ML20196C512

Insp Rept 70-1151/88-15 on 881027-28.No Violations or Deviations Noted.Major Areas Inspected:Licensee Annual Radiological Emergency Drill on 881027

ML20196C512
Person / Time
Site:	Westinghouse
Issue date:	11/22/1988
From:	Kreh J, Rankin W, Testa E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20196C509	List: ML20196C503 ML20196C512
References
70-1151-88-15, NUDOCS 8812080028
Download: ML20196C512 (4)

Text

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• 5"* 4 % l C* '. UNITED STATES

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'" j NUCLEAR REGULATORY COMMISSION R E GIO N il 101 MARitTTA ST., N W.

%,, e', , , e *[ ATLANTA OtomotA 30323 Il0V 2 21998 Report No.: 70-1151/88-15 l, Licensee: Westinghouse Electric Corporation Comercial Nuclear Fuel Division Columbia, SC 29150 1 Docket No.: 70-1151 License No.: SNM-1107 Facility Name: Westinghouse Electric Corporation ,

Columbia Plant t

inspection Condu ted: 0.tober c 27-28, 1988 i Inspectors: , AO e to t - _

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'L , Kreh Date Signtd I

&* e kr fd ///b A )3W Date Sighed i

E. D. Testa [

Approved by: 644.M. ///83/8f f W. H. Rankin,~ Acting Section Chief Date Siged  !

Division of Radiation Safety and Safeguards [

SUPMARY  ;

Scope: This special, announced inspection was conducted to observe and evaluate  ;

the licensee's annual radiological emergency drill, held on October 27, 1988. (

The drill comenced at 5:00 p.m. and terminated at 6:20 p.m..  ;

Results: In the area inspected, no violations or deviations were identified.

However, a Program Weakness was identified involving the Itcensee's failure to  ;

conduct the annual plant drill in a manner that would adequately test the ability to implement the Site Emergtacy Plan, j f

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8912000020 881122 i

PDR ADOCK 07001151 1 C PNU I

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'i.m REPORT DETAILS r r

1. Licensee Employees Contacted

• J. Allen, Manager, Technical Services  !

1. • R. Fischer, Senior Engineer (Site Emergency Plan Coordinatsr) [

1. • W. Goodwin, Manager, Regulatory Affairs

'J. Heath, Manager, Regulatory Operations [

• E. Keelen, Manager, Manuf acturing i

1. • P. l.och, Plant Manager f*E. Reitler, Manager, Regulatory Engineering ,

• C, Sanders, Manager, Nuclear Materials Management and Process Records

• E. Steck, Manager, Conversion  ;

• Attended ed t interview on October 28, 1988

1. Participat - in the telephonic exit interview on November 4, 1988

2. Radiological Emergency Response Drill (88050)

The licensee is required by Section 7.3 of the Site Emergency Plan to conduct an annual announced radiological emergency drill, to include the active participation of offsite support groups, for the purposes of (1) testing the adequacy of the timing and content of the energency procedures, (2) testing emergency equipment, (3) keeping personnel aware of their emergency responsibilities (4) testing communications etworks, and (S) integrating the emergency organization into action. The drill conducted on October 27, 1988 was intended by the licensee to fulfill this requirement.

The inspectors observed various aspects of the drill, including management and control of the simulated accident by the Emergency Director and his staff, notifications and connunications, evacuation and monitoring of pl ant personnel following the simulated criticality, handling and treatm;nt of a simulated victim at the plant and later at the hospital, and radistion protection practices. Several negative findings by the inspectors were independently identified by licensee evaluators (see Parsgraph S). One problem not identified by the licensee was the absence of Health Physics coverage of the Emergency Operations Center (E0C).

Following a major radiation accident, the licensee would need to perform and docutrent contanination surveys, area radiation monitoring, and air sairpling to assure the habitability of any occupied area inside or near the plant. The only habitability check perfomed at the EOC during the drill consisted of area radiation readings taken as the facility was being activated. Licensee representatives agreed that corrective action to address this finding was int.rder.

