ML20247C988

Insp Rept 70-0824/89-02 on 890313-14 & 28-30.Violations Noted.Major Areas Inspected:Emergency Preparedness Program, Including State of Operational Readiness,Training,Periodic Drills & Exercises & Maint of Equipment & Supplies

ML20247C988
Person / Time
Site:	07000824
Issue date:	05/04/1989
From:	Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20247C953	List: ML20247C952 ML20247C958 ML20247C988
References
70-0824-89-02, NUDOCS 8905250110
Download: ML20247C988 (10)

Text

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. 1 a 7.aru UNITED STATES 1

c. jo NUCLEAR REGULATORY COMMISSION l 7f' n REGION 18

f j 101 MARIETTA STREET, N.W.

" # ATLANTA, GEORGI A 30323 s,*****/ MAY 101969 Report No.: 70-824/89-02 Licensee: Babcock and Wilcox Company Naval Nuclear Fuel Division - Research Laboratory Lynchburg, VA 24505 {

1 Docket No.: 70-824 License No. SNM-778 Facility Name: Naval Nuclear Fuel Division - Research Laboratory Inspection Conducted: Mar .h 13-14 and 28-30,1989 Inspector:

A. Gooden O, 4 PDate 4-69 Signed

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Approved y: . - _ ___/ ) .p t -f7- 8 f

/ W. Rankin, Chiefjr Date Signed Q Emergency Prep 6 redness Section Emergency Preparedness and Radiation Protection Branch Division of Radiation Safety and Safeguards

SUMMARY

Scope This routine, unannounced inspection was in the area of emergency preparedness.

Several areas within the emergency preparedness program were reviewed to determine if the program was being maintained in a state of operational readiness. Areas reviewed included training, periodic drills and exercises, maintenance of equipment and supplies, Radiological Contingency Plan (RCP) and Emergency Procedures update and distribution of changes to copy holders, fire protection program, and changes to the normal and emergency organization.

Results Within the areas inspected, the following violations were identified:

- Failure to conduct monthly inspection of portable fire extinguishers (Paragraph 7).

- Failure to conduct monthly inventory of the emergency lockers in Buildings A and B (Paragraph 3).

Failure to conduct quarterly training for the Fire and Rescue Team (Paragraph 7).

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1 A program weakness was also identified as a result of the licensee's failure to conduct the annual emergency drill in a manner that would adequately test the ability to implement the RCP (Paragraph 4). The inspection indicated the following:

- Since the last inspection (May 1988), there appears to be an increased I level of attention to the emergency preparedness program, i 1

- Noted improvements were in the areas of training, equipment maintenance, coordination with offsite support agencies, and initiation of a procedural update program.

The aforementioned improvements appeared to indicate a commitment by the licensee to ensure that the program is maintained in a state of operational readiness.

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REPORT DETAILS

1. Licensee Employees Contacted j

• F. Alcorn, Supervisor, Nuclear Criticality and Safety R. Bennett, Manager, Safety and Licensing

• C. Boyd, License Administrator J

• T. Grochowski, Health Physicist

• R. Loving, Manager, Safeguards and Security

• S. Schilthelm, Supervisor, Health and Safety C. Yates, Health Physicist W. Younger, Supervisor, Plant Engineering Other licensee employees contacted during this inspection included security force members, technicians, and administrative personnel.

• Attended exit interview

2. Offsite Support Agencies (88050)

The inspector held discussions with licensee representatives regarding the coordination of emergency planning with offsite support groups and adjacent Babcock and Wilcox (B&W) facilities (Naval Nuclear Fuel Division

[NNFD] and Commercial Nuclear Fuel Plant). According to Section 8.2 of the RCP, the agreements with offsite support agencies are maintained by the Emergency Officer. Agreements with the Concord Rescue Squad, Lynchburg General-Marshall Lodge Hospital, and the Concord Volunteer Fire Department had been updated in August 1987. The inspector reviewed a memorandum dated May 16, 1988 that outlined the resources and assistance to be provided by each of the B&W facilities in the event of an emergency.

The inspector noted that a site familiarization tour was conducted on August 2, 1988 with members of the Concord Volunteer Fire Department and Concord Rescue Squad. In addition, documentation was provided to the inspector to show that the licensee had contacted Lynchburg General Hospital to discuss the current emergency organization and their roles and responsibilities during an emergency. Further, during the annual exercise conducted in September 1988, the licensee conducted a notification drill with several offsite agencies.

No violations or deviations were identified.

