ML20214M488

Responds to NRC Re Violations Noted in Insp Rept 70-1151/87-01 on 870112-16.Corrective Actions:Regulatory Affairs Procedure RA-300 Incorporated Philosophy That Favorable Geometry Should Be Primary Control for Safety

ML20214M488
Person / Time
Site:	Westinghouse
Issue date:	05/21/1987
From:	Loch E WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8706010322
Download: ML20214M488 (22)

Text

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Westirl h0USS Nudear Fuel Dmsion Maneacug Dwanmem Electri Corporation, "..... m o9-g4 I ' '

Drawer R Columbia. Soum Carohna 29250 803 776 2610 May 21, 1987 U. S. Nuclear Regulatory Commission ATTN: Mr. J. Philip Stohr, Director Division of Radiation Safety and Safeguards Region II 101 Marietta Street, N. W.

Atlanta, Georgia 30323 Gentlemen:

SUBJECT:

NRC INSPECTION REPORT NO. 70-1151/87-01 Westinghouse Electric Corporation herein orovides, in Appendices A, B and C, formal responses to your letter of February 17, 1987 regarding your inspection of our facilities conducted during the period January 12-16, 1987.

Appendices A and B address the " Operational Safety Assessment Weaknesses" and " Operational Safety Assessment Improvement Items" respectively.

Appendix C responds to the Unresolved Item (UNR 87-01-06).

We appreciate the thorough reviews of our operational programs and believe that selective implementation of the recommendations and improvement items will serve to augment operations at the Westinghouse Commercial Nuclear Fuel Division Columbia Plant.

In the area of emergency planning, Westinghouse believes that some of the

comments, although worthwhile, exceeded the original NRC licensing recommendations as outlined in Regulatory Guide 3.42 and the "Stancura Format and Content for Radiological Contingency Plans for Fuel Cycle and Materials Facilities (1981)."

The current NRC approved Site Emergency Plan has been in ef fect since August 1981.

This plan, with its annual revisions, has been an effective management guide in dealing with the emergencies that have occurred as demonstrated by drills and exercises performed since the plan was developed.

We trust that you will take this into account when reviewing our response in this Furthermore, Westinghouse will be commenting on a proposeo rule published area.

in the Federal Register on April 20, 1987, regarding " Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees".

Any modification to our Radiological Contingency Plan and implementing procedures will involve compliance with this new regulation.

C Z.Eo7

Mr. J. Philip Stohr May 21, 1987 Page 2 Personnel will be assigned responsibilities for each of the commitments in Appendices A and B, including target dates for completion.

If you have any questions, please contact me at the above address or telephone me at (803) 776-2610, extension 3301.

Sincerely, WESTItGHOUSE ELECTRIC CORPORATION E. P. Loch, Manager Columbia Plant Ib WP1406E:3p.48

m I

APPENDIX A OPERATIONAL SAFETY ASSESSMENT WEAKfESSES 1.

Nuclear Criticality Safety Program:

1.a.

Policies and practices to specify that ' safe geometry will be the primary control for nuclear criticality safety had not been issued (IFI 87-01-02).

Westinghouse Response-We concur with the philosophy that favorable geometry should be the primary control-for nuclear criticality safety.

In this

regard, Regulatory Affairs Procedure RA-300 has incorporated this philosophy in addition to requirements for analyses to be performed to demonstrate that the double contingency principle is satisfied for systems subject'to administrative controls.

We will revise RA-300 to strengthen this policy.

1.b.

Individuals who may authorize use of hydrogenous fire fighting agents had not been specified in procedures or fire fighting plans (IFI 87-01-07).

Westinghouse Response Site Emergency Plan Procedure CSEP-0003,

" Columbia Site Emergency Procedure Fire Control," presently prohibits the use of water to fight a fire unless it has been specifically authorized.

This procedure will be modified to include the personnel within Regulatory Affairs who are authorized to give such approvals.

2.

Fire Protection Program:

2.a.

A comprehensive fire prevention / protection program based on a plant-wide fire hazards analysis performed by a fire safety specialist was not established (IFI 87-01-08).

