IR 05000267/1986015

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Ack Receipt of 860822 & 27 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-267/86-15
ML20210H532
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 09/24/1986
From: Gagliardo J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Robert Williams
PUBLIC SERVICE CO. OF COLORADO
References
NUDOCS 8609260189
Download: ML20210H532 (2)


Text

July 24, 1986

SUBJECT:

I&E Inspection Report 86-15 REFERENCE: NRC Letter, Gagliardo to Williams, dated 07/24/86 (G-86406)

Dear Mr. Gagliardo:

August 22, 1986

SUBJECT:

I&E Inspection Report 86-15 REFERENCE: NRC Letter, Gagliardo to Williams, dated 07/24/86 (G-86406)

Dear Mr. Gagliardo:

This letter is in response to the deficiencies received as a result of inspections conducted at Fort St.

Vrain during the period May 19-22, 1986.

The following response to the deficiencies is

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hereby submitted.

(267/8615-02) -

"The Plan and RERPs do not correctly implement the requirements for notifying the NRC immediately after state and local agencies and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of an emergency classification as stated in 10 CFR 50.72(a)(3)."

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P-86533-2-August 27, 1986 (1) The corrective steps which have been taken.and the results achieved:

The implementing procedure, RERP-CR, which is the controlling procedure for the Operaticas staff to make required notifications was revised to ensure all wording indicates required NRC notification immediately following state and local agencies. The exact statement added/ revised in RERP-CR is as follows:

" Notification of offsite cathorities will be initiated within 15 minutes after the declaration of an emergency.

Notification to the NRC will be made immediately after notification of the appropriate State and local agencies and not later than one hour after the time of event declaration, except for non-emergency classifications requiring a report within one or four hours."

This procedural change is in Issue 8 of RERP-CR, which became effective on July 17, 1986.

(2) Corrective steps which will be taken to avoid further deficiencies:

To ensure that this, deficiency is positively' eliminated, the existing lesson plans will be reviewed and revised, as necessary, in order that all licensed operators fully understand the notification time requirements associated with the various agencies, including the NRC. Also, the lesson plans associated with the emergency organization will be reviewed and revised, as needed, to ensure all personnel who may be responsible for initiating notification calls, understand the time requirements.

(3) The date when full compliance will be achieved:

SEPTEMBER 30, 1986 (267/8615-03) :

"An unannounced drill has not been conducted to determine if the emergency staffing augmentation goal commitment can be achieved."

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P-86533-3-August 27, 1986 (1) The corrective steps which are being taken and the expected results:

An objective of FOSAVEX-86 (Fort St.

Vrain's 1986 emergency exercise) was to test the off-hours staff augmentation.

The inadequate performance of this augmentation test indicated that the system needed thorough review and revision.

The present system of relying on individuals placing telephone'ralls, in a tier design, is being modified to ensure adequate depth in required personnel to make calls, and reduce the number of such calls needed to' be made by each individual.

The "fanout" procedures will be modified and the responsible individuals instructed in the revision prior tc the change being implemented.

Fort St.

Vrain is currently gathering information from other facilities around the United States for additional input.

It is expected that the present system will be modified on or before November 14, 1986.

Required training, including a

table-top

" walk-through",

should be completed by November 30, 1986.

Following completion of the training requirements, the system will be implemented and an unannounced test of the new system will take place.

Depending on the results of the test, further revisions will be implemented.

Following successful results, periodic testing of the "fanout" system will take place to ensure personnel are familiar with i t s'

requirements.

These periodic tests will vary in degree from requiring call-back to the site, to requiring physical response to the emergency response facilities.

(2) Corrective steps which will be taken to avoid further deficiencies:

An industry review is currently underway to identify an emergency organization notification system which would satisfy Fort St.

Vrain's needs.

Fort St. Vrain will keep the NRC abreast of our findings as a decision is made.

(3) The date when full compliance will be achieved:

Revision of existing system: NOVEMBER 30, 1986 NRC Progress report on new system: prior to DECEMBER 31, 1986 (267/8615-04) :

"No procedural methods had been provided to incorporate radiological field monitoring data into dose assessment and projections".

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o P-86533-4-August 27, 1986 (1) The corrective steps which have been taken and the results achieved:

This deficiency has been determined to be the result of several factors.

In part, this deficiency resulted from the fact that, as stated by the auditors, no explicit procedures were developed to address the need to carry out this function, despite the intent of Fort St. Vrain to always incorporate this'information into its protective action recommendations when available during an emergency.

This item is currently under review:to evaluate available means to formalize the incorporation of field monitoring data into the dose assessment function and procedures, and to implement this data as part of the protective -action recommendations process.

(2) The corrective steps which will be taken to avoid further deficiencies:

A formal procedure will be prepared based upon industry review, affected personnel will be fully trained, and the procedure will be impicmented by December 31, 1986.

It is also felt by PSC that the entire concept of the dose assessment function should be evaluated, based upon the recent experience during FOSAVEX 86.

PSC intends to review that concern and act upon the results of that evaluation with appropriate changes to the emergency organization.

(3) The date when full compliance will be achieved:

DECEMBER 31, 1986 Should you have any further questions, please contact Mr. Frank J.

Novachek at (303) 620-1007.

Sincerely,

.W.

Gahm Manager, Nuclear Production Division Fort St. Vrain Nuclear l

Generating Station JWG/ojc i

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