IR 05000267/1982001

IE Emergency Preparedness Appraisal 50-267/82-01 on 820104- 15.Noncompliance Noted:Significant Deficiencies in Emergency Action Levels,Respiratory Protection,Offsite Radiological Monitoring Capability & Radiation Monitoring

ML20054K296
Person / Time
Site:	Fort Saint Vrain
Issue date:	06/11/1982
From:	Chaney H, Jay Collins, Desrosiers A, Gilcrist R, Hackney C, Rohrer D, Matthew Smith, Wisner C, Zalcman B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20054K282	List: IR 05000267/1982001 ML20054K281 ML20054K291
References
50-267-82-01, 50-267-82-1, NUDOCS 8207010403
Download: ML20054K296 (75)

Text

U.S. NUCLEAR REGULATORY COW 11SSION

REGION IV

Emergency Preparedness Appraisal Report No. 50-267/82-01 Docket No. 50-267 License No. DPR-34 Licensee: Public Service Company of Colorado P. O. Box 840 Denver, Colorado 80201 Facility Name: Fort St. Vrain Nuclear Generating Station Appraisal At: Fort St. Vrain Site, Platteville, Colorado Appraisal Conducted: January 4-15, 1982 Team Members: both,O,Mo6_vuts _ dat/ f/R,/q C. Hackney, Emergency Co @ dJnator, NRC Date (Team Leader)

L(GA. G' FjaJm de s7/.u./r D. Rohrer, Emergency Prepar6dnghs Analyst, NRC- 'Date

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, B. Zalcman, Staff Meteorologigt, NRC '

D' ate Approved by: Idul [d(A Achn T. Collins, Regional-Administrator, NRC

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SUMMARY The appraisal of the state of onsite emergency preparedness at the Fort St. Vrain Nuclear Generating Station (FVS) involved seven general areas:

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Administration of the emergency preparedness program development;

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Emergency organization;

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Emergency training;

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Emergency facilities and equipment;

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Procedures which implement the emergency plan;

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Coordination with offsite agencies; and

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Walk-throughs of emergency duties, including exercises and drill The development of the FSV emergency preparedness program was performed through an outside contractor with little or no substantive input from the general working-level plant staff. The results of the appraisal indicated that the existing program contained a number of deficient area The appraisal findings indicate that the major cause of the deficiencies were incongruities, conflicts, and omissions in the emergency plan and procedure These observations were I substantiated during the review and reinforced during discussions held with various licensee personnel. The auditors noted that several areas that were

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vital to the emergency preparedness program were missing and determined that, while some of those areas had been addressed in other licensee procedures and documents, they were not included in the RERP and EPIP'S as docketed with the NR The auditors concluded that the licensee appeared to be capable of responding to and managing responses to events of limited scope and duration. The auditors determined that additional working space and facilities would be very difficult to secure onsite; however, additional portable buildings could be obtained for long-term recover It should be noted that the appraisal team fully realizes that, due to the time and manpower limitation of the appraisal, it has not identified all of the minute areas of the licensee's emergency preparedness and response program which may need correction to be in full compliance with the NRC emergency preparedness regulations. Additional deficiencies may be identified during the observation of the licensee's emergency drills and exercises and during other normal NRC inspection _ _ _ _ _ _ _ _ _ _ _ _

1.0 ADMINISTRATION OF EMERGENCY PREPAREDNESS The auditors reviewed the contents of the following documents:

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Licensee's " Radiological Emergency Response Plan - Plant" (RERP), dated February 10, 1981;

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Licensee's " Radiological Emergency Response Plan - Station" (EPIP's),

dated February 10, 1981, and January 4, 1982;

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Licensee's " Fort St. Vrain Medical Emergency Plan" (MEP), dated December 31, 1981;

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Licensee's RERP "Public Information Manual" (PIM), undated;

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Colorado " State Radiological Emergency Response Plan" (State RERP), dated February 10, 1981; and

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Other 1icensee procedures which extended and augmented the RERP and EPIP's (e.g., system operating procedures (E0P's), abnormal operating procedures (AOP's), emergency operating procedures (EOP's), various administrative procedures, health physics and radiochemistry procedures, training procedures, and security procedures).

The auditors also reviewed various other licensee documents (e.g. , job descriptions, memoranda, organizational charts, etc.) and held discussions with site management, site general employees, and corporate management personnel.

This was done in order to determine the licensee's normal corporate and site personnel structure, the emergency duty assignments, and the characteristics of the group of persons within the licensee's organization who were responsible for the development and administration of their radiological emergency preparedness program.

1.1 Responsibility Assigned Section 8.1.3 of the RERP stated that the Manager of Nuclear Production had the overall responsibility and authority for emergency response planning and that he had assigned the Technical Services Supervisor the collateral duty of Emergency Planning Coordinator (EPC). The auditor determined, however, that a corporate and site reorganization had taken place after the RERP was written, and that at the time of this appraisal the duties of the EPC had been shifted to the Technical and Administrative Services Manager. The auditors also noted that the responsibilities (but not the authorities) of those two individuals, as related to emergency preparedness, were amorphously reflected in their job descriptions. The auditors further noted that there was no counterpart at the corporate level to the site EP _

During discussions with the EPC, the auditors noted that the individual's emergency response planning duties were in addition to his other duties as the Technical and Administrative Services Manager (with five major units in that organization); the Plant Security Officer; and the alternate chairman of the Plant Operations Review Committee. The auditors questioned the EPC as to his exact duties in emergency planning and determined that the EPC acted as a coordinator only, and that the actual planning effort and writing was performed by an outside contractor for the RERP, by three site employees for the EPIP's, and by the corporate public relations department for the coordination with offsite authorities and response groups. The EPC stated that the assignment of those other corporate and site personnel was done informally by verbal direction.

The auditors noted that no provisions had been used to actively solicit and incorporate input from the working-level staff at FSV into the emergency response planning. The auditors also determined, during interviews with various plant staff, that the working-level employees at the site were not specifically aware of the contents of the emergency p! ,, its provisions and relationship to their actions during an emergency, or who was responsible for emergency planning and how to raise problems they might identify directly to the proper persons.

1.2 Authority Assigned During discussions with the EPC, the auditors determined that, while the individual knew that he was responsible for emergency planning, he could produce no evidence that actual authorities had been delegated to him to enable him to perform his assigned tasks. The individual stated that the very assignment of the responsibility to him implied the authority to perform the task.

The auditors noted that, throughout the emergency planning documentation and the implemented program, many similar authorities, responsibilities, and actions were implied but were not explicitly identified and supported with documented delegations of authority. Coordination of the onsite and offsite organizations and the corporate emergency. organization was the responsibility of the EPC.

The auditors noted that the EPC reported directly to the Manager of Nuclear Production and was on the same management level as the Station Manager.

Further, the auditors noted that the EPC received support from his direct manager when exercising his responsibilities and authorities regarding emergency plannin However, since the real day-to-day emergency planning efforts were not performed by the EPC, but instead by three other site employees under him, it was not apparent that the authority and management support was available to those working individuals. The auditors also determined that the EPC was new to the job and was not familiar with the detailed provisions of the RERP, EPIP's, 10 CFR 50.47, 10 CFR Part 50, Appendix E, or the regulatory guidance contained in NUREG-0654, Revision .3 Planning Coordination During discussions with the EPC, the auditors determined that coordination l between the licensee and the general public/ news media was done at the i corporate level only; however, the auditors noted that the responsibility was not clearly specified in the emergency plan reply or its implementation procedures. The auditors further determined that there was no formal or documented method developed to assure continued coordination between the site and corporate organizations. The EPC stated that such cooperation and coordination had generally been adequate but that it was subject to day-to-day variations due to the lack of a formalized authority base.

The auditors further determined that coordination with offsite State and local authorities and support groups appeared to be adequate (see section 6 )

of this report).

l The auditors noted that, while the EPC attends meetings of the Plant Operations Review Committee (PORC) by virtue of his position as a department head (Technical and Administrative Services), this may not continue if the responsibility for the EPC were to shift to a nondepartment-head individual.

No provision existed that the EPC be a member of the PORC regardless of the position of the individual in the normal station organization.

1.4 Personnel Selection and Qualification During discussions with the site and corporate individuals responsible for the planning effort within the licensee's organization, the auditors noted that the individuals possessed a general understanding of the principles involved in developing plans and procedure The auditors also noted, how-ever, that there were no selection or qualification criteria for the individuals filling positions related to emergency preparedness planning activities.

Since there were no selection criteria or minimum qualification criteria implemented within the licensee's organization, there were no clear provisions established for training the individuals to fulfill minimum criteria of these positions.

Section 8.1.1 of the FSV emergency plan (RERP) addressed training for the individuals responsible for emergency response but did not address training for those individuals responsible for the emergency planning effort. The auditors noted that there were no provisions or existing plans to provide professional development training for those individuals currently holding emergency planning positions to ensure the maintenance of state-of-the-art knowledge. Station management stated that a training program for the currently assigned' individual (EPC) and for future individuals who may hold the EPC position had not been considered nor were there plans to provide such trainin . - _ _ _ _ _ _ _ _ _ _ .

1.5 Quality Assurance of Emergency Preparedness Organization The auditors held discussions with the FSV Supervisor of Quality Assurance and determined that he reports to the Site Manager of Quality Assurance. The Manager of Quality Assurance reports to the Vice President of Production. This reporting structure ensured direct access to corporate management.

The auditors determined that QA provided frequent audits of the FSV training departmen The audit includes a review of the records of training and the frequency of training, but it did not appear to evaluate whether the training program was effective in providing the insight, skills, and understanding needed by members of the emergency response staff sufficient for them to perform their emergency functions as assigned.

The QA staff act as observers during emergency drills and exercises (see section 5.5.4).

1. 6 Conclusions and Determinations Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

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Correct the RERP and EPIP's to accurately reflect the licensee's existing organizational structure (267/82-01-01);

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Designate a single individual within the PSC organization who shall be given direct working-level responsibility for, and authority over, all aspects of the development and maintenance of the emergency preparedness program for both the corporate response and site response functions (267/82-01-02);

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Develop and implement explicit and specific functional responsibilities and authorities for all persons assigned duties for the various emergency preparedness planning and coordination functions (267/82-01-03);

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Develop and implement a program for training individuals, who are assigned emergency planning responsibilities, which will enable them to attain and maintain a state-of-the-art knowledge in the field of emergency preparedness (267/82-01-04);

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Evaluate the adequacy of existing staff assigned responsibility for emergency preparedness planning and coordination, and develop a means to augment existing staff when necessary (267/82-01-05);

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Develop and implement methods to provide substantive-input from plant staff, down to the working level, to the development of emergency preparedness plans and procedures (267/82-01-06);

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Develop and implement specific selection and qualification criteria for individuals assigned to perform emergency preparedness development activities (267/82-01-07);

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Develop and implement quality assurance procedures to evaluate the effectiveness of the emergency planning development training (267/82-01-08);

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Provide formal assignment of all individuals held responsible to perform emergency planning duties (267/82-01-09); and

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Augment existing general employee training (GET) to ensure that all site personnel are adequately trained in the general provisions of the RERP, their responsibilities during an emergency, and how to provide input to correcting deficiencies they identify (267/82-01-10).

2.0 EMERGENCY ORGANIZATION 2.1 Onsite Organization The auditors reviewed the contents of the RERP, its associated EPIP's, other supporting procedures, and held discussions with both site and corporate personnel to evaluate the nature and adequacy of the licensee's onsite emergency response organization and the assignment of emergency duties, responsibilities, and authoritie The auditors also reviewed the licensee's entire organizational structure from the Board of Directors down to the individual working level at FSV and reviewed the job descriptions of key emergency response personnel.

Sections 5 and 6 of the RERP describe the PSC organization for controlling emergencies at FS The auditors noted that the RERP description of the emergency organization provided for an individual designated as the " Emergency Coordinator" (EC) who was responsible for overall coordination and direction of the licensee's response and that this individual had been given responsibility, but not the authority, consistent with NUREG-0654, Revision 1, items A.1.d, and B.2. The auditors further noted, however, that the descriptions in both the RERP and tho EPIP's of the responsibilities of the EC did not specify those duties and responsibilities which could not be delegated by the EC to other emergency worker Further, there was some confusion as to the line of succession of the EC position. At the start of an emergency, the on-duty Shift Supervisor was automatically the EC until he could be relieved by either the Control Room Director or the Technical Support Center Director. If both of those individuals were onsite at the same time, it was not specified which one would be the EC or when the position would move from one to the other. Further, there were no formal criteria or methods to pass the EC position nor provi-sions to inform the emergency workers of the change of the individual in charge of the overall licensee response activities. At the " Alert" or higher classes of emergencies, the licensee activates its entire emergency organiza-tio However, the auditors noted that until those organizations are activated and the Technical Support Center and Personnel Control Center are operational, all of the functional areas as specified in Table B-1 of NUREG-0654, Revision 1, were not performed from the control room.

The RERP and its EPIP's were written to reflect the general functions of six

" emergency centers" as follows: 1) Control Room (CR); 2) Technical Support Center (TSC); 3) Personnel Control Center (PCC); 4) Forward Command Post (FCP);

5) Executive Command Post (ECP); and 6) State Emergency Operations Center (E0C)

(see Figure 1). A director was assigned to each of the emergency centers and was assigned general areas of responsibilitie Further, alternates were specified for the director position for each of the emergency centers and for the key individuals reporting to each of the centers, but such assignment was not made for the supporting groups responding to those key individual It should also be noted that the major licensee operations would be guided from four of the emergency centers and that the licensee actions performed at the ECP and the EOC are limited to the approval and release of large corporate funds or resources, and the development, approval, and release of information

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to the news media (see Figures 1 and 2). The auditors noted that the RERP and EPIP's indicated that the overall command responsibility of the PSC response organization rested with the Corporate Emergency Director (CED) at the FC However, upon review of the responsibilities of that person and the support groups he had at the FCP, the auditors determined that the real direction of the emergency responses was performed by the TSC Director in the onsite TS During discussions with the station personnel, the auditors determined that there was no formal designation of authority for the emergency response personnel to perform their assigned responsibilities, nor was there any formal and documented assignment of persons to the emergency response organization other than the call lists in the RERP, The auditors also determined that formal selection and qualification criteria, and formal training for each emergency functional area, had not been established to govern the assignment of personnel to emergency functions or duty positions. The RERP and EPIP's indicated that certain emergency functions such as chemistry, first-aid, repair / corrective actions, etc., would be performed by teams assembled from a manpower pool of various technical specialties at the PCC. The auditors further noted that the manpower pool relied upon may not be available when needed since site evacuation could result in their having already left the plant sit l An evaluation of the findings in other areas of the licensee's emergency preparedness program indicated that, although the various individuals who may be called upon to perform emergency functions did, in general, possess a 4 fundamental knowledge (based upon their normal job functions) sufficient to

enable them to perform their assigned emergency duties, the licensee's organizational structure in conjunction with the failure to make functional responsibility assignments down to the worker level had resulted in a failure to achieve a proper degree of internal coordination necessary for the development and implementation of an adequate progra .2 Augmentation Organization Augmentation of the onsite and near-site licensee emergency organization was addressed in sections 5, 6, and 9 of the RERP, the FSV Medical Emergency

Plan, and the PSC Public Information Manual. The auditors reviewed the content of those documents and the appropriate sections of the EPIP and other FSV procedures, and held discussions with licensee representatives to verify that i

the corporate organization, which would augment the onsite emergency organization, had been defined; that interfaces among the corporate organiza-tions~and the station organization had been delineated; and that the identified corporate functions were consistent with the licensee's overall emergency response organization, the procedures which implement the emergency plan, and guidance contained in NUREG-0654, Revision The auditors determined that a corporate augmentation organization and a recovery organization had been identified and persons informally assigned to those organizations. The auditors also determined that, although there were provisions within the corporate organization for the various emergency

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. functions to be performed, overall coordination of the descriptions of the functions to be performed by the station organization with the descriptions of the functions to be performed by the corporate organization was not adequat The RERP and EPIP's lacked the unambiguous definitions of responsibilities and authorities similar to the treatment found in the Public Information Manual for exampl The auditors also determined that the corporate individuals who would be members of the augmentation organization did possess work experience in the general types of duties of their assigned functional areas, but that again no specific selection and qualification criteria had been established to govern the assignment of individuals to emergency response duties. The auditors also noted that the licensee had made provision for 24-hour per-day coverage of the HP function in the TS The auditors reviewed the licensee's provisions to use outside contractors and private support organizations during emergencies and noted that the licensee had identified such potential groups and had obtained general letters of

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agreement with those organizations. The auditors determined, however, that the licensee had made no further specific planning as to exactly how or by whom such groups would be contu.ted, used, coordinated, and their authorities, responsibilities or lientts of actions established. Where nonlicensee groups were relied upon to provide emergency response, the working interfaces between the functional areas of emergency activity of the licensee's organization and the nonlicensee groups were not describe The auditors did note that the licensee had made provisions for the use of local services such as fire, ambulance, and hospital service .3 Conclusions and Determinations Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

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Unambiguously define the authorities, responsibilities and duties of all individuals, down to the working level, assigned to the licensee's emergency organization (267/82-01-11);

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Develop a program for training individuals who are assigned emergency l action responsibilities which will enable them to attain and maintain a state-of-the-art knowledge in the field of their assigned emergency action areas (267/82-01-12);

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Include a list of approved licensee personnel (by name) in the EPIP who have been selected and are qualified to perform activities within the functional areas of the licensee's emergency organization to which they are assigned (267/82-01-13);

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Develop and implement specific selection and qualification criteria for all individuals assigned to perform emergency actions and decisionmaking (267/82-01-14);

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Develop quality assurance procedures to evaluate the effectiveness of the 1 emergency action training for the various functional areas (267/82-01-15);

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Develop and implement an unambiguous description of the line of succession for the EC position, including formal criteria to govern the transfer of the position and the notification of emergency workers of such a transfer (267/82-01-16);

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Develop and implement a method of formal assignment of all personnel in the emergency response organization down to the working level (267/82-01-17);

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Develop and implement procedures to ensure that all emergency response functions, as identified in Table B-1 of NUREG-0654, Revision 1, will be performed in the CR until the other emergency centers are manned and operational (267/82-01-18);

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Correct the RERP and EPIP's to properly reflect the true nature of the FCP and the TSC relationship and the authorities and responsibilities of their respective directors (267/82-01-19);

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Specifically identify in the EPIP's, those actions assigned to the EC (ultimately the Corporate Emergency Director) which may not be delegated to other emergency workers (267/82-01-20);

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Develop and implement specific procedures to govern the use and coordination of all outside support organizations and contractors during emergencies (267/82-01-21); and

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Correct the RERP and EPIP's to unambiguously identify the authorities, responsibilities, and limits of actions of the corporate, contractor, private organizations, and local services support groups during emergencies (267/82-01-22).