Westinghouse Response A plant-wide fire hazards analysis will be performed by an independent fire safety specialist.

This analysis will form the basis for making program modifications, as needed, to correct any identified weakness and/or problem areas.

2.b.

Qualification and responsibilities for site fire prevention / control personnel had not been established (IFI 87-01-10).

Page 2 Westinchouse Response Appropriate job descriptions have been revised to reflect the modified qualifications and responsibilities inherent in the organizational change where this function now reports to the Regulatory Affairs Department.

2.c.

The Emergency Brigade training program does not address fire fighting techniques to combat major fires and chemical events, provide fire ground command training to brigade leaders, or provide for specific fire brigade drills or exercises (IFI 87-01-11).

Westinghouse Response The Emergency Brigade has been in existence and actively engaged in training since 1975 (the assessment states that training began in 1985).

Prior to

1985, training was conducted on a monthly basis with approximately half of the training being held in the classroom and half " hands on".

The Emergency Brigade practices annually witn the Columbia Fire Department in a drill exercise which covers the various problems which would be encountereo in any coordinated emergency response effort.

During the training sessions we try to cover not only fire fighting training, but strive to train the brigade to handle any type of emergency which they might encounter at this facility.

In 1985, the training format was changed from monthly to every other month.

We also now send our brigade members to the South Carolina Fire Academy every year to receive selected " hands on" training which cannot be easily provided on site.

For example, this year we sent them through an intense class requiring the use of full protective gear including TBA.

Many or our brigade members have been with the brigade since it was started and have therefore been involved with all aspects of training.

We do review the basics, not only for new members, but also for the benefit of our more senior memoers.

Documentation is available to show the specific subjects covered in the classes and training exercises.

Regarding brigade leader training, we are planning to use fire plans, to be developed ouring the fire hazards analysis, to train these individuals.

2.d.

The fire protection equipment inspection and maintenance program was not addressed in procedures, and the program did not contain all of the necessary elements (IFI 87-01-15).

PQe 3 Westinghouse Response Existing procedures are being reviewed and

revised, as appropriate.

New procedures are being written for those elements which are missing from the program.

2.e.

Fire potential evaluations lacked detailed consideration of storage of flammable / combustibles in the workplace, control-room fires, hydrogen fire potential, and adequacy of fire service main hydrant locations (IFI 87-01-33).

Westinghouse Response Safety has been incorporated into the weekly plant inspections defined in Regulatory Affairs Procedure RA-102.

Other items will be evaluated during the fire hazards analysis that will be performed by an independent fire safety specialist.

3.

Accident Scenarios 3.a.

The risk associated with three accident scenarios involving the UF6 cylinder unloading dock, use of argon, and the advanced waste water treatment facility had not been analyzed, and actions had not been taken to reduce accident potential (IFI 87-01-36).

Westinghouse Response A preliminary evaluation indicates the following actions to be taken at the UF6 cylinder unloading dock:

protecting the service pipes from

damage, and safeguarding the UF6 cylinders with a protective wall (fire hazards analysis to recommend specifics).

Argon lines coming into the facility will be backfitted with " Excess Flow" shut-off valves (a facility request has been submitted).

The tanks in the Waterglass Bulloing have been repiped to preclude accidental mixing of acids and bases.

4.

Emergency Preparedness Program:

4.a.

The emergency classification scheme did not ensure that emergency classifications would be conducted in a consistent manner (lFI 87-01-38).

Westinnhnuse Response The emergency classifications will be modified to more clearly define the emergency action levels and corresponding events.

Site Emergency Plan Procedure CSEP-0013,

" Emergency Notification of On-site and Off-site Organizations" will be modified to provide these additional details.

I Pag] 4 4.b.

Reliable methods for obtaining meteorological information had not been provided (IFI 87-01-50).

Westinghouse Response Reliable methods for obtaining meteorological information will be incorporated into procedure CSEP-00178.

Provisions for contacting the National Weather Service will also be identified in this procedure.

In

addition, the site meteorological station has been repaired and is now operational.

4.c.

