NRC Generic Letter 1995-01
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, DC 20555 January 26, 1995 NRC GENERIC LETTER 95-01: NRC STAFF TECHNICAL POSITION ON FIRE PROTECTION FOR
FUEL CYCLE FACILITIES
Addressees
All current licensees and applicants for uranium conversion and fuel fabrication facilities.
Purpose
The U.S. Nuclear Regulatory Commission is issuing this generic letter to notify addressees about the need to implement a Fire Hazard Analysis and a Pre-Fire Plan and require that all addressees provide the NRC a written response to this generic letter.
Background Section 70.22, Contents of Application, and Section 70.23, Requirements for the Approval of Applications, of 10 CFR Part 70 require that equipment, facilities, and procedures that will be used by a licensee be adequate to protect health and minimize danger to life or property. Similar requirements are found in Part 40. After a January 1986 accident at Sequoyah Fuels Corporation's uranium hexafluoride conversion facility, the NRC formed a Materials Safety Regulation Review Study Group (MSRRSG), which was tasked to review the agency's licensing and regulatory program and recommend measures to strengthen areas of weakness. One such area identified by the MSRRSG was fire protection. On March 21, 1989, the NRC published in the Federal Register (54 FR 11590-98) guidance to applicants and licensees for the preparation of license applications and conduct of operations. Public comments were requested on the guidance, which was in the form of four draft Technical Positions in the areas of Management Controls/Quality Assurance, Requirements for Operation, Chemical Safety, and Fire Protection for Fuel Cycle Facilities.
After consideration of the comments received and the experience gained in using these draft Technical Positions, the NRC then revised and reissued the Technical Position (TP) on Fire Protection for Fuel Cycle Facilities in the Federal Register (57 FR 35607-13) dated August 10, 1992.
Apart from providing guidance on good industry practices and standards for buildings, equipment, maintenance, and training, the TP introduced the concept of a Fire Hazard Analysis (FHA) to identify deficiencies in the fire protection program of a facility. It described FHA as a systematic study of each "fire area' of the facility, and of the facility as a whole, in order to
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GL 95-01 January 26, 1995 identify and quantify all credible fire hazards that could affect the containment and safety of licensed radioactive materials, so that adequate controls can be provided to reduce those risks to acceptable levels. The TP
also stressed the importance of the Pre-Fire Plan to the preparedness of the facility to meet all credible fire emergencies.
On May 29, 1991, a potential criticality incident that developed at the General Electric Nuclear Fuel and Component Manufacturing Facility (see NUREG-
1450) once again raised generic safety concerns regarding the operation of large materials facilities. The NRC established a Materials Regulatory Review Task Force (MRRTF), which recommended a number of regulatory measures. The concept of an Integrated Safety Analysis (ISA) for the facilities, of which FHA would be an integral part, was developed from those recommendations.
Pursuant to the MRRTF report (NUREG-1324), the agency started work on a revision of the 10 CFR Part 70 rule, which is ongoing. The fuel cycle industry has been consulted and informed of the agency's plan.
Discussion While neither of the two incidents cited above involved a fire, fire was recognized as a notable hazard at the conclusion of each review. Large quantities of flammable materials needed for the processes are stored at these facilities. Some of the fuel manufacturing processes themselves involve fire risk. While such risks cannot be completely eliminated, they should be minimized. The TP on fire protection provides guidance on ways to minimize such risks from fire.
Inside facility buildings, fire hazard exists not only in the various fuel manufacturing processes, but also in construction materials, equipment, maintenance operations, and storage and transfer of combustible materials. It is important to safety to know what fire protection equipment is appropriate for a given application. The FHA is the tool that enables such important safety-related decisions. It forms the basis for effective fire protection measures that reduce accident risk and enhance safety.
The TP advises that the facilities should have Pre-Fire Plans. A Pre-Fire Plan contains information to assist a fire fighting team in an actual emergency situation. It is recommended that the plan be prepared in consultation with the local fire department, where such offsite assistance is relied upon. The importance to safety of a Pre-Fire Plan cannot be over- emphasized. The fire fighters' ability to promptly locate ordinary installed hardware, such as a compatible connection for delivery of water or a sectional valve, may be critical in an emergency situation. The purpose of a Pre-Fire Plan is to provide exactly such information. The Pre-Fire Plan should also be a training tool for both the facility's emergency response team and the offsite fire department that is expected to assist the facility in an emergency.
GL 95-01 January 26, 1995 Reguested Action Pursuant to 10 CFR 40.31(b) or 70.22(d), as appropriate, each addressee shall prepare a statement on how it will implement the guidance of Position 9, Fire Hazard Analysis, and Position 10, Pre-Fire Plan, of the Technical Position on Fire Protection for Fuel Cycle Facilities, published in the Federal Register
(57 FR 35607-13) dated August 10, 1992.
