ML20207U066

Forwards Operational Safety Assessment Insp Rept 70-1201/87-02 on 870202-06 & Summary of Operational Safety Assessment Weaknesses & Improvement Items

ML20207U066
Person / Time
Site:	07001201
Issue date:	02/27/1987
From:	Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Alto R BABCOCK & WILCOX CO.
Shared Package
ML20207U067	List: ML20207U066 ML20207U072
References
NUDOCS 8703240578
Download: ML20207U066 (7)

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fE.B27 W Docket'No.-70-1201 License No. SNM-1168 Babcock and Wilcox Company

-ATTN: Mr.' R. A. Alto Plant Manager

' Commercial Nuclear Fuel Plant P. O. Box 11646' Lynchburg, VA 24506-1646 Gentlemen:

SUBJECT:

NRC INSPECTION REPORT NO. 70-1201/87-02 This refers to the Nuclear ' Regulatcry Commission (NRC) Operational Safety Assessment ~ conducted by G. L. Troup and other members of the team on ,

I February 2-6, 1987. The inspection ' included a review of activities authorized

' for your Lynchburg facility. At the conclusion of the inspection, the findings were discussed with those members of 'your staff identified in the enclosed

. inspection report.

' Areas examined during the inspection are identified in the report, Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations of activities in progress.

The-findings of this inspection indicate that weaknesses exist in some aspects of your operational safety program and that there are program areas which should be evaluated and considered for improvement. These are discussed in Appendices A

and B which .are titled " Operational Safety Assessment Weaknesses" and

" Operational Safety Assessment Improvement Items," respectively.

We recognize that explicit regulatory requirements pertaining to each item identified in Appendices A and 8 may not currently exist. Notwithstanding this, you are requested to submit to this office the following information within 90 days of receipt of this report.

'1. the actions you have taken or plan to take on the weaknesses specified in Appendix A, and

2. the results of your consideration of each of the improvement items specified in Appendix B.

In accordance with 10 CFR 2.790(a), a copy of this letter and enclosures, and any reply will be placed in the NRC Public Document Room. If you wish to withhold information contained therein, please notify this office by telephone within ten days 'of the date of this letter and submit a written application to withhold information contained therein promptly thereafter. Such application must be f2fh h c l/l c _

rec 7

O O Babcock and Wilcox Company. 2 FEB271987

. Commercial Nuclear. Fuel Plant consistent with_ the requirement of 10 CFR 2.790(b)(1). If we do not hear from-you'in this regard within the period specified above, this letter and enclosures, and' any reply will be made available to the public and be placed in the NRC

-Public Document Room.

The response directed by this letter and its enclosures are not subject to the clearance procedures of the Office of Management and Budget as required by the -

Paperwork Reduction Act of 1980, PL 96-511.

Should you have any questions concerning this letter, please contact us.

Sincerely, J. Philip Stohr, Director Division of Radiation Safety and Safeguards

Enclosures:

1. Appendix _A - Operational Safety Assessment Weaknesses

2. Appendix B . Operational Safety Assessment Improvement Items

3. Inspection Report - Details bec w/encls:

G. Sjoblom, IE W. Crow, NMSS RII RI

': es EJMc 1pi e WEC ine 2/t1/87 2/2?/87 2 87

01 O APPENDIX A OPERATIONAL SAFETY ASSESSMENT WEAKNESSES-Based on the results of the NRC's operational safety assessment of the Babcock

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-and Wilcox - Commercial Nuclear Fuel Plant conducted on February 2-6, 1987, the following , weaknesses were -identified -(references are to sections in NRC Inspection Report 70-1201/87-02):

1. Collectively the following issues indicate a weakness in the nuclear criticality safety program:

.a. A procedure which specifies the analyses which the Health-Safety Supervisor is authorized to perform without NCSG approval, and the confirmatory requirements for checking the calculations had not been prepared (6.a.).

b. Instructions for receiving authorization to use fire hoses (where otherwise prohibited) to. fight fires, and the authorization '\

requirements has not been standardized (6.b.).

c. A review and proceduralization of the storage requirements for non-SNM materials ~within and between SNM storage arrays which includes nuclear criticality safety criteria to ensure- no potential hazards were introduced had not been performed (6.b.),

d. The NCSG quarterly audits did not include a review of the weekly Health-Safety supervisor's audits ~ to determine whether trends are developing that may compromise nuclear criticality safety (6.c.).

-2. Collectively the following issues indicate a weakness in the fire protection program:

a. A comprehensive fire prevention / protection program which incorporates the guidelines of the Corporate Property Conservation Manual had not been established (7.b).

b. A procedural program for inspection, maintenance, -and testing of all fire protection features and equipment had not been developed (7.c).

c. Annual flow tests of the fire protection water supply have not been performed (7.c).

d. Fire protection training for the fire brigade does not include an annual practice session and classroom training of essential fire protection subjects (7.d).

e. The fire brigade leaders did not complete additional training in leadership and fire ground command (7.d).

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Appendix A 2

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Area specific fire fighting emergency preplans for all_ plant areas have not been developed (7.d).

3. Oikes 'and drainage control in accordance with NFPA-30 to control the spillage of hazardous chemicals had not been provided. (8.c).

