ML20029B534
| ML20029B534 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 02/26/1991 |
| From: | Kasnicki D, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20029B533 | List: |
| References | |
| 70-1201-91-02, 70-1201-91-2, NUDOCS 9103120073 | |
| Download: ML20029B534 (7) | |
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UNITED STATES o
NUCLEAR REGULATORY COMMISSION y")b n
REGION li g
,j 101 MARIETTA STREET, N.W.
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e M LANTA, GEORGIA 30323 N r.. /
FEB 2519f" Report No.:
70-1201/91-02 Licensee:
B&W Fuel Company I
Comercial Nuclear Fuel Plant Lynchburg, VA 24505 l
Docket No.:
70-1201(CNFP)
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License No.: SNM-1168 Facility Name:
Commercial Nuclear Fuel Plant Inspection Con e+eth--Janwt 29 - Feb uar
, 1991 Inspector-
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- 0. Kasnicki /
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Date Signed _
Fuel Facilities Inspector k
Approved by:
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E. J. McAlpine, Chief 4 " Radiction Safety Projects Section Date Signed g
Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection was conducted in the areas of management controls, training, nuclear criticality safety, plant operations, and maintenance and surveillance testing.
Also addressed was one Inspector facility, and 10 CFR 21 reportable items. Follow-up Item (IFI) dealing with the Results:
In the areas inspected, violations or deviations were not identified.
licensee's implementation of the programs inspected and the controls to assure The safety and compliance with specific license requirements were acc The IFI dealing with the construction of a new chemical storage facility remains The open.
Indications of CNFP's Health-Safety group being understaffed were apparent.
Four new IFis were identified to aid in future followup on CNFP's intentions regarding potential weaknesses in safety training and safety procedures.
9103120073 910225 PDR ADOCK 07001201 PDR MTEWSiDNA
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- D. Ferree, Manager, Fuel Operations
- K. Lester, Manager, Health Physics and Licensing
- G. Lindsey, Foreinan, Health-Safety
- C. Speight, Manager, Facilities Engineering Other licensee employees contacted during Lis inspection included craftsmen, engineers, operators, mechanics, security force members, technicians, and administrative personnel.
- Attended exit interview 2.
Organizational Structure (88005)
Section 2.1 of the license application defines the structure of the-Commercial Nuclear Fuel Plan (CNFP) safet organization.
Discussion with a CNFP representative indicated that some langes have been made regarding personnel and responsibilities.
The Safety and Licensing Manager reports directly to the CNFP Plant Manager, leaving the Health-Safety Section functionally unchanged.
Two slots in the Health-Safety Section remain to be filled:
One of the slots will be either a health physics or a-licensing function; the Health-Safety-Manager is -presently assuming both the health physics and licensing functions and will retain whichever responsibility is not delegated to this new slot.
The second slot is the Industrial / Environmental Safety function, the responsibilities of which are still being assumed by the Health-Safety Foreman since the retirement of the previous Industrial / Environmental Safety Officer.
Discussions with Health-Safety Section personnel regarding various aspects of their current' activity indicated that. their present capacity is such that they are just taking care ' of Lday-to-day b'usiness and struggling somewhat to maintain control.
They.do not.have theLcapacity to improve and otherwise maintain existing programs, develop new programs, or be their ' own worst critic in evaluating existing programs and their implementation.
CNFP -management concurred with the above 1
characterizations and stated that filling the two open Health-Safety. slots should correct the situation.
No violations or deviations were identified.
3.
Safety Review Board (8805, 88015, 88020)
Section 2.3 of the license application establishes the CNFP Safety Review Board and specific requirements associated therewith.
The membership of
2 the Safety Review Board and the responsibilities of the Board are specified in Procedure AS-1120, "CNFP Safety Review Board." The inspector reviewed the minutes of the Board meetings since the last inspection (minutes for the third and fourth quarters of 1990) and determined that the meetings had been held at the required _ frequency with the required membership present.
The inspector also determined that the agenda for items reviewed were in accordance with the charter.
The inspector had several questions inquiring about background details on many of the items discussed in the meeting minutes, all-of_ which were answered satisfactorily.
The meeting minutes were very informative and otherwise indicative of the Safety Review Board's function fully meeting the intent-of the license condition.
No violations or deviations were identified.
4 Construction of New Chemical Storage Facility (88005, 88020, 92701)
CNFP had previously committed to build a new chemical storage facility to improve the segregation of incompatible chemicals and to improve the containment of chemical spills which potentially could occur.
