ML20206D539
| ML20206D539 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 02/06/1987 |
| From: | Bidinger G, Blumberg N, Craig Gordon, Keimig R, Krasopoulos A, Mcfadden J, Roth J, Sly D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206D529 | List: |
| References | |
| 70-0371-86-11, 70-371-86-11, NUDOCS 8704130368 | |
| Download: ML20206D539 (30) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-371/86-11 Docket No.70-371 License No. SNM-368 Priority 1 Category UHFF Licensee: UNC Naval Products 67 Sandy Desert Road Uncasville, Connecticut 06382-0981 Facility Name: UNC Naval Products Inspection At: Montville, Connecticut Inspection Conducted: September 29 - October 3, 1986 Inspectors: , hA kd'7 Jpo~th, Froject Engineer, RI date l 1 Y blk7 gJ'. Blumberg, Ledd Reactor Engineer, RI ' da'te f, RAL ler 3; ~KrasopoulossReactor Engineer, RI 1/&h7ddte
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date Specialist, RI A+ _4 2+/ 2N/f7 J. R. McFadden, Radiat' ion Specialist, RI 'date
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- 3idinger, Licensing Project Manager, Z/dhteEl MSS 3,(2A Lv WO7 Sly,' Senior Heal)th Physicist, IE date '
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1 8704130368 870206 PDR ADOCK 07000371 C PDR
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2' Approved by: - 2-d; -g 7 f R. Keimig, ief, Saf rds Section, date Division of adiation fety & Safeguards Inspection Summary: Inspection on September 29 - October 3,1986 (Inspection Report No. 70-371/86-11)
Areas Inspected: Special, announced inspection by a team composed of Region I inspectors and headquarters personnel to conduct a safety review of operational conditions at the licensee's facility to determine whether there are potential safety hazards'that, when combined with routine facility operations, could impact upon public health and safety.
Results: No violations or deviations were idcntified. Twenty-seven observa-tions were made that resulted in 17 recommendations to stregthen safety pro-grams at the Montville site. A summary of the observations and recommendations is contained in Paragraph 3 of the. report.
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i DETAILS L Persons Contacted
- N. Kaufman, President and General Manager
- G. Waugh, Executive Vice President
- J. Vickary, Vice President, Operations
- R. Gregg, Director, Technical. Services
- W. Kirk, Manager, Nuclear and Industrial Safety
- J. C. Andress, Vice President, Engineering
- J. V. Olson, Vice President
- R. J. Gigliotti, Director, Security
- J. P. Robison, Resident Manager, DAR D. Luster, Radiological and Environmental Control Specialist T. Gutman, Criticality Safety Specialist T. Caisse, Fire / Safety Engineer E. A. Barton, Industrial Safety Specialist J. Lawrence, Plant Engineer Present at the exit interview Present at the entrance and exit interviews Other employees were also interviewed during the course of the inspection.
- 2. Backgroind As a result of the accident involving the release of uranium hexafluoride from Kerr-McGee's Sequoyah Fuels Facility in Gore, Oklahoma, on January 4, 1986, the NRC decided to conduct an operational safety review at selected fuel cycle and byproduct material facilities.
The operational safety review is designed to evaluate existing conditions at tach facility and to determine whether there are potential safety hazards that, when combined with facility operations, could impact upon public health and safety. Further, the review will assist the NRC in determining if additional license conditions are needed to deter such impact. During each review, the review team determines whether the li-censee has systems and procedures in place to identify and correct in-plant industrial safety problems that could result in radiological safety consequences, and determines whether the licensee is adequately imple-menting those procedures which exist to prevent or mitigate such problems.
The areas reviewed include personnel training, waste management, and facility operations and encompassed procedure control, equipment main-tenance, nonradioactive chemical control, fire protection,-and emergency planning. Upon completion of the review, based upon observations made during the review, recommendations were made to the licensee. Those ob:,ervations and recommendations will also be forwarded to the appropriate NRC Program Offices for their consideration in effecting program changes.
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4 The operational safety review at the nuclear fuel manufacturing facility of UNC, Inc., UNC Naval Products, Montville, Connecticut was conducted from September 29 - October 3, 1986. A summary of findings, including general observations and recommendations, is provided in paragraph 3. A detailed discussion of each area reviewed is presented in paragraphs 4, 5, and 6.
- 3. Summary of Observations and Recommendations In general, the NRC-review team found that the licensee had adequately addressed the operational procedures, work control practices and overall management controls required by the NRC facility license and had estab-lished an extensive industrial safety program that included good house-keeping, an extensive preventive maintenance program, and a excellent fire safety program. During the review, the team made 27 observations that resulted in 17 recommendations that should be considered by.the licensee to further enhance those programs and strengthen the facility employee training program, the Radiological Contingency Plan, and the techniques for evaluation and analysis of nuclear criticality safety at work loca-tions in the facility. No violations of NRC requirements were identified.
- a. Observations and Recommendations Observations and recommendations made by the inspectors during this review, concerning the operations, facilities, equipment, and procedures examined are as follows:
(1) Chemical, Explosion, and Fire Safety (a) Observations There does not appear to be a chemical, explosion or fire hazard associated with facility operations that could result in a significant impact on workers at the ,
site or on public health and safety. However, minor problems could occur from a fire involving zircalloy chips and turnings or hexane,'with or without the ,
4 involvement of uranium bearing materials. Paragraph 4.a. ,
An extensive preventive maintenance program is established and implemented for all equipment in the facility, with the exception of the hexane storage tank, the hexane distillation unit and associated equipment. The licensee could not locate preventive maintenance records or procedures for that equipment.
Paragraph 4.c.
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5 The storage of zircalloy machining wastes (swarf axi turnings) adjacent to the west end of Building B is a potential significant fire hazard that is in close proximity to radioactive materials. Paragraph 4.d.