Reauired Response Within 30 days from the date of this generic letter, each addressee shall submit a complete statement on how it will implement the referenced guidance.
Please address the required written statement signed by a responsible officer to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555. In addition, please submit a copy to the appropriate Regional Administrator.
Related Generic Communications NRC Information Notice 92-14, "Uranium Oxide Fires at Fuel Cycle Facilities,"
issued February 21, 1992.
PaDerwork Reduction Act Statement The statement is covered by the Office of Management and Budget clearance numbers 3150-0020 (10 CFR 40.8) and 3150-0009 (10 CFR 70.8). The estimated average number of burden hours to comply with the reporting request is 40
person-hours per licensee response, including those needed to assess the new recommendations, search data sources, gather and analyze the data, and prepare the required response. This estimate of the average number of burden hours pertains only to the identified response and not to the time needed to implement any actions discussed in the responses. Send comments regarding this burden estimate or any other aspect of this collection of information, including suggestions for reducing this burden, to the Information and Records Management Branch, Division of Information Support Services, Office of
GL 95-01 January 26, 1995 Information Resources Management, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and to the Paperwork Reduction Project (3150-0020 and
3150-0009), Office of Information and Regulatory Affairs, NEOB-3019, Office of Management and Budget, Washington, DC 20503.
If you have any questions about this matter, please contact the technical contact listed below or the appropriate regional office.
Robert F. Burnett, Director Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards Technical contact: A. Datta, NMSS
301-415-8109 Attachment: Recently Issued NRC Generic Letters st o'Hf
Attachment GL 95-01 January 26, 1995 LIST OF RECENTLY ISSUED NRC GENERIC LETTERS
Generic Date of I _44- C..k 4-4L Tc en is ne. Teciiad Tn LC l.etUUIl v ;F%4§ ak Luau
94-04 VOLUNTARY REPORTING OF 09/02/94 ALL HOLDERS OF OLs OR CPs ADDITIONAL OCCUPATIONAL FOR NPRs, RADIOGRAPHY
RADIATION EXPOSURE DATA LICENSEES, FUEL PROCES-
SING LICENSEES, FABRICA-
TING & REPROCESSING
LICENSEES, MANUFACTURERS
& DISTRIBUTORS OF BY-
PRODUCT MAT'L, INDEPEND-
DENT SPENT FUEL STORAGE
INSTALLATIONS, FACILITIES
FOR LAND DISPOSAL OF LOW-
LEVEL WASTE, & GEOLOGIC
REPOSITORIES FOR HIGH-
LEVEL WASTE.
94-03 INTERGRANULAR STRESS 07/22/94 ALL HOLDERS OF OLs OR CPs CORROSION CRACKING OF CORE FOR BOILING WATER
SHROUDS IN BOILING WATER REACTORS EXCEPT FOR BIG
ROCK POINT, WHICH DOES
NOT HAVE A CORE SHROUD.
94-02 LONG-TERM SOLUTIONS AND 07/11/94 ALL HOLDERS OF OLs FOR
UPGRADE OF INTERIM BOILING WATER REACTORS
OPERATING RECOMMENDATIONS EXCEPT BIG ROCK POINT
FOR THERMAL-HYDRAULIC
INSTABILITIES IN BOILING
WATER REACTORS
94-01 REMOVAL OF ACCELERATED 05/31/94 ALL HOLDERS OF OLs FOR
TESTING AND SPECIAL RE- NPRs PORTING REQUIREMENTS FOR
86-10, FIRE ENDURANCE TEST 03/25/94 ALL HOLDERS OF OLs OR CPs SUPP. 1 ACCEPTANCE CRITERIA FOR FOR NPRs FIRE BARRIER SYSTEMS USED
TO SEPARATE REDUNDANT
SAFE SHUTDOWN TRAINS WITHIN
THE SAME FIRE AREA (SUPP. 1 TO
GL 86-10, "IMPLEMENTATION OF
FIRE PROTECTION REQUIREMENTS")
OL - OPERATING LICENSE
CP = CONSTRUCTION PERMIT
NPR - NUCLEAR POWER REACTORS
GENERIC LETTER 95-01 ACTION
ADDRESSEES
Mr. M. 0. Kosmider, Plant Manager Docket 40-3392 Allied-Signal, Inc.
P.O. Box 430
Metropolis, IL 62960
Mr. Arne F. Olsen, Licensing Officer Docket 70-27 Babcock & Wilcox Company Naval Nuclear Fuel Division P.O. Box 785 Lynchburg, VA 24505-0785 Ms. Kathryn S. Knapp Docket 70-1201 Manager, Safety and Licensing B&W Fuel Company Commercial Nuclear Fuel Plant P.O. Box 11646 Lynchburg, VA 24506-1646 Mr. Robert W. Sharkey, Manager Docket 70-36 Regulatory Compliance Combustion Engineering, Inc.
