ML20216B182

Insp Rept 70-1113/97-07 on 970714-18.No Violations Noted. Major Areas Inspected:Safety Operations,Radioactive Solid Waste Mgt,Transportation & Emergency Preparedness

ML20216B182
Person / Time
Site:	07001113
Issue date:	08/29/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20216B156	List: ML20216B152 ML20216B182
References
70-1113-97-07, 70-1113-97-7, NUDOCS 9709050248
Download: ML20216B182 (45)

Text

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U.S. NUCLEAR REGULATORY COMMISSION REGION ll Docket No.: 70 1113 License No.: SNM 1097 Report No.: 70-1113/97-07 Licensee: General Electric Company Wilmington, NC 20402 Facility Name: Nuclear Energy Production Dates: July 1418,199,'

inspectors: D. Ayres, Fuel Facility inspector W. Gloersen, Senior Fuel Facility inspector A. Gooden, Radiation Specialist C. Hughey, Senior Resident inspector (B&W/NNFD)

Approved by: E. J. McAlpine, Chief Fuel Facilities Branch Division of Nuclear Materials Safety Enclosure 9709050248 970829 PDR C ADOCK 07001113 PDR

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.l Executive Summary General Electric Nuclear Energy Production NRC Inspection Report 701113/97 07 The primary focus of this routine announced Inspection was the observation and evaluation of the licensee's blennial emergency preparedness exercise. Additional areas reviewed included the solid radioactive waste management program, transportation of radioactive materials program, and plant operations. The report covered a one week period and included the results of inspection efforts of three regional fuel facility inspectors and the Senior Resident inspector from the Babcock and Wilcox Naval Nuclear Fuel plant.

Safety Ooerations e The identification of doors that enter into controlled areas were not adequate to prevent inadvertent entry (Section 2.a.2).

e A non-cited violation (NCV) was identified for a practice that allowed workers to leave controlled areas without performing personal contamination surveys (Section 2.a.2),

o The instructions on NSR/R postings were a dequate to assure safety and were fgliowed properly, but most postings need to be replaced with updated versions to reflect new procedural references (Section 2.b.2).

e Housekeeping was adequate except in some indoor locations adjacent to outdoor areas where debris posed a slipping hazard (Section 2.c.2).

e A licensee Identified NCV was noted for an unapproved change in the Dry Conversion Process (DCP) ventilation system implemented by maintenance personnel (Section 2.d.2).

Radioactive Solid Waste Mannaement .

e The present arrangement for the storage of Low Level Radioactive Waste (LLRW) was less than adequate due to the large volume of waste being stored and the fact that the waste storage containers were not shielded from the natural elements (Section 3.a.2).

e- The licensee's contror , procedures, and waste management program appeared acceptable and capable of accomplishing its safety objectives. This program area was effectively managed (Section 3 b.2),

e The licensee's method for determining waste classification was not well documented (Section 3.b.2).

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• 2 9 The licensee had initiated Phase ll of the CaF, relocation project in the basin area, and implementation of the Final Status Survey and Release Plan, Revision 2, dated February 28,1996 (Section 3.c.2).

Transoortation e The transportation activities were managed effectively and the associated directives and procedures which incorporated and implemented the applicable provisions of both NRC and DOT regulations were_ technically adequate (Section 4.b). '

Emeroency Praggedness e A non-cited violation (NCV) was identified for failure to perform the calendar year (CY)1998 independent audit in accordance with Section 7.5 of the Emergency Plan (Section 5.a.2),

e The licensee's response to the postulated accident scenario demonstrated both an effective response, and a tralned emergency response organization (ERO) with properly maintained equipment (Section 5.e.2).

O A tracking system for corrective actions assigned to critique items identified during drills and exercises was not properly implemented and maintained (Section 5.e.2).

- e The interface with offsite support agencies was considered a program strength (Section 5.e.3).-

Attachment:

Persons Contacted and Exit Interview List of items Opened, Closed, and Discussed List of Acronyms Scenario Description and Exercise Objectives

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REPORT DETAILS

1. Summarv of Plant Statua This report covered a one week period. Special activities scheduled during the reporting period included the biennial emergency exercise involving onsite and offsite organizations. There were no unusual plant operational occurrences during the onsite inspection. Pre-operational testing activities for the Dry Conversion Facility were progressing. Preparations were underway for a plant scheduled shutdown.

2. Plant Ooerations (88020) (03)

a. Capduct of Ooffations (O3.01)

(1) Insoection Scope The inspectors conducted a facility tour to observe conduct of operations, and to confirm that materia! storage, process operations, and process related activities were being performed in accordance with written safety requirements.

(2) Ohnervations and Findinas This inspection coincided with the licensee's preparations for their annual process clean out prior to the conduct of a nuclear materials inventory.

The inspectors toured the Dry Conversion Facility (DCF) on July 14, 1997, and observed no materials being processed. At the time of the inspection, only one of the three DCF lines had been used for pr,ocessing non-enriched uranium, while the other two lines were yet to have any uranium introduced, The inspectors observed the safety Instrumentation and postings, and found no problems.

The inspectors oiso toured the Ammonium Dluranate (ADU) processing lines and found limited operations occurring on two lines, and equipment clean out occurring on the idled process lines. The inspectors observed the cleaning of ADU centrifuges, and found the cleaning was being performed per the posted safety instructions and radiation work permit.

The inspectors observed some inconsistencies in the indicator tags use '

on critical valves in the UF, vaporization area. Most vaporizers had the critical valve numbers clearly posted, but the line 4 vaporizers did not.

Also, critical valves on the cold trap cooling system had tags that did not have a unique identifier displayed. Instead they were simply labeled as critical valves and were tagged as either normally open or normally closed. Followup discussions revealed that these tags were being replaced as part of a process upgrade and that the line 4 vaporizer had not been completed since it had not yet been shut down for inventory.

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l 2 j Consistencies within the licensee's critical valve identification system will be investigated during a future inspection.

j Upon exiting the controlled areas after each of the above tours, the inspectors found that one of the contamination survey monitors they were using was turned off. In each case, it was not obvious to the inspectors that the monitors were tumed off until the survey was partially completed.

Upon dia 44 Q the disabled monitors, the inspectors moved to another n%h wby to perform their personal contamination survey.

The inspecth hff observed that the disabled monitors were not tagged as being out of service, nor was there any other indication except the power switch had besa turned off. The inspectors found another instance later during the inspection where one of the monitors was turned off without an out of service tag. The inspectors also observed the entries in the functional testing log book (functional tests occur twice por day) for each monitor and found no indications of problems with the monitors, nor that they had been out of service for a time. The inspectors found that the presence of disabled monitors without a conspicuous indicator of its status was a potential pathway for personnel to leave the controlled area without performing an adequate contamination survey, particularly at shift changes.

During facility tours of the non controlled areas, the Inspectors observed two doors that led directly into controlled areas were unlocked, unalarmed, and accessible to anyone within the non controlled corridor between the new Dry Conversion Process (DCP) facility and portions of the ADU process areas. These docrs were posted with a generic sign which indicated that radioactive materials may be present and that authorized entr/ was required. This was the same sign that was posted at the entrance to the office area, except that the signs on each of these unlocked doors leading to the controlled areas also had a piece of preprinted tape on them that stated it was an "Altborne Radioactivity Area", The inspectors did not recognize that the posting of ' Airborne Radioactivity Area" was synonymous with " Controlled Area'strice the inspectors had noticed the same posting in an area of the UF, cylinder receiving bay which was not a controlled area.

