ML20215L449
| ML20215L449 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/29/1987 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8706260055 | |
| Download: ML20215L449 (24) | |
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. GENERA.Lh ELECTRIC I
NUCLEAR FUEL & COMPONENTS MANUFACTURING GENERAL ELiECTRIC COMPANY
- P.O. BOX 780 e WILMWGTON, NORTH CAROUNA 28402 April 29, 1987 s
D 2.790 INFORMATION REMOVED p.
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Mr. J. Philip Stohr, Director T E' O Division of Radiation Safety & Safeguards
.P_.
U. S.' Nuclear Regulatory Commission, RII
@z 101 Marietta Street, NW - Suite 2900 d
Atlanta, Georgia 30323
Dear Mr. Stohr:
References:
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/86-22 GE Nuclear Fuels & Components Manufacturing hereby submits the following information regarding the subject Operational Safety Assessment inspection report.
Attachment A An overview of GE response to the weaknesses and improvement items noted in the subject report.
Attachment B Detailed response to identified weaknesses in Appendix' B.
Attachment C Detailed response to identified improvement items in Appendix C.
I Attachment D Areas to be considered for improvement in the operational safety assessment program should the NRC elect to continue this type of practice.
Attachment E Summary of NF&CM personnel efforts and costs l
expended in support of the assessment.
Attachment F Licensee commitment information regarding the CO 2 cylinders.
l quench of UFg The Operational Safety Assessment' inspection concept is new to GE and to the NRC as applied to fuel fabrication facilities.
It is clear that the program yielded some degree of information which affords both the licensee and the NRC the opportunity to improve-the safety at fuel fabrication plants.
2.700 INFORMATION REMOVED l
8706260055 870429 PDR ADDCK 0700 3
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C Cortified By ITT) 'O N ' ] E E o'7
p GENER AL $ ELECTRIC Mr. J. Philip Stohr April 29,_1987 Page 2 GE appreciates the, opportunity of having available the NRC's expertise in operational safety in those areas outside the current scope of regulations.
We believe that regulations can only be effective to a certain degree and that improved margins of safety come from prudent planning and behavior by the licensee, a process which is stimulated by activities such as the operational safety assessment.
We will be pleased to discuss our responses in more detail as well as any other aspects of operational safety as deemed necessary.
i Pursuant to 10 CFR 2.790(a)(4), General Electric Company requests that the information contained in Attachnent E be withheld from public disclosure.
Very truly yours, W
0-s T. Preston Winslow, Manager Licensing & Nuclear.Taterials Management M/C J88 1
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Attachments l
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j GENERAL $ ELECTRIC Mr.1J. Philip Stohr
' April 29, 1987 4
i ATTACHMENT A OVERVIEW OF GE RESPONSE TO
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l WEAKNESSES & IMPROVEMENT ITEMS IDENTIFIED DURING THE-OPERATIONAL SAFETY ASSESSMENT FIRE PREVENTION PROGRAM The general area of fire safety and protection received considerable-attention during the' assessment.
A major issue was c
centered on the question of whether GE maintained a " fire brigade"
.(OSHA-terminology).to fight structural fires or relied on an This issue ~
emergency response team to respond to incipient fires..
hasL been resolved with North Carolina OSHA with the understanding
.that for incipient fires, GE will use an emergency response team and for. structural fires, the volunteer' fire department will be relied upon for firefighting.
In' addition to the time spent with N. C. OSHA, we have spent considerable time with Factory Mutal Engineering &-Research personnel and the GE Corporate Health, Safety & Property Protection function reviewing our fire protection program.. Their collective assessment is that our program is appropriate and one of the better ones for a facility of this type.
Our corrective actions have generally exceeded the recommendatons of these highly regarded specialists.
RADIOLOGICAL CONTINGENCY & EMERGENCY PLANNING In this area, a significant thrust appeared to be in the direction i
of making fuel fabrication plants like reactors.
This appears I
somewhat contrary to the 1981 NRC order, NUREGs 0762, 0767, 0810, 1179, 1189 and 1198, as well as the most recent proposed rule for (52 FR 12921-12935).
Fuel facilities clearly face public comment site-specific risks and require proper forms of planning and procedures to adequately address these risks..
Our responses have focused on this referenced information and what we believe to be the most appropriate for our facility in our location.
