ML19312D770
| ML19312D770 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 12/17/1979 |
| From: | Kaplan A GENERAL ELECTRIC CO. |
| To: | Sutherland J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19312D755 | List: |
| References | |
| NUDOCS 8003250315 | |
| Download: ML19312D770 (6) | |
Text
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GER ER AL h ELECTRIC nucubineRoy
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PRODUCTS DIVISinN v
WILMINGTON MANUFACTURING DEPARTMENT CASTLE HAYNE ROAD e P.O. BOX 780 e WILMINGTON. N. C. 28401 e,(919),343 5000_
I Iecember 17, 1979 Mr. J. T. Sutherland, Chief Fuel Facility & Materials Safety Branch U. S. Nuclear Regulatory Commission 101 Marietta Street, NW - Suite 3100 Atlanta, Georgia 30303
Dear Mr. Sutherland:
References:
(1) NRC Inspection Report RII:DJP, 70-1113/79-20',
dated 11/20/79 (2) NRC License SN'!-1097, Docket #70-1113 Thank you for your letter referenced above which reported the results of the inspection of our fuel fabrication plant by Mr. D. J. perrotti of your office on October 25-26, 1979, pertaining to the item of apparent noncompliance with NRC require-ments in your letter, the reply to this item is given in the attachment to this letter.
We appreciate your inspectors comments and suggestions related to our employee safety and environmental protection programs.
These comments and suggestions are helpful to us in our constant efforts to improve these programs, ensure the continued health and safety of plant personnel, and ensure our compliance with NRC regulations and license conditions.
We also welcome further discussion with your staff on the item in your letter and in our related reply, if necessary, for further clarification of this item.
Your inspection report referred to above does not contain information 4
which we believe to be proprietary.
e Very truly yours, GENERAL ELECTRIC COMPANY h
Arthur L. Kap!.an, Manager Licensing & Compliance Audits M/C J26 ALK:bmw Attachment NSD-I i
80032503;s OteFICAAL OvW
GENERAL h ELECTRIC Mr. J. T. Sutherland December 17, 1979 Attachment - Page 1 The information given below refers to the item in Appendix A,
" Notice of Violation," in the N T Inspection Report RII:DJP, 70-1113/79-20, dated 11/20/79.
ine corrective actions detailed below have already been implemen:ed or will be implemented by the dates shown.
Cnidition 13 of the Licatse, idtich incorporated the Evergency Plan as of Apt.it 22, 1979, requited.that the Emstgatcy Plan be implematted by July 30, 1979.
Table 8.2 of the Emetgatcy Plan states tliat the Emergency Director t'utining toitt consist of detailed insttuctions on.the scope, respoutsibilities and functioning of tJte Emchgency Plan and Emergency Procedures, that.the Survey Team and Re-attry Team sciLL initiaily receive Ltahting in on-siteloff-site radiological monitcring and detailed instructions on tize basic plan and Emergvicy Procedates, and tJiat.the Facilities Damage and Conttot Team initial ttaining taitt consist of a review of Emcrgatey Procedurcs.
Conttary to the above, as of July 30, 1979, seven of nhte designated Emergency Oitectors, and sixty percatt of the Survey, Rescue and Facilities Damage Conttol Team personnet had not received the initial t.raisting in.the Emergatcy Plan and Emergency Procedurcs.
This tats p.teviously identified as an wttesolved item (IE Report No. 70-1113/79-03).
This is an infraction.
This apparent item of noncompliance is related to an unresolved item identified by Mr. Perrotti in his last inspection in February 1979.
He left the item unresolved at that time because we were in the process of submitting a new emergency plan to the NRC and of imple-menting the new plan.
He felt that enough time had gone by for us to have completed initial training for all emergency personnel so designated in our plan.
We believe that the citation is unwarranted because of the following; e
We have vigorously pursued implementing a new plan and activating l
a new emergency control center, after recognizing shortcomings in our emergency preparedness, e
Our plan, procedures and emergency facilities and equipment are far in excess of regulatory requirements.
