ML20128C008
| ML20128C008 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 11/23/1992 |
| From: | Kreh J, Sartor W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20128C003 | List: |
| References | |
| 70-1113-92-15, NUDOCS 9212040197 | |
| Download: ML20128C008 (12) | |
Text
.' # Mo UNIVED STATES oq'o NUCLEAR REGULATORY COMMISSION g*.='
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70-1113/92-15 Licensee:
General Electric Company Wilmington, NC 28401 Docket No.:
70-1113 License No.:
SNM-1097 facility Name: General Electric Company InspectionCon}lucted: October 3 16, 1992 Inspector:
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J Kreh, Radiation SpecTilist Date Signed Accompanying Personnel:
K. Ramsey=
Approved by:
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W. M. Sartor, A~cting Chie f Date-Signed-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) emergency facilities, equipment, and implementirg procedures; (2) coordination of emergency planning with offsite support agencies;_and (3) performance of the licensee's emergency response organization during the
-annual-exercise, which was conducted on October 15, 1992 from 1:00 p.m._to_
3:00 p.m.
Resu us:
In the area inspected, no violations or deviations were identified. The-licensee's emergency preparedness program was being maintained-in'a state of readiness that was adequate to protect the health and safety of the public_ and plant personnel.
The site emergency organization performed capably and effectively in response to the events postulated by the exercise scenario.
9212040197 921123 ADOCK 0700 3
{DR
2.
Areas for possible improvement in the emergency preparedness program were identified with_ respect to various inconsistencies in the Radiological.
- Contingency -and Emergency Plan -implementing ' procedures -(Paragraph 3);
documentation of training for offsite support groups (Paragraph 2);.and~
exercise control (Paragraph 5).
-~~
4 REPORT DETAILS 1.
Persons Contacted Licensee Employees
- B. Bentley, Manager,- Fuel Fabrication Manufacturing
- G. Bowman, Senior Program Manager, Compliance Improvement
- T. Brechtlein, Manager, Powder Production
- D. Brown, Manager, Reclaim and Support
- M. Chilton, Manager, Fuel Chemical Technical Resources
- R. Foleck, Senior Specialist, Licensing Engineering
- N. Gutermuth, Safety Specialist-
- J. Harmon, Manager, Manufacturing Technology
- F. Jackson, Manager, Employee and Community Relations
- R. McIver, Manager, Plant Engineering and Site Maintenance
- G. McKenzie, Senior Manufacturing Technologist
- D. McLemore, Manager, Fuel Chemical Manufacturing
- S. Murray, Manager, Radiation Safety Engineering-
- P. Schaeffer, Supervisor, Site Maintenance
- L. Sheely, Manager, Fuel Programs
- D. Silverthorne, Manager, Nuclear Fuel and Components Manufacturing
- H. Strickler, Manager, Environmental Protection and Industrial Safety.
- T. Swirat, M.D., Plant Physician
- R. Torres, Manager, Radiation Protection
- C. Vaughan, Manegrr. Regulatory Compliance
- P. Winslow, Manager. Licensing and Nuclear Material Management.
Other licensee employees contacted during this inspection included engineers, operators, security force members, technicians, and administrative personnel.
Other Organiza is L. Ray, Director, New Hanover County (NC) Department of Emergency Medical Services (EMS)
T. Rickey, Safety Officer, New Hanover Regional Medical Center, Wilmington, NC-Nuclear Regulatory Commission (NRC)
- G. Troup, Senior Fuel Facility Inspector, NRC Region II
- Attended exit interview 2.
. Coordination with Offsite Support Agencies (88050)
The inspector held discussions with licensee representatives and reviewed documentation regWng the-coordination of emergency planning with offsite support agent es.
Letters of agreement (LOAs) with four local and -two State agencies were updated in early-1992. These current LOAs were available for review and will be included in the next revision-
l 2
of the Radiological Contingency and Emergency Plan (RCEP).
Confirmation of the adequacy of the interfaces between the licensee and offsite support organizations was obtained through telephonic interviews with representatives of two of these agencies (see Paragraph 1).
Both interviewees praised the licensee's ef forts-to foster a strong working relationship.
The interview with the Director of New Hanover County EMS i
disclosed that his agency's personnel were not presently able to handle l
patients who had not been radiologically / chemically decontaminated, as i
appropriate, since EMS personnel had thus far been trained to only an
" awareness" level in this area.
However, on October 16, 1992, an agreement was reached whereby the EMS staff would be provided training by the licensee in the handling of patients with radiological and/or -
cliemical contamination.
The licensee's previous offers to provide such i
training had not been accepted by New Hanover County EMS.