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m Mr. J. Philip.Stohr April 29,_1987 Page 1 of 9 ATTACHMENT B Reference Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY GE-86-22-03 L'ack of management controls in the In the subject areas, there are area of procedure change reviews &
adequate management controls which documentation, incident apparently were not reviewed investigations & follow-up during the safety assessment.
No activit ies changes to existing systems are planned.
1 86-22-04 Operating procedures often lack Safety related controls / limits in specificity in the area of safety procedures are intended to be steps or comments as to why the specific in their application.
safety steps are needed Placing explanations of the rationale for safety controls /
limits in operating procedures may lead to inappropriate interpreta-tion by personnel resulting in a negative impact on safety.
No action is planned on this item.
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86-22-05 No positive nuclear criticality This valid observation endorses a safety controls for placing U need previously identified by contaminated materials in 4-ft NF&CM.
At the time of the safety cubic waste boxes assessment, prototype box fill monitors were in place and functioning in UPMP as part of a program to evaluate control alternatives.
NF&CM plans to continue protype testing and l
evaluation.
Results will be l
presented to management for final implementation decisions / actions.
86-22-12 Lack of adequate fire Onsite personnel, including major i
prevention / control training contractors, have received fire l
extinguisher / alarm training. They program have also received training in hazardous materials, including flammables.
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. Mr. J. Philip'Stohr.
April 29,.1987
' ATTACHMENT.B - Page 2 of 9 Reference Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY GE 86-22-13 Lack of specification of The fire prevention specialist.,
~ qualifications and assignment of-must meet approved position guide-i responsibility for fire protection qualifications.which encompass a
personnel those items.specified-in the safety assessment report.
86-22-14 Inadequacies in fire protection NF&CM's weekly, monthly and annual maintenance, testing & inspection inspection and testing is l
program satisf actory and meets the l
requirements of the National Fire Protection Association (NFPA) as
.l verified by Factory Mutual (FM) during an April 1987 site visit and inspection.
Hose stations will be tested-annually. The halon system has been cleaned.
Following vendor maintenance / testing, necessary modifications / improvements will be
.made.
86-22-17 Inadequacies in development &
NF&CM does not maintain a fire implementation of training program brigade.
Emergency Response Team for fire brigade (ERT) members are currently trained to fight all incipient fires. They are well aware of their limitations which dictate
' when offsite assistance should be requested.
Leaders have received additional training.
Site specific training is a part of the quarterly training sessions.
' 86-22-19 Failure of fire brigade to use Applicable items were covered proper manual fire-fighting during the first quarter ERT methods training session.
Specific l
emergency instructions are being written as part of the EMT
Mr. J. Philip Stohr April 29, 1987 ATTACHMENT 8 - Page 3 of 9 Reference Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY GE l
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training manual which each team member receives.
86-22-20 Failure to conduct fire drills in NF&CM has renegotiated a fire a manner consistent with industry response agreement with the Castle practice Hayne VFD.
Drills with the VFD have been held as part of NF&CM training sessions. These drills are considered completely adequate.
e 86-22-21 Lack of adequate manual equipment NF&CM has adequate, up-to-date to mitigate potential site fire equipment to handle incipient fire hazard conditions emergencies as confirmed during an April 1987 Factory Mutual inspection.
86-22-23 No capability to allow offsite A dry hydrant will be installed fire department to draft water to enable the VFD pumper to draft from either pond or elevated fire water from the pond in the event water storage tank & supply of a fire pump failure.
The sprinklers in event of fire pump pumper will be connected to the failure existing pump house hose connections so that this water can be pumped into the sprinkler system.
86-22-24 Sprinkler heads obstructed by HVAC The subject sprinklers have been ducts and struc+ ural steel identified and design FM0/FM0X modifications are in orocess.
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86-22-25 No sprinklers installed under Per the April 1987 Factory Mutual mezzanine near calciners inspection, no additional sprinklers are required in the subject area as sprinkler coverage from adjacent areas is adequate.
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' Mr. J.JPhilip-Stohr
' April 29,.1987
' ATTACHMENT.B - Page 4 of 9
Reference:
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' Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY'GE a
86-22-26.