The licensee har developed and is implementing suf-ficient fire protection and prevention procedures to assure adequate protection for the workers and facil-ities except for (1) testing of the Dry Barrel fire hydrants located throughout the site, (2) checking of the fire pump diesel fuel oil, (3) checking of the Cummins Engine flywheel for cracks, (4) acceptance testing of the Unit 2 CO 2fire suppression system-following installation, (5) sealing of holes in the walls of the zircalloy storage vault, and (6) estab-lishing a combustible material free zone around the autoclaves located in the Sectioning Area. Paragraph 5.d.(2).
(b) Recommendations Assure that the preventive maintenance program established for the hexane storage tank, the hexane distillation unit and associated equipment is conducted and records are maintained.
Re evaluate the practice of storing, pending disposal, zircalloy machining wastes in 55 gallon containers, filled with Argon gas, adjacent to the west end of Building B.
Assure that the Dry Barrel fire hydrants are tested twice each year; that the fire pump diesel fuel oil is checked in accordance with ASTM D-4057-81 require-ments; that the Cummins Engine flywheel is checked and replaced, if necessary; that the C02 concentration in the Unit 2 C02 fire suppression system meet the re-quirements of NFPA Standard No.12; that the holes in the walls of the zircalloy storage vault are sealed; and, that a combustible material free zone has been established around the autoclaves in the Sectioning Area.
(2) Industrial and Radiation Safety (a) Observations
- 1. In general, the licensee's industrial safety program was found to be extensive. However, the following observations were made:
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Enforcement of the facility industrial safety program: ,
1 is the responsibility of each supervisor. _However, there is no mandatory industrial safety training provided to supervisors beyond that routinely provided
- to all newly hired or transferred workers. Paragraph 5.d(3)(b).
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Radia' tion detection instruments needed to measure radiation in the high range during a criticality incident are not available at all times. Para-graph-6.b. '
(b)- Recommendations Provide additional and mandatory industrial safety i training to supervisors.
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Adjust the calibration schedule for high' range radiation detection instruments to ensure that
, sufficient instruments are available at all times.
(3) Housekeeping' f
f (a) Observations 1
) Generally, housekeeping throughout the facility was excel-l 1ent. No significant quantities of combustible trash were
- allowed to accumulate. Paragraphs 4.b. and 5.d.(2).
)4 (b) Recommendations
, None
- (4) Reviews and Audits (a) Observations 1 --
No routine audits or overviews of the: health physics, the industrial safety, the fire safety programs or the i
Radiological Contingency Plan are conducted'by groups or organizations not involved in the activities,~other. ,
,. than by the-licensee's insurance carrier. Paragraph I 5.b.
There is no apparent division: management involvement, I
in the review of nuclear criticality safety inspection findings. Paragraph 5.d.(1)(b).
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~. 7 Records of nuclear' criticality safety' inspections and audits are maintained on a computer. These records are so cryptic.that the personnel generating the -
records are not always able to interpret the
,_ entries. Paragraph 5.d(1)(b) and (c).
There is no tracking system established to assure
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i that all_ nuclear criticality safety audit findings have-been corrected. -Paragraph 5.d(1)(c);
The licensee's operations departments have established " shop" safety committees that tour their assigned areas to identify housekeeping, fire, and industrial safety inadequacies. However,.the.
licensee has not established a nuclear ~ criticality.
safety committee to periodically review the nuclear safety aspects of the facility. , Paragraph 5.d(3)(a).
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- b. Recommendations h --
Establish a program to assure that reviews _and audits in the following. areas are conducted by persons not associated with the operations.(i.e., knowledgeable, but independent):
j health physics program
- industrial safety program
- fire safety program Radiological Contingency Plan.
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With regard to nuclear criticality safety inspections and audits, assure that:
i division management is informed about the_results of these inspections and audits t
records of the results of-these inspections and audits are maintained in a manner that allows i license personnel to understand the documented information l a' system is established to track the corrective actions taken in response to audit findings-4 I
a division' nuclear criticality safety _ committee is established to review the nuclear safety aspects of the facility.
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- 8 (5) Administrative Controls (a) Observations In general, the licensee's system for the control of manufacturing procedures and other manufacturing documents administered by the " Process Instruction Control Center (PICC)" was found to be effective.
However, control over procedures and other documents that are not controlled by the PICC was found to be weak. These included, but are not limited to, Ma-terial Review Board postings, nuclear criticality safety signs, health physics department procedures, shop procedures (SPs), department administrative procedures and manuals, and the Radiological Contin-gency Plan. Paragraphs 5.c. and 6.a.
The format and content of route cards (used to control the movement of fuel bearing components) is not standardized to assure that all required infor-mation (e.g., nuclear criticality safety controls and limits) is presented in the same manner and in the same location in each route card. Paragraph 4.a.
(b) Recommendations Conduct an audit or review of all documents not controlled by the PICC and establish more effective methods for the control of these documents.
Standardize the format and content of route cards to assure that all required information is consistently presented on each route card.
(6) Personnel Training (a) Observations A specific UNC Naval Products Division policy that covers the requirements for training individuals in areas other than those required by the NRC license and fire safety training was not evident. Paragraphs 5.d.
(1)(a) and 5.d.(3)(b).
(b) Recommendations Design and implement industrial safety and nuclear criticality safety training programs for supervisors and engineers.
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9 Include a description of nuclear criticality safety controls used at the facility in the employee indoc-trination training session.
Assure that all new personnel, including management, have received required annual training.
(7) Emergency Planning (a) Observations The Radiological Contingency Plan (RCP) contains sev-
- eral weaknesses that should be addressed. It was determined that the format of the RCP is not consis-tent with the guidance contained in 10 CFR 50, Ap-pendix E, or NUREG-0762; that the RCP contains extraneous and outdated information; and, that there is a lack of information provided in several critical program areas. Paragraph 6.a.
Audits of the Radiological Contingency Plan were conducted by personnel responsible for implementation of the Plan. Paragraph 6.a.
There is no formal or controlled distribution of the Radiological Contingency Plan. Paragraph 6.a.
The Radiological Contingency Plan did not contain a description of the circumstances and types of re-sponses for which each emergency control center will be used. Paragraph 6.b.
