ML20062F773
| ML20062F773 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 11/16/1990 |
| From: | Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20062F770 | List: |
| References | |
| 70-1201-90-06, 70-1201-90-6, NUDOCS 9011280166 | |
| Download: ML20062F773 (12) | |
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NOV 181000 Report No.: 70-1201/90-06 Licensee: Bt,W Fuel Company Conroercial Nuclear Fuel Plant i
Lynchburg, VA 24505 Docket No.:
70-1201 License No.:
SNM-1168 Facility Name: Consnercial Nuclear Fuel Plant inspection Co ducted: October 15-19, 1990' csr E, G o(fen &fj g [ < k L-,
l& MoV, /990 Inspe or:
Date Signed Approved b :
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Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection was conducted 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.
Specific areas reviewed included the following:
observation and evaluation of emergency drill; maintenance of select emergency and fire protection equipment; Radiological Contingency Plan (RCP) and l
implementing procedures update and distribution of changes to copy holders; I
training, periodic drills, and exercises; and open items from previous l
inspections.
Results:
In-the areas inspected, one non-cited violation (NCV) was. identified for failure to document specialized training in accordance with the procedural requirements (Paragrap 4).
Based cr. the licensee's response to the scenario, the exercise was considered fully successful. The following program strengths-were noted:
(1) facility evacuation; (2). timely activation and' notification of the Radiological Contingency-Response organization (RCRO); (3) consnand and control at the incident-scene;- (4) timely and appropriate offsite notifications; (5) pronot response. by Emergency - Teams to incident area; (6) self-criti findings; (7) que and dentification of - corrective actions for exarcise periodic drillst involving. the RCR0; (8) use of the training; gg{}l'(tC1bb b11l9 PDR AIiOCF: 0700 1
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facility as an Err.ergency Operations Center (E0C); and (9) interface and cornmunications between the emergency control point and the E00.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees R. Alto, Plant Manager
- D. Codrea, Manager, Purchasing
- R. Coleman, Senior Monitor, Health-Safety E. Coppola, Manager, Quality and Safety
- D. Ferree, Manager, Fuel Operations
- K. Lester, Manager, Health Physics and Licensing
- G. Lindsey, Foreman, Health-Safety
- M. Moore, Assistant Facilities Engineer
- W. Nash, Project Coordinator i
- C, Speight, Manager Facilities and Services Other licensee employees contacted during this inspection included security force members, technicians, and administrative personnel.
- Attended exit interview 2.
OffsiteSupportAgencies(88050)
The inspector held discussions with a licensee representative regarding l
the coordination of emergency planning with offsite support groups, B&W 4
Naval Nuclear Fuel Division (NNFD), and B&W NNFD-Research Laboratory (NNFD-RL).
According to Section 8.2 of the RCP, agreements are reviewed every two years and updated if aecessary(.Current agreements had been j
executed with the Concud Rescue Squad September 8,1989), Lynchburg General Hospital (February 1 1989), and the Concord Volunteer Fire '
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Department (January 10, 1900). According to documentation, on December 5, l
1989, twelve members o' the Concord Volunteer Fire Department were l
provided a site familiarization tour in accordance with Section 7.2 of the RCP.
In view of the support role provided by Emergency Rescue Teams (EkTs) from NNFD and NNFD-RL, the inspector questioned a licensee representative regarding site familiarization tours for the aforementioned I
groups.
The inspector was informed.by the Manager, Health Physics and Licensing, that currently other groups (NNFD and NNFD-RL) are not included in an annual tour.
The inspector discussed as an improvement item the inclusion of both ERTs in a periodic site familiarization tour for training purposes.
The licensee acknowledged this item and indicated that periodically a site familiarization tour will be provided to members of both teams.
No violations or deviations were identified.
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EmergencyPlans, Procedures, Facilities,andEquipment(88050) a.
Radiological Contingency Plan (RCP) and Emergency Procedures (EPs)
The inspector reviewed documentation to verify that an annual review had been conducted of one RCP and tiFs in accordance with Section 7.1 of the RCP and Section 11.1 of Procedure AS-1106.
The current copy of the RCP was dated October 17, 1990, Revision 0.
The inspector noted that the proposed changes had been submitted for NRC review and approval.
A licensee representative informed the inspector that full implementation of the revised NRC emergency planning rules would occur within the - next 60-90 days.
