ML20215A870
| ML20215A870 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 06/01/1987 |
| From: | Alto R BABCOCK & WILCOX CO. |
| To: | Stohr P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8706170120 | |
| Download: ML20215A870 (16) | |
Text
{{#Wiki_filter:T Babcock & Wilcox Eo" d ',lT 3 2,' L pi.,- a McDermott company - P.O. Box 11646 Lynchburg, VA 24506 1646 jiDImg (8p4F 2 6000 ,3., ., n. e - June 1, 1987 United States Nuclear' Regulatory Commission ^ Region II 101 Marietta Street, N. W. Atlanta, GA 30303 j _4 Attention: Mr.' Philip Stohr, Director Division of Radiation Safety and Safeguards
References:
(1) SNM-1168, Docket-70-1201 (2) Inspection Report No. 70-1201/87-02 Gentlemen: l This letter addresses the weaknesses and recommendations noted in Inspection Report No. 70-1201/87-02. This inspection was the Operational Safety Assessment that was conducted by Messrs. G. L. Troup, N. Ketzlach, D. K. Sly, G. R. Wiseman-and Ms. A. E. Tabaka on February 2-6, 1987. 3 We have addressed each item in the same format as used in your inspection report. Appendix A and B correspond to the weaknesses and recommendations respectively. The numbering system for each item was also kept the same for your convenience. If there are any questions about this, please call me at (804) 522-5315. Sincerely, BABCOCK & WILCOX COMPANY COMMERCIAL NUCLEAR FUEL PLANT ,.,* - d - R. A. Alto Manager, Nuclear Fuel and Specialty Manufacturing RAA:cmr cc: K. E. Shy W. T. Engelke J. P. Watters Attachment ,.a D Db QQ {t b"7. c
3 APPENDIX A i The following discussion lists each assessment weakness followed by our response. The same numbering scheme used in the NRC Inspection Report 70-1201/87-02 is used here for your convenience. 1. Collectively the following issues indicate a weakness in the nuclear criticality safety program: i a. A procedure which specifies the analyses which the Health-Safety Supervisor is authorized to perform without NCSG approval, and the confirmatory requirements for checking the calculations had not been prepared. B&W RESPONSE: We concur with your assessment and have updated Procedure AS-1120, "CNFP Safety Review Board" to provide for nuclear safety analyses (i.e., smeared density calculations) that are performed by the CNFP Health-Safety Group without NCSG approval. Additionally, we have indicated in AS-1120 that appropriate QA of these analyses must be performed by an independent party, b. Instructions for receiving authorization to use fire hoses (where otherwise prohibited) to fight fires, and the authorization requirements has not been standardizea. B&W RESPONSE: We concur with your assessment and have standardized our postings regarding the use of fire hoses to agree with both our license and procedural requirements. c. 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. B&W RESPONSE: We agree with the assessment and have revised the local safety rules for the Fuel Assembly Storage Area to indicate those non-SNM items that are approved for storage between and within the storage racks. Also, a requirement has been added to the local safety rules that Health-Safety be notified prior to storage of any other non-SNM item in thir area.