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3.0 TRAINING / RETRAINING 3.1 Program Established The auditors reviewed the RERP, EPIP's, FSV Administrative Procedures (AP's),

FSV Training Program Administrative Manual (TPAM), FSV Health Physics Manual (HPM), FSV Health Physics Procedures (HPP's), and the FSV Radiochemistry Manual (RCM). The auditors also reviewed available lesson outlines, training records, GET video tapes, GET brochures and lesson handouts, and interviewed the Training Supervisor, FSV supervisory personnel, station personnel and corporate personne The auditors determined that the licensee's emergency training program con-sisted of a requirement that ". . . station personnel who actively participate in emergency situations are familiar with the contents and responses set forth in this RERP." This requirement was supposed to be fulfilled by

" Training and Annual Retraining" (RERP 8.1.1). RERP Section 8.1.1 referenced TPAM, Sections 4.0 through 4.5, for delineation of specific training and where applicable, " qualification requirements," for key members of the station emergency response organization. Section 4.0, " Situation Response Training Program," of the TPAM covered the requirements for onsite emergency organiza-tion training and health physics qualified personnel trainin To be health physics qualified required: 1) fire fighting training, 2) first-aid training, 3) job-related health physics training, and 4) respirator trainin Also within Section 4, TPAM, was Table 4.1.1, " Station Personnel Emergency Organization Assignments and Training for Support Personnel," which listed the various " emergency centers," personnel to staff them, and the training for those staffs. Under the training needs, reference was made to Form G-8,

" Emergency Directors and Coordinators Training," and Form G-9, " Fire Brigade Team, Medical Response Team and Radiation Survey and Monitoring Team Training."

Each of those forms contained a variety of subjects (e.g., calculation of onsite and offsite dose rates) that the respective personnel were to be trained i However, the auditors determined that, for most of the subjects listed, there were no lesson plans, handouts, acceptance criteria or level of proficiency required. None of the above references listed any requirements for emergency training of health physics (HP) technicians, radiochemistry (RC)

technicians, radiological environmental survey and monitoring teams, or other specialized technical suppor The auditors noted an apparent discrepancy between RERP Figure 8.1-1 and Forms G-8 and G-9 of the TPAM. For example, Figure 8.1-1 specified that the radiological monitoring team did not receive training in "Off-Site Support" or in " Transportation of Injured and Contaminated Personnel." However, Form G-9 required training for the team in "Off-Site Emergency Organizations," " Medical Response," and " Radiation Monitoring Drills." Within those drills, the radiological monitoring teams were required to simulate monitoring contaminated victims and escorting them to the hospital, as required by RERP 6. (Although RERP 6.5.3 did not specify who would be required to accompany the victim, the auditors were told by the licensee that it would be an HP technician.)

The RERP did not specify training requirements for the offsite emergency organization. It did reference the TPAM, which contained Section 4.6,

"Off-Site Emergency Organization Training." It should be noted that section 4.6 was not listed in the Table of Contents of the TPAM, but was located by

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the auditors after reviewing the entire manua The auditors determined that annual training had been provided to PSC corporate personnel as described in Table 4.6.1, TPAM, which referenced Form G-8, TPAM. However, discussions with corporate personnel revealed a general unfamiliarity with the specifics of the-RERP and their respective responsibilities.

The licensee provided annual RERP retraining to local support service groups.

The Training Supervisor stated that this training included classroom lectures, videotape presentations, and group discussions. The subjects included types of accidents, accident response by PSC, radiation safety, radiation instruments, handling contaminated victims, station layout, equipment location, and additional FSV fire-fighting peculiarit However, the auditor noted that the licensee did not have formal lesson plans with clearly stated student performance objective ,_

The auditors were informed b'y~the Training Supervisor that instructors were hired without the use of established selection criteria. However, he also stated (and it was verified) that only' licensed instructors were used in teaching specialized subjects (e.g., reactor. operators and fuel handlers).

The auditors noted that-the licensee did'not require routine training for the training instructors.

Station management stated that the' selection criteria for assignment to the situation response teams were the' individuals' routine job requirements.

In most cases the job requirements also included a commitment to ANSI N18.1-1971,

" Selection and Training of Nuclear Power Plant Personnel." However, to be appointed an Emergency Director, the individual did not have to have specialized training or demonstrate a specified skill leve He only had to have, or be promoted to, a job listed in Section 4.1.1.1.1, " Emergency Directors and Coordinators Qualifications," TPAM. Once in that position, the TPAM requirements specified that he must complete annual training listed on Form G-8,'TPAM.

Based on this system, an individual could be called upon to perform the job of Emergency Director before he received the specified training (see section 2.0 of this report).

The licensee's initial general employee emergency training program consisted of training in the following areas: fire fighting, first-aid, health physics, respiratory protection, and quality assurence (QA). Of those five 8-hour courses, only QA and first-aid required a written examination. However, respiratory protection and health physics did require a physical demonstration of the student's ability to don respirators and handle survey instruments.

Each of the five courses had provisions for documenting: the name of the attendees, the date, lesson title, and the instructor's name.

While attempting to locate various training records, the auditors determined that there was a lack of continuity between the training records. The files that contained the Forms G-8 and G-9 (TPAM) were not up to date and contained conflicting information with other department file The auditors were told by the licensee that part of the problem was that the Forms G-8 and G-9 were not correct and needed revision. Additionally, the magnitude of the separate files maintained in the training office appeared to contribute to the failure to keep all files curren i

Training on emergency duties and responsibilities of station personnel was covered by a self-review by the station personnel of the emergency plan (RERP)

and implementation procedures (EPIP's), or by short presentations by some department heads. The reactor operators, for example, participated in a practical demonstration of some of their emergency duties. Specifically, all of the operators.were taught how to use the TI-59 calculator in performing offsite dose calculations and were required to solve a practical problem to demonstrate their understandin I The auditors discussed training with several reactor operators and determined I that their understanding of health physics and emergency action levels )

indicated a need for additional formal trainin :

l The auditors also determined that the HP and RC technicians did not receive specialized emergency-training (e.g.,'postaccident coolant sampling and analysis). It was also noted that the current training program for HP 1 technicians did not contain criteria upon which to base a determination '

of proficienc Discussions with senior HP technicians revealed that the method used to determine junior HP technicians' proficiency in performing various tasks varied depending on the senior HP technician conducting the verbal examinatio !

The auditors determined that the licensee performed quarterly training and exercises for the FSV fire brigad They also performed semiannual medical exercises, which included an annual exercise with St. Lukes Hospital in Denver,

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Colorado. The licensee's performance in these exercises was considered adequate. However, the auditors determined that the St. Lukes Hospital staff had not been trained by the FSV HP staff in handling severely contaminated victim The news media had not been trained or received a familiarization session in health physics; however, the Training Supervisor stated that the training had been offered to the local medi The general public within the 5-mile EPZ had received an emergency information brochure. This brochure described the action to be taken in the event of an acciden The auditors determined that the licensee's method for training new employees allowed a considerable time lag (greater than 5 months) between their reporting date and receiving health physics qualification trainin The cause of the time delay was attributed to the class only being offered once every 3 month Under this system, the new employee could have been put in the position of donning anticontamination clothing, handling unfamiliar radiation protection instruments, and entering a radiation zone before having been trained on any of these area The auditors also determined that the security force did not receive health physics or respiratory protection training. They did receive GET, first-aid and fire fighting training from their own company; however, in the event of a radiological emergency, the guards would not be qualified nor trained in donning or wearing respirators or other protective items, i

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3.2 Program Implementation The TPAM specified the requirement for GET in emergency response under section 4.1.1.1, which listed the initial and annual retraining subject That section required annual GET retraining; however, section 2.2, TPAM, only required GET retraining every 2 years. The auditors determined, through a review of training records and personnel interviews, that the GET retraining for PSC employees was conducted annually and biennially for non-PSC employees. The auditors reviewed the lesson outline and overhead viewgraphs for the last annual GET retraining and determined that the lecture notes were adequate to cover the various types of radiological emergencies. Discussions with several PSC employees verified that they were aware of their assembly and accountability responsibilities during an emergency, but that they were not generally aware of the specific provisions of the RERP and the EPIP's (see section 2 of this report).

Training for revisions to the RERP and EPIP's was accomplished by individual review of the new documents. Verification that all employees had read and understood the changes was accomplished by only routing a signature sheet to each department supervisor. Upon questioning the department supervisors, the

auditors determined that classes were not conducted, rather the signature sheet was merely routed to everyone to sign. The supervisor ensured that all of his employees had signed the sheet and then returned it to the Training Departmen The latest edition of the EPIP was distributed without training the responsible personnel in changes in their dutie . .

3.3 Conclusions and Determinations _ '

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Based on the findings' in the above area, improvements in the following areas s;.culd be considered in order to achieve an adequate program:

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Establish and implement a formal radiological em'ergency response training l

program to provideispecialize'd training and annual retraining for all individuals assigned to each of the; functional areas of the emergency

'

organization.(267/82-01-23); '

--

Provide in the new 'training program: formal classroom instructions and practical demonstration drills; walk-throughs; formal lesson plans; and a means of evaluating student performance i.e., written tests as well as evaluations of individual performance in drills and walk-through Lesson plans shall include student performance objectives (267/82-01-24);

'

--

Develop and implement a formal training program to familiarize all site employees with the changes in the RERP and EPIP's if and when substantive changes are made to the respective responses by individuals assigned to the emergency organization (267/82-01-25);

--

Revise the TPAM to include the new section 4.6, to remove the redundancy between the sections, and to revise Forms G-8 and G-9 to reflect the current training (267/82-01-26);

i

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Rectify the discrepancy between the training requirements of RERP, Figure 8.1-1, and TPAM, Forms G-8 and G-9 (267/82-01-27);

- . . --_ - -

--

Rectify the discrepancy between the training requirements of TPAM Section 4.1.1.1 and Section 2.2 (267/82-01-28);

--

Develop and implement formal training. requirements for the offsite emergency response organizations and specify those requirements in the RERP and EPIP's (267/82-01-29);

--

Develop and implement formal training lesson plans which clearly state student performance objectives for local support service groups (267/82-01-30); ,

--

Develop and implement formal s' election criteria to be used in selecting training instructors (267/82-01-31);

--

Develop and implement a written examination for the health physics GET *

(8-hour class) (267/82-01-32);

--

Have a member of the health physics department conduct an annual formal training program for St. Luke's Hospital emergency response staff

.

(267/82-01-33);

--

. Develop and implement a formal emergency training program for HP and RC technicians (267/82-01-34);

--

. Develop and implement acceptance criteria to be used in evaluating junior HP technician proficiency (267/82-01-35); and

,

--

Establish a method for ensuring that new employees cannot enter a radiation zone prior to receiving HP training (267/82-01-36).

l l

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4

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- 16 4.0 EMERGENCY FACILITIES AND EQUIPMENT l

4.1 Emergency Facilities

4.1.1 Assessment Facilities 4.1. Control Room (CR)

The auditors reviewed sections 7, 8, and 10.E of the FSV RERP, HPP-37, and toured the CR located in the turbine building. The auditors noted that the brief description in the RERP of the CR stated that, "The CR contains full

'

plant instrumentation, technical drawings, protective breathing apparatus, i radio, telephone, and intercom systems. Emergency radiological monitoring i equipment and protective clothing are located nearby."

'

The auditors determined that there was a copy of the RERP, dated February 10, 1981, and an updated copy of the EPIP's, dated January 4, 1982 in the CR. The auditors noted that the EPIP was not the same document that had been previously

docketed with the NRC. Further, the auditors determined that the CR personnel had not been trained as to the changes in the new documen '

,' The auditors also determined that there were no emergency kits or portable radiological monitoring equipment located in the CR; however, the auditors did i note that the CR was equipped with a gamma area radiation monitor. The auditors determined there were two air supply lines with three connectors on each line in

'

,

the CR, and that there were three full-face masks with air hose Further, it

'

was noted that during an emergency as many as nine persons may be in the CR-(see section 4.2.2.1 of this report).

.

l The auditors noted that there was a permanent area radiological monitor

'

located in the.CR, and it had both a-local and remote-alar The auditors

, determined that.the CR did not have a dedicated radiological-airborne i activity monitor. The auditors determined that the CR HVAC would be automatically transferred from its normal mode of using outside air as its j source, to a recirculation mode, upon receiving a high-activity signal from the installed stack area radiation monitor. .The auditors also determined

that there was no other dedicated emergency equipment located near the CR; e.g. ,

i self-contained breathing apparatus (SCBA), spare air hoses, tools, anti-Cs, etc.

Based on the findings in the above area, improvements in the following l- areas should be considered in order to achieve an adequate program

!

l

--

Provide a continuous monitor, with-both visual and audible alarms, for detecting airborne radioactivity in the CR (267/82-01-37); and

! ---

Provide dedicated emergency portable radiological monitoring equipment and protective clothing in the CR (267/82-01-38).

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. _ . _ , _.. _ . _ _ _ , _ . _ _ _ - _ . _ , . _ _ . , , _ . - _ - _ _ . , _ , . _ _ _ _ _ _ _ _ . . . , , _ _ . _ _ _ , . , _ _ . - , -

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .

4.1. Technical Support Center (TSC)

The auditors reviewed the FSV RERP section 7.1, the TSC section of the EPIP's, and toured the TSC located east of the turbine building.

The auditors determined that the travel time to the CR was approximately 2 minutes.

The auditors noted that the RERP did not list the documents, instruments, communications equipment, or other emergency equipment which was dedicated for use in the TSC. The auditors noted that the TSC did have copies of the State Emergency Plan, RERP, EPIP's, Administrative Procedures Manual, Final Safety Analysis Report, Operating Procedures, Reference Design Book, HTGR Technology Course, and Instrument Lists. The auditors noted that the TSC did not contain a dedicated copy of the HPP' Further, the auditors noted that the TSC contained six desks, two tables, three chairs, two bookcases, and one file cabinet.

The auditors also noted that there were 10 telephones located in the TSC and determined that two of those telephones were the NRC Emergency Notification System (ENS) and the NRC Health Physics Network (HPN) telephones. The auditors performed a telephone check on both NRC systems and determined that they were operating; however, the HPN telephone had very poor quality and the Region IV office could not understand the auditor's conversation.

The auditors further noted that there were two Contac Cathode Ray Tube (CRT)

display repeaters mounted on the wall which were driven by a double-screen

"Two-on-One" computer-based safety parameter display system (SPDS). The auditors determined that this system was not fully operable at the time of the appraisal but the licensee indicated that it would be operational to a point of being able to perform dose calculations using real-time meteorological data within 1 to 3 months and that the full SPDS would be operational within 1 year.

The auditors determined that the TSC had a ventilation filter system equipped with HEPA and charcoal filters, but that the entire system had not been installed; e.g. , radiation detection instruments for the recycle air damper control system had not been installed.

The auditors determined that there were no radiological monitors *.o detect and indicate exceeding a preset level, with both audible and visual atarms, for either airborne activity or direct radiation in the TSC.

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate prograa:

--

Provide radiological monitoring equipment in the TSC to detect and indicate, by both audible and visual alarm upon exceeding a preset limit, both radioactivity and direct radiation (267/82-01-39);

--

Provide adequate respiratory protection equipment and protective clothing for all emergency personnel in the TSC (267/82-01-40);

.- ._-______---_____ _ __-__

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

--

Develop and implement a specific listing of all emergency equipment and supplies necessary for the full activation and operation of the TSC i

(267/82-01-41); and l

--

Complete the full installation of HVAC system for the TSC, including the necessary detectors had controls to initiate damper and full filter operation during emergencies (267/82-01-42).