GEC0 nezzanine sprinkler heads As. suggested, heat collection l
require installation of heat devices will be installed.
j collection devices 86-22-27 FM0/FM0X 1.5" fire hose stations This item has been evaluated; NFPA do not - appear ' designed in and FM requirements are met..
accordance with NFPA criteria 22-28 FM0/FM0X 1.5" fire. hose station This item has been evaluated;L NFPA design may be inadequate to and FM requirements are met, support effective hose stream due to excessive-friction
-i 86-22-29 Fire potential due to New ground cable has been deterioration of _ ground cable at H installed.
This cable is now truck trailer facility routinely inspected.
86-22 Lack of adherence'to safety Procedures for locking out precautions & controls when equipment will be reviewed with servicing process equipment applicable _ operating and maintenance personnel.
86-22-32 Failure to treat important Systems and documented procedures I
equipment & controls, FM0/FM0X, as are in place which implement a.
-l essential equipment from-a continuing program to identify key
- calibration, maintenance &
equipment and controls essential.
surveillance standpoint to safety, and to specify calibration and maintenance requirements.
Identification of 1
key control elements within the j
fuel f acility will. be incorporated j
in this program on an ongoing basis as appropriate.
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.Mr.d.PhilipStohr April 29, 1987 EATTACHMENT B - Page 5 of 9 Reference.
-Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY GE 86-22-43
' Failure to have fire protection The potential for UF cylinder 6
capabilities to prevent propane exposure to a LP tank BLEVE is tank BLEVE or to protect UF minimal.
In an accident,.the LP 6
cylinders tanks, as ~ designed and. installed, would not BLEVE in the direction,
of UF cylinder storage (i.e., the -
cylin8ersarenotintheBLEVE line of sight).
j Additional protection is afforded by the volunteer fire department deluge gun and NF&CM hydrant system.
86-22-4'4 Detailed accident evaluation is GE has a program in place which warranted with emphasis on requires technical and legal risk administrative & engineered evaluations of.any planned / revised controls to mitigate accident operation involving hazardous consequences business activities'in which the potential damages from a single, low probability accident exceed
$50 million.
However, for the potential fire and process accidents identified during the safety assessment, administrative and engineered controls preclude either technical or legal risk evaluation.
For all routine or special activities involving enriched uranium, a technical criticality and radiological evaluation is performed which includes both normal operating and accident conditions such as equipment f ailure, fire explosion, etc.
Prior to approval for operation, criticality and radiological consequences are assessed considering the administrative and
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Mr. J.. Philip Stohr April 29, 1987-ATTACHMENT 8 - Page 6 of 9 Reference L
Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY GE engineered controls, and verified to be acceptable. These i
assessments are documented and available for review.
Further, NF&CM maintains 'a safety review committee which routinely reviews the significant aspects of safety associated with major site operations and imposes corrections or conditional actions to assure and improve safety.
Discussions of these programs and demonstratons of accident evaluation are included in Part II of the SNM-1097 license document.
NF&CM plans no additional action.
'86-22-47 Include complete description in During the next renewal of NRC RCP of response role &
license SNM-1097, NF&CM will capabilities of offsite agencies provide any required demonstration for emergency response information in accordance with NRC licensing guidance.
86-22-48 Designate in RCP licensee Detailed information regarding interf ace with various offsite agency interfaces is included in groups during an emergency the implementing procedures.
The RCP is inappropriate for working agreements and day-to-day instructions. No actions are planned.
86-22-49 Include description in RCP of GE equipment located at New equipment at NHMH including Hanover Memorial Hospital (NHMH) inventory / calibration frequency is is included in the listing of typical equipment in Table 2.2 of the current RCP and, as such, is
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l Mr.- J. Philip Stohr April 29, 1987-ATTACHMENT B - Page 7 of 9 Reference Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY GE maintained under the same.
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calibration program as equipment H
located - onsite. During the next routir,e RCP update, Table 2.2 will-be revised to more clearly indicate which types of instrumentation are typically at 1
the hospital.
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~86-22-50 Specify annual training program
'GE will continue to hold annual for offsite agencies, ensuring training, exercises and request that training describes specific participation from support response role & plant operating agencies as appropriate for the i
procedures type of emergency.
i 86-22-51 Failure of RCP emergency.
NF&CM believes that our l
classifications to conform to classification program conforms to.
i industry practice the NRC guidelines for our f acility and our State I
classification' system, i
Additionally, implementing j
procedures specify what communications are required when i
the Emergency Organization is assembled.
No actions are planned.