l 1 i 1. Continued -- q d. 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 l criticality safety. B&W RESPONSE: The review of our weekly Health-Safety audits during the NCSG quarterly audits is presently covered in Procedure AS-1125, " Health-Safety Audits". Section 4.1'of AS-1125 pertains'to our Independent Nuclear Safety and Health Physics Audit and indicates that the " audit scope consists of physical inspection and records review for industrial, radiological, and nuclear safety elements-of plant activities". The procedure further states (in Section 4.1.3) that this includes " audit of operating records where such records provide a means of verifying procedural compliance with safety specifications". The CNFP weekly safety audits are an integral part of our k operating records and therefore are included in the scope .l of the NCSG quarterly audits as provided for in AS-ll25. l No further action is needed to correct this weakness. 2. Collectively the following issues indicate a weakness in the fire protection program: j l a. A comprehensive fire prevention / protection program.which incorporates the guidelines of the Corporate Property Conservation Manual had not been established. B&W RESPONSE: The NRC safety assessment report indicated three specific pa weaknesses concerning the Corporate Property Conservation Manual. These are: 1-Control of Combustible Materials, 2-Control of Welding, Grinding, and Cutting Operations, and 3-Identification, Accessibility, and Marking of All Emergency Shutoff Valves. Regarding the control of combustible materials, we presently utilize local safety rules to alert the employee of the importance of specific safety measures in his work area. These are conspicuously posted and are readily available for the employee's reference. Most of these local safety rule postings do include guidelines on control of combustible materials. There are however some
2. Continued-- postings without this stipulation. We will review all our local safety rule postings and assure that there are adequate statements included on the control of combustible materials. The control of welding, grinding, and cutting operations is also addressed in certain local safety rule postings at the CNFP. Welding and/or open flames c're-prohibited in those plant areas consistent with the real fire potential at the CNFP. It is appropriate for us to investigate the use of welding / cutting guidelines that l would include a safety checklist for the operator to follow before, during, and after the welding operation. Identification, accessibility, and marking of all j emergency shutoff valves would be accomplished by using the P&ID drawings addressed in Safety Assessment Recommendation #20. These drawings would include 1 diagrams to provide a quick and definitive means of I proper identification and to indicate the accessibility of the shutoff valves. Additionally, markings utilized on these shutoff valves would also be included on the l P&ID drawings to aid in identification. ) We will conclude our evaluation and make the necessary changes for the 3 areas above by September 1, 1987. b. A procedural program for inspection, maintenance, and testing of all fire protection features and equipment had not been developed. B&W RESPONSE: The weakness identified above is addressed in Procedure j AS-1116, "CNFP Fire Protection Equipment Control". This procedure covers all aspects of fire protection equipment maintenance and control relevant to CNFP operations. The discussion of this weakness on Pages 10-11 of the inspection report included references to fire doors, fire dampers, penetration seals, etc. The CNFP does not utilize these fire protection devices and as a result were not included in Procedure AS-ll16. Emergency lighting maintenance is addressed in Procedure AS-1130, "CNFP Emergency Equipment Maintenance". c. Annual flow tests of the fire protection water supply have not been performed.
2. Continued-- B&W RESPONSE: We agree with the assessment on the annual flow tests. As a result, we will purchase an appropriate flow meter which will be used in future annual tests. Procedure AS-lll6, "CNFP Fire Protection Equipment Control", will be updated to include;this new requirement. Scheduled completion date for this is August 1, 1987. d. Fire protection training for the fire brigade does not include an annual practice session and classroom training of essential fire. protection subjects. (The response to 2.d. is included with Item 2.e. below.)- e. The fire brigade leaders did not complete additional-training in leadership and fire-ground command.- i i B&W RESPONSE: We have evaluated items d and e above and have concluded that our present training is sufficient for the early response of our fire brigade to provide initial fire containment until arrival of offsite emergency response organizations. l Page 15 of the safety assessment report indicates the following concerning the CNFP's fire potential. " 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". Based on this, we believe that the existing fire brigade training provides more than adequate classroom and practical training to cover the conditions which may impact the health and safety of the workers and plant structures at the CNFP. f. Area specific fire fighting emergency preplans for all plant areas have not been developed.
s d 2. Continued-- B&W RESPONSE: i We have evaluated the weakness identified Item f. with respect to the CNFP operations and have coc.luded.that the existing fire fighting emergency preplans as indicated in our Emergency Plan and Procedure are 1 adequate to cover the potential fire emergencies -encountered at the CNFP'which is in line with the fire potential as indicated in the safety assessment (see B&W Response to 2.e.). 3. Dikes and drair. age control in accordance with NFPA-30 to l control the spillage of hazardous chemicals had not been provided. B&W RESPONSE: ] Presently, our bulk storage of hazardous chemicals is remote from the CNFP main building. This separative distance precludes a near term hazard to plant and personnel. We will be evaluating NFPA-30 and other appropriate regulations to determine the proper long term control <4 to implement. 4. Collectively the following issues indicate a weakness in the emergency preparedness program: a. 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. B&W RESPONSE: We are presently reviewing our Emergency Plan (RCP) and Emergency Procedure with regard to the other B&W sites, NRC requirements, including the proposed rule for Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees, and Virginia regulations. Our goal is to establish an overall consistency of notification between all B&W facilities, NRC, and the State to preclude misunderstanding and provide for efficient dissemination of emergency. information. We will conclude our evaluations and make appropriate revisions to our Emergency Plan and Procedure in accord with the numerous regulatory requirements.
