IR 05000267/1985018

Insp Rept 50-267/85-18 on 850617-21.No Violation or Deviation Noted.Major Areas Inspected:Emergency Preparedness Exercise Observation,Evaluation & Insp

ML20135H591
Person / Time
Site:	Fort Saint Vrain
Issue date:	09/10/1985
From:	Baird J, Terc N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20135H588	List: IR 05000267/1985018 ML20135H587
References
50-267-85-18, NUDOCS 8509240045
Download: ML20135H591 (7)

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APPENDIX U. S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/85-18 License /CP: ORP-34 Docket: 50-267 Licensee: Public Service Company of Colorado P.O. Box 840 Denver, Colorado 80201 i Facility Name: Fort St. Vrain Nuclear Generating Station Inspection At: Fort St. Vrain Site, Platteville, Colorado i Inspection Conducted: June 17-21, 1985

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Inspector: )"'- * (

Nemen M. Terc, NRC Team Leader

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Other Inspectors:

J. MacLellan, PNL

, S. Hawley, PNL F. McManus, Comex G. Wehman, EG&G T. Workinger, Comex A. Smith, EG&G

Approved: __ h d $M J.'8. Baird, Acting Chief Dats f//o' f5-Emergency Preparedness and Safeguards Programs Section

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Inspection Summary Inspection Conducted June 17-21,1985 (Report 50-267/85-18)

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Areas Inspected: Routine, announced emergency preparedness exercise observa-tion, evaluation and inspection. The inspection involved 265 inspector-hours onsite by seven NRC and contract inspector Results: Within the emergency response areas inspected, no violations or 1 deviations were identified. Eleven deficiencies were identified by NRC and 1 contractor inspector <MP24CM)45 85 CMP 19  ;

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-2-DETAILS Persons Contacted Principal Licensee Personnel T. Dice, Senior Reactor 00perator G. Moore, Senior Reactor Operator H. O'Hagen, Shift Supervisor D. Evens, Control Room Director G. L. Glass, PCC Director

• H. G. Olson, QA Supervisor T. Schleiger, Sr. Health Physics Representative

• F. Novacheck, Technical / Admin. Services Manager

• 0. Clayton, Technical Services Engineer

"S. Stanley, Technical Services Engineer

• M. Ferris, QA Operations' Manager M. Speed, Quality Assurance Engineer A. Greenwood, Quality Assurance Engineer J. Gahm, Manager, Nuclear Production H

• C. Fuller, Station Manager

"L. Singleton, QA Manager

• F. Borst, Support Services Manager

• 0. Lee, Vice President, Nuclear Production

• R. Walker, President and CEO

• D. Alberstein, Member NFSC

• B. Matheney, Member NFSC The inspectors also contacted other licensee employees during the course of the emergency exercise. They include chemistry and health physics technicians, reactor and auxiliary operators, members of the security force and maintenance personne * Denotes those present at the exit intervie . Licensee Action on Previous Inspection Findings (Closed) Open Item (267/8419-01): The control room staff was adequately informed of plant status during the exercise. This item is close (Closed) Open Item (267/8417-85): Procedures were followed in the control room (CR), technical support center (TSC) and in the personnel control center (PCC). This item is close . Exercise Scenario The exercise scenario was reviewed to determine if provisions had been made for the required level of participation by state and local agencies, and that all the major elements of emergency response would be exercised in accordance with the requirements of-10 CFR 50 and the guidance criteria in NUREG 0654,Section I _ _ _ - _ - _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _

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The review included an evaluation of the technical adequacy of both,

! operational and radiological aspects of the scenario. In addition, an j evaluation of its internal consistency, and the information provided to l participants, observers, controllers and evaluators, was made.- Results of this review were as follow ~

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• The scenario failed to specify which actions would be simulated and to give reasons'for-the simulation * The technical challenge to the operations staff appeared to be limited. In addition, technical reasons for the failure of corrective actions which.would have stopped or limited the release were not provided by the scenario, and as a consequence were not available to the. operators to-add realism to their action * Initial plant conditions were not describe * Some messages prompted the emergency staff, coaching them and facilitating their response, and thus diminishing the level of l

realism and free pla *

Controller cards were incomplete. For example, data or infor-

'mation for vario'us 'rganizational o elements appeared on the same sheet without instructions on the order of presentatio l

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In addition, instructions needed to aid exercise controllers in handling and distributing data were lackin *

Contingency messages, needed to maintain the exercise on schedule when the response from participants expected was inadequate, were lackin ,

Radiological data for implant conditions, search and rescue 'and first aid scenario, and onsite and offsite monitoring teams were generally incomplete. In addition, thyroid dose rates and radiotodine release rates provided by the scenario were inconsistent with offsite field monitoring dat ' Based on the above,- the following item is considered to be an emergency preparedness deficiency:

Internal inconsistencies and lack of completeness in the scenario data and instructions for players and controllers resulted in various instances of unnecessary simulations, coaching and a lack of realism. As a conse-quence, some exercise objectives were not completely demonstrate .(267/8518-01)

No violations or deviations were identified.

