ML20207U072

Operational Safety Assessment Insp Rept 70-1201/87-02 on 870202-06.No Violations Identified.Four Weaknesses & 32 Improvement Items Re Emergency Contingency Planning,Fire Protection,Maint & Nuclear Criticality Safety Identified

ML20207U072
Person / Time
Site:	07001201
Issue date:	02/27/1987
From:	Ketzlach N, Mcalpine E, Sly D, Tabaka A, Troup G, Wiseman G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20207U067	List: ML20207U066 ML20207U072
References
70-1201-87-02, 70-1201-87-2, NUDOCS 8703240585
Download: ML20207U072 (35)

Text

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@ MO: UNITE 5 STATES o NUCLEAR REGULATORY COMMISSION l[ , REGION 11 '

g 'j 101 MARIETTA STREET, N.W.

• ATLANTA. GEORGI A 3o323 s.,+... /

Report No.: 70-1201/87-02 Licensee: Babcock and Wilcox Company Commercial Nuclear Fuel Plant Lynchburg, VA 24506-1646 Docket No.: 70-1201 License No.: SNM-1168 Facility Name: Commercial Nuclear Fuel Plant Inspection Conducted: F bru -6, 1987 Inspectors: M E7!87 Date Signed G. L . Trou~p,' Team pader Fuel Facility oaect Manager, RII

- zk2/s7 N. Ketzlach, Sinior Scientist Date Signed Uranium Fuel Lice ing Branch, NMSS s b D. K. 51y' Se'nior/ Fuel Facility Engineer, IE E7!6 ~/

Date Signed AA%

A. E. Tabaka, Radiation Specialist, RII A&

Date S'ig'ned OWh 7 G. R. Wiseihan, Fire Motection Engineer, RII k 2/27/8 7 Date Signed Accompanying Personnel: W. E. Cline, Chief Nuclear Materials Safety and Safeguards Branch, RII Approved by: B M ' d_ ' N E. J. McA' pine, Chief P 2.[27{f7 Date Signed Material Control and Accountability,Section Nuclear Materials Safety and Safeguards Branch, Division of Radiation Safety and Safeguards s

SUMMARY

Scope: This special, announced ' inspection involved an , operational safety assessment of the Babcock and Wilcox Commercial Nuclear,. Fuel Plant (CNFP) in

Lynchburg, Virginia to determine whether .there are potential operational cafety l hazards which, when combined with facility operations, could adversely impact the j health and safety of the public or workers at the plant.

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Results: No violations were identified. Four weaknesses and 32 improvement items pertaining to operational safety and relating to emergency contingency planning, fire protection, maintenance, nuclear criticality safety, and chemical process safety programs were identified.

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W TABLE OF CONTENTS

1. Persons Contacted-------------------------------------------------------1

2. Exit Interview----------------------------------------------------------I

3. Inspection Scope--------------------------------------------------------I

a. Assessment Methodology---------------------------------------------I

b. Lessons Learned----------------------------------------------------1

4. Plant Operations--------------------------------------------------------2

a. Fu e l Ma n u f a c t u r i n g -------------------------------------------------2

b. Mechanical Manufacturing-------------------------------------------2

c. Uranium Storage----------------------------------------------------2

d. Failed Fuel Rod Detection System-----------------------------------2

5. Management Controis-----------------------------------------------------2

s. Organization-------------------------------------------------------2

b. Training-----------------------------------------------------------3

6. Neelear Criticality Safety----------------------------------------------4

a. Analysis-----------------------------------------------------------4

b. Fue l Handl i ng and S to rag e -P rocedure s-------------------------------4

c. Audits and Inspections---------------------------------------------5

7. Fi re P ro t e c t i o r,/ P rev e n t i o n P rog ram--------------------------------------7

a. Summary of Facility Design, Construction and Fire Protection Features----------------------------------------------7

b. Fi re Prevention Admi ni stration Control Procedure s------------------8

c. Fire Protection Systems Inspection and Maintenance Program---------9

d. Si te Eme rg e ncy ( Fi re B ri gade ) Team--------------------------------11

e. Assessment of Fire Potential--------------------------------------15

8. Chemical Process Safety------------------------------------------------16

a. General-----------------------------------------------------------16

b. Hazards Communication Programs------------------------------------17

c. Chemical Storage--------------------------------------------------17

9. Operations Engineering-------------------------------------------------18

a. Lessons Learned---------------------------------------------------18

b. Ma i n te n a n c e o f Li f t i n g De v i ce s------------------------------------19

10. Evaluation of Accident Potential---------------------------------------19

11. Radiological Contingency Plan------------------------------------------19

a. Emergency Classification and Notification-------------------------20

b. Emergency Facilities and Equipment--------------------------------22

c. Training and Performance of Drills--------------------------------25

d. Offsite Agency Coordination and Training--------------------------28 Administration and Maintenance of Programs------------------------29 l

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' REPORT DETAILS

1. . Persons Contacted Licensee Employees R. A. Alto, Plant Manager

'*W. T. Engelke,' Manager, Quality and Safety

• 0. V. Ferree, Manager, Manufacturing

• B. W. Pugh, Manager, Production and Material Control

• J. T. Ford, Manager, Fuel Manufacturing

• K..E. Shy, Health Physicist

• J. P. Watters, License and Control Administrator The team also interviewed other licensee employees including health physics, maintenance and manufacturing personnel.

' Other Organizations F. M. Alcorn, Nuclear Safety Engineer, B&W LRC R. W. Loving, Manager, Security, B&W NNFD

• Attended exit interview

2. Exit Interview The assessment scope and findings were summarized on February 6, 1987, with those persons indicated in paragraph 1 above. No dissenting comments were received from the licensee. The weaknesses and improvement items identified during the assessment were reported to licensee management.

3. Inspection Scope j a. Assessment Methodology The assessment involved identification of accident potentials, determination of the adequacy of controls to prevent accidents, review of the licensee's maintenance and surveillance programs which assure i that controls would be operative to prevent an accident, and assessment of the licensee's ability to mitigate the effects and consequences should an accident occur. Programmatic assessments were performed of management controls, emergency contingency plans, nuclear criticality safety, fire protection, chemical process safety and operations

j. engineering (maintenance).

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b. Lessons Learned NUREG-1198, " Release of UF6 From a Ruptured Model 48Y Cylinder at I Sequoyah Fuels Corporation Facility: Lessons - Learned Report" l

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' discussed the ~ findings of the accident at Sequoyah Fuels Corporation '

and listed recommendations to prevent or mitigate accidents. The assessment included a review of the NUREG-1198 recommendations and the licensee's conformance with the recommendations. As CNFP operations do not involve-UF6 (paragraph 4), the. recommendations of Section:2 of the -

report were not. applicable to this' assessment except.for recommendation 2.3.2(2) (paragraph 9.a). The recommendations ' of Section- 3.1 were .

evaluated as part of the Radiological Contingency Plan (paragraph 11).

4. Plant Operations

a. . Fuel Manufacturing Finished uranium dioxide pellets are received from a supplier' and loaded into fuel ' rods. Completion of the rods, fabrication of fuel assemblies, and storage of the assemblies are licensed activities. No activities -involving vaporization of UF6, chemical conversion, or pellet _ manufacturing are conducted on site.

b. Mechanical Manufacturing Components for the . fuel assembly structural members, and other special manufacturing activities conducted in the plant are not NRC-licensed activities. However, they are conducted .in shared or contiguous plant areas. Certain of the operations were reviewed by the team because of

the potential for a fire or accident in those areas affecting licensed activities,

c. Uranium Storage The licensee is authorized to possess for storage purposes only 'UF6 (both natural and enriched) and uranium oxides (natural only). The UF6 is stored in an outside area while the oxides are stored in a separate:

building. The stored materials were reviewed by the team as a potential source of an accident and as contributors to the consequences of an accident.

d. ' Failed Fuel Rod Detection System The licensee is authorized to have and maintain a failed fuel rod detection system (ECHO-330), which is in a separate area of the ' plant -

site from the uranium operations. This system was judged by the team to be of a low potential for an accident. No further review action was necessary.