I l 4. Continued-- b. A timely method for communication between emergency team members and emergency coordinators-and leaders had not been implemented such that emergency operation could be efficiently controlled. B&W RESPONSE: We agree with this weakness regarding a need for improved communication methods. We will provide appropriate key emergency team members with portable radios which will be compatible with the security radios presently in place. .c. The supply of emergency SCBA equipment was not sufficient to outfit both a full fire brigade and radiation monitoring personnel that may require the use of SCBA equipment. B&W RESPONSE: Presently, we have a supply of 4 SCBA equipment which is sufficient to immediately outfit 3 fire brigade members and one rad team member. The intent of our emergency equipment is to provide for the immediate needs of our emergency team members for the minor emergencies that could realistically occur at the CNFP. We agree with the assessment teams' conclusion that there is not a significant fire hazard associated with the CNFP operations and as a result have strived to structure our emergency response organization and equip.aent to suit these specific needs. In the very unlikely event that a major emergency requires additional SCBA equipment, these are readily available within 5 minutes from the NNFD or LRC facilities. Also, we have structured our emergency response team to utilize the local agencies (i.e., fire departments, hospitals, etc.) if a major emergency response is warranted. We have secured letters of agreement from these local agencies regarding the use of their emergency services. In light of these considerations, we believe that our present emergency equipment inventory is more than adequate with regard to the scope of operations and potennial emergency situations that could be encountered at the CNFP. d. 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. I
0 0 4. Continued -- B&W RESPONSE: i We concur with this weakness in that we do not have a formalized training for key management and security personnel. On.3-12-87, we initiated a basic training of CNFP management on the provisions of our SNM License and l Health-Safety program, which included information on our Emergency Plan. We intend to expand on this training by-having an annual training of management and security personnel where various scenarios of emergencies will be 1 related and appropriate response offered. ~ e. The Emergency Procedure did not provide.all the pertinent emergency information. B&W RESPONSE: The intent of this weakness is to indicate.in general terms that certain services and potentially important information given in the Emergency Plan (1:CP) was omitted from the Emergency Procedure. Specific examples were not given in the body of the assessment, however, this was discussed with Region II inspectors and specific examples of this weakness include: The RCP states that Meteorological data is available from B&W, LRC as well as Virginia and National Weather Bureaus. The Emergency Procedure does not indicste j this. The RCP indicates that instrumentation and laboratory ana2:nical capabilities are available at LRC and NNFD but this is not reflected in the Emergency Procedure. It is our intention to review the RCP and the Emergency Plan to assure that all necessary emergency information is accurate and consistent between the two documents. The above examples will be included in this review. We will conclude our evaluations and make appropriate revisions to our RCP and Emergency Procedure in accord with the numerous regulatory requirements.
l l APPENDIX B The discussion lists each assessment recommendation followed by our response. The same numbering scheme used in the NRC Inspection Report 70-1201/87-02 is used here for your convenience. .l 1. Proceduralizing the multipurpose use of safe transport carts to remove the. possibility of their misuse. B&W RESPONSE: Transport cart.: can be utilized for SNM (4" slab only) and for miscellaneous non-SNM items. We presently have administrative j controls in place regarding the applicability of the 4" slab nuclear safety requirement which precludes the misuselaf these transport carts for SNM. Our SNM is contained in 3 basic forms: pellet boxes, individual rods and completed fuel assemblies. The fuel assemblies are not controlled by the 4" slab, however, their size, weight, 'nd quality and administrative controls prohibit ti use of transport carts for fuel assemblies. Non-SNM items that may be placed on the transfer carts are not of a nature to create a nuclear safety concern or industrial or chemical hazard. As a result, we feel our existing controls are adequate to prevent hazardous j misuse of these transport carts. i 2. Revising the Health-Safety Audit Procedure (AS-1125, Rev. 6) to reflect CNFP practices and commitments. B&W RESPONSEg Revision 6 of Procedure AS-1125, " Health-Safety Audits", referenced Exhibit A (Form HS-113) as the form used by outside CNFP independent auditors. We concluded that.the use of this form was unnecessary and redundant and has been deleted from the procedure. Exhibit B of Revision 6 of AS-1125 was not mentioned in the procedure text. Exhibit B was redesignated as Exhibit A and is now appropriately referenced in Section 4.3 of the procedure. 3. Providing a copy of the memorandum to the independent auditor (NCSG and Radi" '.on Safety) on the corrective action taken on recommendatior. made based on the quarterly audit. I a