The availability of only a single telephone line in the alternate emergency control center (AECC), for use by the Emergency Director and other key responders, has the potential to significantly inhibit information flow. Paragraph 6.c.
The licensee has not determined to.whom, in the State of Connecticut, information on emergency in-cidents should be transmitted and has not assured that the proper notification instructions are provided in the RCP. Paragraph 6.c.
Written agreements are provided with local agencies, with one exception. The agreements contained in the-RCP were not updated and current. Paragraph 6.c.
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10 Qualification criteria for key emergency response personnel (Emergency Directors, etc.) have not been established. Paragraph 6.e.
Emergency drills and tests conducted at the facility are not designed to test all aspects of the emergency plan. Paragraph 6.e.
Visitors entering the unclad fuel processing area do not receive adequate emergency training. Para-graph 6.e.
(b) Recommendations Review and revise the Radiological Contingency Plan to:
provide a format consiste't n with the guidance contained in 10 CFR 50, Appendix E or NUREG-0762 remove extraneous and outdated information include necessary information, such as a description of emergency response facilities incorporate procedures to assure formal or
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controlled distribution of the Plan describe the circumstances and types of responses-for which each emergency control center will be used provide for audit of the Plan implementation by independent personnel identify State of Connecticut contacts and proper notification instructions i
assure written agreements have been executed with, and are understood-by, all required offsite support groups establish qualification criteria for emergency _
response personnel assure emergency drills and tests, conducted at the facility, test all aspects of the emergency plan.
11 Evaluate the Alternate Emergency Control Center to: '
assure:
it is properly sized to accomodate.the require'd emergency response support staff ~
an-adequate number of telephone lines are avail-able.
Assure that visitors entering the-unclad fuel proces-
- l. sing area receive: adequate emergency training.
(8) Nuclear Criticality Safety -
(a) Observations Licensee personnel responsible for conducting nuclear.
criticality safety analyses did not have a-formal procedure that' established the mechanisms, techniques, or considerations required to perform a nuclear-criticality safety analysis. Paragraph 5.d.(1).
Not' all of t.he nuclear. criticality safety analyses specified limits on unit size, spacing between units,
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or control of hydrogen ;in all forms -(water, organic solvents, paper, plastic). Paragraph 5.d.(1)(a).
(b) Recommendations Establish a formal procedure for conducting nuclear criticality safety analyses to assure.that all:
required considerations have been. addressed.
Assure that hydrogen in al'1 forms-has been considered during the conduct of nuclear criticality safety analyses.
- 4. Process Review i
-l a. Fuel Component Manufacturing Area 1 Metal clad, fuel bearing components for the United States Navy Nuclear Power Propulsion Program are fabricated.in a controlled access area of Building B at the Montville site. ' Details of the
, fabrication process are classified as Confidential-Restricted Data-4 and, therefore, that process is not described in this report.
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o 12 Procedures for each step in the fabrication process are specified on route cards that accompany each fuel component throughout fabri-cation. The applicable procedures are located at each processing work station and are frequently used by the operators for reference.
In general,-there appear to be no significant chemical or explosive hazards in the fuel bearing component fabrication area that could affect the general public or the workers, with the possible exception of workers in the immediate area of an accident. Potentially haz-ardous materials used at the facility include acids, caustics, and organic solvents that are kept in drums and tanks, and uranium bearing materials. The licensee has established administrative controls that limit the quantity of radioactive materials and com-bustible materials stored or used in the fuel bearing component fabrication area of the facility. As a result, a fire in this area would not be expected to result in the release of significant quan-tities of radioactive materials to the environment. Other fire hazards present in the area are discussed in Paragraph 4.d.
Through an examination of route cards during a tour of the fuel bearing component fabrication area, the inspectors determined that the specification of nuclear criticality safety controls had not been standardized. Some of the route cards provided criticality safety controls on each page, others provided references to posted signs or other manufacturing procedures, and still others provided the criti-cality controls only on the route card cover page. The inspectors recommended that the licensee standardize the format and content of route cards to facilitate identification of nuclear criticality safety control information.
- b. Hazardous Material Storage and Use The inspectors observed that the licensee has large quantities of hazardous chemicals, used in the fuel bearing component manufacturing process, stored in large tanks (several hundred gallons or more) at the site. Those chemicals include nitric acid, hydrochloric acid,
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and hexane. In addition, several thousand gallons of used nitric and hydrofluoric acid are stored in tanks located south of Building M.
No inadequacies were identified in these storage installations.
Numerous other containers of hazardous materials, such as sodium hydroxide, alcohol, acetone, zircalloy, and various industrial solvents and caustics were stored in various locations outside the processing buildings, in separate storage buildings. These hazardous materials are brought into the processing buildings in appropriate small containers, as needed. Hydrofluoric acid is stored in small (one gallon) containers inside the processing buildings.
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13 The inspectors determined that the licensee has established an extensive program to assure the proper handling and storage of hazardous materials. All hazardous materials have been cataloged and their hazards identified in a safety manual that is available to all employees.through facility supervisors. While the handling of hazardous materials pose potential hazards to employees, there.is little potential for exposure of the general'public to those hazards.
All hazardous liquids are stored in large. tanks that are vented and grounded, and with the exception of hexane,.all are non-volatile and non-flammable. Acid'and hexane tanks are surrounded by catch basins capable of retaining the contents of the tank in case of leakage or rupture.
Based on the review of the licensee's hazardous materials storage and handling facilities and procedures, the inspectors determined that inadvertent releases should not have an adverse effect on the general public.
- c. Hexane Treatment System The inspectors determined, through discussions with licensee repre-
- sentatives and examination of processing equipment, that the licensee uses large quantities of hexane in the fabrication process and reuses the hexane after distillation to remove organic impurities. The hexane recovery distillation unit and associated retention tanks are located outside and about 100 yards south of Building B. Therefore, since the hexane treatment system is remote from the buildings, it should not pose a threat to the processing facility or the general public.
