ML20236C830
| ML20236C830 | |
| Person / Time | |
|---|---|
| Site: | Vallecitos Nuclear Center |
| Issue date: | 10/21/1987 |
| From: | Darmitzel R GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8710270355 | |
| Download: ML20236C830 (4) | |
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NUCLEAR ENERGY BUslNESs OPERATIONS g
. GENERAL ELECTRIC COMPANY
- VALLECITOs NUCLEAR CENTER e PLEAsANTON, CALIFORNIA 94566 J l
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October 21, 1987 3
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U. S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Document Control Desk
Subject:
Reply To A Notice of Violation
References:
- 1) License R-33, Docket 50-73.
- 2) Inspection Report No. 50 73/87-01; September 24, 1987.
i Gentlemen:
This letter is in response to a Notice of Violation issued in NRC Inspection Report No. 50-73/87-01 dated September 24, 1987. The three items contained in the Notice and GE's responses are as follows.
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(1,) none of the three firemen listed on the NTR Building (Building 105)
Energency Tcues had been provided with self-contained breathing apparatus (SCBA) training; V following the implementation of the VNC Radiological Emergency Plan in September,19N, there has been an ongoing effort to ensure all firemen assigned to building emergency teams receive SCBA training and retraining.
Due to changes in personnel and in the firemen assignments, our efforts to fulfill this commitment and to maintain an up-to-date record system were not completely successful. A thorough rcview of our records of the Building 105 firemen indicated that one of three firemen had received SCBA retraining in January, 1987; but his record had been tdsfiled and was not located at the time of the inspection. A second fireman previously trained for SCBA was
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removed from the emergency team and was erroneously returned to the emergency team as a fireman before he received the required SCBA retraining.
The third fireman could not be properly fitted with SCBA and was excused from SCBA e
training by the facility manager and the Site Emergency Planning Coordinator on the basis that his emergency" response activities could be controlled to y
ensure that they would not require use of SCBA.
Therefore, SCBA training was not " appropriate for their assigned responsibilities".
(See Vallecitos Nuclear Center Radiological Emergency Plan, Section 10.0.) The fireman that had been excused from SCBA training; bas been replaced on the emergency team.
8710270355 871021
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- All Eur'rently assigned' firemen have received SCBA training or retraining.
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' order; to avoid this problem in the future,'one' individual in-Nuclear Safety will maintain the traintag records and notify mangement when training or retraining is'needed.. "3
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/j (2) for the;perlo of.
1984toMarch3,198,documentationofinitib1 training and: annual' reviews was not maintained;
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Due to.a decreaWin the activitie's conducted at VNC, a decrease in the number;of personnel.at,VNC, and orgdizational changes resulting from these decreases, the central! training record ' file has not: been maintained as y
originallyL ntended. While.it is our belief that the necessary training has i
been provided;in.the past,'the documentation of that training is.not available. SThis -is due in part;to.tly fact that training includes,.in-addition to formal training preNidesby the Nuclear Safety organization, 1
safety meetings, ' Job-oriented tra f r,f re classes, energency drills, etc.,- all of-which were not properly-documented;.
In addition, the initial radiological safetytrainingformanyBuilding10yemergencyitaammembersoccurredprior to the.. establishment of the central record syster; and are not available. VNC has-conducted a complete assessment of our records and the results have bee'n" a o documented. All. Building 105 emergency team members for which training has
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not bgen. documented will receive the required training-by 12/31/87.
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4 In order.to avoid this problem in the future, one individual in Nuclear i
ji Safety will-maintain all training records required for building emergency 4
team members. Management will be notified when training or retraining is e
required.
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k (3)VcththeperiodofMay1984toJanuary1986,annualreviewsin p
respiratory protection, radiological protection, first aid and fire protectfon were not conducted.
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This violation is for not conducting annual, reviews in respiratory protection, radiological protection, first.Md and fire protection for l
building emergency team members.
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a Re::piratory tr.Onirg%d retraining for building emergency team membebs was 6i addressedin item Wo.1 above.
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.The' state in S ct n 10.0'of the VNC Radioli a
.., annual reviews....as appropriate for their bg,1 cal Emergency Plan,
.ssigned responsibilities",
was assume (toallowflexibilityinthedeterminatnnofwhattrainingis i
neceszary and at whry frequency for specific team members.
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p GENER AL $ ELECTRIC USNRC October 21, 1987 Radiological protection is one of the subjects addressed in the NTR operator's requalification program which they complete every 2 years. All NTR operators work routinely in radiation areas with. radioactive materials.
Three of these operators were assigned to the emergency team. Two certified radiation monitor technicians who monitor routinely for NTR activities were also assigned to the team.
There are only minute amounts of radioactive material in Building 105 outside of the NTR facility, and the personnel working there have not been required to have radiation protection training which would permit them to perform radiation work unescorted during emergencies.
Their activities would be controlled to ensure they performed only duties for which they are adequately trained.
A valid first aid card issued by the American Red Cross has been considered adequate first aid training for emergency team members.
These cards expire 3 years from the date the course was completed.
It was felt that annual i
reviews were not "... appropriate for their assigned responsibilities".
First aid classes were given by the Red Cross at VNC in 5/84 and 3/87.
There were two individuals assigned to the Building 105 Emergency Team as First Aiders.
One of them satisfactorily completed the Red Cross course in'3/87; the other one completed the course in 5/84. The second individual was scheduled to take the course in 3/87 but was ill. Another member of the team (the assigned Alternate Building Emergency Coordinator) completed the course in 3/87 and should have become the second first aider. The team now has two designated first aiders with valid Red Cross first aid cards.
Building emergency team firemen are trained to fight incipient-stage fires with portable fire extinguishers and installed hoses.
If a fire progresses to the interior structural stage fire, the team will wait for off-site assistance.
Building 105 has an installed sprinkler system. All three individuals assigned as firemen to the Building 105 Emergency Team received fire training in 10/85 when it was given by the Site Fire Marshal assisted by firemen from the California Division of Forestry.
Fire drills have been held j
annually for Building 105. They were held in 3/86 and 7/87. These drills i
were critiqued, but attendance for the drills was not documented.
Following the drills, the Site Fire Marshal normally has an instruction period for the firemen..
Building 105 emergency team members requiring training or retraining have been identified and the training or retraining will be completed by 12/31/87.
In order to avoid this problem in the future, one individual in Nuclear Safety will maintain the training records required for building emergency team personnel. Management will be notified when training or retraining is
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required.
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. GENERAL $ ELECTRIC-USNRC October 21, 1987-I'believe that these responses demonstrate our intention to fully comply with-the requirements of the Emergency Plan for.the Building 105 emergency team 1
training.- We will bring our training records as well as our response capabilities into full compliance' as quickly as possible.
. Sincerely, h h 4fm>
,R. W. Darmitzel, Manager j
Irradiation Processing
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cc: USNRC.
Regional Administrator, Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 4
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