IR 05000267/1986030

Insp Rept 50-267/86-30 on 861027-31.Deviation Noted:Failure to Implement Corrective Action to Preclude Recurrence of Violation by Submitting Changes to Radiological Emergency Response Plan in Timely Fashion

ML20214E915
Person / Time
Site:	Fort Saint Vrain
Issue date:	11/19/1986
From:	Baird J, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214E859	List: IR 05000267/1986030 ML20214E856 ML20214E876
References
50-267-86-30, NUDOCS 8611250137
Download: ML20214E915 (5)

Text

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APPENDIX B U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/86-30 License: DPR-34 Docket: 50-267 Licensee: Public Service Company of Colorado (PSC)

P. O. Box 840 Denver, Colorado 80201-0840 Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)

Inspection At: Fort St. Vrain, Colorado Inspection Conducted: October 27-31, 1986 Inspector: O /d /jd //// 9/pr, JfB. Baird, Emergency Preparedness Analyst Date

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Approved: y utw t l l // "/ /ff, et L. A. Yandell, Chlet, Emergency Preparedness Date'

and Safeguards Programs Section Inspection Summary Inspection Conducted October 27-31,1986(Report 50-267/86-30)

Areas Inspected: Routine, unannounced inspection of changes to the licensee's emergency preparedness program and licensee audits of the emergency preparedness progra Results: Within the emergency response areas inspected, one deviation was identified (paragraph 3 - failure to implement corrective action to preclude recurrenceofaviolation). No violations were identifie %2SDhk G

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-2-DETAILS Persons Contacted Principal Licensee Personnel K. Blanchard, Records Center Supervisor

• F. Borst, Support Services Manager 0. Clayton, Technical Services Engineer P. Collins, Nuclear Documents Specialist

• M. Ferris, Quality Assurance Operations Manager

• C. Fuller, Station Manager J. Gahm, Manager, Nuclear Production

• A. Greenwood, Supervisor, Quality Assurance Auditing A. Kitzman, Nuclear Documents Su)ervisor

• Millison, Technical Services Engineering Technician

• F. Novachek, Technical / Administrative Services Manager H. Olson, Member, Nuclear Facility Safety Committee

• J. Sills, Technical Services Su]ervisor

• T. Schleiger, Supervisor, Healti Physics

• P. Tomlinson, Manager, Quality Assurance Division R. Willians, Jr. , Vice President, Nuclear Operations NRC

• Ireland, Chief, Engineering Section

• Denotes those present at the exit intervie . Licensee Action on Previous Inspection Findings (Closed) Violation (267/8419-01): The NRC inspector deterained that changes to the emergency plan and implementing aracedures had been submitted to the NRC within 30 days after the clanges were made in accordance with the requirements of 10 CFR 50.54(q) and the licensee's response to the NRC Notice of Violation dated November 16, 1984. However, a related deviation was identified and is described in paragraph This item is close (Closed) Violation (267/8529-02): The NRC inspector determined that an adequate review of the emergency preparedness program had been provided for the 12 month period ending in 198 This item is close (Closed) Deficiency (267/8615-02): The NRC inspector determined that the emergency' plan and implementing procedures revisions correctly implement the requirement for notifying the NRC immediately after state and local agencies and within one hour of an emergency classification as stated in 10CFR50.72(a)(3). This item is close .. .

-3- Changes to the Emergency Preparedness Program The NRC inspector reviewed the licensee's program for control of changes totheRadiologicalEmergencyResponsePlan(RERP)andimplementing procedures, and discussed the status of changes to the staff, facilities, and equipment since the last NRC inspection of this are The NRC inspector determined that a management control system to review and approve changes to RERP documents was in effect and included review and ap)roval by the Plant Operations Review Committee (PORC) to determine that tie chan Breparedness.gesdidnotdegradesafetyanddidnotdecrea Distribution of changes was in accordance with a Document istribution Handbook The NRC inspector selected, which listed all of the required distribution. sampl which had been completed during the period the fromimplementing procedures,d 1984 to the present, an verified that they had received appropriate review and were submitted to the NRC within 30 days of issuance as rec uired by 10 CFR 50.54(g). Failure to submit the changes as required hacbeenpreviouslyidentifiedasaviolation(267/8419-01). While reviewing the corrective action by PSC the NRC insaector determined that the verification of distribution commi{ted to by PS: to preclude recurrence of the violation, by incor) orating the verification into a quarterly surveillance test,'had not 3een accomplished. The NRC inspector brought this to the licensee s attention as an a) parent deviation from a commitmenttotheNRC(267/8630-01). Prior to tie end of the inspection, PSC completed a Procedure Deviation Report which added a requirement to procedure SR-TE-8-0, " Maintenance of Emergengy Preparedness," to verify distribution and added a precautionary note identifying this change as a commitment to the NRC which could not be deleted without issuance of comparable controls. A Document Coordination and Concurrence form was also initiated to incorporate the change in the procedur Discussions with the emergency preparedness staff held by the NRC inspector indicated that changes to PSC staff organization, equipment, and facilities during, emergengy responsethe period had any,majorchangesintheemergencypreparednessprogram. It was anticipated that changes to the program during 1987 would be based on findings from the 1986 emergency exercis The following is an observation the NRC inspector called to the licensee's attention. This observation is neither a violation nor an unresolved ite This item was recommended for licensee consideration for improvement, but it has no specific regulatory requiremen Provisions should be made for cross-referencing emercency plan and implementing procedures changes documentation with NEC transmittal letters to facilitate audit and surveillance activitie No violations were identifie l

