustry has been consulted and informed of the agency's plan.DiscussionWhile neither of the two incidents cited above involved a fire, fire wasrecognized as a notable hazard at the conclusion of each review. Largequantities of flammable materials needed for the processes are stored at thesefacilities. Some of the fuel manufacturing processes themselves involve firerisk. While such risks cannot be completely eliminated, they should beminimized. The TP on fire protection provides guidance on ways to minimizesuch risks from fire.Inside facility buildings, fire hazard exists not only in the various fuelmanufacturing processes, but also in construction materials, equipment,maintenance operations, and storage and transfer of combustible materials. Itis important to safety to know what fire protection equipment is appropriatefor a given application. The FHA is the tool that enables such importantsafety-related decisions. It forms the basis for effective fire protectionmeasures that reduce accident risk and enhance safety.The TP advises that the facilities should have Pre-Fire Plans. A Pre-FirePlan contains information to assist a fire fighting team in an actualemergency situation. It is recommended that the plan be prepared inconsultation with the local fire department, where such offsite assistance isrelied upon. The importance to safety of a Pre-Fire Plan cannot be over-emphasized. The fire fighters' ability to promptly locate ordinary installedhardware, such as a compatible connection for delivery of water or a sectionalvalve, may be critical in an emergency situation. The purpose of a Pre-FirePlan is to provide exactly such information. The Pre-Fire Plan should also bea training tool for both the facility's emergency response team and theoffsite fire department that is expected to assist the facility in anemergency.
GL 95-01January 26, 1995 Reguested ActionPursuant to 10 CFR 40.31(b) or 70.22(d), as appropriate, each addressee shallprepare a statement on how it will implement the guidance of Position 9, FireHazard Analysis, and Position 10, Pre-Fire Plan, of the Technical Position onFire Protection for Fuel Cycle Facilities, published in the Federal Register(57 FR 35607-13) dated August 10, 1992.Reauired ResponseWithin 30 days from the date of this generic letter, each addressee shallsubmit a complete statement on how it will implement the referenced guidance.Please address the required written statement signed by a responsible officerto the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk,Washington, DC 20555. In addition, please submit a copy to the appropriateRegional Administrator.Related Generic CommunicationsNRC Information Notice 92-14, "Uranium Oxide Fires at Fuel Cycle Facilities,"issued February 21, 1992.PaDerwork Reduction Act StatementThe statement is covered by the Office of Management and Budget clearancenumbers 3150-0020 (10 CFR 40.8) and 3150-0009 (10 CFR 70.8). The estimatedaverage number of burden hours to comply with the reporting request is 40person-hours per licensee response, including those needed to assess the newrecommendations, search data sources, gather and analyze the data, and preparethe required response. This estimate of the average number of burden hourspertains only to the identified response and not to the time needed toimplement any actions discussed in the responses. Send