ML20058J891
| ML20058J891 | |
| Person / Time | |
|---|---|
| Site: | 07000824 |
| Issue date: | 11/19/1993 |
| From: | Barr K, Salyers G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058J885 | List: |
| References | |
| 70-0824-93-05, 70-824-93-5, NUDOCS 9312140288 | |
| Download: ML20058J891 (10) | |
Text
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UNITED STATES
[earcy,t NUCLEAR REGULATORY COMMISSION i
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REGION 11 a
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101 MARIETTA STREET, N.W., SUITE 2WJO
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- E ATLANTA. GEORGIA 30323-0199 N0Y 19 BS3 f
Report No.: 70-824/93-05 Licer.see: Babcock and Wilcox Company Lynchburg Technology Center Lynchburg, VA 24505 t
Docket No.: 70-824 License No.:
SNM-778 Facility Name: Lynchburg Technology Center j
Inspection Condf:ted:October 18-2,
93 Inspector: $ k J
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7'97 3 G. W. Salyers 1
Date Signed i
Approved by:
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/ g K. T. Barr, Chief Date Sig'ned Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection was conducted in the area of emergency preparedness, and included evaluation of the following program elements; (1) coordination of emergency planning with offsite support agencies; (2) Radiological Contingency Plan and its implementing procedures; j
(3) emergency facilities and equipment; and (4) performance of the licensee's emergency response organization during the annual exercise, which was l
conducted oi. October 20, 1993.
Results:
i In the area inspected, one exercise weakness (EW) and one drill control l
problem were identified. The EW concerned a failure to request the Concord Volunteer Fire and Rescue to respond to the simulated fire (Paragraph 6). The drill control problem involved simulation of offsite notifications (Paragraph 6). The licensee's emergency preparedness program was being maintained in a sts+.e of readiness that was adequate to protect the health and safety of the public and p1 personnel.
1 9312140288 931119 PDR ADOCK 07000824 j
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- C. Boyd, Licensing and Compliance Officer
- J. Calvert, Manager, Industrial Health and Safety-
- J. Hughes, Emergency Preparedness Officer, Naval Nuclear Fuel Division
- D. Spangler, Supervisor, Health Physics
- D. Ward, Manager, Safety Naval Nuclear fuel Division
- J. Whitaker, Health Physicist
- C. Yates, Health Physicist 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.
2.
Offsite Support Agencies (88050)
The inspector reviewed the coordination of emergency planning with offsite support groups and NNFD. The Letters of Agreement with offsite support groups are with the B&W facility which includes NNFD, CNFP, and LTC. The Letters of Agreement were maintained by B&W NNFD for the entire B&W facility. The inspector noted that current agreements had been executed with the Concord Rescue Squad, Lynchburg General Hospital, and the Concord Volunteer Fire Department. Additional assistance to LTC was provided by CNFP.
Section 7.2 of the RCP stated that Campbell County Emergency Services would be offered radiation safety training and facility familiarization annually. The inspector reviewed documentation that indicated radiation safety training and site familiarization tours were provided to members of the Concord Volunteer Fire and Rescue on August 29, 1993; Lynchburg General Hospital on April 16, 1993; and NNFD on April 25, 1993.
As stated in Section 4.2 of the RCP, emergency response at the LTC site was coordinated through the NNFD Emergency Organization (NRC License SNM-42). The inspector noted that LTC relied upon NNFD for the fire team, hazardous material team, and the medical team responses.
LTC also i
I utilized the same E0C as NNFD.
No violations or deviations were identified.
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1 3.
Radiological Contingency Plans Procedures (88050)
)
The inspector reviewed documentation indicating that the licensee had conducted an annual review of the RCP in accordance with Section 7.4 of the Plan.
The annual review was conducted from October 1992 through l
January 1993, and resulted in Revision 4 to the RCP. The initiation of l
the review process was prompted by concerns from an NRC inspection and the 1992 annual exercise. The revision reflected several LTC organizational changes and editorial corrections.
Revision 4 was submitted to the NRC on February 1, 1993, and approved by the NP,C on i
May 10, 1993.
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IR 70-824/92-06 identified an NCV for failure to submit an appropriately revised RCP in conjunction with the June 1992 license renewal l
application. The inspector noted that since the last inspection, the licensee had submitted a revised RCP in accordance with 10 CFR 70.22(i)
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to NMSS. NMSS reviewed and returned the revision with comments. The licensee responded to NMSS' comments and the revision was currently in the State and local review process.