One of these doors led into the newly constructed DCP facility. The inspectors opened the door, observed a worker dressed in protective clothing, and observed indications on the " controlled' side that the door was an emergency exit for the DCP facility, The othee door that was found unlocked from the non controlled side was about 10 meters down the new corridor. This doorway entered into an area where uranium powder processing in the ADU facility was being performed. The inspectors opened this door and observed a worker dressed in protective clothing who was preparing to load a bucket of uranium powder into the process. The inspectors did not observe any indication that it was an

3 emergency exit for the controlled area, but subsequent discussions revealed that such Indications existed beyond the sight of anyone in the non-controlled area. The inspectors discussed this situation with the licensee and NRC licensing staff and found that the 'Altborne Radioactivity Area' posting was generally accepted at the licensee's site as being indicative of a controlled area, and that these unlocked doors may be necessary for emergency response personnel to enter the controlled areas. However, since these doors are not specifically labeid as entrances to controlled creas, and since training received by the inspectors on facility postings did not emphasize the intended meaning of the ' Airborne Radioactivity Area' posting, additional barriers are needed to ensure that inadvertent entrance into the controlled areas through these (and other similar) doors is prevented. The licensee's improvements will be reviewed in a later inspection and tracked as Inspector Followup Item (IFl 701113/97 07-01).

During another portion of the facility tour of non controlled areas, the

) Inspectors found an area Interfacing with the Decontamination and Volume Reduction Facility (DVRF) controlled area where a step-off pad existed for workers to exit the DVRF controlled area, remove contaminated clothing, and enter the non controlled area without performing a personal contamination survey in order to accomplish a small task. Once the task was performed, the worker could go back to the step-off pad, redress in the contaminated clothing, and re enter the controlled area. Upon discussions with licensee management, a simliar step off pad was identified in the UF, cylinder staging area, where workers would agaln leave the controlled area without performing a, personal contamination survey in order to operate a crane to transfer a full UF, cylinder to the controlled area. Further discussions with the licensee indicated that this practice had been analyzed as acceptable by their safety function, approved by licenseo management, and the non.

controlled area was monitored weekly for the presence of spreadable contamination. However, the inspectors found that this practice was in violation with the license application which states that personnel contamination surveys are required when leaving a controlled area, and that access to controlled areas will be established through change rooms.

The inspector reviewed the licensee's seven (7) most recent sets of contamination surveys of the area and found that all of them were well within the release limits for non-controlled areas. Based on this data and the licensee's demonstrated control of contamination in these areas, these NRC-identified violations of the license application are not being, cited because criteria specified in Section Vll B of the NRC Enforcement Pohcv were satisfied and will be considered a NCV (NCV 70-1113/

97 07-02). Additionally, since this situation is a continuing practice, the licensee's efforts to bring itself into compliance with the license application will be tracked as an IFl(IFl 70-1113/97 07 03).

l' 4 (3) Conclusions The limited operations and clean out activities observed by the inspectors were adequate to ensure worker and public safety. Critical valve identification tags need to be consistently marked and 'isplayed. The identification of barriers between controlled areas and non-controlled areas were not adequate. The licensee's standard practice of allowing workers to leave and re-enter certain controlled areas without performing a personnel survey and without going through a change room was identified as a NCV.

b, lmolementation of Progggs Safety Controls (O3.03) and imolementation of Storage Safely Controls (03.04)

(1) Insoection Sc2DA During the facility tours, the inspectors reviewed the implementation of plant process and storage safety controls to confirm their availability to personnel and the licensee's adherence to them. The inspectors also reviewed the approval criteria for two newly issued Criticality Safety Analyses.

(2) Observations and Findinas The inspectors observed the Nuclear Safety Release / Requirements (NSR/R) postings for various operational areas, in process SNM storage areas, and scrap materials storage in both Indoor and outdoor locations.

The inspectors found that most of the NSR/R postings referenced procedures that were no longer valid, The inspectors also found that the licensee was changing its system of producing and documenting its operating procedures. Procedures produced by the new system had been given new procedure numbers to differentiate them from the idled procedures, The inspectors noted an uncontrolled copy of a NSR/R in the UF, cylinder receiving bay that was not under document control, This uncontrolled copy was immediately removed by the licensee upon notification of its existence.

The inspectors observed the NSR/R postings for the large number of cans containing low level scrap material on " pads' behind the fuel manufacturing buildings. These postings had beer > led more than two years prior to this inspection, and most of these outdoor postings were found to be weathered and, in some cases, barely legible, t The inspectors observed two Criticality Safety Analyses for portions of the DCP (CCR# 97,0001, Rev. 2 and CCR# 9/.0009, Rev. 4). Both c

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analyses were found to have been completed using validated methods and independently reviewed and validated by qualified staff.

(3) fanclusions The instructions on the NSR/R postings were adequate to assure safety, and were being followed. However, most (if not all) of these postings

} needed to be replaced with updated versions to reflect the new procedural references. Additionally, outdoor postings needed to be updated and/or replaced before they became deteriorated. The one uncontrolled copy of a posting that was found was an apparent isolated case, as all of the other dozens of postings reviewed were under t document control,

c. Housekeeolna f03.06)

(1) Insoection Scoce During the plant tours, the inspe: tors noted the condition of housekeeping throughout the process areas and adjacent portions of the plant.

(2) Observations and Findinan The inspectors observed the general condition of housekeeping in the SNM processing areas. The inspectors found that storage of combustibles throughout the processing areas was adequate to prevent significant fire hazards, particularly in the moderation controlled areas of the ADU process. The inspectors observed collections of granular materialinside pipe stubs on top of most of the UF vaporizer cabinets.

These pipe stubs are fastened to the vaporizer cabinets to provide a resting place for the flexible ventilation ducting located at each set of vaporizers. The flexible ducting provides temporary ventilation for operators to disconnect pigtails from the UF, cylinders. The granular material was thought to have been fluoride salts that likely contained uranium which had fallen out of the flexible duct during its storage. This material was identified to the Area Manager and promptly removed.

The inspectors observed the general housekeeping of the UF, cylinder receiving bay and other non-controlled locations adjacent to outdoor areas. The inspectors found numerous discarded tamper seals along with food-related trash items scattered on the floor of the UF, cylinder receiving bay, More food and drink related trash, along with cigarette butts, were also found in a non-controlled area adjacent to the DVRF controlled area. The inspectors observed that the ' barrier" between

6 these controlled and non controlled areas was a piece of yellow tape on the floor, and one of the food wrappers was observed to be within a few feet of the ' barrier".

(3) Conclusions Housekeeping of combustibles in the process areas was adequate to prevent them from causing or adding to a significant fire hazard.

Housekeeping was also adequate to keep routes of egress clear.

However, the amount of debris in the locations adjacent to outdoor areas created a potential slipping hazard, especially in a scenario where someone in the area may be reacting to an emergency. Licensee management indicated that improvements would be made in their housekeeping efforts to maintain working areas clear of debris.

d. Review of Previous Events (O3.07)

(1) insoection Scope The inspectors reviewed safety significant events that had occurred since the last inspection to determine whether the licensee's responses were adequate to properly address problem areas.

(2) Observations and Findinas The inspectors inquired about the following three events that occurred prior to the inspection:

o !nadvertent 9 arming of the criticality detection system during a thunderstorm, o Ventilation condensate spill from a chiller system underneath a moderation restricted area, and e Scalding of a maintenance worker during disassembly of a pump in the Uranium Recovery area.

The inspector found that these three items were still under investigation.

The third item caused a lost time injury and was undergoing a more in-depth root cause investigation. The inspector was briefed on the preliminary findings of this investigation and an IFl was identified to review the adequacy of the Tap Root findings and to evaluate the licensee's corrective actions (IFl: 70 1113/97-07-04).

The inspectors were briefed by the licensee on July 16,1997, concerning an event which had occurred the evening of July 14,1997. A small release of radioactive material (thought to be uranyl fluoride at the time of

7 this report) occurred during an attempt by maintenance to clear a blockage in a nitrogen purge line connection in DCP Line 1. This system had processed only non enriched (natural) uranium in order to ' hot test' the system as a precursor to SNM processing. High-volume air samples and bloassays both indicated results above the licensee's internal action levels for resampling, but were well below regulatory limits (the highest intake was found to be 3.1% of the weekly limit based on chemical toxicity). The disconnecting of the nitrogen line to clear the blockage was considered a temporary modification to the HVAC system which requires proper review and authorization through the licensee's configuration management system. A violation of the licensee's configuration management procedure occurred when this modification transpired without such authorization. Since this event was identified by the licensee, resulted in a low level of exposure, and did not involve SNM, the inspector considered it to be of low safety significance and is not being cited because the criteria specified in Section Vll.B of the NRG Enforcement Policy were satisfied (NCV: 70-1113/97-07-05). In response to the discovery of this event, the licensee was initiating an investigation and was generating an Unusual incident Report (UIR) requiring a higher level critique. The findings from this UIR and any subsqumt Root Cause Analysis will be reviewed as part of an IFl (IFl: 7041113/97-07-06).