86-22-76 Include evacuation routes, This will be done during the next assembly areas, ECC location in routine RCP update.
RCP site map-86-22-77 Include all maps and diagrams NF&CM will resupply the NRC with
- specified to be in RCP copies of the maps and diagrams with the exception of the topographical map which is no longer available per the U. S.
Geological Survey.
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Mr. J. Philip Stohr April ~29, 1987 ATTACHMENT B.- Page 8 of 9 Reference
.,_ Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY GE-86-22-78 Include vicinity map with location This will included as part of the of support fire & medical response to 86-22-77, facilities o
86-22-79 Include a discussion of transient There is no significant transient populations in RCP population at NF&CM; work is performed onsite primarily by employees of GE and the site contractor.
In addition, there is no significant transient population near the plant site.
86-22-80 Include schematic diagrams of Current process and equipment, piping &
instrumentation drawings are instrumentation in RCP maintained in the Emergency i
Control Center-(ECC) where they j
are immediately available if a
required.
Portions of SNM-1097
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provide general process i
descriptions and layout
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information. We believe this to be adequate.
86-22-81 Include'a description of how Items 81 and 82 - This information emergency equipment should operate is included in the demonstration during an emergency portion of the application for SNM-1097 (specifically, Chapters 86-22-82 Include a specific discussion of 15 and 16 of Part II).
design criteria for precluding criticality accidents l
1 86-22-83 Include a description of expected Section 2.1.2 of the RCP states performance of f acility structure that the f acility structure meets in severe weather all applicable building codes with respect to wind, flood, fire and earthquakes.
In the event of hurricanes, floods, fire and/or
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~Mr. J. Philip Stohr-April 29, 1987
- ATTACHMENT B - Page 9 of-9 Reference Number NRC IDENTIFIED WEAKNESSES ACTIONS TAKEN OR PLANNED BY GE earthquakes, these codes provide a high degree of assurance that only minimal damage would occur.
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GENERAL & ELECTRf C Mr. J. Philip Stohr April 29, 1987 Page 1 of 9 ATTACHMENT C Reference NRC IDENTIFIED AREAS Number FOR IMPROVEMENT RESULTS OF GE CONSIDERATION
. 86-22-02 Establish criteria for review of The formal system for review and procedure changes in order to make documentation of process changes better use of procedural change and repairs which impact nuclear i
review system safety is governed by a department level procedure.
Significant safety-related changes to the UF 6 vaporization areas, some of. which.
necessitated revisions to operating procedures, were documented in the formal review system in accordance with the criteria prior to the' safety assessment.
No changes to the existing system are planned.
86-22-06 Ensure proper training of key A review will be made of the personnel in nuclear criticality
~ training program for new key individuals from a criticality procedures standpoint, and a revised program will be implemented if applicable.
86-22-07 Establish maximum enrichment Enrichment of feed material into allowed in UPMP as an automatic vaporization is administrative 1y engineering control controlled and UPMP has been demonstrated safe for the currently allowed maximum enrichment. Therefore, no additional controls are planned for UPMP at this time.
Should NF&CM elect to bring higher enriched material into some portion of the facility, this situation would be re-evaluated and proper controls implemented to assure segregation.
86-22-08 Control the use of non-fire These areas are protected by fire retardant wood in U process area suppression systems.
Some time ago, the subject of a requirement
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.Mr. J. Philip Stohr April'29, 1987 j
ATTACHMENT C - Page 2 of 9
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1 Reference NRC IDENTIFIED AREAS Number FOR IMPROVEMENT RESULTS OF GE CONSIDERATION
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i for fire-retardant wood was J
evaluated and determined to be I
unnecessary. This decision is to be re-evaluated considering current practices.
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86-22-09 Establish a fire prevention As' suggested, inspection inspection program which complies frequenciae ner Factory Mutual with nuclear industry standards (FM) requirements are now included in the safety manual.
l 86-22-10 Improve loss prevention inspection This will be included as part of 1
of welding, cutting & grinding the NF&CM Industrial Safety I
operation Manual.
86-22-11 Establish fire watch training This will be included as part of program for individuals associated the NF&CM Industrial Safety with welding, cutting & grinding Manual.
86-22-15 Maintain adequate number of fire The Emergency Reponse Team (ERT) brigade members on each production manual has been updated to assure i
shift that an adequate number of ERT members is maintained on each production shift.