Hematite Nuclear Fuel Manufacturing
3300 State Road P
Hematite, Missouri 63047 Mr. John F. Conant, Facilities Manager Docket 70-1100
Combustion Engineering, Inc.
Windsor Nuclear Fuel Manufacturing
1000 Prospect Hill Road Windsor, CT 06095-0500
Mr. Keith E. Asmussen, Director Docket 70-734 Licensing, Safety, and Nuclear Compliance General Atomics P.O. Box 85608 San Diego, CA 92186-9784
Mr. James F. Klapproth, Manager Docket 70-1113 Fuels and Facilities Licensing General Electric Company Nuclear Energy Production P.O. Box 780, MC J26 Wilmington, NC 28402 Mr. Andrew M. Maxin Docket 70-143 Acting Vice President Safety and Regulatory Management Nuclear Fuel Services, Inc.
P.O. Box 337, MS 123 Erwin, TN 37650-9718 Mr. L. J. Maas, Manager Docket 70-1257 Regulatory Compliance Siemens Power Corporation
2101 Horn Rapids Road Richland, WA 99352-0130
Mr. Robert A. Williams, Project Manager Docket 70-1151 Westinghouse Electric Corporation Drawer R
Columbia, SC 29250
GL 95-01 January 26, 1995 Information Resources Management, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and to the Paperwork Reduction Project (3150-0020 and
3150-0009), Office of Information and Regulatory Affairs, NEOB-3019, Office of Management and Budget, Washington, DC 20503.
If you have any questions about this matter, please contact the technical contact listed below or the appropriate regional office.
Robert F. Burnett, Director Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards Technical contact: A. Datta, NMSS
301-415-8109 Attachment: List of Recently Issued NRC Generic Letters
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OFFICIAL RECORD COPY
GL 95-XX
January XX, 1995 Information Resources Management, U.S. Nuclear Regulat ry Commission, and Washington, DC 20555, and to the Paperwork Reduction roject (3150-0020 Office of
3150-0009), Office of Information and Regulatory Aff irs, NEOB-3019, Management and Budget, Washington, DC 20503.
If you have any questions about this matter, pl dse contact the technical contact listed below or the appropriate region office.
bert F. Burnett, Director ivision of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards Technical contact: A. Datta, NMSS
301-415-8109 Attachment: List of Recently Iss d NRC Generic Letters 60
[A:\generic.ad]
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NAME
- See previous concurrence FCLB* IE
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NAME ETenEyck RBurnett /
DATE 1/ /95 1/)1/95__
COVER 7E COVER & ENCLOSURE N = NO COPY
j OFFICIAL RECORD COPY
GL 94-XX
December XX, 1994 Information Resources Management, U.S. Nuclear Regula ry Commission, Washington, DC 20555, and to the Paperwork Reduction roject (3150-0020 and
3150-0009), Office of Information and Regulatory Aff irs, NEOB-3019, Office of Management and Budget, Washington, DC 20503.
If you have any questions about this matter, pl ase contact the technical contact listed below or the appropriate region office.
obert F. Burnett, Director ivision of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards Technical contact: A. Datta, N S
301-415-810
Attachment: List of Recently Issued NRC Generic Letters
[A:\generic.ad]
- See previous concurrence /_boor n OFC FB* E FCLB* E FLB* lE IE K Wm /4 IMOB l
/9 NAME Au :mh VTharpYTokar RPierson JSurmeier KRamsey DATE 2 /94 11/28/94 11/28/94 11/29/94 12/1__/94 12/ /94 12/ /94 O FC LFCSS I L
NAME ETenEyck lurn2Et DATE 12/ /94 12/ /94
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OFFICIAL RECORD COPY
GL 94-XX
December XX, 1994 Information Resources Management, U.S. Nuclear Regula ry Commission, Washington, DC 20555, and to the Paperwork Reduction roject (3150-0011),
Office of Information and Regulatory Affairs, NEOB-3 19, Office of Management and Budget, Washington, DC 20503.
If you have any questions about this matter, pleas contact the technical contact listed below or the appropriate regional ffice.