(3) CADshtslona The licensee's responses to the events that involved the actual exposure of workers to a hazard were quickly initiated, and methodical enough to address problem areas adequately. The licensee was somewhat slow to develop a response to the two items that apparently involved only mechanical malfunctions. However, the quicker initial response to known hazards may be warranted if those events involving only mechanical failures are not expected to contribute toward an immediate hazardous situation.

3. Waste Management (84850 and 84900)(R3)

a. On Site Waste Storaae (R3.05)

(1) Insoection Scong The licensee's storage of low level radioactive waste (LLRW) was reviewed, including management controls and surveys, adequacy of the storage area, and waste container integrity.

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(2) Observations and Findinas As of July 1,1995, the State of South Carolina was no longer accepting LLRW generated from facilities located in the State of North Carolina for burial at the Bamwell Facility. During late 1998, the licensee had a limited waste shipment campaign established with Envirocare of Utah, however, due to NRC concerns, Envirocare was, at the time of this inspection, not accepting radioactive waste from any generator. Thus, at present, the licensee had no options for the disposal of LLRW. To compensate, the licensee relied on a combination of incineration, decontamination, and waste mlnlmization to reduce both the volume of waste in storage and the volume of waste generated.

Various solid wastes were generated from the fuel manufacturing operations (FMO) and field examination technology (FET) operations.

FMO solid LLRW ranged in form and type, such as, packaging and construction materials, worn-out tools and equipment, spent process oils and chemicals, uranium sludge, and by product generated hydrofluoric acid. FET solid LLRW consisted primarily of compactible and non-compactible dry active wastes (DAW) and cuno filters.

At present, the licensee temporarily stored radioactive solid wastes in several outside storage areas or " pads" located in the controlled area.

The inspector toured the licensee's temporary waste storage locations.

The pads consisted of several graveled surfaces each surrounded by a fence. Although the fences were not locked, all of the waste, as noted above, was located within the controlled area. The waste containers were placed directly on the graveled surface. The inspector noted that since the last inspection of this program area, the licensee had moved the oil and solvent waste storeu in 55 gallon drums into a warehouse.

As of June 30,1997, the licensee's totalinventory of LLRWin storage was as foliows:

• 24,601 cans of waste (3 and/or 5 gallon cans) -

- Recoverable waste ~10,000 cans

- Ash waste - 5.000 cans

- Residue waste ~10,000 cans .

e 450 non-combustible waste boxes (51,3 cubic feet each)

• 285 combustible waste boxes

• - 331 drums of oil and solvent waste (55 gallon drums)

The inspector noted that the licensee recovers uranium from the recoverable waste, however, under current operating conditions, the recovery plant was unable to keep up with waste production. Once the DCP becomes fully operational, the inventory of recoverable wast 6 should be reduced. With regard to the ash waste, the licensee was

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9 negotiating with other fuel cycle facilities to transfer this waste for uranium recovery. The residue wastes were destined for burial pending authorization to resume shipments to an authorized LLRW disposal facility. All of the waste cans in outside storage areas recently had the outer plastic bag replaced with ultraviolet resistant black plastic bags.

The inspector observed that for selected plastic bags that contained either a three or five gallon bucket of waste, an inventory control tag was affixed and mostly legible. The licensee indicated that the waste buckets were periodically inspected for inventory and container integrity purposes.

The inspector did note a significant reduction in the number of combustible waste boxes since the last inspection. In January 1997, the licensee had approximately 670 combustible waste boxes in storage.

The licensee was able to reduce the inventory to 285 boxes due to the successful operation of the onsite incinerator. The inspector noted that the Ccensee had stored the combustible waste in wooden boxes for direct placement into the incinerator chamber, The tops of the boxes were covered with plastic to minimize weather damage. To reouco the quantity of solvent and oil waste, the licentee was evaluating the use of a new incinerator burner that would be better suited for oll/ water mixtures.

The inspector had also noted that the licensee generated approximately 3000 three and five gallon buckets of waste during the first six months of 1997, which was significantly greater than the licensee's goal for waste generation. However, most of this waste was considered recoverable waste from the Wurgassan fuel assembly download project. The licensee had allocated approximately 28400 spaces for waste cans to the end of 1997.

In May 1997, the licensee organized a Burial Strategy Team consisting of members from the Departments of Environmental, Health, and Safety; Criticality Safety; Licensing; Shipping; and Waste Management. The team tracked inventory, types, locations, and quantity of solid waste, along with investigating options for burial.

(3) Conclusion The inspector noted a significant reduction in the number of combustible waste boxes, however, the present arrangement for the storage of LLRW was less than adequate due to the large volume of waste being stored and due to the fact that the stored solid waste wts not adequately shielded from the natural elements. There was also the potential for ground contamination from the waste being stored directly on the ground.

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b. Waita3hipolna. Trackina. and Classification (R3.00 R3.07. R3.08)

(1) InsoectionJtone The inspector reviewed the licensee's program as it pertained to the requirements of 10 CFR 20.2006 and Appendix F to 10 CFR Part 20. In addition, the inspector reviewed and discussed with licensee representatives activities associated with the notification of receipt of LLRW shipped to a burial facility for disposal. Appendix F to 10 CFR Part 20 specifies the requirements for LLRW transfer for disposal at land disposal facilities, including the control and tracking of waste shipments.

(2) Observations and Findinas From a review of the records for solid waste disposals made from November 1996 to December 1996, it was noted that the licensee shipped selected noncombustible waste !! ems to a licensed waste burial facility (Envirocare of Utah). The inspector verified that the licensee i provided an acceptable level of information in the shipping papers to determine the quantitles of individual radionuclides shipped, The inspector reviewed manifest records of one shipment of radioactive waste made on November 17,1996. The manifest was complete and met the applicable requirements of Appendix F to 10 CFR Part 20.

10 CFR 20, Appendix F, Section Ill.A.1 requires that the licensee prepare all wastes so that the waste is classified according to $$61.55 and meets the waste characteristics requirements in $$61.56, Classification of waste materials to meet the $661.55 requirements was discussed with licensee representatives. All waste streams were classified utilizing material accountability methods for identification and quantification of radionuclides in each container. Each waste container was scanned using a sodium lodide (Nal) gamma spectroscopy system.

The containers were rotated in front of the detector and assayed to determine the quantity of U 235 and U 238 within the waste. The licensee indicated that only Class A unstable waste had been shipped for burial. The stability of the waste was achieved with the waste container.

The licensee controlled the types of materials that could be placed in the waste containers and the types of materials that were prohibited from being placed in the waste containers by detailed work instructions.

The inspector reviewed an internal memo dated June 21,1983 which indicated that all radioactive waste materials should be designated as Class A wastes. There was no apparent documentation detai!!ng how the licensee reached this conclusion. The inspector noted that before the waste shipments were delivered to Envirocare, the licensee collected 1

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waste stream samples for radionuclide and toxicity characteristic leaching procedure (TCLP) analyses to satisfy the requirements of the burial facility. The inspector discussed with the licensee the ONMSS Branch '

Technical Position (BTP) on waste classification, dated May 11,1983.

• Tne licensee indicated that the BTP would be re reviewed so that acceptable licensee documentation of waste class can be developed.

In addition, the inspector reviewed the licensee's shipping records to determine if ta system had been established to verify that acknowledgment of recelpt of the manifest from the waste burial facility had been received. For selected waste shipments made between November and December 1996, the inspector verified that the licensee had received an acknowledgement of receipt from the waste burial facility .

within the required time period specified in 10 CFR Part 20, Appendix F.

