ML20058J201
| ML20058J201 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 11/23/1993 |
| From: | Barr K, Gooden A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058J196 | List: |
| References | |
| 70-1151-93-08, 70-1151-93-8, NUDOCS 9312140003 | |
| Download: ML20058J201 (15) | |
Text
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UNUED STATES
/*g nog'g, NUCLEAR REGULATORY COMMISSION
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.p4 REGloN il 101 MARIETTA STREET, N.W., SulTE 2930 r,
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Report No.:
70-1151/93-08 Licensee: Westinghouse Electric Corporation Commercial Nuclear Fuel Division (CNFD)
Columbia, SC 29250 Docket No.:
70-1151 License No.:
SNM-1107 Facility Name: Westinghouse Electric Corporation Inspection Conducted: October 25-29, 1993 Inspector:
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//- 2. 3-13 A. Gooden Date Signed Accompanying Personnel:
W. Gloersen G. Kuzo
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Approved By:
K. BarV, Chief
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Date Signel Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch Division Of Rrdiation Safety and Safeguards
SUMMARY
Scope:
This routine, announced inspection was conducted to assess the operational readiness of the licensee's emergency preparedness program, evaluate the biennial emergency response drill, and evaluate the adequacy of corrective actions taken by the licensee in response to the Operational Safety Assessment Team findings. Program readiness areas reviewed included maintenance of select equipment used in emergency response; emergency response training (onsite and offsite support); program changes since the last inspection; and licensee actions in response to select NRC Information Notices issued since the last inspection.
Results:
Within the areas reviewed, one violation in addition to a non-cited violation were identified:
A non-cited violation for failure to fcilow Procedure RA-304 governing the periodic test of the criticality accident alarm system -
(Paragraph 3).
9312140003 931126 PDR ADOCK 07001151 C
m A violation for failure to train members of the Emergency Brigade in acccedance with Section 7.2 of the Plan and Section 7.2 of Procedure CSEP-0015 (Paragraph 4).
No deviations, or exercise weaknesses were identified. The licensee's exercise l
was considered fully successful in the demonstration of an adequate response capability to protect the health and safety of plant personnel and the general public. The licensee had taken corrective actions to resolve previous-concerns identified by the Operational Safety Assessment Team as program weaknesses.
Several items were identified as Inspector Follow-up Items (IFIs) or discussed with the licensee for consideration as improvement items.
Positive aspects of the licensee's program included the following:
i Good command and control by the Emergency Coordinator / Emergency Director Demonstration of drillsmanship by plant staff during facility evacuation Good interface between the on-scene assessment personnel and the licensee's Emergency Operations Control Center Strong commitment to training as evidenced by the performance of drills in excess of the number and type required by the Emergency Plan (10 drills conducted during the period March 17 - October 13,1993)
The licensee initir.'..
- ctions to address the violations above regarding training and periu, surveillance (discussed in Paragraphs 3 and 4).
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_.sm ea REPORT DETAILS 1.
Persons Contacted Licensee Employees K. Bartsch, Regulatory Engineering B. Dougherty, Coordinator, Staffing Services J. Fici, Plant Manager f
R. Fischer, Senior Engineer, Regulatory Engineering W. Goodwin, Manager, Regulatory Affairs J. Heath, Manager, Regulatory Operations R. Hicks, Mechanic, Maintenance J. Hooper, Engineer, Regulatory Engineering R. Jacobs, Supervisor,. Conversion E. Keelen, Manager, Manufacturing G. LaBruyere, Manager, Conversion Services S. Mcdonald, Manager, Technical Services J. Nay, Principal Engineer, Plant Systems Engineering D. Precht, Manager, Materials, Planning and Services E. Reitler, Manager, Regulatory Engineering M. Ruhl, Supervisor, Maintenance D. Trevett, Manager, Component Services B. Ward, Manager, Uranium Recycle and Recovery C. Yoder, Technician, Regulatory Operations Other licensee employeer contacted during this inspection included engineers, technicians, administrative, and security personnel.
Other Organizations l
A. Graves, Lieutenant, Wackenhut Security S. Threatt, Manager, Radiological Emergency Planning, South Carolina Department Of Health and Environmental Control Attended Exit Interview An index of abbreviations used throughout this report will be found in j
the last paragraph.
2.