Situations for which sheltering and evacuation would be recommended were not consistent with EPA Protective Action Guidelines (IFI 87-01-51).

Westinghouse Response Site Emergency Plan Procedure CSEP-0018,

" Emergency Communication (Two-Way Radios)," will be modified.

Table 5.5 will be reformatted to be consistent with EPA guidelines.

4.d.

Drills that integrate the entire emergency response organization were not performed on an annual basis (IFI 87-01-59).

Westinghouse Response Within the context of the plan, annual drills will be performed which integrate the entire emergency response organization into action.

4.e.

The training program for interim Emergency Directors did not assure that they understand the full scope of their responsibility as it relates to classification and notifications and that they have full authority to implement all aspects of the RCP (IFI 87-01-60).

Westinghouse Response The Site Emergency Plan Implementing Procedures will be modified to clarify the Emergency Coordinator's responsibilities and authorities.

Once completed, training of cognizant personnel will be implemented.

WP1406E:3p.49-52

APPENDIX B OPERATIONAL SAFETY ASSESSMENT IMPROVEMENT ITEMS 1.

Placing the industrial safety audit functions under the Regulatory Compliance Committee (IFI 87-01-01).

Westinghouse Response Industrial safety and fire protection issues and concerns have been on the standing agenda of the Regulatory Compliance Committee since the recent plant reorganization which placed the Safety Engineer under the jurisdiction of the Regulatory Affairs Department.

In addition, Regulatory Affairs Procedures RA-102 and RA-104 were revised and implemented to provide industrial safety and fire protection safety audits and reviews, respectively.

2.

Issuing procedure RA-303 concerning control of moderating materials as soon as possible (IFI 87-01-03).

Westinghouse Response Regulatory Affairs Procedure RA-303,

" Control of Mooerating Materials in Process Systems and Plant Application," will be developed.

3.

Issuing a procedure for performing surface density, solid angle and KENO calculations (IFI 87-01-04).

Westinghouse Response Regulatory Affairs Procedure RA-300, " Regulatory Affairs Reviews Requests" was revised to delete the equipment reviews that were incorporated into Procedure RA-104.

RA-300 will be entitled,

" Nuclear Criticality Safety Design and Review Criteria", and will incorporate the above referenced calculation criteria.

4.

Establishing and documenting the qualifications of the individuals who perform and review nuclear criticality safety calculations (IFI 87-01-05).

Westinghouse Response A formal document will be prepared for qualification of individuals who perform and review nuclear criticality safety calculations.

Requirements for these individuals are provided in StN-1107.

5.

Removing excess combustible materials from the UF6 loading dock and the UF6 Bay area (IFI 87-01-09).

W

Pagi 2 Westinghouse Response A new plant policy is being established to address housekeeping concerns.

Routine audits of housekeeping are now included in the weekly inspection tours.

Sprinkler protection is being considered in all areas where control of moderating materials is not required for nuclear criticality safety.

6.

Providing site-wide training on selection and use of fire extinguishers (IFI 87-01-12).

^

Westinghouse Response Fire extinguisher use training is currently given to Emergency.

Brigade members, Health Physics Technicians, and Safety Observers.

There are sufficient numbers of these individuals in locations throughout the plant to provide trained coverage to respond to an incipient fire situation.

7.

Including an evaluation of cardial function in medical examinations for fire brigade members (IFI 87-01-13).

Westinghouse Response The Columbia Plant Medical Department has been requested to evaluate the medical examination criteria for firefighters and its application to the Emergency Brigade.

8.

Developing site specific fire emergency plans to provide guidance to the Fire Brigade (IFI 87-01-14).

Westinghouse Response Current Emergency Brigade training is very comprehensive.

The fire hazards analysis will include the identification of site specific fire emergency plans needed to provide the Emergency Brigade with basic emergency information.

9.

Verifying that at least the minimum water level is present in the i

fire protection water tank during weekly inspections (IFI 87-01-16).

Westinghouse Response l

l Maintenance procedures will be developed and implemented to insure that minimum water levels are maintained.

