IR 05000267/1989022

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-267/89-22.NRC Believes Util Ref to Abundance of Senior Reactor Operators Present in Control Room Had No Impact on Plant Evaluation
ML20012D497
Person / Time
Site: Fort Saint Vrain 
Issue date: 03/16/1990
From: Collins S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Crawford A
PUBLIC SERVICE CO. OF COLORADO
References
NUDOCS 9003270418
Download: ML20012D497 (4)


Text

{{#Wiki_filter:, ., ' '. '. * MAR I 61990 i In Reply Refer To: Docket: 50-267/89-22 _ L Public Service Company of Colorado ' ATTN: A. Clegg Crawford, Vice President h Nuclear Operations ' P.O. Box 840 h Denver, Colorado 80201-0840 Gentlemen: , o L Thank you for your letter of January 19, 1990, in response to our letter and ' . inspection report dated December 18, 1989. We have the following comments

regarding your response:

With respect to your response to Exercise Weakness 267/8922-01 regarding the diversion of the shift technical 6dvisor and the senior reactor operator, three points should be stressed: (1) Early in the accident scenario the senior reacter operato,, or as rou- ' have designated him, the Directing Reactor Operator, appeared to be

occupied with filling out not"fication forms and making notification ' calls. Your respense stares that these activities in no way .) interfered with the proper evaluation, analysis, and control of the , rea:: tor. Our point was not this individet.i's interference with ~! ' phnt evaluatinn, but whether he shoula have, in fact, been 'l participating in phnt enlustion.

(2)- It was our observation that during this period (8:08 a.m.), the Shift Supervisor was involved in briefing the arriving Operations , Manager. The Operations Manager assumed the Emergency Coordinator's

position at 8:15 a.m.

Therefore, we believe your reference to the ' abundance of senior reactor operatcrt present in the control room had , no impact on the period in question in terms of plant evaluation, analysis, and control.-

(3) In consideration of the Fort St. Vrain operating license - requirements, the present condition of your facility (defueling/ decommissioning) cannot mitigate any weaknesses or concerns identified in the area of emergency preparedness until plan-revisions are reviewed and approved by the NRC staff.

  • With respect to your response to Exercise Weakness 267/8922-02 regarding improper use of respiratory protection equipment, we observed, contrary to your evaluation, that the individual with an improperly donned respirator was exiting the reactor building, not preparing to enter, as you assert in your. response. While we may also have observed this individual preparing

to enter the reactor building, this was not the basis for the observed weakness.

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f > . .. . . i , ' Public Service Company of Colorado-2-i ! Except as noted above, we accept your explanations and corrective actions relative to Exercise Weaknesses 267/8922-02 and -03.

For Exercise

Weakness 267/8922-01, we request additional information regarding additional , controls you have' implemented to prevent further weaknesses in this area.

' Please provide the additional information within 30 days of your receipt of th h letter so that we may continue our review. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

  • Sincerely, O!!tinal Sita?d Bp

"' .. Samuel J. Collins, Director Division of React 9r Projects cc: Public Service Cortpany of Colorado ATYN: 0, W. Warembourg, Manager , Nuclear Engineering Division , P.O. Box 840 t Denver, Colorado 80201-0840 GA Interr,ational Services Corporation Fort St. Vrair> Sewices ATTN: David Alberstr.it., Manager - P.O. Box f%CS St.n Dieco, California 92138 i Public Service Conpany of Coirrado ATTN: Charles H. Fuller, Manager .' Nuclear Production and Station Manager 16805 Weld Ccunty Road 19-1/2 Platteville, Colorado 80651 Public Service Company of Colorado ATTN: H. L. Brey, Manager, Nuclear Licensing and Resource

Management Division P.O. Box 840 Denver, Colorado 80201-0840 i Public Service Company of Colorado ATTN: P. F. Tomlinson, Manager , ! Quality Assurance Division l 16805 Weld County Road 19-1/2 ' Platteville, Colorado 80651 ' l-l . . --

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. .; 4- . , Public Service Company of Colorado-3-Public Service Company of Colorado ATTN: D. D. Hock, President and Chief Executive Officer P.O. Box 840 Denver, Colorado-80201-0840 Public Service Company of Colorado ATTN: Commitment Control Program Coordinator 2420 W. 26th Ave. Suite 100-D Denver, Colorado 80211 Kelley, Standfield & 0'Donnell ' ATTN:. Mr. J. K. Tarrey Public Service Company Building Room 900 550 15th Street Denver, Colorado 80202 Chai rman Soarc'. cf County Commissioners of Weld County, Colorado Greelvy, Colorado 80631

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Eegional Aepresentative Radiation Programs Environmental Protection Agency .1 Denver Place 999-18th Street, Seite 1300 , Denver,;Colorade 80202-2413 . Department of Health ATTN: Robert M. Quillen, Director Radiation Control Division 4210 East lith Avenue Denver, Colorado - 80220 Colorado Public Utilities Commission l ' ATTN: Ralph Teague, P.E.