Emergency Plan and Implementing Procedures (88050)
-The review, approval, and distribution of Plan changes was examined to determine whether significant changes were made in the licensee's 1
program since the OSAT inspection (August 1992), to assess the impact of
. j any program changes on the overall state of emergency preparedness at-i the facility, and determine if the Plan and procedures were revised to reflect those changes. Requirements applicable to this area are found in 10 CFR 70.22 (i) and Section 7.0 of the Emergency Plan.
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2 Since the last inspection, the Westinghouse Columbia Site Emergency Plan i
referred to as SEP, and the Plan implementing procedures (CSEPs) had been revised. The Plan revision in effect at the time of the inspection was Revision 4, dated April 30, 1993. In accordance with the SEP, the licensee provided offsite agencies a copy of Revision 4 to the SEP via letter dated May 19, 1993, and requested they review and provide i
comments prior to NRC submittal. Documentation reviewed by the inspector disclosed the offsite response organizations had no comments. According to licensee documentation, the effective date for Revision 4 to the SEP was September 30, 1993. The referenced document was sent to NRC by letter dated October 8, 1993. The significant changes made in the aforementioned revision included:
Criteria was added for relocating the primary EOCC to an alternate location in the event the primary became uninhabitable.
The frequency for renewal of agreement letters with offsite support groups was changed from two years to every four years for consistency with Regulatory Guide 3.67.
Organization' charts were revised to reflect changes in titles and the reporting chain for the normal organization.
Section 3 of the SEP was revised to include a section entitled
" Transportation Emergency" to address issues identified in NRC i
A requirement was added to notify the NRC immediately after the State notification, but not to exceed one hour following declaration of an Alert or Site Area Emergency.
i The inspector's selective review of changes did not identify any i
decrease in the effectiveness of the SEP or CSEP. (Note: The NRC's formal review would occur via a license review resulting in separate correspondence.) The inspector's review of the licensee's dose projection procedure (Procedure CSEP-0017-A) disclosed that Figures 1 and 2, containing curves as a function of post accident release times, were not easily read. Due to print characteristics, procedure user may j
experience difficulty in discerning the appropriate curve for 4-30 days i
and 8-24 hours. This matter was discussed with the licensee for consideration as an improvement item.
The inspector reviewed the status of agreement letters with offsite i
support agencies (Appendix A of the SEP) and determined that agreements were current and up to date. To ensure that control copies of the SEP and CSEP were maintained current and up to date, the inspector examined copies at various locations and no problems were noted. The SEP and selected CSEPs were current-revisions.
i Section 7.7 of the SEP states that quarterly communications will be performed to verify and update all necessary telephone numbers. The emergency notification telephone numbers for onsite and/or offsite
3 contacts are located in CSEP-0013 entitled " Emergency Notification of Onsite and Offsite Organizations." The inspector discussed with a licensee contact the licen_ee's procedure for periodic communication check and update of the aforementioned numbers. According to.the licensee contact, checks are performed and the appropriate sections of CSEP-0013 are revised if needed to reflect the updates. The current document was Revision 4 dated April 30, 1993. However, when questioned by the inspector regarding previous revisions and documentation to show quarterly verification (October 1992 to October 1993), the licensee contact indicated that formal records (e.g. superseded roster) were not maintained to show that a quarterly review was performed. In response, the inspector discussed with the licensee for consideration as an improvement item, that formal documentation of quarterly checks be available for review as verification that the commitment in Section 7.7 of the SEP was met.
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No violations or deviations were identified.
3.
Emergency Facilities and Equipment (88050)
Facilities and equipment were inspected to determine whether the licensee's EOCC, emergency response equipment, instrumentation, and supplies were maintained in a state of operational readiness, and to assess the impact of any changes on the emergency preparedness program.
l Requirements applicable to this area are found in Sections 6 and 7 of l
the SEP and various plant procedures.
Select records of calibrations and/or surveillance performed during the period December 1992 to October 1993 were reviewed for the health physics emergency cabinets, emergency power source, backup communications (cellular telephone), two-way radios, criticality alarms, and the portable meteorological system. With the exception of the criticality alarm system (CAS) testing, inventories, calibrations, and/or operability checks were performed in accordance with procedures and the SEP. Regarding CAS, personnel failed to follow Procedure RA-304 which assigns responsibility for the operation and maintenance of the Columbia Plant CAS. Section 5.0 of RA-304 required the licensee to test i
the alarm system a minimum of once per month. Section 6.0 of RA-304 required that alarm testing and audibility verification be conducted and i
documented on Forms RA-304-3 and RA-304-4. Contrary to the aforementioned procedural requirements, when questioned by the inspector to provide documentation as verification of CAS testing for the period October 1992 to October 1993, the licensee contact could_only provide data for verification of system testing for the period May 27, 1993 to September 30, 1993.