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Pige 3

10. Assuring that fire hydrants and hose houses exist in sufficient numbers and at proper locations to provide required water flow to plant buildings while still meeting NFPA Standard 24 (IFI 87-01-07).

Westinghouse Response This evaluation will be conducted by an independent fire safety specialist during the fire hazards analysis of the facility.

Results of the analysis will be reviewed and acted upon accordingly.

11. Implementing an inspection and testing program for the new central fire detection system when it is installed (IFI 87-01-18).

Westinghouse Response Inspection and test procedures will be developed and implemented once the new fire detection system becomes operational.

12. Developing an inspection and maintenance program for passive fire barriers (IFI 87-01-19).

Westinghouse Response Fire barriers will be identified and evaluated.

Procedures will be developed and implemented for routine inspections and maintenance of fire barriers.

13. Evaluating the hazards to personnel associated with the dust suspension in the dissolution area (IFI 87-01-20).

Westinghouse Response Chemical sampling and analysis were performed in the past and no significant problems were identified.

14. Ensuring that incompatible chemicals do not share common diked areas (IFI 87-01-21).

Westinghouse Response Several areas have already been reviewed, with safety concerns identified and corrected.

The fire hazards analysis being performed by an independent fire safety specialist will include the tank farm.

t

15. Analyzing the anhydrous ammonia system for off-site release potential and providing appropriate safeguards (IFI 87-01-22).

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Page 4 Westinghouse Response This evaluatio1 will be completed b'y ' an independent fire safety specialist during the fire hazards analysis.

16. Evaluating chemical servicing piping for adequacy of color coding and/or labeling (IFI 87-01-23).

Westinghouse Response A Facilities procedure exists that identifies required color coding on service piping and sprinkler water piping. Some repaired systems require backfitting to insure that all piping is properly marked and/or labelled.

An action request has been initiated to have this completed.

17. Reviewing Standard Operating Procedures to assure that safety precaution sections include safe ranges for operating conditions and that emergen y operations sections include safety-oriented steps (IFI 87-01-24.

Westinghouse Response All. current operating procedures are being reviewed for safety bi concerns / items.

We are investigating the inclusion of safe f

operating ranges of parameters such as temperature,

pressure, volume, and concentration in operating procedures.

!3

18. Revising procedure FP 226 to include all instruments on the QC Tool and Gauge Monitor List (IFI 87-01-25).

Westinghouse Response Procedure FP 226 will be revised.

We are evaluating a new policy which will require that Procedure FP226 be revised within 30 days of i

any revision of the QC Tool and Gauge Monitor List.

19.

Including pressure switches on the QC Tool and Gauge Monitor List (IFI 87-01-26).

m Westinghouse Response The Tool and Gauge Monitor List was developed to track items which affect product quality.

Pressure switches generally do not affect product quality.

Pressure switches such as the vaporizer pressure T

switches, which do affect the process from a safety standpoint are

'e,'*

included in the maintenance tracking system and are calibrated within required frequencies.

20. Removing the statement in Procedure FP-236 that the calibration results will be recorded in the weekly industrial instrumentation listing (IFI 87-01-27).

S p'

Page 5 Westinghouse Response Revision of Policy FP-236 will be initiated to remove the statement.

21. Investigating the availability of hydrofluoric acid monitors which have larger mean-times-between-failures (IFI 87-01-28).

Westinghouse Response This is currently under investigation.

22.. Testing of pressure relief valves on a regular basis (IFI 87-01-29).

Westinghouse Response There are no pressure relief valves currently installed on either ADU or IDR vaporization systems.

The ADU system incorporates a pressure relief rupture disk for each vaporization chest.

This item had been identified for maintenance and testing on a routine basis prior to the Operational Safety Assessment.

The IDR system has no relief devices since this system operates at ambient pressures.

23. Checking specific gravity in battery pilot cells (IFI 87-01-30).

Westinghouse Response A procedure will be generated to do this for the four emergency generators and the diesel fire water pump drivers.

24. Updating the computer maintenance system to provide maintenance history in selected areas (diesels) (IFI 87-01-31).

Westinghouse Response The program has been updated to include the capability for providing work history for each generator.