1580 Logan Street OL1 Denver, Colorado 80203-U.S. Nuclear Regulatory Commission ATTN: Senior Resident Inspector P.O. Box 640 Platteville, Colorado 80651 , I-l

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,r . . , o i . " L Public Service Company of Colorado-4- -U.S. Nuclear Regulatory Commission ATTN: Regional Administrator, Region IV < 611 Ryan Plaza Drive, Suite 2000 j Arlington, Texas 76011

, , Dr. Olson, Regional Director FEMA Region 8 . Denver Federal Center Eldg. 710 j Box 25267 .i Denver, Colorado 80225-0267 i y!ectoDMB(IE35) ] b bec: DRP i Resident Inspector' - Lisa Shea, RM/ALF Section Chief, DRP/B . DRS 'SEPS File-i MIS System RSTS Operator RIV File Inspector Section Chief , B. Beach

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[. Denver co sa2010640 g\\) [} W j$ 12lM U A. clees crewford . January 19, 1990 t ll g;gy,,, Fort St. Vrain / Unit No. 1 ~ l ' < P-90011 - . a,.. ~ [$$$I U. S. Nuclear Regulatory Comission EE "~~ ! ATTN: Document Control Desk M: E Washington, D.C.

20555 i:8 Docket No. 50-267 !!".C-i s.

. > SUBJECT: Response to NRC t2 ' Inspection Report 89-22 [{ ! REFERENCE: NRCLetter,Collinsto'h " ' "

Crawford, dated

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12/18/89(G-89410) [g , Ge.",tlemen: ! ff

ll".3 &~ This letter is in response to the weaknesses idt.ntified in the , int.pection ccnducted by Dr.

D.

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Spitzberg during the period ' November.*4*6,1989(Inspection 89-?2). The inspection included the implementation of the emergency plan and procedures during the annual ! emergency response ex ucise (FOSAVEX-89).

No violutions or - deviations were identified. There were, however, several weaknesses ' identifted-in the course of the inspection. The following is PSC's respons:t t.nd schedule of corrective actions plarined for each admitted , weakness, as requested.

l 267/8922-01: - , "The diversion early in the emergency of both the STA and SR0 from , activities involving evaluation, analysis, and control of reactor emergency conditions is considered an exercise weakness."

PSC Response: J ' PSC considers that a misunderstanding of the Control P.oom organization and duties was responsible for this perceived weakness, and that the following explanation will resolve this issue.

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..... P-90011-2-January 19, 1990 L During power operations, such as the conditions present for F05AVEX-89, there are three Licensed Reactor Operators (LRO) in the Control Room.

Two of these LR0s are assigned strictly to plant evaluation, analysis, and control. The third, called a Directing Peactor Operator (DRO) maintains the administrative and overview functions associated with Control Room activities.

One of the administrative functions of the DRO is to perform the necessary notifications following any non-emergency or emergency event classification. His activities, in no way, interfere with the proper evaluation, analysis, and control of the reactor and secondary plant.

Following a plant transient, or emergency situation, the Shift Supervisor responds to the Control Room to assume responsibilities and duties ~of the Emergency Coordinator.

In order to maintain proper supervision of the LR0s assigned to the " boards", by procedure, he designates someone (in this case the DRO) to perform the necessary notifications following an emergency classification.

During FOSAVEX-89, once the Operations Manager arrived and assumed the responsibilities of Emergency Coordinator, along with the arrival of the Superintendent of Operations, there were a total of five Senior Reactor Operators present in the Control Room, two of which (one LR0 and the Shift Supervisor) had no auxiliary functions outside of plant evaluation, analysis, and control of reactor emergency t conditions, ' , Based en these procedures and processes. PSC considers that there was never a lack of necessary evaluation, analysis, and control of ' reactor emergency conditions by a SRO, therefore, no corrective , actions are planned.

< The Technical _ Advisor (TA), upon arriving in the Control Room.

l performs a review of the Dain logger (plant computer) to bring him or herself "up to speed" on the emergency event.