No other data was available to reflect system activation or audibility testing and verification. Licensee personnel indicated in interviews that the CAS was being tested.-Consequently, the
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licensee was informed that the aforementioned item was considered a violation for failure to document the CAS testing in accordance with j
Procedure RA-304, Criticality Accident Alarm System. The inspector was informed that the reassignment of responsibility in certain areas within j
the Regulatory Affairs Department resulted in the lack of data due to i
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4 personnel oversight. The licensee contact stated that future tests will be documented as required. Actions were.taken by the licensee to assign a member of the Radiation Protection staff responsibility for verification and documentation of test results. Subsequent to the exit interview, personnel were briefed on the requirements of Procedure RA-304. In light of the aforementioned actions, this NRC identified violation.is not being cited because criteria specified in Section VII.B of the NRC Enforcement Policy were satisfied. The licensee was informed that this finding was considered a NCV.
1 NCV 70-1151/93-08-01: Failure to follow Procedure RA-304 governing j
operation and maintenance of the criticality accident alarm system.
The inspector verified via inventory and operability checks that equipment, supplies, and instrumentation stored in emergency cabinets were not only operational but adequate inventories were available for
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response personnel. Radiation survey instruments responded properly to both battery and radioactive source checks. The licensee's computerized system for performing site accountability (referred to as COMET) was observed and noted as operational and effective in achieving timely j
accountability.
The licensee's emergency power supply includes four diesel generators.
l The inspector reviewed the maintenance and test program which was tracked by the plant-wide Maintenance Planning and Control System (referred to as MAPCON). The referenced system is a computerized, menu driven system for tracking periouic equipment maintenance and testing.
The inspector requested documentation to show diesel generator #3 was being tested in accordance with procedural requirements. According to a l
computer generated printout, testing was performed at the required intervals. As further verification, the inspector reviewed the hardcopy documentation to reflect weekly tests that were performed during October 1993.
Based on the records reviewed, interviews, and facility walkdown, the j
inspector determined that the licensee generally was maintaining equipment in a state of readiness. Two items were discussed with the licensee for consideration as program improvement items:
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't Change the frequency for performing an operability check on the i
portable meteorological system from annually to a minimum of semi-i annually.
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Modify Procedure RA-208 " Chemical Area Hazard Warning System" to include periodic test and visual verification that emergency l
lights are operational (indicates and rotate).
j One additional aspect of the licensee's program discussed in a previous report (70-1151/92-08) involved the adequacy of the plant notification system (fire alarm / voice communication). Although progress had been made (see details in Paragraph 7), continued action is necessary by the licensee for resolution. The current timetable (dated October 28,1993)
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5 projects a completion date of June 1994 for upgrades. Therefore, the adequacy of the licensee's plant notification system require Region II followup during subsequent inspections and is discussed as an IFI in Paragraph 7.
f One NCV was identified.
4.
Training (88050)
Emergency response training was reviewed to determine if the licensee was providirg training in accordance with the SEP. The requirements for training are found in Section 7.2 of tha SEP.
Since the last inspection, the licensee had implemented a system of training for the emergency response organization referred to as
" performance-based training." The aforementioned training was implemented in accordance with licensee commitments to NRC in response to Inspection Report 70-1151/92-04 issued by the OSAT. According to a i
member of the licensee's staff, the performance-based training is associated with the following concepts: needs analysis, program development, implementation, and evaluation. The training program involved formal class room instructions, a self-study exam composed of 26 questions, and eleven drills were condu::ted during the period March 17, 1993 to October 21, 1993. The inspector reviewed the training outline for Emergency Directors and Emergency Coordinators training.
i Areas covered included types of accidents and classification system; responsibilities; transportation accident; notification requirements; and recent changes to the SEP and CSEPs. Onsite training was reviewed for the following positions or areas of responsibility: Emergency l
Coordinator, Emergency Director, Security, and Emergency Brigade. The inspector requested training documentation for randomly selected personnel listed on the security staff roster, emergency notification roster (CSEP-0013, dated April 30,1993), and the Emergency Brigade Roster (dated October 14,1993). Based on the review of documentation and interviews with personnel assigned the responsibility for training and/or tracking training, with one exception, training for response personnel was current t.nd up to date. The exception involved personnel assigned to the Emergency Brigade Team. The inspector's review of the referenced training disclosed the following:
Two individuals assigned to the Emergency Brigade had not received i
and passed a respiratory physical examination since July 1992.
