ML20057E340
| ML20057E340 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 09/29/1993 |
| From: | Barr K, Salyers G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20057E337 | List: |
| References | |
| 70-1201-93-04, 70-1201-93-4, NUDOCS 9310120040 | |
| Download: ML20057E340 (9) | |
Text
6 UNITED STATES f'p aah NUCLEAR REGULATORY COMMISSION y +-
S AEGION ll 3
101 MARIETT A STREET. N.W.. SUITE 2900 3
.j ATLANTA. GEORGIA 30323-0199
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Report No.:
70-1201/93-04 Licensee:
B&W Fuel Company Commercial Nuclear Fuel Plant i
Lynchburg, VA 24505 Docket No.:
70-1201 License No.: SNM-Il68 i
Facility Name: Commercial Nuclear Fuel Plant Inspection Conduct
- August 30 Se ember 3, 1993 T f. /f fd Inspector:
-r _
G. W. 'Salyepf {
/DateSi@ned i
Approved by:
b/vs' 9cM 3
K. 18 Barr,4tnef'
// Date' Signed Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
I Scope:
This routine, unannounced inspection was conducted in the area of emergency preparedness.
Several areas within the emergency preparedness program were reviewed to determine if the program was being maintained in a state of operational readiness. Specific areas reviewed included the following:
maintenance of selected emergency and fire protection equipment, Radiological i
Contingency Plan and implementing procedures update, training, periodic drills, and open items from previous inspections.
Results:
In the areas inspected, no violation was identified. Training documentation needed improvement. The physical condition of the emergency preparedness equipment was well maintained. Annual retraining of the emergency response teams was identified as an Unresolved Item (Paragraph 4).
9310120040 930929 5
i PDR ADDCK 07001201 s
C PDR 2
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- D. Codrea, Manager, Purchasing
- D. Gordon, Healtn Physicist
- K. Knapp, Manager, Safaty and Licensing
- G. Lindsey, Health and Safety Foreman
- L. Morrell, Regulatory Compliance Officer Other licensee employees contacted during this inspection included security force members, technicians, and administrative personnel.
- Attended exit interview Abbreviations used throughout this report are listed in the last paragraph.
1 2.
Offsite Support Agencies (88050)
The inspector discussed with the licensee the coordination of emergency planning with offsite support groups and B&W, NNFD. The Letters of 1
Agreement are with the B&W facility which includes NNFD, CNFP and LTC.
According to Section 8.2 of the RCP, Letters of Agreements are reviewed every two years and updated if necessary. The Letters of Agreement in the licensee's RCP and licensee's files were not the most recent version.
The most recent Letters of Agreement were maintained by B&W, NNFD. The inspector contacted the B&W NNFD Emergency Coordinator and noted that agreements had been executed with the Concord Rescue Squad (December 7,1991), Lynchburg General Hospital (October 1991), and the Concord Volunteer Fire Department (October 8, 1991).
In accordance with Section 7.2 of the RCP, documentation indicated that members of the Concord Volunteer Fire Department were provided a site familiarization tour on September 1, 1992, and another tour was scheduled for November 1,1993.
ERTs from NNFD and the Concord Rescue Squad were not identified as needing site tours in Section 7.2 of the RCP. On June 10, 1992, CNFP held a meeting with CNFP personnel, NNFD, and Concord Volunteer Fire Department to review and discuss the CNFP Pre-Fire Plan.
The inspector reviewed comments from that meeting and reviewed a revised edition of the Pre-Fire Plan that incorporate the meeting comments. The inspector concluded that comments enhanced the Pre-Fire Plan. The inspector noted that the revised Pre-Fire Plan had not been distributed at the time of the inspection, but that it was printed and ready for distribution.
The inspector was informed that as of April 1993, B&W Fuel Company, excluding B&W NNFD was totally owned by Framatome and Cogema. B&W CNFP's RCP was dependent upon support from B&W NNFD. Therefore, the inspector queried the licensee concerning CNFP offsite support from NNFD. The licensee provided a purchase order number BWFill32PH dated
2 June 3, 1993, that stated on item 5 that for 21 months, NNFD would provide emergency support services for health physics, fire, first aid, and security. The inspector concluded that this purchase order maintained the continuity of NNFD's onsite and offsite support to CNFP as stated in various sections of the licensee's RCP.