3.- Continued -- B&W RESPONSE: J Procedure AS-1125, " Health-Safety. Audits", Paragraph 4.2 has -{ been revised to require the written response of audit findings I to.the auditor with a copy of the response to the Plant Manager. 4. 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. B&W RESPONSE: i We concur with the recommendation and as a result we have modified our testing apparatus to meet the requirements of this recommendation. 5. Performing fire hose inspections on a monthly basis and including an intense visual inspection of hoses. B&W RESPONSE: We have reviewed this recommendation to our present procedure (AS-1130, "CNFP Emergency Equipment Maintenance Procedure") and our scope of operations. We concluded that the quarterly inspections of fire hoses is more than adequate to identify equipment degradations that could lead to a meaningful reduction in our emergency response program. The response for Recommendations 6 through 8 is collectively indicated after Recommendation 8. 6. Performing annual medical examinations for fire brigade-members including pulmonary and EKG testing. 7. Conducting fire drills in a manner consistent with nuclear fire protection industry practice. 8. Providing sufficient fire fighting equipment to outfit a full-complement of fire brigade personnel.
i 8. Continued -- B&W RESPONSE: We have evaluated Items 6, 7, and_8 and conclade. hat the systems presently in place for our fire brigade and fire drills are appropriate with regard to the scope of operations and real fire potential at the CNFP. The degree of equipment, training, and fitness for duty requirements are adequate to cover the emergency conditions that may impact the health and safety of the workers and plant structures at the CNFP. This approach is consistent with the safety assessment report analysis of the CNFP's fire potential. 9. Evaluating the risk to the plant and workers from fire or toxic gas exposure and implementing a fire safety program to 1 minimize the risk. B&W RESPONSE: We agree with the recommendation and therefore will evaluate-the risk to the plant and workers from fire or toxic gas exposure. As we conclude our evaluations, we will incorporate necessary changes either in our procedures or on our local safety rules. 10. Including data from the Material Safety Data Sheets (MSDSs) and the Hazards Communication Program in the refresher training program. B&W RESPONSE: We have reviewed the recommendation and conclude it is appropriate to include pertinent information from the Material Safety Data Sheets and the Hazards Communication Program in our employee training program. We will be revising the appropriate inhouse procedures to accommodate this recommendation. Scheduled completion of procedure revisions is set for July 1, 1987. 11. Including data from the MSDSs in the Fire Prevention / Protection Plan. B & W R' ONSE: We have evaluated this recommendation and conclude that our present system is very effective in controlling chemical hazards at the CNFP. We utilize two Master Copies of the complete MSDS books in the Health-Safety and Manuft turing
1 q 11. Continued -- i areas for personnel access. Also, MSDSs are provided for the 'l specific chemicals used in an area. Personnel are aware of the purpose, importance, and location of the MSDS books. Providing additional copies of MSDSs in other guidelines or procedures would not significantly add to the effectiveness of the hazardous chemical control program used at the CNFP. s 1 12. Incorporating the review of chemicals and chemical hazards into the facility change review process. B&W RESPONSE: We concur with this recommendation and will incorporate appropriate guidelines in procedure AS-1120, "CNFP Safety Review Board" for the review of chemicals and chemical hazards used at the CNFP. This will cover both our change review process and Safety Review Board meetings. Scheduled completion date is July 1, 1987. j The response for Recommendations 13 through 19 is collectively J indicated after Recommendation 19. ] l 13. 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. ] 14. 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. 15. 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. 16. Providing for renotification of offsite agencies upon emergency termination and as any significant change in plant conditions occur. 17. Developing and using a standard message form to facilitate the transmission of emergency information to offsite organizations which includes: time, date, classification, plant status, onsite and offsite protective actions, dose estimates, and meteorological information.