Under requirements for membership, Section 7.2.2 of Procedure CSEP-0015 (Emergency Brigade Organization), members must pass a physical exam given annually.
Two individuals had not participated in drills during the calendar year, and documentation was not available to indicate the personnel received a briefing regarding their specific duties and I
role during an emergency as a member of the Brigade. Section 7.3.2 of Procedure CSEP-0015, states that " Brigade members should attend all scheduled training sessions each calendar year and shall
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6 attend the training conducted by the South Carolina Fire Academy.
Further, Section 7.2.4 of the SEP delineated the minimum training i
requirements for Brigade members. However, the licensee was unable j
to provide documentation to show that the individuals had i
satisfied the minimum requirements for Brigade members.
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The above examples indicated that personnel were being assigned to the Emergency Brigade roster as Emergency Brigade members prior to attainment of training in accordance with Section 7.2.4 of the Plan, which stated that "an Emergency Brigade member must attend at least 75 percent of the training annually to remain qualified."
In response to the above finding, the licensee took immediate action prior to the exit to provide a respiratory physical to one of two individuals identified; in addition, the licensee contacts for Brigade training discussed establishing a roster which would represent the official list of Emergency Brigade members and their current status to perform Brigade functions. The aforementioned list would be provided to Emergency Coordinators and Emergency Brigade Chiefs so that the assignment of Brigade functions during an emergency would be consistent with Brigade training.
i A similar violation was identified involving the Emergency Brigade training during an October 1991 inspection (see Inspection Report 70-1151/91-05). In response, the licensee indicated that actions to prevent recurrence would include:
j An emergency training record tracking form to audit applicable records. The referenced form would be used to assure that if an individual does not attend a prescribed training (or makeup) t session, the individual would be immediately disqualified from the i
emergency organization pending required training.
Use of the formal Regulatory Affairs Commitment Tracking System to control the above training record tracking form.
Contrary to above, actions to prevent recurrence in response to violation 70-1151/91-05-01, the two examples noted during the recent inspection indicates failure to implement effective corrective action i
for the previous violation; or the previous corrective action was inadequate to prevent the violation discussed above. Consequently, this matter is considered a repeat violation for failure to provide Emergency Brigade members training in accordance with Section 7.2 of the SEP.
i Violation 70-1151/93-08-02: Failure to provide Emergency Brigade training in accordance with Section 7.2 of the SEP.
Regarding offsite agency training, by letter dated September 7, 1993, offsite agencies identified in Appendix A were invited to attend a briefing and training session on September 20, 1993. Topics included a review of the updated SEP, past emergency preparedness interactions, and a discussion of basic radiological safety issues at the Westinghouse 1
facility. The length of training session was one hour. Attendees i
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included representatives from Richland County Emergency Medical Services, South Carolina Department of Health and Environmental Control, South Carolina Emergency Preparedness Division, and Columbia Fire Department.
With the exception of the violation noted above, the training program for emergency response personnel was considered a program strength.
Both the quantity and quality of drills conducted by the licensee far exceeded any regulatory basis or Plan commitment. The results of the program ennancement in this area were demonstrated by the prompt and effective response on the part of the emergency organization to the i
postulated accident (see Paragraph 5).
One violation was identified.
5.
Emergency Response Drill (88050)
Section 7.4 of the SEP required a biennial onsite exercise to test the response to simulated emergencies. The last biennial exercise was conducted on October 24, 1991, and participants included the City of l
Columbia Fire Department, Richland County Emergency Medical Services, and Richland Memorial Hospital.
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The 1993 exercise was conducted on October 28, 1993, and postulated a criticality accident. The criticality occurred as moderating materials j
were being added to one of the MAP blenders. The scenario required response to a medically injured, and contaminated victim by onsite medical personnel and the offsite emergency medical services transport agency. The drill lasted approximately one hour and twenty minutes.