No violations or deviations were identified.
3.
Emergency Plans, Procedures, Facilities, and Equipment (88050) a.
Radiological Contingency Plan and Emergency Procedures The licensee had made a major revision to the plan to meet the revised requirements of 10 CFR 70. The RCP revision was in the State and local review process. The licensee had also rewritten AS-1106, " Emergency Procedures" and AS-Il41, " Incident Procedures" in June 1993.
The licensee considered the rewrite to be the annual review of the RCP and EPs in accordance with Section 7.1 of the RCP and Section 11.1 of Procedure AS-1106.
The inspector reviewed the EALs in the RCP and emergency classification procedures (AS-Il06 and AS-1141) for consistency and verification that the EPs adequately implemented the RCP classification scheme. The inspector reviewed documentation that indicated that the Emergency Telephone list had been updated and verified quarterly as required. The current copy of the RCP was dated May 5, 1992, Revision 17. The inspector checked for proper distribution of the RCP using the " Distribution of Copies" list located on page 74 of procedure AS-1106, " Emergency Procedure."
No deficiencies were identified by the inspector.
b.
Facilities and Equipment The inspector observed the readiness of the facility emergency response capability and equipment.
The inspector performed the t
following review:
i Layout and general house keeping of the Emergency Operations Facility building Incorporation of significant review comments and updates to the Pre-Fire Plan J
Started, moved, and checked the fuel level in the dedicated fire response truck Checked breathing air cylinder pressure and the positioning and condition of the personal turn our gear, for all fire fighters Training records of fire fighters i
I
3 Randomly selected and tested the operability of the thirteen five-channel radios and the radio scanner Observed the availability and condition of the colored vests that are used by the different emergency teams Observed the condition of the Golf cart assigned to the
=
radiation monitor team and how it was equipped No problems were identified by the inspector.
The following records of calibration and/or surveillance performed during the period of September 1992 thru September 1993, were reviewed:
Quarterly invertory of emergency lockers Monthly check of smoke detectors Quarterly check of emergency power source Weekly check of the emergency showers a
Monthly inspection of the respiratory protection equipment Semi-annual fire extinguisher maintenance inspection All inventories, calibrations, and/or operability checks were performed in accordance with procedures and the RCP.
The inspector randoaly selected three emergency kits from the Emergency Building and emergency lockers. The inspector observed a licensee representative inventory the emergency kits and operationally check the equipment (radiation survey instruments, fire protection equipment, air sampling equipment, and respiratory protection equipment). All survey instruments observed were within calibration and s :ccessful battery checks. The randomly selected items for inventory were available in quantities as i
specified on the equipment inventory sheets, i
The inspector walked down evacuation routes from different areas within the facility to the assembly points (accountability area).
The inspector did not observe any impediments to an orderly evacuation. The licensee's accountability area was located to the -
rear of the parking lot and adjacent to the picnic shelter.
The accountability area was clearly marked.
The inspector note that the licensee had not completed an evacuation since the June 1992 annual exercise. The licensee stated that they intend to perform i
an evacuation drill in October 1993.
No violations or deviations were identified.
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4.
Training (88050)
This area was inspected to determine if the licensee was providing training in accordance with Section 7.2 of the RCP.
The inspector reviewed the RCP and implementing procedure AS-1101, " Employee Safety Training" for a description of the training program.
The inspector reviewed training records for the onsite Fire Brigade Team, Radiation Monitoring Team, First Aid Team, and other members of the onsite and offsite emergency organization. Documentation was available to show that training was being performed.
Procedure AS-1101,
" Employee Safety Training," is the implementing procedure for the training specified in Section 7.2 of the RCP. AS-Il01, Section 6.3, Specialized Training, defines the training requirement for areas or assignments requiring specialized knowledge. These areas include the Radiation Monitoring Team members and Fire Brigade members.
Exhibit B outlines the training curriculum for the Radiation Monitoring Team and Fire Brigade.
Subsection 6.3.2 specifies retraining of Emergency Monitoring Team / Fire Brigade personnel annually and first aid personnel at least every three years.
The inspector reviewed retraining documentation and retraining outline.
The inspector concluded that the retraining outline was adequate to maintain the efficiency and proficiency of the emergency teams.