(NF&CM does not have a fire brigade.)
86-22-16 Include an evaluation of cardiac ERT members are currently function during medical exam of scheduled to receive an annual fire brigade members physical.
Cardiac function will continue to be performed as deemed necessary by the NF&CM onsite physician.
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i Mr. J. Philip Stohr April 29,-1987 ATTACHMENT C - Page 3 of 9 Reference NRC IDENTIFIE0 AREAS Number FOR IMPROVEMENT RESULTS OF GE CONSIDERATION 86-22-18 Develop fire emergency plans which This suggestion has been provide guidance to fire brigade incorporated into the quarterly i
for various process areas ERT training program.
l 86-22-22 Implement a comprehensive fire Fire potential is minimized by protection program which will controlling combustible material minimize potential fire risk to at the periphery of these radioactive. waste material stored locations.. In the event of a outdoors fire, onsite equipment and.
Volunteer Fire Department (VFD) tankers and pumper trucks would be used.
Additional air support is i
available from the Forestry i
Service.
Past experience has indicated good communications and support.
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86-22-30 Conduct annual audit of chemical A complete inspection of NF&CM safety program bulk storage tanks has been 2
completed. This inspection will l
be done on an annual basis, j
l 86-22-33 Modify computer programs used for The current calibration program is calibration scheduling in order to planned to be replaced as part of
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accommodate more than one an overall upgrade to the site I
calibration frequency maintenance program.
The new l
system will have the capability to accommodate more than one
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calibration frequency.
j 86-22-34 Correct calibration "due date" Errors identified in calibration l
records due date records have been corrected, l
4 86-22-35 Evaluate procedural requirements &
Procedural requirements concerning I
practices concerning " extension" calibration extension will be of calibration dates reviewed as part of the overall site maintenance program upgrade.
Mr. ' J. Philip Stohr -
April 29, 1987 ATTACHMENT C - Page.4 of 9 Reference NRC IDENTIFIED AREAS
. Number FOR IMPROVEMENT RESULTS OF GE CONSIDERATION 86-22-36 Improve overall recordkeeping Recordkeeping will be improved as pertaining to calibration a result of the site maintenance
' improvement program.
86-22-37' Implement vendor recommendations Vendor recommendations are now for preventive maintenance of included as part of the diesel generator computer-based preventive maintenance request program.
I 86-22-38 Include inspection ' of - electrolyte This is now part of the preventive l
1evel in maintenance checks for maintenance program.
batteries 86-22-39 Improve log entries pertaining to This is now part of the preventive maintenance activities maintenance program.
l-86-22-40 Improve recordkeeping related to Vendor service manuals have been vendor service manual returned to the files.
86-22-41 Identify passive interlocks &
Items 41 & 42 - A study is develop periodic functional currently underway to review the testing program identification of equipment and j
l controls essential to safety from j
86-22-42 Identify active interlocks &
a calibration and maintenance develop periodic functional st andpoint.
Proper functioning of testing program active and passive interlocks l
essential to safety is being included in the scope of the I
review.
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86-22-46 Resolve out-of-date calibration of The subject instruments will no j
two radiation monitors at offsite longer be maintained at New i
medical facility Hanover Memorial Hospital (NHMH) and have consequently been l
replaced.
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Mr. J.' Philip Stohr i
~ April 29,:1987
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. ATTACHMENT C - Page 5 of 9 j
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l Reference NRC IDENTIFIED AREAS Number FOR IMPROVEMENT RESULTS OF GE CONSIDERATION 86-22-52 Modify Notification of Unusual In 10 CFR 70.22(1) the NRC Event Class to be notifiable acknowledges the differences'in within 15 minutes potential radiological hazards to the public from a fuel fabrication facility and from a reactor. To further distinguish these-differences, the NF&CM NRC-approved RCP utilizes the " Site Emergency" designation instead of the " Unusual Event" used for reactors.
l Current procedural notification requirements are considered adequate for the site.
86-22-53 Clarify notification procedures to When a potential hazard to the define "immediate" notification public exists, NF&CM's emergency procedures provide for immediate J
notification to State and local agencies.
For clarity, the procedures will be revised to note that State and local notifications are to be promptly initiated, followed by NRC notification not later than one hour after the emergency is declared.