5. Management Controls

a. Organization Babcock and Wilcox (B&W) is a wholly-owned subsidiary of the McDermott Company. The Commercial Nuclear Fuel Plant (CNFP) is a unit of the '

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3 Nuclear Power Division (NPD) of B&W. Basic management policy used at the ' CNFP stems from McDermott Corporate policy and subpolicies developed by NPD. As a result, no separate policy manual for the CNFP exists and the authority for defining the responsibility and methods for preparing, _ reviewing, authorizing and issuing CNFP operating procedures rests with McDermott corporate policy 0131-005.

The functional organization of the CNFP is established on Organization and Responsibility charts. The functional organization included in the license has .recently been changed to include four major functional sections. These sections are Quality and Safety, Production and Material Control, Field Operations, and Manufacturing. Six additional sections support the four major sections.

Procedures have been written by each functional section to cover activities in the areas of responsibility. These procedures appear to be comprehensive and up-to-date. The document control system is adequate to ensure that new and revised procedures are distributed by management to the user.

The management controls in place appear to be effective for current activities,

b. Training Formal employee training is provided for employees at the facility in the areas 'of radiation and industrial safety. Radiation safety refresher courses are presented to employees on an annual basis.

Emergency response procedures are also reviewed on an annual basis.

Formal industrial safety training consists of instruction in specific areas such 'as hazards communication, fire extinguishers and lifting devices. Formal specialized technical and managerial courses are presented off. site by a corporate training group. Formal training is recorded in class attendance records and in a computerized training history file.

Worker training in specific job categories is accomplished through on-the-job training of new employees by experienced employees. Some jobs such as welding and mobile equipment operation require formal certification.

The scope and implementation of the program, excluding fire and emergency training, which are addressed in sections 7.d(3) and 11.c, is judged to be adequate for a facility of this type and size.

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6. Nuclear Criticality Safety

a. Analysis

' The process for approval of procedures and - changes thereto .were reviewed. The following observations were made:

Pre-operational safety evaluation records were found to be complete and

. included:

(1) Pre-operational reviews and approvals (2)' Analyses made by Health-Safety and/or the Nuclear Criticality Safety Group (NCSG)

(3) NCSG evaluations included those made by the qualified independent' reviewer (4) License amendment and related Safety Evaluation Report (when a-license amendment was required)

The license application permits the Safety Review Committee (SRC)

Chairman or his designee- to determine whether a proposed facility modification must be reviewed and approved by the NCSG before the modification may be implemented. If a modification is determined not to require prior NCSG approval, then the nuclear safety evaluation may be performed by the CNFP staff. The Health-Safety Supervisor is the designee who performs these nuclear criticality safety evaluations using approved surface density criteria. The NCSG had informally advised the Health-Safety Supervisor to have a second party independently " check the arithmetic" of nuclear criticality safety evaluations before the results of calculations were implemented. The team observed that recent Health-Safety surface density calculations were not initialed by a checker. The Health-Safety Supervisor stated that the checker had not only reviewed the calculations but also had reviewed the applicable drawing indicating the layout of the proposed work station locations. Review of the calculations and analysis by the NCSG may not occur until the next quarterly review. The guidance for

. the Health-Safety Supervisor which specifies the analyses he is authorized to perform without NCSG approval prior to implementing the results, and the confirmation requirements for checking the calcula-tions are not established in a procedure which has received concurrence from NCSG.

b. Fuel Handling and Storage Procedures The team noted an inconsistency in the instructions located in the work areas for fighting fires. The work area instructions specified that no fire hoses were allowed in the fuel rod assembly and fuel assembly storage areas without approval. In the fuel assembly storage area and the fuel rod assembly area, instructions require approval by supervision and by Health-Safety, respectively. The license

5 application provides that the use of a single hose may be authorized by a knowledgeable management representative of the _ plant emergency response organization. The team noted the lack of consistency between the approval requirements for the use of a fire hose, where otherwise prohibited.

The Lteam noted that fuel assembly structural ' con caants (containing no SNM) were stored in the aisles between fuel assei tes (at an elevation no higher than the bottom of the fuel in the as- .ty) and within.the rows of assemblies. There was no approved writ' n procedure for such storage. It is not considered to be good practice to store materials in the aisles of fuel assembly storage arrays without a _ written approval. If no other location for the.. storage of the non-SNM materials is available, a review of the materials to be stored should be made, . nuclear criticality safety criteria (e.g., materials to be stored, storage locations within the array) should be developed to ensure no potential hazard is introduced (e.g., introduction of moderation), and procedures should be written and approved before their implementation.

-Safe transport carts are used for fuel rods, poison rods, and fuel rod trays (with or without fuel rods). A procedure had not been developed for the multipurpose use of safe carts which specifies that no more than one type material may be on the cart at any given time. Stacking fuel -rod trays no higher than four high whether loaded or unloaded is .

recommended.

The Health-Safety Audit Procedure (AS-1125, Rev. 6) references Exhibit A as the form being used by the outside CNFP independent auditor when, in fact, it is not used by him. Exhibit B, however, for use in reporting Health-Safety weekly audits is not mentioned in I the procedure text. This audit procedure was not consistent with CNFP practices and commitments.

c. Audits and Inspections A Health-Safety technician performs a daily inspection of the facility for conformance to both radiation and nuclear criticality safety operating procedure requirements. Reports of his findings, as well as the weekly safety audit reports prepared by the Health Physicist and the quarterly audit reports prepared by a member of the NCSG (Lynchburg Research Center) were reviewed. The team noted that the inspection and audits met the requirements of the license. It was noted, however, that the NCSG audits do not include a review of the Health-Safety Supervisor's weekly audits. The quarterly NCSG audits did not include a review of the weekly audits to assist in determining whether there are any trends that may compromise nuclear criticality safety.

The quarterly NCSG audits reviewed by the team (February 28, 1985 -

November 17, 1986) contained no recommendations for corrective action (none were required). However, a review made of action taken on a

6 recommendation made in a ' quarterly independent health physics audit indicates prompt action is taken on recommendations. Documentation on

'the- action taken was . submitted to the Plant Manger. The latter's comments on the action taken were reported to the individual responsible for taking the corrective action. _A copy of the report on the actions taken was not provided to the independent reviewer who made the recommendations to provide assurance that the recommendations were not misinterpreted.

Based on the above findings, the following weaknesses were noted in the nuclear criticaTity safety program which warrant licensee management attention:

-- A procedure which specifies the analyses the Health-Safety Supervisor is authorized to perform without NCSG approval, and the confirmatory requirements for checking the calculations had not been prepared (paragraph 6.a.) (IFI 87-02-01).

Instructions for receiving authorization to use fire hoses. (where otherwise prohibited) to fight fires, and the authorization requirements had not been standardized. (paragraph 6.b.) (IFI 87-02-02).

- A review and proceduralization of the storage requirements for non-SNM materials within and between SNM storage arrays which includes nuclear criticality safety criteria to ensure no potential hazards were introduced had not been performed (paragraph 6.b.) (IFI 87-02-03).

The NCSG quarterly audits did not include a review of the weekly Health-Safety Supervisor's audits to determine whether trends are developing that may compromise nuclear criticality safety.

(paragraph 6.c.) (IFI 87-02-04)

In addition to the weaknesses noted above, the following items were noted that should be considered for program improvement:

Proceduralizing the multipurpose use of safe transport carts to remove the possibility of their misuse (paragraph 6.b) (IFI

! 87-02-05).