The inspector noted that some of the personnel had not attended all of the scheduled training classes. The licensee did not have a minimum attendance requirement for maintaining qualification. The licensee explained that in some instances attendance sheets were incomplete, in other instances personnel were either on travel status or vacation. The licensee noted that in an actual emergency, their major emergency response team support would come from NNFD (see Paragraph 2). The inspector discussed the importance of maintaining emergency team retraining with the licensee.
In a telecom on September 29, 1993, the inspector identified to a licensee representative that the concern of ERT personnel not attending all retraining sessions would be identified as an URI.
URI 70-1201/93-04-01:
ERT personnel not attending all retraining sessions.
The licensee had requested and received a license amendment to process 5.1 percent enriched fuel. As a condition to the amendment, the licensee revised their RCP to require specialized training for the fire brigade team. The fire fighting team was taught fire fighting techniques to prevent disrupting the geometry of fissile material. The inspector reviewed documentation that indicated the fire brigade had received the specialized training.
Section 7.2 of the RCP, required personnel assigned to the ERT (Fire Brigade and Radiation Monitoring Teams) to be medically certified for respirator use on an annual basis, in addition, Procedure AS-Il09,
" Respiratory Protection Program," Section 5.4.1 requires respiratory
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i retraining for members of the Radiation Monitoring Team and Fire Brigade j
in conjunction with the annual medical certification. The inspector verified that medical certification was current for selected workers.
Training was reviewed for other individuals assigned to the onsite ERO personnel (Emergency Officer, Evacuation Officer, etc.). AS-1101, l
Employee bafety Training Section 9.1.1, Emergency Officers Team Training states that all members designated as emergency officers and alternates must meet the minimum qualifications as outlined in the emergency i
procedure. The inspector noted that the AS-Il06, Emergency Procedure i
did not specify any training or qualification requirements for ERO members. A licensee representative stated that the omission had occurred as a result of rewriting AS-1106, and that AS-1106 would be revised to define the training and qualification requirements of ERO members. The licensee was informed that the revision of AS-Il06 to define the training and qualification requirements for ERO members would
'i be tracked as an IFI.
IFI 70-1201/93-04-02:
Revise AS-1106 to define the training and qualification requirements for ERO members.
The Radiological Contingency Plan Section 7.2, Training, requires that the officers of the Emergency Organization meet on an annual basis to review the emergency procedures and the respective roles they play in emergencies. The inspector noted that the last documented ERO officers procedure training was April 1992. The licensee stated that they had delayed the training due to the rewriting of AS-1106, " Emergency Procedures" and AS-1141, " Incident Procedures." The licensee's documentation indicated that training and review of the newly reviewed procedures and RCP was scheduled for September 15, 1993.
Based on the i
licensee's definition of " annual" meaning within the calendar year, the inspector concluded that training and review of the newly reviewed I
procedures and RCP on September 15, 1993, would satisfy the Emergency Organization annual training requirement.
j i
AS-Il01, Employee Safety Training, Section 9.1.2 Emergency Officers Team l
Training required that annually, the emergency officers participate in an emergency exercise involving activation of the CNFP emergency response organization. The inspector's review of records indicated that the ERO was last activated on September 24, 1992, the remedial ~ annual exercise.
The licensee conducted a fire drill in April 1993 (an actual fire was used in the drill), and by their procedures, the emergency teams and ERO were activated. The initial inspector review of the drill documentation eluded to only a fire drill and there was no documentation supporting any other ER0 response. The licensee stated that the radiological team, medical team, and two members of the ERO responded to the drill.
The inspector discussed with the licensee the necessity for a more thorough description and documentation of the their drills, j
specifically details of drills scenarios (training) and drill
i 6
participation (attendance). The inspector explained that better documentation was necessary to document their compliance with their RCP.
The licensee was informed that the improving details of drills scenarios and drill participation attendance would be tracked as an IFI.
IFI 70-1201/93-04-03:
Improve documentation of drill scenario details and drill participation attendance.
^
Documentation indicated that offsite support groups, Concord Volunteer Fire Department, B&W NNFD, and Concord Rescue Department were provided a site familiarization tour and training during 1992, and was scheduled again in November 1993.
No violations or deviations were identified.
5.
Organization and Management Control (88050)
There were no changes in the licensee's management structure or emergency organization since the last inspection. Management was supplying the resources to maintain the emergency preparedness equipment.
No violations or deviations were identified.
6.