Licensee actions were observed in the following areas:
On-scene coordination by the Emergency Coordinator.
j On-scene respcnse by Emergency Brigade and Health Physics i
personnel.
EOCC operations.
Response by medical and rescue personnel to the injured and i
contaminated victim.
Offsite notifications.
l Facility evacuation and personnel accountability.
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The inspector observed that notification methods and procedures had been established for onsite and offsite organizations and were discussed in Section 4.3 of the SEP. Activities involving notification were implemented via CSEP-0013, " Emergency Notification of On-site and Off-site Organizations." The notification to State authorities (5 minutes) and NRC (7 minutes) were completed in a very timely manner.
The inspector's review of the notification form (Attachment CSEP-0013-A)
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disclosed certain details were eith'er lacking or insufficient in details (e.g. no information regarding plant status, incomplete description of i
personnel injuries, and single form used for notification to SCDHEC and NRC irrespective of the notification time differences). This matter was discussed with the licensee as an area for cunsideration as an improvement item. Although initial communications with SCDHEC were timely, SCDHEC was unable to contact the E0CC for followup and additional information once the main guard station was evacuated. Due to radiation levels in the vicinity of the main guard station, personnel were required to evacuate. Just prior.to evacuating the main guard station, telephone switchboard responsibility was transferred from the main guard station to the truck guard gate. An EOCC phone extension was not provided to offsite authorities during the initial notification for obtaining additional details, and personnel manning the truck gurd gate -
delayed transferring the switchboard responsibility back to the main guard station. Consequently, SCDHEC was unsuccessful in obtaining details for accident assessment. In response to this matter, the licensee discussed providing a plant extension during the initial notification, revising the checklist for security guard regarding phone transfer, and evaluating the need for providing a dedicated line for communications with SCDHEC. The licensee was informed that actions in this area would be tracked as an IFI.
IFI 70-1151/93-08-03: Verify communications capability for offsite authorities in the event of a facility evacuation.
An inspector evaluating activity at the incident command post and the south assembly area observed the following:
Two examples were noted of inadequate processing and bdling for SRPDs. SRPDs were not read prior to issuance; ar.d following plant entry, SRPDs for health physics personnel were immediately processed fur exposure whereas dosimetry for Fire Brigade members -
was delayed.
Health physics personnel di_d not fully implement Procedure CSEP-l 005-A for documenting survey results and exposure information.
Rather than using data sheets and/or figures (e.g. site map, facility layout, etc.), documentation was made to procedure margins, or included in the details to procedure text..Therefore, plume tracking or plotting' of rad data by health physics personnel 4
at the incident command post was lacking. However, personnel in the E0CC were noted plotting data on Figure 5.1 of-CSEP-005-A (site map) to aid in the development of protective actions.
The licensee was informed that the actions by health physics personnel l
involving the issuance of dosimetry and documentation of survey results would be reviewed during a subsequent inspection and was considered an IFI.
-l IFI 70-1151/93-08-04: Review the adequacy of health physics activity in the arcas of personnel dosimetry and documentation of survey results.
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9 The licensee and NRC observers evaluating the medical response and response to the missing person noted the following:
Delay of approximately 15 minutes before onsite medical personnel provided medical attention to criticality victim.
Delayed response by r 7 site emergency medical services transport vehicle due to lack oi notification.
In response to the above delays, the licensee considered the medical response as inadequate and issued a CTS item for taking corrective actions. The licensee was informed that the licensee's actions in this area would be tracked as an IFI.
IFI 70-1151/93-08-05: Review licensee actions resulting from medical response delays.
In addition to the above, the inspector noted that Emergency Teams received little or no details prior to plant entry regarding expected rad conditions, team task, travel routes, equipment needs, etc. This was evidenced by rescue personnel who responded to the missing person report without equipment or a mechanism (stretcher, blanket) for transporting the potentially injured victim. Consequently, the inspector discussed with the licensee for consideration as an improvement item that Emergency Team personnel (Emergency Brigade / Survey Team) be briefed regarding their mission, incident conditions, hazards, and possible equipment needs.
The licensee's accident assessment program was considered effective in view of the prompt deployment of survey personnel and verification of the criticality accident. The event classification was both timely and correct. Approximately 20 minutes following activation of the CAS, the Site Area Emergency was declared. One aspect of the licensee's assessment discussed by the inspector as an IFI involved the lack of consideration and discussion regarding meteorological conditions. During i
the event evolution, meteorological conditions were not discussed between the E0CC and tie incident. command post for consideration in the overall assessment and relocation of assembly areas.