The licensee was required by RCEP Section 7.2 to offer appropriate training to offsite support agencies on an annual basis.
- However, except for detailed documentation of training provided to New Hanover Regional Medical Center Personnel in 1991, the licensee's records of training offered or provided to offsite support agencies during 1991 and 1992 consisted of only the dates of that training.
Licensee management agreed that documentation of future training provided to offsite agencies would be maintained, and that such records would include (but not necessarily be limited to) information on lesson plans, handout material, attendees, and instructors.
This matter will be tracked as an Inspector Follow-up Item (IFI).
IFI 70-1113/92-15-01: Maintaining documentation of training provided to offsite support groups
.No violations or deviations were identified.
3.
Radiological Contingency and Emergency Plan / Procedures (88050)
The version of the RCEP in effect at the time of the current inspection was Revision 7, dated December 1, 1988.
Subsequent to the inspection, the NRC approved RCEP Revision 8 (dated October 2, 1992, with supplementa! pages dated October 26) on October 29, 1992 following several iterations of review and discussion with the licensee.
Significant changes were made to. clarify and enhance the specificity of-the emergency classification scheme, offsite notification requirements, and the emergency response training program for both licensee and offsite support personnel.
The-procedures for implementing the RCEP were known simply as the RCEP Procedures.
The inspector reviewed the " master" copy of the Procedures as well as several controlled copies in the ECC intended for emergency use (particularly those designated for the Emergency Director and.the
-Nuclear Safety Advisor). Numerous minor administrative discrepancies were identified, including the following examples:
(1) some procedures, such as Nos. 6 and 7, with text pages having-higher revision numbers than the cover page; (2) multiple cases of unlabeled pages of material
3 (i.e., no procedure numbers or page numbers) in appendices to various procedures; (3) inconsistencies between controlled copies with regard to
- the content of the aforementioned appendices;'and (4) several instances-of-missing pages r_esulting-from duplicat. ion errors (e.g., pages 2 and 4 of Procedure 6-0 were missing, but pages 1 and 3 each appeared twice).
The inspector informed licensee management during the exit interview that the subject discrepancies indicated the desirability of management attention and oversight in order to transform the RCEP Procedures into the professional-quality document that the NRC expects licensees to develop and maintain. This matter will be tracked as an IFl.
IFl 70-1113/92-15-02:
Resolution of administrative discrepancies in 3
RCEP Procedures In addition to the administrative inconsistencies delineated above, review of the RCEP Procedures disclosed a variety of shortcomir,gs in the actual content of the procedures.
None of these problems were so serious as to result in a determination of procedural inadequacy, but they were numerous and widespread among the procedures.
The most significant faults concerned the lack of prioritization of procedural steps and the presence of numerous redundancies which impeded procedural
" fl ow. " Procedure No. 5, " Criticality," was especially problematic in these respects. The inspector provided detailed comments to the licensee regarding these matters, and licensee management agreed during the exit interview to give attention tu the development of appropriate corrections.
This issue will be tracked as an IFI.
IFI 70-1113/92-15-03:
Review and upgrade of the RCEP Procedures 4
No violations or deviations were identified.
4.
Emergency Facilities and Equipment (88050)
This area was inspected to determine whether emergency facilities, equipment, instrumentation, and supplies were maintained in a state of operational readiness since the last such inspection (March '1991), and to assess the impact of any changes in this area upon the licensee's emergency response capability.
The licensee's Emergency Control Center (ECC),-located at the primary personnel entrance to.the Controlled Access Area,- served-as the focal point for the management of emergency response and mitigation efforts.
Although occasionally used as a training or meeting room, the ECC was essentially a dedicated-facility. An annex to the management area of
.the ECC-housed portable radiation-detection equipment and miscellaneous emergency response supplies. The inspector observed that minor changes in-the layout of the ECC had been made since the last NRC-evaluated exercise (December 1991).
During the October'15 exercise, the effects of these changes on ECC operations were determined to be positive.
Inspection of selected equipment at the ECC indicated that a fully adequate level'of readiness was being maintained for that faci _lity.
4 The inspector reviewed documentation of the weekly surveillances of the ECC and the licensee's Emergency Vehicle (used in rescue and fire-fighting) for the nriod July 1,1991 to the present,- These records indicated that the subject surveillances were effective in identifying equipment discrepancies, and that such problems were being corrected expeditiously.
Communications equipment available for emergency use was delineated in Section 6.2 of the RCEP, and included standard telephones at the ECC, several cellular telephones, base and portable VHF radio transceivers, and amateur radio equipment owned by a number of plant personnel active-in that field.
