ML20011D330

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Insp Rept 50-267/89-22 on 891114-16.No Violations Noted. Major Areas Inspected:Licensee Performance & Capabilities During Annual Exercise of Emergency Plan & Procedures
ML20011D330
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 12/13/1989
From: Powers D, Spitzberg D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20011D329 List:
References
50-267-89-22, NUDOCS 8912260171
Download: ML20011D330 (8)


See also: IR 05000267/1989022

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APPENDIX A

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U.S. NUCLEAP. REGULATORY COMMISSION

REGION IV

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NRC Inspection Report:

50-267/89-22

Operating License: DPR-34

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Docket:

50-267

Licensee: Public Service Company of Colorado (PSC)

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P.O. Box 840

Denver, Colorado 80201-0840

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Facility Name:

Fort St. Vrain Nuclear Generating Station (FSV)

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Inspection At: Weld. County, Platteville, Colorado

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Inspection Conducted:

November 14-16, 1989

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Inspector:

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Dr. D. B. Spitzt;grg/Fr.efgency Preparedness

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Analyst (NRC Team Lelater)

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Accompanying

Personnel:

P. W. Michaud, Resident Inspector

E. M. Podolak, Emergency Preparedness Analyst, NRR

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'F. L. McManus, Comex Corporation

Approved:

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Dr. D. A. Powers, Chief, Security and

Date

Emergency Preparedness Section

Inspection Summary

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Inspection' Conducted November 14-16, 1989 (Report 50-267/89-22)

' Areas Inspected:

Routine, announced inspection of the licensee's performance

and capabilities during an annual exercise of the emergency plan and

procedures.

The inspection team observed activities in the control room (CR),

technical' support center (TSC), forward command post (FCP), and personnel

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control center (PCC) during the exercise.

Results: Within the areas inspected, no violations or deviations were

identified.

Three exercise weaknesses were identified by the inspection team

(paragraphs 4, 7, and 8). Weaknesses identified included the diversion of key

CR personnel from direct reactor evaluation and control activities, failure of

emergency response teams to follow adequate health physics practices, and

8912260171'891218

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inadequacy of_the plant public address system's audibility in certain onsite

locations.

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Generally, the licensee's response to the exercise is considered to be

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excellent and assures.an emergency preparedness program _that is adequate to

protect the health and safety of.the public.' _All. staff performed well

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throughout;the exercise. ' Responsibilities for decision making were clearly.

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defined, and almost all actions were performed in accordance with approved

procedures.

In general,-communications were effective and timely.

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111censee's self-critique-identified weaknesses and involved the participation

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DETAILS

1.

Persons Contacted

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PSC

  • A. C. Crawford, Vice President, Nuclear Operations

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  • C. H. Fuller, Manager, Nuclear Production and Station Manager
  • J. K. Eggebroton, Manager, Technical Projects
  • M. E. Deniston, Superintendent of Operations
  • P. F. Tomlinson, Manager, Quality Assurance Division

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  • H. L. Brey, Manager, Nuclear Licensing and Resource Management Division-

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  • 0. J. Clayton, Emergency Planning Coordinator
  • H. O'Hagan, Manager, Dafueling/ Decommissioning

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  • J. P. Hak, Superintendent of Maintenance
  • D. W. Evans, Manager, Operationt,/ Maintenance
  • F. J. Borst, Manager, Training and Support
  • T. E. Schleiger, Superintendent, Chemistry and Radiation Protection
  • L.

R.' Sutton, Supervisor, QA Auditing

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  • R. Millison, Senior Technical Services Engineering Technician

Other

  • R. E.~Farrell, Senior Resident Inspector
  • J. Everett, Colorado Disaster Emergency Services
  • P. Hatiker, Observer, State-Emergency Operation Center
  • R. Hatter, Director of Disaster Emergency Services
  • J. Truly,= Director of Disaster Emergency Services
  • Denotes those present at the exit interview.

The inspector also held discussions with other station and corporate

personnel in the areas of security, health physics, operations, training

and emergency response.

2.

Followup ~on Previous Inspection Findings (92702)

(Closed) Deficiency (267/8518-09):

Inadequate training to prepare first

aid, search and. rescue responders to properly decontaminate injured and

contaminated persons.

The inspector observed the response of emergency

personnel to two contaminated individuals.

One, a severe injury victim,

had the contamination surrounding the injury properly assessed prior to

transporting to the medical facility.

Decontamination was not attempted

on this individual due to the severity of the injury.

A second

contaminated victim was observed to have been promptly and properly

decontaminated by emergency responders.

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(Closed) Deficiency (267/8719-04):

Failure of emergency responders to

properly characterize and indicate contamination levels on injury victims

in accordance with Procedure RERP-MEP.