Robert F. Burnett, Director Divis on of Fuel Cycle Safety a Safeguards Off ce of Nuclear Material Safety nd Safeguards Technical contact: A. Datta, NMSS
301-415-8109 Attachment: List of Recently Issued NRC Generic Letters
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NAME A tamhV X e RP i RF JSurmeier KRamsey DATE 11/Zk/94 11/,/94 1 1//9+11/ 94 __4 11/ /94 11/ /94 OFC_ FCSS 1l 1 11 NAME ETenEyck RBurnett /
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/OFFICIAL RECORD COPY
Attachment GL 95-01 January 26, 1995 I Tev nr nrfruTIv TecIIpF UDr CFNFRjr IETTFRS
L14l Yu nIvLuLn I I hv; ~
An zz" - ._,
Generic Date of TI---l Tecur&A Tn Letter SUDject ImUaITC -
94-04 VOLUNTARY REPORTING OF 09/02/94 ALL HOLDERS OF OLs OR CPs ADDITIONAL OCCUPATIONAL FOR NPRs, RADIOGRAPHY
RADIATION EXPOSURE DATA LICENSEES, FUEL PROCES-
SING LICENSEES, FABRICA-
TING & REPROCESSING
LICENSEES, MANUFACTURERS
& DISTRIBUTORS OF BY-
PRODUCT MAT'L, INDEPEND-
DENT SPENT FUEL STORAGE
INSTALLATIONS, FACILITIES
FOR LAND DISPOSAL OF LOW-
LEVEL WASTE, & GEOLOGIC
REPOSITORIES FOR HIGH-
LEVEL WASTE.
94-03 INTERGRANULAR STRESS 07/22/94 ALL HOLDERS OF OLs OR CPs CORROSION CRACKING OF CORE FOR BOILING WATER
SHROUDS IN BOILING WATER REACTORS EXCEPT FOR BIG
ROCK POINT, WHICH DOES
NOT HAVE A CORE SHROUD.
94-02 LONG-TERM SOLUTIONS AND 07/11/94 ALL HOLDERS OF OLs FOR
UPGRADE OF INTERIM BOILING WATER REACTORS
OPERATING RECOMMENDATIONS EXCEPT BIG ROCK POINT
FOR THERMAL-HYDRAULIC
INSTABILITIES IN BOILING
WATER REACTORS
94-01 REMOVAL OF ACCELERATED 05/31/94 ALL HOLDERS OF OLs FOR
TESTING AND SPECIAL RE- NPRs PORTING REQUIREMENTS FOR
FIRE ENDURANCE TEST 03/25/94 ALL HOLDERS OF OLs OR CPs
86-10,
SUPP. 1 ACCEPTANCE CRITERIA FOR FOR NPRs FIRE BARRIER SYSTEMS USED
TO SEPARATE REDUNDANT
SAFE SHUTDOWN TRAINS WITHIN
THE SAME FIRE AREA (SUPP. I TO
GL 86-10, "IMPLEMENTATION OF
FIRE PROTECTION REQUIREMENTS-)
A. .. aN .
Tr r UL = UF'LAIlNU LILtNbt CP = CONSTRUCTION PERMIT
NPR = NUCLEAR POWER REACTORS
GENERIC LETTER 95-01 ACTION
ADDRESSEES
Mr. M. D. Kosmider, Plant Manager Docket 40-3392 Allied-Signal, Inc.
P.O. Box 430
Metropolis, IL 62960
Mr. Arne F. Olsen, Licensing Officer Docket 70-27 Babcock & Wilcox Company Naval Nuclear Fuel Division P.O. Box 785 Lynchburg, VA 24505-0785 Ms. Kathryn S. Knapp Docket 70-1201 Manager, Safety and Licensing B&W Fuel Company Commercial Nuclear Fuel Plant P.O. Box 11646 Lynchburg, VA 24506-1646 Mr. Robert W. Sharkey, Manager Docket 70-36 Regulatory Compliance Combustion Engineering, Inc.
Hematite Nuclear Fuel Manufacturing
3300 State Road P
Hematite, Missouri 63047 Mr. John F. Conant, Facilities Manager Docket 70-1100
Combustion Engineering, Inc.
Windsor Nuclear Fuel Manufacturing
1000 Prospect Hill Road Windsor, CT 06095-0500
Mr. Keith E. Asmussen, Director Docket 70-734 Licensing, Safety, and Nuclear Compliance General Atomics P.O. Box 85608 San Diego, CA 92186-9784
Mr. James F. Klapproth, Manager Docket 70-1113 Fuels and Facilities Licensing General Electric Company Nuclear Energy Production P.O. Box 780, MC J26 Wilmington, NC 28402 Mr. Andrew M. Maxin Docket 70-143 Acting Vice President Safety and Regulatory Management Nuclear Fuel Services, Inc.
P.O. Box 337, MS 123 Erwin, TN 37650-9718 Mr. L. J. Maas, Manager Docket 70-1257 Regulatory Compliance Siemens Power Corporation
2101 Horn Rapids Road Richland, WA 99352-0130
Mr. Robert A. Williams, Project Manager Docket 70-1151 Westinghouse Electric Corporation Drawer R
Columbia, SC 29250