In the event the release involved Uranium Hexafluoride, the lack of meteorological considerations may have resulted in unnecessary exposure. The licensee was informed that the licensee's actions in this area would be tracked-as an IFI.
IFl 70-1151/93-08-06: Verify use of meteorological conditions in accident assessment and protective action decisions.
One press release was prepared for issuance. Previous comments'regarding improvements in this area had been considered by the licensee. However, the inspector noted that the release was not completed in a timely manner due to required editorials for accuracy. The final version was reviewed for approval by the Emergency Director 13 minutes after the drill was terminated. As a result, the inspector discussed with the
a 10 licensee as corrective action the development of standard press releases for various postulated accidents and incorporate into a CSEP addressing press releases. The Plant Manager discussed plans to implement the aforementioned actions. The licensee was informed that the development of standard press releases would be tracked as an IFI and reviewed during a subsequent inspection.
IFI 70-1151/93-08-07:
Develop and implement standard press releases.
During the exercise, several minor inconsistencies were noted; however, these inconsistencies did not detract from the overall performance of the licensee's emergency organization. The licensee's critique was detailed and identified similar findings as the NRC evaluators.
According to a member of the licensee's staff, those items identified by licensee evaluators / controllers during the critique as requiring corrective actions would be assigned a CTS No. for followup.
No violations or deviations were identified.
6.
NRC Information Notices IN 92-14 " Uranium 0xide Fires At Fuel Cycle Facilities" The inspector reviewed documentation to show that the IN was i
received and distributed to various staff for evaluation and implementation of appropriate actions. Areas evaluated included storage requirements, equipment maintenance, fire protection measures, etc. Although actions were not complete at this time, actions deemed appropriate by the licensee was scheduled.
IN 93-07 " Classification of Transportation Emergencies" The licensee actions in response to the aforementioned IN included modification to the SEP to include Section 3.1.4 entitled
" Transportation Emergency." Delineated in the SEP are actions to initiate as a result of a transportation incident.
7.
Licensee Action on Previous Inspection Findings j
a.
(Closed) URI 70-1151/92-04-35:
LRI-The SEP did not contain various provisions and/or information including preplanned initial 3
protective action recommendations, a summary of stack heights, and i
provisions for an annual independent audit.
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The inspector's review of the licensee's revised SEP dated April 30, 1993, and review of select CSEPs disclosed that with one exception, the licensee had completed actions to incorporate i
guidance from Reg Guide 3.67. The one exception was a SEP commitment to conduct an annual independent audit. A member of the licensee's staff provided for review Procedure RA-106 addressing internal audits. However, a detailed review disclosed the procedure did not adequately address an independent audit of the 1
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s 11 emergency preparedness program in that no frequency for conducting the audit was included. Consequently, the licensee contact with emergency planning responsibility committed to include in Section 7.5 of the SEP, a requirement for conducting an annual independent audit as discussed in Regulatory Guide 3.67. The inspector informed the licensee that item 92-04-35 would be closed and a new item opened as a result of actions taken, and the commitment for an annual independent audit be added to the SEP.
(0 pen) IFI 70-1151/93-08-08:
Revise the SEP to reflect an annual independent audit of the emergency preparedaess program.
b.
(Closed) URI 70-1151/92-04-37:
PWI-Inadequate annual retraining for Emergency Directors and Emergency Coordinators.
Training incorporating table-top drills, classroom training, and hands-on responses were conducted in accordance with the licensee's response (letter dated January 29, 1993) to NRC Inspection Report No. 70-1151/92-04. See additional description regarding enhancements to this program area discussed in Paragraph 4.
c.
(Closed) URI 70-1151/92-04-38:
PWI-Inadequate procedure for l
Procedure RA-107 which does not give adequate directions to Emergency Coordinators on when to make different types of notifications following emergencies.
The procedure was revised in accordance with the licensee's response (letter dated January 29,1993) to NRC Inspection Report No. 70-1151/92-04. The inspector's review of Procedure RA-107 (Rev. 5, dated September 30,1993), entitled " Internal Reporting, and NRC Notification of Unusual Occurrences," disclosed several references provided to procedure user regarding conculting the SEP and/or CSEP for possible event declaration and activation of Plan.
d.