Inspector Follow-up Iten (!FI) 70-1151/88-10-01: Develorrent of a procedure which delineates how radiological habitabllity of the EOC will be routinely renitored and documented while that facility is activated.

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In discussing the emergency response training program with licensee j representatives prior to the drill, the inspectors identified what  !

appeared to be a fundamental misconception on the part of the licensee  !

regarding the con 6uct of the annual emergency drill. The licensee did not i use a scenario that was held in confidence from the drill "players". In i fact, a handout provided to members of the emergency organization during i predrill training (conducted on October 17, 1988) included the actual scenario to be used for the drill. The scenario and the various players' The anticipated ro'es were referenced hanjout alsodiscussed and "rehearsed" offered applicable during emergency the trainingor(.

procedures portions thereof) for use by players during the drill, in discussions with licensee management representatives before and af ter  !

the drill, the inspectors attempted to delineate the reasons why the NRC considered the licensee's mode of operatier, as described above, to be an i unacceptable approach to conducting the required annual emergency drill, f in order to fairly and properly test the content and adequacy of the  !

emergency program and procedures, the players must not have advance  !

knowledge of the scenario to be used for the drill. For reasons of  !

operational safety and continuity, it is acceptable practice (required, in this uase, by the license) to universally announce the date and time of f the drill. Beyond this, however, the drill players should not be i knowledgeable of specific cenditier,3 or developments expected during the t simulated accident, consistent with what would occur in an actual accident situation. In addition, players must not be provided with materials intended to facilitate their responses, such as epplicable procedures and [

completed notification forms. Selection of appropriate emergency L procedures and coepletion of relevant forms should be "real-time" d *:11 I activities. I i

Based on these findings and a discussion with licensee management NRC  !

Regional management detemined that the licensee's concept of drill I operations appeared to result from a misunderstanding on the part of the l Itcensee, combined with an absence of explicit hRC guidance regarding the

! conduct of required drills. During a telephone cenference on November 4 I t

1988, between licensee and NRC management representatives, the licensee made a commitment to conduct another radiological energency response (

drill, prior to January 1,1989, in accordance with the standard drill t methodology discussed during the inspection and sumarized above. This l drill is to involve the onsite emergency organization only, since  :

participation by offsite groups during the October 27, 1988 drill was  !

detemined by the inspectors to adequately demonstrate the support r capabilities of those groups, irrespective of their advance acquaintance with the scenario. [

The licensee's unacceptable method of conducting drills, as described [

i above, was categorized as a Program Weakness requiring proept corrective action. l t

Program Weakness 70-1151/88-15-02: Required annual emergency drill did not adequately test implementatien of Site Emergency Plan.

, .- 3 The inspectors attended the licensee's formal critique of the drill on October 28, 1988. The critique was thorough, with licensee evaluators independently identifying virtually all the problems observed by toe inspectors. Future inspections will review the corrective actions implemented in response to the critique items.

3 Exit I-terview (30703)

Ir e inspection scope and results were summarized on October 28, 1988, with those persons indicated in Paragraph 1. The inspectors described the dreis inspected and discussed in detail the inspection results listed Selvw. Proprietary information is not contained in this report. Licensee management representatives disagreed with item 88-15-02, stating their

, convictiua that the drill had been conducted in accordance with both the letter and intent of the license requirement.

I+em Number Description 70-1151/88-15-01 Inspector Follow-up Item - Development of a procedure which delineates how radiological habitability of the Emergency Operations Center will be routinely monitored and documented.

10-1151/88-15-02 Program Weakness - Required annual emergency drill did not adequately test implementation of Site Emergency Plan, i During a second exit interview conducted by telephone on November 4,1988, item 88-15-02 was categorized as a Program Weakness based upon the licensee's commitment to conduct another radiological emergency response drill prior to January 1,1989.

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