The licensee's records were orderly and well maintained.

(3) Conclusion The inspector concluded that the licensee's waste shipping program was i adequate, however, the licensee's method for determining waste classification was not well documented. The licensee's program for the control and tracking of waste shipments was adequate. The records were readily available and well maintained.

c, Decommissionina Activities (CaF3 Removal Project)(R2.07)

(1) Insoection Scoce During the inspection, licensee activities associated with the management of Phases I and ll of the long term program of Calcium Fluoride (CaF )

removal from in-ground storage areas were reviewed and discussed with cognizant licensee representatives.

(2) Observations and Findinas Phase I, involved the removal of CaF, from the Northwest storage area and the free release of that area, The licensee had removed the CaF, from tr.] Northwest storage area and relocated to an above ground L storage warehouse. By letter dated April 16,1996, the NRC had L approved the licensee's Final Status Survey and Release Plan for the Northwest CaF, Area (FSS Plan), Revision 2, dated February 28,1996.

The purpose of the FSS Plan was to demonstrate that residual

' radioactivity concentrations at the Northwest CaF, Storage Area satisfy the NRC criterla for future use without licensing restrictions and radiological controls. The licensee was in the process of making the preparations to perform the final survey and release activities.

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12 Phase ll Involves the removal of CaF, from the central basin area, however, the licensee initially had no plans for the free release of that area until decommissioning of the Wilmington facility based on the proximity of other operations in that area. On September 13,1996, the licensee submitted notification to the NRC pursuant to the requirements of 10 CFR 70.38 that the central basin area had been inactive for 24 months. The licensee indicated its intention to remove the CaF from the basin area, but not to seek decommissioning of the area until final plant closing. On January 23,1997, the NRC notified the licensee that it could not grant a request for a delay in decommissioning, since the licensee had not adequately justified such delay in accordance with the requirements in 10 CFR 70.38(f). On March 24,1997, the licensee requested an additional 120 days to review the submission of a request for delay of decommissioning or an alternate schedule for decommissioning. In a letter to the licensee dated April 28,1997, the NRC granted the licensee's request for an additional 120 days to submit either a request for a delay of decommissioning or an alternate schedule of decommissioning for the CaF, accumulation area. The licensee's new submittal date was July 24,1997.

The inspector examined the CaF: excavation and removal activities associated with the central basin area. At the time of this inspection, the licensee had basically completed removal of most of the CaF, from the north and south basins and had started removing CaF, from the central basin. The CaF, was being relocated to the same above ground warehouse storage facility where the CaF, from the northwest storage area was placed. The warehouse storage facility was near its volume limit. With the removal of the CaF approximately 70 % complete, the licensee was evaluating options to deal with the remaining CaF,.

(3) ConclubD The CaF, relocation project had progressed within the allowed schedule.

Preparation for implementation of the FSS Plan, Revision 2, dated February 28,1996 had just begun. The continued use of the CaF, warehouse storage facility for placement of material excavated from the central basin area was in question due to the limited available storage space. This storage problem will be further evaluated by the licensee, with an emphasis on disposal options.

4. Transportation (86740)(R4)

a. The inspector reviewed the licensee's program for routine radioactive materials shipments, including waste shipments, to determine whether the licensee had established and was rnaintaining an effective management controlled program, to ensure radiological and nuclear safety in the receipt, packaging, and delivery to a carrier of licensed radioactive materials, and to determine whether

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13 transportation activities were in compliance with the applicable NRC and DOT transport regulations noted below. During the inspection. transportation activities associated with LLRW and fissile material shipments, in 6 ding procedural guidance, quality control (QC) activities, and record completeness conducted in accordance with 10 CFR Part 71, and 49 CFR Parts 171 178 were reviewed.

10 CFR 71,5(a) requires that licensees who transport licensed material outside the confines of its plant or other place of use, or who delivers licensed material to a carrier for transport, shall comply with the applicable requirements of the regulations appropriate to the mode of transport of the DOT in 49 CFR Parts 170 through 189.

b. P3eparation and Delivery of Comoteted Packmaes for Shloment (R4.01. R4.02)

(1) Insoection Scone

' The inspector examined the licensee's written procedures and shipment records related to the preparation and delivery of completed packages for shipment of licensed material.

(2) Observations and Findinas The inspector verified that the licensee had procedures for the preparation of shipping packages and delivery of the packages to the carrier for shipment. The inspector reviewed selected portions of the shipping procedures and noted that there were no significant changes to the procedures since the last inspection of this program area, in addition, the inspector verified that the procedures incorporated and implemented the applicable provisions of both NRC and DOT regulations. The inspector also verified that the appropriate personnelin the traffic department had current copies of the applicable DOT regulations. The licensee used a vendor service that provided periodic updates to 49 CFR 106-180. This service provided a well organized version of the DOT regulations with an indexing system that allowed quick access to the appropriate regulation.

During the onsite inspection, licensee transportation activities regarding shipments of unirradiated fuel, uranium dioxide powder, and low level radioactive waste shipments were reviewed. Selected records covering the period November 1996 to June 1997 for those consignments were reviewed in detail. The inspector reviewed and discussed in detail the documentation used, and subsequently maintained in the licensee's records for each radioactive material shipment, including, the Bill of Lading, Radioactive Material Shipment Record, Vehicle inspection

- Report, Receipt and Loading Verification Checklist, Packing List (Fuel Assemblies / Component Assemblies), Fuel Shipment information Form, Container Log Sheet, and Health Physics Survey Forms.

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14 In general, the shipping records referenced above were complete and the information supplied on the shipping papers was appropriate.

The inspector observed the licensee prepare for shipment the fuel rod and fuel assembly shipping containers, Model Numbers RA 2 and RA 3.

The inspector verified that the licensee prepared the packages for shipment and operated them in accordance with Chapter 6, Operating Procedures, Acceptance Tests, and Maintenance Program of the Application to NRC Certificate of Compilance (CoC) No. 4986.

In addition, the inspector observed the licensee's maintenance activities for the inner and outer fuel shipping containers Models RA 2 and RA 3, including the refurbishment and inspection. The inspector verified on selected RA inner containers that the gasket had been replaced as required and was in good physical condition.

(3) Conclusion Through the observation of packaging operations underway during the .

Inspection, it was concluded that the licensee's performance in this program area was acceptable. The procedures and licensee activities related to 'he refurbishment, package preparation, loading, operating, and maintenance of the RA 2 and RA 3 packages generally implemented the requirements of the CoC.

c, Recelot of Packages (R4R)

(1) Insoection Scone The inspector examined the licensee's procedures and records of incoming shipments to verify compliance with the applicable requirements of 10 CFR 20.1906 relating to the pickup from a carrier, receiving, and safe opening of packages.

(2) Observations and Findinas The inspector reviewed the records and discussed with licensee employees the program for the safe receipt and handling of UF, cylinders. The inspector examined the receipt survey records for the first six months of 1997 and noted that the correct direct and contamination surveys were performed within the time frame specified in 10 CFR 20,1906(b).

-(3) Conclusion Through the review of survey records for the receipt of radioactive materials, evaluation of written procedures, and discussions with

15 personnel responsible for performing the surveys, it was concluded that the licensee had an acceptable program for the safe receipt of radioactive materials.

d. Package Procurement (1) Inspection Scong 10 CFR 71.101(b) requires each licensee to establish, maintain, and execute a QA program satisfy;ng each of the applicable criteria of $$101 through 137. The inspector reviewed and discussed with cognizant licensee representatives selected aspects of current QA program and QC activities associated with packaging and transportation operations, specifically in the area of package fabrication, selection, and procurement.

(2) Observations and Findings The inspector noted that the licensee recently purchased 75 Model RA 3 wooden fuel rod and assembly outer shipping containers in 1997. The inrecN verified that the licensee had a quality control program e' d to inspect each package before its initial use. The program eliminary determinations and quality control measures related er 'ruction of the packaging. The inspector noted that the NRC r- '986, Revision 33 did not specify a dimensional tolerance for 3 ' outer container, however, the Quality Control Inspection u vcU ng No. 829E209, Revision 9, RA Outer Page 3 of 4 6 ace of 1/8 inch unless otherwise indicated.