4.1. Operations Support Center (OSC)

The auditors reviewed sections 6 and 7 of the FSV RERP and ADM-09, and toured areas indicated in the RERP NUREG-0654 cross reference as being the licensee's OS The auditors determined that the licensee had a primary assembly plan in which the persons at the site would assemble at their " emergency stations" and, after personnel accountability had been completed, the people would wait at their station until contacted by their management. If the situation required, the nonessential personnel would leave the site and essential personnel would report to their emergency centers, if assigned, or would report to the PC The auditors determined that there are approximately 17 emergency stations (assembly areas) (see sections 5.4.3.2 and 5.4.3.3 of this report).

The auditors noted that there were two areas designated as the PCC's and that personnel will report to one of the two centers, depending on the wind direc-tion, af ter accountability if so directed by the Shift Superviso The auditors also noted that the QA/ Engineering PCC was outside of the protected area (security) and the onsite warehouse PCC was inside the protected area (security).

The auditors reviewed two procedures referenced in the RERP: ADM-09, Rev. 1, dated December 6, 1974; and GP-13 (which has been revised and replaced by the G-XX series procedures which should be used). The auditors determined that the primary phone number for reporting accountability was not consistent in the above procedure The auditors further determined that, should the two onsite PCC's become uninhabitable, there were three designated offsite areas which could be utilized. The preferred offsite location was the Johnstown County Shops. The RERP did not address the location of the Johnstown County Shops or the names and location of the other two alternate site The auditors determined that the two onsite PCC's did not have permanent radiation detection instrumentation with visual and audible alarms for both radioactive air activity and direct radiation in order to determine their habitability during emergencie _ _ _ _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

. -.- -- - . . . .__ ._- . . . - - - -

i

i

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Based on the findings in the above~ area, improvements in the following areas

should be considered in order to achieve an adequate program:

--

Revise the RERP and EPIP's to reflect the names, locations, and routes to the alternate PCC(s) (267/82-01-43);

--

Provide radiological instrumentation in the onsite PCC(s) to detect and

'

indicate, by audible and visual alarms upon exceeding a preset level, both airborne radioactivity and direct radiation (267/82-01-44); and

~

--

Correct the RERP and EPIP's to specifically identify all " emergency stations" and "PCC's" (267/82-01-45).

.

4.1.1. 4 ' Emergency Operations Facility (EOF)

The auditors reviewed section 5.4.1.a of the FSV RERP and discussed the present location of the Emergency Operations Facility (Forward Command Post) with the

.

'

EPC. The auditors noted that a new facility had been constructed in the old garage of the Fort Lupton PSC offices. The auditors visited the EOF and noted the installation of three telephones and the presence of fourteen additional telephones. The auditors determined that the EOF had copies of'the following documents: the Administrative Procedures Manual; Medical Emergency Plan; RERP

Station; RERP Plant; RERP State; and the Technical Specifications. The auditors

noted that the State and Federal agencies had predetermined areas; however, th auditors also noted that the NRC ENS and HPN telephones had not been installe ! The auditors did note that the space available for all agencies' response personnel appeared adequat Based on the findings in the above area, this portion of the licensee's program

,

appeared to be adequate.

,

4.1.1. 5 Postaccident Sampling and Analysis

!

4.1.1.5.1 Postaccident Coolant Sampling and Analysis i The auditors reviewed the facilities and equipment for primary coolant gas i sampling and analysis during emergencies and determined that they would be

[ accessible during an emergency.

c The auditors noted that the beta radiation present in the primary coolant gas (helium) was monitored by a beta scintillator which was immersed in the primary coolant gas. The range of this instrument was from 2.4E-7 to 2.4E-1 uCi/cc.

!

The instrument had readouts in the CR where the radiation levels were recorded.

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_ _ _ _ _ . _ . . . _ _ _ _ _ _ _ _ . _ _ _ _ - - _ _ _ _ _ _ _ _ . . _ _ _ _ . . _ . _ ,

The normal radiation level present in the primary coolant gas was in the range of IE-2 to 1E-3 uCi/cc. Thus, the continuous monitor had a limited upper dynamic range and could be off-scale during an emergenc However, an area radiation monitor and an airborne radioactivity monitor in the analytical instrumentation (AI) room allowed the sampling technician to obtain advanced information concerning radiological conditions in the AI room prior to entr The valving procedures for sample acquisition were described at the sampling location. There was also a flow diagram on the panel and a schematic diagram on the desk. The flow into the system was measured by a flow meter located at the top of the panel which was about 6 feet from the sampling port. The volume of this line was estimated at less than 10 ml and the normal radiation level measured on the line was less than 1 mr/h The auditors found that the sample system was set up to take samples of 2 ml during emergencies. The use of 12-inch tongs to handle the sample made the whole-body dose the limiting dose. A cask to shield the sample was available and the sampling system could be isolated from the CR. A 1-minute purge at a rate of 100 ml/ min, was adequate. The time required to take the sample and transport it to a pneumatic rabbit tube was less than 3 minute A representa-tive sample is obtained as long as the gas coolant circulates by the sample por The auditors concluded that the facilities and equipment were adequate to result in radiation doses that ara ALARA. The sample analysis facility, located under the TSC, had a separate outside entrance to the plant yard and may be accessible under accident condition Based on the findings in the above area, this portion of the licensee's program appeared to be adequat .1.1.5.2 Postaccident Containment Atmosphere Sampling and Analysis l The auditors reviewed the design basis accidents for FSV and the reactor building air sampling facilities. FSV does not have a containment structure and the airborne concentrations within the reactor building would not be high i as compared to LWR's. The design review (FSV Letter P-79312) indicated a l maximum dose rate of about I rem /hr during a loss of circulation accident.

'

This dose rate does not require fixed high-activity air sampling facilitie The licensee was preparing to place portable continuous air monitors in operation when necessar Normal portable grab-sampling equipment was also availabl Facilities for analyzing air samples are discussed in section 4.1.1.5 of this repor Based on the findings in the above area, this portion of the licensee's program l appeared to be adequate.

!

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l

4.1.1.5.3 Postaccident Stack Effluent Sampling and Analysis The auditors reviewed the facilities for sampling effluents from the plant stack. The sampling and measurement stations are in the turbine building in the vicinity of the main filter bank This area could have the highest dose rates in the plant during an acciden The RT-7343 and RT-7325 sampling locations and the RT-4801/02/03 channels were not adjacent to the filters, but the high-range vent monitor (portable survey meters) was adjacent to the filter

'

ban However, the FSV accident analysis for NUREG-0578, item 2.1.6.b (see FSV letter P-79312), indicated that the peak radiation doses from the filters would not be reached until several weeks after the accident. By this item, effluent release rates would be significantly reduced from earlier levels due to radioactive decay of short-lived volatile specie During the postaccident

period when environmental monitoring is not available, the effluent monitors

'

would be accessible. A high-range area monitor was adjacent to the main filter banks. A shielded sample container and handling tools are kept in the HP offic The licensee did not demonstrate that the facility for high-range stack monitoring was adequat This facility consisted of a collimator fabricated of lead bricks and two survey meters. The collimator was able to receive an ion chamber from either of two portable ion chamber survey meters that are reserved for the requiring measurement. The measurement location was adjacent to the main filter bank The licensee did not demonstrate that direct radiation from the filters would not interfere with the measurement. The auditors did not determine that the present facility was adequat The RT-7324 effluent monitor has a range of 5 mci /cc and the accident analysis in P-79312 suggested that the maximum noble gas concentration could be SE-2 mci /c However, the RI-7324 monitor is not calibrated for a mixture of short-lived noble gases. The auditors did not conclude that the RT-7324 monitor was an adequate high-range noble monitor. However, a monitor with a range to 5 mci /cc of noble gases would be acceptable at FS Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

--

Demonstrate that a fixed monitor has a range of at least 5 mci /cc of mixed noble gases and that ambient radiation fields will not interfere with this measurement (267-82-01-46).

- . _ _ _ _ _ _ , . _ . . _ ____ _ . . _ __ ___

- - . -- . . - . -

4.1.1.5.4 Postaccident Liquid Effluent Sampling and Analysis The auditors examined the liquid effluent sampling facilities discussed in section 4.1.1.5 of the RERP, and noted that the sampling points for the liquid waste discharge tank and the reactor building sump were accessible during accident conditions. Area radiation monitors were well placed and the holding tanks were shielded. As the reactor core was not water-cooled, these liquid wastes are primarily derived from secondary systems. Shielded containers and remote handling tools were not reserved for use in taking these samples. The auditors determined that the sampling technique should give a representative sample.

Based on the findings in the above area, this portion of the licensee's program appeared to be adequate.

4.1.1.5.5 Offsite Laboratory Facilities The auditors reviewed provisions in the FSV RERP for the use of offsite laboratory facilities in the event that the FSV radiochemistry laboratory becomes unavailable during emergencies. The FSV staff had identified a laboratory at the Department of Radiology and Radiation Biology at Colorado State University in Fort Collins, Colorad This laboratory currently performs environmental sorveillance measurements for FSV and presently maintains dedicated instruments. The calibration and operability of the instruments and the performance of the laboratory are audited by FSV.

The auditors reviewed the results of QA audits that FSV had performed to verify the adequacy of the laboratory facilities and programs at the Ft. Collins laboratory. The auditors examined QAC-81-0458, the 1981 audit report, and additional internal appraisal reports. The auditors concluded that the QA program provided a thorough audit of FSV's contractor laboratory. The audit findings indicated that the Ft. Collins laboratory maintained, calibrated, and routinely checked its instrumentatio The FSV audit results do not disclose whether the Ft. Collins laboratory has prepared calibration procedures that are appropriate for the activity level anticipated in FSV's postaccident sample The auditors examined followup items CAAR-314 and CAAR-315 and determined that the Ft. Collins laboratory had corrected deficient items by investigating and correcting out-of-tolerance analysis and providing a formal calibration frequency schedule.

The auditors reviewed Table II G.4 of the environmental surveillance report for the first and second quarter of 1981. This table gave results of the three-way sample split program among the FSV, Ft. Collins laboratory, and the Colorado Public Health Laboratories. The auditors noted that error bounds for the analysis were not reported and that the Ft. Collins laboratory had not provided results that diverged systematically from the other two reports.

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop and implement a procedure for transferring appropriate secondary and/or primary calibration sources from the FSV radiochemistry laboratory to the Ft. Collins laboratory in the event that the FSV laboratory is not functional during emergencies (267/82-01-47); and

--

Develop and implement procedures to transfee postaccident samples from FSV to the Ft. Collins laboratory, which meet all applicable State and DOT transportation regulations (267/82-01-48).

4. Protective Facilities 4.1. Assembly / Reassembly Areas s The auditors reviewed the contents of the FSV RERP, dated February 10, 1981; the EPIP's, dated January 4, 1982; the FSV Emergency Procedures Manual; the FSV Administrative Procedures; and held discussions with plant personne ,,

The auditors determined that there were no provisions available for assembling or sheltering onsite personnel as intended by the guidance set forth in NUREG-0654, Revision 1.

FSV EPIP, " Visitors Center Procedure," specified evacuation of offsite personnel at the visitors center upon activation of the RERP.

FSV RERP Section 6.4 specified that, "on-site actions to protect station personnel and visitors are the responsibility of the Shift Supervisor (as Emergency Coordinator) until he is relieved."

The auditors noted that there were currently two FSV Administrative Procedures available (ADM-09 and G-5) that provide for assembly and accountability of onsite personnel. These procedures provide for onsite personnel to assemble at 17 individual " emergency stations" located throughout the station. The auditors reviewed those assembly stations and determined that the CR, HP.

office, and the two areas designated as the PCC's were the only assembly sta-tions that had any provisions for personnel monitoring and limited respiratory protection.

The auditors noted that section IV.B of the introduction of the FSV emergency procedures specified that, "All personnel, upon hearing the alarm, shall report immediately to their preassigned emergency station for accountability and further instructions."

Based on the findings in the above areas, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop and implement procedures in the EPIP's that will specify the locations of emergency stations, assembly and reassembly areas for all onsite personnel (267/82-01-49);

--

Develop and implement procedures that provide for relocation of onsite assembly areas to offsite assembly areas in the event of a site evacuation (267/82-01-50);

--

Provide radiological monitoring devices that will indicate at each emergency station or assembly area, the radiological conditions for the emergency station or assembly area; e.g. , radioactive air monitors and gamma monitors which will give both visual and audible alarm upon exceeding a preset level (267/82-01-51); and

--

Provide respiratory protection and anticontamination clothing for all persons remaining onsite after the declaration of an emergency (267-82-01-52).

4.1. Medical Treatment Facilities The auditors reviewed the contents of sections 6.5.2, 7.5, and 10.E of the FSV RERP, dated February 10, 1981; FSV HPP-37; the FSV Medical Emergency Plan, dated December 31, 1981; and held discussions with station personne Sections 6.5.2 and 7.5 of the FSV RERP addressed the existence of first-aid facilities onsite and that first-aid kits were available at other onsite location No reference was made to where these onsite first-aid kits were located. Section 10.E or "'- FSV RERP listed emergency kits, protective equipment and supplie V Medical Emergency Plan provided information -

on evacuation of injure, .a contaminated personnel to offsite medical facilitie The first-aid facility was located on level 7 of the turbine building, inside the health physics access control area, adjacent to the personnel decontamina-tion showers. The facility had direct access to the reactor, building approxi-mately 60 feet away from the CR on the same level. The auditors toured the facility and determined that_ access was normally achieved via a circuitous route through the HP office area and that the door providing immediate and unobstructed

. access directly into the facility was blocked by personnel lockers in an x adjacent area. The auditors noted that the medical equipment'and supplies refererced in the FSV RERP were the same as used for routine daily use and that

,

not all of the equipment was under inventory contro The auditors noted that there were sufficient first-aid supplies presently available and operating personnel monitoring equipment available with backup equipment nearb The auditors determined that there were no emergency medicalsprocedures available at the facility and that the HP personnel yere not cognizant of requirements contained within the FSV Medical Emergency Pla The auditors noted that there were readily available, in the facility and adjacent HP office, decontamination procedures. The auditors determined that the facility was accessible to rescue personnel bearing victims on stretchers and that the decontamination shower was

,

of sufficient size to accommodate victims on stretchers. The auditors also noted that there were no thyroid blocking agents available.

~

Based on the findings in the above area, improvements in the'following areas should be considered in order to achieve an adequate program:

--

Provide direct, immediate, and unobstructed access to the first-aid facility (267/82-01-53);

s

%

. . .

.

.

• L /

25'

. a. v ' l *

- :, 'h

• *

/

,

/ y i

--

Develop and implement procedures that ensure that dedicated firr,t-aid equipment is controlled by a documented inventory program (267/82-01-54);

--

Provide and maintain up-to-date'FSV medical emergency procedures in the first-aid facility (267/82-01-55); and

--

Incorporate the provisions of the FSV Medical Emergency Plan into the FSV RERP and EPIP'S (267/82-01-56).

4.1. Decontamination Facilities -

.

The auditors reviewed the contents of the FSV, RERP, dated February 10, 1981; the EPIP's, dated January 4, 1982; FSV Health Physics % ocedure - HPP-11; the NRC Office of Inspection and Enforcement,Hea~1th Physics Appraisal Report for FSV (Report No. 50-267/80-13); and held iiscussions with station personnel.

Section 6.4.1.a.1 of the FSV RERP stated that, " Site Visitors inside the owner controlled area will be escorted by stat' ion personnel to the Security Building where they will be monitored for contamination and depart the site." Further, that " Contract personnel will exit via the Security Building, where they will be monitored for contamination . . . ." i Section 6.5.2 of the FSV RERP, " Decontamination and ~*

First Aid," stated that,

"There are personnel on-site who are trained in first aid and decontamination procedures." In addition, onsite decontamination areas'were equipped with decontamination facilities and other specialized equipment. Personnel found to be contaminated (any detectable activity above background) will undergo decontamination under the control of HPP' *

Section 7.1 of the RERP, " Emergency Control Centers," specified that d con-tamination equipment was stored at the two prospective PCC locations, 9 i

Attachment 7ofthePCCsectionoftheEPIP'scontainedaprocedureehtitled '

" Decontamination" and provided limited instructions on personnel decontamination.

HP-11, entitled " Personnel Decontamination," contained more detailed instructions ~

for routine personnel decontamination,' including the use of titanum dixoide paste and potassium per.nanganate for personnel decontamination.

The auditors toured the onsite PCC locations and noted the presence of anticontamination clothing and basic decontamination equipment; i.e., water-less hand cleaner, soap and water, towels, etc. The auditors noted that the decontamination kits were not provided with copies of the HPP-37 decontamination procedure, nor were there provisions for collecting generated radioactive waste.

The auditors observed the personnel frisking area at the security building and noted that the only personnel monitoring equipment available was a portable monitor which will not detect the levels of radioactivity specified in the FSV RERP; also noted was the absence of any decontamination equipment or instructions on what to do if contamination is detected during monitorin The auditors determined that current FSV procedures for decontamination of personnel were insufficient for emergency events in that they did not address the need to expeditiously separate personnel for decontamination, to prevent additional whole-body exposure, by contamination levels. The auditors also noted that existing procedures did not address control of solid and liquid wastes generated during emergency decontamination at areas other than the station's permanent decontamination facility.

The auditors toured the personnel decontamination area located at the HP office on level 7 of the turb'ne building. The personnel decontamination facilities consisted of a five person shower of sufficient size to allow a stretcher-borne person's access. The auditors noted that the shower floor slope was minimal and during emergency use water could escape the shower area and spread contamination to the first aid area adjacent to the shower facility.