The inspector revined the emergency action levels (EALs) in the RCP and emergency classification procedures (AS-1106 and AS-1141) for consistency and verification that the EPs adequately implemented the RCP classification scheme, b.
Facilities and Equipment Records of calibrations and/or surveillance performed during the period October 10, 1989 thru September 18, 1990 were reviewed for the emergency lockers, emergency power source, and respiratory protection equipment.
Inventories, calibrations, and/or operability checks were performed in accordance with procedures and the RCP.
Surveillance records indicated that, for discrepancies, corrective actions were prompt and properly documented.
One minor problem was noted involving the documentation for periodic surveillances, Documentation was not available to show a third-quarter audit (1990)
I of the emergency lighting), and documentation for the backup power supply (evacuation alarms was missing for the fourth quarter 1989 and third quarter 1990.
Personnel assigned the responsibility in thir area acknowledged the absence of documentation to verify the referenced surveillances. Consequently, a commitment was made by the licensee to develop and implement administrative controls to ensure that the appropriate documentation is available for periodic equipment audits and operability checks.
The inspector informed l
licensee representatives that the corrective actions to ensure proper recore are being ) maintained will-be tracked as an inspector Follow-up Item (IFI.
IFI 70-1201/90-06-01:
Development and implementation of administrative controls to ensure the appropriate documentation of surveillance activity and periodic audits.
The inspector selectively examined emergency kits and equipner,t from the Emergency Building and emergency lockers (radiation survey instruments, fire protection equi respiratory protection equipment)pment, air sampling equipment, and All survey instruments were within calibration and a successful battery check was obtained. The randomly selected items for inventory were available in quantities as specified on the equipment inventory sheets.
One item noted as an
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improvement item involved the performance of a periodic hydrostatic test of respiratory protection equipment.
During the surveillance, the inspector noted two self-contained breathing apparatus (SCBA) tanks which had not been recently tested.
When informed, the licensee took intnediate action to schedule all SCBA cylinders for hydrostatic testing during November 1990.
A review of the plant evacuation routes and assembly points found no impediments to an orderly evacuation. The audibility of the plant emergenc,v alarms was assessed by the licensee in several areas of the plant. Accotding to documentation, dated March 29, 1990, with the exception of a meeting room, no audibility 3roblems were noted. The licensee was evaluating this matter for speater placement within the conference room.
No violations or deviations were identified.
4.
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 and the implementing procedure (AS-1101. Employee Safety Training) for a description of the training program._
The inspector revieweJ training for the onsite Fire Brigade Team, Radiation Monitoring Team, First Aid Team, and other members of the onsite and offsite emergency organization.
Although documentation was'available-to show that training was being offered, there were several examples of-lack of documentation to verify that personnel attended the training.
According to Procedure M-1101, retraining sessions will be documented on an employee training attendance record and input to the employee computerized training record.
Contrary to procedural requirements, the inspector noted the following:
Employee training attendance records were lacking for Radiation t
Monitor Team (training scheduled for March 29,1990),'FirstAidTeam (scheduled for March 28,1990), and Fire Bri and during April and May 1990)gade (scheduled for March 29, 1990, The employee computerized training records had not been updated to reflect recent training.
The licensee took the following actions: 1) met with each training instructor or Team Captain to stress the importance of record keeping and procedural compliance, and 2) the training data base was updated with entries from recently completed training.
In light of the aforementioned I
actions, this apparent violation for failure to document specialized training in accordance with procedure is not being cited because criteria 4
specified in Section V.A. of the NRC's Enforcement. Policy were satisfied.
This finding is therefore considered a non-cited violation (NCV),
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NCV 70-1201/90-06-02:
Failure to document specialized training in accordance with Sections 6.2 and 6.3 of procedure AS-1101, " Employee Safety Training."
In accordance with Section 7.2 of the RCP, personnel assigned to the Emergency Rescue Team (Fire Brigade) and Radiation Monitoring Teams were medically certified for respirator use on an annual basis.
Documentation was available to verify that personnel had been recertified during the calendar year 1990.
However, the current respiratory protection training program does not specify a frequency for periodic refresher training, nor a requirement for First Aid personnel to be certified and trained for respirator use.