4. Collectively J the following issues indicate a weakness in the emergency preparedness program:

a. Notification of the counties for all emergency classes and notifica-tions to the State and local governments within 15 minutes and NRC with 1; hour of any emergency declaration has not been established in the RCP and Emergency Procedure (11.a).

b. A timely method for communication between emergency team members and -

emergency coordinators and leaders had not been implemented such that emergency operation could be efficiently controlled (11.b).

c. The supply of emergency SCBA equipment was not sufficient to outfit both a full fire brigade team and radiation monitoring personnel that may require the use of SCBA equipment (11.b).

d. A formalized program for providing annual emergency training to key management and security personnel who are expected to respond in the event of an emergency including primary, alternate, and backshift personnel had not been provided (11.c).

e. The Emergency Procedure did not provide all the pertinent emergency information (11.e).

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O O APPENDIX B OPERATIONAL SAFETY ASSESSMENT IMPROVEMENT ITEMS Based on the results of 'the NRC's operational safety assessment of the Babcock and Wilcox - Commercial Nuclear Fuel Plant conducted on February 2-6, 1987, the following items should be considered for improvement of the operational safety program at this facility (references are to sections in NRC Inspection Report 70-1201/87-02):

1. Proceduralizing the multipurpose use of safe transport carts to remove -the possibility of their misuse (6.b).

2. Revising the Health-Safety Audit Procedure (AS-1125, Rev. 6) to reflect CNFP practices and commitments (6.b).

3. Providing a copy of the memorandum to the . independent auditor (NCSG and Radiation Safety) on the corrective action taken on recommendations made based on the' quarterly audit (6.b).

4. Providing the sprinkler system's inspectors test connections with suitable outlets to simulate the flow of a single sprinkler head as denoted by NFPA 13 and 13A (7.c).

5. . Performing fire hose inspections on a monthly basis and including an intense visual inspection of hoses (7.c).

6. Performing annual medical examinations for fire brigade members including pulmonary and EKG testing (7.d).

7. Conducting fire drills in a manner consistent with nuclear fire protection industry practice (7.d)

8. Providing sufficient fire fighting equipment to outfit a full complement of fire brigade personnel (7.d).

9. Evaluating the risk to the plant and workers from fire or toxic gas exposure and implementing a fire safety program to minimize the risk (7.e).

10. Including data from the Material Safety Data Sheets (MSDSs) and the Hazards Communication-Program in the refresher training program (8.b).

11. Including data from the MSDSs in the Fire Prevention / Protection Plan (8.b).

12. Incorporating the review of chemicals and chemical hazards into the facility change review process (9.a).

13. Clarifying the action levels which constitute an emergency declaration for severe weather and fires so as to decrease the ambiguity involved in the classification process (11.a).

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Arpendix B 2

14. Coordinating with B&W NNFD and B&W LRC to ensure that consistent declarations are made for ' conditions affecting all three sites, such as severe weather (11.a).

'15. Including additional occurrences under the NOUE classification which would warrant-upgraded offsite awareness, such as transportation of contaminated, injured individual to an 'offsite medical facility or a transportation accident requiring response by site personnel (11.a).

16. Providing for renotification of offsite agencies upon emergency termination and as any significant change in plant conditions occur (11.a).

17. Developing and using a standard message form to facilitate the transmission of emergency information to offsite organizations which includes: time, date, classification, plant status, onsite and offsite protective actions,-

dose estimates, and meteorological information (11.a).

18. Providing for a quarterly review and update of emergency telephone numbers and personnel assignments in the Emergency Procedure (11.a).

19. Including in the Emergency Procedure the various site and offsite emergency center locations (11.b).

20. Including P& ids and other operational data in the assembly area emergency kit (11.b).

21. Including in the Emergency Procedure the sources of accurate meteorological information as well as the telephone numbers for contacting them (11.b).

22. Including in Exhibit C to the Emergency Procedure the actual State Protective Response Level / EPA Protective Action guides as they relate to sheltering and evacuation recommendations (11.b).

23. Incorporating a specific battery verification program into the routine maintenance procedures to include what checks are made and at what frequencies (11.b).

-24. Performing communications drills on a monthly basis to include the actual transmission of an emergency message to of fsite agencies (11.c).

25. Performing radiation monitoring drills semiannually to include environmental monitoring and responses to simulated releases (11.c).

26. Revising Section 4.4 of the RCP to include a description of the types of responses and assistance that each of the groups listed can provide and including the means of contacting these groups in the Emergency Procedure

-(11.d).

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O O Appendix B 3

'27. Including in the RCP and Emergency Procedure a clear -description of which site individual will be the primary interface and will be in charge of coordinating the offsite agency support effort (11.e).

28. Designating an individual on the backshift who has the full authority to control emergency operations and has received training on.the RCP (11.e).

'29. Providing foria formal annual review of the RCP and providing for management concurrence-and approvals on its revisions (11.e).

30. Performing an independent audit of the emergency preparedness program to include an evaluation of offsite interfaces, capabilities:and equipment, RCP and Procedures, and assignment of responsibility, ' on a periodic basi s (11.e).

31. Providing a-copy of the RCP to State and local support agencies (11.e).

32. Providing for. wider distribution of the RCP to onsite emergency management personnel (11.e).

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