The personnel decontamination facility contained two knee-operated sinks.

There was also a third knee-operated sink adjacent to the facility, in the reactor building access area. All decontamination sinks and showers had hot water and the auditors verified, by structural plan review, that all drains went to the reactor building liquid radioactive waste sump. The decontamina-tion area was also being used for the dirty anticontamination clothing laundry, as noted in the NRC HP appraisa The auditors noted that this decontamina-tion facility was the only area with provisions for the use of extensive and special decontamination procedures.

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop and implement specific procedures, for use at all assembly areas, which govern the radiological monitoring and decontamination of large groups of personnel during a station emergency (267/82-01-57);

--

Upgrade personnel monitoring procedures and station training to ensure that all station personnel are aware of the limitations of personnel monitoring equipment, and the proper procedures to be used to self-monitor themselves (257/82-01-58);

--

Include provisions for control of radioactive wastes during decontamination of personnel at all assembly areas (267/82-01-59); and

--

Provide cofferdams and shower curtains at the two entries into the personnel decontamination shower to prevent the unnecessary spread of contamination to the adjacent area during use (267/82-01-60).

4. Expanded Support Facilities The auditors toured the protected area facilities and those facilities located just outside the protected are The auditors determined that expanded demand for office space and equipment facilities during emergencies would require additional facilities; e.g., house trailer The auditors determined that initial recovery could be initiated.

Based on the findings in the above area, this portion of the licensee's program appeared to be adequat '

. _ _ _ _ ._ _ __ _ ._

>

4.1.4 News Center The auditors reviewed the contents of the RERP, the State EOC section of the EPIP's; the Public Service Company of Colorado, RERP Public Information Manual; and visited the State of Colorado Emergency Operations Center facility, located at Camp George West in Golden, Colorad The auditors noted that the FSV RERP and EPIP's did not contain specific and detailed public information responsibil-ities or' implementation procedures. This information was contained in the PSC RERP Public Information Manual which had not been docketed with the NRC as a part of the RERP and its EPIP' The State E0C was located in the State of Colorado's permanent emergency operations facility, located adjacent to Interstate 70, in Golden, Colorado, about 55 miles from the FSV plant. The public information provisions of the RERP were discussed with the Public Relations Staff at the PSC Corporate Offic The auditors visited the State E0C and met with the Director, Colorado Division of Disaster Emergency Services, and members of his staff. The auditors held

discussions with the PSC media relations staff and the State staff included such areas as: telephone service potential capabilities; electrical demands, news media space; and public information staff work areas for State, local, PSC, and NRC personne The E0C appeared adequate to accommodate over 300 news media representative Public Service of Colorado has provided a news media center in Ft. Lupton, Colorado, about 15 miles from the FSV plant, to accommodate approximately 50 news media representatives. The auditors toured that facility and noted that the Ft. Lupton center was also the FCP and the only provision to the news media there was for local media to obtain the latest information released from the State E0 Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

--

Incorporate the "RERP" Public Information Manual (PIM) into the EPIP's and docket the PIM as a part of the RERP and EPIP submittals to the NRC (267/82-01-61).

4.2 Emergency Equipment 4.2.1 Assessment Equipment 4.2. Emergency Kits and Emergency Survey Instrumentation The auditors reviewed the contents of section 6.2, 7.1, 8.3, and 10.E, as well as Tables 5.4.2 and 7.3.1 of the FSV RERP, dated February 10, 1981; FSV EPIP's dated January 4, 1982; HPP-37 HPP-56; the NRC Office of Inspection and Enforcement Health Physics Appraisal Report for FSV (Report 50-267/81-13);

and held discussions with station personnel, i

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i

Section 7.3 of the FSV RERP, " Emergency Control Centers," specified that, "The Personnel Control Center (PCC) is located in either the QA/ Engineer Complex or the onsite warehouse, depending upon the nature of the release and the prevailing wind direction. Emergency radiological monitoring equipment, first-aid and decontamination equipment, protective clothing, communications equipment, portable lighting, and protective breathing apparatus are stored in emergency kits at both locations."

Section 10, Appendix E, of the FSV RERP provided a listing of emergency kits, protective equipment, and supplies stored and maintained for emergency purpose The RERP indicated that an emergency kit was located in the PCC, CR, and the HP area. Also listed were supplies and equipment in the decontamination area, the first-aid room, as well as the emergency respiratory protection equipment available at the site. Within this appendix there was a gereric listing of equipment and supplies without regard to the specific types of equipment or the number, with the exception of the listing of respiratory protection equipment. It should also be noted that the list of respiratory protection

'

equipment did not include the air line equipment (e.g. , hoses and masks) by number, for the C HPP-37, " Emergency Kit Check List," provided a procedure delineating the requirements for inspection of the emergency kits. The procedure contained an inventory list of the contents for the emergency kits in two PCC sites and provided for a quarterly inspection of the specified emergency kits. The procedure also requires that the emergency procedures in the kits must be update Individual items were accounted for by name/ type and quantity and verification of current calibration on survey instruments. The PCC procedure in the FSV EPIP's specified (in pt agraph 1.2.3.1) that, " Emergency kits are stored at both the Engir eering/QA Complex and the GA Field Office laboratory."

'

The FCP procedure in the FSV EPIP's specified that an emergency kit is located at the FCP.

The auditors reviewed the locations and inventories of the specified emergency kits and determined that " official" emergency kits containing dedicated equip-ment only existed at the onsite warehouse, the QA/ Engineering Complex, and the HP area first-aid room. The auditors also noted that procedural inventory (HPP-37) was only provided for two PCC locations and that controls to prevent loss or general use of the emergency kit equipment was only employed for the kits in the QA/ Engineering Complex and the first-aid room. The auditors noted that the HPP-37 inventory sheets lacked the identification of the quantity of some items and listed some radiological monitoring and dosimetry devices in generic terms. The auditors determined that the quantity of radiological survey equipment and film badges at the kits were not sufficient for the number of personnel expected to be present in the PCC's or to supply offsite and onsite monitoring and emergency teams with the necessary equipmen The auditors also noted that the individual PCC staff instruction booklets had not been updned to reflect the January 4,1982, EPIP revision The auditors noted that the September 30, 1981, inventory of the emergency kit at the warehouse identified several items as missing; among the missing items were two portable radios to be used by the offsite radiological monitoring teams. As of the December 31, 1981, inventory, those radios had not been

. . . - . _ . - .

replaced or the inventory modified to reflect their disposition. The auditors noted that the two PCC emergency kits contained slide rules for making calcu-lations but that staff personnel were not trained in the use of slide rules and that hand-held calculators were routinely used for calculations. The auditors determined that sufficient emergency procedures were present in the emergency kits at the PCC's and at the HP area, even though no controls existed to ensure their presenc The auditors determined that the equipment located in the emergency kits was operable; however, while each PCC kit has a spare HP-219 frisker probe, the necessary tool (small Allen wrench) was not provided to facilitate replacemen Also, an HP-177 GM beta / gamma probe was provided for use on the R-14 ratemete '

The auditors determined that the design characteristics of that probe provided insufficientsensitivigytodetectradioactivityattheFSVadministrative limit of 100 DPM/100CM or less, and should not be used for personnel monitor-ing unless specific calibration and operational procedures are developed (see section 5.5.1 of this appraisal for identification of radiological survey equipment deficiencies).

The auditors determined that FSV did not have the capability to measure air-borne radioiodine concentrations at 1E-7 uCi/cc under field conditions and can only analyze radioiodine samples at the onsite radiochemistry laborator The auditors also determined that FSV could analyze airborne particulate concentrations at levels below 1E-09 uCi/cc under very limited conditions. The current FSV portable air sampling procedures did not provide sufficient instructions on the minimum detectable activity of the monitoring equipment in situations of high background radiation levels or how variations in sample volumes affect the minimum detectable airborne activity. The auditors noted that the FSV HP procedures restricted monitoring of whole-body dose rates to ion chamber instruments, but that the procedures did not specify whether or not beta / gamma distinguishing capabilities were required for such survey The auditors noted that there were no provisions provided for operationally checking portable radiation survey instruments (for response within a specified range when exposed to a known source of radiation) during periods between quarterly inventories anu prior to emergency use. The auditors also noted that instructions for the two radiation survey instruments stored at level 10 of the reactor building for in plant backup stack monitoring did not provide for operationally checking these instruments prior to us ,

The auditors noted that FSV had on station four 200 R/hr portable ion chambers (Eberline R0-5) and two 20K R/hr portable ion chambers (Eberline R0-7 with 7-foot extendable probes); however, the auditors noted that neither were usable due to manufacturer's recall on the R0-7's and the lack of operational and calibration procedures for the R0-5's.

'

The auditors also noted, during the review of the emergency kit inventories, that there were charcoal and silver zeolite cartridges present that had markings on them that indicated previous use, and that several of the other i stored charcoal and silver zeolite cartridges were not packaged to prevent exposure to moisture which might degrade their efficienc _ _

.., ._ ._ _ . _ . ,_ _- -_ , _

- - - - _ _ . . ._

,

Specific determinations on maintenance, source checks, and calibration are contained in section 5.5.1 of this repor Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

.

'

--

Revise and consolidate station procedures so that there is a concise nongeneric listing of all dedicated emergency equipment and suppliers and the quantity necessary to support all areas of endeavor during the highest classification of emergency event (267/82-01-62);

--

Develop and implement inventory procedures and emergency use procedures, and provide for operational checking of instruments prior to use (267/82-01-63); and

--

Develop and implement instructions for the proper storage and maintenance I

of charcoal and silver zeolite filters (267/82-01-64).

4.2. Area and Process Radiation Monitors The auditors reviewed the installed area and process radiation monitors.

] The licensee's response to the post-TMI requirements for containment monitoring had been partially addressed. In the FSV HIGR the reactor building, a confine-ment structure, was the nearest equivalent to a containment structur The licensee stated in a letter, PCC-81-2392, that the high-range area monitor that was on the east wall of the refueling floor (RT-93250-14) had been exchanged with the monitor (RT-93521) located near the reactor exhaust filters. The basis for this interim action was the design basis accident No. 2, rapid depressurization. The result of this exchange placed an area monitor with a range of 0.1 to 10,000 R/hr near the exhaust filters, leaving the reactor fuel floor level with an area monitor having a maximum range of 10 R/hr. The

, licensee had not committed to upgrading the area monitor for the refueling

{ floor to provide a maximum range of 10,000 R/hr by September 1982, although a higher range monitor had been ordered. There was also no permanent high-range monitor on the reactor building exhaust ven The auditors found that seven area monitors in the reactor building had local alarms, with readouts and recorders in the C Each instrument consisted of a GM tube mounted in a cabinet with a meter and local alarm circuit. In

! addition, four area radiation monitors of the same type were located in the turbine building, with readouts in the CR. All of these units have a built-in check source that can be exposed electrically and controlled from the CR to verify that the system is operable. The upper range of these instruments was *

, 10 R/hr and the lower limit of sensitivity appeared to be about 0.5 mR/hr.

'

This range is adequate because the auditors found that the area radiation monitors are designed to operate in the environment anticipated during an

,

'

emergency. The auditors found that the area radiation monitors were appropri-ately located.

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. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

The area and process radiation monitor calibration records were examined by the auditors and found to be current. The calibration schedule at FSV is computerized and backed up by a file card system. The record of each calibration was signed by the person doing the calibration, and by a member of the staff of the section responsible for the operation of the instrumen The auditors reviewed the radioactivity monitors for the liquid waste streams from the reactor buildin The trip setting for the monitor on the reactor building sump line was 1E-6 uCi/cc. A trip on the monitor diverts flow from the sump drain to the liquid waste system to prevent the composite liquid waste from exceeding IE-7 uCi/cc at the site boundary. A second monitor system, RT-2125/1, monitored the low pressure separator drain line and the trip setting was 10,000 cpm. When a trip occurred, the system flow diverted to the recycle mod The third system, RT-2263 and RT-2264, monitored the reheat steam con-densat Both trip settings were at 600 cpm; automatic diversion follows a trip. The fourth liquid monitoring location (RT-46211 and RT-46212) monitored the gas waste compressor. The trip was set at 1000 cpm and no autcmatic action was taken. All of these systems used sodium iodide gamma scintillation detectors.

l The auditors reviewed the steam header monitors (three detectors were on loop 1 and three detectors were on loop 2). The trip setting on these

'

monitors was set at 3 R/hr. In addition, PCRV relief valve piping was monitored by RT-93252-12 and the trip setting was 5 mr/h The auditors reviewed the gas monitoring systems which consisted of beta scin-tillation detectors that were immersed in the monitored air stream. Detectors RT-7324-1 and -2 monitored the reactor ventilation exhaust. The high trip was set at 77,000 cpm. A trip signal automatically diverts the exhaust to the gas waste tank and shuts down the turbine building ventilation system. This signal also begins recirculation of the CR air and closes the inlet air damper This system operates on noninterruptable powe The RT-7312 gas monitor monitored samples via five locations on a 7-minute cycl The trip was set at 1000 cpm and monitored the following locations:

PCRV bottomheads, analytical instrumentation room, health physics access point, CR, and the turbine dec The air ejector was monitored by RT-31193, located on the mezzanine of the turbine building, and had no automatic control action and the trip was set at 500 cp The primary coolant gas was monitored by RT-930 located in the AI roo Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

--

Install a high-range radiation monitor on the reactor refueling floor (267/82-01-65).

- __ _ _ _ ___ _ _____ _ -______

_ _ _ _ _ _ _ _

4.2. Nonradiation Process Monitors The auditors reviewed the process monitors described in the RERP and EPIP's that were used as a basis of detecting, classifying, and assessing emergencie The major process monitors were the coolant inlet and outlet temperatures, primary and secondary coolant flow, reactor building vent flow, and bus voltage meter These monitors were operable and had readily observable readouts located in the C Based on the findings in the above area, this portion of the licensee's program appeared to be adequat .2. Meteorological Instrumentation The basis for the auditors' review of the licensee's meteorological measurements program included Regulatory Guides 1.23 and 1.97, and the criteria contained in NUREG's-0654, -0696, and -073 The licensee outlined a description of their meteorological measurements program in section 7.3.1 of the FSV RERP. The integration of meteorological data into the licensee's dose assessment scheme was described as based on Regulatory Guide 1.14 The auditors determined that the licensee's meteorological capabilities addressed the requirements of NUREG-0737 Task Action Plan Item III.A.2, and the criteria set forth in Appendix 2 to NUREG-0654, Revision 1, in adopting the compensating measures to milestone The licensee had installed a 10-meter meteorological measurement system tower in conjunction with NOAA, Boulder, Colorado. The combination of the existing and recent installation provided the basis parameters (i.e., wind direction and speed, and, an estimation of atmospheric stability) necessary to perform the dose assessment functio The auditors determined that those systems provided the interim access from a primary and alternate data source. The installation of the planned 60-meter tower primary system will access from both the primary system and the backup system (10-meter mast). The auditors noted that the existing system would be taken out of service at that tim All measurement systems appeared to be in operation. The preventative main-tenance program consisted of operability checks on the data recorders on a daily basis, and system calibrations on an annual basi For the grade of equipment in place and the limited time it will remain (less than 6 months),

the scope and frequency of calibrations is adequat There was no apparent mechanism in place that would ensure that CR staff would be apprised of severe weather conditions (e.g., tornado) that could impact the site are . _- . . - _ _ - _ _ _

__

Provisions had been made for followup messages from the plant to offsite authorities (see section 4.2.3 of this report) regarding meteorological con-ditions in the plant vicinity. The licensee had made additional provisions for obtaining supplemental meteorological information, including forecasts, from NOAA, Boulder, Colorado, and the National Weather Servic Straight-line Gaussian transport and diffusion assumptions were incorporated into the dose projection procedures as outlined in RG 1.145. Such assumptions with site-specific coefficients (e.g., meander effect), if available, were appropriate for the terrain environment in the FSV plant vicinit Based on the findings in the above, improvements in the following areas should be considered in order to achieve an adequate program:

--

Establish the level of uncertainty associated with the use of meteoro-logical information from the proposed primary system in the dose pro-jection process and provide direction such that recommended protective actions are adequate (267/82-01-66);

--

Identify within the RERP and EPIP's how to gain access to alternate meteorological data sources, how to use (e.g., adjust) available information, and how documentation of data sources (other than primary system) will be achieved (267/82-01-67);

--

Facilitate the input of the transport and diffusion data into the dose projection process for manual assessment methods (267/82-01-68);

--

Formalize the meteorological measurements preventative and corrective maintenance program and data qualification program to provide reasonable assurance that meteorological data will be available for use during a radiological emergency (267/82-01-69); and

--

Formalize the procedure to inform the CR staff of impending severe weather conditions that may impact the site area (267/82-01-70).

!

Based on the findings in the above area, this portion of the licensee's program appeared to be adequate.

.

I I

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4. Protective Equipment 4.2. Respiratory Protection The auditors toured the turbine building, reactor building, and the emergency facilities and determined that self-contained breathing apparatus (SCBA) had been positioned in various areas around the plant; e.g., SCBA had been positioned near the cable room and six SCBA's were located outside the HP offic The licensee stated that all SCBA's were emergency equipment and should be readily available; therefore, no SCBA was locked up or dedicated for radiological emergencies. The auditors determined that there were two emergency kits, located in tne PCC, which contained full-face masks. The auditors determined that the station personnel could refill expended air bottles via a plant breathing air compressor; however, it was noted that the intake filter for that compressor would be insufficient to remove radioiodine and other airborne radioactivity during emergency conditions.

