TRANSMITTED TO DOE/MARK WHITAKER 02/22/95

DEFENSE NUCLEAR FACILITIES SAFETY BOARD


September 14, 1994


MEMORANDUM FOR:       G. W. Cunningham, Technical Director

COPIES:               Board Members

FROM:                 D. Thompson
                      Senior Technical Specialist

SUBJECT:              Supplementary Report on Hanford Emergency
Response Exercise
                      Fraser



1.     Purpose:  This report supplements the June 23, 1994, trip
report
       evaluating the Hanford Emergency Response Exercise Fraser,
and documents
       DNFSB Staff observations concerning the formal Department of
Energy (DOE)
       Evaluation of the same exercise.

2.     Summary:  Westinghouse Hanford Company's (WHC's) Exercise
"Fraser" Final
       Critique, dated July 26, 1994, was received by the Board on
August 15,
       1994.

       In general, the WHC report adequately reviews the Exercise
against the
       stated objectives, in accordance with evaluation criteria
set forth in the
       Department's Emergency Management Guide dated December 11,
1991. 
       Unfortunately, it appears the authors of the report chose to
soft pedal
       their criticism, apparently seeking to avoid offending
anyone.  Although
       the evaluation does note most of the same areas of poor
performance
       identified by the DNFSB Staff - and some other problems as
well - in
       almost every instance, the findings are presented in
contexts that would
       lead the reader to conclude that the exercise was more
successful than it
       actually was.

3.     Background:  DNFSB Staff evaluators reported the results of
their
       monitoring of Exercise Fraser in a June 23, 1994, memorandum
to the
       Technical Director, including their evaluation of DOE's
development,
       conduct and control of the exercise.  DNFSB Staff evaluators
also provided
       their initial assessment of the adequacy of DOE's own
evaluation of the
       exercise, based on the information provided during the
post-exercise "hot
       washes" and discussions with controllers and evaluators
following
       completion of the exercise.  At the time the trip report was
written, the
       DNFSB Staff proposed withholding release of its report until
DOE
       documented its review.

       Section II B of DOE's Emergency Exercise Evaluation Criteria
calls for
       evaluator findings to be categorized as "Deficiencies",
defined as
       failures to meet the requirements of applicable DOE Orders
or failures to
       meet evaluation criteria leading to inadequate demonstration
of the
       standard; "Weaknesses", defined as degradations of the
demonstration
       called for in the exercise objectives; or "Improvement
Items", defined as
       subjects for which improvements appear to be warranted. 
Corrective
       actions for Deficiencies and Weaknesses must be documented
and tracked to
       closure, whereas Items for Improvement do not require formal
tracking and
       closure documentation.

4.     Discussion/Observations:  DOE evaluators of Exercise Fraser
identified 43
       negative findings (No Deficiencies, 15 Weaknesses and 28
Items for
       Improvement).  WHC evaluators identified 15 objectives that
either were
       not observed or were not met.  DNFSB Staff members believe
that at least
       some of these 15 failed objectives constitute deficiencies
defined in the
       applicable Evaluation Criteria.  It is recognized, however,
that the
       difference between "inadequate demonstration" and "degraded
demonstration"
       may be perceived differently by different evaluators. 
Inasmuch as both
       deficiencies and weaknesses must be tracked to completion by
DOE, the
       DNFSB Staff believes that suitable means are available to
determine the
       adequacy of corrective actions.

5.     Additional Future Staff Actions:  Staff will track and
monitor corrective
       actions for each of the weaknesses identified in the DOE
evaluation.