ML20042A523
| ML20042A523 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 02/26/1982 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20042A518 | List: |
| References | |
| P-82056, NUDOCS 8203230520 | |
| Download: ML20042A523 (8) | |
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, y 6 \\/a 3 16805 WCR 19 1/2, Platteville, Colorado 80651-9298 February 26, 1982 Fort St. Vrain Unit #1 P-82056 Mr. John T. Collins, Regional Administrator Region IV Nuclear Regulatory Commission 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
SUBJECT:
Fort St. Vrain Unit No. 1 Emergency Preparedness Audit Confirmatory Action Letter
REFERENCE:
NRC Letter Collins to Lee Dated January 21, 1982 Docket No. 50-267/82-01
Dear Mr. Collins:
In response to your letter of January 21,
- 1982, in regard to confirmation of PSC response to six items of concern noted by the NRC Emergency Appraisal Team during its visit to Fort St. Vrain the weeks of January 4-15, 1982, I am attaching our evaluations of PSC position on those items.
We have reviewed those items in depth and have responded with our plans for actions in those areas of concern, in addition to providing our scheduled implementation dates.
Our responses ( Attachment A) are based on our evaluation of the applicability of each specific item to our emergency preparedness program at Fort St. Vrain, and are based upon our discussions with the Emergency Appraisal Audit Team at the exit interview of January 15, 1982, at Fort St. Vrain. At that exit interview, we were informed that the Appraisal Team would be preparing a report of findings from that audit.
To date, we have not received any further information with regards to that report, and as been able to factor those comments into our
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-2 It is our understanding that we will receive a draft copy of the appraisal findings in the near future.
Very truly yours,
'A-E}' Ww.w{w Manager,NuclearProduc[ tion Don W. Warembourg Fort St. Vrain Nuclear Generating Station DW/jms cc:
Brian Grimes George Kuzymycz David Rohrer Charles Hackney Robert Clark l
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ATTACHMENT A PSC RESPONSE TO CONFIRMATORY ACTION ITEMS 1.
Emergency Action Levels NRC REQUIRED ACTION The licensee's emergency action levels (EALs) shall be
-integrated into the present operating procedures such that they are site specific.
The flow of procedures shall be written to reflect continuity from the station operating procedures into the emergency implementing procedures (RERP-STATION).
PSC RESPONSE Station Emergency Procedures (EPs) have been reviewed for each set of specified symptoms in the EP symptom-action matrix for a particular class of events (e.g. Two Loop
- Trouble, Reactor Scram,
- Fire, etc.),
and an initial emergency classification established.
These classifications have been consolidated into aclassification overview procedure to be included as an introduction to the EPs.
This draft procedure describes both RERP accident classification for FSV and 10CFR50.55 "Significant Event" classification.
In addition, each emergency procedure will be revised to contain a new section (4.0) entitled
" REPORTING / CLASSIFICATION" which reiterates the classifications cited in the classification overview procedure for each set of symptoms.
It is anticipated that response to this action item will be implemented by June 1, 1982.
2.
Respiratory Protection NRC REQUIRED ACTION The licensee shall determine the expected number of onsite emergency personnel who may be required to perform essential duties under conditions of significant airborne radioactive contamination and who, therefore, require self-contained breathing apparatus in order to perform their assigned tasks.
The licensee shall make provisions for acquisition of the necessary quantities of appropriate respiratory l
protection equipment and for locating the equipment in areas safely and quickly accessible to all onsite emergency l
response personnel.
The licensee shall assure the NRC that all emergency response personnel will maintain their capability to safely and efficiently don appropriate respiratory protective equipment.
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PSC RESPONSE PSC has reviewed the anticipated number of essential personnel required to remain onsite to cope with the contingencies of a large scale accident, wherein site evacuation may be required.
It has been determined that these personnel will be required at both the Technical Support Center (TSC) and the Control Room (CR).
Personnel that would normally be required in the Personnel Control Center (PCC) can be relocated to an alternate PCC office.
Both the TSC and CR are provided adequate HVAC filtration and shielding to maintain personnel exposures below limits stated in NUREG-0737 and GDC-19 for Design Basis Accidents.
However, it is necessary to provide for transit of these personnel between the CR and TSC and to any other locations ensite that could become necesssary (e.g., shift change of personnel, valve line-ups, etc.).
It has been determined that five (5) people would be required at the TSC and five (5) people would be required to remain in the CR.
Additionally, six (6) Scott Air-Paks will be provided to personnel required to remain / enter at the Search and Identification Facility / Central Alarm Station and (5) Scott Air-Paks will be provided at the primary and alternate Personnel Control Centers. An additional four (4) Scott Air-Paks are to be provided at the Enginnering/QA building for respiratory training purposes.