Although the RCEP contained no requirements for periodic testing of the referenced equipment, the inspector determined that breakdowns in communications systems or hardware would likely be disclosed promptly because of routine use of this equipment on essentially a daily basis.
Equipment for the provision of emergency power consisted of two diesel generators (500 kW and 150 kW) and a battery system.
In the event of a loss of offsite power, the diesel generators provided emergency aower to various plant areas and systems, including the ECC.
Battery bac(up power was provided for the criticality warning system and the "Autocall" system, which was used to notify designated emergency response personne!
to report to the ECC.
Reccrds of weekly, monthly, and annual-surveillance tests of this emergency power equipment were reviewed for the period July 1991 to the present. These surveillances were scheduled and tracked through a computer-based system of Inspection Work Orders, and all were performed as required.
No violations or deviations were identified.
5.
Emergency Response Exercise (88050)
Section 7.3 of the RCEP required the performance of periodic tests and drills in order to maintain proficiency in emergency response, to include-an annual exercise integrating the onsite and offsite components of the emergency response organization.
In fulfillment of this requirement, the licensee conducted an exercise on October.15, 1992, commencing at 1:00 p.m. and terminating at approximately 3:00 p.m.
The licensee submitted the exercise objectives and scenario (included as the Attachment to this report) to the NRC for review in advance of the exercise.
No significant problems were identified with regard to this submittal. The inspector telephonically discussed various aspects of the scenario with a licensee representative prior to the inspection, and was provided appropriate clarifying information to resolve several questions.
The remainder of this report makes references 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 (ERO). All such
5 conditions referenced herein were simulated, although the licensee's responses actually occurred (to the extent practicable), and were evaluated.
The exercise scenario involved an explosion in the Solvent Extraction area of the facility.
Although no major fire resulted, there were three persons physically injured and chemically contaminated.
Injuries to one
.y of these individuals were intended by the scenario to result in deeth shortly after rescue.
Details of the exercise objectives and scenario are provided in the Attachment to this report.
The inspector observed selected aspects of the drill, including the following:
(1) activation of the ER0; (2) management of the response / mitigation efforts by the Emergency Director and his staff at the ECC; (3) offsite notifications; (4) personnel search, rescue, treatment, and other support efforts at the accident scene by the Emergency Response Team (ERT); (5) contamination-control practices; and (6) communications among onsite respon e personnel.
Licensee personnel at both the ECC and the incident scene performed capably and effectively in response to the scenario events.
No significant performance problems were observed during the exercise.
The milestones in terms of event initiation, ERO activation, event declaration, and offsite notifications during the exercise were as follows:
(1) fire alarm at 1:00 p.m.; (2) "Autocall" signal for personnel to report to ECC sounded at 1:05 p.m.; (3) Alert declared by Emergency Director at 1:13 p.m.; (4) notification of State and local authorities initiated at 1:22 p.m.; and (5) notification of NRC initiated at 1:57 p.m.
These responses were consistent with the requirements of the RCEP.
The only significant problems observed by the inspector in relation to the conduct of the exercise were in connection with the licensee's control of the scenario events.
Several complicating factors designed into the scenario did not enter into the play of the exercise because of inaction (or improper reaction) on the part of those individuals designated as exercise controllers.
The subject factors were as follows:
(1)
As mentioned earlier in this paragraph, one of the three explosion victims was intended in the scenario to be fatally injured.
However, appropriate vital signs were either not unambiguously conveyed to the players by the controller, or were not believed or accepted by the players (apparently the latter).
This caused a chain of confusion, culminating in a question regarding a fatality from a reporter during the mock press conference at the end of the exercise; the licensee player who was being interviewed knew nothing of a fatality having occurred.
(2)
The explosion in the Solvent Extraction area was supposed to have produced a small opening in the roof as a result of a buckled seam, with subsequent action required by ECC management to 1
~. -.
t 6-determine whether a potential for an offsite ra'diological release; existed and how to close %a spening.
It was not clearly determined why the existence of the opening was not conveyed to the players, but the inspector discussed with licensee-representatives how " contingency" messages can be used when scenario events do not occur exactly as predicted.
(3)
At the outset of the exercise, the controller in the ECC wrote the-simulated meteorological conditions on an obscure portion of a chalkboard.
ECC personnel did not notice this information, and instead used actual meteorological data, for which the wind direction was almost exactly opposite to that of the simulated meteorology. This resulted in considerable _ confusion on the part of ECC players when near-' site (mock) members-of the public living -
unwind (actual meteorology) of the plant called to report an acrid odor, indicating a possible chemical release.