During examination of the hexane recovery distillation unit, the inspectors observed that the unit contained numerous operational and safety devices for regulating pressure and temperature. A main-tenance supervisor stated that an extensive preventive maintenance-(PM) program existed and is being carried out on the hexane equip-ment. However, at the time of this review, no PM records-or pro-cedures for this equipment could be located by licensee personnel.
Following discussions with the inspectors, licensee personnel agreed that this equipment should be formally included in the. facility preventive maintenance program. The licensee immediately. initiated-actions to assure that the hexane tanks and distillation recovery unit were included in the facility PM program.
Further review of the facility PM and equipment calibration programs by the inspectors indicated that they appeared to be extensive and thorough. Failure to document PM on the hexane equipment appeared to be an isolated case.
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- d. Zircalloy Handling and Storage The licensee uses zircalloy during fabrication of the fuel bearing components and generates large. quantities of zircalloy chips and shavings during machining operations. The unprocessed zircalloy is stored in argon filled bunkers located in a building about 150 feet west of Building B. During examination of this building, the in-spectors observed several holes (2-3 inch diameter) in the walls of the bunkers, about 10 feet from the floor. The inspectors stated that air entering the bunkers through these holes could provide sufficient oxygen to sustain combustion of the zircalloy and, there-fore, recommended that these holes be sealed.
During the zircalloy machining operations, the resultant accumulation of chips and shavings is periodically removed from the tray beneath the lathe and transferred to a closed container filled with water, as required by established procedure. At the end of each day, the closed containers are removed from the buildings and stored, unprotected, against the west wall of Building B. Subsequent to removal from the buildings, the water is drained f"om each container, the container is filled with argon gas and is then sealed. The containers are then retained for up to about three months prior to-shipment offsite.
The inspectors expressed concern about this method and the storage location. As a result of these concerns, the inspectors reviewed-the contents of the National Fire Protection Association " Standard for the Production, Processing, Handling, and Storage of Zirconium", NFPA 482-1982. The Standard also applies to zircalloy mixtures. The following zircalloy storage and handling weaknesses were_ identified when the licensee's practices were compared to the standard:
Fines (including chips) produced in wet operations are not kept wet by storing under water or oil until ultimate disposal by recycling or burning.
Oily lathe turnings and swarf are stored in the buildings in covered 55 gallon containers (rather than bucket size) and are not stored in protected, outside areas, that are remote from buildings.
It is recommended that the licensee review and revise its methods for the handling and storage of zircalloy waste material.
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- 5. Management Controls
- a. Organization Organizationally, one group, the Nuclear'and Industrial Safe'ty (NIS)
Department, is responsible for assuring safety at the Montville site. The basic responsibilities for the control of safety.are described in the Naval Products Division Policy Manual. Additional responsibilities and working relationships among the various groups are further defined in various department (engineering, operations, quality control) precedures in accordance with performance require-ments established by the Division President and his staff. The Nuclear and Industrial Safety. Department sets safety standards for the operating division to meet; monitors compliance with those standards; provides technical evaluation and advice to management; maintains cognizance of new or modified regulatory requirements; performs medical evaluation of personnel; provides specialized safety training to employees, the fire brigade, and the emergency directors; and conducts facility inspections in the areas of nuclear criticality safety, health physics and industrial safety.
- b. Quality Assurance / Quality Control Programs The licensee has a Quality Assurance / Quality Control.(QA/QC) Depart-ment to assure that fuel bearing components have been fabricated in accordance with U.S. Department of the Navy requirements. The li-censee's QA/QC Department activities are routinely reviewed by customer resident inspectors. The QA program includes plant audits, vendor audits, source inspection, receipt inspections, and extensive Quality Control (QC) inspections at various stages of the fuel com-ponent manufacturing and assembly process. A QA manual has been developed and extensive QA specifications exist to ensure the quality
, of the product. The QA organization is independent and reports, through the Vice-President, Quality Assurance, to the Division President. The emphasis of the facility QA/QC program is on product quality. QA personnel perform no audits or overview of health physics or industrial safety. The inspectors recommended that an audit / surveillance program be established by QA, or some other in-dependent organization, to provide periodic overview in these areas.
- c. Document Control The adequacy of the licensee's document control program was reviewed by the inspectors. In order to assure proper control of the manu-facturing process and to assure that correct procedures are at the work stations, an elaborate document control system has been estab-lished. This system is inplemented through a document control center called the Process Instruction Control Center (PICC). Documents i
controlled by PICC include route cards (RCs), manufacturing process
16 operating procedures (M0Ps), Process Sheets (PSs), and quality con-trol instructions (QIs). Based on the review conducted by the in-spectors, the document control program appears to adequately assure that current and correct revisions of procedures, controlled by the program, are available at the locations where they are to be used.
The inspector randomly sampled 12 M0Ps, 2 PSs and 2 QIs located at various work stations throughout the facility. Each procedure was the latest revision and had the appropriate approval signatures and document control numbers.
There are many other documents in the plant which are not part of the PICC system. These include but are not limited to, administra-tive control policies and procedures, criticality safety postings, and Material Review Board approved postings. Each of these documents is controlled by the department that generates the document. In each instance, implementation of the applicable document control system appeared to be weak. Document control deficiencies observed by the inspectors, for those documents not included in the PICC system, are as follows:
(1) Material Review Board (MRB) Postings Procedure MRP-010, " Prohibited Material Control Procedure",
which is a PICC controlled document, states in paragraph 5.1, in part, that each Material Control Zone will have the list of approved materials posted conspicuously. Revisions to the list will be made by the MRB. Administration of the system will be the responsibility of the Operations Department (distribution
, of revisions, etc.). The inspectors examined ten MRP material control signs posted throughout the plant. Errors were iden-tified on six of the ten signs examined. Those errors were immediately identified to licensee representatives and prompt corrective action was taken. Although the postings had no effect on safety, a serious potential document control problem exists.
(2) Nuclear Criticality Safety Signs The licensee has posted nuclear criticality safety signs at each work station in the facility. The inspectors examined a large number of these signs to assure that they were the latest revision. No inadequacies were identified. However, through discussions with licensee representatives, the inspectors de-termined that the licensee did not have an approved procedure that established the process by which the posted signs are maintained current. This was identified as a weakness in the l document control system and the inspector recommended that j the licensee prepare a procedure to ensure that all postings are ;
current. !
