ML20246J799

Insp Rept 70-1113/89-03 on 890327-31.No Violations or Deviations Noted.Major Areas Inspected:Previously Identified Fire Protection/Prevention Program Findings from Oct 1986 Operational Safety Assessment Insp

ML20246J799
Person / Time
Site:	07001113
Issue date:	05/04/1989
From:	Mcalpine E, Ward D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20246J774	List: ML20246J768 ML20246J799
References
70-1113-89-03, 70-1113-89-3, NUDOCS 8905170175
Download: ML20246J799 (10)

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UNITED STATES d'; ,

[ pit Rf ouq'o NUCLEAR REGULATORY COMMISSION a

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s nf Report No.: 70-1113/89-03 Licensee: General Electric Company Wilmington, NC 28401 Docket No.: 70-1113 License No.: SNM-1097 Facility Name: General Electric Company Inspection Conducted: March 27-31, 1989 Inspector:

D. C. Ward ~

N/ di/I ~

6/ /b Date Signed Accompanying Personnel: A. Datta, Nb S-HQ Approved by: FjffG c% 5/4-/E 9 E. McAlpine, Chief \

Date Signed Material Control and Accountability Section Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards

SUMMARY

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Scope: This routine, announced inspection was in the areas of review of l previously identified fire prevention / protection program findings

! from the October 1986 Operational Safety Assessment Inspection.

l-Results: In the areas inspected, violations or deviations were not identified.

l The licensee has implemented a number of corrective actions to l address the recommendations described in the Operational Safety Assessment Inspection report. In all cases, for the items reviewed, l

the licensee has established a position regarding each item and

! followed through with the corrective action. However, in many cases l the licensee has established positions which take exception to the NRC recommendations.

The weaknesses and areas needing improvement identified in the Operational Safety Assessment regarding the onsite firefighting capability are the recommendations which the licensee has taken exception to. The licensee has established the position that the site fire team, Emergency Response Team (ERT), will only be trained and equipped to fight fires in their incipient stages. Any' fire growing out of the incipient stage would require assistance from the local fire department. The licensee has not provided training, 8905170170 890508 PTiR ADOCK 07001113 C PDC

2 recommended in the Operational Safety Assessment Inspection report.

The inspector does not necessarily agree with the licensee's position; however, the NRC has not provided any ' guidance regarding training, manning and equipping of fire brigades for this type of facility. Therefore, these items have been closed in this report for records keeping purposes only and the program may be reevaluated upon issuance of guidance by the NRC.

The licensee's response to the remaining items reviewed by the inspector were found to be complete and based on sound fire protection judgement.

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! LEPORT DETAILS j

l 1. Persons Contacted Licensee Employees

! *J. A. Bergman, Acting Plant Manager

• G. M. Bowman, Senior Program Manager, Nuclear Safety Engineering

• J. H. Bradberry, Program Manager, Security and Emergency Preparedness

• R. J. Bragg, Full Manufacture Engineer i

• L. A. Divons, Manager, Chemical Manufacture

• G. L. Fring, Senior Facility Engineer, Facilities

• R. H. Foleck, Senior Specialist, Licensing Engineering l

• P. D. Godwin, Fire Safety and Property Protection '

• R. J. Keenan, Nuclear Safety Engineer 1

• G. A. Kendall, Manager, Technology and Automation

• W. C. Peters, Manager, FM0 Maintenance

• H. R. Strickland, Senior Program Manager, Environmental Protection and Industrial Safety

• C. M. Vaughan, Manager, Regulatory Compliance

• P. Winslow, Manager, Licensing and Nuclear Material Management Other licensee employees contacted during this inspection included craftsmen, engineers, operators, mechanics, security force members, technicians, and administrative personnel.

• Attended exit interview

2. Fire Protection Program Implementation During this inspection the licensee's implementation of the administrative controls associated with the fire prevention program were reviewed. The licensee's control of combustibles within the facility appeared adequate.

The inspector verified that weekly fire prevention inspections for 1989 had been conducted as required.

The implementation of the program for controlling ignition sources on site j was also reviewed. Procedure Number 503, Cutting and Welding Permits, i Revision 3 governs the implementation of this program. The inspector reviewed approximately fifty cutting and welding permits issued under this procedure. Of these fifty nearly 100 percent were not being properly j completed. These permits did not document the pre and post work area inspections as required by the procedure. Discussions with facility personnel, indicated that these inspections were being performed but not documented. Based on this finding it does not appear the ignition source control program is being adequately implemented. In addition, the licensee has not implemented a requalification training program for ignition source fire watches and was unable to produce documentation of required training for fire watches. The lack of documentation appeared to l

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2 be the result of a recent change from one site contractor to a new one. l However, based on these observations, Inspector Followup Item 89-03-01, Implementation of the Ignition Source Control Program, is being opened.