86-22-54 Develop & implement standard The NRC incident notificaton notificiation procedure including format, currently used by NF&CM, a standard message form will be formally incorporated into emergency procedures, i
86-22-55 Make provisions for authenticating GE has provisions for emergency messages authenticating emergency messages.
This will be more clearly I
m Mr. J. Philip Stohr.
April,29, 1987 ATTACHMENT C - Page 6 of-9 Reference NRC' IDENTIFIED AREAS
. Number FOR IMPROVEMENT
-RESULTS OF GE CONSIDERATION 4
described in emergency procedures during the nert routine review.
I 86-22-56 Describe back-up communication Adequate communication systems and j
system for notifying offsite alternates exist and are described agencies in Section 6.2 of the RCP.
86-22-57 Provide quarterly update of The GE Emergency Call List will be emergency call list updated twice a year.
j 86-22-58 Include CP&L on emergency call The CP&L telephone number, listed li st '.
on the emergency call board in the ECC, will be added to the Emergency Call List.
86-22-59 Update ECC library end emergency The fire alarm box sketches have procedures to include location &
been updated to include UPMP and number of UPMP fire alarm boxes have been included in the ERT manual.
In addition, these updates will. be posted on ERT bulletin boards located at various i
locations onsite.
l 86-22-60 Make provisions for performing Items 60 & 61 - Immediate l
computerized dispersion dispersion calculations would not calculations in ECC be necessary for a fuel f abrication f acility such as 86-22-61 Include in procedures a NF&CM. A release would generally correlation of UF dispersion be of very short duration and of s
results & public hazard potential such a character that dispersion to f acilitate making protective results are not needed to define action recommendations to offsite immediate response actions.
agencies Dispersion calculations, available i
onsite to the Emergency J
Organization from outside the 1
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'Mr. J. Philip Stohr 1
April 29, 1987 J
ATTACHMENT C - Page 7 of 9 t
Reference NRC IDENTIFIED AREAS Number FOR IMPROVEMENT RESULTS OF GE CONSIDERATION l
i controlled access area (CAA),
would be useful later'in the l
recovery cycle to evaluate potential longer term actions and document potential exposure levels.
86-22-62 Specify in RCP or procedures the Location of radios will be l
location of portable radios used
~ indicated on documentation in the by emergency teams ECC and in internal procedures.
86-22-63 Provide for monthly operability Communication equipment-is
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tests of emergency communication routinely used which.provides r
equipment sufficient operability checks.
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-Make provisions for formal Items 64 NF&CM has an' onsite inventory program of all on site Medical function as described in medica 1' units Chapter 6 of the RCP. Onsite EMTs, trained and qualified by 86-22-65
' Add tamper indicators to emergency offsite agencies, serve in a kits voluntary capacity across the plant site and have immediate i
86-22-66 Include in RCP a description of access to supplemental medical l
content & location of all supplies. GE replenist.es EMT j
emergency equipment / kits supplies as requested-by the i
EMTs.
l 86-22-67 Modify evacuation instructions to Done as suggested.
indicate to visitors the need for calm & timely evacuation 86-22-68 Train interim Emergency Directors The training syllabus and i
in offsite notification procedures will be revised to responsibilitiee include offsite notification requirements I
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m "r.'J. Philip Stohr april 29, 1997~
- ATTACHMENT C - Page 8 of 9 Reference NRC IDENTIFIED AREAS 1
Number FOR IMPROVEMENT RESULTS OF GE CONSIDERATION
-l 86-22-69 Train EMTs concerning radiological Primary medica 1' personnel are hazards trained in radiological hazards.
A volunteer EMT responding to an incident within the CAA, would perform under the direct supervision of. personnel trained i
in potential radiological hazards.
l 86-22-70 Formalize annual program for.
Drills encompass changes and act updating & retraining emergency as training-for Emergencv personnel on pertinent aspects of Organization members and their RCP alternates.
86-22-71 Ensure annual participation in These groups are included in drills by members of survey, exercises (drills) that accentuate reentry, & damage -control teams their skills. Eac* group participating in annual emergency participates in at least one drills exercise annually.
i 86-22-72 Clarify descriptions in RCP on all Items 72 & 73 - These positions important emergency staff are described in Chapter 4 of the assignments & corresponding RCP.
Detailed responsibilities responsibilities for the emergency staff and the Emergency Director are found in 86-22-73 Expand written responsibilities of the implementing procedures.
