IR 05000267/1985029

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-267/85-29. Violations Re Failure to Provide Adequate Training & Perform Audits of Emergency Preparedness Program Did Occcur

ML20211K440
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/03/1986
From:	Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Robert Williams PUBLIC SERVICE CO. OF COLORADO
Shared Package
ML20211K444	List: IR 05000267/1985029 ML20211K447
References
NUDOCS 8611170179
Download: ML20211K440 (3)

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NOV 3 1986 In Reply Refer To:

Docket: 50-267/85-29 Public Service Company of Colorado ATTil: Robert O. Williams, J Vice President, fluclear Operations P. O. Box 840 Denver, Colorado 80201-0840 Gentlemen:

Thank you for your letter of February 10, 1986, in response to our letter and the attached flotice of Violation dated Jcnuary 10, 1926. We have reviewed your response and the related information and concluded that the violations, as stated, did occu Our comments on your response are as follows: _ Failure to Provide Adequate Training Paragraphs A.l(l), A.2(1), and A.3(1) of your response together constitute adequate corrective actions for Paragraph A.(1) of the flotice of Violatio Paragraphs A.l(2), A.2(2), and A.3(2) of your response taken together constitute adequate corrective actions for Paragraph A.(2) of the flotice of Violatio We agree that further specialized formal training in the specific areas identified as deficient by the inspectors is required to qualify Health Physics technician Paragraph A.l(4) and A.3(4) of your response together constitute adequate corrective actions for Paragraph A.(4) of the flotice of Violatio Paragraph A.l(3) in your response stated that your training methods were adequat As a consequence, you stated in Paragraph A.2(3) that no corrective actions were required. This statement contradicts the findings of the inspection, which identified that a sample of emergency response personnel, e.g., Health Physics technicians lacked technical knowledge and know how required to perform some of their specific tasks. As a consequence of these findings, the f1RC inspectors determined that your method of training emergency personnel was deficient. We noted that regardless of the above consideration your response stated that grouping students by Emergency Response Facilities is appropriate and adequate to qualify students and that your method of training was thus appropriate and adequat We will consider this response to Paragraph A.(3) adequate pending a review of this training method at a future inspectio '

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Public Service Company of Colorado -2-1 Failure to Perform Adequate Audits The NRC inspectors identified a concern regarding the manner in which Quality Assurance Audits of the Emergency Preparedness Program were conducte The inspectors determined that in order to be effective audits should be performed during the course of normal operations and not almost solely during the conduct of emergency exercises. Observations during exercises mostly establish procedural adherence since the determination of procedural adequacy requires analytical methods which are more precise and thorough than observations made during an exercis The NRC inspectors feel that through the years 1984 and 1985 auditors failed to identify training deficiencies (e.g., inability of Health Physics Technicians to determine whether a plume contained radiciodine).

The NRC inspectors noted that 10 CFR 50.54(t) requires the verification of adequacy of interfaces with State and local governments of interfaces during exercises, but it also requires the evaluation of capabilities and procedures for such interface {

Paragraphs B.1(2) and B.1(3) of your response indicated adequate corrective actions in response to Paragraph E(1) of the Notice of Violations Paragraphs B.2(3) and B.2(4) of your response indicated adequate corrective actions in response to Paragraph B.(2) of the Notice of Violatio The part of your response title " Programmatic Corrective Steps and Results Achieved," properly addressed the concerns of Paragraph B.(3) of the Notice of Violatio We noted that since this inspection substantial changes to your emergency preparedness program have been planned. We will review the implementation

of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintaine We hope that our delayed written response to your letter has not caused any inconvenience to yo

Sincerely, ORIGINAL SIGNED BY:

J. E. Gagliardo, Chief Reactor Projects Branch cc: ~

J. W. Gahm, Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 19h Platteville, Colorado 80651 (ce continued next page)

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Public Service Company of Colorado -3-L. Singleton, Manager, Quality Assurance Division (same address)

Colorado Radiation Control Program Director Colorado Public Utilities Commission bcc to DMB (IE35)

bcc distrib. by RIV:

RPB DRSP Resident Inspector R. D. Martin, RA Section Chief (RPB/A)

RSB Section Chief (RSB/ES)

R&SPB MIS System RSTS Operator RIV File Inspector Section Chief W. L. Fisher R. L. Bangart D. B. Matthews, IE

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