The inspector reviewed

Procedure RERP-MEP (Revision 21), which had been revised to make the une

of contamination tags on the victim optiona?.

The handling of a

contaminated injury victim was observed during the 1989 exercise, and it

was determined that surveys of the victim. properly characterized the

levels of contamination of the victim in accordance with RERP-MEP.

(Closed) Exercise Weakness (267/8822-01):

Failure of the CR staff to

complete notification messages properly.

The inspector observed the

completion of notification forms during the course of the 1989 exercise

and determined that all notification messages and forms were completed

properly.

(Closed) Exercise Weakness (267/8822-02):

Procedure RERP EP-CLASS, " Event

and Emergency Classification Overview," did not contain emergency action

levels (EALs) for a notice of unusual event (NOVE) on loss of electrical

power consistent with NUREG 0654, Appendix 1.

The inspector reviewed

EP-CLASS, Issue 7, dated July 26, 1989, and found that it now contains the

appropriate EAL classification for a NOVE on a loss of offsite or onsite

AC power.

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(Closed) Exercise Weakness (267/8822-03):

Inadequacies in

Procedure RERP-CR, " Implementing Procedure-Control Room," in notification

formats and timely communication of event information.

The inspector

reviewed-Issue 12 of Procedure RERP-CR dated July 26, 1989, and determined

that instructions for proper event notifications and communications of

events including radiological releases is included in Attachment B.

(Closed) Exercise Weakness (267/8822-04):

The staff at the PCC did not

maintain continuous radiation exposure records of in plant teams.

The

inspector reviewed the PCC accountability records maintained on

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Checklist 8 of RERP, " Implementing Procedure." Dosimetry entries were

properly maintained for dispatched and returning emergency teams.

3.

Program Areas Inspected

.The inspection team observed licensee activities in the CR, TSC, PCC, and

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FCP during the exercise.

The PCC and FCP are equivalent to the operations

support center and the emergency operations facility, respectively, both

referenced in NUREG-0654 and 0696.

The inspection team also observed

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emergency response organization staffing, facility activation, detection,

classification, and operational assessment, notifications of licensee

personnel, and offsite agencies, formulation of protective action

recommendations, offsite dose assessment, in plant corrective actions,

security / accountability activities, and recovery operations.

Inspection

findings are documented in the following paragraphs.

There were various deficiencies identified during the course of the

exercise; however, none of the observed deficiencies were of the

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significance as defined in 10 CFR 50.54(s)(2)(ii).

Each of the observed

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deficiencies has been characterized as an exercise weakness according to

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10 CFR 50, Appendix E.IV.F.5.

An exercise weakness is a finding that a

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licensee's demonstrated level of preparedness could have precluded

effective implementation of.the emergency pr%acedness plan in the event

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of an actual emergency.

It is a finding that needs licensee corrective-

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4.

Control Room' (82301)(1)

The inspection team observed and evaluated the CR staff as they performed

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. tasks in response to the exercise.

These tasks included detection and

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classification of_ events, analysis of plant conditions and corrective

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actions, protective action decision making, notifications, implementation

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of protective actions, dose assessment, post-accident sampling, and

environmental monitoring.

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The CR staff performed well throughout the exercise.

Responsibilities for

decision making were clearly defined and actions were performed in

accordance with approved procedures.

Communications within the CR were

good throughout the exercise.

Habitability was verified promptly and

frequently by health physics personnel.

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Classification of events were made appropriately by the CR staff. 'The

inspector noted, however, that early into the scenario following the

reactor trip at 0808, both the shift technical advisor (STA) and the

senior reactor operator (SRO) were involved in activities other than the

analysis and evaluation of reactor plant conditions.

The STA was filling

out the reactor safety situation report and the SR0 was filling out the

notification of NOVE' form and making the notification calls to the state

and county.

During a 10 to 15 minute period,_these key CR personnel were

diverted from direct evaluation and control of reactor plant conditions.

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.(267/8922-01).

The_CR staff correctly used EALs to determine protective action

recommendations.

Event conditions were consistently examined against the

highest EALS, moving to lower EALs until the events were properly

classified.

The inspector noted that CR staff promptly entered into the

appropriate emergency procedures and adhered to them well.

Control room

personnel did not, however, review or second check use of flow charts or

emergency procedures in order to protect against errors made by the user.

As~an improvement item, the licensee should task CR personnel to

independently verify use and location within critical emergency

procedures.

No violations or deviations were identified in this program area.

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5.

Technical Support Center (82301)(2)

The inspection team observed and evaluated the TSC staff as they performed

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tasks in response to the exercise.