1 18. Providing for a quarterly review and update of emergency telephone numbers and personnel assignments in the Emergency Procedure. 1 i 19. Including the Emergency Procedure the various site and offsite emergency center locations. B&W RESPONSE-In regard to Recommendations 13 through 19, we will follow the same corrective action plan as described in our response to Weakness 4.e. 20. Including P& ids and other operational data in the assembly area emergency kit. B&W RESPONSE: We agree with this recommendation and we will be including appropriate plant drawings and operational data in the assembly area emergency kit. Scheduled completion date.is August 1, 1987. The response for Recommendations 21 and 22 is collectively indicated after Recommendation 22. l 21. Including in the Emergency Procedure the sources of accurate c meteorological information as well as the telephone numbers t for contacting them. 22. 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. j B&W RESPONSE: In regard to Recommendations 21 and 22, we will follow the same corrective action plan as described in our response to Weakness 4.e. )
e ~ 23. Incorporating a specific battery verification program into the routine maintenance procedures to include what checks are made and to what frequencies. I B&W RESPONSE: k We agree with this recommendation and will incorporate this-improvement in Procedure AS-1130, "CNFP Emergency Equipment Maintenance". Scheduled completion date is August 1, 1987. 24. Performing communications drills on a monthly basis to include the actual transmission of an emergency message to'offsite agencies. B&W RESPONSE: We believe that communication drills on a monthly basis is inappropriate for our facility. The scope and true risk potential as described in the safety assessment is such that our present annual method of communication-drills is more than adequate to ensure the proper and efficient execution of our emergency procedures. 25. Performing radiation monitoring drills semiannually to include environmental monitoring and responses to simulated releases. B&W RESPONSE: Presently we have a formalized drill program with provisions for annual evacuation, medical and radiation monitoring drills. The safety assessment team indicated in their report i that "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". We agree with this assessment of our emergency drill program and conclude that requiring semiannual radiation monitoring drills to include environmental monitoring and response to simulated releases would not significantly add to the effectiveness of our emergency program. The scope and potential hazards associated with CNFP operations should not require added radiation monitoring drills. The response for Recommendations 26 and 27 is collectively indicated after Recommendation 27. 26. 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.
27. Including in the RCP and Emergency Procedure a. clear description of which site individual will be the primary interface and will be in charge of coordinating the offsite agency support effort. B&W RESPONSE: In regard to Recommendations 26 and 27, we will follow the same corrective action plan as described in our response to Weakness 4.e. 28. Designating an individual'on the backshift who has the full ] authority to control emergency operations and has received J training on the RCP. B&W RESPONSE: The backshift operation for the present and foreseeable future will be for Machine Shop operations of no more than seven machinists. Work to be conducted does not involve any j operation that constitute a risk in nuclear or radiological safety. Training of the backshift foreman who may be rotated l with day shift personnel is not readily achievable and is not appropriate based on the minimum risk involved. In the rare 1 case of any emergency, the foreman as well as any of the personnel on duty have been instructed to contact the security guard on duty. The guard is trained adequately for his response in emergency situations and will immediately notify key emergency officers who will be able to commence full authority and control over the situation, i 29. Providing for a formal annual review of the RCP and providing I for management concurrence and approvals on its revisions. B&W RESPONSE: We agree with this assessment and we will establish a formal annual review and approval of the Emergency Plan (RCP) by j appropriate management personnel including revisions. Scheduled completion date is August 1, 1987. 30. 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. j
(, l 30. Continued -- B&W RESPONSE: We believe our present audit and practice drill program is sufficient to assess the effectiveness of onsite and offsite interfaces, capabilities, and equipment as well as our Emergency Plan and Procedure. The Emergency Procedure is presently approved by CNFP management and we are planning to establish a similar management approval process for our Emergency Plan (see Recommendation #29). These audit and-overcheck measures are appropriate to cover the scope of our emergency systems at the CNFP. The response for Recommendations 31 and 32 is collectively indicated after Recommendation 32. 31. Providing a copy of the RCP to State and local support agencies. 32. Providing for wider distribution of the RCP to onsite emergency management personnel. B&W RESPONSE: In regard to Recommendations 31 and 32, we will follow the same corrective action plan as described in our response to Weakness 4.e. i ..}}