Procedures have been revised and implemented.

25. Sampling diesel fuel storage tanks during preventative maintenance (IFI 87-01-32).

Westinghouse Response In June of 1987 a program will be established for sampling diesel fuel tanks on an annual basis.

If sampling does not show any contaminants after several years data, sampling will probably be discontinued.

If contamination is found then corrective measures will be taken.

Page 6-

26. Completing the ' installation of the modifications identified by the Risk Assessment Committee (IFI 87-01-34).

Westinghouse Response All modifications identified by the Risk Assessment Committee are scheduled to be implemented during 1987.

27. Evaluating the accident potential associated with the UF6 Bay drainage trench (IFI 87-01-35).

Westinghouse Response The trench capacity and filtration system is sized to prevent accumulations for a hypothetical accident scenario involving.a small fire (6 sprinklers energized) and. major UF6 release.

This sprinkler system'is equipped with manual shut-off valves in order to prevent ' material -accumulations during a

major fire and UF6 release.

Efforts are currently underway to identify modification that will prevent trench accumulations during a major fire and UF6 release.

28. Analyzing and -providing mitigation for the accident scenarios involving solvent extraction, hydrogen and propane storage, UF6

' heating and dissolver corrosion (IFI 87-01-37)_.

Westinghouse Response Solvent _ Extract _lon The Solvent Extraction Evaporator Operations were reviewed to ensure that a

" Red 011" incident could be precludea.

The Solvent Extraction process -(Purex) uses Kerosene and T8P for purification of uranium-materials.

These oils are extracted from the process streams via packed transparent columns prior to evaporator processing.

The oils and UNH separate-out in these columns due to differences in specific gravity.

Procedures require operations to inspect,these packed transparent columns to safeguard against oil carryover to the evaporator.

Furthermore, evaporator steam temperatures are regulated below that

. required for a " Red 011" accident.

P,rppan_e Stor_ age _

There is no residual propane in the propane storage tanks.

Steps were taken to purge the tanks with nitrogen and back-fill each with a pressurized nitrogen blanket.

The future use of these tanks is currently being evaluated.

In the interim, the tanks will be locked out to preclude further use.

Page 7 M rogen During the fire hazards analysis, the hydrogen storage tank area will be reviewed to determine what steps need to be taken to ensure a continued safe operating system.

In addition to the excess flow valves, flow limited valves have also been installed on the hydrogen piping system within the tank farm area.

This arrangement provides a double contingency to excess hydrogen flow.

Dissolvers A new dissolver system (favorable geometry) is being developed for installation in the new plant expansion area. Steps are being taken to improve its operation in order to prevent excessive leakage and subsequent dissolver and floor corrosion.

In order to minimize corrosion, a stainless steel floor is being contemplated.

Uf6 yagor_ization The ADO UF6 vaporization process has undergone a very extensive modification to ensure that the maximum cylinder temperature does not exceed 250oF.

The new steam delivery system is equipped with dual pressure regulators in series coupled with an interlock shutdown and rupture disk to prevent over pressurization.

The system is equipped with automatic termination of steam supply in the event of a UF6 leak.

A further study is already in process to determine if existing pressure gauges and transmitters can operate to provide startup pressure information during cylinder heating.

The second phase would then evaluate a

modified processing arrangement (valving arrangement) to provide pressure monitoring during startup.

The existing emergency cylinder cooldown system will be reviewed for adequacy.

29. Defining the action levels for the accidents associated with a given emergency class in the RCP (IFI 87-01-39).

Westinghouse Response The plan will be modified to add a " Notification of Unusual Event" (NOUE) category for loss of communication and fire incidents.

Action levels are already defined in the scenario section of the Site Emergency Plan.

30. Evaluating the classification of certain incidents to verify that they warrant such a level of response (IFI 87-01-40).

Westinghouse Response Add a local emergency classification category for fires.

The civil disorder and flood categories will be downgraded to NOUE.

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Page 8-

31. Including additional examples of occurrences which would warrant upgraded attention by off-site and site personnel,- or would significantly inhibit assessment capabilities (IFI 87-01-41).