PSC already maintains 16 Scott Air-Paks onsite, of which, 8 are directly applicable to the above stated needs, and 8 are required for non-radiological emergency needs.
In summary, PSC is in the process of ordering twenty-four (24) additional Scott Air-paks.
Expected delivery is June 1,1982.
Proper selection, fitting, and use of all respiratory protection gear is taught initially at General Employee Training (GET) and, presently, is being taught on an annual basis at annual GET refresher to all site assigned personnel with emergency j
response assignments.
Based upon promised vendor delivery dates and allowing time for equipment checkout and distrubution, this item will be I
implemented by June 15, 1982.
3.
Offsite Radiological Monitoring Capability NRC REQUIRED ACTION The licensee shall describe their capabilities to perform off-site radiological monitoring to a
sufficient level to demonstrate that the offsite radiological monitoring teams can find and characterize an airborne release plume and obtain the necessary information with which the licensee can perform dose calculations, consequence assessment, and provide input to the decision making for recommending offsite protective actions to appropriate officials.
The licensee's response shall include at a
minimum; location, availability, and capability of vehicles which would be used by the offsite radiological monitoring team during an emergency;
- location, availability, and capability of necessary radiological
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detection and measurement instrumentation and equipment (reference NUREG 0654-Rev.
1,Section I.9.);
e.g.,
capability to determine in the field radiciodine
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concentrations of 1 x 10 ' pCi/cc in air.
PSC RESPONSE The Colorado Department of Health (CDH) has accepted responsibility for offsite radiological monitoring.
- However, it is possible that circumstances may prevent the arrival of CDH monitoring teams to the Forward Command Post (FCP) concurrent with full activation of the FSV emergency organization.
PSC therefore will accept interim responsibility for offsite radiological monitoring within the plume exposure EPZ prior to the arrival of CDH monitoring teams after full activation of the FSV emergency organization.
This will be accomplished by allocating two FSV monitoring teams at the Personnel Control Centec (PCC) to the primary task of offsite radiological monitoring. One of these teams will be primarily used for near-site assignment in the vicinity of the Exclusion Area Boundary (EAB),
and the other will be utilized for more distant assignmonts within the plume exposure EPZ.
In the event that there are no offsite radiological releases occurring, or none are anticipated, these teams may be authorized for inplant radiological surveys by the TSC Director at the request of the most senior Health Physics representative at the TSC.
PSC is in the process of purchasing additional instrumentation for field use by these radiological monitoring teams to allow in field determination of airborne
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radioiodine concentrations as low a's 1 x 10 7 pC1/cc.
PSC is in process of ordering two portable Multi-Channel Analyzers (MCAs) with oortable shields.
These two portable MCAs will be stored at the Engineering /QA complex for rapid access by field monitoring teams.
This equipment will be maintained in accordance with manufacturer's specifications.
An additional air sampler and ample silver zeolite cartridges will also be provided and stored with the MCAs, as well as an adequate number of portable GM detectors for determiration of ambient radiation levels.
Transportation of these field monitoring teams will be by use of two site assigned vehicles normally maintained at the Engineering /0A complex when not in use. Backup for these vehicles is provided by designated captive vehicles.
Spare sets of keys for these vehicles will be made and stored in the emergency kit at theEngineering/QA complex.
Use of captive vehicles for these purposes is considered an alternate in the event that site assigned vehicle (s) are not available, and the TSC Director will be notified of such captive vehicle use by the PCC Director.
The TSC Director will inform Security to release designated vehicles from the ProtectedArea at that time.
l Based upon preliminary vendor delivery schedules, PSC projects that this item will be fully implemented by July 1, 1982.
Prior to that time, however, PSC will make
4 provision for dispatch of field monitoring teams with air samplers within the plume exposure EPZ as determined by equipment availability onsite.
4 Radiation Monitoring NRC REQUIRED ACTION The licensee shall describe the mechanism for indicating radiological conditions in the Control Room, Technical Support Center and all emergency assembly areas during and following an incident.
The licensee shall describe how personnel in each facility will be made aware of radiological conditions, e.g.,
radioactive airborne contamination and direct radiation upon entering the facility and during occupancy of each facility.
PSC RESPONSE The primary purpose in having personnel report to emergency assembly stations is to promote rapid personnel accountability assessment.
PSC is in the process of ordering a new station security computer system for installation in early 1983. One of the primary functions of this security computer system will be the maintenance of continuous personnel accountability within the Protected Area by station Security staff.