3. Emergency Plans, Procedures, Facilities, and Equipment (88050)

In accordance with Section 7.4 of the RCP, the RCP and Emergency Procedures (EPs) shall be reviewed on an annual basis. The current copy of the RCP was dated June 1987, Revision 2. The inspector reviewed i documentation dated September 20,19P8 to verify that an annual review had been conducted. However, at the time of the inspection, due to personnel 1

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2 i reassignments in the License Administrator's position, proposed revisions i had not been incorporated into a revised draft RCP for review by the Emergency Control Organization and subsequent submittal for a license amendment. the distribution of changes to the RCP, Area Regarding(A0Ps),

Operating Procedures and EPs, the current program involved transmitting A0Ps under a cover letter. The cover letter required copy holders to return old pages with the cover letter as an acknowledgement that changes were received and inserted into the procedures manual.

However, changes to the RCP and EPs were not included in the formal program governing document control and distribution. The licensee acknowledged the need for a formal program to ensure that manuals are maintained current and up-to-date. Consequently, a commitment was made to formalize the distribution of changes to the RCP and EPs by May 1989. The i licensee was informed that this item was considered an Inspector Followup Item (IFI) for review during a subsequent inspection.

IFI (70-824/89-02-01): Formalize the distribution of changes to the RCP and EPs to ensure that manuals are maintained current and up-to-date.

The inspector selectively examined emergency kits and equipment from Building B. All survey instruments were within calibration and a successful battery check was obtained. Further, the inspector noted that the randomly selected items for inventory were available in quantities as listed on the equipment inventory sheet. As part of the equipment and instrumentation operability check, the inspector verified that the meteorological system and area radiation monitoring system were operable and calibrated. Both systems had calibration / certification stickers and none of the due dates for decertification had been exceeded. With two exceptions, licensee records confirmed that the required emergency equipment audits were conducted during the period January 1988 to February 1989. One exception involved failure to conduct monthly inspection of portable fire extinguishers (see item 70-824/89-02-06, Paragraph 7 for discussion); the other exception involved the failure to conduct a monthly inventory of emergency lockers in Buildings A or B during February 1988. Cognizant licensee personnel, when informed of the potential violation regarding the emergency lockers, informed the inspector that administrative actions had been taken to prevent recurrence. The administrative actions involved the implementation of a

" Task Assignment / Commitment Sheet," containing weekly and monthly tasks assigned to varicus staff personnel, which required staff sign-off when the task was completed. According to the licensee contact, status reviews or updates will be conducted on a weekly basis to ensure tasks are being completed at the specified frequency. The licensee was informed that this potential violation appears to meet the criteria specified in Section V. A of the revised NRC Enforcement Policy for not issuing a Notice of Violation. Consequently, this item is considered as a Non-Cited Violation (NCV).

NCV (70-824/89-02-02): Failure to conduct a monthly inventory of emergency lockers (Buildings A or B) in accordance with the RCP.

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3 Maintenance records for the emergency power source were reviewed. In the event of a loss of power, the emergency power sourca provides power to the evacuation alarm system, the hot cell's exhaust. fans, and criticality monitors. Weekly test documentation covering the period March 1988 -

March 1989 was randomly reviewed. No problems were noted. Tests were l conducted at the frequency specified in the procedure. Additionally, test results and corrective actions taken to resolve test failures were properly documented. The inspector conducted an operability test of the Emergency Notification System (ENS) from Building B with the NRC Operations Center.

l One NCV was identified as discussed above. No deviations were identified.

4. Tests and Drills (88050)

Discussions with licensee personnel and a review of records verified that tests and drills were conducted at the frequency specified in Section 7.3 of the RCP. An evacuation drill was conducted on April 11, 1988 and September 15, 1988. The latter was the annual emergency drill and included the activation of the Emergency Control Organization. The scenario for this drill involved a fire with an injured, slightly contaminated employee. In accordance with the RCP, a report was prepared by the Emergency Officer (dated November 1988), summarizing the exercise findings and recommendations in response to findings. Discussions with licensee representatives regarding the conduct of the annual emergency exercise disclosed what appeared .to be a fundamental misconception on the part of the licensee regarding the conduct of the annual emergency drill. The licensee did not use a -scenario that was held in confidence from the drill players. Although drill participants were not afforded the opportunity to participate in a " dry run" of the drill, the scenario details were provided to members of the Emergency Control Organization. l The inspector discussed with licensee representatives the reasons why the i NRC considered the licensee's current practice, as previously described, to be an unacceptable approach to conducting the required annual emergency drill. The licensee was informed that responding to a preplanned exercise does not appear to provide a true test of the adequacy of timing (mobilizing personnel, event classification, and notification), Plan  !

implementation, and assurance that personnel are familiar with their roles and responsibilities. In order to properly test the content and adequacy of the emergency program and procedures, the participants must not have advance knowledge of the scenario details. Licensee representatives agreed with this finding and indicated that plans for the 1989 calendar year (CY) exercise included using a scenario held in strict confidence from members of the Emergency Control Organization. The current practice of conducting a drill using a scenario that was provided to drill players was categorized as a program weakness.