In add tion, ti,,, in.pector verified, with regard to reporting defects and noncompliances, that the procurement documents included the statement that the provisions of 10 CFR 21 apply as required by 10 CFR 21.31.

The inspector also verified by record review that the licensee performed inspections of each overpack before the first use as required by 10 CFR 71.85. The inspections ascertained that there were no defects that would significantly reduce the effectiveness of the packaging. The liccnsee also conspicuously and durably marked the packaging with its model number, serial number, gross weight, and a package identification number assigned by the NRC in accordance with 10 CFR 71.85. Before applying the model number, the licensee, through its QA program, verified that the packaging had been fabricated in accordance with the designed approved by the NRC.

(3) Conclusion Through the review of quality control records, procurement documents, and interviews with personnel responsible for this function, the licensee's

s 16 performance in the area of QC activities associated with package fabrication, selection, and procurement was acceptable.

e. Quality Assurance and Audit Proaram (1) Insoection Scope 10 CFR 71.101(b) requires each licensee to establish, maintain, and execute a Quality Assurance Plan (QAP) satisfying each of the applicable criteria specified in 10 CFR 71.10171.137.

10 CFR 71.137 requires, in part, that the licensee carry out a comprehensive system of planned and periodic audits to verify compliance with all aspects of the QAP and to determine the effectiveness of the program.

(2) Observations ard Findinas The inspector reviewed QA Audit 96 7, "10 CFR Part 71, Subpart H,"

conducted from September 0 to October 11,1996, which was the most recent audit of the transport activities conducted by the licensee. The audit was performed by three Individuals, that included observations of work in progress, in general, the audit addressed the applicable activities specified in the quality assurance program plan, including, package refurbishment, inspection, QA recoids, drawings, procurement documents, and source evaluations. However, the inspector did not note a review of an adequate representation of the shipping and receiving program, including shipping procedures and shipping paper documentation preparation. The licensee's audit team did not identify any non-conformances.

(3) Conclusion Through the review of audit records and planning documents,it was concluded that the quality of the audit performed in 1996 was acceptcNe and met the applicable requirements.

5. Emeroenev Preoaredness (880 soke 3)

a. Review of Proaram Chanaes (F3.01)

(1) Insoection Scoce Changes to the licensee's Radiological Contingency and Emergency Plan (RC&EP), procedures, organization, facilities, and equipment were reviewed to assess the impact on the effectiveness of the program; and

. to verify that changes met commitments, license conditions, and were

= _.

17 provided to NRC in accordance with 10 CFR 70.32(l). Examine the adequacy of the emergency preparedness independent audit program.

(2) . Observations and Findinos Since the last inspection of this area (April 1996), the following changes were made:

Several organizational changes were made to both the normal and emergency organization. The most significant change involving emergency preparedness was the retirement of the individual assigned primary responsibility as the Emergency Director (ED) for implementing the emergency procedures and directing the ERO. The current ED and alternate ED were assigned earlier as alternates to the former ED. The management reporting chain and/or day to day responsibility for emergency preparedness was unaffected. Additionally, the ERO was effectively managed by the ED during the blennial exercise discussed in Section 5.e. Therefore, the before mentioned change would not appear to reduce the effectiveness of the program.

Since the last inspection, two revisions were made to the Plan dated July 31,1996 (Rev.2) and December 17,1996 (Rev.3).

Changes included site maps updated; the addition of DCP to operation description details; administrative changes to reflect organizational and/or title changes; updated references for hydrogen fluoride (HF) permissible exposure limits; and numerous other updates such as the emergency procedures listing.

Changes were made to the emergency procedures which implement the Plan and are discussed below in Section 5.b. Each Plan revision (Rev.2 and 3) was reviewed and approved by NRC via letters dated September 20,1996 and February 21,1997.

Section 7.5 of the Plan required an annualindependent audit of the emergency preparedness program. According to the Plan,"this program audit will include such items as the plan, procedures, emergency facilities, equipment and supplies, off site interface to assure the emergency preparedness program is being adequately maintained.'

Consequently, this area was reviewed to determine if the licensee had performed the independent review or audit, and verify that the licensee had evaluated any significant changes on the emergency preparedness program. Contrary to Section 7.5 of the Plan, the inspector determined from an interview with the auditor and a review of audit documentation, that the scope of the licensee's CY 96 audit was limited to ascerialning the status of audit findings opened during a 1995 program review. The inspector informed the Manager, Site Security and Emergency Preparedness (MSSEP), that the CY 96 audit was inadequate and did not m_.__ _ . . _. - ---

18 meet the requirements of Section 7.5 of the RC&EP for an independent audit, in response, the following actions were taken by the licensee:

o A schedule for the CY 97 audit was identified (starting late Sep' ember and completed by October 10,1997).

o The audit plan was established and included such areas as identified in Section 7.5 of the Plan (e.g., offsite interface, emergency equipment and facilities, procedures, etc.).

The licensee was informed that failure to conduct an independent audit during 1996 in accordance with the Plan was a violation of the license commitment. This failure constitutes a violation of minor significance and is being treated as a NCV consistent with Section IV of the NRC Enforcement Policy. (NCV 701113/97 07 07: Failure to conduct an independent audit during 1996 in accordance with the RC&EP).

(3) Conclusions Based on interviews and documentation, changes made since the last inspection had no negative impact on program effectiveness. Site maps were updated including the Plan to reflect the addition of the dry conversion facility (DCF). All Plan changes were submitted to NRC for review and approvalin accordance with 10 CFR 70.32(l). The licensee's independent audit was inadequate in assessing the readiness status of the site emergency preparedness program (maintenance of equipment, facilities, Plan, procedures, etc.) and resulted in an NCV.

b. Plan and imolementing Procedures (F3.02)

(1) 10$Dection Scoce Select implementing procedures were reviewed for adequacy in the implementation of the Plan.

(2) Observations and Findings Nine (9) procedures were designated by the licensee as Emergency Procedures (EP) for implementing the requirements of the RC&EP. The procedures were as follows: 1) Bomb Threat,2) Environmental-Chemical / Toxic Hazards, 3) Communications (External), 4) Security Compromise,5) Criticality,6) Fire and Explosion,7) Radiological,8)

Severe Weather, and 9) Transportation. According to documentation and an interview with the MSSEP, each cf the before mentioned EPs are revised and updated during June 1997. The inspector noted that with two exceptions (Procedures 3 Communications and 8 Severe Weather),

all EPt included under classification level the term " Unusual Event." In

_ = _ _

_____ _______------w-a ---5

19 response to this observation, the inspector discussed with the licensee the potential for confusion associated with the use of the term

• Unusual Event

• as a classification level. Prior to the revised emergency planning rule (April 1990) for fuel cycle licensees, the emergency classes were based on planning guidance in NUREG 0654 for nuclear power reactors, which included four emergency classes (Notification of Unusual Event referred to as NOUE or Unusual Event; Alert; Site Area Emergency; and General Emergency). Effective April 7,1990, the requirements for fuel cycle facilities was based on two emergency classes (Alert and Site Area Emergency) rather than four as required by Emergency Plans for nuclear power plants. Consequently, in the event of a plant upset requiring notification to offsite authorities in the vicinity of a nuclear power plant, the use of term ' Unusual Event" by members of the General Electric (GE) staff may result in confusion regarding the significance of the call and the necessity of bringing response personnel to an increased state of readiness due to the potential significance of an Unusual Event as associated with a power reactor. In response to the inspector's comments, the licensee contact Indicated that the term ' Unusual Event" was only used during internal communications. However, the potential for confusion would be reviewed.

Three procedures (Bomb Threr, Environmcntal-Chemical / Toxic Hazards, and Radiological) were reviewed for applicability and adequacy in implementing the RC&EP. No problems were noted. Controlled copies of the Plan and EPs were examined in the Emergency Control Center (ECC) and verified as current and up to date. The inspector also verified that ERO position notebooks and an emergency telephone listing in the ECC were current and up to date.