Once this system is completed, personnel with non-essential emergency assignments will be redirected to exit the Protected area and assemble at the Engineering /QA building, and contractor personnel will be instructed to exit the Protected Area and return home and remain there until contacted by their respective supervisors.
Prior to the arrival of the new computer system, PSC will be taking interim measures to evaluate personnel accountability while verifying habitability of assembly areas.
Procedures will be revised such that plant management on duty, or their designated alternates, will report to the Control Room when the plant radiological alarm is sounded, personnel defined as essential in action item number 2 above report to either the CR or TSC as previously assigned, and non-essential personnel whose normal duty station is within the protected area report either to the turbine deck or lunchroom (stations to be procedurally defined).
Contractors and site-assigned personnel whose normal work station is outside the protected area will be reassigned to report to the Visitor's Center.
The CR and TSC are provided shielding,
- HVAC, and both ambient and airborne radiological logical monitoring, as well as, visible and audible alar..: of off-normal conditions.
The turbine deck and cafeteria are located immediately adjacent and are served by a common ambient and particulate airborne monitoring system which will alarm in the Control Room.
The first individual arriving at either of these stations will contact the Control Room if a public address announcement regarding habitability has not already been given.
If it is determined that there is a habitability problem, this I
individual will post a prepared sign indicating an alternate assembly area as instructed by the Shift Supervisor and
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evacuate to that designated location.
A Health Physics Technician will be dispatched by the Shift Supervisor to the Visitor's Center to evaluate habitability.
PSC will have this interim response implemented by June 1, 1952.
This time is necessary to provide the required time for revision to a level I procedure and to allow ample time for the retraining of site personnel.
5.
Develop Emergency Plan Implementing Procedures NRC REQUIRED ACTION The licensee shall develop and implement specific procedures in the EPIP, which implements the provisions of the RERP and which identify what tasks must be performed and how to perform those tasks, including adequate referencing to other supporting plant procedures.
The procedures shall also identify the specific individual by title, responsible for the performance of the tasks and shall contain adequate checklists or other methods to insure that all required steps are performed in the proper sequence.
PSC RESPONSE It must be made clear that PSC has maintained a full set of emergency plan implementing procedures for quite some time, and that these procedures have resulted in adequate response by PSC personnel in both drills and any off-normal events.
These procedures are presently entitled "RERP-STATION".
PSC has studied this item in depth and developed a new format and title for RERP implementing procedures.
These procedures will be reorganized into a combination subject / facility format.
Certain procedures, such as CR-UE and CR-ALERT are felt to be necessary for the rapid assessment actions required by operators in the early stages of an emergency.
Other subjects, such as dose calculations by TSC and FCP personnel, offsite survey, primary coolant
- sampling, etc.,
lend themselves more efficiently to a subject format presentation.
Sample procedures have been developed by FSV staff, and have resulted in the following format of presentation:
GENERAL (or introduction) 1.0 CRITERIA (for use) 2.0 PROCEDURES 3.0 RESPONSIBILITIES
4.0 REFERENCES
5.0 REFERENCED PROCEDURES (routine procedures)
FIGURES WORKSHEETS DATASHEETS CHECKLISTS WORKSHEET/DATASHEET/ CHECKLIST CONTROL LIST FORM USE REPORTING SHEET Due to the magnitude of this task, it is estimated that a period of five months will be required for procedure revisions,
- review, and retraining of affected emergency
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response personnel.
This would result in a scheduled implementation date of August 1, 1982.
6.
Emergency Coordinator Responsibility NRC REQUIRED ACTION The licensee shall correct the RERP, EPIPs, and station orders to unambiguously define the authorities of the Emergency Coordinator (including the Shift Supervisor, until relieved by another EC) such that the EC has the ultimate PSC authority to classify emergencies, make notifications to offsite autorities, and provide recommendation to offsite authorites for offsite protective actions without the need for concurrence or consultation by upper management.
Implementation of this correction shall include both the
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physical writing of such changes as required in the reference documents as well as the performance of formal training of all EC qualified personnel as to the changes.
PSC RESPONSE As stated by PSC during the emergency appraisal audit closecut meeting between PSC staff and NRC staff held at Fort St.
Vrain January 15, 1982, PSC is already in full compliance on this issue.
It is clearly stated in Section 5.2 of the FSV RERP that the duty Shift Supervisor has both the responsibility and authority to take the above referenced actions.
On January 25, 1982, Operations Order 80-018 was issued to clearly define the responsibility / authority of the Shift Supervisor. A copy of Operations Order 80-018 was sent to Inspection and Enforcement, Region IV, by letter dated January 25, 1982 (P-82025).
In
- addition, the subject of Emergency Coordinator responsibility and authority will receive additional stress during annual retraining of station personnel.