When informed of this matter, the licensee committed to the following:
- 1) revising the training program for Fire Brigade and Radiation Monitoring personnel to recuire annua 1 > respiratory protection training; and 2) evaluating the neer nit'ag First Aid Team members t
to be respirator-certified.
The iny,c' informed licensee representatives that the actions taken in response to this finding would be tracked as an IFl.
IFl 70-1201/90-06-03:
Review and revise as appropriate the respiratory protection training program for emergency response personnel.
Training was reviewed for other individuals assiored to the onsite RCR0 (Emergency Officer. Health-Safety Officer, Evacuation Officer, etc.).
t According to documentation, training was conducted via a table-top discussion regard'ng the respective roles and responsibilities in the RCRO.
In addition, personnel participated in a walkthrough drill on September 14, 1990, in response to a simulated fire.
On September 28, 1990, the RCR0 participated in a practice drill involving a simulated criticality acci dent.
The referenced RCR0 training since the last l
inspection indicated improvements in the licensee's emergency response training program.
Regarding offsite support training, as discussed in Paragraph 2 above, members of the Concord Volunteer Fire Department were provided a site l
familiarization tour and training during December 198P.
No other offsite support groups were included in calendar year.1989 training.
A licensee representative indicated that neighboring support personnel (NNFD/NNFD-RL) would be included in a future site familiarization / training session.
One NCV was identified.
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Organization and Management Control (88050)
A licensee. representative disclosed that the following administrative changes had occurred since the last inspection:
Due to retirement, the responsibility for RCP implementing procedure development, coordination with offsite support groups, training, and-day-to-day maintenance of emergency response equipment 'was reassigned.
The aforementioned responsibility was previously
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assigned to the Industrial Safety and Environmental Control Officer who retired during May 1990.
The Manager, Health Physics and Licensing, and Foreman, Health-Safety were assigned the referenced responsibilities.
As a result of an organizational change effective Octcher 17, 1990, emergency preparedness will report direwtly to the Plant Manager.
Previously, the management position with responsibility for emergency preparedness was the Manager, Quality and Safety. This position was deleted from the plant organization.
The individual filling this position (reassigned to the corporate office) was also designated as the Emergency Officer in the emergency organization.
The responsibility as Emergency Officer was reassigned to an individual who previously served as the Emergency Of ficer.
According to the former Manager. Quality and Safety, training and a turnover briefing for the newly designated Emergency Officer would be conducted on October 17, 1990.
The deletion of the Manager, Quality and Safety position from the plant organization resulted in the reassignment of programs involving quality (e.g. Inspection, Data Evaluation, etc.) to the corporate office; and programs involving safety (e.g. Industrial Safety. Health Physics and Licensing, etc.) were assigned directly to the Plant Manager.
Reassignment of Management Support functions (e.g. Field Operations, Purchasing, etc.) to the corporate office from the Plant.
The above changes would not appear to decrease the effectiveness of the emergency preparedness. program.
Personnel with the overall management authority for emergency preparedness remain unchanged.
No violations or deviations were identified.
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FireProtection(88050) 1 l
The inspector discussed this program area with a licensee representative-and reviewed appropriate documentation.
The. licensee's Fire Brigade Team is synonymous with the Emergency Rescue Team (ERT).
The ERT listing identified eight individuals as team members.
Since the last inspection, training sessions involving classroom instructions and hands-on training were scheduled as follows:
S-A-F-T Fire Fighting (April - Hay 1990) and EquipmentFamiliarizationDress-outProcedure(March 1990).
The inspector reviewed Procedure AS-1116 CNFP Fire Protection Equipment Control, for a description of the fire protection maintenance' program.
According to procedure, audits of the fire protection system involved weekly and/or monthly inspections of the fire extinguishers, sprinkler system, and fire valves.
On an annual basis, fire hydrants are inspected.
Audit records reviewed for the period October 1989 to September 1990 indicated that audits were conducted at the required frequency.
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included documentation to show that fire hoses and extinguishers were hydrostatically tested during the calendar years 1989 and 1990.
The inspector conducted a facility walkdown of selected areas within the main building and noted the following:
Fire alarm and radiation alcrm pull stations were co-located as shown on diagrams / figures in the RCP and EPs.
Portable fire extinguishers were available with tags indicating d te of inspection.
There were no impediments to randomly selected fire protection equipment (hose, fire cart, hydrants, etc.)