The inspector also reviewed the Periodic Maintenance (PM) instructions for conducting maintenance, testing and inspections of i fire protection systems against the guidance provided in NFPA codes. 'l The inspector found that in many cases the licensee had not developed j procedures for the testing recommended by the NFPA codes. The I following are two examples: )

NFPA 20, Centrifugal Fire Pumps, Section 11-3 states an annual q fire pump performance test shall be conducted. The licensee  !

does not presently have a procedure to implement this test. I Instead the licensee relies on their issuance carrier, Factory '

Mutual, to conduct this test. However, the inspector found that in 1987 Factory Mutual did not conduct the annual pump test.  ;

The licensee does not presently have a program to insure the l pump is tested annually and following maintenar.ce. I NFPA 12A, Halon 1301 Fire Extinguishing System, Section 1-11 requires semiannual and annual inspection of Salon fire suppression systems. In March of 1988, the licensee issued a purchase order (P0) to a vendor to service and inspect the UPMP halon system. However, this PO was only for 1988 and the licensee could not provide the inspector with documentation that additional inspections were planned. The licensee had not developed a facility procedure to address the inspection requirements of NFPA 12A.

In addition, some procedures which had been developed did not cover all the inspection points required by the NFPA codes. Also data recommended to be recorded by the NFPA codes was not documented. The annual fire hose station and fire hydrant inspections are examples of this findings.

Based on these observations, it appears that the program for maintenance, testing and inspection of fire protection systems and equipment is a program weakness. The inspector emphasized the need ,

for improvement in this area in the exit meeting with facility j management. The licensee should reevaluate this portion of the l program against the NFPA code requirements and make the necessary i improvements. The licensee has taken corrective action to issue periodic maintenance instructions to provide for the maintenance, testing and inspection of fire protection systems and equipment.

This identified Inspector Followup Item 89-03-02, Reevaluate maintenance, Testing and Inspection Program for Fire Systems.

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3. Review of Operational Safety Assessment Findings.(92701)

An Operational Safety Assessment was conducted by the NRC at the licensee's facility in October 1986. Findings of the assessment were reported in Inspection Report 70-1113/86-22. By letter dated April 29, 1987, the licensee responded to the assessment findings and described the corrective action being taken on the identified weakness and improvement items.

During this inspection, the corrective action in response to the following items was reviewed:

a. (Closed) 86-22-08, Controlling the use of non-fire retardant wood in the uranium process area. The use of non-fire retardant wood in process related areas was identified as an area needing improvement.

The licensee's Manager of Fuel Production issued a memo to the Manager of Plant Engineering and Maintenance on July 8,1987, stating that only Exterior Fire Ex Blue, fire retardant, type wood is to be used in controlled areas. During this inspection, the implementation of this directive was reviewed during plant tours. The inspector did not note any significant deviations from this policy.

b. (Closed) 86-22-13, Lack of specification of qualifications and assignment of responsibility for fire protection personnel. During the Operational Safety Assessment a weakness was identified due to the licensee not having established the qualifications and responsibilities for fire protection personnel.

The licensee provided the inspector with the a position description for Job Code 1555, Fire Safety and Property Protection Operator.

This position description clearly states the qualification requirements and responsibilities for the position which implements the fire prevention / control program. The qualifi:ation requirements for this position include knowledge of National Fire Protection Association (NFPA) codes, background in fire fighting, knowledge of fire protection equipment and systems and ability as a fire protection instructor / trainer. The responsibilities of this position include conducting weekly and monthly fire prevention and fire protection system inspections and maintenance, Emergency Response Team (ERT) incipient fire fighting training, and other fire protection administrative responsibilities. The individual presently assigned to this position appears to have the knowledge and qualifications to fulfill this position description,

c. (Closed) 86-22-14, Inadequacies in the fire protection maintenance, testing and inspection program. The lack of an adequate maintenance, testing and inspection program for the fire protection systems and equipment at the facility was identified as a program weakness. The licencee has taken corrective action to issue periodic maintenance, testing and inspection of fire protection systems and equipment.

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d. (Closed). 86-22-15, Maintaining an adequate number of fire brigade members on each production shift. This item was identified as . an  !

improvement item during the Operational Safety Assessment due to the minimum Emergency Response Team (ERT) of seven people not being maintained on site. The requirement for seven ERT members was documented in the licensee"s Plant Emergency Organization - Fire Brigade Training Manual.

Subsequently, the licensee has revised this manual into the Emergency Response Team Training Manual. The revised manual no longer states

, that seven ERT members are required. In addition, the licensee has taken the position that the ERT will only be trained to fight fires  !

in their incipient stages. The ERI is not trained or equipped to fight fires inside structures which have grown beyond the incipient i stages. The local fire department, Castle Hayne Volunteer, would be called for a fire of any significance size. Therefore, the licensee's program presently dose not identify a minimum number of ERT members; however, the ERT is routinely manned by no less than then four members.

