ML20151R051
| ML20151R051 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 04/14/1988 |
| From: | Asmussen K GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 29229, NUDOCS 8804270227 | |
| Download: ML20151R051 (5) | |
Text
7d-Z3 6 1
e CENERAL ATOMICS
.9 p asto usne gpR19 W
\\.
utG5
' 'g y#t %g s
gocnt oj p Y [ ~"'
,e April 14,1988 p
k[C{y{g 696-1216 APR1919sy f[-
-V.LAuctugnfoh#08Y U.S. Nuclear Regulatory Cmmission t
C03W13s ATIN: Document Control Desk Washington, D.C. 20555
,(g fqg #8 9
u
Subject:
Docket 70-734: SNM-696; Response to Notice of Viola to i.
Reference:
James L. Montgmery letter (NRC Inspection Report No. 70-734/88-02) to R. N. Rademacher dated March 17, 1988 Gentimen:
his letter is in response to the referenced letter notifying General Atmics (GA) of a violation.
he violation was identified during a routine unannounced safety inspection of GA's NRC licensed activities ccaducted February 22-26, 1988.
A brief statement of the violation (parts 1 and 2) followed by our explanation and response (parts 1 and
- 2) follows:
Statement of Violation:
1.
Secticn 8.5 of GA's approved Radiological Contingency Plan states, in part, (1) Radiatico detection instruments will be checked monthly, (3) Protective breathing equignent will be checked monthly, (4) Other supplies designated for mergency use will be checked monthly, and (6) Essential emergency (quipnent will be kept secured to prevent pilfering and misappropriation.
Contrary to the above, at the time of the inspection, the required inventories for the Health Physics van, which contains essential emergency response equipnent, had not been conducted since September 1987.
Also, the essential equignent and emergency kits were not secured to prevent pilfering or misappropriation.
2.
Section 4.1.7.1.
of the Radiological Contingency Plan (RCP) entitled, Emergency Response Teams, states, in part, team mmbers are trained in basic first aid, cardiopulmonary resuscitation (CPR), building familiarization, fire suppression, and the use of Self Contained Breathing 4paratus (SWA).
Contrary to the above, at the time of the inspectico, the licensee had not ecoducted the required training for ten mmbers of the Emergency Response Team. Records indicated all ten were lacking 8804270227 880414
~
PDR ADOCK 07000734 C
PDR 10955 JOHfi JAY HOPKINS DRIVE. SAN OtEGO. CA 92121 1194 PO BOX 85608. SAN DIEGO CA 92138-5608 (619) 455-3000 a&M Wo
training in Self Contained Breathing Apparatus and Fire Suppression.
Eight of the ten were also noted to be lacking training in CPR and first aid.
Explanation / Response 1.
GA's energency van had been inventoried on a monthly basis for all radiation detection instruments, breathing equignent and other supplies designated for emergency use until October 1987. At that time, the Health Physics staff person who was responsible for this
- i activity was suddenly dicabled by illness.
What was initially i
thought to be only a temparary disability proved to be long term.
'Ihis person's duties were reassigried to other Health Physics staff personnel; however, the monthly check of the emergency van was inadvertently left unassigned.
Corrective action was initiated inmediately.
Full con @ lance was achieved on February 25, 1988, prior to the empletion of the j
subject NRC inspection.
On that day, an inventory of the emergency van contents was empleted and each emergency kit was sealed to prevent pilfering or misappropriation.
To prevent recurrence, this mmthly check of the emergency van contents and of the seals on emergency kits therein has been added a
to a list of "required activities," thus ensuring its timely cmpletion in the future.
Such inventories were empleted on March 3,1988, and April 6,1988, and will continue to be i
concheted cn a monthly basis.
2.
When Sectim 4.1.7.1. of the Radiological Contingency Plan was written, it was not intendad that it be interpreted to mean that each metber of a facility's Emergency Response 'Itam would be j
trained in all of the subjects entanerated in the paragraph. GA's facilities (buildings) have different emergency response j
requirenents, depending upon the nature of the work being performed and the materials involved.
Each facility's anergency Pesponse and Recovery Director is responsible for reviewing the facility's emergency requirenents and specifying those areas in which various of his team members should be trained.