17 (3) Shop Procedure Control Shop Procedures (SPs) provide general instructions to workers concerning the operation of equipment (e.g., the hexane recovery distillation unit). Through discussions withl shop personnel, the inspectors determined that there was no established system for the control of these procedures and no mechanism to assure that the procedures, available at the~ work stations, are current.
As a result, the inspectors recommended that the licensee es-tablish controls over the shop procedures.
(4) Department Administrative Procedures and Manuals The inspectors determined through discussions with licensee representatives that there were essentially no controls established to ensure that the department administrative procedures and manuals are maintained up-to-date.
Based on the above observations, the inspectors concluded that con-trol over procedures and documents not implemented by the PICC could be improved. Therefore, it was recommended by the inspectors that the licensee conduct an audit or review of such procedures and docu-ments to identify inadequacies and then establish an effective means
, of control.
- d. Operational Safety (1) Nuclear Criticality Safety Controls During review of nuclear criticality safety controls, the in-spectors made a number of observations that indicated a need for improvement. Observations and recommendations pertaining to route cards were previously discussed in Paragraph 4.a., and recommendations for the control of nuclear criticality safety postings were discussed in Paragraph 5.c.(2). Additional observations and recommendations made by the inspectors with regard to nuclear criticality safety controls are as follows:
(a) Nuclear Criticality Safety Analyses The inspectors reviewed licensee records of internal nu-clear criticality safety _ analyses. The inspectors noted that the licensee's Nuclear and Industrial Safety (NIS)
Department, which is responsible for conducting the analyses, did not have a formal procedure that established the mechanisms, techniques or considerations required to perform a nuclear criticality safety analysis. Operations Department Procedure 300.20, " Request for NIS Authorization i
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18 for Criticality Control", provides a format for requesting changes to criticality safety postings. However, the methodology this procedure. to be used for the analyses is not addressed in The procedure and attendant form is used by sis,the andNIS theDepartment approval. to document the request, the analy-The inspectors.also noted that some of the requests appeared to be sufficiently cryptic to question the ability to perform an in-depth review.
During a review of the analyses conducted by the licensee within the past six months, the inspectors observed that not all of the analyses specified limits on unit size or spacing between units. In other instances, it was noted that there was no. limit specified for total hydrogen (moderation);
solvents) only hydrogen in liquid form (water, organic was specified.
The following recommendations were made by the inspectors:
A-procedure should be prepared by NIS to establish the mechanisms, techniques or other considerations required to perform a nuclear criticality safety analysis.
The request, the analysis, and the review should be well documented so that it can be understood by other UNC personnel and so that-the process can be audited.
NIS approval should include consideration of all license requirements, not just nuclear criticality controls.
Each nuclear criticality safety analysis should specify unit size and unit spacing limits.
1 Posted limits for each work station should include total hydrogen allowed (liquid and solid).
Approvals to include moderation (hydrogen) at work-stations or between fuel bearing components should-4 specify controls for hydrogen in non-liquid form.
(b) Nuclear Criticality Safety Inspections During a review of the licensee's nuclear criticality safety inspection program, the inspectors determined that NIS safety has established a procedure for conducting criticality inspections.
, This procedure requires Operations and 1 Quality Control personnel to take corrective actions when-
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violations are found. The procedure was not approved by
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the Operations or Quality Control Departments, but records indicated.that corrective actions were being taken by these' personnel, when required.
l The licensee's nuclear criticality safety inspectio'n t' program is monitored by a computer program called
" Audit." A monthly printout provides a listing.of open.
items, which may include violations, recommendations, and -
action items. .These open items are to be addressed during-
) each inspection._ It was noted that the computer. record of j the inspection findings was very cryptic and difficult to
, interpret. The Nuclear Criticality Specialist had to rely i on his memory.to interpret the computer record for the NRC team.
The licensee's inspectio'n program is designed to cover each-authorized work station during a calendar year, with about ten percent of the stations being inspected each month.
, However, the procedure does not -identify each work station -
! to be examined. Some, but.not all, operating areas are to be and were inspected every two. months on the second and third operating shifts.
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i Violations are~ reported by the NIS. inspector 'to the area
. or group manager and to the NIS_ Manager. The area super-
! visor reports the corrective. action taken to the-NIS l Manager. A record of'the violation observed and-the I
corrective action taken is maintained on a violation form retained in the NIS files. <
During the tour of the facilities, discussions were held .
I by the NRC assessment -team members with .the two NIS per-sonnel who conduct monthly inspections. The NIS personnel
- could not explain the limits on two criticality limit postings or how operations personnel could satisfy the.
posted criticality -limits.
In order to improve the licensee's nuclear criticality
, safety inspection program, theLinspectors made the y following' recommendations:
Copies of NIS inspection findings and corrective action-reports should be provided to. facility management so-that they-can be examined for generic, facility-wide
- implications and so that management is aware of.the.
} -findings.
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.c 20 The computer program " Audit". record should be modified so that the inspection findings.are readable by in-dividuals familiar with the licensee's program.
The inspection procedure should require that all operating areas be inspected at a specified frequency during second and third shifts.
NIS inspectors should be trained in the interpretation of posted criticality limits so that meaningful in-spections are performed.
(c) Nuclear Criticality Safety Audits The inspectors examined licensee records of nuclear criticality safety audits. The audit program consists of an annual audit by a consultant who submits a written report to the Division President. The consultant develops.
his audit plan from a UNC procedure that identifies the potential audit areas. In response to the 1985'and 1986 written audit reports, the Division President sent the consultant (auditor) a letter specifying the corrective actions taken.
The " Audit" computer program described previously is also used by the licensee to track the actions taken to correct the items identified during the audits. The computer record is so poor and cryptic that it does not even iden-tify the source of the item, e.g. , the audit report.