Revising the Health-Safety Audit Procedure (AS-II25, Rev. 6) to reflect CNFP practices and commitments (paragraph 6.b) (IFI 87-02-06)

Providing a copy of the memorandum to the independent auditor (NCSG and Radiation Safety) on the corrective action taken on i_

recommendations made based on the quarterly audit. (paragraph 6.b)

(IFI 87-02-07)

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-7. Fire Protection / Prevention Program The NRC has not established fire protection / prevention guidelines or regulatory requirements for nuclear fuel fabrication facilities; therefore, the following nuclear industry fire protection standards were utilized by the team to perform the assessment of the licensee's overall fire protection / prevention program:

• American National Standard Institute (ANSI) N665-1985, Facilities for Fabricating . Fuel for Light Water Reactors (LWR) - Fire Protection -

International Guidelines for Fire Protection at Nuclear Installations Including -Nuclear Fuel Plant, Nuclear Fuel Stores, Teaching Reactors and Research Establishments - 1978 Edition

• NUREG 0800, Standard Review Plan 9.5.1, Guidelines for Fire Protection for Nuclear Power Plants - Revision 2, July 1981 Applicable Codes and Standards of the National Fire Protection Association (NFPA)

'The scope of this fire protection / prevention assessment included an evaluation of the following: design and construction of the facility; administrative fire prevention control procedures; fire protection system maintenance and surveillance program; emergency (fire brigade) team organization and training; implementation of the fire protection program, fire potential from industrial operations or following a nuclear criticality accident; possible release of radioactive materials which may result in the event of a fire or explosion; and, licensee's response capabilities to mitigate fire conditions.

a. Summary of Facility Design, Construction and Fire Protection Features The main plant building consists of a single subdivided structure plus several smaller attached buildings. Smaller detached buildings and covered storage structures are located around the main structure. The main plant building is essentially of noncombustible, unprotected f structural steel metal clad construction. The main building is i subdivided by walls into several separate main production areas and other process and office areas. These walls, however, are not considered fire walls having a minimum fire rating as recommended by general industry standards.

The site fire protection water is supplied from the B&W-NNFD facility through a single 10-inch supply main to an 8-inch water system loop around the plant buildings. This system supplies eleven fire hydrants strategically located around the plant site and sprinkler systems installed in the machine shop and records storage areas. A break in the single supply pipe could result in the elimination of the fire protection water available to the site. Loss of water pressure in the fire main is alarmed locally in the plant's south bay.

( 0' 8-No automatic heat or smoke . detection systems.are installed within the plant. A manual pull fire alarm system is provided within the main plant building to initiate a plant. evacuation.

Portable fire extinguishers are distributed throughout the facility and meet the type, location, and spacing requirements of NFPA-10. No interior standpipe and hose stations are provided for the facility.

l: Fire' prevention practices in general are being followed in most areas of the plant. . The fire hazards associated with the UF6 cylinder storage and radiation areas of the plant appear to be adequately safeguarded. Although fires within the plant structure are probable,

! there does not appear-to be a fire hazard associated with any of the 5 operations . reviewed by the- team that could result ina significant impact on public health and safety.

I b. Fire Prevention Administrative Control Procedures The team reviewed the following fire prevention / administrative-procedures provided in the Health and Safety Procedures Manual:

Procedure No. Title AS-1101, Revision 10, Employee Safety Training

. dated 3/3/86 AS-l'110, Revision 9, Waste Control i dated 3/24/86 AS-1133, Revision 0, Hazardous Chemical Communication dated 4/8/86

'AS-1134, Revision 0 CNFP Safety Review Board dated 3/28/86 AS-1135, Revision 1, Occupational Accidents / Incidents /

! dated 1/19/87 Injuries These procedures appeared adequate for the areas they cover; however, detailed procedures were not provided for several important fire i prevention / protection features. These include the lack of procedures for:

Control of combustible materials including wood, cardboard and '

F paper, plastic materials.

Control of welding, grinding, and cutting operations by a permit system and fire watches for plant process / production areas.

Identification, accessibility and marking of all emergency shutoff valves for flammable and toxic gases and other utilities.

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These items are also identified in the guidelines of the McDermott Property Conservation Manual which outlines guidance for plant compliance to Corporate Policy Number 0701-003, Conservation of Company-Property Policy.

The requirements for the safe storage and disposal of zirconium are included in Procedure AS-1110, Waste Control. Trash containers at the facility are emptied at the end of the day shift. No smoking areas are posted by Health-Safety in the local work station safety rules but procedures are not provided to identify which areas should be classified as no smoking areas. Material safety data sheets on potential hazardous materials are provided near work stations for the employee's information and reference as required by Procedure AS-1133.

'Also Procedure AS-1134 provides that a preoperational safety evalution be performed prior to implementing major plant changes which may affect plant industrial safety criteria. Management walkthroughs are performed weekly to assess plant operations and industrial safety practices.

Based on the above findings, the following weakness was noted in the fire prevention / protection program which warrants licensee management attention:

A comprehensive fire prevention / protection program which incorporates the guidelines of the Corporate Property Conservation Manual had not been established (IFI 87-02-08).

c. Fire Protection Systems Inspection and Maintenance Program The team reviewed the licensee's procedures AS-1116, Revision 8, dated March 28, 1986, CNFP Fire Protection Equipment Control, and AS-1130, Revision 1, dated January 17, 1986 CNFP Emergency Equipment Maintenance Procedure, to determine if the various test outlines and inspection instructions adequately follow general industry fire protection practices and the guidelines of the applicable NFPA Codes.

The program for the following fire protection systems and equipment was reviewed:

(1) Fire Extinguishers All fire extinguishers are inspected monthly by Health-Safety personnel. On a semiannual basis, a fire protection equipment contractor conducts maintenance service inspections. These should assure that the extinguishers will be functional when needed.

Extinguishers in various areas of the plant were inspected by the team during the plant tours. It was noted that the monthly and semiannual inspections / maintenance were being conduc.ted.

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(2) Emergency (Fire)~ Alarm System The manual pull station alarm system is checked on a monthly basis by a ~ telephone test and- quarterly an operability test is performed. The entire alarm system is test activated twice a

. year. Once each year the system is sounded for familiarization then again during the plant emergency drill. This schedule appears adequate to meet the intent of the requirements ~ of NFPA 720; however, results of all testing are not_ documented.

(3) Fire Protection Sectional / Control Valves All- valves are visually inspected weekly to verify correct alignment. On a monthly basis, the valves are partially closed,-

reopened, and properly realigned. The weekly and monthly inspection reports, Form HS-03, for January through December 1986 were reviewed. These indicated that the valves were being ,

inspected and tested at the specified frequency.

.(4) Automatic Sprinkler Systems The water flow alarms for the records storage and machine shop automatic- sprinkler systems are tested- monthly to verif>

operability. In addition, a 2-inch main drain test is conducted to verify that an open water supply is available to the sprinkler systems. On a semiannual basis, a sprinkler drain test is conducted by opening the inspectors test. connection and allowing the flowing water to initiate the sprinkler waterflow -alarms.

This test as presently conducted, however, does not simulate the flow of a single sprinkler head as denoted by NFPA Standards 13 and 13A in that a 1/2-inch smooth bore outlet giving flow equivalent to one sprinkler was not used in the inspectors test pipe during the flow tests.

(5) Fire Hydrants Annually each fire hydrant is opened to permit a full flow water stream for a minimum of one minute. This provides for an adequate flush test; however, documentation of annual flow tests for the fire main loop was not available for review. It is customary to have annual flow tests made of private fire systems so that the operating performance and overall adequacy of the system can be determined.

(6) Exterior Fire Hose Inspections All fire hose carts are inspected quarterly to inventory the fire hose for the required quantity of hose and an inspection for defects and deterioration. During the plant walkdown, the team

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.noted mud and insect nests in several lengths of fire hose'on the exterior fire carts. The fire hose is hydrostatically tested annually by an outside contractor.

The team noted that . surveillance test procedures were not developed for fire doors, fire dampers, separation fire barrier walls,. penetration seals, and battery powered emergency lighting units including fixture alignment and aiming.