(Closed) IFI 70-1151/92-08-01:
Review the plant notification system and the communications equipment for use in protective clothing.
l The inspector interviewed members of the licensee's staff with l
responsibility in the aforementioned areas. In response to voice communications for Brigade members outfitted with " level A" suits, the inspector noted that the licensee had procured voice activated devices for use in level A suits to enhance communications. The licensee's actions in response to the recurring problems associated with the plant notification system had not been completed. However, several aspects of the system review and i
upgrade had been completed. For example, documentation and a discussion with the System Engineer disclosed the following:
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system documentation had been updated to reflect the as-built status of the system; a variety of wiring problems were discovered
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and corrected; development and implementation of formal and -
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.i 12 documented preventive maintenance checks; adding and adjusting
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speakers to assure complete coverage of all areas of the plant in dissemination of information during non-fire emergencies; and other upgrades associated with fire protection program (e.g.
installation of additional detectors, updating and modernizing alarm legends, etc.). According to the licensee contact, all work involving the system epgrade is scheduled for completion by June IS94. As a result, the previous open item-is closed and a new item
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is opened to verify upgrades to the fire alarm system for ensuring i
audibility of alarms and clarity of voice messages during i
emergencies. The licensee was informed that this item would be tracked as an IFI.
j (0 pen) IFI 70-1151/93-08-09: Verify upgrades to plant i
notification system for fire and non-fire emergencies.
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Exit Interview The inspection scope and results were summarized on October 29, 1993, with those persons indicated in Paragraph 1. The inspector discussed the t
areas assessed and the exercise results in detail. The inspection results are listed below. Dissenting comments were not received from the i
licensee. Proprietary information is not contained in this report.
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Subsequent to the exit interview (November 15, 1993), the inspector contacted the Manager of Regulatory Engineering telephonically to l
discuss a potential repeat violation (described in Paragraph 4). The i
inspector discussed with members of the licensee's staff the training tracking system for Emergency Brigade members and the process of i
disqualification. In addition, documentation to illustrate the l
disqualification process was provided to the inspector for review. Based i
on the review and discussion with regional management, on November 17, 1993, the inspector informed the Manager of Regulatory Engineering that the finding was considered a repeat violation.
i Item Number Descriotion/ Reference 70-1151/93-08-01 NCV - Failure to follow Procedure RA-304 governing operation and maintenance of the CAS (Paragraph 3).
70-1151/93-08-02 VIO - Failure to provide Emergency Brigade training in accordance with Section 7.2 of the SEP and Section 7.2.2 of Procedure CSEP-0015 t
(Paragraph 4).
70-1151/93-08-03 IFI - Verify communications capability for offsite authorities in the event of a facility evacuation (Paragraph 5).
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13 70-1I51/93-08-04 IFI - Review the adequacy of health physics l
activity in the areas of personnel dosimetry _and i
documentation of survey results (Paragraph 5).
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70-1151/93-08-05 Irl - Review licensee actions resulting from medical response delays (Paragraph 5).
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70-1151/93-08-06 IFI - Verify use of meteorological conditions in
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accident assessment and protective actions decisions (Paragraph 5).
70-1151/93-08-07 IFI - Develop and implement standard press releases (Paragraph 5).
70-1151/93-08-08 IFI - Revise the SEP to reflect an annual independent audit of the emergency preparedness program (Paragraph 7).
70-1151/93-08-09 IFI - Verify upgrades to plant notification system for fire and non-fire emergencies (Paragraph 7).
Licensee management was informed that four open items from a previous inspection were reviewed and are considered closed (Paragraph 7).
f 9.
Index of Abbreviations Used In This Report CAS Criticality Alarm System COMET Columbia Onsite Monitoring and Emergency Tracking System i
CSEP Westinghouse Columbia Site Emergency Procedures CTS Commitment Tracking System E0CC Emergency Operations Control Center IFI Inspector Followup Item IN Information Notice LRI License Renewal Issue MAPCON Maintenance Planning and Control System NCV Non-cited Violation OSAT Operational Safety Assessment Team i
PWI Program Weakness Item j
RA Regulatory Affairs Rev.
Revision SCDHEC South Carolina Department of Health and Environmental Control i
SEP Westinghouse Columbia Site Emergency Plan SRPD Self-Reading Pocket Dosimeter URI Unresolved Item VIO Violation
Attachment:
Scenario and Exercise Objectives
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