Discussion with a CNFp representative indicated that this project has been budgeted for the current fiscal year (ending April 1991) but that funds have not yet been released and that no schedule toward completion --has yet been established.
Further progress on this project will be checked during subsequent inspections and Inspector Follow-up Item (IFI) 89-07-02 remains open.
No violations or deviations were identified.
5.
10 CFR 21 Reporting -of Defects and Noncompliance (36100) 10 CFR 21 requires the reporting to the NRC of defects and noncompliance which could create a substantial safety hazard, the inspector-discussed this requirement with a.C_NFP representative who indicated that their program had not identified any reportable items.
No violations or deviations were identified.
6.
Audits (88005,88015,88020).
Section 2.7 of the license application establishes the CNFP internal audit-program and specific requirements associated therewith.
The inspector reviewed the nuclear safety audit reports for the third and fourth.
quarters of.1990.
The audit reports were indicative of thorough audits
-and no violations were identified.
The audits were conducted in accordance with requirements of the license application and a written procedure: AS-1125, " Health-Safety Audits."
i No violations or deviations were identified.
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7.
FuelHandlingandStorage(88015,88020) l During tours of the production areas, the inspector observed the handling l
of pelluts, fuel rods and fuel assemblies.
All observed activities were in accordance with posted safety limits and storage requirements.
Completed assemblies were stored in permanent fixtures.
Storage and 6
transport of fuel pellets were in accordance with the license requirements for slab thickr.ess, unit separations, and enrichment segregation.
No violations or deviations were identified, f
8.
Criticality Monitoring System (88015, 88025) l Section 3.2.4.3 of the license application establishes the required functional testing and calibration frequency for the criticality monitoring system.
The inspector reviewed the functional test and i
calibration records for the period of time since this item 'was last inspected (March 1990 through December 1990).
No violations or deviations-were identified...
9.
Training (88010)
Section 2.5 of the license application establishes the CNFP radiation worker training / retraining program and specific requirements associated therewith.
The inspector determined that procedural controls were -in place for employee safety training.
Radiation safety refresher training j
was last conducted in December 1990.
A review.of CNFP's training record system indicated that, while all of the. necessary information exists in these records, the system appears to be-somewhat awkward and therefore not readily auditable.
Accordingly, the inspector questioned whether this system was readily manageable.
Discussions with CNFP representatives =
indicated that this system is administered by the Health-Safety Foreman-who is generally-familiar with any peculiarities of _this system.
The
' inspector suggested ~ that a more readily auditable system would be more readily manageable without as much reliance on the corporate knowledge of 1
an individual, Regarding retraining, CNFP stated that in December, 1990, they had instituted a " badge pulling" policy as a control mechanism to
-preclude individuals from missing required retraining.
-In reviewing training / retraining records, the inspector noted that only people who routinely work in controlled areas virtually 100 percent of the -
time were retrained and requalified as "Radiatior Workers"; e.g. managers and engineers were not retrained _and requalified even though they are authorized to have unescorted access into controlled areas.
The inspector discussed-this with CNFP representatives and stated that the term
" Radiation Worker" and related training / retraining requirements typically apply to everyone who is authorized unescorted access to controlled areas.
Further, the scope of " Radiation Worker" training is usually limited to the basics of radiation and contamination control practices and is not-job
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specific.
Job specific -control practice's are learned on-the-job by-
" hands on" workers, who also enter and exit controlled-areas daily.
From that perspective, it appears that those who do not routinely enter and exit controlled areas may also be those who most need the retraining.
CNFP representatives agreed to evaluate their definition ~ of " Radiation Worker" (within the context of the above discussion) and CNFP's intentions in this regard will be followed up on during-a subsequent-inspection; this is IFl 91-02-01.
CNFP does not use written examinations in its " Radiation Worker" training or other safety training _.
The inspector suggested that written examinations should be-used as an aid tc.both_ teaching; and-learning.
Written examinations, while not a total indicator of competenca, do for example, provide feedback-to the instructor, force the instructor to delineate learning objectives, increase the interest level of the trainee, etc.
(Also see discussion of employee interviews below).
CNFP agreed to evaluate the use of written examinations in its training / retraining and their intentions in this regard will be followed up on during a subsequent inspection; this is IFI 91-02-02.