Fire Protection (88050)
The inspector discussed this program area with a licensee representative and reviewed appropriate documentation.
Since the last inspection, the i
Fire Brigade members had received Fire Fighter 2 training and were l
currently in the Fire Fighter 3 training program. The inspector noted fire fighter team training sessions involved classroom instructions and hands-on training.
The inspector reviewed Procedure AS-ll16, "CNFP Fire Protection program. According to procedure, audits of the fire protection system Equipment Control," for a description of the fire protection maintenance involved weekly and/or monthly inspections of the fire extinguisher, sprinkler system, and fire valves.
Fire hydrants were inspected on an annual basis. Audit records reviewed for the period June 1992 to September 1993, indicated that audits were conducted at the required frequency. Documentation indicated that the required fire hoses and extinguisher were hydrostatically tested by an independent firm during i
the calendar year.
The inspector conducted a walkdown of selected areas within the main building and noted the following:
Portable fire extinguisher were available with tags indicating date of inspection No impediments to randomly selected fire protection equipment existed 4
No violations or deviations were identified j
e e
.=
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7.
Test and Drills (88050)
This area was reviewed to determine if the licensee was conducting drills in accordance with Section 7.3 of the RCP.
The RCP required that a planned evacuation be conducted annually for CNFP personnel.
The RCP further stated that " Emergency Drills (or a combined drill) of planned medical emergency and radiological monitoring capabilities will be held at least annually." The licensee defines annual as within the calendar year.
The inspector noted that the licensee had not performed an evacuation drill since the July 16, 1992 annual exercise, and only one fire drill since the September 24, 1992 remedial exercise.
The licensee conducted a fire drill in April 1993, and by their procedures the radiological team, medical team, and two members of the ERO responded to the fire drill. The licensee had scheduled a full ERO activation drill and site evacuation for October 1993.
The licensee had not conducted or scheduled an annual exercise in 1993 and did not plan on an annual exercise until 1994. The licensee provided the inspector documentation dated June 3, 1993, from NMSS that granted them permission to go a bi-annual exercise pursuant to 10 CFR 70.22(3)(xii).
The licensee had implemented a computer program for tracking " Action Items." The inspector observed the computer tracking list and noted that action items were being tracked and properly responded to in a i
timely manner.
No violations or deviations were identified 8.
Action on Previous Inspection Findings (92701) a.
(Closed) Violation 70-1201/92-04-01:
Failure to properly distribute AS-Il06, " Emergency Procedure."
The inspector reviewed AS-ll24, " Preparation, Distribution and Control of Occupational Procedures," Revision 12, dated November 17, 1992. The licensee had revised Section 7.0,
" Distribution of Occupational & Industrial Safety Procedures" to document distribution and accountability of the procedures.
b.
(Closed) IFI 70-1201/92-04-03:
Establish and implement an inspection schedule and cleaning if necessary of the cavity of the pellet loading machine.
I The inspector noted that the Emergency Preparedness Manager had placed the inspection of the pellet loading machine during each plant shutdown on her computerized action item tracking system.
The same requirement was placed on the Scheduling Managers status board as a required item.
)
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8 s
t 9.
Exit Interview (30703) l t
The in:paction scope and resuits were summarized on September 3, 1993, l
with those persons indicated.n Paragraph 1.
The inspector described the areas inspected and discusced in detail the inspection results listed below. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
There were no dissenting comments.
Item Number Description / Reference 70-1201/93-04-01 URI - ERT personnel not attending all retraining sessions (Paragraph 4).
70-1201/93-04-02 IFI - Revise AS-1106 to define the training and qualification requirements for ERO members (Paragraph 4).
i 70-1201/93-04-03 IFI-Improve documentation of drill scenario details and drill participation attendance i-(Paragraph 4).
l 10 Index of Abbreviations Used in ti.is Report l
CNFP Commercial Nuciear Fuel Plant EAL Emergency Action Level EP Emergency Procedure l
ERT Emergency Rescue Team ERO Emergency Response Organization IFI Inspector Follow-up Item LOA Letter of Agreement i
NMSS Nuclear Materials System & Safeguard i
NNFD Naval Nuclear Fuels Division i
RCP Radiological Contingency Plan SERF Service Equipment Refurbishing Facility UPA Ultra particulate air filter 4
]
URI Unresolved Item
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