(3) Conclusions The procedures selected for review were consistent with details contained in the Plan and appeared to adequately implement the RC&EP.

The flow chari format for dea,Islon making involving ERO activation and event classification appeared to be an effective and user friendly tool,

c. Trainina and Staffino of Emeroency Oraanization (F3 03) *

(1) Insoection Stqpa Emergency response training was reviewed to determine if the licensee had provided training to response personnelin accordance with Section 7.2 of the Plan.

20 (2) Ohsmyations and findings The inspector observed tne licensee's biennial exercise (see Section 5.e) and noted that personnelin key ERO positions demonstrated good familiarity with their role and responsibility. The performance by response eersonnel during the postulated accident in the implementation of the Plan and EPs demonstrated a trained ERO. In addition to the exercise observation, the inspector reviewed documentation resulting from practice drills conducted by the licensee in preparing ERO personnel for the blennial exercise conducted on July 10,1997. Documentation disclosed the lleensee conducted drills on May 28,1997, and June 19,1997 simulating a chemical accident involving an anhydrous ammonium tank. Both drills involved the activation of the ERO and ECC and provided effective training for response persorenel in dealing with potential chemical hazards associated with site operations at GE.

Regarding offsite support training, the inspector noted that the following training was conducted:

e On April 15,1996, New Hanover Regional Medical Center personnel were provided a training session entitled ' Hospital Emergency Department Management of Radiation Accidents.'

The referenced training was a full day in length and included both a group exercise and critique. On April 24,1996, an additional training session was conducted for members of the New Hanover emergency room staff providing instructions on the use of radiological suNey instruments, e On May 22,1996, personnel from the offsite support volunteer fire departments (VFD) and the Wilmington Forest Service attended site overview training regarding the DCP; plant access during an emergency; and participstod in a site tour.

The offsite support training provided personnel with updated infortnation to assist in responding to incidents at GE.

Regarding ERO staffing and activation of the ECC, the inspector reviewed documentation covering the period August 1,1996 through July 10,1997, and interviewed the licensee contact with responsibility in this area. Prior to the replacement of the previous pagers, the results from pager drills demonstrating timely activation and staffing revealed 75-88 percent of the responders were contacted and available for responding to the ECC in a timely manner. Following the implementation of an alphanumeric type pager (during April 1997), the percentage of responders acknowledging contact and availability to respond were 100 percent.

21 (3) Concluslona Based on exercise observations, documentation reviews, and interviews with licensee personnel, the inspector determined that training provided sufficient Information to assist responders in their roles and responsibilities to the ERO. Additionally, provlous problems in the area of timely notification and activation appeared to be resolved via the licensee's administrative system (pagers) and call in procedure which was effective in assuring that staffing and ECC activation could be accomplished in a timely manner,

d. Offsite Sucoort (F3 04)

(1) Insoection Scooe Licensee activity in the areas of training, agreements, and exercises, was reviewec, to determine if the licensee was properly coordinating with offsite authorities.

(2) Observations and Findinos Discussions were held with a member of the licensee's staff regarding the coordination of emergency planning with offsite support agencies.

Table 7.1 of the Plan required the licensee to periodically offer training to offsite groups. The inspector reviewed documentation to show that during calendar year 1990, training was provided to personnel from New Hanover Regional Medical Center, Castle Hayne VFD, Wrightsboro VFD, and local Forest Service. The offsite support groups were invited to participate in the biennial exercise held on July 10,1997, The inspector observed an effective interfaco between the onsite ir,eldent Commander and the offsite VFD incident Commander in the utilization of resources (personnel and equipment) respor' ding to the postulated accident. All agreement letters were reviewed and renewed in accordance with the RC&EP requirement.

(3) Conclusions The offsite interface was considered a program strength based on documentation to show periodic training (e.g., blennial exercise participation and site familiarization tours), and the MSSEP involvement with the county emergency management officials as a volunteer to the local emergency planning organization. The licensee's interface with the offsite support agencies was effective in assuring that the offsite authorities were familiar with their role, responsibilities, and the licensee's concept of operations during an emergency.

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e. Drills and Exercises (F3.05)

(1) Insoection Scan Section 7.3.1 of the RC&F.P required that at least one drill / exercise be cor ducted every other year to test t.1e timing and effectiveness of the implementing procedures, to test emergency equipment, and to ensure that emergency organization personnel are familiar with their duties.

Further, the RC&EP required that the drill / exercise simulate an on site emergency condition that will require participation by the site emergency organization and a number of the off site support agencies.

Examine records from previous drills and exercises to verify that critiques were held and action items were assigned along with a corrective action completion date.

(2) Observations and Findinas The last full scale NRC observed exercise was conducted on November 10,1994. By NRC letter dated October 8,1990, the licensee was granted a one time exemption to delt.y the exercise. The basis for the exercise delay resulted from the impact of Hurricanes Bertha (July 1996) and Fran (September 1996) on licensee and offsite resources. Consequently, the exercise held on July 16,1997, was conducted in fulfillment of the exemption request and the requirement in Section 7.3 of the Plan.

The licensee submitted for NRC review and approval the information on the scope, objectives, and scenario in advance of the exercise date. The scenario was reviewed in advance of the exercise and was discussed with licensee representatives prior to the exercise. No major problems were identified during the review, but minor inconsistencies became apparent during the exercise. The inconsistencies failed to detract from the overall performance of the licensee's emergency organization. The exercise scenario simulated an accident involving a GE liquid transfer truck (transporting material to the onsite waste treatment facility) and a fork truck (transporting shipping containers fron, FMO). The exercise commenced at approximately 1:03 p.m., but due to high temperatures and humidity an exercise participant experienced heat exhaustion and the exercise was terminated at approximately 2:18 p.m. The scenario and associated props were well developed and provided participants with a set of conditions which exercised and challenged many aspects of the ERO, Plan, and procedures. The inspector noted as a program strength the licensee's commitment to training the exercise controller organization.

During practice drills, the licensee's controller organization was identical to controllers and evaluators used during the exercise. This resulted in a significant enhancement to exercise control.

23 i

Exercise participants includud offsite VFD, local hazardous material team, and the Nuclear Regulatory Commission (NRC). NRC participation included the Reglon 11 Base Team, and two inspectors designated as the NRC Site Team. Offsite observers included State, local, and industry personnel. The NRC evaluators observed the licensee's actions in the following areas:

e Notification and communication with offsite authorities, e Interface between the ED, the ECC staff, and on scene response personnel, e On scene response by various emergency teams (onsite and offsite fire brigade, medical, transport, and health physics).

e ECC activation and event classification.

In response to the simulated emergency, the ERO was effective in classification, notification, establishment of a decontamination facility, criticality safety assessment, and laterface with offsite response groups.

Good command and control w6.e displayed by the ED in the ECC and the incident Commander at the scene of the incident. As required by the RC&EP, the i,censee conducted a critique following the exercise which afforded players, controllers, evaluators, and observers an opportunity to provide comments, items were noted for improving the response as follows: 1) establishing the location for the incident command post to avoid potential exposure from releases in the event of a sudoen wind shift and change of direction; 2) an inappropriate route was taken by emergency medical personnel to treat the injured victims from the accident; and 3) re-entry team personnel did not exhibit concern for avoiding direct contact with leaking material (simulated HF). In addition to the aforementioned items, the NRC evaluators noted that inaccurate information was provided to offsite authorities regarding the emergency classification. The offsite communicator reported that a Site Area Emergency (SAE) was declared at a time in which the facility was actually in an Alert classification. The licensee attributed this error to the physicallocation of the communicator from the status boards and the lack of Information from briefings and emergency logs. The inspector indicated that the corrective actions taken to resolve those items discussed in the critique and the improvement to the offsite communicator's location ano/or information flow would be reviewed during a subsequent inspection and was considered an IFl. >

(IFl: 70-1113/97-07-08: Review the adequacy of corrective actions taken to resolve items from the exercise critique).