No attempt was:made to correct this situation _during the exercise, although the L
controller did realize the problem when the' players began to express confusion, and could have intervened to place this aspect of the scenario "back on track."
The inspector discussed these matters during the exit interview and-indicated that additional coaching of the ERO with _ regard to "drillsmanship" might be helpful in eliminating the type of problem discussed in item (1), above. The other problems suggested a need for better training of exercise controllers and consideration of the use of contingency messages to maximize the training benefit from emergency response exercises.
This issue _ will be tracked as an IFI.
IFI 70-1113/92-15-04:
Improving exercise control and player "drillsmanship" 6.
Exercise Critique As required by tLe RCEP, the licensee conducted a critique during which verbal comments from controllers, evaluators, observers, and principal l
players were received. The inspectors observed the critique and l
determined it to be adequate in identifying several response problems, corrective actions for which will be tracked by the licensee to ensure -
implementation.
Future NRC inspections will review the adequacy of those corrective actions.
7.
Action on Previous Inspection Findings (92702) a.
(Closed) IFI-70-Ill3/90-04-01:- Verification of actions to ensure performance of periodic sur_veillance testing, inspection, and~
documentation of results.
Review of emergency equipment surveillances as reported in Paragraph 4, above, verified that the licensee had developed a-system to ensure the-performance and documentation of such tests.
.l 1
7 1
i b.
_(Closed) Violation 70-1113/91-04-05:
Failure to promptly identify and declare an Alert condition on May 29,- % 1.
.The inspector reviewed the licensee's April 9,- 1992 response to-f the subject violation.
The licensee. appropriately revised the RCEP and its implementing procedures _ to explicitly specify the declaration of an Alert in the event of a potential criticality incident.
In addition, a special, NRC-requested exercise was successfully conducted during off hours on December 18,1991_(see NRC Inspection Report No. 70-1113/91-09).
c.
(Closed) Exercise Weakness 70-1113/91-07-01:
Failure to demonstrate the capability to conduct a timely search and rescue operation for an individual known to be missing following an explosion.
Search and rescue techniques were emphasized in ERT training conducted since the 1991 exercise.
During the current exercise, the ERT conducted a timely and successful search and rescue operation-.
8.
Exit Interview The inspection scope and results were summarized on October 16, 1992 with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in-detail the inspection results listed below.
Licensee management agreed to consider the: Inspector Follow-up Items below for possible emergency-preparedness program improvement.
Proprietary information is not contained in this report.
~
l Dissenting comments were not received from the licensee.
Item Number Cateaor_v, Description, and Reference 70-1113/92-15-01 IFl: Maintaining documentation of training provided to offsite support groups (Paragraph 2) 70-1113/92-15-02 IFI:
Resolution of administrative discrepancies in-RCEP Procedures (Paragraph 3) 70-1113/92-15-03 IFI:. Review and upgrade.of the RCEP Procedures (Paragraph 3) 70-1113/92-15-04 IFI:
Improving exercise control and player "drillsmanship" (Paragraph 5)
-Attachment (3 pages):
Objectives and Scenario for October 15,~1992 Exercise at GE Wilmington-Facil_ity
4 SITE EMERGENCY EXERCISE I
SCHEDULED FOR OCTOBER 1992 GOAL:
DEMONSTRATE CAPABILITIES OF GE WILMINGTON'S EMERGENCY RESPONSE PROCEDURES, PERSONNEL SKILLS, AND INTERACTION OF THE EMERGENCY ORGANIZATION, RESPONSE TEAMS \\ND OFFSITE AGENCIES IN RESPONDING TO A SITE EMERGENCY.
OlkTECTIVES OF THE DRILL:
o ACTIVATE THE EMERGENCY ORGANIZATION IN A TIMELY MANNER.
o DEMONSTRATE ABILITY TO PROPERLY CLASSIFY EMERGENCY.
o PROVIDE SUFFICIENT CHALLENGES TO THE EMERGENCY ORGANIZATION TO DEMONSTRATE THEIR STATE OF RESPONSE AND READINESS.
g o PRACTICE A WORKING RELATIONSHIP WITH THE ON SITE NRC RESPONSE
- TEAM, o DEMONSTRATE RADIATION PROTECTION'S CAPABILITIES TO CONTROL CONTAMINATION EXITING THE AREA AND SCENE.
o DEMONSTRATE RADIATION PROTECTION'S ABILITY TO HANDLE CONTAMINATED INJURIES.
o PRACTICE THE INCIDENT COMMAND AND COMMUNICATIONS REQUIRED BY THE EXERCISE.
o PERFORM REGULATORY NOTIFICATIONS.AS REQUIRED.
o DEMONSTRATE THE ABILITY TO PREPARE A MEDIA RELEASE.
o SIMULATE A PRESS CONFERENCE INCLUDING RESPONDING TO QUESTIONS FROM OUTSIDE INTEREST AND FOR RUMOR CONTROL.