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Provide dedicated respiratory equipment for all persons that will remain onsite during an emergency (267/82-01-71); and

--

Develop and implement procedures to ensure adequate supplies of clean breathing air (spare bottles) during radiolog'. cal emergencies when the normal refilling equipment may not be available (267/82-01-72).

4.2. Protective Clothing The auditors toured both the normal protective clothing dispensing area in the turbine building, and the reserve supplies stored in the main warehouse. The auditors noted that during an emergency where several teams would be dispatched to the protected area, that there would be sufficient protective clothing; however, during an extreme radiological condition, the auditors determined that the turbine building could be inaccessibl The auditors determined the follow-ing protective clothing inventory on station: 500 pair of cotton coveralls, 800 pair of heavy cotton gloves, 500 canvas shoe covers, 200 low-top canvas covers, 400 disposable towels, and 600 pair of vinyl gloves. The auditors determined that there appeared to be adequate protective clothing available to begin a cleanup operation following an incident at FSV.

Based on the findings in the above area, this portion of the licensee's program appeared to be adequate.

4. Emergency Communications Equipment The auditors reviewed the FSV Section 7.2 of the RERP, Annex E of the State RERP, and toured the onsite emergency facilities. The auditors checked for the telephones depicted in Figure 7.2-1 of the RERP and determined that the NRC ENS and HPN telephones were operable, except for the HPN telephone in the TSC, which did not have a clear and understandable line to Region I . _ _ . - , _ _ _ _ _ _ _ _. - . _

_ _ _ The auditors noted that there were two distinct emergency alarms; e.g., one steady tone for fire alarm and one warble tone for radiological emergencie The auditors were onsite when the alarms were tested and noted that the signal was difficult to hear (the auditors were outside the protected area in the training trailer). The auditors deterrrined that there were several other speakers located in the training building and that personnel in training would be notified in the event of an actual emergency. The auditors also noted that the station intercom was adequate in those areas tested by the auditors;

. further, the messages were understandabl The auditors noted that there were radio and telephone communications from the CR to the TSC, and from the CR to the Weld County Communications Cente Based on the findings in the above area, this portion of the licensee's program appeared to be adequat . Repair / Corrective Action Equipment The auditors toured the mechanical maintenance shop store room and the onsite warehouse and discussed general ordering procedures and material stocking policies, and reserve material storage with the store room personnel. The auditors determined that a computer program existed for maintaining certain materials and supplies. Further, it was determined that there were three additional PSC power stations within 35 miles of FSV that would provide additional equipment upon request from FS Based on the findings in the above area, this portion of the licensee's program appeared to be adequate.

I 4. Reserve Emergency Supplies and Equipment The auditors toured the CR, HP office, and the emergency stations. The licensee did not maintain dedicated respiratory equipment (see Section 4.2.2.1, Respiratory Protection), protective clothing or recovery equipment.

'

Based on the findings in the above area, improvements which should be considered in order to achieve an adequate program are identified in section 4.2.2.1 of this repor .2.6 Transportation The auditors reviewed the contents of the FSV RERP, dated February 10, 1981, 3 and January 4, 1982; and held discussions with station personne Section 5.3.2 of the RERP stated that, "In emergency situations, assistance from outside companies and services may be required. Assistance available from outside companies includes ambulance service to transport injured and/or contaminated personnel . . . for station personnel who require such assistance."

Section 6.2 of the RERP specified that, " Air concentration levels are verified by monitoring teams . . . deployed in captive vehicles with . . . ." Attachment 1 to PCC EPIP's, entitled "PCC Director's Checklist," Item 11 stated that,

" Health Physics and Driver, with communication equipment, dispatched to obtain

"

. . . surveys.

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The auditors determined that the station had available onsite four PSC vehicles, two 1-1/2 ton stakebed trucks, one 3/4-ton pickup truck, and one 1/2-ton pickup truc The auditor determined that all four vehicles were kept on the station site, either inside or outside of the protected area, during off-shif t hours. The auditor noted that there were three se of keys in the Shift Supervisor's office for some vehicles. It was deterrt .1 that the operations vehicle was operational and that the remaining keys v e.d not permit access to other available site vehicle Further, it was determined that there were no provisons for determining, at any given time, the availability of a vehicle to perform required emergency function The auditors noted that there were no procedures available that list items such as: emergency vehicles available; the capabilities of each; the preferred vehicles to use for a given emergency function; the state of readiness (i.e.,

maintained with full tank of gas); two-way radio installed; when not in use the vehicles will be parked at a specified location; when out of service, another vehicle will be designated to replace; and how the change would be communicated to necessary emergency response personnel. The auditors also noted that there were no procedures available that ensured that the necessary emergency vehicles were consolidated at the PCC for use during emergencies or how emergency vehicles would be recalled from offsite if their use was deemed necessary for an emergency functio Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop and implement procedures describing the type, number, equipment, state of readii,ess, location of keys and availability of vehicles for emergency respense (267/82-01-73); and

--

Provide instructions in the RERP and EPIP's that ensure the necessary vehicles are made available at'the PCC during an emergency (267/82-01-74).

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5.0 PROCEDURES 5.1 General Content and Format The auditors reviewed the general content and format of the FSV RERP, EPIP's, CR Operations Emergency Procedures (E0P's), CR Operators Standard Operating Procedures (50P's), and Administrative Policies and Procedure Personal interviews were also conducted with reactor operators, senior reactor operators, shift supervisors, and various PSC employees. The auditors noted that the method used in the E0P's for referencing the EPIP's was vague and varied in styl Frequent reference was made to implementing the RERP, but it was not specified whether the Station RERP or the Plant RERP was intended.

The auditors discussed this deficiency with the reactor operators who stated that they were not clear as to which document was intende Reference was made in the E0P, H-2, Section 3.2 to the RERP, Attachment 5 or Attachment 9, without specifying which section or which RERP was intended. (Note: There were three RERP's - Station, Plant, and State.)

The auditors determined, through discussions with the reactor operators, that the current E0P's did not provide an early warning of possible RERP implica-tions. The operators stated that they could potentially be 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> into an accident situation before the procedure required RERP implementation.

It was also noted that some E0P's did not reference the RERP or the EPIP's.

For example, E0P-P, " Loss of a D.C. Bus," dated November 16, 1981, did not reference the EPIP Alert, attachment 10, Table 4.1-2, Item 6, " Loss of

"

vital D.C. power . . . .

The auditors noted that the EPIP's did not contain or reference supporting implementing procedures. The various sections of the EPIP's did contain a number of attachments, but they did not contain reference to supporting proce-dures; e.g., HPP's or APM, G-5.

The auditors noted that the procedures did not provide guidelines to be used for exercising judgment in the implementation of the specific actions, in the interpretation of emergency action levels, or in the application of protective action guides. For example, the auditors requested that a senior reactor operator (SRO) interpret the Radiological Alert EAL, #1 " Coolant Inventory of a) 2.4 Ci MeV/lb Beta-Gamma": as listed in the FSV EPIP's. The SR0 attempted to obtain the needed information from CR gauges. After approximately 10 minutes, he remembered that the process required a radiochemical analysis.

However, he forgot that HP had to take the sample.

The auditors noted that the RERP, Section 10, Appendix D, " Titles of Written Procedures that Implement the Plan," referenced a number of procedures contained in the Administrative Policies and Procedures Manual (ADM). However, the licensee had issued an Administrative Procedures Manual (APM) that had in part superseded the ADM. In the FSV procedural system, the ADM was classified as a Level II procedure and APM was classified a Level Procedure G-2,APM,

"FSV Procedure Systems," dated April 17, 1981, Section 3.C, stated "in the event of procedural conflicts, Level I procedures take precedence over Level II and III procedures." However, the licensee had not provided station personnel with a list of procedures that contained conflict The auditors noted that the ADM procedures that were totally superseded by APM procedures had not been

removed from circulation. Discussions with reactor operators (R0's) revealed that they were confused as to which set of procedures were to be followe For example, both ADM-09, " Administrative Procedure for Emergency Organization,"

and APM, G-5, " Personnel Emergency Response," contain requirements for report-ing to emergency station The auditors determined that FSV's method of classifying procedures; i.e.,

Levels 0, I, II, and III had caused confusion among station personnel as to the level of importance placed on the RERP. Procedure G-2, APM, listed the entire contents of APM as a Level I and the RERP, EPIP's, EP's, etc., as Level II The licensee management stated that the various levels were FSV's system for classifying the level of management approval require Based on the findings in the above areas, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop a method for referencing the section in the EPIP's that pertains to the E0P's being used and ensure that the method is workable through R0 training and drills (267/82-01-75);

--

Retitle the RERP's (Station, Plant, and State) so as to clarify which document is being referenced (267/82-01-76);

--

Develop a method of flagging an E0P to indicate early in the procedure that it may include a reference to the EPIP's (267/82-01-77);

--

Review the E0P's and include references to potential unusual event items, including EAL's and action items and identify the specific EPIP sections to which the operator must go (267/82-01-78);

--

Review EAL's and include guidance on how to determine when the EAL has been reached (267/82-01-79);

--

Revise the current procedure process to clarify or remove the discrepancy between the APM and ADM (267/82-01-80); and

'

--

Clarify the purpose of the FSV procedure classification system to remove the confusion of policy procedures having a higher classification than the RERP (267/82-01-81).

5.2 Emergency Alarm and Abnormal Occurrence Procedures The auditors reviewed the contents of the FSV EPIP's, E0P's, Abnormal Procedures for Shutdown Cooling and Safe Shutdown with Highly Degraded Conditions (APSC),

SOP's, HPP's, and RCP' The auditors noted that the APSC did not contain any reference to the EPIP's, nor did it address immediate action requirements for the plant RERP or necessary followup action The auditors also noted that the E0P's do not directly reference, by section or title, the EPIP's, which should be used by the station operators to classify the emergency and take the necessary actions, including notifications to offsite authorities (see section 5.1 of this report).

_ _ __ __

The auditors determined that the E0P's did address immediate action and followup action requirements necessary to gain control of the reactor. However, the E0P's did not address EAL's directly, but did periodically reference the RERP. It was never clear which RERP (Statin, Plant, or State) was being referenced or where to find the EAL's in the respec.tive RERP. The auditors also noted that some E0P's did not contain a reference to the EPIP's or RERP even when they might have had an Unusual Event transpire.

Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

--

Assure that the emergency procedures are expanded to include the initiating conditions and EAL's in NUREG-0654, Revision 1, Appendix 1, and lead the station operators into the appropriate section of the FSV EPIP (267/82-01-82).

5. 3 Emergency Plan Implementing Instructions The auditors reviewed the contents of the FSV EPIP and its attachments. The l auditors noted that the EPIP was separated into: two sections for emergency classification (Unusual Event and Alert, with attachments); six command posts, ECP, FCP, PCC, SEOC, TSC, and CR; and a phone roster separated into nine phone rosters. The Alert section of the EPIP's also contained the classification requirements for the Site Area Emergency and General Emergenc The auditors noted that the EPIP's required the same response to all three upper classes of emergencies.

The auditors determined that the EPIP's were actually implementing instructions and not procedures. The current EPIP's instructed the responsible personnel in the proper process for establishing the various command posts and the proper reporting requirements. It did not specify procedures for implementing action such as repair and corrective actions, etc. Thus, the EPIP's gave guidance only in generally what to do, not how to do i (See section 5.4.5 of this report.)

The EPIP's did not tie together all of the station procedures needed to support the implementation of the RERP. For example, the EPIP, CR-UE, Section 2.2.5 stated, " Initiate radiological protective actions for station personnel," but it did not specify nor reference supporting procedures to describe the process necessary to achieve that task.

The current EPIP's had EAL's that were based on observable information readily available to the individual reactor operators; however, the EAL's were located

,

{

in the attachments section and were not readily located. The auditors determined that some EAL's required the services of HP and RC technicians to acquire the correct information, but the table did not indicate that this assistance was l required.

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Correct the EPIP's to ensure that all appropriate and applicable emergency actions are defined, and properly referenced in the FSV E0Ps and the EPIPs (267/82-01-83); and

--

Correct the EPIP's to include reference to all supporting procedures necessary to perform the required tasks (267/82-01-84).

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5.4 Emergency Plan Implementing Procedures 5. Notifications The auditors reviewed the FSV RERP and EPIP's for the licensee's notification process to offsite authorities. For each class of emergency, the licensee had established a sequence of notifications for the State and local governments.

The EPIP's made provisions for alternate contacts in the event that the primary contact could not be reached.

The auditors noted that planned messages, announcements, and alarms used for initial notifications were contained in the relevant procedure It was also noted that the phone roster was separated into nine catagories, which were identified by tab Each tabbed section contained instructions to be used by the calle However, the auditors determined that the telephone numbers were not all current and needed additional instructions for using the FSV station telephone system as a number of different code numbers and prefix numbers must be used in order to make outside calls (see section 4.2.3 of this report).

Based on the above findings, improvement in the following areas should be considered in order to achieve an adequate program:

--

Correct all appropriate procedures to ensure that all of the necessary information is available to enable all outside notification calls to be made (including special code numbers, prefix numbers, and telephone numbers), and ensure that this information is kept up to date on at least a quarterly basis (267/82-01-85).

5.4.2 Assessment Actions The auditors reviewed the procedures for assessing the offsite radiological impacts of an accident at FSV. These procedures are contained in the FSV EPIP's. The auditors also examined the FSV FSAR and a design review analysis (FSV P-79312). The auditors noted that the EPIP's contain procedures for directing accident assessment, data collection, and decisionmaking. The procedures were deficient because the onsite Emergency Director was not authorized to sound the station alarm, or notify offsite agencies without first obtaining management concurrence of the accident categor This provision does not ensure protection of the health and safety of the public.

The auditors also determined that the procedures were written for use by the appropriate members of the emergency organization, except that attachment 4 of the TSC procedures was missing from the CR procedure.

The auditors noted that the EPIP's established priorities for assessment actions.

However, the auditors noted that the dose assessment (release assessment)

procedure preceded the offsite notification The auditors noted that this procedure generally required 30-45 minutes to complete by a reactor operator.

This amount of time is too long, compared to the 15-minute notification time goal. Moreover,the data required to complete the notification form did not require completion of the release assessment attachment because the emergency classification and protective action recommendations may be based upon plant parameters and emergency action level .

The EPIP's were found deficient in that protective action recommendations were not found to be based upon plant parameters. There was excessive and exclusive reliance upon dose projection informatio The auditors also noted that dose assessments based upon field monitoring data were only assumed to affect the extent of areas to be evacuate This policy ignored the fact that environmental monitoring data is potentially more accurate than dose projections.

'

Furthermore, the auditors observed that the assessment procedures failed to accommodate isotopic release data that could be available from the chemistry laborator The auditors noted that attachment 9 of the CR procedure allowed projections of radiation doses from unmonitored releases. This procedure was adequate for the FSV HTG Provisions also existed for estimating offsite radiation doses in the event that installed CR instruments were inoperabl Procedures required the TSC staff to observe and record trend data on graphs and charts that were available. The auditors noted that the computerized display in the CR could be programmed to collect and display on a Cathode Ray Tube monitor; however, the computer was not yet operational during the appraisal visi The auditors noted that FSV has implemented an appropriate method of updating information needed by offsite agencies through the use of communications equipment available in the TSC and E0 Instructions for long-term environmental monitoring were in place with a contractor (Colorado State University (CSU)).

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Delegate sole authority for all protective actions and notifications to the onsite Emergency Director, provide for an onsite Emergency Director at all times (267/82-01-86); and

--

Revise the EPIP's to improve the timeliness of offsite notifications (267/82-01-87);

,

--

Revise the guidance for protective actions to include plant system para-meters and offsite monitoring in the decision basis (267/82-01-88);

and

--

Provide for use of isotopic release data in dose assessment procedure (267/82-01-89).

._ __

. _ - - - - _ _ _ _ _ . _ _ -_ _

__ _. _ _ _ _ .

,

5.4.2.1 Offsite Radiological Surveys The auditors reviewed the contents of the FSV RERP, dated February 10, 1981, FSV EPIP's, dated January 4,1982, and held discussions with station personne Section 4.2, "Off-Site Accident Assessment," of the FSV RERP specified that,

"The station had the responsibility to perform a preliminary assessment of the off-site consequences of an accident." This preliminary assessment was accom-plished by precalculated analytical methods and/or field surveys. Also, Section 4.2 specified that, "Upon activation of the Forward Command Post (FCP),

the Colorado Department of Health (CDH) assumes responsibility for . . . off-site accident assessment."

Section 7.3.2 and the RERP entitled "Off-Site Systems and Equipment" stated that CSU was under contract with FSV to provide routine and emergency event environmental monitorin The auditors determined that FSV did not have any procedures that delineated the performance of radiological surveys beyond the exclusion area boundary (EAB)

by FSV personnel in the event of an emergency until they were relieved by the CDH team.

'

The auditors also noted that the EPIP for dispatching FSV survey teams to areas within the EAB did not specifically identify the types of surveys to be performed or the special types of filters-to be used for radiciodine sampling.