The inspector questioned licensee representatives regarding a facility fire fighting plan that identified the fire hazards of each plant area, the protective systems or equipment for each area, responsibilities, etc.
Licensee representatives informed the inspector that such a plan did not exist.
Recognizing the benefit of such a document, the licensee committed to the development of a facility fire fighting plan.
The inspector informed the licensee that this iten would be tracked as an IFI for review during a subsequent visit.
IFI 70-1201/90-06-04: Develop a facility fire fighting plan.
No violations or deviations were identified.
7.
TestsandDrills(88050)
This area was reviewed to determine if the licensee was conducting drills in accordance with Section 7.3 of the RCP.
The RCP required that a I
planned evacuation be conducted annually for CNFP personnel.
The RCP further stated that " Emergency drills (or a combined drill) of plant medical emergency and radiological monitoring capabilities will be held at least annually."
The annual evacuation drill was held on October 16, 1990, as part of the annual emergency drill.
The calendar year 1990 drill conducted on l
October 16, 1990, did not involve any of the State, local, or federal I
agency pa ticipation other than notification and communication.
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duration vf the drill was approximately 30 minutes.
The scenario required a response to a major fire from the S-1 Building.
One employee working inside the building was postulated as incurring burns on both hands and a head injury.
In addition, a member of the Fire Brigade Team was postulated as suffering a broken forearm.
Additional details regarding the scenario events are included in the attachment to this report.
The inspector observed the licensee's actions in the following areas:
RCR0 activation, staffing, and operation Facility evacuation and accountability
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l On-scene response by ERT, Radiation Monitoring Team, and the-Emergency Officer i
Communications between the incident scene-(Emergency Officer) and Emergency Control Center (Alternate Plant Manager)
Response to-the injured and slightly contaminated employee Notification methods and procedures had been established for NRC, State and local response organizations.
However, activities associated with offsite notification and communications were not observed by the-inspector.
The licensee provided documentation of the _ required offsite l
notifications which disclosed that the notifications were both timely and appropriate.
In discussing the conduct of the annual emergency exercise-with licensee representatives, the inspector noted,the many. simulations during the exercise in the absence of player messape and radiation data.
One area of simulation which previously has not be tested in real: time n ite support and could result in a false sense of preparedness involved o s
in responding to a fire which exceeds.the ERT capability.
' During.
discussions with-a licensee representative prior to the exercise, the inspector was informed that offsite fire support from the B&W NNFD would be requested for real-time activation-and deployment. However, according to a licensee contact, miscommunication resulted in a simulation rather than actual deployment.
The licensee acknowledged this item and committed to the performance of real-time notification and deployment of the.
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NNFD-ERT during a future drill.
The inspector informed the licensee that this item will be tracked as an IFI for review during a subsequent drill.
I IFI 70-1201/90-06-05:
Perform real-time notification, activation, and deployment of NNFD ERT.
The RCR0 was both prompt and effective in responding to the postulated accident.
The organization was activated and fully staffed in a timely vanner.
The facility evacuation was. timely and orderly.
The inspector dscussed the importance 'of varying the exercise starting time and improvements administratively to ensure that the confidentiality of the exercise starting time is maintained to prevent; the introduction of artificialities in facility evacuation time.
Communications-from the i
incident scene to the Plant Manager's Alternate was good.
The Emergency Off rer's command and control over the. emergency teams :(fire, radiation-monitoring, and first ~ aid) in managing the emergency was. apparent throughout the simulated accident.
Several minor problems were' discussed by the inspector _as items for improvement.
Dri11smanship, as evidenced - by inadequate ' surveys for alpha contamination'and the assumptions included in accountability reporting.
Poor health physics practices by a member of the first aid team.
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Excessive simulations by exercise participants due to lack of data / emergency messages.
The licensee's critique was held immediately after the exercise.
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Individuals serving as exercise players, controllers and/or evaluators were provided an opportunity for input. The licensee-demonstrated a very effective and critical self-assessment of the exercise.
Many of the items identified by the inspector were also noted by licensee personnel.
Included in the assessment discussions were corrective actions to resolve diterepancies.
When questioned regarding a formalized tracking program (log book or computerized data base) for exercise and drill findings, the inspector was informed that such a program did not exist.
The licensee-stated that, although a plant tracking system existed, exercise and drill-findings were not included.