During the review of the 1985 audit report, the inspector i observed that the auditor recommended that a specified periodic action be taken by UNC. UNC personnel closed the recommendation when the initial action was taken. However, licensee records reviewed by the inspector indicated that no periodic action was taken since the initial action. As a result of this observation, the inspectors pointed out that the licensee had not established a system for assuring that " periodic" actions have been taken, when required.
As a result, the inspectors recommended that the ifcensee:
establish a tracking system to assure that " periodic" actions are taken, when required.
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(d) Nuclear Criticality Safety Training--
4 During a-review-of the nuclear criticality safety training
. program provided to new employees'by the licensee, the' .
< inspectors determined that the training consists'of a
. lecture, a handout, an Oak Ridge video tape,-and an' exam-
- ination.
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-The handout-(NIS-84-2-35),~which is distribute'd duringithe .
lecture, was also reviewed by the. inspectors. The handout gave a definitiori of a nuclear neutron-chain reaction and described some of the controls that the UNC employs for criticality control.
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!- The inspectors noted that the new Division President-had.
not' received new employee training. It was-also noted that the new employee training program did not cover all 4
criticality. safety control. methods.used by the licensee.
. In addition, through discussions with licensee representa-tives, the inspectors determined that the licensee did'not-2 provide technical training in.the-area of nuclear criti-cality safety to engineers and supervisors, other than that described above.
l As a result ofLthese observations, the inspectors made the 4
following recommendations:
The new Division President ~should be trained as soon as possible.
l-The training program provided to workers should dis-i cussf all nuclear criticality safety. control methods.
- used by the licensee.
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The licensee should establish a~ technical nuclear
- criticality saf,ety training program for engineers and
- supervisors. s
) (2) Fire Protection In order to assess the'1,icensee's fire protection program,.the
- inspectors examined the administration and organization of the facility fire protection program. .This included review of
- administrative controls on combustibles and ignition sources;
- equipment maintenance and inspection procedures; and fire
- brigade training. '
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22 (a) Administrative Controls on Combustibles and Ignition Sources The inspectors verified through a review of licensee documents that the licensee had developed and implemented fire protection and prevention procedures to assure adequate protection of the workers and facilities. The documents reviewed included the Supervisors Guide, numerous department process and material handling pro-cedures, and the Division Policy and Procedures Manual.
During a tour of the facility the inspectors also verified that the procedures examined by the inspectors were properly implemented by the licensee. No unacceptable conditions were identified.
(b) Equipment Maintenance, Inspection, and Tests The inspectors examined licensee documents to determine if the licensee had developed procedures that established maintenance, inspection and testing requirements for the facility fire protection equipment. No inadequacies were identified. The inspectors also examined the equipment maintenance / inspection / test records to verify compliance with the established procedures.
The inspectors noted through a review of records that the licensee conducted annual tests on the Dry Barrel fire hydrants located throughout the site. The inspectors recommended that the licensee conduct these tests semi-annually as recommended by the National Fire Protection Association (NFPA) in accordance with the American Water Works Association (AWWA) Manual 17, " Installation, Operation and Maintenance of Fire Hydrants."
The inspectors noted that the licensee has a Cummins Engine Company diesel-oil powered fire pump available at the site but does not check the diesel fuel oil in accord-ance with the ASTM D-4057-81 requirements. The inspectors recommended that a sample of fuel oil be obtained in ac-cordance with ASTM D-4057-81 requirements to assure that it is within the acceptable limits, as specified in Table 1 of ASTM D-975-81, for viscosity, water and sediment. These checks should be conducted every three months. The inspec-tors also informed the licensee that Cummins fire pumps, similar to the one observed onsite, have developed flywheel cracks. The NRC has issued Information Notice No. 84-92 which advises licensees of this problem. However, UNC apparently did not receive this Information Notice, which
- O 23 was issued only to power reactor licensees. As a result, the inspector recommended that the licensee check the Cummins fire pump flywheel for cracks and replace the flywheel, if necessary.
(c) Fire Brigade Training The inspectors examined the licensee's requirements and records of fire brigade training and retraining. The in-spectors determined that the licensee maintains a well-trained brigade consisting of about 42 members. Training sessions are held at least monthly and include both classroom and practical training. One of the inspectors participated in the monthly training session during this inspection. Each member of the fire brigade obtains about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of training each year and the brigade officers receive additional training from regional community-sponsored firefighting schools. Members of the local com-munity fire departments also participate in training on the site. The inspectors did not identify any unacceptable conditions in this training program.
(d) Facility Tour During a tour of the facility, the inspectors examined fire protection systems, including piping and distribution sys-tems, post indicator valves, hydrants, contents of hose houses, fire detection and alarm systems, automatic and manual fire suppression systems, fire barriers, and fire doors. The inspector noted that water hoses were tested hydrostatically on the required frequency, that house-keeping in the facility was excellent and that portable fire extinguishers were inspected at the required fre-quency. No deterioration of equipment was observed.
The inspector observed that a CO 2 flooding fire suppression system had been installed in the Unit 2 area pit. The inspectors requested records of the acceptance tests on this system to verify that the proper C02concentrations have been achieved for the required duration, as specified in the NFPA Standard No. 12. The licensee stated that this testing did not take place. The inspectors. recommended that, because of the inaccessibility of the pit area for manual firefighting, the C0 2 fire suppression system for this area should meet the appropriate NFPA Standard. The inspectors also recommended that a combustible free zone be established around the autoclaves located in the Sectioning i Area to prevent the accidental storage of flammables (i.e., l organic solvents, spray cans, etc.) on top of the auto- )
claves.
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24 (3) Radiation Protection and Industrial Safety The industrial safety organization consists of an industrial safety specialist and two staff members, i.e., a safety engineer and a safety equipment technician. The organizational structure and responsibilities of the industrial safety function at this facility were previously described in Paragraph 5.a.
(a) Safety Committees Although the licensee is not required to have, and does not have, a nuclear safety committee, each of the operations departments have established a " shop" safety committee that tours its assigned areas of the facility every two months.