!

,

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop and implement procedures which identify specific survey instru-ments and other equipment used, documentation, and communication of results that provide detailed instructions for the performance of radio-logical surveys within the EAB and the offsite area (until officially relieved by CSU or CDH teams during an emergency) (262/82-01-90);

--

Develop and implement specific procedures in the EPIP's to govern the peri'ormance of offsite field radiological surveys (including the identi-fication of specific equipment and supplies needed) by PSC offsite teams until they are officially relieved by the State teams (267/82-01-91);

and

--

Correct the RERP and EPIP's and provide the capability to perform offsite radiological surveys by PSC teams throughout the entire 5-mile EPZ until

• hat responsibility is assumed by the State and the PSC teams are relieved

.

by the State teams (267/82-01-92).

- _ _

_ _ _ _ _ _ _ _ _ _ , _ _ _ _ _ . _

_ _

._ .

. .

__________

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

5.4.2.2 Onsite (Out-of-Plant) and In-Plant Radiological Surveys The auditors reviewed the contents of the FSV RERP dated February 10, 1981; FSV EPIP's dated January 4,1982; and HPP's -8; -12; -45; -56; discussions were also held with station personne HPP-8, " Radiation Surveys," provided instructions for obtaining routine radiation surveys and listed, in generic terms, the instruments and plant survey maps available. This procedure provided for distinguish-ing between beta and gamma radiation level HPP-12, " Portable Air Sample Collection and Analysis," provided for determining airborne radioactivity concentrations by portable air samplers and references the procedures to use in analyzing the samples. The procedures covered high-volume air sampling which the station did not

!

'

employ, as low-volume sampling was the station's primary method for particu-late and radioiodine samplin HPP-45, " Air Activity Analysis Using the RM 14/15 with HP 210 Probe,"

provided for assessment of particulate activity on a 47 mm diameter filte Sampling and monitoring data logs were provided in the procedur HPP-56, " Reactor Building Exhaust Stack Discharge Activity Calculation,"

provided for measuring and computini stack noble gas concentrations up to 1.0E + 5 uCi/c The auditors determined that only HP)-45 was explicitly identified in the HPP's as an emergency event procedurt ; however, this procedure was not referenced in the FSV EPIP's. The at jitors similarly noted that the FSV EPIP's contained instructions for per'ormance of the survey specified in HPP-45, but not in sufficient detail to ensure that the survey would be expeditiously carried out. For example, the EPIP did not identify the necessary survey instruments to us The auditors determined by discussions with station HP personnel that directions for conducting radiological surveys would be provided by the Shift Supervisor (EC)

during the Alert stage and by the Health Physics Supervisor or Health Physicist when the TSC is manne The auditors noted that the existing routine procedures for radiological surveys onsite and in plant surveys lacked the following: provisions for uniquely labeling air samples for later identification; provisions for the use and analysis of silver zeolite cartridges for radioiodine sampling; and instructions for obtaining in situ whole-body dose rate measurement Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

OcVelop and implement procedures for onsite and in plant radiological surveys during emergency events (267/82-01-93); and

--

Ensure that onsite and in plant radiological survey procedures address the following: specific emergency radiological equipment to be used, labeling of samples, and analysis procedures to be used and to whom to report the results (267/82-01-94).

_ _ - _ _ _ _ _ _ _ _ _

-. . _

. _ . _ - ._

i 44 .

5.4. Postaccident Sampling The auditors reviewed the current HP sampling procedures. The FSV procedures for normal and off-normal events are combined in a single set of procedures in the HPP series. The auditors examined procedures HPP-5, -12, -14, -15, -17,

-18, -33, -36, -44, -45, -53, -55, -56, -58, and -60 because these procedures were either specifically for emergency situations, support emergency procedures, or for use in both emergency and normal situations.

'

The auditors noted that procedures for sampling primary gas coolant (HPP-14)

and the reactor building vent (HPP-53) contained specific provisions relating to potential emergency conditions. These procedures reference dose limits, preassessment of conditions, use of shielded containers, and the need for reducing exposure time and the magnitude of exposure. Other procedures relating to tritium sampling (HPP-5, -15), air sampling (HPP-12), fast gas sampling (HPP-33) and suma effluent monitoring (HPP-60) did not direct the technician to employ specirI precautions during emergencies. Furthermore, the auditors noted that HP technicians did not receive hands-on training regarding special emergency sampiing procedures. The FSV health physicist felt that the normal sampling procedures are sufficiently similar to the emergency procedures to constitute aJequate trainin The qualiiications of technicians for assignment to swing shift and backshift consisted of reading appropriate procedures and references, completion of a task checklist under guidance of a qualified technician, and an oral review by the health physicis The sampling procedures contained detailed operational checklists, and specific sampling points were noted where applicable. Equipment and sampling media were generally addressed (see HPP-5, below). The use of data sheets and labeling techniques was addressed in section 7.2. Individual (each) samples could be obtained within 30 minutes. Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

--

Correct all procedures intended for use under emergency conditions to include specific guidance in additional health physics aspects needed to maintain personnel exposures ALARA (267/82-01-95)

5.4. Postaccident Sample Analysis The auditors reviewed FSV RC Procedures RC-1 through RC-32 and pertinent HPP's (see sections 5.4.2.4, 5.4.2.6, 5.4.2.8, and 5.4.2.10 of this report). The auditors discussed the procedures with the station staf The review indicated that HPP's and RC procedures were not compatible in some respects. The auditors noted two basic types of difference These differences were failures to coordinate HP sampling with RC analysis, and failures to imple-ment similar analysis procedures in HP and RC. The rationale for specifying the latter inadequacy is that station staff indicated HP technicians could use RC facilities for air sample analysi This implies that HP and RC procedures should be similar so as to prevent possible analysis error The auditors also felt that the RC procedures were superior to the HP procedures and that HP procedures should be improve . . -. -- . -. .- . . - _ _ -

- __ _ ___________________.._____ _

Specifically, the auditors found that HPP-4 did not specify a warmup time for 4 the TLR-5 TLD reader. There was not a specification of an acceptable range of  !

values for dark current. The procedure did not specify or reference a require-ment for efficiency check HPP-12 did not explain the meaning of the terms " instrument background" and

" area background" in attachment 7.1 of the procedure. The auditors found that all HP staff did not understand the analysis procedure of attachment There was not a specification for the acceptable frequency or location of the l area background samples that attachment 7.1 required. The auditors considered '

that this apparent confusion could lead to even greater confusion during an emergency. The lack of detailed specifications for labeling samples could increase this problem. This problem could be avoided by adopting a procedure for HP technicians similar to RC-29, " Radiochemistry Sampling Procedures."

Further, HPP-54 did not specify a warmup time for the proportional counter.

l The auditors found that HPP-5, HPP-15, and RCP-8 were in conflict. HPP-5 and HPP-15, procedures for sampling tritiated gas and water vapor, required the HP technicians to mix the samples and liquid scintillation cocktail in counting vials. RCP-8 directed the RC technicians to perform this function. The staff indicated that HPP-5 and HPP-15 were outdate The auditors noted that HPP-14 included the tritium sampling instructions that were in HPP-5 and HPP-1 The HP technicians were not generally aware of the differences between HPP-5 and HPP-1 The auditors determined that HPP-5 and HPP-10 were apparently superfluous. The auditors determined that RCP-8 also did not provide instructions that were appropriate for analysis of gaseous condensate. A new procedure that corrects this deficiency was being prepare Although HPP-14 specified that 2 ml primary coolant helium samples would be taken during emergencies, RCP-9 did not give instructions for analyzing the 2 mi samples. The RC Supervisor indicated that the GeLi analyzers are in fact calibrated for a 2 ml bottle geometry, but this was not reflected in the procedur The analyzers are also calibrated for small volumes of liqui The HP Supervisor explained that the sample apparatus for primary gas coolant was capable of taking various concentrations of the primary coolant by varying the vacuum drawn on the sample bottle. The HP technicians did not indicate awareness of this possibilit The procedures for gaseous effluent and air monitoring mentioned charcoal cartridges. However, FSV had adopted silver zeolite cartridges for those sample RCP-27 duplicated HPP-60 (reactor building sump sampling); the FSV staff indicated RCP-27 would be delete The auditors noted that there was direct provision for using the isotopic data that is available from the radiochemistry computer in the dose assessment procedure The licensee is encouraged to continue bring the HPP's into reconciliation with RC procedures and to delete unnecessary procedures in a timely fashio . .. .. _-

Based on the findings in the above areas,

--

Develop and implement HP and RC procedures which are compatible and define responsible functions for postaccident sample analysis (267/82-01-96)

5.4. Radiological Environmental Monitoring Program (REMP)

The auditors reviewed the content of the FSV RERP dated February 10, 1981; FSV EPIP's dated January 4, 1982; FSV Technical Specifications, section 5.9 dated January 24, 1974; and held discussions with station personnel.

The auditors noted that prepositioned environmental survey points were l established within the FSV Environmental Assessment Branch (EAB) but that no procedures were available for the licensee to perform the environmental sampling during an emergency as this is under contract with CSU. Further, the RERP assigned responsibility for the Colorado public domain environmental sampling program to the Colorado Department of Health as defined in the State RERP.

Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

--

Develop and implement procedures that ensure onsite and offsite environ-mental surveys will be performed on all impacted lands until appropriate State or contracted agencies can augment the licensee's staff and take official responsibility for that emergency function (267/82-01-97).

5. Protective Actions 5.4. Radiation Protection During Emergencies The auditors reviewed the content of the FSV RERP dated February 10, 1981, FSV EPIP's dated January 4, 1982, HPP's, Emergency Medical Plan, and had discussions with station personnel.

The auditors determined that there were no overall procedures governing the implementation of a radiation protection program during emergency events.

Section 6 of the RERP assigned radiation protection (personnel monitoring /

dosimetry / decontamination / access / reentry control) to the PCC Director.

Section 6.4.1.a.4 of the RERP provided for the dispatch of rescue teams and that they are to observe the emergency exposure limits outlined in Table 6.5.1 of the RERP.

Section 6.5.1 of the RERP, entitled " Emergency Personnel Exposure Criteria,"

specified in general terms that emergency worker exposures were controlled by the PCC Director in accordance with the recommendations by the U.S. Environmental Protection Agency (EPA). Emergency workers will carry self-reading dosimeters, and 24-hour emergency dosimetry services will be provided through contract with the R.S. Landauer Corporation. Also it was specified that the PCC Director is responsible for distribution of self-reading dosimeters to the emergency worker Section 6.5.2 of the FSV RERP, entitled " Decontamination and First-Aid,"

specified decontamination of personnel whenever contamination above background is detected. That is unrealistic during emergency situations.

HPP-53 provided instructions for removal of the filter and cartridge from the reactor building stack monitor during radiological accident conditions.

The procedure did provide for reducing the radiation exposures at the work site, using remote handling tools, and the use of shielded container The procedure did not provide for the use of anticontamination clothing and respiratory equipment or for removal of the high activity contained in the filter and cartridge, nor did it provide for contamination control.

The auditors noted that adequate emergency exposure criteria existed in the FSV RERP; however, this criteria did not appear in HPP-53.

Further, the FSV EPIP for the PCC Director specified that the PCC Director can authorize emergency workers to receive doses in excess of 10 CFR 20 limits as described in Table 6.5.1 of the RERP (U.S. EPA Emergency Exposure Criteria).

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop and implement a procedure that provides guidance on the administration of radiation protection for survey and emergency work teams, that includes specific dosimetry requirements (whole-body and extremity), methods to ensure assigned stay times are not exceeded, locations of temporary shielding, personnel responsibilities, and methods for performing assessments on the necessary protective measures needed (267/82-01-98);

--

Incorporate station procedures specified for emergency use into the EPIP's (267/82-01-99);

--

Develop and implement emergency exposure worksheets that provide for signature concurrence on all personnel exposures that may exceed 10 CFR 20 exposure limits (267/82-01-100); and

--

Develop stay-time determination calculations (whole-body and extremity),

including a method of enforcement and acknowledgment (267/82-01-101).

5.4. Evacuation of Owner-Controlled Areas The auditors reviewed the contents of section 6 of the RERP, the EPIP's, other station and security procedures, and held discussions with station management, station personnel, and other personnel onsite.

The auditors noted that section 6, page 12 of the RERP, identified the criteria to be used by the Shift Supervisor to initiate evacuation of the reactor building or the site of nonessential personnel. The auditors also noted, however, that the criteria did not appear in the EPIP' The auditors determined that when the need to evacuate station areas was recognized by the Shift Supervisor, the Shift Supervisor would sound the station

" Plant Emergency Alarm," and make an announcement over the station Gaitronics syste All persons onsite would then report for accountability purposes to one of 17 " Emergency Stations" as identified in procedures G-5 and ADM-09. The auditors noted, however, that neither procedure. addressed what the persons at the FSV Visitor's Center or the persons residing outside the security fence but within the owner-controlled property would do. The auditors did determine that the EPIP's did make provisions to remove personnel from the Visitor's Center and telephone persons within the owner-controlled propert The Shift Supervisor was responsible, in the CR section of the EPIP's, to call the Visitor's Center to inform them of the need to evacuate. The PCC Director was responsible in the PCC section of the EPIP's to have communications call each residence within the owner-controlled area and to dispatch a driver to contact any persons not reached by the phone call The personnel at the Visitor's Center (VC) also had a procedure to direct them to evacuate the center; however, directions were "Do not attempt to detain any visitors who will not cooperate in the evacuation of the Visitor's Center."

The auditors, therefore, determined that the licensee did not have positive control and accountability of persons at the VC when evacuation was require Further, the actual accountability would not be performed until evacuation from the VC was completed and the people had arrived at the Ft. Lupton Fire Station (the assembly area) and then only the accountability of the PSC employees would be reported to the PC Further, persons who did not cooperate in the evacuation would be reported to the State Health Department, not to the licensee. It must also be noted that the PCC may not be operational until 90 minutes after the evacuation was initiated, thus the 30-minute account-ability could not be me The auditors noted that no markings of any kind were apparent either within the plant or on the roads leading from the plant to guide personnel to the selected assembly areas. Further, the locations of the assembly areas were not addressed either in the RERP or EPIP's, nor were there provisions to determine the radiological conditions and habitability of the various assembly areas (see section 4.1.2.1 of this report).

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Correct the EPIP's to include the criteria used to determine the need to initiate the evacuation of owner-controlled areas (267/82-01-102);

--

Develop and implement procedures to ensure positive control of all persons in the owner-controlled areas during evacuation (267/82-01-103);

--

Develop and implement procedures to ensure evacuation of all nonessential i personnel from owner-controlled areas, including the VC and to verify within 30 minutes of the initiation of the evacuation, that all non-essential personnel have been removed from the owner-controlled areas (267/82-01-104);

,

__

--- . . _ ,- __ . _

. -- -

-

, 49

--

Provide clear and conspicuous markings for primary and secondary evacuation routes both within the plant and outside the plant (267/82-01-105);

--

Correct the RERP and EPIP's to specifically identify the location of all assembly / reassembly areas (267/82-01-106); and

--

Provide method and equipment to determine radiological conditions and habitability of all assembly / reassembly areas within the 5-mile EPZ (267/82-01-107).

'

5.4. Personnel Accountability The auditors reviewed the contents of the RERP, the EPIP's, other supporting plant and security procedures, and held discussions with both plant management and station personne The auditors noted that section 6 of the RERP addressed personne' account-ability during emergencies at FSV and stated that initial accountability will be completed within 30 minute The auditors also noted that the RERP stated that, " Supervisors report accountability status to the Central Alarm Station (Security Desk in lobby) which in turn reports to the Emergency Coordinator."

Further, that "The search and rescue function is handled by a trained SCAT Team" which was assigned by the E Upon review of procedure G-5 (which was not in the EPIP's), the auditors deter-mined that there were 17 identified " emergency stations" (assembly / reassembly areas) for personnel accountability:

(1) Shift Supervisor's Office (2) Control Room (3) Technical Support Building Office Area (4) Technical Support Center (5) Water Chemistry Laboratory (6) Health Physics Mechanic's Work Shop (7) Lunch Room

(8) Health Physics Access Control Area Office (9) Clerical Office (10) Technical Support Center Radiochemistry Facility

- _ .

(11) Maintenance Shop (12) Electrical Shop (13) Quality Assurance Field Office (14) NPD Field Office (15) Main Warehouse (16) Receiving Warehouse (17) Security Duty Station The auditors noted, however, that three groups of people did not have account-ability stations identified in the procedure: (1) persons at the VC; (2) non-PSC work crews; and (3) site visitor The auditors did note that the persons in the VC and site visitors were addressed in other areas of the RERP and EPIP' This left only the non-PSC work crews as having no accountability statio The auditors noted that there were no specific procedures for personnel account-ability in the EPIP's nor was reference made to either procedure G-5 or security procedure 6.10 which, together, made up the process of personnel accountability at FSV. The auditors further noted that the supervisors did not, in all cases, perform the accountability of their people as stated in the RERP but that other individuals are informally assigned, verbally, by the supervisors to perform the actual accountability and telephone their results into the CA The auditors noted that security procedure 6.10 specified that the Shift Supervisor in the CR would be informed of the final results of the account-abilit This is different than what was specified in the RERP because the EC would not always be the Shift Supervisor; e.g., the CR Director or the TSC Director could have relieved the Shift Supervisor as the " Emergency Coordinator."