These tasks included activation of the

TSC -accident assessment and classification, dose assessment, protective

action decision making, notifications, implementation of protective

actions, technical support to the CR, post-accident sampling, and

environmental monitoring.

The TSC team appeared well trained and performed very well during the

exercise.

Technical assessment of plant conditions and trending of

parameters were accomplished in an effective and timely manner by TSC

engineering personnel.

Communications to the CR, PCC, and FCP were

effective and TSC briefings were frequent and informative.

The inspector

also observed that TSC habitability was checked every 15 to 20 minutes.

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Status boards were maintained and updated rapidly with data points logged

very close to scenario time.

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No violations or deviations were identified in this program area.

6.

Forward Command Post (82301)(3)

.The inspection team observed and evaluated the FCP staff as they performed

tasks in response to the exercise.

These tasks included activation of the

FCP, accident assessment and classification, offsite dose assessment,

protective action decision making, notifications, implementation of

protective actions, and interaction with state-and local officials.

Activation of the FCP was timely, and player performance was of a competent

and professional nature.

Communications and coordination with the state

and county government representatives were excellent.

Classification of

the general emergency and use of the appropriate protective action

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recommendations were observed to have been appropriate.

No violations or deviations were identified in this program area.

7.

Personnel Control Center (82301)(4)

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The inspection team observed and evaluated the PCC staff as they performed

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tasks in response to the exercise.

The tasks included activation of the

PCC, personnel staffing, and support to the CR, TSC, and FCP.

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The inspector observed the assembly and briefing of emergency

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repair / rescue teams and followed the teams into the reactor building to

observe their activities during the exercise.

In two instances the

inspector noted inadequate health physics practices exhibited by the

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response teams as follows:

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Failure to use proper contamination control during medical treatment

of the containated injury victim.

An emergency team member was

observed assisting an emergency medical technician dress and

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stabilize a wound known to be contaminated without using protective

gloves, which had been brought to the scene for that purpose.

Use of

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appropriate protective clothing when treating contaminated injury

victims is specified in Procedure MEP-FSV, Section 8.4.1-8;4.2.

Improper use of respiratory protection equipment.

An equipment

operator exiting the reactor building at Level 7.was observed to have

improperly donned the full facepiece of his self-contained breathing

apparatus.

The facepiece was worn such that his head coverir.g passed

between the sealing surface of the mask and his head, preventing an

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adequate seal.

This is a prohibited practice according to

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ANSI Z88.2, " Practice for Respiratory Protection," - 1980,

Section 7.3.4.

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The failure of emergency response teams to adhere to proper health physics

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practices is considered an exercise weakness (267/8922-02).

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No violations or deviations were identified in this program area.

8.

Security and Accountability (82301)(8)

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The inspection team observed certain elements of the personnel

accountability practices and emergency facility security during the

exercise.

The inspector observed a site communication problem that impacted onsite

accountability.

The announcements of emergency conditions,

classifications, protective actions, and the status of any radiological

release were communicated to onsite personnel via the plant public address

system.. These announcements and alani.s were not audible in the resident

inspector's office nor in the main warehouse, both within the protected

area. .This was noted to have impaired the rapid evacuation and

accountability of site personnel.

The inadequate volume or coverage of the plant public address system was

identified.as an exercise weakness (267/8922-03).

No violations or deviations were identified in the program area.

9.

Licensee Self-Critique

The inspectors observed and evaluated the licensee's self-critique for the

exercise.

The inspector determined that the process of self-critique involved

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adequate staffing and resources and involved the participation of higher

management.

The licensee identified five weaknesses as summarized below:

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Media-relations personnel seemed unfamiliar with the draft / final

process of press release approval.

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Contamination control practices were weak among first responders to a'

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contaminated injury victim.

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Ineffective communications between the TSC, CR, and PCC resulted in a

delay in dispatching an emergency medical technician to the medical

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A response team entered the-reactor building to simulate dressing out

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without proper protective clothing and without authorization by a.

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controller.

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The performance of the plant public address system-was inadequate.

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The inspectors noted that the licensee was able to properly identify and

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characterize a number of exercise weaknesses and that several coincide

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The licensee's critique included

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preliminary proposed corrective actions for identified weaknesses and

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improvement items.

No violations or deviation were identified in this program area.

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'10.

Exit Interview

The inspection team met with the resident inspectors and licensee

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representatives indicated in paragraph 1 on November 16, 1989, and

summarized the scope and. findings of the inspection as presented in this-

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report.

The' licensee acknowledged their understanding of weaknesses and

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agreed to examine them to find root causes in order to take adequate

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corrective measures.. The licensee did not identify as proprietary any of

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the materials provided to or reviewed by the inspectors during the

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inspection.

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