comments regardingthis burden estimate or any other aspect of this collection of information,including suggestions for reducing this burden, to the Information and RecordsManagement Branch, Division of Information Support Services, Office of GL 95-01January 26, 1995 Information Resources Management, U.S. Nuclear Regulatory Commission,Washington, DC 20555, and to the Paperwork Reduction Project (3150-0020 and3150-0009), Office of Information and Regulatory Affairs, NEOB-3019, Office ofManagement and Budget, Washington, DC 20503.If you have any questions about this matter, please contact the technicalcontact listed below or the appropriate regional office.Robert F. Burnett, DirectorDivision of Fuel Cycle Safetyand SafeguardsOffice of Nuclear Material Safetyand SafeguardsTechnical contact: A. Datta, NMSS301-415-8109Attachment: st o'Hf Recently Issued NRC Generic Letters AttachmentGL 95-01January 26, 1995 LIST OF RECENTLY ISSUED NRC GENERIC LETTERSGenericI _44-Date ofT c en is neC..k 4-4LTeciiad TnLC l.e tUUIl v ;F %4§ ak Luau .94-0494-03VOLUNTARY REPORTING OFADDITIONAL OCCUPATIONALRADIATION EXPOSURE DATAINTERGRANULAR STRESSCORROSION CRACKING OF CORESHROUDS IN BOILING WATERLONG-TERM SOLUTIONS ANDUPGRADE OF INTERIMOPERATING RECOMMENDATIONSFOR THERMAL-HYDRAULICINSTABILITIES IN BOILINGWATER REACTORSREMOVAL OF ACCELERATEDTESTING AND SPECIAL RE-PORTING REQUIREMENTS FOREMERGENCY DIESEL GENERATORSFIRE ENDURANCE TESTACCEPTANCE CRITERIA FORFIRE BARRIER SYSTEMS USEDTO SEPARATE REDUNDANTSAFE SHUTDOWN TRAINS WITHINTHE SAME FIRE AREA (SUPP. 1 TOGL 86-10, "IMPLEMENTATION OFFIRE PROTECTION REQUIREMENTS")09/02/9407/22/9407/11/9405/31/9403/25/94ALL HOLDERS OF OLs OR CPsFOR NPRs, RADIOGRAPHYLICENSEES, FUEL PROCES-SING LICENSEES, FABRICA-TING & REPROCESSINGLICENSEES, MANUFACTURERS& DISTRIBUTORS OF BY-PRODUCT MAT'L, INDEPEND-DENT SPENT FUEL STORAGEINSTALLATIONS, FACILITIESFOR LAND DISPOSAL OF LOW-LEVEL WASTE, & GEOLOGICREPOSITORIES FOR HIGH-LEVEL WASTE.ALL HOLDERS OF OLs OR CPsFOR BOILING WATERREACTORS EXCEPT FOR BIGROCK POINT, WHICH DOESNOT HAVE A CORE SHROUD.ALL HOLDERS OF OLs FORBOILING WATER REACTORSEXCEPT BIG ROCK POINTALL HOLDERS OF OLs FORNPRsALL HOLDERS OF OLs OR CPsFOR NPRs94-0294-0186-10,SUPP. 1OL -OPERATING LICENSECP = CONSTRUCTION PERMITNPR -NUCLEAR POWER REACTORS
GENERIC LETTER 95-01ACTION
ADDRESSEES
Mr. M. 0. Kosmider, Plant ManagerAllied-Signal, Inc.P.O. Box 430Metropolis, IL 62960Mr. Arne F. Olsen, Licensing OfficerBabcock & Wilcox CompanyNaval Nuclear Fuel DivisionP.O. Box 785Lynchburg, VA 24505-0785Ms. Kathryn S. KnappManager, Safety and LicensingB&W Fuel CompanyCommercial Nuclear Fuel PlantP.O. Box 11646Lynchburg, VA 24506-1646Docket 40-3392Docket 70-27Docket 70-1201Mr. Robert W. Sharkey, ManagerRegulatory ComplianceCombustion Engineering, Inc.Hematite Nuclear Fuel Manufacturing3300 State Road PHematite, Missouri 63047Mr. John F. Conant, Facilities ManagerCombustion Engineering, Inc.Windsor Nuclear Fuel Manufacturing1000 Prospect Hill RoadWindsor, CT 06095-0500Mr. Keith E. Asmussen, DirectorLicensing, Safety, andNuclear ComplianceGeneral AtomicsP.O. Box 85608San Diego, CA 92186-9784Docket 70-36Docket 70-1100Docket 70-734 Mr. James F. Klapproth, ManagerFuels and Facilities LicensingGeneral Electric CompanyNuclear Energy ProductionP.O. Box 780, MC J26Wilmington, NC 28402Docket 70-1113Mr. Andrew M. MaxinActing Vice PresidentSafety and Regulatory ManagementNuclear Fuel Services, Inc.P.O. Box 337, MS 123Erwin, TN 37650-9718Docket 70-143Docket 70-1257Mr. L. J. Maas, ManagerRegulatory ComplianceSiemens Power Corporation2101 Horn Rapids RoadRichland, WA 99352-0130Mr. Robert A. Williams, Project ManagerWestinghouse Electric CorporationDrawer RColumbia, SC 29250Docket 70-1151 GL 95-01January 26, 1995 re = nu Our I