The inspector reviewed CNFP's safety training. procedure (Procedure No. AS-1101, " Employee Safety Training",- Rev.13, dated April 2,1990) and a computer printout listing of categorized cafety training. courses which CNFP conducts.
It was -noted that the training procedure does not-explicitly define which types of jobs require which training courses.
In general, while the training procedure contained useful information, it did not otherwise appear to give clear definition to' the safety training program.
Again, as with CNFP's training' record-system discussed above, CNFP appeared to be largely relying on the corporate knowledge of the Health-Safety Foreman for the-details of implementing their safety training program.
The inspector suggested that CNFP consider _' expanding its safety training procedure to more clearly and explicitly define their training program and its implementation.
CNFP agreed to evaluate their training procedure in this regard and their intentions will be'followed up on during a subsequent inspectiot:; this is IFI 91-02-03.
The inspector conducted interviews _with-six CNFP employees regarding basic
" Radiation Worker" topics.
Three of these people worked in SERF:
operations and three of_ them worked _-in a controlled area for uranium handling.
These discussions indicated that the SERF people were quite knowledgeable; this was somewhat anticipated since SERF personnel receive this type = of training. repeatedly at _the 'various power plant sites where i
they perform service work.
Two_ of the_ other three people appeared iless knowledgeable and none of these three, for example, understood that alpha contamination is -the most harmful-to ingest; this point is' covered in -
- their training.'
The inspector stated to CNFP_ management that these_ types of apparent understanding deficiencies, while curious, 'are not uncommon based on similar interviews conducted at other fuel facilities.
No violations or deviations were identified.
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10.
Health and Safety (H&S) Manual (88005, 88010, 88015, 88020, 88025)
The inspector reviewed CNFP's H&S Manual which consists of all of their H&S Procedures contained in two 3-ring binders.
It was noted that these procedures are ordered in the binders according to sequential. procedure number, which probably corresponds to the order-in which they were originally written; i.e.
they are not grouped according to safety discipline, e.g., radiation safety, fire safety, chemical safety, safety training, industrial safety, etc.
The inspector suggested that reorganizing these procedures according to safety discipline, and perhaps
. separating them into their own respective safety manuals, could make the procedures more useable and manageable; it would also better reflect the structure, scope, and content of these programs.
CNFP agreed to evaluate this and-their intentions in this regard will be followed up on during a -
subsequent inspection; this is IFI 91-02-04.
In reviewing -some specific H&S procedures, the inspector noted that the responsibility for a particular action did not always appear to be placed where it best belonged, i.e. Health and Safety versus Operations.
CNFP representatives agreed that in general, given the support of a good safety program, the responsibility for safety actions rests with the operators and first line supervision; and that. care should be taken to write procedures to reflect that.
No violations or deviations were identified.
- 11. Handling of-Non-Fuel Components that Look Similar to Fuel _ Components (88005,88015,88020)
During a previous inspection (Inspection Report No. 70-1201/90-04), the inspector noted a CNFP internal audit comment questioning whether these non-fuel items should be handled to the same nuclear criticality safety
-requ rements (NSR) as fuel components to avoid confusion and i
misunderstanding.
A review of subsequent Safety Review Board meeting minutes during this inspection-revealed that the decision had been made to handle non-fuel rods to -a four-inch slab thickness NSR,.just as with fuel-rods. CNFP should be commended for this decision.
No violations or deviations were identified.
12.
Preoperational Audits of Changes (88005, 88015, 88020)
The inspector reviewed a file of preoperational audit documentation for
- calendar year 1990 and noted that none related to plant nuclear criticality safety.
No violations or deviations were identified.
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Exit Interview The inspection scope and results were summarized on February 1, 1990, with those persons indicated in paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results.
Although reviewed during this inspection, proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
Item No.
Description and Reference (0 pen) IFl 89-07-02 Construction of New Chemical Storage Facility.
.(Paragraph 4)
(0 pen) IFI 91-02-01 Follow up on CNFP intentions on training for all personnel who have unescorted access to controlled areas.
(Paragraph 9)
(0 pen)IFI 91-02-02 Follow up on CNFP intentions regarding written tests for Rad Worker training and other safety training.
(Paragraph 9)
(0 pen) IFI 91-02-03 Follow up on CNFP intentions regarding expanding ard upgrading their safety training procedure.
(Paragraph 9)
(0 pen)IFI 91-02-04 Follow up on CNFP intentions regarding reorganizing and upgrading their Health-Safety Manual.
(Paragraph 10) i l
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