The current practice was to assign items to an individual during the critique; however, a system for ensuring _ prompt follow-up had not been implemented.
The licensee committed to the use of the existing plant tracking system for tracking items identified during drills and exercises. ' The inspector indicated that the implementation of an exercirUdrill -commitment tracking program was considered an IFI for review dursr4 a subsequent inspection.
IFI 70-1201/90-06-06:
Implementation of exercise / drill commitment tracking.
Ne violations or deviations were identified.
8.
Event Follow-up (92701)
According to the documentation and a discussion with a member of the licensee's-staff, since th. last inspection, one incident. had occurred i
which required activatir" of emergency personnel..0n July 7. 1990, a l
truck transporting a fuel assembly shipment overturned on.lghway I-81 near Wytheville, VA. A review of the documentation disclosed that actions taken by the licensee were in accordance with procedures delineated in l
Section 7.2 of Procedure AS-1141, " Incident Procedure."
Although Form HS-100 (Highway Accident Notification. Questionnaire') was - not utilized, pertinent details including a chronology ofsevents were included l
in file documentation.
The inspector also noted a response critique was conducted on July 13, 1990.
Nine items were identified as requiring follor-up actions.
l No violations or deviat. ions were identified..
9.
Action on Previous Inspection Findings (92701) a.
(Closed)IFI 70-1201/89-08-01:
Evaluate the current training. program for the entire emergency organization and include upgrades to Section 7.2 of the RCP. '
Section 7.2 of ~the revised RCP (dated October 17,1990)'reflectedan annual requirement for officers of the Emergency Organization to
9 review the emergency procedures and their respective roles and responsibilities during an emergency.
b.
(Closed)IFI 70-1201/89-9-02:
Revise the RCP and Emergency-Procedure to include additional occurrences under the N00E-classification..
This item is closed by -virtue of the licensee's plans to submit a revised RCP within 60 days ~which incorporates the new planning rules as discussed in the Federal Register (Vol. 54, No. 66, dated April 7, 1989).
The referenced document allows licensees-to utilize an event classification system for classifying accidents as alerts or site area emergencies.
c.
(Closed)DEV 70-1201/89-08-03:
Failure to establish a formal annual-review and approval of the RCP.-
The requirement for performing an annual re"lew and the procedure for documentation were included in Section-11.0 of Procedure No. AS-1106,
" Emergency Procedure."
Further, as documentation that an-annual review was performed, by letter dated October 17, 1990, the licensee submitted chan under 10 CFR 70.32(1)ges to the NRC for review and approval
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(Closed)IFI 70-1201/89-08-04:
Complete the distribution of the RCP to appropriate State and local support agencies.
By letter dated October 11, 1990, the RCP was distributed to S_ tate and local authorities.
e.
(Closed) IFl 70-1201/89-08-05: Evaluate the appropriateness of the current RCP distribution-to onsite management personricl 'and adjust the distribution as needed.
A review of the RCP ' distribution matrix (Section '11.0 of 7tocedure l
No. AS-1106) disclosed that the licensee's review and evaluation 4
resulted in a revised distribution. listing since the last inspection, i
10.
Exit Interview The inspection scope and results were summarized on October 19, 1990, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in det;il the inspection results listed below.
The licensee did not idenMiy as proprietary any of the material provided to or reviewed by the inspector during this. inspection.
There were no dissenting comments.
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Item Number Description / Reference 70-1201/90-06-01 IFI - Develop and implement administrative controls to ensure the appropriate documentation of surveillance activity and periodic audits-(Paragraph 3).
NCV - Failure to document specialized training)in 70-1201/90-06-02 accordance with Procedure AS-1101 (Paragraph 4.
70-1201/90-06-03 IFI - Review and revise training program to require periodic respiratory protection refreshertraining(Paragraph 4.)
70-1201/90-06-04 IFI - Develop a facility fire fighting plan (Paragraph 6).
70-1201/90-06-05 IFI - Perform real time notification, activation, and deployment of NNFD ERT (Paragraph 7).
t 70-1201/90-06-06 IFI - Implementation of exercise / drill commitment tracking (Paragraph 7).
Licensee management was informed that five items from a previous inspection were reviewed and are considered closed (Paragraph 10).
Attachment:
Exercise Scenario l
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