The inspector reviewed documentation that indicated the licensee had I
performed an annual review of the EPs in accordance with Section 7.4 of l
the RCP. The EPs were reviewed during the last quarter of 1992. This review resulted in procedures EP-1, EP-2, EP-3, and EP-4 being revised.
1 The inspector noted that the revised EPs were distributed on October 12, 1993.
No violations or deviations were identified.
4.
Facilities and Equipment (88050) 1 Sv. tion 4.2.1 of the RCP required that the EPC conduct quarterly i
I meetings. The inspector reviewed EPC Meeting Minutes from September 1992 through September 1993. The meeting minutes indicated the EPC had exceeded their quarterly commitment and had met on a monthly basis. The inspector reviewed selected EPC Meeting Minutes and noted that the committee was organized and the meetings were divided into Old Business, E Plan commitment list items, and New Business.
The inspector observed that the licensee had installed new meteorological instrumentation process capable of monitoring wind speed and direction at the 25 foot and 130 foot elevations. The system was computerized and powered by a regulated power supply and an emergency backup power supply. The inspector observed that the meteorological data could be read locally, at the stack monitoring panels in Building B, and in Building C.
The inspector considered the licensee's new system to be a good improvement to the licensee's meteorological monitoring capability.
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The inspector reviewed documentation from surveillance procedure TP-578, i
Monthly Inspection of Emergency Equipment.
Records indicated that calibrations and operability checks of instruments and equipment were performed as required and that identified discrepancies were corrected.
l A random inspection of selected emergency equipment by the inspector did not identify any problems. Documentation for the period of September 1992 through September 1993.
From Surveillance Procedure TP-182, Changing Area Film and Environmental TLD Badges, Surveillance Procedure TP-410, Changing Area Air Samples, and monthly tests of the Emergency Notification System were reviewed.
No discrepancies in the performance of these surveillances were noted by the inspector.
i The inspection of the NNFD's E0C, which was shared with LTC, indicated l
that the facility was being properly maintained, and that no significant changes had been made to the E0C since the last inspection.
Monthly inventory records of emergency lockers were reviewed for the j
period of September 1992 through September 1993. Also, the visual condition and accessibility of the emergency showers and condition of i
the respiratory protection equipment was inspected. No deficiencies were identified.
l The inspector observed a licensee representative inventory an emergency kit in Building A and operationally check the radiation survey instruments, fire protection equipment, air sampling equipment, and i
respiratory protection equipment. All survey instruments observed were i
within calibration and battery checks were acceptable. The randomly selected items for inventory were available in quantities specified on the equipment inventory sheets.
The inspector did a walkdown of 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 clearly marked and located adjacent to the parking lot.
No violation and no deviations were identified.
5.
Fire Protection (88050)
The inspector discussed the Fire Protection program with a licensee representative and reviewed appropriate documentation. The licensee relied totally on NNFD's Fire Brigade response capabilities.
Based on the close proximity of NNFD, and the inspector's observation of NNFD's participation in LTC's annual exercise, the inspector concluded that NNFD's Fire Brigade was capable of responding swiftly and effectively to an emergency at LTC.
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The inspector reviewed the monthly checks of licensee's portable fire extinguishers. Audit records were reviewed for the period of September 1992 through September 1993. The list indicated each extinguisher's location, type, last hydrostatic test date, and the last maintenance.
j The records indicated that 13 extinguishers had exceeded either their hydrostatic test or maintenance date. An independent verification by the inspector revealed that the hydrostatic test and maintenance dates of the 13 extinguishers were current but the computer documentation was not up-to-date. The licensee noted and corrected the documentation errors. The inspector randomly checked 10 additional extinguishers and verified that they were fully charged, in good working order, and being checked monthly. No problems were identified. Documentation indicated that extinguishers were inspected by an independent firm during the calendar year. The inspector conducted a walkdown of selected areas within the main building and noted the following:
Portable fire extinguishers were available with tags indicating the dates of their inspection and that inspections were within requirements.
No impediments to accessibility of randomly selected fire protection equipment existed.
