IR 05000073/1987001

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-073/87-01

ML20236K416
Person / Time
Site:	Vallecitos Nuclear Center
Issue date:	11/02/1987
From:	Wenslawski F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Darmitzel R GENERAL ELECTRIC CO.
References
NUDOCS 8711090220
Download: ML20236K416 (1)

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NOV 2 1997 I

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Docket No. 50-73 i

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General Electric ^ Company

Vallecitos Nuclear Center a

P. O. Bnx 460

.l Pleasanton, California 94566 l

Attention:

Mr.' R. W. Darmitzel, Manager l

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Irradiation Processing Operation

Gentlemen:

Thank you for. your letter dated October 21, 1987,'in response to our Notice

'I of Violation and Inspection Report No. 50-73/87-01, dated September 24, 1987, inforfeing us of the steps you have taken to correct the items which we j

. brought to your attention.

Your corrective actions will be verified during a

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future inspection, Your cooperation with us'is appreciated.

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Sincerely, j

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A. Wenslawski, Chief

Emergency Preparedness and

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Radiological Protection Branch (

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DNImnDODIGUll.L GENERAL $ ELECTRIC ECEIvE0 C

Certit'l ed Dy Myfmg/hkUCLEAR ENERGY BUslNEss OPERATIONS GENERAL ELECTRIC COMPANY e VALLECITOS NUCLEAR CENTER e PLE

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October 21, 1987 j

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U. S. Nuclear Regulatory Cc'nmission Washington, D.C.

20555 Attention: Document Control Desk Subject:

Reply To A Notice of Violation 2) Inspection Report No.,50k73!

Referencest 1) License R-33, Docketi ~ 50-73/87-01; September 24, 1987.

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Gentlemen:

This letter is in response to a Notice of Violation issued in NRC Inspection j

Report No. 50-73/87-01 dated September 24, 1967. The three items contained in the Notice and GE's responses are as follows.

(1) none of the three firemen listed on the NTR Building (Building 105)

Emer.gency Team had been provided with self-contained breathing apparatus (SCBA) training; Following the implementation.of the VNC Radiological Emergency Plan in September,1984, there has been an ongoing effert 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 review 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 misfiled and was not located at the time of the inspection. A second fireman previously trained for SCBA was j

removed from the emergency team and was erroneously returned to the emergency

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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 training by the facility manager and the Site Emergency Planning Coordinator on the basis.that his emergency response activities could be controlled to 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 has been replaced on the emergency team.

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October 21,,1987'

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'All currently' assigned firemen have received'SCBA training or retraining.

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nrder to avoid this problem in the future, one individual in Nuclear Safety l

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l will maintain the training records and notify. management when training or

retraining.is needed.-

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ll-(2) for the period of May 1g84 to March 3,1987, documentation of initial-y

. training and annual reviews was not maintainedt.

Due to-a decrease.in the' activities conducted at VNC, a decrease in the.

'l number of personnel at VNC,. and organizational changes resulting from these j

decreases, the central training record file has not been maintained ast

originally intended..While it is our belief that the necessary. training has-j e

.been provided -in the past, the documentation of that training is not available. This is due.in part to the fact that training includes, in~

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. addition to formal. training provided by the Nuclear Safety, organization,.

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. safety meetings,. job-oriented training classes; emergency drills, etc.,:all

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. of'which were not_ properly documented.

In addition, the initial; radiological

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safety training for many Building 105 emergency team rambers occurred prior

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to the establishment of the central. record system and are.not available. VNC lhas' conducted a. complete assessment of our records and the results have been'-

. documented. All Bu'ilding 105 emergency team members for which training has

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not:been documented'will receive the required training by 12/31/87.

In order to avoid this problem in.the. future, one individual in Nuclear Safety will maintain all training records required for building emergency

team members. Management will be notified when training or retraining is required.

(3)' for the period of May 1904 to January 1986, annual reviews in '

respiratory protection, radiological protection, first aid and fire i

protectton were not conducted.

This violation is for not conducting annual reviews in respiratory

protection, radiological protection, first aid and fire protection for building emergency team members.

Respiratory training and retraining for building emergency team members was addressed in Item No. I above.

The statement in Section 10.0 of the VNC Radiological Emergency Plan,

... annual reviews....as appropriate for their assigned responsibilities",

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was assumed to allow flexibility in the determination of what training is necessary and at what frequency for specific team members.

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GENERAL $ ELECTRIC USNRC-

-3-October 21, 1987 Radiol 6gical 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 perforced only dutics 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

. reviews were not "... appropriate for their assigned responsibilities".

First l

aid classes.were given by the Red Cross at VNC in 5/84 and 3/87.

There were

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l two individuals assigned to the Building 105 Emergency Team as First Aiders.

l One of them satisfactorily completed the Red Cross course in 3/87; the other

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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 raurse in

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3/87 and should have become the second first aider. The team now 'ias two l

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 annually for Building 105. They were held in 3/86 and 7/07. These drills 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 l

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

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team personnel. Management will be notified when training or retraining is l

required.

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USNRC-4.

October 21, 1987

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I'believe that these responses demonstrate our intention to fully comply;with

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the requirements of the Emergency Plan for the Building 105 emergency team

. e will bring our training records _as well as our response W

training.

capabilities.into full compliance as quickly as possible, t

Sincerely,

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$6t0d m W R. W. Darmitzel, Manager-l

. Irradiation: Processing i

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USNRC.

J Regional Administrator, Region,V

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1450 Maria. Lane,' Suite 210

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Walnut Creek, CA' 94596 -

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