Westinghouse Response A. transportation accident involving StN. material, requiring

. Westinghouse response and possible support, will be added to the alert category.

32. Adding the requirement that off-site ' notification be made upon declaration of an emergency in Procedure CSEP-0013 (IFI 87-01-42).

33. Modifying notification times such that they are made to the State and Local agencies within 15 minutes and to the NRC within one hour of emergency declaration (IFI 87-01-43).

Westinghouse Response

. Site Emergency Procedure CSEP-0013,

" Emergency Notification of-On-Site and Off-Site Organizations" will be revised to indicate that upon declaration of an emergency off-site, notification by the Emergency Director - or his alternate, will~ be mace to the State within fifteen (15) minutes and to the tEC within one (1) hour.

34. Modifying notification procedures to assure notifications are performed upon reclassification or significant changes in condition within an emergency class (IFI 87-01-44).

Westinghouse Response Site Emergency Procedure CSEP-0013 will be modified to assure that all organizations requiring notification within an emergency class are to be. notified of reclassifications or significant changes in the emergency conditions.

35. Adding meteorological information, emergency class, and provisions for message authentication to the notification procedure (IFI 87-01-45).

Westinghouse Response

-Meteorological information, emergency class and provisions for message authentication will be added to the listing in Proceoure CSEP-0013.

Provisions will be made for automatic callback for message authenticity.

l

Page 9 36.'. Providing 'for a quarterly review of the emergency call listing '(IFI 87-01-46).

Westinghouse Response An implementing procedure is being evaluated to require quarterly reviews of phone listings.

37.

Including alternates for. the Emergency Staff members in the emergency call list (IFI 87-01-47).

-Westinghouse Response A-sufficient number of members already exists on the Emergency Staff whereby alternatives are not needed. Line managers or engineers may be used as a resource.

38. Providin additional visual alarms in high noise areas (IFI 87-01-48.

Westinghouse Response The new fire alarm system is currently being installed with additional alarm horns in all areas of the facility.

In addition, a facilities request has been initiated to install a blue rotating beacon in the Mechanical Equipment Room.

39.

Posting 9) pproved a

evacuation routes throughout the facility (IFI 8 7 Westinghouse Response A revised evacuation route drawing is being prepared reflecting recent facility upgrades and additions.

Once completed, the routes will be posted throughout the plant.

40.

Providing for multiple copies of the RCP and procedures in the Emergency Control Center (ECC) for use by members of the Emergency Staff (IFI 87-01-52).

41. Providing a variety of administrative supplies, logbooks and multiple copies of notification forms in the ECC (IFI 87-01-53).

~ Westinghouse Response Extra copies of the RCP and procedures will be stored in the ECC, which is the Plant Manager's Conference Room.

Other administrative supplies will also be provided.

Page 10

42. Documenting the daily checks of the backup mobile phone (IFI 87-01-54)

Westinghouse Response The daily check involving operability of the backup mobile phone will be proceduralized.

Plans are to provide information in the site security plan.

43. Including in the RCP and procedures a complete description of the backup communications

systems, the locations and under what 1

circumstances they are operable (IFI 87-01-55).

Westinchouse Response The description of the backup communication systems, locations and applicable circumstance will be contained in Section 6.2.1.1 of the plan.

44. Securing the HP Emergency Equipment Cabinets and SCBA units with breakaway tags to ensure no tampering or use between inventories (IFI 87-01-56).

Westinghouse Response Typically, breakaway seals are used on devices to ensure against tampering or otherwise unauthorized use.

Plans are to implement a tamperseal for the HP cabinets and SCBA units, as defined in Health Physics procedure.

45.

Including a typical listing of the emergency equipment in Appendix 0 of the RCP (IFI 87-57).

Westinghouse Response Inventory listings, where appropriate, are maintained at each storage location.

We believe that this is the proper location for the inventory _ listings.

46. Providing for segregation and labeling of the different respirator filter cartridge types to ensure that appropriate protection is used (IFI 87-01-58).

Westinghouse Response In emergency response situations, SCBA's are required for respiratory protection during the response.