GL 95-XXJanuary XX, 1995 GL 94-XXDecember XX, 1994 GL 94-XXDecember XX, 1994 n = nu sureI
AttachmentGL 95-01January 26, 1995 I Tev nr nrfruTIv TecIIpF UDrCFNFRjr IETTFRSL14l Yu nIvLuLn I hv; An I ~ zz" -._,GenericDate ofTI---lTecur&A TnLetter SUDject ImUaITC -94-0494-0394-0294-0186-10,SUPP. 1VOLUNTARY REPORTING OFADDITIONAL OCCUPATIONALRADIATION EXPOSURE DATAINTERGRANULAR STRESSCORROSION CRACKING OF CORESHROUDS IN BOILING WATERLONG-TERM SOLUTIONS ANDUPGRADE OF INTERIMOPERATING RECOMMENDATIONSFOR THERMAL-HYDRAULICINSTABILITIES IN BOILINGWATER REACTORSREMOVAL OF ACCELERATEDTESTING AND SPECIAL RE-PORTING REQUIREMENTS FOREMERGENCY DIESEL GENERATORSFIRE ENDURANCE TESTACCEPTANCE CRITERIA FORFIRE BARRIER SYSTEMS USEDTO SEPARATE REDUNDANTSAFE SHUTDOWN TRAINS WITHINTHE SAME FIRE AREA (SUPP. I TOGL 86-10, "IMPLEMENTATION OFFIRE PROTECTION REQUIREMENTS-)09/02/9407/22/9407/11/9405/31/9403/25/94ALL HOLDERS OF OLs OR CPsFOR NPRs, RADIOGRAPHYLICENSEES, FUEL PROCES-SING LICENSEES, FABRICA-TING & REPROCESSINGLICENSEES, MANUFACTURERS& DISTRIBUTORS OF BY-PRODUCT MAT'L, INDEPEND-DENT SPENT FUEL STORAGEINSTALLATIONS, FACILITIESFOR LAND DISPOSAL OF LOW-LEVEL WASTE, & GEOLOGICREPOSITORIES FOR HIGH-LEVEL WASTE.ALL HOLDERS OF OLs OR CPsFOR BOILING WATERREACTORS EXCEPT FOR BIGROCK POINT, WHICH DOESNOT HAVE A CORE SHROUD.ALL HOLDERS OF OLs FORBOILING WATER REACTORSEXCEPT BIG ROCK POINTALL HOLDERS OF OLs FORNPRsALL HOLDERS OF OLs OR CPsFOR NPRsA. ..aN .Tr rUL =CP =NPR =UF'LAIlNU LILtNbtCONSTRUCTION PERMITNUCLEAR POWER REACTORS
GENERIC LETTER 95-01ACTION
ADDRESSEES
Mr. M. D. Kosmider, Plant ManagerAllied-Signal, Inc.P.O. Box 430Metropolis, IL 62960Mr. Arne F. Olsen, Licensing OfficerBabcock & Wilcox CompanyNaval Nuclear Fuel DivisionP.O. Box 785Lynchburg, VA 24505-0785Docket 40-3392Docket 70-27Ms. Kathryn S. Knapp Docket 70-1201Manager, Safety and LicensingB&W Fuel CompanyCommercial Nuclear Fuel PlantP.O. Box 11646Lynchburg, VA 24506-1646Mr. Robert W. Sharkey, ManagerRegulatory ComplianceCombustion Engineering, Inc.Hematite Nuclear Fuel Manufacturing3300 State Road PHematite, Missouri 63047Mr. John F. Conant, Facilities ManagerCombustion Engineering, Inc.Windsor Nuclear Fuel Manufacturing1000 Prospect Hill RoadWindsor, CT 06095-0500Mr. Keith E. Asmussen, DirectorLicensing, Safety, andNuclear ComplianceGeneral AtomicsP.O. Box 85608San Diego, CA 92186-9784Docket 70-36Docket 70-1100Docket 70-734 Mr. James F. Klapproth, ManagerFuels and Facilities LicensingGeneral Electric CompanyNuclear Energy ProductionP.O. Box 780, MC J26Wilmington, NC 28402Docket 70-1113Mr. Andrew M. MaxinActing Vice PresidentSafety and Regulatory ManagementNuclear Fuel Services, Inc.P.O. Box 337, MS 123Erwin, TN 37650-9718Docket 70-143Mr. L. J. Maas, ManagerRegulatory ComplianceSiemens Power Corporation2101 Horn Rapids RoadRichland, WA 99352-0130Docket 70-1257Mr. Robert A. Williams, Project ManagerWestinghouse Electric CorporationDrawer RColumbia, SC 29250Docket 70-1151