In the Operational Safety Assessment report, the NRC suggested that  ;

the minimum ERT size he five members and that these members receive  !

additional training. The licensee has taken exception to this recommendation and the NRC has not issued guidance in this area.

Therefore, this item is closed for records keeping purposes.

e. (Closed) 86-22-18, Develop fire emergency plans which provide fire fighting guidance to the fire brigade for various process areas. The licensee had not developed facility pre-fire plans. Therefore, this was identified as an area needing improvement.

The licensee has elected to not develop detailed pre-fire plans as described in the Operational Safety Assessment report. Instead the, ERT discusses potential fire hazards in the facility during the quarterly training. These discussions are not formalized in a lesson plan; however, the inspector attended quarterly training and verified the training included this information. The licensee's position is that detailed pre-fire plans are not required for the ERT since they are trained only to fight incipient fires. The licensee does provide l emergency plan and hazardous materials information to the local fire department for their information in fire fighting on the plant site.

This information includes site specific drawings and the information is reviewed with the local fire departments during annual training and drills. The licensee feels this is sufficient and no f urther action is required.

In the Operational Safety Assessment report, the NRC suggested that detailed pre-fire plans be developed for the facilities process areas. The licensee has taken exception to this recommendation and the NRC has not issued guidance in this area. Therefore, this item is closed for records keeping purposes, i

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f. (Closed) 86-22-19, Failure- of the fire brigade to use proper manual fire fighting methods.. This item was identified after the site. fire

. brigade failed to properly respond to a fire drill witnessed by the inspectors.

The licensee has taken the position that the facility ERT will only be capable of responding to fires in the incipient stages. Therefore during this inspection, the inspector witnessed a drill to determine if the ERT would respond properly.

The drill scer /10 was a fire in the warehouse yard involving wooden shipping crates for fuel assemblies. Approximately fourteen ERT-members responded to .the fire scene where the fire chief. for the ERT had established a command post. Radiological and security personnel also responded to the scene to assist. The ERT members responding to the scene brought the ERT vehicle which contains Self Contained Breathing Apparatus (SCBAs), spare air bottles, fire hose, fire nozzles and other fire fighting equipment. After an initial sizeup of the fire, it was determined that the fire had. grown out of the incipient stage and that offsite assistance would be required. The request for offsite assistance was simulated and the ERT took action to lay fire hose and stage equipment in preparation for the fire departments arrival. The overall ERT performance was considered adequate for responding to incipient fires.

g. (Closed) 86-22-21, Lack of adequate manual equipment to mitigate potential site fire hazard conditions. This item'was identified during the Operational Safety Assessment when it was determined that manual = fire fighting equipment for the site fire brigade was not available in sufficient quantity or quality.

The licensee has taken the position that the site ERT will only be trained and equipped to fight fires in the incipient stages. Fires which grow out of the incipient stage will require offsite fire department assistance. However, . following the Operational Safety Assessment the licensee did purchase additional new equipment which included listed fire fighting turn out gear, variable stream nozzles, and smoke exhaust fans. This equipment is stored in.the ERT van and is inventoried periodically. The equipment provided appears adequate to support incipient fire fighting activities.

h. (Closed) 86-22-22, Discrepancies in fire protection systems relating to fire control capability. This item was identified due to the lack of adequate fire protection for materials stored outside, combustible waste storage boxes, UFs cylinders, and propane tank. See the closure of item 86-22-43 for discussion of the propane tank I protection.

The UFs cylinders are located in a fenced yard area west of the l FM0/FM0X. The yard area is paved and the only storage located in l this area is the UFs cylinders. The site fire pump house is located j just west of the yard area. Although a fire hydrant is not provided 1

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near this yard area, a fire pump test connection at the fire pump house has six 2 inch hose connections available. In addition, the licensee installed a 6 inch fire pumper connection at the fire pump house which provides suction for the local fire department pumper, should the site fire pump be inoperable. Either of these sources will provide adequate water to protect the UFc cylinder storage area.

The combustible waste storage boxes are located in yard areas at the extreme west end of the facility. A fire hydrant is not provided for this area. These boxes contain contaminated waste and are stored in this area until they can be disposed of. The storage yard is gravel which is weed free. The only exposure fire would be from a forest fire in the woods south of the yard area. A clear space of 30 feet is provided between the forest and the storage containers. The licensee's insurance carrier, Factory Mutual, reviewed this item during a 1987 site inspection and determined a fire hydrant at this location is not necessary.

The inspector concurs with the conclusion based on his observations during this inspection. In addition, should a fire occur in this area the local fire department tankers and pumper trucks could be used to extinguish the fire. Additional support would be available from the Forestry Service in the case of a forest fire.

i. (Closed) 86-22-23, Capability for offsite fire department to draft from fire water pond. This item was identified when it was determined that with a loss of the site fire pump the local fire department would not have a source of water for fire fighting.