Based on the above. findings the following weaknesses were noted in'the fire protection inspection and maintenance program which warrant licensee management attention:

A' procedural program for inspection, maintenance, and testing of all fire protection features and equipment had not been developed.

(IFI 87-02-09)

. Annual flow tests of the fire protection water supply have not been performed. (IFI 87-02-10)

In addition to the weaknesses noted above, the following items were noted which should be considered for program improvement:

Providing the sprinkler system's inspectors test connections with suitable outlets to simulate the flow of a single sprinkler head as denoted by NFPA 13 and 13A. (IFI 87-02-11)

Performing fire hose inspections on a monthly basis and including an intense visual inspection of hoses (IFI 87-02-12) ,

d. Site Emergency (Fire Brigade) Team (1) Organization The fire brigade is a designated part of the site emergency team and is composed of seven individuals, of which six are assigned during the single day shift operation. Two individuals rotate their shifts as required such that at least one member is on. duty during any backshift operations. The fire brigade is composed of volunteer plant employees and is under supervision of the Health-Safety organization management. The day shif t brigade has at least a fire chief and an alternate assistant chief.

Additional fire fighting assistance can be requested from the B&W Naval Nuclear Facility (NNFD) and/or the offsite Concord Volunteer Fire Department.

Since a minimum of a five member fire brigade is required on each shift for power reactors, tha same number should be adequate at a fuel f acility. The brigade should be structured such that the i team leader and two other members have sufficient knowledge of the r

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(2) Fire Brigade Medical Qualifications Each fire brigade member is required to pass an annual physical examination. The licensee stated that the physical includes a stress (cardiac and EKG) review. All seven fire brigade members had received a physical in 1986. A review of the seven fire brigade member's records indicated that five individuals had not received pulmonary testing during the 1986 physical. Three persons did not have EKG testing during the 1986 physical, yet, they were cerc1fied as qualified by the examining physician. The examination, therefore, appears to be lacking with respect to determining on an annual basis the overall physical condition of fire brigade members as to their ability to conduct strenuous fire fighting activities.

(3) Training The licensee's procedure AS-1101, Exhibit 8, states that Health-Safety is required to instruct fire brigade members in the types of fire equipment at the plant, proper use of fire extinguishers, contamination control, respiratory protection, the CNFP emergency procedure, and fire fighting limitations at CNFP.

This procedure does not clearly define the frequency of the training. It also dces not require training records to be maintained, although Health-Safety has developed a computer program for tracking of this training.

The licensee does not require all fire brigade members to participate in an annual structural fire fighting practice session. These sessions are needed to demonstrate the proper methods of fighting the various types of fires which would occur in a nuclear fuel facility and should provide members with actual hands on experience in fire extinguishment and use of self contained breathing apparatus under strenuous actual fire conditions. These practice sessions could be conducted at a state certified fire academy under the supervision of state certified fire service instructors. Also, the existing fire training program does not assure that the following items are covered in an initial training program and repeated on a two year frequency:

Indoctrination of the plant fire fighting plan with specific identification of each emergency team member's responsibility.

- Identification of the type and location of fire hazards and associated types of fires that could occur in the plant.

- The toxic and corrosive characteristics of expected products of combustion.

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O .O 13 Identification of the location of fire fighting equipment for each fire area and familiarization with the -layout of the i

plant, including access and egress routes to each area.

The proper use of available fire fighting equipment and the correct method of fighting each type of fi_ro. .The types of.

fire should include fires in energized electrical equipment, fires in special process . equipment, gas fires, fires involving flammable and combustible liquids or hazardous process chemicals, and fires resulting from construction or modifications (welding).

The proper use of communication, lighting, ventilation and emergency breathing equipment.

l The proper method for fighting fires inside buildings and confined spaces.

- The direction and coordination of the fire fighting activities (fire brigade leaders only).

- Detailed review of fire fighting strategies and procedures. ,

- Review of the latest plant modifications and corresponding changes in fire fighting plans.

Also the licensee does not require the emergency fire brigade leaders to participate in additional fire ground command or leadership training. The team observed that the present . fire brigade training program is very general and not based on potential site specific fire hazards other than exposures to the UF6 yard storage.

The team also noted that the licensee does not have an established fire drill implementation program which assures the following:

- Drills are held at regular intervals, not to exceed three months for each fire brigade shift.

Each brigade member participates in two (2) drills. ,

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- Each fire brigade shift participates in one unannounced drill.

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- Each fire brigade shift performs at least one drill held on a

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- Drills are preplanned. ,

i - Drills are critiqued, and if unsatisfactory, they are i repeated within 30 days.

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(4)' Fire Emergency Plans (Fire Fighting Strategies)

The licensee stated that fire emergency preplans or fire fighting strategies, other than Procedure AS-1101, Employee Safety Training, Fire Fighting Limitations Imposed at CNFP, had not been developed for the plant, Emergency fire preplans prcvida fire fighting strategies which can be used to mitigate pending fire conditions. These plans normally address the following:

Fire hazards in the area Extinguishant tc be used Direction of attack Systems to be managed to reduce loss Heat sensitive systems Fire brigade specific duties Smoke control capabilities Instructions for process control and isolation Criticality concerns.

These plans may also include other specific emergency actions now identified in the Emergency Plan such as remote shutdown of ventilation, water systems, flammable / explosive gases, or toxic substances.

I (5). Fire Brigade Manual Fire Fighting Equipment The fire brigade manual fire fighting equipment for the plant is stored at the emergency equipment building outside the main plant building. The equipment consists of four sets of self-contained breathing apparatus (SCBAs), seven sets of turnout gear including coats, hats, gloves, and boots, a fire cart with 200 feet of 2-1/2 inch hose,100 feet of 1-1/2 inch hose, nozzles, hose wyes and miscellaneous forcible entry tools. An identical fire cart is located near the maintenance shed on the opposite end of the main ouilding. r The team reviewed the inventory of equipment and found the equipment to be properly stored and in satisfactory condition as required by Procedure AS-1130, CNFP Emergency Equipment Maintenance Procedure; however, the quantity of equipment and spare air supplies is not sufficient to outfit and protect a full complement of fire brigade personnel in a major' fire situation. *

, ., , The fire brigade inventory lacks the items considered essential to

, fire fighting as noted below:

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All fire brigade members (five minimum) should be equipped t with SCBAs.

All fire fighters should have a full set of turnout gear

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The fire brigade leaders should be equipped with adequate radio communications to the plant Emergency Officer.

Each SCBA should have two spare air cylinders with a reserve air supply available on site.

Based on the above findings the following weaknesses were noted in the fire protection program which warrant licensee management attention:

Fire protection training for the fire brigade does not include an annual practice session and classroom training of essential fire protection subjects. (IFI 87-02-13)

The fire brigade leaders did not complete additional training in leadership and fire ground command. (IFI 87-02-14)

Area specific fire fighting emergency preplans for all plant areas have not been developed. (IFI 87-02-15)

In addition to the weaknesses noted above, the following items were noted which should be considered for program improvement:

Performing annual medical examinations for fire brigade members including pulmonary and EKG testing (IFI 87-02-16)

Conducting fire drills in a manner consistent with nuclear fire protection industry practice. (IFI 87-02-17)

Providing sufficient fire fighting equipment to outfit a full complement of fire brigade personnel. (IFI 87-02-18)

e. Assessment of Fire Potential The team performed an evaluation of the fire potential in various plant areas against the combustible loading of the area under evaluation and the fixed fire prevention / protection features provided to mitigate a fires consequences on criticality and radioactive release.

Based on the team's evaluation there does not appear to be a significant fire hazard associated with any of the facility operations reviewed by the team that could result in a significant impact on public health and safety. However, several conditions were identified which may result in a minor impact on the general health and safety of the plant structures and/or workers.