New combination cartridges for both radiological particulate and ammonia or acid mist absorption are color coded and requisitioned from the Westinghouse storeroom.

Appropriate training is given in selection of the proper combination cartridge.

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Page 11 47.

Including a discussion of the four emergency classes and their relationship to plant safety degradation in general employe training (IFI 87-01-61).

Westinghouse Response Training will be modified at a future date to include a discussion of the four emergency classes for all personnel.

48. Specifying that emergency monitoring and security training will be provided annually in the RCP (IFI 87-01-62).

Westinghouse Response Health Physics emergency and security training will be performed on an ' annual basis.

This will be documented through modification of Section 7.2.2 and an addition of the requirement in section 7.2.6 for security training.

49. Specifying in the RCP that Emergency Director and Emergency Coordinator training will be provided annually in the RCP (IFI 87-01-63).

Westinghouse Resoonse The Emergency Director and Coordinator Training will be provided annually.

This will be documented in Section 7.2.1.

50.. Including a description of the annual integrated drill which

-includes objectives, range of scenarios, conduct on back shifts, and groups to be exercised in the RCP (IFI 87-01-64).

Westinghouse Response Within tha context of the plan, annual drills will be performed which integrate the entire emergency organization into action.

51. Including re-entry and annual off-site monitoring in the semi-annual drills for HP technicians (IFI 87-01-65).

Westinghouse Response Annual training for Health Physics technicians should be sufficient to cover re-entry and annual off-site monitoring for the semi-annual drills.

In addition, Health Physics technicians will be active in all full-scale drills which will require additional training.

52. Performing communications drills monthly to include message transmission and use of backup equipment (IFI 87-01-66).

Page 12 Westinghouse Response Communication drills will continue to be practiced as is documented in the Site Security Plan.

A revision will be made to insure that message transmissions are documented.

53. Updating of all off-site agreement letters biennually (IFI 87-01-67).

Westinghouse Response This practice has been successfully completed informally since the plan's inception and will continue in this manner to ensure interaction between Westinghouse and respective off-site groups.

54.

Providing annual orientation training to off-site groups expected to respond to an emergency which includes access procedures, radiological and chemical

hazards, means of protection, and prearranged interfaces (IFI 87-01-68).

Westinghouse Response Training sessions have been offered in the past for outside groups including the Columbia Fire Department, Richland County EMS and Richland Memorial Hospital.

We will continue to offer voluntary training sessions and document this by official correspondence.

Some groups are not able to devote the time for in depth on-site training sessions, and it would be impractical to make this a requirement.

55. Clarifying in the RCP that orills will be conducted annually with off-site fire departments (IFI 87-01-69)

Westinghouse Response Past practice has been to involve the Columbia Fire Department in an annual drill.

Section 7.2.5 in the RCP will be mooified to occument this practice.

56.

Including the Sheriff's Department in drill participation periodically (IFI 87-01-70).

Westinghouse Response Plans will be made to include the Sheriff's Department in the next major drill and periodically as is needed.

57. Expanding the description in the RCP of the specific off-site support available and the personnel assigned to direct these off-site groups upon arrival (IFI 87-01-71).

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Page 13 Westinghouse Response The specific off-site support groups are currently documented within the Plan.

The Emergency Director is responsible for assigning individuals to direct those groups as applicable.

58. Requesting the State of South Carolina to periodically comment on the RCP to-ensure that it is consistent with the State Plan with respect to classifications, notifications and the action levels at which off-site responses are required (IFI 87-01-72).

Westinghouse Response A copy of the RCP has been forwarded to the _ State of South Carolina Department of Health and Environmental Control (SC-DHEC), Bureau of Radiological Health.

We will officially request them to comment on our Plan.

59.

Inviting the State of South Carolina to observe and critique drill activities periodically (IFI 87-01-73).

Westinghouse Response Invitations will be extended to the SC-DHEC, Bureau of Radiological Health personnel, to observe and critique drill activities.

60. Providing all off-site groups with controlled copies of the RCP and procedures so that they will be available to them for reference and internal training purposes (IFI 87-01-74),

i Westinghouse Response Copies of the RCP and procedures will be distributed to off-site groups with which letters of agreement are maintained.