, The auditors determined that there was no procedure in the EPIP's, or referenced in the RERP or the EPIP's, which would govern the establishment and operation of a search and rescue team. However, section 6 of the RERP did identify the SCAT team as the unit which would perform that task and identified the emergency exposure limits which would govern their operations. During discussions with the licensee, the auditor determined that the SCAT team no longer existed at FSV and that they were now only the fire brigade. The PCC procedure in the EPIP's identifies the PCC Director as being responsible for the assembly of personnel for search and rescue teams and for performing continued personnel acountability after the initial accountability is completed. The auditors determined, however, that there were no procedures to govern how the PCC Director would perform that continued accountabilit Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program: _ _ _ .---

. .

--

Develop and implement a specific single procedure to govern all aspects of initial personnel accountability for all persons in the owner-controlled area (267/82-01-108);

--

Correct the RERP and EPIP's to properly reference the personnel account-ability procedure (267/82-01-109);

--

Correct the RERP and EPIP's to remove discrepancy (EC or Shift Supervisor)

between the two documents (267/82-01-110);

--

Develop and implement specific procedures to govern the establishment and operations of a search and rescue team (267/82-01-111);

--

Develop and implement specific procedures to govern the actions necessary to ensure continued personnel accountability after the initial personnel accountability is completed (267/82-01-112); and

--

Specifically identify in the RERP and EPIP's the persons, by name and title, who are individually responsible to take personnel accountability at each emergency station (267/82-01-113).

5.4. Personnel Monitoring and Decontamination The auditors reviewed the content of the FSV RERP dated February 10, 1981, FSV EPIP's dated January 4, 1982, HPP's, and held discussions with station personne The auditors noted that the FSV RERP and EPIP's contained provisions for monitor-ing of personnel assembled at the PCC ard those personnel exiting via the security building. The auditors also noted that there were no provisions for dosimetry readings, documenting names of persons surveyed, the extent of contaminated personnel, and the results of decontaminatio The auditors noted that the FSV Medical Emergency Plan provided adequate

.

'

information on handling of contaminated injured persons and protection guidance for first-aid treatment of personne Decontamination procedures and personnel monitoring are covered under section 4.1.2.3 of this report.

.

Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

,

--

Provide instructions that ensure each person who is monitored for contami-nation at an assembly area, reassembly area, or exit point during an emergency event is logged by name; and data is entered on contamination levels found, minimum detectable activity of instrumentation, and results of any decontamination (267/82-01-114).

.i

, -.-- -- -

-- ,, . -, .- .,- - , ~ - .

5.4.3.5 Onsite First-Aid / Rescue The auditors reviewed the content of the FSV Medical Emergency Plan and noted that it provided for rapid transportation of injured personnel to the offsite medical facility, rapid deployment of the first-aid personnel, and proper handling to prevent the spread of contamination to those administering first-aid and the offsite attendants. If necessary or practical, decon-tamination would be performed prior to transport of inju~ red personnel offsite and the radiological information forwarded to the offsi.te medical facilities.

llowever, the FSV Medical Emergency Plan was not referenced in the FSV RERP.

This item is covered under section 4.1.2.2 of this report. The auditors determined that during an emergency event, it is the responsibility of the Shift Supervisor and the PCC Director (when the PCC is established) to assemble rescue teams, ensure that HP and the emergency medical attributes are involved in personnel selection of the team members, and brief rescue personnel on protective neasures to be implemented.

Based on the findings in the above area, this portion of the licensee's program appeared to be adequat x 5. Security During Emergencies The auditors reviewed the contents of the slicensea's RERP and its associated EPIP's, toured both the CAS and the SAS; held discussions with the licensee's security personnel; and reviewed the contents of the licensee's Security Instructions 13.7, " Radiological Emergencies," 13.8, " Emergency Response Access," and 6.10, " Personnel Accountability for Station Emergencies."

The auditors noted that the licensee's EPIP's did not contain security procedures nor did they reference security procedures which would Govern the actions of the security personnel during a radiological emergency at FSV. However, the auditors determined that such security procedures did indeed exist and were available to security personne The auditors further noted the conspicuous lack of referencing from the EPIP's to Security Instruction 6.10, " Personnel Accountability for Station Emergencies," even though the ultimate collection function of personnel accountability data rested with the security officers at the CAS.

The auditors also noted that neither the CAS nor the SAS had any radiological protective equipment such as respiratory protection equipment, permanent radiological monitoring equipment for either direct radiation or airborne radioactive materials, anticontamination clothing or potassium iodide.

Further, the auditors verified that neither the CAS nor the SAS were equipped with adequate shielding and ventilation system (HEPA and charcoal) to allow them to remain habitable during accident condition Based on the findings in the above areas, improvements in the following areas should be considered in order to achieve an adequate program:

-

Correct the EPIP's to properly reference the appropriate security procedures to be implemented during radiological emergencies (267/82-01-115);

--

Provide adequate radiological protective equipment and supplies at the CAS and SAS for all security personnel expected to remain at stations or onsite during radiological emergencies (267/82-01-116); and

--

Provide permanent radiological monitoring equipment to determine habitability of CAS and SAS during radiological emergencies (267/82-01-117).

5.4.5 Repair / Corrective Actions The auditors reviewed the contents of the FSV RERP and EPIP sections TSC and PCC, and determined that no procedure existed for specifically addressing repairs and corrective actions. The EPIP's did not address what person would initiate such action, what key positions would be needed, the methods used to control and direct corrective action teams, or the criteria used to select individuals for the team Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

--

Develop and implement a specific procedure which governs the formation, direction, and control of emer0ency repair and corrective action teams during an emergency (267/82-01-118).

5.4.6 Recovery The auditors reviewed the contents of Section 9, " Recovery," of the RERP and the EPIP's for the TSC and the FCP and held discussions with licensee managemen The auditors noted that only the general concept of a recovery organization and the identity of its key positions had been developed by the licensee. Plans for the recovery operations as discussed in the RERP were of an extremely limited depth and scope and no EPIP's had been developed to govern the operations of the recovery organization and its actions to recover the FSV station or its environs after a radiological emergenc The_ auditors noted that limited consideration had been given in section 9 of the RERP and section 4 of the TSC EPIP's as to the general criteria used to base a decision for initiating the recovery organization. However, the auditors also noted that the decision to recommend activation of the postaccident recovery organization rested with the TSC Director and not with the FCP Director

>

(Corporate Emergency Director) who has overall responsibility for and command of the licensee emergency operations and who would become the " Recovery Manager."

_ _ _ _ , . - - -- . ... _ .- -

.

The auditors noted that the postaccident recovery operation planning did not address the criteria for determining when reentry would be appropriate (e.g.,

reactor status and radiological conditions), or when plant operation could resume. Further, there were no methods presented to periodically estimate total population exposure, or to inform members of the various response organi-zations that the recovery operations were to be initiate There also was no discussion as to the new changes in the licensee's response organizational structure due to entering the recovery phase.

Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop and implement specific and detailed procedures to govern the functional operations of the recovery organization (267/82-01-119);

--

Expand both the depth and scope of the recovery operations planning in the RERP (267/82-01-120);

--

Correct the RERP and EPIP's to reflect that the authority and responsibility for activation of the recovery organization rests with the licensee's Corporate Emergency Director who is the EC when such a decision would be made (267/82-01-121);

--

Develop and implement specific criteria to be used to determine when, after an accident, reentry of the facility would be appropriate, or when operation of the plant could resume (267/82-01-122);

--

Develop and implement procedures, during recovery operations, to periodically estimate total population exposure and integrated dose (267/82-01-123); and

--

Develop and implement methods to inform members of the various response organizations of the initiation of the recovery organization or of any other changes in the licensee response organizational structure or functions (267/82-01-124).

5. Public Information The auditors reviewed those portions of the PSC media relations implementing procedures pertaining to the public information section of this appraisal. The official FSV Emergency Plan did not address the area of media relations. The auditors held discussions with the media relations personnel and were shown a document which dealt with media affairs during an emergency. The auditors discussed with the PSC media relations staff, in detail, the telephone require-ments and what their capabilities should b Further, this information was discussed with the State media relations staff and the E0F Manager at the State EOC. In Section SE0C, 2.0 Implementation, paragraph 2.1.2 of the FSV RERP, the NRC Public Affairs representative was not included in the list of authorized representative Based on the findings in the above area, the following improvement should be considered in order to achieve an adequate program.

--

Add NRC Public Affairs representatives to the list of authorized representatives listed in Section SE0C, 2.0 Implementation, paragraph 2.1.2 of the FSV RERP (267/82-01-125).

5.5 Supplementary Procedures 5. Inventory, Operational Check and Calibration of Emergency Equipment, Facilities, and Supplies Auditors reviewed the contents of the FSV HPP's and the NRC Office of Inspection and Enforcement Health Physics Appraisal Report for FSV (Report 50-267/81-13), and held discussions with station personnel.

The auditors noted that FSV procedures for inventory of radiation detection equipment and procedures for routine use of station equipment did not provide for preoperational source checking of instrumentation to a known source for verification that the instrumentation would produce readings of a predetermined value. The auditors exposed three randomly selected radiation detection instruments to a wall mounted Cs-137 source used by station personnel to response check instruments prior to use. The duty HP technician was not aware of the proper value to be obtained during response checking instruments. The instruments checked were an Eberline E-500B portable GM beta gamma survey instrument with a range of 0 to 200 mr/hr, two Eberline E-400 portable GM beta gamma survey instruments, and a Ludlum Micro-R meter, which is a gamma scintillation detector, with a range of IE-6 to SE-3 R/h All instruments were within current calibration. One of the E-500B's (#3325) would not battery check properly and was not used for the tes The duty HP technician was made aware of the problem. Further, the next day the auditors noted that the subject instrument had not been tagged out of service, and the poor battery condition still existed. This was brought to the attention of the dayshift lead HP technician, the instrument's batteries were changed, and the instrument produced a proper battery response indicatio The remaining instruments were exposed to the wall-mounted source in a way to produce the highest reading and the following values were obtained: E-400 #3321 indicated 8 Mr/hr, E-400 #3220 indicated 5 Mr/hr, and the Micro-R #3348 indicated 4.2 Mr/hr.

The attending HP technician could not offer any explanation for the variance in readings.

The auditors also noted that FSV procedures did not provide for or require operational source checking emergency instruments p"ior to u m or during quarterly checks. It was noted that the HP-210 probes used e radiation monitors 14 and 15 ratemeters were not provided with check sources for operationally checking instruments tg verify that they can detect the FSV contamination limit of 100 DPM/100cm . The auditor noted the methods used to response check the cart-mounted airborne monitors (PING) used for detection of particulate, radiciodine, and noble gas radioactivity. The method HP personnel used involves engaging the internal check sources and noting that an upscale alert light trip was initiate This was in lieu of checking for a known indication based on the internal source strength and the instrument's determined efficienc Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop and implement procedures that will ensure all radiation, contami-nation control, and area monitors are periodically checked to verify response to a predetermined value of a known source strength and include what corrective actions are to be taken when discrepancies are encountered (267/32-01-126); and

--

Provide procedures which ensure operational response with check sources of the radiological survey equipment during quarterly inventories and prior to emergency use (267/82-01-127)

5.5.2 Drills and Exercises The auditors reviewed the RERP, Section 8.0 (Maintaining Emergency Prepared-ness), the APM, the available records of drills and exercises including quality assurance records and the TPAM. The auditors obtained additional information on the conduct of drills and exercises through interviews with onsite and station personne The auditors determined that the licensee did not have a procedure dedicated to

, drills and exercise However, Section 4.1.2. (On-Site Emergency Organization Retraining) of the TPAM and Section 8.0 of the RERP described the content of the annual exercise and drills as defined in NUREG-0654, Revision 1, Section The RERP identified the Emergency Planning Coordinator and the Training Supervisor as those individuals responsible for planning, coordinating, approv-ing, and conducting the drills and exercise The RERP contained provisions for backshift exercises; however, neither document contained forms for planning, initiation, or observation of the dril The TPAM specified that communication checks were to be performed monthl However, the RERP specified that some checks were to be performed quarterly and annually. Contrary to either document, the auditors determined that the communication checks were not always verified directly. (See section 4.2.3'

of this report.)

The auditors noted that the licensee conducted pretraining for drills and exercises. However, discussions with plant personnel revealed a lack of understanding as to the purpose and intent of the drills and exercises. It was also noted that individuals with specific problems were not identified personally to allow for additional trainin Based on the findings in the above area, improvement in the following area should be considered in order to achieve an adequate program:

--

Develop and implement a formal procedure that describes, in detail, the drills and exercise program (267/82-01-128).

.- . . - -. . - . . . -, . _ . - . -, - ,. - -. - - . , _ - - - . - - .

5. 5. 3 Review, Revision, and Distribution of Emergency Plan and Procedures The auditors reviewed the FSV RERP, EPIP, APM-G2, " Administrative Procedure System," APM G-3, " Action Request - Preparation and Processing," and APM G-10," Data Management." The auditors determined that there were no procedures for the review, revision, and distribution of the emergency plan

'

and implementing procedures. Section 8.0 of the emergency plan stated, on pages 8 and 9, that the EPC reviewed the RERP annually to ensure that it was kept up to date, that the station government agency interfaces, including contact and notifications lists, are up to date, and that effective communi-cation exists. The auditors noted that the RERP was reviewed annually; however, the nuri.ber of discrepancies identified in other sections of this report indicated that the review process was inadequat The auditors reviewed the distribution list for the RERP and.EPIP and deter-mined during interviews and walk-throughs with onsite and offsite personnel that the current plan and procedures had been distributed in accordance with those lists. The responsibility for distribution of the plan and implementing procedures was specified in the FSV Document Distribution Handbook (November 1, 1981) to be the responsibility of Plant Clerica The auditors determined that the names, titles, and telephone numbers in the implementing procedures were not all correct. For example, the EPIP tab, entitled "FSV Employee Emergency File," listed F. J. Borst's work telephone as 253; whereas, the tab entitled "FCP (CEDS)" listed T. Borst's (the same person) work telephone as 785-1281. (See section 4.2.3 of this report.)

The auditors noted that the RERP stated in Section 8 that, "PSC Corporate Emergency Planning personnel review the RERP annually and make recommendations for updating, as appropriate." Contrary to this statement, the auditors were informed that there were no corporate emergency planning personne Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

i

--

Develop and implement a procedure to ensure a thorough annual review and l documentation of the review of the RERP and EPIP's (267/82-01-129); and l

--

Remove the reference to the corporate emergency planning personnel

'

(267/82-01-130).

5.5.4 Audits of Emergency Preparedness The auditors reviewed the Quality Assurance Monitoring Manual (QAMM), Sections G 5-1 (Radiological Emergency), G 5-2 (Medical Emergency QAMM), P l-5 (Health Physics) and QA audit record The auditors determined that the QA department did not audit the emergency plan and procedures. However, they did perform an audit of equipment, drills, and exercises. They also performed annual audits of each supporting department based on well-developed procedural guideline .- .. -- - - - . , . - - - .--

The audit procedure provided for observation of the emergency plan exercise by QA personne During interviews, the auditors determined that the QA personnel acted simultaneously as drill observers and auditors. Any findings that the QA

personnel had could be written up as a Continuous Action Action Report (CAAR).

The CAAR items were followed until they were rectified and filed in the QA office fil Based on the above findings, improvement in the following area should be considered in order to achieve an adequate program:

--

Develop and implement a procedure for the routine audit of the RERP and EPIP's (267/82-01-131).

5.6 Human Factors Engineering The auditors reviewed the contents of the FSV RERP, the EPIP's, and various other plant procedures used in addition to the EPIP's to implement provisions of the RERP, and plant facilities and equipmen The auditors observed several areas of impediment for the user of the EPIP's, other plant procedures, and assessment equipment. Impediments in the areas of classifying emergency conditions and making appropriate recommendations were identified. The licensee's EPIP's were not adequately tabbed for quick location of critical EPIP sections or attachments such as: (1) emergency classification, (2) notification, and (3) the emergency coordinator emergency procedure The auditors also noted that decisional aids such as maps and spare copies of multiple-use forms were not readily available and caused unnecessary time delays in the decisionmaking process. The decisionmaking process was further delayed by the fact that personnel could not readily find the specifically needed pages of the RERP or its EPIP's and that single EPIP pages required many different persons to perform steps of the procedure, and adequate checklists did not exist to ensure that all steps were completed'in the proper sequenc The auditors further observed that the use of color-coded tabs or other similar means would greatly enhance the retrievability of the immediately necessary document Similar coding would also be beneficial for those specific instruments used for the classification of emergencie Based on the findings in t! e above area, improvements in the following areas should be considered in order to achieve an adequate progra Evaluate the usability of existing documents and instruments, which would be used during an emergency, for human factors engineering corrections (267/82-01-132);

--

Correct EPIP's to provide that a single individual be responsible for actions on any single page of the procedure (267/82-01-133); and

--

Correct EPIP's to provide adequate checklists to ensure all steps are performed in a timely and properly sequenced fashion (267/82-01-134).