Program Weakness (70-824/89-02-03): Failure to conduct the annual emergency drill in a manner that would adequately test implementation of the RCP and EPs.

No violations or deviations were identified.

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5 '. . Training (88050)

This area was inspected to determine if the licensee was providing training in accordance with the RCP. The inspector reviewed Section 7.2 of the RCP for a' description of the training program.

Annual' training was provided during the CY-88 to onsite and offsite response personnel in accordance with RCP. Walkthroughs were conducted with two individuals assigned to the emergency organization: one individual was designated as an alternate for the Emergency Officer position, and one individual was designated as a backup to the Receptionist. No problems were noted with the event classification, notification time requirements, or protective action recommendations.

However, the individual designated as backup to the Receptionist demonstrated a need for additional training as evidenced by the following:

When questioned regarding the appropriate notification in response to an accident involving an injured employee, the interviewee incorrectly stated that the initial notification would go to the Emergency Control Officer. According to Emergency Procedures, notification initially goes to the Emergency Team Personnel (Fire and Rescue).

When questioned regarding the meaning and actions in response to the panel of red lights (located in the kneewell of the receptionist desk) indicating, the interviewee was knowledgeable regarding the lights, but an incorrect answer was given regarding notifications to emergency personnel. According to the interviewee, if lights were indicating, the initial call would be made to the Emergency Officer or in his absence the Alternate Emergency Officer. According to procedure, the receptionist should contact the Emergency Control Organization personnel via group page or pocket pager.

A licensee contact accompanying the inspector during the walkthrough acknowledged the need for additional training on notification procedures.

This item was identified to licensee management as an IFI.

IFI (70-824/89-02-04): Provide security personnel serving as an alternate or backup to the Receptionist additional training on actions in response to an emergency (specifically notification and activation).

The inspector discussed the elements of the licensee's respiratory protection program with a member of the licensee's staff. Specific areas

' discussed included the types of devices used at the facility, training, decertification, medical examinations, and program documentation. Records for several individuals assigned to the Emergency Response Team were reviewed to verify the implementation of respiratory protection training for team personnel. The records showed that selected individuals were ~

I within their certification dates and had current medical examinations.

No violations or deviations were identified.

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6. Organization and Management Control (88050)

The inspector's discussion with a licensee representative disclosed that administrative changes had been made to both the normal and emergency organizations since the May 1988 inspection as a result of retirement, promotion, and reassignment. Example of changes in this category included the retirement of an individual who previously filled the position of Industrial Safety Officer. The individual previously assigned as Licensing Administrator and Facility Supervisor to the normal organization, and alternate to the Emergency Officer in the emergency organization, was reassigned to the B&W NNFD. The aforementioned changes did not impact the reporting chain for emergency planning, and, further, there was no impact on the operational readiness of the emergency preparedness program.

No violations or deviations were identified.

7. FireProtection(88050)

The inspector discussed this program area with a licensee representative and reviewed the appropriate documentation. The licensee's Fire Brigade is synonymous with the Emergency Response Team (ERT). The Emergency Response Organization chart identified five individuals assigned to the ERT. During CY-88, several training sessions involving classroom instructions and hands-on training were conducted. However, the inspector noted during the review of documentation that training had not been conducted during the period October 1988 through March 1989. Section 7.2 of the RCP required that the fire and rescue team attend quarterly training which includes hands-on and/or classroom training. The licensee was informed that failure to conduct the quarterly training with fire and rescue team personnel in accordance with Section 7.2 of the RCP is a violation.

Violation (70-824/89-02-05): Failure to conduct quarterly training for fire and rescue team personnel in accordance witn Section 7.2 of the RCP.

The inspector reviewed B&W Research and Development Division Administrative Procedure Section 19.0 for a description of the fire protection maintenance program. According to procedure, portable fire extinguishers will be inspected on a monthly basis, and fire hoses are inspected and hydrostatically tested on an annual basis.

Audit records reviewed for the period January 1988 to February 1989 indicated that, with two exceptions, audits were conducted at the required frequency. The two exceptions involved the months of December 1988 and January 1989. There was no documentation available to show that an inspection took place during the referenced time periods. This was identified to the licensee as a violation.