61.

Denoting those duties specifically assigned to the Emergency Director and how these are distinguished from the outies of the 1

Emergency Coordinator in the RCP (IFI 87-01-75).

Westinghouse Response These duties are currently defined in Section 4.2.1 of the Plan.

The responsibilities for the Emergency Director are:

Direct emergency responses above the alert level.

Advise as is required at the alert level and below.

Assist with incident classification.

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Page 14 Assemble an emergency staff organization.

Maintain contact with the Corporate WNES Emergency Committee.

Maintain communication with off-site governmental agencies and notification.

Maintain communication with American Nuclear Insurers Authorize re-entry plans in rescue situations.

Initiate on-site evacuation.

62. Defining the specific responsibilities of the Emergency Staff members in the RCP (IFI 87-01-76)

Westinghouse Response The following specific responsibilities for Emergency Staff members will be documented in the Plan:

Assemble and' support Emergency Director in emergency responses above the alert level.

Consult with Emergency Director in their respective area of expertise.

Function as an alternate Emergency Director during incidents above the alert classification if the Plant Manager is not present.

63. Developing an overall controlling procedure / checklist for the direction of emergency actions to include classifying emergencies, activation of off-site and site groups, and making protective action recommendations (IFI 87-01-77)

Westinghouse Response A new implementing procedure will be written referencing CSEP-0013 which will provide more direction for emergency actions.

64. Providing a specific line of succession for the Primary Emergency Director (IFI 87-01-78)

Westinghouse Responses A line of succession will be created to pass the Emergency Director role to the in-charge or first responding Emergency Staff member, and default to the senior Conversion Staff Supervisor if an Emergency Staff Member is not present.

'Page 15

65.. Providing alternates for other emergency staff positions (IFI 87-01-79).

Westinghouse Response A sufficient number of members already exists on the Emergency Staff whereby alternates are not needed.

Line managers or engineers may be used as a resource by the Emergency Director or Emergency Coordinator acting in that role.

66. Providing for an independent audit of the RCP and emergency preparedness program (IFI 87-01-80)

-Westinghouse Response An independent audit of the Plan and program will be performed by an outside group such as Corporate Licensing.

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67. Incorporating the distribution of the RCP into the already established Regulatory Compliance procedure as planned (IFI 87-01-81).

Westinghouse Response A procedure will be written to document distribution of the Emergency Plan to controlled document holders.

68. Ensurino that all drill critique comments are. documented and incorpoiated into the formal tracking system for timely completion of corrective actions (IFI 87-01-82).

Westinghouse Response All formal critique items are currently documented into the tracking system.

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APPENDIX C OPERATIONAL SAFETY ASSESSMENT UWESOLVED ITEM 1.

The storage array for incinerator ash in the scrap recovery area is based on _ moderation control.but the ash storage area is not designated as.a moderation control area since hydrogenous materials are used throughout the area.

Whether there is sufficient control in this area could not be determined by the team.

The storage arrays may not be consistent with the double contingency requirement (Um 87-01-06).

Westinghouse Response The storage array for incinerator ash in the incinerator and UF6 bay areas was evaluated prior to installation of the fire suppression system.

In the past, (coupled with favorable geometry) moderation control and mass control were the primary criteria for nuclear criticality safety of the rack arrangement.

The evaluation indicated that the moderation control requirement could be eliminated through concentration _ control (as opposed to mass control) for each container.

The storage arrangement is now based on limiting storage to favorable geometry (8" diameter containers),

uranium concentration (14gU-235/1),

and adequate spacing, so that the solid angle criteria of TID-7016 (Rev. 2) coupled with additional SW-1107 requirements would be satisfied.

Although storage is maintained in a " dry" state, within moderation controlled. limits, moderation control criteria is not required for criticality safety.

An additional evaluation concerning the sprinkler system was conducted to determine the degree of reflection that would be anticipated during entire system operation.

This evaluation indicated that water densities approximately 100 times below optium reflection (0.2g/cc) would result.

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