The inspector observed that facility modifications were under construction. The inspector walked down the facility with a licensee representative and discussed the facility changes. The walkdown indicated that the licensee had or was in the process of conver'.ing offices into six additional laboratories. The six laboratories were:
Volatile Organic Chemistry laboratory Semi Volatile Organic Chemistry laboratory Sample Distribution laboratory Waste Extraction laboratory Two Operation laboratories The inspector reviewed LTC's Pre-Fire Fighting Plan which was implemented in 1991 and noted that it had not been updated. Discussions with the licensee indicated that they planned to update the Pre-Fire Fighting Plan when the current laboratory construction project was complete. The inspector discussed the importance of maintaining the Pre-Fire Fighting Plan up-to-date and informed the licensee that the update of the Pre-Fire Fighting Plan would be tracked as an IFI.
IFI 70-824/93-05-01: Update the LTC Pre-Fire Fighting Plan to accurately depict present facility utilization.
No violations or deviations were identified.
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Test and Drills (88050)
Section 7.3 of the RCP required the licensee to conduct an annual emergency exercise to test the integrated response of all emergency responders. The required exercise was conducted on October 20, 1993.
The exercise began at 08:55 and lasted until 09:40.
In the scenario, offsite participation was limited to testing the communication links
.i with State and local authorities and the NRC, and transporting of a contaminated and injured individual to the Lynchburg General Hospital.
l The licensee submitted the exercise objectives and scenario to the NRC for review in advance of the exercise. No problems were identified with regard to this submittal.
The remainder of this report makes reference to facility equipment damage, abnormal radiological conditions, and personnel casualties, all of which were postulated to have occurred in order to effect activation of the licensee's emergency response organization.
All such conditions referenced herein were simulated, although the licensee's responses actually occurred and were evaluated.
In the exercise scenario, a worker drops a cylinder of acetylene gas against a cabinet in the Analytical Laboratory which caused a crack in the cylinder valve. The maintenance worker heard gas leaking from the bottle and realizes that acetylene gas was highly explosive.
The maintenance worker ran down stairs to the nearest phone and dialed the emergency number 5000. The evacuation alarm was sounded by the maintenance worker. The acetylene gas never ignited during exercise.
At the same time, a fork lift operator was transporting a drum of high level waste from the hot cells to the high level waste silos. The fork lift operator transporting the drum of high level waste was startled by the evacuation alarm and fell off the fork lift. The fork lift hits one of the trailers on the west end of the restricted area, ignited, and caught all three trailers on fire. The gas storage pad and fuel tanks were in close proximity to the trailers on fire.
The fork lift operator was rendered unconscious when he fell off the fork lift. The high level waste drum had radiation levels of 100 R/hr on contact and 7 R/hr at I meter. A Health Physics Technician assigned to monitor the high level waste transfer observed the accident and reported what he had seen.
The inspector observed the following aspects of the drill:
(1) activation of the ER0; (2) response of the Emergency Director and his staff at the E0C; (3) offsite notifications; (4) on-scene command and control; (5) fire fighting and medical response efforts at the accident scene by the NNFD Emergency Teams; (6) contamination control practices; (7) facility evacuation; and (8) communications among onsite response personnel.
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Licensee personnel in the EOC and at the incident scene were both organized and professional in their response to the scenario events.
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-The emergency alarm sounded at 08:55 and the EOC was staffed at 09:04.
I In accordance with EP-4, Emergency Response at the Lynchburg Technology Center, three members of LTC's ERO, the Plant Operations Director, Radiation Protection Coordinator, and Industrial Engineering Coordinator responded to NNFD's E0C and assumed their emergency response positions.
The LTC ERO members integrated smoothly and worked effectively with members of the NNFD ERO in the E0C. Communication in the E0C was good.
The on-scene command and control was excellent.
The On-Scene Director established a command barrier at a distance from the event that would ensure the safety of the command personnel, but not interfere with the activities of the emergency responders, and still maintain a clear view of the incident and all of the emergency responders. The On-Scene Director maintained overall direction and i
control necessary to support of the emergency responders, and maintained j
a continuous flow of pertinent information to the E0C.
The emergency response teams were on the scene at 09:16 and the first fire hose was charged at 09:19. The inspector considered this an excellent response time by the emergency response teams. At the scene, the Fire Brigade, Medical, and Radiological emergency response teams functioned as one team, not as individual units. At the scene, a 1 R/hr i
perimeter was established, air samples and surveys were taken. The i
" attack" of the fire, attention to the medical victim, and radiological condition were planned, prioritized, and professionally executed.