During the plant walkthroughs the team noted that the hydrogen gas supply to - the small sintering furnace in the pellet loading room, Acea 7. is from two wall-mounted high pressure H2 cylinders located in s -+

s _

16 Fuel Rod Fabrication, Area 8. The cylinders have pressure regulators which are pigtailed to the gas supply piping manifold using lengths of 150 psi pressure rated pneumatic tubing. The manifold piping co.nsisted of low temperature soldered copper tubing. The location, design, and arrangement of this system does not meet the requirements of NFPA 50-A, Standard for Gaseous Hydrogen Systems at Consumers Sites.

Based on these discrepancies a potential exists for a fire or explosion in the area of the H2 cylinders or manifold within the fuel rod fabrication area should a pressure regulator fail and the low pressure system rupture.

In addition, it was noted that the arrangement, piping, ar.d venting of the carbon dioxide (C-]2) supply to the laser welding machine located in the machine shop,, Area 20, was not in accordance NFPA-12, in that the

. pressure relief valves vented into the building and the piping did not appear to be suitable for high pressure C02 service.

Outside the main building it was noted that the flammable liquids storage area covered shed was not provided with emergency drainage '

systems as denoted in NFPA-30, Flammable and Combustible Liquids Code, to prevent the potential spread of fire to the main plant building.

(see paragraph 8.c.)

Based on the above findings the following item was noted which should

'be considered for program improvement:

Evaluating the risk to the plant and workers from fire or toxic gas exposure and implementing a fire safety program to minimize '

the risk. (IFI 87-02-19)

8. Chemical Process Safety

a. General As the plant operations do not involve the vaporization and chemical conversion of UF6, there are no bulk chemical supplies or large quantities of chemical wastes on site. Chemicals used range from very low toxicity to extremely high, and include flammable materials.

Quantities of materials on site are small and consist principally of one or more 55 gallon drums. A small storage tank is provided for acetone, because of the wide use throughout the plant as a cleaning agent.

Observation of the use of hazardous chemicals in the plant areas

-indicated that the quantities are limited to immediate needs, materials (especially flammable materials) are handled in appropriate safety containers and cleaning tanks are labeled to indicate the contents and type of hazard involved.

O O

17

b. Hazards Communication Program The licensee has established a Hazards Communication Program to implement the' requirements of 29 CFR 1910.1200. The administration of the . program is specified in Procedure AS-1133, " Hazard Chemical.

Communications." As part of this program, Material Safety Data Sheets (MSDSs) have been compiled for materials used throughout the plant,

' including materials' such as soaps, cleaners and waxes, in addition to the chemicals used in the manufacturing processes.

Master. copies of the MSDS books are maintained in the Health-Safety Office and in a central location in the manufacturing area.

Additionally, the MSDSs for a particular operation or area are provided for the chemicals-in use in that area. Personnel interviewed by the team were aware of the location and purpose of the MSDS books for their particular operation.

Each ' MSDS includes recommendations for fire fighting involving the material. This information would be pertinent to the fire protection /

prevention program discussed in paragraph 7 d(3) and (4), and should be' incorporated into the program. Also, each MSDS has pertinent data on hazards, limiting values, first aid and other information regarding

~

exposures to the material. While it is not necessary for every employee to be informed of the hazards involved with every chemical in the' plant, retraining on the MSDS and hazards program is not provided as part of the annual retraining program.

Based on_. the above findings,. the following items were noted which 4- should be considered for program improvement:

Including . data from the MSDSs and the Hazards Communication Program in the refresher training program (IFI 87-02-20).

Including data from the MSDSs in the Fire Preventicn/ Protection Plan (IFI 87-02-21).

c. Chemical Storage Chemicals are stored in two separate sheds away from the plant structure. Acids are stored in one shed and bases and flammables are stored in another shed. ~ Empty drums awaiting shipment are stored in a separate shed.

Drums of flammables are electrically grounded in the storage area.

L Safety cans used to collect drippage from the drum spouts have been grounded as well. The acetone tank is electrically grounded and is vented outside the shed.

v w) 18 During the assessment, water from melting snow was observed standing in the flammable material shed, and had flowed outside, as evidenced by an oily film. The shed was not provided with a dike to keep water out and/or spillage in. Should a spill occur, materials such as naptha, isooropyl alcohol or trichloroethylene could be released onto the ground and accumulate in low ground pockets, unknown to plant personnel. This situation was discussed in paragraph 7.e, Assessment of Fire Potential.

Based on the above findings, the following weakness was noted in the

, chemical safety program which warrants licensee management attention:

Dikes and drainage control in accordance with NFPA-30 to control the spillage-of hazardous chemicals had not been provided. (IFI 87-02-22)

9. Operations Engineering

a. Lessons Learned Recommendation 2.3.2(2) of NUREG-1198 suggests that a requirement generally analogous to 10 CFR 50.59 should be established requiring certain facilities to perform engineering evaluations of proposed changes to ensure that overall safety margins are not compromised by changes. The licensee has established a program which is " generally analogous to 10 CFR 50.59," in that new or revised facilities must be reviewed for acceptability prior to initiating a change, and a second review is required before releasing the facility for use. The term

" facility" may be a building, new equipment or relocation of existing equipment.

Procedure AS-1134, "CNFP Safety Review Board" specifies the requirements for submitting, reviewing approving and verifying the acceptability of new or revised facilities. Radiation Safety, nuclear safety and industrial safety evaluations are required. Industrial safety reviews include such items as lighting, equipment guards, fire safety, electrical grounding and noise control.

The team noted that the review does not explicitly address the hazards of chemicals which may be involved with new equipment or processes.

The Hazard Communication Program (paragraph 8.b) requires the MSDSs be available but the safety considerations are not necessarily addressed.

Pending further regulatory action to address Recommendation 2.3.2(2),

the licensee's review and approval appears adequate to address the overall safety of changes.

Based on the above findings, the following item was noted which should be considered for program improvement:

Incorporating the review of chemicals and chemical hazards into the facility change review process (IFI 87-02-23).

,3 U O, 19

b. Maintenance of Lifting Devices As part of the manufacturing operations, materials up to a metric ton are moved in the plant areas. A failure of a lifting device or crane would not cause a radiation hazard or result in offsite releases, but could cause personnel injuries to individuals in the work area. 29 CFR 1910.179 specifies the requirements for overhead and gantry cranes, including inspection requirements.

Procedure AS-1117, " Crane, Sling and Lifting Fixture Inspection and Testing" requires monthly and annual inspections of cranes, in accordance with 29 CFR 1910.179, as well as annual inspections of special purpose lif ting devices and fixtures. The procedure further requires that new, altered or repaired fixtures, devices and cranes be load tested, brakes and limit switches checked, and other inspections be performed.

The team reviewed the records for selected cranes and verified that the periedic tests and inspections had been performed and documented. TFa team also reviewed the test and administrative release forms for new fuel lifting fixtures prior to their being placed in service.

The inspection and testing of cranes and lifting devices appears to be adequate.

10. Evaluation of Accident Potential The team conducted a review of conditions and operations at the facility to identi fy possible accident situations. Situations considered included nuclear criticality safety, fire safety chemical safety, and combinations of these three. Accident scenarios which were considered by the team as credible involved accidents which could result in localized damage to the facility or localizeo hazards to personnel in specific plant areas.

Considering the types of materials present, plant operations, and control measures, an accident which would present a significant hazard to the public health and safety from chemicals and/or radiation was not considered credible.

11. Radiological Contingency Plan (RCP)

The purpose of this evaluation was to assess the licensee's ability to respond in the event of an emergency or abnormal condition requiring the implementation of the RCP and Procedures. This evaluation included an examination of the following: (1) emergency classification and notification scheme, (2) emergency facilities and equipment, (3) offsite agency coordination and training, (4) administrative and maintenance of the RCP and its procedures, and (5) training and performance of drills. In addition, a review of the RCP to determine its adequacy with respect to standard industry practices was performed.