Section 4.1.7.1 lists the various subjects in which team msnbers could be trained to satisfy the unique requirements of their specific facility.
Again, they need not all be trained in all, or the same, subjects.
i
'1he role of the emergency response team msnber is that of the first responder; they do what they ce.n to control the situation until GA's Bnergency Services personnel arrive.
For example, in the event of a fire their participation is restricted to the incipient stage.
Response team mesters are given specific assigreents calculated to reduce risk and damage during an emergency, such as shutting down certain equipnent, turning off gas and power, etc. 'Ihese tasks are generally work related, f
l
o l
i It was never intended that all response team msnbers be trained in i
the use of a self-contained breathing apparatus (SCBA). Prior to being certified to use a SCBA, a person nest first have satisfactorily undergone a lung stress evaluation.
Not all personnel are physically capable of passing such a test, yet they are very valuable nerrbers of a response team.
All response personnel do receive instructions relative to the SGA to better i
understand the device and to guard against its accidental use by uncertified personnel.
SCBAs are primarily used under circumstances where there is a need to enter a facility during an emergency to rescue a person, shut off gases, power, equignent, etc. and/or clean up spilled materials.
However, the presence of SCAB equipnent in a facility does not necessarily mean that smeone there has been, or should be, trained to use the item.
Rather, see have been pre-positioned for emergency use by trained specialists (i.e.,
GA's Emergency Services Personnel); for example, if the item has been used in a contaminated area, it might be kept at that facility for future use.
We Fuel Fabrication Facility was aEproved for shutdown in 1985; the working force was eliminated and the production area has since been virtually unoccupied except for the security force, maintenance and an occasional enployee. hose conducting training assumed that the training was no longer required after the facility was placed in the shutdown mode since there was no longer a work force and the facility (for which portions of the plan had been developed to support) was no longer active.
ne Dnergency Procedures for the Fuel Fabrication Facility are current and, as noted in the inspection, there is an eight-person Emergency Response Team.
We team is cmposed mostly of management and office personnel and their main focus is the adninistrative areas.
Since the facility is in a shutdown mode these persons often work on programs requiring their presence elsewhere.
We other persons referred to in the report, whose training records were checked, are menbers of the Emergency Response Team for a chemical Analysis Laboratory. We maximum anount of special i
nuclear material that can stored and used in this location at any i
given time is 350 grams of U-235. We energency equipnent at this j
facility consists of hand-held fire extinguishers, washes and
)
lights.
Emergency training was not up-to-date due to a i
misinterpretation of the type of training required.
/s corrective action, training was initiated innediately.
Further, all personnel resycasible for scheduling, conducting, and traintaining records of training were lectured as to the urgency and importance of an exacting training program and as to their individual responsibilities.
. We energency response team menbers whose training was in question will have been trained in those subjects that are aEplicable to their respective activities by June 1, 1988.
In fact, eight of the ten team menbers have already canpleted their training.
Additionally, training records for other menbers of the Radiological Contingency Plan response teams are being reviewed and any needed training will likewise be accomplished by June 1, 1988. Selected Health Physics technicians will also have received SCBA training by that date.
'Ib prevent recurrence, the following actions have been or will be taken.
An additional person has been detailed to interface with the Emergency Response and Recovery Directors to determine their training needs and objectives.
% e individual will assist in the adninistrative aspects of notifying team menbers of the need for training and retraining. Wis same person will monitor records to ensure training is given in a timely manner.
W e Radiological contingency Plan is currently being updated, he wording of Section 4.1.7.1. will be restated to more precisely reflect the training objectives.
We trust you will find our response and corrective actions to be appropriate and satisfactory.
If you should have any questions or require additional information, please contact me at (619) 455-2823.
Very truly yours, bC se Keith E. Asnussen, Manager Licensing, Safety and Nuclear Compliance KEA/nk cc: John Martin, Regional Adninistrator, NRC Region V bbY
l*
~
DOCKET !!0.
CONTROL NO.
DATE OF 000.
- _/Y b DATE RCVD. ___.b h
/
FCUF PDR FCAF LPSR I & E REF. _[___. _
MicGUARSS.
FCTC OTHER DATE 13 lN:1 11. 4D._
,