The evacuation alarm sounded at 08:55. LTC personnel evacuated in an orderly manner and reported to their pre-designated assembly areas. All personnel were accounted for by 09:07 and this information was transmitted to the E0C by two NNFD security guards with radios.
Overall the drill was successful, although, several concerns were noted.
Accuracy and timeliness of required agency notifications were objectives of the exercise. During the exercise, these notifications were simulated. The licensee stated to the inspector that in the exercise scenario, offsite notifications were intended to be made. The licensee further explained that construction was going on in the immediate vicinity of the offsite comunication system and one of the drill observers, without authorization, instructed the offsite communicator to simulate the notification. Also, the licensee noted the same personnel, procedures and equipment used during this exercise were used during the NNFD exercise in July 1993. The NNFD exercise, including offsite notification was evaluated by NRC to be satisfactory.
The inspector observed'during the controller critique, that licensee i
management discussed the simulation and stated to all participants that j
offsite notifications were not to be simulated in future exercises.
i After the discussion with the licensee, the inspector concluded that the i
offsite notification simulation would be classified as a drill control problem and did not warrant further NRC actions.
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Another simulation incident occurred during the simulated medical emergency. A contaminated and injured person was transported to Lynchburg General Hospital. When the ambulance departed the scene of the accident, the ambulance was informed by the E0C that the hospital was aware that the ambulance was in transient to the hospital. When the ambulance arrived at the hospital, the hospital was not prepared to accept the simulated contaminated and injured individual.
The hospital objected to the unannounced arrival of the exercise ambulance and did not participate in the drill. Discussion with the licensee revealed that the ambulance departed the site at approximately the same time the site secured from the drill and the E0C believing the "whole" exercise was over, simulated making the call to the hospital. Again, the inspector considered the communication simulation a drill control problem.
RCP Section 7.3, " Drills and Exercises" stated "When the annual evacuation drill includes simulated fire involvement, Concord Volunteer Fire Department will be requested to respond with equipment and personnel. " The licensee's annual exercise involved an evacuation and a simulated fire. During the exercise Concord Volunteer Fire Department was not requested to respond. The issue of Concord Volunteer Fire Department not being requested to respond to the simulated fire was discussed with the licensee. The inspector further discussed with the licensee the fact that Concord Volunteer Fire Departments participation was a method of their maintaining familiarity with the site. The licensee in a telephonic conference on November 18, 1993 was informed that the failure to request Concord Volunteer Fire Department to respond with equipment and personnel during an evacuation with a simulated fire was an Exercise Weakness.
EW 70-824/93-05-03:
Failure to request Concord Volunteer Fire Department to respond with equipment and personnel during an evacuation with a simulated fire.
7.
Exercise Critique As required by the RCP, the licensee conductef a player critique following the exercise and an evaluator critique following the players critique. During the critiques, verbal comments from controllers, evaluators, observers and principal players were received. The inspector observed the evaluator critique and determined the self critique to be objective in identifying issues.
The licensee implemented a computer program for tracking critique items.
The inspector observed the computer tracking list and noted that critique items were being tracked and resolved.
No violations or deviations were identified 1
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8.
Action on Previous Inspection Findings (92701)
(Closed) IFI 92-06-03:
Implement a system for tracking critique 1
findings.
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The inspector observed a computer printout for tracking critique items.
The inspector observed that the critique items were being tracked and i
resolved in a timely manner. This item is considered closed.
9.
Exit Interview (30703)
The inspection scope and results were summarized on October 25, 1993, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed 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 70-824/93-05-01:
IFI - Update the LTC Pre-Fire Plan to accurately depict present facility utilization (Paragraph 5).
]
70-824/93-05-02:
EW - Failure to request Concord Volunteer Fire Department to respond with equipment and personnel during an evacuation with a simulated fire (Paragraph 6).
10.
Index of Abbreviations Used in this Report CNFP Commercial Nuclear Fuel P1 ant 1
EAL Emergency Action Level J
E0C Emergency Operations Center EP Emergency Procedure EPC Emergency Preparedness Committee ERT Emergency Rescue Team ERO Emergency Response Organization EW Exercise Weakness IFI Inspector Follow-up Item LTC Lynchburg Technology Center NCV Non-Cited Violation NMSS Nuclear Materials Safety and Safeguards NNFD Naval Nuclear Fuels Division NOUE Notice of Unusual Event RCP Radiological Contingency Plan
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ITEMS CONTINUED 7 (YlN):
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