L

O O 20

a. Emergency Classification and Notification The classification scheme used by the licensee was consistent with the standard nuclear industry scheme and consists of four emergency l classes: Notification of Unusual Event, Alert, Site Area Emergency, i and. General Emergency. For each of these classifications, the licensee had identified potential accidents each associated with actions to be taken, required notifications, and activation of emergency personnel end teams.

The licensee's classification system was adequate with respect to the potential emergencies that could occur in each class. The accidents rar.ged from fire, severe weather and loss of utilities to security threats and criticality accidents. In general, the various occurrences l are defined such that little ambiguity would be encountered when l classifying a particular accident type. There are emergency conditions (severe weather and fire) for which more clearly defined action levels which would constitute an emergency declaration are needed. Coordina-tion of action levels with NNFD and LRC to ensure consistent declarations for emergencies that could affect all three sites is warranted. In addition, the classification scheme did not include transportation of a contamirated and injured individual to an offsite treatment facility or a transportation accident involving company owned material requiring response by plant personnel. Incorporation of such off-normal /non-operational events in the classification scheme is consistent with the anticipatory guidance of NUREG-0654 and would make all licensee response plans consistent. It would also assure the timely notification of offsite groups such that they would be adequately informed and could answer public inquiries factually.

The licensee's emergency procedure clearly defined the offsite groups to be contacted for the four emergency classifications and the times within which notifications should be performed. The procedure did not provide for offsite notification of the counties for all four emergency classes and for notifications to the State and local governments within 15 minutes and to the NRC within one. hour for all declared emergencies. This would be in accordance with 10 CFR 50, Appendix E

and would again essure consistency throughout the nuclear industry. In

[ addition, the emergency procedure provided for notifications to the l appropriate groups for changes in emergency classification; but, it did I not specifically provide for renotifications upon emergency termination or when significant changes in conditions within a given emergency class occur.

To facilitate the notification process, the licensee had developed a standard form to be used when making notifications. For each classification it provided for the groups to be contacted, the corresponding telephone numbers, and the recording of the time and individual contacted; however no standard message content had been formulated.

( (.

U V 21 The licensee had developed methods for activating the emergency organization during both normal and offshift hours. Activation of emergency response personnel is accomplished via telephone contact, a dedicated page code, or actuation of the fire or criticality alarm systems. The method used was dependent upon the nature and time of accident occurrence. For contracting emergency personnel, the licensee naintained an emergency call list in a procedure. This listing included the home and plant telephone numbers of key emergency response personnel and their alternates, and the telephone numbers for critical offsite support personnel. These telephone numbers are not reviewed and updated on a quarterly basis to ensure the telephone numbers and personnel listed are current, but rather this is accon.plished on an annual basis.

The licensee maintains a system for notifying all site personnel of the need for site evacuation, and maintains a fire alarm system for making employees aware of a hazardous condition. During a plant tour, the team observed the placement of posted evacuation route signs and the location of the plant assembly area.

Based on the above findings, the following weakness in the area of emergency notifications was identified which warrants management attention:

Notification of the counties for all emergency classes and notifications to the State and local governments within 15 minutes and NRC with I hour of any emergency declaration has not been established in the RCP and Emergency Procedure (IFI 87-02-24).

In addition to the weakness noted above, the following items should be considered for program improvement:

Clarifying the action levels which constitute an emergency declaration for severe weather and fires so as to decrease the ambiguity involved in the classification process. (IFI 87-92-25)

Coordinating with B&W NNFD and B&W LRC to ensure that consistent declarations are made for conditions affecting all three sites, such as severe weather. (IFI 87-02-26)

Including additional occurrences under the NOUE classification which would warrant upgraded offsite awareness, such as transportation of contaminated, injured individual to an offsite medical facility or a transportation accident requiring response by site personnel. (IFI 87-02-27)

Providing for renotification of of fsite agencies upon emergency termination and as any significant change in plant conditions occur. (IFI 87-02-28)

O O 22 Developing and using a standard message form to facilitate the transmission of emergency information to offsite organizations which includes: time, date, classification, plant status, site and offsite protective actions, dose estimates, and meteorological information. (IFI 87-02-29).

Providing for a quarterly review and update of emergency telephone numbers and personnel assignments in the Emergency Procedure. (IFI 87-02-30).

b. Emergency Facilities and Equipment The team toured the site and offsite first aid facilities, the evacuation assembly area, the various emergency kit and equipment storage locations, decontamination facilities, the criticality alarm panel area, and the locations from which emergency operations might be conducted to determine if adequate facilities and equipment were available for conducting operations during an emergency.

In Section 6.0 of the RCP the licensee had designated locations from which emergency ' operations could be conducted. These facilities included any one of the various site trailers, the assembly area, or from the accident scene. In view of the types of accidents postulated for this facility these locations appeared adequate. Typically, the emergency organization would muster at the guard house, and conduct emergency operations from a location convenient to the accident scene.

If the plant were evacuated due to fire or a radiological incident, however, the organization would gather at the assembly / muster area and proceed to one of the previously mentioned localities. If the site locations were not habitable, the licensee would use alternate locations for conducting operations such as B&W NNFD and B&W LRC. The facilities at NNFD have been evaluated in previous inspections, and would be adequate to serve as a backup operations centers. Although the licensee has specified the locations of primary and alternate emergency centers in the RCP there is no mention in the procedure of the possible backup facilities that could be used and copies of the RCP are not available in the emergency kits.

The primary location for emergency equipment, protective clothing, and re-entry equipment is the Emergency Shed located adjacent to the south assembly area. This building houses first aid equipment, .

decontamination equipment, fire fighting supplies, protective clothing, sampling equipment, SCBA equipment and spare cylinders, an emergency generator, air samplers and emergency lighting. All survey equipment and personal dosimetry devices are located at the main guard house.

This kit contained an array of detection instrumentation of various ranges and types, dosimetry devices, and a dosimeter charger. An additional kit was located at the site assembly area that contained various administrative supplies, the Emergency Procedure, area maps and multiple copies of the various procedures and forms.

r 23 In general the locations, types and quantities of equipment available appeared adequate .except for the quantity of SCBA equipment on site.

Specifically, there is not enough equipment to equip both a full fire brigade team and the radiation monitoring team personnel that may be required to use SCBA equipment. This was discussed previously in section 7.d(5). P&ID drawings and related operational data were not available in the emergency equipment storage at the assembly area such that locations of utility shutoff valves, electrical, and other operational information would be available if needed.

Emergency communications equipment available for emergency operations was reviewed. In general, the licensee relies primarily on commercial telephone lines. Such communications are available throughout the plant, including several of the trailers. If the telephone lines should become inoperable, the licensee could utilize the continuous radio communications with the B&W NNFD Security organization who have direct radio communications with the Campbell County Sheriff's Department. B&W NNFD has also been provided with the appropriate information to contact B&W CNFP plant management and augmentation personnel if needed. In addition to the radio backup capability, there is adequate communications located in B&W NNFD's Emergency Operations Facility for contacting the NRC, maintaining communications within the CNFP plant, and communicating with State and local authorities.

Although the licensee has sufficient primary and backup communication equipment available for contacting outside agencies, the communication between plant emergency response personnel during an emergency is weak, Currently, the licensee communications between key response personnel is by the use of runners. No formalized method has been developed for the use of portable radios, nor is this equipment available at the site. The licensee maintains only two portable radios, which would be in use by security during an emergency. As a result, information could not be transmitted from the accident scene and assessed in a timely manner, without the use of additional personnel who might otherwise be occupied.

The licensee has developed a procedure for manually calculating doses to site personnel and projecting doses offsite. The methods used for both uranium releases and criticality accidents appear to provide an adequate estimation of dose. The licensee emergency procedure does not include the information necessary for obtaining meteorological data.