. The licensee's response to issue a press release was reviewed and considered an area for improvement in the timeliness of issuance and the

t 24 content of information. The inspector noted that the SAE was declared at 1:22 p.m.; at 1:29 p.m., a simulated phone call was received from a nearby resident reporting fumes were observed in vicinity of subdivision; and numerous offsite support agencies (VFD, EMS, and HAZMAT) had responded to the site as of 2:20 p.m. However, no press release was issued to inform nearby residents regarding facility status or potential danger to plant employees, the public, or environment. When questioned regarding the press release, the inspector was informed that the licensee's policy is to prepare a release and have available only in the event of a media Inquiry However, unless informatlan is requested by the media, a press release is not issued. The inspector Indicated that this area will be reviewed during a future exercise for improvement.

The inspector reviewed the Exercise Planning Team (EPT) evaluation report for a November 1994 and November 1995 comprehensive emergency exercise for verification that records were being maintained in accordance with Section 8.2 of the RC&EP. The review disclosed that critiques were held, items recommended for corrective actions were assigned to a responsible manager including a commitment date.

However, when questioned regarding the status of an item as opened or closed, the licensee contact was unable to ascertain the status due to -

lack of supporting documentation and/or a tracking system for followup on those items assigned outside of the emergency preparednesc reporting chain (e.g., maintenance, rad protection, etc.). The licensee contact acknowledged this area as requiring attention and committed to the development and implementation of a formalized tracking program.

During the exit meeting, the inspector was informed that the plant system know as REGTRACK was being considered. The inspector informed the licensee that the implementation of a formalized tracking system to ensure timely closure was an IFl for review during a subsequent inspection. (IFl: 701113/07 07 09: Verify the implementation of a formalized tracking system for ensuring timely closure of action items identified during drills / exercises).

(3) Concluslot s The ERO response to the postulated accident was effective in assessing the impact and consequences of the incident on plant personnel, the environment, and the offsite population. The controller / evaluator critique was critical of the response and identified similar items for improvement as the NRC evaluation team.' An area requiring improvement is the system of followup on items identified during exercises and drills.

4

t 25

f. Emeroency Eauloment and Facilities (F3.06)

(1) Insoection Stopa Facilities and equipment were inspected to detent.:ne whether the licensee's ECC, emercency response equipment, instrumentation, and -

supplies were maintained in a state of operational readiness,-

(2) Observationg_and Findinas During the exercise, the inspector observed equipment operations at the

- ECC and the locaelen of the simulated accident. With one exception, no problems were'noted. The exception had to do with the licensee's inability to boot up the computerized dese projection program due to problems asulated with the local area network (LAN), The licensee later resolvec' the problem and discussed actions to ensure the automated capability was available in the future in the event the L.AN is lost.

The meteorological system located in the ECC for providing wind speed and direction was verified as operational and according to documentation calibrated on April 9,1997. The inspector reviewed documentation to -

confirm the periodic testing and surveillance performed on the backup  :

power source for the ECC and survey instruments located inside the ECC. In addition, as stated in Section F3.03, the licensee's notification system for contacting responders during off hours was reviewed and no problems were noted; terting and periodic surveillance was performed at the rey Jted intervals.

(3) - Conclusions The Phn and procedures were maintained current and up to date. The ECC and equipment were adcouately maintained and appeared to be operationally ready for responding to various types of accidents.

- g, Followuo on Previousiv IdenTied items (1) Insoection Scooe tl

[ The insp6ctor reviewed actions taken by the licensee to correct a 1 previous issue to verify that the corrective actions were adequate and  !

had been completed.

(2) Observations and Findi3gs (Closed) IFl 70-1113/96 05-01: Verify the adequacy of corrective actions to ensure timely activation and staffing of the ECC.

.___-__-.a

4 26 Based on documentation review and an interview with the MSSEP, corrective actions were taken in accordance with licensee commitments discussed in Paragraph 4 of NRC Inspection Report No. 70-1113/96-05.

In addition, since the CY 96 inspection, the licensee purchased alphanumeric type pagers (April 1997) which provided the capability for Messaging or providing details to responder (e.g., drill, actual event, type of event, etc.). The inspector reviewed the results of pager tes tavering the period August 1,1996 to July 10,1997. Prior to the replacement of ,,

the previous pagere, t% results from pager drills demonstrating timely activation and staffN revealed 75 to 88 percent of the responders were contacted and avaihbke for responding to the ECC in a timely manner.

Following the implementation of an alphanumeric type pager (during April-1997), the percentage of responders acknowledging contact and availability to respond were 100 percent.

(3) - Conclusions The corrective actions were adequate for item closure,

h. Information Notices (1) Insoection Scoce  ;

The inspector reviewed the following information Notice (IN) to determine if the information had been received by the licensee; IN 97-23: Evaluation And Reporting Of Fires And Unplanned Chemical Reaction Events At Fuel Cycle Facilities (2) Observations and Findinos The inspector determined that IN 97-23 had been received by the licensee, distributed to appropriate personnel, and reviewed for applicability with the RC&EP and Practices / Procedures 40-32 entitled

" Criticality / Radiological Safety Event Communicatk and Notificatinn."  :

The results indicated that the details from IN 97-23 had been properly addressed.

(3) Conclusions The licensee's actions were appropriate.

6.- Exit Interview The inspection scope and results were summarized on July 18,1997, with those persons indicated in the Attachment. The inspector described the areas inspected and dira msed the inspection results, including apparent violations, non-cited violations, and

27

' the likely informational content of the inspection report with regard to documents and/or processes reviewed during the inspection Although proprietary documents and processes were occasionally reviewed during this' inspection, the proprietary nature of

- these documents or processes has been deleted from this report. Disser..ing comments were not received from the licensee.

Apparent violations were discussed with NRC HQ staff ana Region ll management in the days following the exit intervlow Based on their low safety significance, the apparent violations were recharacterized (as IFis and NCVs) to the licensee in a

- telephone conversation on August 1,1997.

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ATTACHMENT Licensea W. Baker, Manager, Quality Audits and Programs

• D. Barbour, Coordinator, Radiation Protection

• D. Brown, Team Leader, Environmental Project D. Calcaterra, PMQC Inspector

• M. ChlPon, Manager, Joint Conversion Project -

• S. Dale, Lead Auditor, Compliance Auditing

• D. Dowker, Team Leader, Environmental Process Team

• T. Flaherty, Manager, D y Conversion Project

• R. Foleck, Senior Licensing Specialist G. Fornaslero, Engineer, Packing and Transportation

• P. Godwin, Coordinator, Fire Safety and Emergency Response "L. Gutermuth, industrial Safety Manager

• T. Hinshaw, Team Leader, Powder Preparation and Pack

• R. Keenan, Manager, Site Security and Emergency Preparedness

• J. Kline, Powder Production Line Manager

• A. Mabry, Principal Nuclear Safety Engineer i

1. • C, Monetta, Manager, Environmental Health and Safety

• S. Murray, Team Leader, Chemical Conversion J. Newton, PMQC Inspector

• W. Ogden, Facilities Manager

• R. Pace, Manager, Logistics and Emergency Director

• L. Paulson, Acting Manager, Nuclear Safety

• L. Quintana, Manager, Fabrication Product Line

• R. Reda, Manager, Fuels and Facility Licensing

• G. Sbraco, Environmental, Health and Safety Engineer H. Shaver, Nuclear Safety Engineer D. Sheppard, Lead Exercise Controller

• S. Smith, Radiation Safety Monitor

• C. Tarrer, Leader, Configuration Management

• K. Theriault, Manager, FMO Quality

• F. Walker, Team Leader, Shipping and Traffic

• R. Yopp, Shipping and Traffic Specialist Other licensee employees contacted included engineers, techniciens, production staff, security, and office personnel. .

• Denotes those present at the exit meeting on July 18,1997. *

1. Participated in telephone call on August 1,1997

2 INSPECTION PROCEDURES USED IP 84850 Radioactive Waste Management IP 84900 Low Level Radioactive Waste Storage IP 86740 Inspection of Transportation Act:vities IP 88020 Plant Operations IP 88050 Emergency Preparedness LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Item Number Status DescriotioD 70 1113/96-05-01 Closed IFI-Venfy the adequacy of corrective actions to ensure timely activation and staffing of the ECC.