The membership of each committee consists of: the area production shop manager, two hourly employees, invited NPD managers, and the NIS department representative. Reports are issued for each tour. These reports identify defi-ciencies, if found, corrective actions required, and in-dividuals responsible for corrective actions. No inade-quacies were identified with regard to these " shop" safety committees. However, the inspectors recommended that the licensee establish a nuclear safety committee to examine and review the nuclear criticality safety aspects of the facility.
(b) Enforcement of Industrial Safety Requirements It was noted by the inspectors through a review of policy manuals and discussions with licensee representatives that the enforcement of safety requirements throughout the fa-cility is the responsibility of supervisors. For non-routine hazardous work, a special work permit (SWP) is required. SWPs are completed and issued by the area super-visor. However, it was also noted by the inspectors that there is no mandatory industrial safety and hygiene train-ing for supervisors beyond that provided for all newly hired or transferred employees. In order to compensate for this lack of mandatory training, the NIS industrial safety section personnel have conducted a four-hour safety train-ing course for supervisors and have made a National Safety Council course in industrial safety available, free of charge, to supervisors. As of the date of this inspection, only about one-third of the supervisors have taken this voluntary safety training. The inspectors recommended that ,
1 the licensee establish mandatory industrial safety training for supervisors, beyond that routinely provided to newly hired or transferred employees. )
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- 6. Emergency Planning
- a. Radiological Contingency Plan and Implementing Procedures The inspectors initiated a review of emergency planning at this fa-cility by examining the contents of the Radiological Contingency Plan (RCP) and the Emergency Manual. The Manager, Nuclear and Industrial Safety (NIS) Department is responsible for carrying out the major functions of the emergency preparedness program. He is assisted by the Health Physics Specialist. The Emergency Manual contains the RCP implementing procedures. The inspectors determined that an emergency organization, resources, and planning arrangements have been estab-lished to respond to criticality, fire, bomb threat, power outage, civil disturbance, uncontrolled environmental release, natural disaster, and transportation incidents. Although the RCP adequately identifies particular types of incidents requiring implementation of an emergency response, the inspectors identified several weaknesses that should be addressed, e.g., the RCP contains extraneous infor-mation, overlaps with the Emergency Manual, and in some cases does not reflect the actual emergency preparedness program. The inspec-tors believe that these deficiencies result from a lack of review of the overall emergency plan by an independent audit group. No review of the RCP, the Emergency Manual, training, equipment, or interfaces with state or local governments have been conducted since the RCP became effective. The inspectors also found that neither the RCP nor the Emergency Manual are controlled through a formal distribution process. Copies of the Emergency Manual are made available to some offsite authorities, but the licensee has not distributed the RCP to all groups that would be required to support responses to an emer-gency at the facility.
The inspectors recommended the following items for consideration by the licensee:
Modify the format of the Radiological Contingency Plan to be consistent with 10 CFR 50, Appendix E, or NUREG-0762, " Standard Content and Format for Radiological Contingency Plans."
Extraneous and outdated information in the RCP should be eliminated. Information generated and implemented prior to the 1981 NRC Order requiring a Radiological Contingency Plan should be revised, as necessary. Unnecessary classified information, process descriptions, and implementing procedures should be deleted. The licensee should consider condensing the existing RCP through the elimination of safety standards and equipment descriptions, nuclear alarm coverage calculations, procedures and instructions, telephone numbers and expired letters of agreement that are currently contained in the Emergency Manual.
O O 26 Include in the RCP information in several critical program areas, including: description of emergency response facilities (pump house, central alarm station); a description of the emergency support staff; conduct of RCP audits; responsibility for RCP maintenance; methods of conducting drills and exercises; training of site and corporate emergency staff; primary and backup communications capability; protective action recommen-dations consistent with incident type; and current letters of agreement with supporting offsite agencies.
Regular audits of the RCP should be conducted by personnel who do not have direct responsibility for Plan implementation. The audits should cover major RCP areas, such as, the Emergency Manual, training of emergency personnel etc. Results of these audits, including recommendations for improvements, should be submitted to appropriate licensee management.
Formalize and control distribution of the RCP to ensure that key members of the emergency organization, the NRC Office of Nuclear Material Safety and Safeguards, NRC Region I, and off-site authorities receive updates and changes,
- b. Facilities and Equipment The inspectors toured the pump house, first aid stations, central alarm station (CAS), secondary alarm station (SAS), and health physics office. These facilities are to be used for emergency response purposes. During the tours of these facilities, the in-spectors examined emergency kits and lockers, communications equip-ment, criticality monitoring equipment, radiological survey instru-ments, and first aid supplies. The facilities and equipment are as described in the Emergency Manual (in lieu of the RCP) and appear adequate for response to criticality and other potential nuclear related incidents at the UNC Montville facilities. Eyewash fountains and acid showers were also inspected and found to be in working order.
The pump house is used as the emergency control center for critical-ity and other types of emergencies where facility evacuations are required. The CAS is used as the emergency control center for non-radiological incidents. Emergency equipment lockers are located in the health physics office, pump house (also includes medical sup-plies) and at other selected locations around the site. The lockers are inventoried by the Health Physics Specialist.at least quarterly.
Inspection of lockers and review of inventory records indicated that equipment was available, maintained, and in operable condition.
However, the inspectors found that all of the high range radiation detection instruments designated for use during criticality emer-gencies are unavailable one day every six months. All of these instruments are sent out for calibration at the same time. i l
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27 The following recommendations were made as a result of the in-spector's observations:
The RCP should describe the circumstances and types of response each emergency control center (pump house and CAS) will be used for.
The calibration frequency of high range radiation detection instruments should be staggered to ensure that sufficient in-struments are available at all times.