____

6.0 COORDINATION WITH OFFSITE GROUPS

I 6.1 Offsite Agencies The auditors reviewed the letters of agreement in the RERP and the Outside Assistance Phone Numbers Director The auditors contacted responsible individuals within the'following organizations to verify that: (1) they understood their responsibilities and l procedures in responding to an emergency at the license.e's facility; (2) their

'

understandings were consistent with the agreements made between themselves and the licensee and the licensee procedures; and (3) their expectations as to the interfaces and cooperative relationship with the licensee were adequat . Institute Nuclear Power Operations

. Platteville Fire Department

. Fort Lupton Fire Department

. Weld County Ambulance Service The auditors established that the one local fire department had made two visits to the facility for the purpose of ; rainin Further, it was noted that one training session was a tour of the facility and the other session consisted of fighting a fire at the fire pi The auditors determined that one response organization listed had requested a visit to the site, but had no response from the licensee. Further, it was determined that there was no letter of agreement in the RERP, but a letter had been previously signed according to the response organization.

l The auditors determined that the licensee had an agreement with the State whereby the State would provide offsite radiological support, and a cooperative agreement for releasing public information during an incident. The State is heavily involved in offsite training and retains highly qualified personnel for offsite radiological emergency respons The auditors determined that the telephone numbers, as they appeared in the Outside Assistance Phone Numbers Directory were inadequate due to a telephone system change; e.g., Fort Lupton number requires 17 digits to call and only 7 digits were listed in the director Based on the findings in the above area,_ improvement in the following area should be considered in order to achieve an adequate program:

--

Provide actual telephone numbers and instructions for calling offsite assistance (267/82-01-135).

_ _ _ _ _ _ .

6.2 General Public The auditor reviewed pertinent sections of the PSC Public Information Implementing Procedures and interviewed two PSC media relations representative The auditors also interviewed the Postmistress of Platteville, Colorado, the only community located within the 5-mile EPZ. The Weld County Sheriff was contacted for verification purpose The auditors determined that the information concerning emergency planning for the local residents in the EPZ had been disseminated. The PSC media relations managers indicated the brochures were supplied to the Weld County Sheriff for distribution to business establishments in the 5-mile EPZ and for the transient publi The Weld County Sheriff verified that the brochures had been supplied to him, and he had his people distribute them to residences and businesses in a 2-mile area on both sides of U.S. Highway 85 from Platteville to Ft. Lupton. The sheriff had no more brochures on hand, but

,

said he believed an additional supply had been requeste Since a decision about an Early Warning System (EWS) was not made by PSC until the past few weeks, information had not been made available to any transient public facilities within the 5-mile EP The PSC public information procedure identified the Public Inquiry Center (PIC)

in the Colorado Health Department facility (manned by Health Department personnel with a PSC Public Affairs staff member available) as responsible to keep infor-mation current and accuratri. However, the PSC News Manager was not knowledgeable about the staffing of the center during an emergency or cognizant of the number of telephones available for public inquirie There was only one phone number available for public inquiry and that was answered by a switchboard operato Based on the findings in the above area, improvements in the following areas should be considered in order to achieve an adequate program:

--

Develop a transient public information program as soon as possible now that the decision to install an EWS has been made (267/82-01-136) and;

--

Review the current arrangements for public inquiry, staffing requirements, and telephone capabilities, and consider training requirements for PIC personnel (267/82-01-137).

6.3 News Media The auditors reviewed the FSV Emergency Plan, the PSC Public Information Implementing Procedures, and interviewed the PSC Media Relations Director and the News Director. The auditors also interviewed the editors of the Ft. Lupton newspaper and the Platteville newspaper. PSC had an active program for familiarizing the news media with emergency plans, establishing points of contact for release of public information, providing space allocation for media use at the EOC and FCP, and providing information about radiation, normal plant operations versus accident operation, and accident sequence _ ..

PSC had provided two plant tours and briefings for the area news media and had a third tour and briefing scheduled for April 198 Based on the above findings, this portion of the program appeared to be adequat .0 DRILLS, EXERCISES, AND WALK-THROUGHS 7.1 Drill and Exercise Program Implementation The auditors reviewed section 8.0 of the RERP, drill and exercise records, QA records, and conducted interviews with station personne Through a review of QA and drill records, the auditors determined that drill and exercise-identified improvement items had been resolve The auditors determined that the required drills and exercises were conducted according to the time requirements of the RERP, section The licensee routinely coordinates the FSV fire drills to include the Platteville Fire Departmen The fire training, fire brigade and fire drills

,

conducted as FSV were considered exceptiona Based on the findings in the above area, this portion of the licensee's program appeared to be adequat . 2 Walk-Through Observations 7. Assessment Actions i

The auditors walked through the dose assessment action with a CR reactor operator during which the operator was asked to respond to an annunciator trip which indicated an upscale response on the reactor vent monitor. He responded by going to look at the instrument and the chart, and was given a response representing full scale on the instrumen He went to the Control Room -

Emergency Plan (CR-EP) and made a dose calculation using current meteorological data available in the CR and by using a program on the TI-59 programmable calculator. He obtained a comparable result to one dose calculation previously calculated using slightly different meteorology. The operator obtained the CR E0P and determined that the dose level calculated would require an " Alert" classificatio He then presented the completed form to the Shift Supervisor, who would be responsible for all further actio The emergency plan implement-ing procedures, where needed, were integrated in CR-EP series procedures so that the implementation was accomplished without the use of the emergency plan implementing procedure. (The emergency plan implementing procedures refer personnel to the RERP.)

7. Dose Calculation by Reactor Operators The auditors conducted a practical drill of dose assessment procedures using CR operators on day, swing, and night shifts. The operators were asked to respond to simulated annunciator trips and to trace their actions from the E0P's to the applicable EPIP' The operators who attempted to follow their E0P's and find the correct EPIP by following the RERP did not succeed in correctly classifying the incident. This was because the EAL's were described in terms that were not directly observable in the CR. For example, one operator attempted to find a radiol (gical monitor of coolant radioactivity with a readout in Ci-MeV/lb. This operator was not familiar with the sensitivities and action levels for the radiological monitors.

Also, the RERP referenced inappropriate parameters for some EAL's. For example, EAL #11 of table 4.1-2 of RERP listed RT-7325-1 with an EAL of 2.8E-9 Ci/cc of I-131. The EAL is 100,000 times lower than the minimum detectable level of RT-7325-1.

The operators who successfully completed the dose walk-through circumvented the RERP and went directly from the E0P's to the EPIP's. Since the same dose calculation attachment was found in each major EPIP and since the dose calculation attachment contained instructions for all emergency classifica-tions, the operator eventually classified the incident correctly.

The auditors noted that E0P's did not provide explicit guidance for classifying accidents or directing the operator to specific EPIP's. The auditors did not find that this imple:nentation scheme appeared adequate.

The operators did complete the actual dose assessment calculations in a satisfactory manner. The auditors found the operator's results were comparable to results obtained by the auditors using the same instructions.

The auditors observed that the recording of differential temperature on the meteorological data chart was not identical to the value indicated by the pointer on the sliding scal The auditors observed a pointer indication of

+0.75 F while the chart indicated +1.5 F temperature difference. This difference caused one operator to classify the stability class-as E rather than F. However, this was not considered a significant error.

One operator did not clearly understand the meaning of wind direction. He stated that a 70 wind direction resulted in wind blowing into the ENE sector, rather than from the ENE sector.

Extra copies of the dose assessment worksheets were not available. Several operators explained that EAL's relating to coolant activity (and therefore fuel integrity) require RC analysi Measurements of gross coolant activity in Ci-MeV/cc and radioiodine in equivalent curies of I-131 were not available on the CR panels. Since RC technicians were not present on all shifts, the operators were not able to implement the RERP adequately. The auditors suggested that available indicators, such as coolant AT or differential temperature, be integrated into the EAL's.

The operators indicated that they did not have a method of determining stability class in the absence of temperature dat Attachment 7 provided information that related the standard deviation of the horizontal wind

" fluctuation" (should read " direction") to stability class, but the operators were not instructed in methods for using this information. When questioned, the operators indicated that they would apply a conservative (F) classificatio ,- -- - ,_- --- - - -

.

7. Postaccident Stack Effluent Sampling and Analysis The auditors observed a demonstration of the collection of filters from the reactor building vent monitor The HP technician who demonstrated the stack sampling procedure demonstrated appropriate skills and knowledge sufficient to protect his health and safet He was familiar with the location of the monitors and the necessary equipment and supplies and used these materials to complete the sampling. The equipment (monitors, survey instruments) was operable. The facilities were adequate. The procedure was understandable to the technician. However, the procedure section " apparatus" should include replacement filters and envelopes. Further, the procedure section " precautions" should specify obtaining the CR readout of the area radiation monitor adjacent to the stack filters prior to entry into the are . Postaccident Primary Gas Coolant Sampling The auditors observed a demonstration of primary coolant sampling under accident conditions. An HP technician on the swing shift was asked to perform a dry run. The technician informed the auditors that he had not actually practiced this procedure as part of his trainin He further stated that he would determine the radiological conditions in the AI room prior to entr He did not show a great deal of knowledge regarding the location of the radiation detector that had a readout in the AI room. He did not receive adequate training on the locations of the radiation detectors in the reactor building ventilation ducts.

,

The HP technician appeared to possess good working knowledge of the use of the AI room sampling equipment. All required supplies were in the AI roo The technician did not follow the instructions in the procedur He did not acknowledge the instruction to restrict helium flow to the AI room. He did not follow the valve lineup specifications in the procedure because he understood the lineups as a result of experienc The technician and the auditors agreed that the procedure was defective because it d'd not call for closing valve HS-93431 af ter the sample vial had been evact ate This would cause the sample to flow into the vacuum syste The HP technician did not realize that the emergency sampling procedure speci-fied a 1-minute sampling time for the 2 ml via The purge time is 15 minutes under normal conditions. This would have been apparent to the technician had he read the procedur The fact that he did not follow the procedure reflects on his trainin A technician should not be allowed to attempt an unfamiliar procedure without first reading the procedure thoroughly or following a check-list, or bot The technician indicated that the valves on the mimic board tended to stick or otherwise be inoperable and that the sampling equipment was not reliabl Further, it was noted that the damper for the ventilation duct in the AI room had been disconnected from the servo ar n -

, ,y- - - - - , . , , , - - . , ,-,m , -v, ,- , - .-,.- --

i

8.0 EXIT MEETING On January 15, 1982, at the conclusion of the onsite portion of the appraisal, the appraisal team, along with a representative from the NRC's Office of Inspection and Enforcement Headquarters, met with licensee representatives denoted in Annex A to this report. The team leader summarized the scope of the appraisal and the significant appraisal finding Licensee management acknowledged the appraisal findings and indicated that, prior to the NRC appraisal, they were aware that there .are areas which needed to be improve Further on January 15, 1982, Mr. Charles A. Hackney, Emergency Coordinator,

,

Region IV; Mr. Sheldon A. Schwartz, Deputy Director, Division of Emergency Preparedness; and other members of the Nuclear Regulatory Commission staff met with Mr. Oscar R. Lee, Vice President Electric Production, and other members of his staff of Public Service Colorado, to discuss the results of the NRC emergency preparedness appraisal of the Fort St. Vrain Nuclear Generating

^

Station. At the meeting, problems needing immediate attention were identified and a mutually agreed-upon date for discussing commitments was establishe __- , -__

_ _ _ . - _ - _ _ .__, , . __ . . ~ , , , - . - _ .

ANNEX A INDIVIDUALS CONTACTED A. Selected Licensee Individuals Contacted NAME TITLE R. Alps Security Supervisor P. B. Bearly Training Instructor M. B. Bennett Licensed Senior Operator D. B. Bilstein Senior Programmer M. L. Block Reactor Operator

• • F. J. Borst Radiation Protection Manager C. D. Brewer Supervisor Records Center D. J. Brown Results Engineer

• • L. Brey Manager, Nuclear Engineering B. Burns Director, Media Relations S. Caines Training Secretary M. O. Collins Technical Clerk and Recorder W. A. Craine Superintendent, Maintenance W. J. Franek Site Engineering Manager C. H. Fuller Engineering Supervisor

• • J. W. Gahm QA Manager G. D. Gilliland Senior Programmer - Lookout Center J. P. Hak Reactor Operator D. E. Haloin, J System Analyst J. E. Hanlon Auxiliary Tender C. D. Harding Senior Storekeeper E. D. Hill Station Manager D. B. Holmes Reactor Operator l C. C. Holland Licensed Senior Operator D. P. Hood Shift Supervisor A. Horsechief HP Technician B. Husted QA Auditing Coordinator D. L. Klaus Senior Analyst R. E. Lamb Electrician K. L. Latimer HP Technician

• • 0. R. Lee Vice President of Production M. D. Lombard Nuclear Engineer R. L. Marcus Lead Security Officer-Trainee

• • L. M. McBride Tech / Administrative Service Manager V. McGaffic Chemistry Supervisor P. McMahan Coordinator, FSV Nuclear Info. Center M. Miller Engineer, Nuclear Projects Engineering G. B. Moore Reactor Operator

• • Denotes those individuals attended the exit meeting on January 15, 1982.

.- = -

NAME TITLE J. S. Nickles HP Technician M. Niehoff . Supervisor, Nuclear Projects Engineering

J. O'Donahue HP Technician M. R. Prochownik Radiochemistry Lab. Assistant

J. R. Reesy Nuclear Design Manager

5. Reeves News Director, Media Relations

! G. U. Reigel ' Shift Supervisor

R. Reiss QA Specialist T. E. Schleiger HP Supervisor

• • J. M. Sills Technical Services Engineer

• • L. W. Singleton QA Supervisor H. Starner Design Coordinator

, E. Stroud Senior HP Technician i

J. G. Vandyke Shift Supervisor i

• • R. E. Wadas Training Supervisor

• • D. W. Warembourg Manager Nuclear Production R. W. Webb Maintenance Supervisor

.,

S. Willford Training Instructor

] W. E. Woodard Health Physicist

,

.

I i

,

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• • Denotes those individuals attended the exit meeting on January 15 198 ,

.

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B. Selected Nonlicensee Individuals Contacted NAME TITLE H. Andrews < Sheriff, Weld County, Colorado P. Bryne Director, Colorado Division of i Emergency Service R. D. Ceretto' Fire Chief, Fort Lupton, Colorado M. Davis Postmistress, Platteville, Colorado

• • M. W. Dickerson '

NRC Senior Resident Inspector R. Estereick Weld County Communications C. Koontz ' Editor, Fort Lupton Press D. Lawton Operations Officer, 000ES W. Martin Radiological Defense Officer, D0 DES J. L. Montgomery NRC Regional State Liaison Officer

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• • G. L. Plumlee III NRC Resident Inspector D. Vickers Editor, Platteville Herald E. P. Wilkinson President, INP0 t

!

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• • Denotes those individuals attended the exit meeting on January 15, 1982.

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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FIGURE I 3 ONSITE/0FFSITE EMERGENCY ORGANIZATION j FORT ST. VRAIN NUCLEAR GENERATING STATION )

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TECHNICAL SUPPORT CENTER l'

PERSONNEL CONTROL CENTER CONTROL ROOM L

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STATE EMERGENCY FORWARD EXECUTIVE 1 COPMAND POST COMMAND POST i OPERATIONS CENTER  ;

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FIGURE 2 EMERGENCY ORGANIZATION (ALERT, SITE EMERGENCY, GENERAL lllERGENCY)

FORT Sl. VRAIN NUCLEAR CORPORATE STATION EMFRGFMCY DIRECTOR TSC DIRFCTOR DW M NEW 0F PRODUCTION OF ENG. & PLANNING MGR NUC PROD STATION MGR l CONTROL ROOM DIRECTOR STATION TECHNICAL LI A{SSIL ENGRG & TECH ANALYSI PCC DIRECTOR -

SUPT OF SHIFT . TECH.& ADMIN TEC SR PLT ENGR RX ENGR SCHED/S TRAINING __ _ OPERATIONS SUP SERVICES SERVICES STORES SUPV SUPV PLANT CONDITION ASSES l_ MG JUEL OFF-DUTY OFF-DUTY _ PLANT CONTROL CLERICAL ASSISTANCE

__ PERSONNEl ACC00NTABIlITY SHIFT SUPV ShlfLSUEL 4 - '

SHIFT SUPERVISOR CLERICAL STAFF SECURITY FORCE, HP TECHS, SCtlED/QC STAFF, TRAINING GENCLEAMENAEE~ l P OPm0N m MM g SRT MEDIA RE MEDIA RE MAINTENANCE, --

REPAIR, DAMAGE CONTROL INSTR & CONTROL SUPPQR MAINT, STAFF, I&C TECHS RESULTS SR RESULTS -

TECflNICAL' ASSISTANCE _

ENGRG SUPV ENGINEER -

SHIFT TECH ADVISOR

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HAZARDS __ CONTROL ,

FIRE BRIGADE PERSONNEL HEALTH PHYS & RAD ASSES HP SUPV

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NOTE-OPERATING STAFF EllppnpT PHUSICIST ' NUMBkROFSTAFFSUFPORTPERSONNEL IN PCC WILL VARY ACCORDING T0 i ADMIN & LOGISTICS SUPPORT EQPT OPERATIONS & SEVERITY OF EMERGENCY AND SPECIFIC AUXILIARY TENDERS CLERICAL SENIOR . . -

SITUATIONAL NEEDS

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j l PERSONNEL CONTROL CENTER CONTROL ROOM FORWARD COMAND POST TECHNICAL SUPPORT CENTER l

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