Part T this process I involves discussion with counterparts in the Technical Support Center (if manned) and filling in an assessment sheet which highlights key plant parameters and conditions. This process, even though it may seem that the TA is distracted from imediate plant recovery actions,

actually allows the TA to become better informed of the events which l 1ed up to the emergency situation. With this knowledge, the TA can , l then better assist the Control Room staff in evaluation of what took place and how to mitigate the consequences. The TA also assists the Control Room staff with technical evaluations of plant systems, l responses, etc.

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' P-90011-3-January 19, 1990 i Again, PSC believes that this weakness is partially due to a misunderstanding of the Control Room organization, responsibilities r and procedures and that this explanation should clarify the situation and as such, resolve this issue. Considering the staffing size of ) Tort St.

Vrain and the present condition of defueling/ decommissioning, no corrective actions are believed necessary or planned for this weakness.

> 267/8922-02: "The failure of emergency response teams to adhere to proper health

physics practices is considered an exercise weakness."

PSC Response i The first part of this observation refers to the medical response i personnel not using protective gloves during the treatment of the I injured individual. A thorough critique was held with the members of the medical emergency team following FOSAVEX-89.

It is agreed that

overall, some HP practices should have been more closely adhered to.

The Emergency Medical Technician (EMT) who responded to this particular situation was briefed by the Health Physics Technician ' , concerning contamination problems.

It was the decision of the EMT, , with the concurrence of the Health Physics Technician, that the ! in.iury had preference over the contemination levels reported and the . EMT elected to administer first aid without the protective gloves, as the g*; oves may have impaired the LKf's ability to perform proper - first aid.

In precedure MEP-FSV, Sections 8.4.1 and 8.4.2 do not dictate that protective clothing must be worn to administer first aid.

As mentioned. PSC has discussed the observation that closer attention should be given to health physics practices in future responses.

No further carrective actions are planned.

The observation by the NRC Inspector of improper use of respiratory protection equipment is acknowledged. The observed individual did . don his protective equipment in the wrong sequence. The plant t operator donned his Anti-C hood, then his full-face Scott Air Pack.

- However, prior to entering the Reactor Building, the Health Physics Technician assigned to that team noticed this error.

He took the steps necessary to determine that the plant operator had a sufficient face seal prior to proceeding with their assignment.

It was the decision of the Health Physics Technician, based upon the immediate need for the team in the Reactor Building and the fact that the operator had a good face seal, to proceed with the team entering.

Please note that the personnel involved have indicated that the NRC Inspector had left the area following the initial dress-out and was not present for the final equipment check prior to entering the , L Reactor Building.

Therefore, the Inspector did not observe the ' determination that the face seal was good.

. PSC-agrees that the operator donned the equipment in the improper sequence.

This observation will be added to the 1990 respirator protection training program to ensure personnel are aware of the potential dangers of donning protective equipment in an improper sequence.

No further corrective actions are planned.

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__ _ _.... - - -.. -..... f ) [,;. = . P-90011-4-January 19, 1990 167/8922-03 "The inadequate volume or coverage of the plan *, public address system was-identified as an exercise weakness."

, PSC Response This concern was also identified as an exercise weakness by the PSC evaluation-team and was presented as such at the post-exercise ' critique.

PSC has evaluated the problems with the Gai-Tronics systems at Fort St. Vrain. Just prior to FOSAVEX-89, the plant's Gai-Tronics system _' had developed a short in one of the transmitting stations.- This short caused a hissing noise to be transmitted over the entire system. This was considered to be irritating in several office and work areas.

Even though PSC does not condone turning down 'the volume of Gai-Tronics speakers,_this does occur on occasion. The Main Warehouse was-investigated after FOSAVEX-89 and was found to have the volume turned low. The NRC Resident Inspector has informed us-that his speaker is working properly. The.short in the system was repaired and the irritating hissing noise has ceased.

Gai-Tronics speakers have been returned to fully operational-status. A memo from executive-management-will be issued to all Nuclear Operations personnel emphasizing the importance of maintaining proper Gai-Tronics coverage.

Additionally, as the-plant de-staffing continues, the background noise from personnel in all plant areas-will decrease.

No further corrective actions are planned.

If you have any questions or comments associated with this inspection response, please call Mr. M. H. Holmes at (303) 480-6960.

Sincerely, I 46 A h p , A. C. Crawford Vice President Nuclear Operations-ACC/0JC/tk cc: Regional Administrator, Region IV ATTN: Mr.' T. F. Westennan Chief, Projects Section B .(2 copies) Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain Mr. Rick Hatten, Director Division of Disaster Emergency Services State of Colorado , f .....__-_m }}