Emergency Director to reflect full J
range of responsibilities given to 1
position j
86-22-74 Indicate minimum staffing levels During the next routine RCP
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for each function area on site update, the minimum Emergency Organization staffing level will be defined and included relative to functional area assignments.
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Mr.-J. Philip Stohr
- April 29, 1987.
ATTACHMENT C'- Page 9 of 9 Reference NRC IDENTIFIED AREAS Number FOR IMPROVEMENT RESULTS OF GE CONSIDERATION 86-22-75 Improve method for distributing Procedure is being' reviewed and RCP updates to ensure intended steps will be taken to improve the recipient receives RCP update process.
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GENER AL $ ELECTRIC Mr. J. Philip Stohr April 25, 1987 ATTACHMENT D AREAS TO BE CONSIDERED FOR IMPROVEMENT IN THE OPERATIONAL SAFETY ASSESSMENT PROGRAM As a result of the October 1986 Operational Safety Assessment of the General Electric Company Nuclear Fuel & Components Manufacturing and after review of the assessments of eight other f
fuel fabrication facilities, the following items should be I
. considered by the NRC for improvement prior to similar assessments.
(1)
The assessment teams would be much more efficient if they had better integration and training prior to site visits.
(2)
The scope, approach and individual member assignments need better definition up front.
(3)
The scope and depth of the assessment need to be balanced with the personnel resources (NRC and licensee) and time allocated to the effort.
(4)
The make up of teams should be consistent between facilities.
(5)
There should be a central review of the findings and recommendations for the facilities to assure that all are 1
reported in a consistent manner.
(6)
Consideration should be given to interchanging regional team l
members between NRC Regions so as to take advantage of l
strength in various regions and to provide a periodic fresh set of eyes.
(7)
We believe that the cost benefit of the assessment effort should be evaluated to ensure that appropriate benefit is gained from the effort expended.
We have included a summary of personnel effort and costs as a proprietary attachment to this letter.
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GENER AL & ELECTRIC i
l Mr. J. Philip Stohr April 29, 1987 ATTACBMENT E NP&CM PERSONNEL EFFORTS & COSTS EXPENDED AS RESULT OF OPERATIONAL SAFETY ASSESSMENT NF&CM PERSONNEL EFFORTS:
Manhours NRC
Response
Team to Function Support Assessment
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l Shop Operations f
Facilities & Maintenance Industrial Safety Nuclear Safety Emergency Preparedness Others I
I ESTIMATED COST OF COMMITTED ACTIONS:
SK Materials Activity Labor Equipment Verification of Functional Controls Waste Box Monitors 1
Emergency Preparedness Procedures Changes Fire Protection Miscellaneous TPW bsd a
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GENERAL $ ELECTRIC i
l Mr. J. Philip Stohr' April 29, 1987 ATTACHMENT F j
i ENGINEERING EVALUATION OF CYLINDERS LIQUID CO QUENCH ON UF 6 2
(Reference Number 86-22-01)
During the Operational Safety Assessment, the NRC requested that NF&CM report the results of the subject evaluation.
This l
evaluation focused on ASTM A285 and A516 steels, construction l
materials for the ORO 30A and 30B cylinders, respectively.
Our l
l results and conclusions are as follows:
i Reducing these steels to -110* F would place them at o
temperatures below their lower-shelf energy.
There is minimal probability of cooling the UF cylinder to o
this low temperature during an emergency control situation.
Reducing the cylinder temperature below the lower-shelf energy o
value Soes.not damage the cylinder.
However, this condition coupled with sharp defects and/or a sufficient stress level could lead to brittle failure.
Charpy V Notch impact properties of ASTM A285 steel are f
o marginal at -20* F and for ASTM A516 become marginal at -90*
i l
F.
Based on these findings, NF&CM still considers CO quenching as 2
the most appropriate method for handling emergency situations.
We have, however, modified the procedures for use of liquid CO as 2
follows:
(1)
Routine use of CO for rapid cooling has been discontinued.
2 (2)
Cylinders which are subjected to liquid CO, cooling will be brought back to ambient temperature naturafly without the addition of heat.
Any subsequent heating required to prepare the cylinder for recertification will be conducted under controlled conditions and the cylinder will not be refilled /
reused without recertification.
CMV bsd
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