70-1113/97-07-01 Open IFI-Review improvements in identifying entrances to controlled areas.

70-1113/97-07-02 Closed NCV Failure to require worker to perform personal contamination survey upon leaving controlled area.

70-1113/97-07-03 Open IFI-Review corrective action (s) to correct discrepancies between plant practices and License Application concerning step-off pads.

70-1113/97-07-04 Open IFI-Review TaproM investigation findings and corrective actions concerning the scalding of a maintenance worker in Uranium Recovery.

70-1113/97-07-05 Closed NCV-Failure of a maintenance worker to obtain proper authorization for a temporary modification to a ventilation system in DCP area.

70-1113/97-07-06 Open IFl-Review licensee's investigation of the configuration management procedure violation involving a temporary modification to a ventilation system in the DCP area.

1 q

______ _ 1

3 70-1113/97-07-07 Closed NCV Failure to conduct an independent audit during CY 96 in accordance with the RC&EP.

70-1113/97-07-08 Open IFI-Review the adequacy of corrective actions taken to resolve items from the exercise critique.

70-1113/97-07-09 Open IFl Verify the implementation of a formalized tracking system for ensuring timely closure of action items identified during drills / exercises. ,

LIST OF ACRONYMS USED ADU Ammonium Diuranate BTP Branch Technical Position CaF, Calcium Fluoride CoC Certificate of Compliance CFR Code of Federal Regulation '

CY Calendar Year DCF Dry Conversion Facility DCP Dry Conversion Process DVRF Decontamination and Volume Reduction Facility ED Emergency Director EP Emergency Procedures ERO Emergency Response Organization FET Field Examination Technology FMO Fuel Manufacturing Operations FSS Final Status Survey GE General Electric IFl inspector Followup Item IR Inspection Report LLRW Low Level Radioactive Waste ,

MSSEP Manager, Site Security and Emergency Preparedness Nai Sodium lodide NCV Non-Cited Violation NSI Nuclear Safety Instruction NSR/R Nuclear Safety Release / Requirement ONMSS Office of Nuclear Material Safety and Safeguards P/P Practices and Procedures QA - Quality Assurance QAP Quality Assurance Plan QC Quality Control RC&EP Radiological Conti igency and Emergency Plan SCBA Self-Contained B eathing Apparatus

1 .

l 4

SNM Special Nuclear Material TCLP Toxicity Characteristic Leaching Procedure UF. Uranium Hexafluoride l UIR Unusual incident Report URI Unresolved item URU Uranium Recovery Unit VIO Violation I

9

NEP SITE EMERGENCY EXERCISE July 16,1997

1.0 INTRODUCTION

in compliance with Radiological Contingency and Emergency Plan (RECP) )

Sectm,7.3, GENE's Nuclear Energy Production (NEP)in Wilmington, NC, will conduct a biennial drill / exercise to simulate an on site emergency condition that will require participation by the site emergency organization and a number of off site support agencies. The licensee submitted the objectives and the scenario for this site emergency exercise to the NRC for review 30 days in advance of the exercise. 'Ihis scenario package describes the objectives, scenario, expected activities, exercise control, evaluation and controller check list and will be presented to the NRC inspectors participating in the exercise prior to the event.

2.0 DRILL OBJECTIVES This exercise has the objective of exercising and evaluating the performance of NEP's ERT, EMT, and Emergency Organization's (EO) response to a large incident and will require the following:

2.1 Activation of the Emergency Organization.

2.2 Solicitation and activation of Mutual Aid Response for local Fire, EMS, .

HAZMAT, Emergency Management from the County and State.

2.3 Demonstration of the Incident Command System utilizing the ERT, EMT, Building Manager, and Security functions.

2.4 Classification of the event and communication with off site County and State agencies as well as the NRC.

2.5 Participation of the visiting NRC inspectors on site during the event.

2.6 Evacuation of personnel from the affected areas and accountability of all GE and Contractor personnel in a safe and timely manner.

2.7 Incident to initiate inside the Controlled Access Area and include radionuclide contamination.

2.8 Incident simulation to include as mucn realism as practical.

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2.9 Evaluat .n of the environmental impact including assessment and evaluation of down wind & drain implications.

2.10 Preparation and plans for response to Media inquiries.

3.0 SCENARIO DESCRIPTION (Times approximate) 2300 hrs GE liquid transfer truck with nomially generated 3 ppm uranium at 40% solution con:entration HF has been loaded with 4500 gals. and is to transfer the liquid to waste , ~

treatment as it is insufficient concentration for off site sale.

While en route at the intersection just N,W of the HF building, a fork truck from FMO traveling North with 8 Uranium loaded BUJs improperly being driven with the forks fonvard, impacts the side of the tank truck causing a leak of HF, The BUJs come off the fork truck,2 outer lids come off and the internals are exposed / sprayed with liquid and vaporizing HF. The containers are attacked by the acid and the contents will potentially be released to the environment. (Representative equipment will be utilized. Liquid and vapor will be simulated using water and a smoke generator).

1302 hrs .

A bystander near a telephone (on-site controller) sees the accident and reports by phone to 5555. He reports possible injuries and fuming. The fire alarm is also sounded by the on-site controller.

The fork truck operator (Actor 1) is burned on the legs and requires medical assistance but is conscious and mobile. (Injury will be simulated).

The tank truck driver (Actor 2) receives hand and shoe HF contamination when he cornes to the aid of the injured fork truck operator. The two move away and up wind from the plume. Any other unstaged personnel who render assistance and enter either the plume or sustain liquid contamination, become victims.

4 130S hrs The injured individual's legs (Actor 1)'are painfully buming and he locates a safety shower inside the HF building. He will disrobe and continue to shower until EMT arrival for subsequent disposition.

Phone caller (on-site controller) remains at scene out of danger to appraise the ERT of the situation.

4 .

t There is a plume of gas vapor rising from the leak which drifts offin w".ntever direction the wir.d is blowing at the time.

The 4500 gals. ofliquid Hf continues to drain / spray out of the tanker, ento the road and ground, chemically attacking the BUJs and contents. (Liquid spill will be simulated with water).-

1308 his The ERT arrives on scene and recognizes that BUJs are involved and the HF vapor plume is significant. The Emergency Organization convenes in the ECC.

1330 hrs An off site phone call is made to the GE switch board (Security) indicating the plume has been observed off site resulting in a bad odor and some respintory irritation. (Call by Actor 3),

1400 am The leak stops and the plume begins to diminish.

4.0 EXPECTED ACTIONS The following actions are expected to be performed by the Emergency Organization (EO) at the scene of the event, on the plant site, and in the Emergency Control Center (ECC):

INCIDENT SITE ERT ECC EO Determine the nature of the emergency.

Establish Incident Commander and EO convenes in ECC.

, communicate with Building Manager. Request EO to assemble with 4 "ones".

Assess the nature and extent of the release, EO establish communication with both the vapor, uranium and liquid on the incident Commander.

ground.

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Response team advises EO in ECC as to the Evaluate incident Command's dangerous nature of the vapor plume and liquid assessment and make recommendations and may initiate or recommend appropriate evacuations, i

Assess safety and appropriateness of assembly Adjust assembly areas as appropriate.

areas.

EMT's assess nature and appropriate Identify individual and verify intervention for injury. Injury will be severe appropriate actions are taken.

enough to require hospital treatment.

(simulated) They will advise EO.

Contact GE medical that victims will be taken All appropriate off site notifications to local hospital. and interfaces should be made or simulated.

Incident is classified Alert and possibly a Site Emergency.

An appropriate news release for the media should be prepared.

The EO should dispatch GE team to the site down wind boundary to assess the conditions leading to the off site phone call.

The EO should evaluate the potential environmental impact of the incident and plan appropriate action. Liquid will have been introduced into drainage system. Depending upon the extent of i vapor plume and wind direction, EHS may be requested to perform off site sampling.

A clean up plan will be developed.

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