Violation (70-824/39-02-06): Failure to conduct monthly inspection of portable fire extinguishers during December 1988 and January 1989. j

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Two violations and no deviations were identified.

8. Action 'on Previous Inspection Findings (92701)

a. (Closed) Violation 70-824/88-04-01: Failure to provide . the opportunity for local emergency assistance personnel to annually tour the facility. The inspector reviewed licensee documentation to verify that actions had been taken in accordance with ' licensee's response to the Notice of Violation dated July 20,19% According to the documentation on August 2, 1988, 21 members of the Concord Volunteer Fire. Department and Concord Rescue Squad received a site familiarization tour that included discussions regarding the NNFD-RL emergency organization, hazardous materials, fire protection equipment, . notification, etc. Further, a letter dated June 1988 extended- an invitation to Lyr.chburg General Hospital for a site

' facility visit and tour.

b. (Closed) Violation 70-824/88-04-02: Failure to perform periodic meteorological instrument calibration as required by procedure. The inspector reviewed documentation to show that the meteorological system had been calibrated or certified during CY-88, and accurding to unification stickers, recertifications were planned at a 6-month intaval from the current date. Example: Wind speed and direction certification done October 18, 1988 and due for decertification (according to sticker) on April 18, 1989.

c. (Closed) Violation 70-824/88-04-03: Failure to perform a test of the communication links and notification procedure for early warning'of the public between the sitn State, and local emergency units during the annual drill. The inspector reviewed licensee documentation dated November 3, 1988, which summarized the annual exercise conducted on September 15, 1988. Included as part of the exercise were notification calls to offsite agencies (State, local, and Federal). With one exception, offsite notifications were tested with appropriate agencies. The exception was Campbell County' Sheriff's Department; according to the RCP, Campbell County is the local agency with responsibility for warning the public. As a result, this item was discussed with a licensee contact who acknowledged Campbell County's responsibility in preding notification to the general public. Further, the licensee ontact 5 formed the inspector that the CY-89 exercise will include a co9ere nsive communications drill between the site, State, and local re te se personnel, The licensee was informed that Violation 88-04-03 was considered closed, but an IFI would be opened to ensure that the annual emergency drill includes a comprehensive test of the communication links and procedures with offsite agencies.

IFI 70-824/89-02-07: Ensure that CY-89 exercise include a comprehensive communications drill between the site, State and local response personnel.

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d. (0 pen) Violation 70-824/88-04-04: Failure to provide annual retraining for members of the emergency control organization.

Licensee documentation dated August 10, 1988 indicated that the Receptionist and individuals designated as her relief personnel (alternates) had received training specific for the Receptionist role. Additionally, other personnel assigned key positions had received the required training. However, recent personnel changes due to reassignment and/or retirement resulted in personnel assignments to the emergency organization prior to completion of training.

c. (0 pen) IFI 70-824/88-04-05: Develop a pr,cedure to perform emergency radiological dose assessment using meteorological and source term input. The licensee had initiated actions in this area with tentative dates assigned for copletion. However, at the time of the inspection, all required changes to fully implement the procedure had not been completed.

9. Exit Interview The inspection scope and results were summarized on March 30, 1989, with those persons indicated in Paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results listed below.

Proprietary information is not contained in this report. Dissenting comments were not received from the licensee. The licensee acknowledged the findings as presented by the inspector. As stated in the summary of this report, the inspector acknowledged those areas of improvement since the last inspection.

Item Number Description and Reference 70-824/89-02-01 IFI - Formalize the distribution of changes to the RCP and EPs to ensure that manuals are maintained current and i up-to-date (Paragraph 3).

70-824/89-02-02 NCV - Failure to conduct a monthly inventory of emergency lockers in  ;

accordance with the RCP (Paragraph 3).

70-824/89-02-03 Program Weakness - Failure to conduct the annual emergency drill in a manner that would adequately test implementation of the RCP (Paragraph 4).

70-824/89-02-04 IFI - Provide Security personnel serving as backup to the Receptionist additional training on actions in response to an emergency (Paragraph 5).

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70-824/89-02-05 Violation - Failure to conduct quarterly training for' fire and rescue team ' personnel in accordance with Section 7.2 of RCP (Paragraph 7).

70-824/89-02-06 Violation - Failure to conduct monthly inspection of . portable fire extinguishers during December 1988 and January 1989 (Paragraph 7).

70-824/89-02-07 IFI - Ensure that annual exercise includes a comprehensive communications drill between the site, State, and local = response personnel (Paragraph 8.c).

Licensee management was informed that five open items were reviewed, as

' discussed in Paragraph 8. Three items were closed and two items remained open.

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