JHB 10/92 l
4
l t.
. SITE EMERGENCY EXERCISE OCTOBER 1992 SCENARIO:
AN EXPLOSION OCCURS IN THE SX FACILITY.
THE EXPLOSION DOES NOT RESULT IN A MAJOR FIRE.
HOWEVER, SEVERAL PEOPLE IN THE TACILITY ARE HURT AND ONE EMPLOYEE IS KILLED.
THE EXPLOSION CAUSES A OPENING IN THE ROOP AND SEVERAL LIQUID LINES ARE SEPARATED.
BOTH ACID AND DODECANE ARE SPILLED.
ANTICIPATED ACTIONS:
THE EXPLOSION WILL REQUIRE RESPONSE BY THE EMERGENCY RESPONSE TEAM.
THE EMERGENCY RESPONSE TEAM WILL ASSEMBLE AND SET UP AN INCIDENT COMMAND CENTER.
THE EMERGENCY ORGANIZATION WILL BE ACTIVATED.
THE MEDICAL TEAMS WILL BE REQUESTED TO RESPOND TO THE INJURIES.
THE VICTIMS WILL BE REMOVED FROM THE AREA.
NOTIFICATION TO THE REGULATORY ACTIONS WILL OCCUR.
VICTIMS WOULD BE TRANSPORTED TO HOSPITAL. (HOSPITAL IS NOT ABLE TO PARTICIPATE - HAVING COMMITTED TO THE BRUNSWICK RADIOLOGICAL DRILL IN JUNE AND A MASS CASUALTY ACCIDENT THAT WILL BE DONE IN NOVEMBER FOR CERTIFICATION.)
THE OUTSIDE VOLUNTEER FIRE DEPARTMENT WILL RESPOND.
THE SPILL INSIDE THE SX FACILITY WILL HAVE TO BE ADDRESSED.
THE HOLE IN THE ROOF WILL HAVE TO DE ADDRESSED.
DAMAGE ASSESMENT WILL HAVE TO BE CONDUCTED.
QUESTIONS REGARDING POTENTIAL OFFSITE EXPOSURE WILL HAVE TO BE ADDRESSED.
THE NRC TEAM WILL BE COMMUNICATING TO THE OPERATIONS CENTER AND REGION II THE FINDINGS OF THE SURVEY AND RESPONSE TEAMS.
NOTIFICATION OF THE FAMILY FOR THE INJURED PERSONNEL WILL HAVE TO BE CONSIDERED.
A PRESS RELEASE WILL HAVE TO BE PREPARED, A MEDI A PRESENTATION WILL HAVE TO BE SIMULATED (ON SITE PERSONNEL TO PERFORM THIS FUNCTION).
l
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TIME LINE OBSERVED EXERCISE 1992 1300 FIRE ALARM 1305-10 4 1s CALL FOR FIRE CALL FOR RESQUE SQUAD CALL FOR ACTIVATION OF E.O.
1315 EOC ACTIVATED EXPLOSIVE MEASUREMENT TAKEN PROBLEM IDENTIFIED 1315-20 CLASSIFICATION MA15E CALLS INITIATED TV STATE AND LOCALS CALL MADE TO OPS. CENTER.
CHEMICAL TEAM REQUESTED / ACTIVATED START RESPONDING 1315-30 RESCUE SQUAD ARRIVES VFD ARRIVES 1325 ENVIRONMENTAL TEAM OUT 1330-45 INJURY TRANSPORTED 1345 ER CALLS COMMENCE PUBLIC MEDIA FAMILY 1400 SHOULD HAVE STABILIZED SCENE 1430 MEDIA ARRIVES FOR INTERVIEW DISCUSSION WILL BE AT SOUTH GATE.
NRC & GE EXPECTED TO COMMENT 1430-1500 EMERGENCY EXERCISE WILL BE DECLARED OVER WHEN:
1.
SCENE OF EXPLOSION IS CONTROLLED 2.
ALL INJURIES TAKEN CARE OF 3.
ISSUES DE ALING UITH ENVIRONMENTAL CONDITIONS RESOLVED.
4.
CLASSIFICATIONS MADE & REPORTED.
5.
PRESS CONFERENCE COMPLETE.
6.
TERMINATION IS COMMUNICATED BY CONTROLLER.
1530 CRITIQUE
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