Specifically, the procedure should include the sources of accurate information (LRC, National Weather Service) as well as the telephone numbers for contacting them. In Exhibit C of the Emergency Procedure the licensee has provided for the incorporation of the State Radiological Response Levels, but did not incorporate the State Protective Responses / EPA Protective Action Guides such that a l

0: O 24' comparison of calculated doses and'the action levels for evacuation and

~

sheltering can be made.

The team made selective examination of site emergency . kits and. found them to be inventoried and well- maintained. These include the site-

.first aid equipment and a transportation accident kit, ~ in addition to those previously mentioned. The licensee has a procedure. outlining the maintenance and inventory program for these kits in AS-1130, "CNFP Emergency Equipment Maintenance Procedure. The team verified that

~SCBAs and monitoring instrumentation had been checked and calibrated as required.

The team also reviewed the program for maintenance and testing of the criticality and fire alarm system and the emergency lighting. Health and Safety Procedure AS-1131 " Calibration and Maintenance of the Plant Criticality Alarm System" provides for an annual maintenance and

. calibration of the criticality alarm system as well as a quarterly functional test. Licensee documentation confirmed that such activities were performed. In addition, the licensee conducted monthly actuation tests of both alarms via a telephonic connection. The licensee's procedure calls for an annual check of the batteries-providing 'back-up power to the system; however, the specific description of maintenance check points were not given. Discussions with licensee representatives indicated that the batteries-to the emergency lighting units were also on a regular maintenance program. Specifically, water level is checked on a monthly frequency, specific gravity semiannually, and an overall electrical and actuation check yearly, but these verifications had not been incorporated into the maintenance procedures.

In addition to the ' site emergency equipment, the team evaluated the-emergency equipment and facilities available at the Lynchburg Memorial Hospital for handling a contaminated individual. This evaluation was conducted during the B&W NNFD Assessment in November 1986 which was-documented-in NRC Inspection Report 70-27/86-22. It was noted that the licensee maintained specific procedures for preparing and transporting a contaminated, injured individual to the hospital.

Based on the above findings, the following weaknesses in the area of facilities and equipment were noted which warrant licensee management attention:

A timely method for- communication between emergency team members and emergency coordinators and leaders had not been implemented such. that emergency operation can be efficiently controlled (IFI 87-02-31).

The supply of emergency SCBA equipment was not sufficient to outfit both a full fire brigade team and radiation monitoring personnel that may require the use of SCBA equipment (IFI 87-02-32).

O

~

.O -

25 In addition to .the weakn' esses noted -above, the following items were noted which should be considered for program improvement:

' Including in the-Emergency Procedure the various site and offsite

, emergency center locations (IFI 87-02-33).

Including P& ids and other operational data in the assembly area emergency; kit (IFI. 87-02-34).

Including in the Emergency Procedure _ the sources of accurate.

meteorological information as well as the telephone numbers for contacting them (IFI 87-02-35).

Including in Exhibit C to the Emergency Procedure the actual State Protective Response Level / EPA Protective . Action Guides as they relate to sheltering and evacuation recommendations (IFI 87-02-36).

Incorporating a specific battery verification program into _the routine maintenance procedures to include what checks-are made and

.at what frequencies.(IFI 87-02-37).

c. Training and Performance of Drills The team reviewed-Sections 7.2 and 7.3 of the Radiological Contingency Plan as well as selected course outlines and documentations. These reviews indicated that' the licensee had established a formalized training program for general employees and limited emergency response personnel.

The team determined that the licensee had established a program for training permanent and temporary employees on pertinent portions of the RCP and general safety precautions. Before unescorted access to the faci _lity is allowed, temporary' employees and visitors must attend a -

brief training session. This training includes familiarization with-the fire and criticality _ alarms, general safety procedures, potential for radiation exposure, and evacuation and general emergency procedures. In order to gain permanent unescorted access to the facility the licensee has developed a ' more detailed program for training employees as delineated in Procedure AS-1101, " Employee Safety Training." Each new employee is trained on general radiation safety, nuclear criticality safety, chemical hazards, and potential hazards associated with radiation exposure. As it relates to emergency

planning, training is provided on the overall emergency organization, plant and nuclear criticality alarms, evacuation routes and assembly areas, and an overview of potential incidents which do not require total plant evacuation.

The general employee training is conducted on an annual basis and I attendance is required for all employees. In addition, the licensee annually sounds the evacuation and fire alarms for familiarization

O O 26 purposes. Various other types of training are also provided to employees such as the use of fire extinguishers via the distribution of an information brochure. In general, this aspect of the licensee's program appears adequate.

The licensee has also provided a specific training program for some

-individuals who may be called upon to assist in an emergency. These include radiation monitoring . team members, fire brigade members and first- aid _ qualified employees. These formalized programs are documented in Procedurs AS-1101. Fire brigade training' and qualification were discussed in sections 7.d(2) and (3).

Radiation monitoring team personnel are trained annually on their roles in the emergency organization. The ' training topics include instrumentation use, survey techniques, decontamination techniques, exposure limits and the use of dosimetry, environmental and air sampling, the establishment of control zones, and handling a contaminated and injured individual. In addition, members of this team are:to be medically qualified for respirator use. The team noted that-one irdividual designated as a team member was not respiratory qualified; however, the licensee was aware of this and had consulted with the attending _ physician concerning the problem. The licensee understood that this individual is limited with respect to his participation on this team; however, due to the small Health-Safety.

staff he was . retained on the team to perform duties not requiring the use of a respirator. A retest is to be performed. The team noted that additional personnel can be provided by B&W NNFD and B&W LRC to support the Emergency Monitoring Team, if needed.

Although the RCP does not provide for a dedicated first aid team, the licensee has provided for coverage by first aid trained personnel .

This training is in the form of a' Red Cross Multimedia First Aid Course. An adeaate number of individuals were identified who had received this training to ensure that a qualified first aider would be present during normal operations. The frequency for retaining was as dictated by the Red Cross-- every three years.

A review of licensee documentation indicated that, for those response positions previously discussed, training had been performed as required by the RCP.

Discussions with licensee representatives indicated that no emergency response training had been provided to key emergency response management personnel because the RCP did not require such training.

Specifically, this includes such positions as plant manager, emergency officer, health and safety officer, evacuation officer and assistant, and the security officer. Training of these response personnel on an annual basis to include such topics as emergency classification, notifications, offsite interfaces, assistance available, communications meth'o ds, response actions, and their specific role in an emergency

m O O 27 would ensure that all individuals remain up-to-date on their response role as well as any changes to the RCP or Procedure. Similar training had not been provided to alternate personnel as well as backshift foreman.

Specialized emergency plan training to security personnel who perform a key role in communications, notifications, and interfacing with offsite agencies had.not been provided.

The team conducted walk-through evaluations with selected members of the emergency organization. The individuals included primary and alternate Emergency Officers and an alternate Plant Manager. In general, these individuals were cognizant of their responsibilities, the notification process, available site support, and the contents of the emergency procedure; however, it was evident that additional indoctrination was needed particularly in the areas of control of offsite support organizations and emergency classification logic.

The team verified that the licensee had a formalized drill. program.

These included an annual evacuation drill, medical drill and radiation monitoring drill. Verification of communications links with offsite agencies is only done during annual drills. Licensee documentation indicated that all these drills had been conducted as required by the RCP. A review of drill scenarios indicated that the drills had involved activation of the entire emergency organization and were of a scope consistent with the postulated accidents for the facility.

Based on the above findings, the following weakness was noted in the area of training which warrants management attention:

A formalized program for providing annual emergency . training to key management and security personnel who are expected to respond in the event of an emergency including primary, alternate, and backshift personnel had not been provided (IFI 87-02-38).

In addition to the weaknesses noted above, the following items were noted that should be considered for program improvement:

Performing communications drills on a monthly basis to include the actual transmission of an emergency message to offsite agencies (IFI 87-02-39).

Performing radiation monitoring drills semiannually to include environmental monitoring and responses to simulated releases (IFI 87-02-40).

o m C b 28

d. Offsite Agency Coordination and Training This area 'was reviewed to ensure that the licensee had established letters of agreement with external organizations and that these organizations had been made aware of their responsibilities in the event of an emergency.