They are what we believe we need to provide a high degree of protection for and attention to personnel onsite in the event of any foreseeable emergency.
Mr. J. T. Sutherland December 17, 1979 Attachment - page 2 4
e Initial training has been completed for all personnel essential to the handling of an emergency in the fuel manufacturing area.
o Allocation of resources to complete the implementation of the new emergency plan and procedures was made based on priorities established for completing the most urgent tasks first.
e We do not believe that we have violated any license or regulatory requirements in this instance which would warrant this citation for apparent noncompliance because:
- We had not committed to completion of initial training for all emergency personnel by any specific date.
Uc arranged to complete such training according to priorities established for tra,ining the most essential emergency personnel first.
- The requirements for implementation of our new emergency plan by 6/30/79 reads in the relevant condition of NRC License SNM-1097 as follows:
In accordance tcLth yout applica, tion dated Fektuary 28, 1979, as supptcmatted April 4 and 19, 1979, and pursuastt to Title 10, Code of Fedstal Regulations, Part 70, Special Nuctcar Matetials License No. SWf-1097 is hereby amended to include your cmergatcy ptm1.
Accordhtgly, cffeetive July 30, 1979, Condition 13 of SNM-1097 is amended to read as follotes:
J Condition 13: Notcithstandbtg Section 6.2.8 of Appatdix A of the ticatsce's application, the Licatsce shall maintabt a capability for handling emetgoteles bt accordance scith the cmergatcy plan ttansmitted by the letter of Febtuary 28, 1978, and supptcmatted Aptil 4 and 9,1979. The licatsee shall make no changes to the plan tdtich decrease L
its effectivesness tolthou.t ptior apptoval of the
^
Commission.
Changes made to the cmcrgency plan tolthout ptior Commission apptovat shall be subnitted tolthin thLtty days, for b1 formation parposes, to.the Reginn 11 Office of htspection and Enforccmott and the Office of Nacicat Material Safety and Safeguards.
Cettabt wording in the plan, patterned aft the teordbtg in Regulatory Ga,ide 3.42, such as, "The e
plat ptovides for..." in paragraph 8.1.2, teilt be istterpteted as initoducing requirements w1 der i
I the plan.
This httchpretation of the httent of j
the teordb19 tats discussed and agreed to by L
Mt. Kaplan on Ifarch 1, 1979.
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Mr. J. T. Sutherland December 17, 1979 Attachment - Page 3
- The commitment in our emergency plan is as follows:
- 1) Emetgenct) Director a) Initial training teill consist of detaded instruction on the scope, responsibit< ties and functionbt9 of 61e Emetgency Plan and
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Emetgency Procedures.
b) Rettaining on an annual basis teilt include a revice of die basic plan scith any changes.
- 2) Petsonnet Responsible All members of die Adviso.ty Staff, Emetgency Staff Advisors astd Site Emetgatcy Support groups are resportsible for bioteledge of the castatt Emetgenet) Plan and Emetgatcy Procedates.
- 3) Settvey Team & Re-Etttty Team Health Phisics personnet htitially receive j
extensive trabting and subsequatt iststtuctions on new methods and equ.ipmestt.
Att personnel indica.ted initialltj receive Ltabting in onsite/offsite radiological monitor-ing and detaded instructions on the basic plan and Emergency Procedures.
Retta.ining on an annual ba. sis teill include a reviac of Bie Emcrgency Plan and Procedates.
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- 4) Fite Stigade htitial trahting is conducted seith teams and includes lat oat of Bie plant and familiarization j
telth equipment, location and operation. Trabsing scitt also be coordinated seith local fire fightbtg orgastization.
Retta.inbtg scitt be bij participation in drills (at least quarterti ), and by team and individual j
iststtuetion at least.tcice per t ear.