.. o-4- Licensee Audits TheNRCins)ectorreviewedauditreportsandhelddiscussionswithQuality Assurance (QA)personnelandamemberoftheNuclearFacilitySafety Committeetodeterminethestatusofcompliancewith10CFR50.54(t)

requirements for independent review of tile emerger,cy preparedness program each 12 month Reports reviewed included the following:

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NFSC E-86-01, " Review of Emergency Preparedness Procedures"

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NFSC E-86-02, " Emergency Preparedness Exercise" The NRC inspector's review and discussions revealed that the two audits identified above constituted an independent review of the arogram within the 12-month period by a part of the PSC organization whic1 had no direct responsibility for development and implementation of the program. The review further showed that an evaluation of the licensee's annual emergency exercise, capabilities, emergency and interfaces with state and local governments )lan andperforme lad been procedures, During the discussions, it was determined that additional broad emergency preparedness training for QA auditors could be beneficial in expanding the capability for evaluating the adequacy of emergency preparedness program elements in the futur The NRC inspector determined that audit reports and findings were transmitted to PSC management, and that the audit records were to be maintained for the life of the plant. It was noted that audit findings were identified to responsible personnel by issuance of Corrective Action and tracked for corrective actions. It was also noted Requests (CARS)ingsandCARsdealingwiththeadequacyofinterfaceswith that audit find state,and local government agencies had been transmitted to those agencie The NRC inspector also reviewed the licensee's action item tracking and discussed impiementation of tracking with PSC personnel to determine if a system had been put in place to identify deficiencies and weaknesses observed during exercises, and to track the items for corrective actions inaccordancewiththerequirementsof10CFR50.47(b)(14)andAppendixE to Part 50 It was noted that three tracking systems were in use,that paragraph IV. followed these items depending on the origin of the ite CARsresultingfromQAauditsandNRCreportsweretrackedbytheFSV Status Keeping System commitments resulting from NRC inspection findings were tracked by the F$V Regulatory Commitment Log; and exercise criticue comments from the annual exercise were routed to key staff and trackec by the emergency preparedness staf Taken together, these systems appeared to adequately track the items identified above, but it also appeared that a prioritized system specifically for emergency preparedness item tracking could facilitate the assessment of corrective action progress on these item o .. .

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The NRC inspector determined that corrective actions for items in the tracking systems appeared to be taken in an appropriate time frame. This included corrective actions for weaknesses and deficiencies identified during the emergency preparedness exercis The following are observations the NRC inspector called to the licensee's attention. These observations are neither violations nor unresolved item These items were recommended for licensee consideration for improvement, but they have no specific regulatory requiremen Provisions should be made for formal emergency preparedness training for QA auditors to enhance their capability to assess the adequacy of emergency pre)aredness program elements reviewed each 12 months pursuant to t1e requirements of 10 CFR 50.54(t).

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Consideration should be given to using the Institute of Nuclear Power Operations (INP0)documentofgoodpracticesfor10CFR50.54(t)

reviews as a resource in formulating audit plans and checklist A tracking system should be provided to consolidate and prioritize emergency preparedness items which require followup action No violations or deviations were identifie . Exit Meeting The NRC inspector met with licensee representatives (denoted in

)aragraph 1) at the conclusion of the inspection on October 31 198 The iRCinspectorsummarizedthescopeoftheinspectionandthefinding The NRC inspector stated that no violations or deficiencies had been identified, but one apparent deviation had been identified. The NRC inspector also acknowledged that immediate action had been taken to correct the deviation and to preclude recurrence.