- c. Notifications and Communications The telephone network used for communications by personnel throughout the site is also used to report emergencies. During working hours, the caller dials telephone extension 333 fthe emergency telephone number identified at each telephone ext.enhion at the site) and is connected to the site security Central A1.;rm Station. Security per-sonnel have been instructed to notify a qualified on-site Emergency Director (ED). On weekends and holidays, the senior company security supervisor on site assumes the E0 role and initiates notification to senior UNC management personnel. Individuals designated to serve as ED have also been instructed to notify cmergency response personnel listed on the call-out forms, which includes outside support groups, via telephone or an emergency hot line. An on-site paging network and portable radios are also designated as backup communication sources. The inspectors noted that the NRC's emergency notification system telephones were available in the CAS, the Division President's office, the pump house and the Secondary Alarm Station (SAS). How-ever, only one other telephone line is available for use in the pump house (the emergency control center during facility evacuations),
and thus has the potential to significantly inhibit information flow. The inspectors also determined that the licensee uses a nuclear incident report form to make notifications to the State of Connecticut. Although not designed for fuel facility use (this form was designed for use by power reactor facilities in the state), this form appears to provide useful information to the State. However, through a review of the RCP and discussions with licensee representa-tives, the inspectors could not determine when this form was to be used and to whom in the State the information is to be transmitted (State Police, Civil Defense Agency, Department of Environmental Protection,etc.).
Primary and backup communication systems are adequate for emergency response purposes, but the following recommendations for improvement were made by the inspectors:
The communications equipment in the Alternate Emergency Control Center should be evaluated and any indicated corrective action taken.
28 The licensee should determine to whom, in the State, information on emergency incidents should be transmitted and assure that the proper notification instructions are provided in the RCP.
- d. Coordination with Offsite Groups The inspectors reviewed the RCP and Letters of Agreement with offsite agencies and support personnel, and then contacted four representa-tives of these agencies to verify their understanding of the agency's role and responsibilities in response to an incident at the Montville site. Offsite support groups contacted by the inspectors, and their primary emergency function, were: Connecticut State Police (Mont-ville Barracks) - traffic control of interstate highways around the site; Lawrence and Memorial (L and M) Hospital - treatment of criti-cality victims; William Backus Hospital - treatment of chemical or nonradiological accident victims; and the Mohegen Fire Company -
firefighting and ambulance services. Each representative expressed a clear understanding of its group's respective role and respon-sibility. The inspectors found that arrangements for technical and administrative support with each group were consistent with the language specified in the Letters of Agreement, with the exception of that arranged with Backus Hospital. This Letter of Agreement pro-vides for the treatment of patients involved in radiation emergen-cies. However, according to licensee representatives, this function will be performed at the L and M Hospital.
The inspectors determined that close working relationships with offsite support groups were established by the licensee. Support group representatives interviewed by the inspectors were aware of the licensee's operation, had been provided with site orientation, and were prepared to honor their Letter of Agreement by providing support to the licensee, upon request. Drills or exercises have been held annually with State Police, local fire departments, and ambulance services. The inspectors also reviewed the manual entitled " Emergency Medical Handling of Radiation Accident Patients",
dated September 1986, developed by the NIS Department, and determined that it adequate.y covers medical arrangements (radiological and other trauma) to treat patients on site or at the L and M Hospital.
In addition, it outlines basic site operations, types of accidents, and provides first aid procedures, for reference during training sessions.
The following items are recommended by the inspectors for licensee improvement:
Clarify the role of Backus Hospital for providing specialized medical treatment and revise the Letter of Agreement accord-ingly.
- 29 W
Ensure that Letters of Agreement included in the RCP are updated and current.
- e. Training, Drills and Exercises The inspectors reviewed a videotape shown to new employees for indoctrination training. The tape covers basic site information, operating procedures, criticality safety, fire safety, and radio-logical controls, in addition to emergency alarm, evacuation and accountability instructions. Following interviews with workers in Building C and Building B-South, the inspectors determined that initial (and requalification) training for immediate employee response, during emergencies, appears to be effective. When the inspectors toured the facilities, and prior to entry into Building B-South, it was determined that a "B-South Temporary Access Form" was provided to each visitor, including the inspectors, for signature.
The form indicates that specific training in emergency response, health physics contamination control, criticality control, and SNM safeguar Js and security has been given to the visitor. However, no such training was provided to visitors except for an evacuation map issued upon initial entrance to the site.
Training of Emergency Directors to carry out emergency functions consists of participation in drills and classroom instruction pro-vided by the Manager, Facilities Engineering. Qualification criteria for each specific emergency duty have not been established. Per-sonnel are selected as Emergency Directors based upon their back-ground and experience. Discussions held with training department representatives by the inspectors revealed that all key managers, trained as ED's, can respond to different types of accidents. The inspectors consider that this concept is adequate to provide a prompt response and make an on-the scene evaluation of the incident. How-ever, there appears to be no definition or description in the RCP of personnel and task assignments within the emergency organization, other than the Emergency Director position. Typical task assignments, dependent on the type of incident, could include the
- areas of health physics, protective actions, security, operations, and accident assessment.
Drills, held annually, provide training in site evacuation procedures to personnel with respect to simulated criticality incidents. A drill is also conducted annually to test personnel evacuation re-
' sponse to a simulated hexane spill or release. Medical emergency and fire drills are condtcted quarterly. Although various types of drills are held each year, a comprehensive exercise to simultaneously test all portions of the licensee's RCP and emergency response capability has not been conducted.
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.*. 30 The inspectors reviewed reports of drills held in 1985 and 1986 and determined that critiques were held that identified deficient areas.
The inspectors also determined that the Health Physics Specialist.
follows up on identified program weaknesses with appropriate cor-rective actions.
As a result of these observations, the inspectors made the following recommendations:
Ensure that visitors entering the unclad fuel processing area receive the training outlined on the B-South Temporary Access Form.
Define and describe task assignments for personnel reporting to the Emergency Director and establish qualification criteria for each duty or assignment. ,
Conduct exercises that simultaneously test as many areas of the RCP as possible to a variety of simulated accidents (radio-logical and non-radiological) having a potential for offsite impact. The exercises should provide for an integrated response by facility and offsite groups expected to be involved.
- 7. Exit Interview The inspectors met with the licensee representatives indicated in Para-graph 1 at the end of the inspection on October 3, 1986. The inspector summarized the scope and findings of the inspection.
No written information was supplied to the licensee by the inspector during this inspection.
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