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- 5) Facilities Damage Conttot Team
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initial training scitt consist of a reviac of Emergenct) Procedutes, seith accideftt control and repaLts emphasized.
Normat teork activities cover tchat tanttd be done during an cmetgency.
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Mr. J. T. Sutherland' December 17,'1979 Attachment - page 4
- 6) Fiut Aid & Rescue Teams Personnel sitall be t*utined to perform basic fitst aid and rescue functions. At least one petson scill be onsite at all times telio lias been t*iained and/or retrained periodically in advanced fLtst aid metiteds.
- 7) Local Support Petsonnet Fire figitters from tocal fite and liose compastics teill receive a,t least one familiarization per ycar toitit compatibility of equipnent and special radiological precautions applicable to tite Wilnington Manufac.turbig Ocpartmestt.
Retta,bting scitt inetude an annual exercise.
- 8) Mcdical Support Petsonnel Familiarization teltit tile Emchgency Plan and implementbtg Emchgency Procedures sciLL be coordinated by tlie Emchgency Preparedness Coordbtator. Trahting teill be conducted by qualificd individuals.
Rettabthtg scill include participa. tion in annual drills and/or exchcises.
- 9) Corpora,te Level Support Titese h1dividuals are advised to familiarize tlicmsetucs toitit tlie Emergency Plan and applicable Emchgency Procedures as istltial trabthtg and as
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clutnges are made to tite Emergency Plan and/or Emergency Proceaures.
Since there is no specific commitment to accomplishing the initial training either by the implementation date for the emergency plan'(July 30, 1979) or by any other date, we believe i
that we have not violated any related license or regulatory conditions.
Furthermore, we believe that based upon the above, the accomplish-ments we have made in implementing our new emergency plan (including the initial training for the most essential emergency personnel relative to response to an emergency in the fuel manufacturing area), are quite reasonable from a compliance standpoint.
Since the time that we began implementing our new emergency plan, we have been scheduling and providing initial training to the various personnel assigned emergency duties in accordance with
'the commitment in our emergency plan shown above.
m _
Mr. J. T.
Sutherland December 17, 1979 Attachment - Page 5 With respect to the inspector's finding related to personnel assigned to,the Survey, Rescue and Facilities Damage Control Team, two problems were encountered in training these personnel who work on the graveyard (11:00 pM to 7:30 AM) and swing (3:30 PM to 11:30 pM) shifts.
One problem was that of scheduling.
Many of these personnel were unable to be scheduled for the special training provided by our contractor, Radiation Management Corporation.
Also, although these personnel do work on a rotating shift basis, many were not at work to participate in the emergency response exercises and drills which have been conducted only during the day shift (7:00 AM to 3:30 pM).
The other problem was that an essential part of the training to be provided to these personnel was to be conducted by the New Hanover County Sheriff's Department.
In turn, the Sheriff's personnel had to complete their training at Redstone Arsenal, Alabsma, before being able to train the General Electric personnel.
The Sheriff's personnel have since completed their training and, in turn, are scheduled to complete the training of our personnel assigned to the Survey, Rescue and Facilities Damage Control Team by April 30, 1980.
A l so, all other aspects of their training have been completed.
We also wish to point out that emergency damage control personnel are constantly being trained to fulfill their emergency roles, because the activities which they would perform in an emergency situation are very similar to those activities in which they are normally engaged as a part of their regular work assignments.
With respect to iritial training of the designated Emergency Direc*sts, there are fourteen different individuals designated as Emergency Directors or alternates, depending upon the type, location and extent of the emergency.
All of these individuals have received initial training relative to their emergency functions, by participating in at least one emergency exercise or training
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session.
A draft procedure listing these fourteen indi'iduals and their cse.ceency functions, already implemented as part of our emergency plan, will be prepared for review and approval by 1/31/80.
This draft procedure will enter the WMD review cycle with a targeted issue date of March 31, 1980.
A. L. Kaplan
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