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4. Deficiencies Identified by NRC Inspectors Deficiencies, grouped by location or function, identified by NRC inspectors during the exercise were as follows: l Control Room Initial plant conditions were provided to the control room staff assigned to respond to the simulated emergency at 0922 by the exercise controller and the exercise was initiated at 0945 with a seismic event and loss of six tower fan's. This prompted the declaration of an Alert emergency classification and the commencement of an orderly shut down of the reactor at 0949. A second seismic event at 1030,. coinciding with a total loss of offsite power, a' failed open relief valve and a release of radioactivity offsite, resulted in the declaration of a General Emergency at 110 The NRC inspector in the control room observed the appropriate use of Emergency Implementing Procedures (EIPs) for classifying events and noted that the initial notifications to state'and local agencies were made promptly (completed at 0957)'and efficiently by the control room communicato The NRC inspector noted that the shift supervisor (SS) was formally relieved by the Control Room Director, and that announcements and frequent updates were made to keep the control room staff aware of significant events as they occurre The NRC inspector, howeser, observed the following deficiencies:

Controller actions in the control room indicated a deficiency in controller and player training for conducting the exercise. For example, controllers, place information cards on the control panel where the shift supervisor could see repair team messages and the outcome of their actions. Another instance was that controllers allowed players to depart from the senario and form actually turn off audible and visual alarms intended for the actual operating staf (267/8518-02)

Habitability surveys were not conducted in the control roo (267/8518-03) Technical Support Center The NRC inspector observed that the TSC was promptly activated according to procedures, after the declaration of Alert and declared operational at 1023. The TSC director assumed overall

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responsibility for emergency coordination and direction making a

formal. announcement at that time. The transition of responsibilities from the control- room to the TSC was well

, coordinated. The NRC inspector noted that the TSC was a well planned f facility with adequate. space for assigned personnel to perform their f required function The NRC inspector, however, noted the following deficiencies:

l Habitability surveys in the TSC were deficient in that the surveys did not include contamination check (267/8518-05)

Information flow within the TSC was deficient. For example, the-

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j communicator did not advise the TSC Director about a real ~

L contamination event which occurred during the exercise. Another instance demonstrating poor information flow occurred when scenario

, monitoring data indicating high levels of radiation were not

reported to decision makers. (267/8518-05)

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Field monitoring team results were not properly logged on sampling data worksheets as required by procedure. (267/8510-06)

, Inplant Repair Teams i

i The NRC inspector observed that a-repair team, consisting of two

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-maintenance employees and a health physics technician failed to i adequately implement radiological precautions, in that they removed ;

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their respirators, failed to check pocket dosimeters, and removed i their potentially contaminated anticontamination clothing within the j -control room office space. This is considered to be a deficiency in 3 training of personnel in radiological control procedure !

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1 Accountability of Personnel l'

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The NRC inspector noted that approximately 50 percent of plant personnel that would report to the main building lunch room during 7 site accountability were prepositioned in the lunch room prior to-the sounding of the site evacuation alarm. Others were prepositioned in adjacent area In addition, the accountability method'used was

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inadequate in that it was accomplished by visual identification only.

Accountability of all site personnel was therefore not demonstrated 1 under realistic conditions. This in considered to be a deficiency in

, demonstration of site accountability. .(267/8518-08)

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, First-Aid, Search and Rescue 1

. .The NRC inspector observed that no decontamination of the victim

, was attempted during the 30 minute period elapsing between the arrival of the victim in the decontamination facility and his

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-6-subsequent placement in the vehicle. This is considered to be a deficiency in the training of personnel to handle injured and contaminated persons. (267/8518-09) Forward Command Post (FCP)

The NRC inspector noted that the physical layout and licensee support. staffing of the FCP (the licensee's near-site emergency operations facility) required that the Corporate Emergency Director acted more as a communicator between the TSC and the state representative than the manager of overall licensee emergency response. Because of this, the licensee failed to fully demonstrate coordination of radiological and environmental assessment, development of recommendations for public protective actions, and management of onsite and emergency operations facility activities. This is con-sidered to be a deficiency in the direction and control of the licensee's emergency response activitie (267/8518-10)

No violations or deviations were identifie . Exercise Critique The NRC inspection team attended the post-exercise critique conducted by the licensee staff on June 19, 1985, to evaluate the licensea's identification of deficiencies and weaknesses as required by 10 CFR 50.47(b) (14) and Appendix E to Part 50, paragraph IV. The licensee's staff identified the deficiencies listed below and stated that responsibilities for followup and corrective actions would be assigned after a final review of their finding. Corrective actions for these deficiencies will be examined during a future NRC inspectio * A lack of organizational control occurred when the Control Room Director escalated the classification to General Emergency, preempting the Corporate Emergency Director who had assumed the emergency coordinator responsibilitie * There were no written procedural requirements for the use of self contained breathing apparatus (SCBAs), or for checking out the same before using the * Inplant radiological data was lacking for the inplant scenari As a consequence, it was not possible for team members to evaluate radiological conditions and demonstrate adequate response *

The content of radiation protection briefings for in plant teams was generally vague, and without useful informatio .

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-7-6. Exit Interview The NRC inspection team met with licensee representatives identified in paragraph 1 above. The NRC team leader summarized the deficiencies observed during the exercise. The NRC team leader stated that although a number of deficiencies had been identified during the exercise, within the scope and limitations of the scenario, the licensee actions were found to be adequate to protect the health and safety of the public, and that such actions were consistent with their Emergency Plan and implementing procedures. No violations or deviations were reported.

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