In response to this item, the licensee generated Project Task (PT)

No. 577-87 which installed a 6" fire pumper connection, dry hydrant, to the fire pond. This will provide adequate backup to the site fire pump. The licensee also tested the dry hydrant during a site emergency drill in 1988.

j. (Closed) 86-22-24, Obstructed sprinkler heads in FM0/FM0X. A number of sprinkler heads obstructed by heating ventilation and air conditioning (HVAC) ductwork were identified during the Operational Safety Assessment.

The licensee issued PT No. 595-87 which provided sprinklers below the HVAC ducts in the northwest corner of the press room, west side of chemical area under hydrolysis platform and east side of the evaporation area in the FM0/FM0X. These modifications resolve the sprinkler head obstruct ons,

k. (Closed) 86-22-25, Sprinkler protection under the mezzanine areas near the calcination furnaces. Sprinklers are not provided under three walkways between the mezzanines above the calcination furnaces approximately 5 feet wide and 20 feet long. The area above the mezzanine is fully sprinklered and the area below the mezzanine is fully sprinklered except under the walkways. No equipment is located

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l-directly under the walkways and sprinklers are provided under the mezzanine at each end of the walkway. The licensee has taken the position that the sprinklers above and below the mezzanines provide adequate protection to the area under the walkway. The inspector concurred with this position. The installation of additional sprinklers under the walkways would not significantly enhance the fire safety in this area.

1. (Closed) 86-22-26, Heat collectors for sprinkler heads in the GEC0 process mezzanine.

The licensee installed heat collectors over all sprinkler heads under the GEC0 mezzanine grated floor,

m. (Closed) 86-22-27 and 86-22-28, FM0/FM0X 14 inch fire hose station not designed to NFPA codes and may have excessive friction loss.

In response to this finding, the licensee performed a hydraulic calculation for the most hydraulically remote 1 -inch hose outlet.

The calculation is documented in Environmental Protection and Industrial Safety memo HRS 89-51. This calculation is based c.i the need for 50 GPM flow from the hose nozzle to produce an adequate fog spray. This calculation shows that a hose connection pressure of 84.5 psi will be available. This flow and pressure is adequate for use by an incipient fire brigade,

n. (Closed) 86-22-43, Failure to have fire protection capabilities to prevent propane tank Boiling Liquid-Expanding Vapor Explosion (BLEVE) or to protect UFc cylinders. The licensee has two filled propane tanks located on the west side of the plant. During the Operational Safety Assessment the team was concerned that a propane tank fire would expose the UFc cylinders located approximately 150 feet from the tank and that should a propane tank BLEVE UFe cylinders may be heated and overpressurize or rupture. At the time of the inspection fire protection capabilities were not available to prevent the propane tank BLEVE or protect the UFs cylinders.

Subsequent to the inspection, the licensee installed a fire pumper connection for the local fire department to take suction from the fire pond just north of the propane tank area. In addition, the site fire pump has a test connection with six 2 -inch outlets which could also be used to suppress a fire at the propane tanks. These two sources of fire fighting water are also available to protect the UFs cylinders.

One propane tank is oriented north to south and the second east to west. The UFs cylinders are not located in the BLEVE line of sight, along the longitudinal axis of the tank, of either tank. The probability of a BLEVE is also low. The propane tanks are located in a cleared and fenced in area with no other storage within the area.

Therefore, there does not appear to be adequate in situ combustibles surrounding the propane tanks to create a fire large enough to induce

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a BLEVE in the large tanks. In addition, three safety relief valves are provided on each propane tank which discharge approximately

• l 10 feet above the tanks. The only probable source of a fire large l enough to induce a BLEVE in these tanks would appear to be a reloading accident when the tanks are being filled. These tanks were put in service in the late 1970's when there was the possibility of natural gas shotages at the plant. The licensee provided the, inspector with a environmental report which showed that the site's propane use since 1982 has been 0 gallons. Therefore, it appears based on the low probability of a BLEVE that the fire fighting capabilities presently provided are adequate at this time. However, should these tanks be put in service at a later date the licensee should evaluate the need for additional fire protection.

4. Exit Interview The inspection scope and results were summarized on March 31, 1989, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed below.

Although reviewed during this inspection, proprietary information is not contained in this report. Dissenting comments were not received from the licensee.

The single Inspector Followup Item identified in this report was identified to the licensee during a telephone call on April 6,1988 with Herb Strickland of General Electric.

Item Number Description and Reference 89-03-01 IFI, Implementation of the Ignition Source Control Program, Paragraph 2.

89-03-02 IFI, Reevaluate Maintenance, Testing and Inspection Program For Fire Systems, Paragraph 2.

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