The team verified that the licensee had established letters uf agreement with designated support groups. The agreements were current and valid and consisted of the following groups: hospital, rescue squad, fire department, B&W facilities mutual aid agreement and the Department of Energy. It was noted that no specific letter of agreement between CNFP and the Campbell County Sheriff's Department had been formulated; however, such an agreement has been established through the B&W NNFD Security organization. Since the B&W NNFD Security organization is the primary point for coordination and contact with offsite law enforcement, and the CNFP Plan and Procedures reflect this fact, this is an acceptable situation.

The RCP pruvided for a biennal review of the offsite letters of agreement; however updates were only indicated "as needed." It was noted that with the exception of the DOE letter, all agreements had been updated within the last two years. Although the renewal of agreements is a combined three-site effort, renewal every two years as opposed to an " update as necessary policy", unless this review consists of actual communication with each offsite group, would be consistent with general industry practice.

The team determined that the licensee had made provision in its RCP to provide annual training to the offsite fire departments in the form of facility tours. Review of licensee documentation indicated the indoctrination included discussions of plant layout, storage locations, facility operations, and a review of hazardous substances.

Periodic drills had been performed with the hospital and rescue squad exercising their ability to handle a contaminated individual. Drills and training with these two organizations have also been coordinated through the other two Babcock and kilcox facilities. The Campbell County Sheriff's Department had also participated in drills with the B&W NNFD security force. The licensee's documentation also indicated the State and local organizations had observed and assisted in critiquing drills.

During the 1986 B&W NNFD Operational Assessment the team interviewed representatives of the Concord Fire Department, the Concord Rescue Squad, the Lynchburg General-Marshall Lodge Hospital, the Campbell County Emergency Services and the Campbell County Sheriff's Department.

Results of these discussions are documented in NRC Inspection Report No. 70-27/86-22. In general, no significant problems in coordination

[

OL O 29 and communications as they relate to CNFP were noted. The team noted '

that offsite coordination and training is a B&W site effort and the resolution of the generic issues noted in the aforementioned inspection' report must be a joint effort.

Based on the findings noted above, the following item should be noted for program improvement:

Revising Section 4.4 of the RCP to include a description of the types of responses and assistance that each of the groups. listed can provide and including the means of contacting these groups in the. Emergency Procedure (IFI 87-02-41).

e. Administration and Maintenance of Programs The team reviewed this area to determine whether adequate management attention and support was given to the emergency response program and whether an adequate emergency response organization had been established.

The licensee had assigned the responsibilities for emergency preparedness planning and program development to the Quality and Safety Section. The responsibilities of this Section are delineated in the RCP and appear to cover the important aspects of emergency planning -

training and drills, review and changes, agreement renewals, and record retention. Although the emergency program is the ultimate responsibility of the Manger of Quality and Safety, individuals have been delegated specific responsibilities within his organization such as the License and Control Administrator and Health Physicist, the latter having primary responsibility for training and implementation.

Although the individuals have a variety of other responsibilities in the normal plant organization, there appears to be sufficient time available and dedicated to the emergency preparedness program. These

-individuals appear to posses the technical ability to perform' their duties effectively.

The licensee had provided for a system of management control over emergencies. The licensee's RCP Section 4.0 and 5.0 describe the various emergency response positions and the duties associated with each. In addition, the emergency procedure also gives a complete description of each position's responsibilities as they relate to a particular accident type; however, neither the RCP nor the Emergency Procedure clearly defines which site individual will be the primary interface and point of contact with offsite agencies and who will coordinate their support activities. Such agencies would include both Campbell County and NNFD law enforcement, the fire departments, and State and local response groups.

m., - _ - , . _

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Q 30 The licensee had provided alternates for each of the primary emergency response positions including the Radiation Monitoring Team and Fire Brigade Team Captains. The emergency call listing also included the home and work numbers for these alternates.

Typically, the licensee does not conduct operations involving special nuclear material on the backshifts -- all such activities are limited to the dayshift when the full management organization is present. When operations activities are performed during other than normal hours, the work usually is limited to the machine shop _with only a few staff and a foreman. Although few operations are performed during these hours, the licensee has made some provisions for conducting emergency operations.

Instructions included immediate notification of B&W MNFD Security for the needed support (fire, health physics, etc.), notification of management personnel, and evacuation and accountability instructions.

The licensee's RCP specifies the senior site individual as in charge until arrival of the emergency organization. This individual is not designated and receives no formal emergency training. It is not clear that he would have complete authority for carrying the Emergency Officer responsibilities in the event that augmentation personnel could not be reached or respond to the site and more extensive back-shift planning and delegation of authority in anticipation of expanded operations or a worst case scenario was needed.

The licensee provided for an annual review of the Emergency Procedure, AS-1106. A records review indicated that such reviews and updates were performed as needed and required. The licensee's procedure AS-1123

" Preparation, Distribution and Control of Health Safety Procedure" governs the review and approval of Emergency Procedure enanges. If changes are made, they must be reviewed and approved by appropriate management personnel before becoming effective. The required concurrences include Health-Safety (the originator), Manufacturing, Production and Material Control, and Quality and Safety. The team also noted that this procedure included the methods for making temporary changes to the procedure if necessary. Although the mechanism was in place for reviewing and updating of the Emergency Procedure, there was no formal review and management approval required for the RCP prior to implementation and transmittal to the NRC.

Although the licensee had regularly performed the required internal review of the procedure, no external audits of the overall emergency program had been performed. Particularly, no independent audit had been conducted on the RCP and its procedures by individuals who do not have any responsibility for implementing them. As a result, an annual determination of (1) coordination and the adequacy of offsite responses, (2) capabilities and equipment, (3) assignment of responsibility, and (4) the RCP and its implementing procedure had not been accomplished.

The licensee has a formalized method for distributing changes to the RCP and its procedure. This distribution is governed by Procedure AS-1124. A listing of individuals who were to receive copies of the i

V U 31 Plan and Procedure were not part of the procedure, but were available and maintained by _ Health-Safety. Recipients of the revisions are required to sign a notice of receipt to be returned to the originator.

It appeared that all key members of the emergency organization and plant management were distributed copies of the Procedure; however, only a few site individuals received a copy of the RCP. A wider distribution of the RCP or incorporation of appropriate information into the procedure would assure that all the necessary information will be available to response personnel. In addition, the team recognized that no non-B&W offsite support agencies had been provided copies of the RCP and therefore questioned whether they will understand and can knowledgeably coordinate their roles and responsibilities.

The licensee's program for record retention of drill activities, and associated evaluations and critiques were reviewed. The team found that such records were maintained as well as those for actual incidents. The records generally included documentation of scenarios, offsite participants, and critique comments. All drill results were reported to plant management. The team reviewed internal correspondence which showed that appropriate follow-up action was taken to correct problems identified during the drills.

Based on the above findings, the following weakness was identified which warrants management attention.

The Emergency Procedure did not provide all the pertinent emergency information (IFI 87-02-42).

In addition to the weakness noted above, the following items should be considered for program improvement:

Including in the RCP and Emergency Procedure a clear description of which site individual will be the primary interface and will be charge of coordinating the offsite support effort (IFI 87-02-43).

Designating an individual on the backshift who has the full authority to control emergency operations and has received training on the RCP (IFI 87-02-44).

Providing for a formal annual review of the RCP and providing for management concurrence and approvals on its revisions (IFI 87-02-45).

Performing an independent audit of the emergency preparedness program to include an evaluation of offsite interfaces, capabilities and equipment, RCP and Procedures, and assignment of responsibility, on a periodic basis (IFI 87-02-46).

O O 32 Providing a copy of the RCP to State and local support agencies (IFI 87-02-47).

Providing for wider distribution of the RCP to onsite emergency management personnel (IFI 87-02-48).

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