ML20054K281
| ML20054K281 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 06/11/1982 |
| From: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Lee O PUBLIC SERVICE CO. OF COLORADO |
| Shared Package | |
| ML20054K282 | List: |
| References | |
| NUDOCS 8207010385 | |
| Download: ML20054K281 (14) | |
See also: IR 05000267/1982001
Text
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JUN 11 1982
Docket No. 50-267/82-01
Public Service Company of Colorado
ATTN: Oscar R. Lee, Vice President
Electric Production
P. O. Box 840
Denver, Colorado
80201
Gentlemen:
Subject:
Emergency Preparedness Appraisal
To verify that licensees have attained an adequate state of onsite emergency
preparedness, the NRC Office of Inspection and Enforcement is conducting
special appraisals at each power reactor site.
These appraisals are being
performed in lieu of certain routine inspections normally conducted in the area
The objectives of the appraisal at each facility
are to evaluate the overall adequacy and effectiveness of emergency
preparedness and to identify areas of weakness that need to be strengthened.
We will use the findings from these appraisals as a basis not only for
requesting individual licensee action to correct deficiencies and effect
improvements, but also for effecting improvements in NRC requirements and
guidance.
During the period of January 4-15, 1982, the NRC conducted an appraisal of the
emergency preparedness program for the Fort St. Vrain Nuclear Generating
Station. Areas examined during this appraisal are described in the enclosed
report (50-267/82-01).
Within these areas, the appraisal team reviewed
selected procedures and representative records, inspected emergency facilities
and equipment, observed work practices, and interviewed personnel.
The findings of the emergency preparedness appraisal at the Fort St. Vrain
Nuclear Generating Station indicate that significant weaknesses exist in several
These are addressed in Appendix A, "Significant Appraisal Deficiencies,"
areas.
of this letter.
Significant deficiencies for which you have made acceptable commitments to
resolve were discussed in the Confirmatory Action Letter, dated January 21,
1982.
These deficiencies are identified in Appendix A.
For your convenience,
a copy of the January 21, 1982, letter is enclosed as an attachment to this
letter.
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The findings of this appraisal also indicate that there are areas for
improvement in your emergency preparedness program.
These are discussed
in Appendix B, " Preparedness Improvement Items."
In conjunction with the aforementioned appraisal, emergency plans dated
February 10, 1981, for your facility were reviewed by the Emergency
Preparedness Licensing Branch.
The results of that review indicated that
_
certain deficiencies existed in your emergency plan.
The second set of
these deficiencies was transmitted to you by letter dated December 14, 1981,
from Mr. Robert A. Clark, Chief, Operating Reactors Branch #3, Division of
Licensing, Office of Nuclear Reactor Regulation.
In a meeting with the
licensee on December 3, 1981, it was agreed that the Fort St. Vrain Nuclear
Generating Station would provide a revised emergency plan that would correct
the identified deficiencies.
We recognize that an explicit regulatory requirement pertaining to each item
identified in Appendices A and B may not currently exist.
Notwithstanding
this, you are requested to submit a written statement within 30 days of the date
of this letter, describing your planned actions for removing each of the
deficiencies identified in Appendix A and the results of your consideration
of each of the items in Appendix B.
This de.;ription shall include:
(1) steps
which have been taken, (2) steps which will be taken, and (3) a schedule for
completion of actions for each item.
This request is made pursuant to
Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
This is to inform you that if the deficiencies addressed in Appendix A are not
corrected by the commitment dates provided, the Nuclear Regulatory Commission
will determine whether the reactor shall be shut down until such deficiencies
are remedied or whether other enforcement action is appropriate.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures
and the responses directed by this letter will be placed in the NRC Public
Document Room unless you notify this office by telephone within 10 days of
the date of this letter and submit written application to withhold information
contained therein within 30 days of the date of this letter.
Such application
must be consistent with the requirements of 2.790(b)(1).
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The responses directed by this letter and the accompanying attachments are not
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subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
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Public Service Company of Colorado
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Should you have any questions concerning this appraisal, we will be pleased to
discuss them with you.
Sincerely,
Original signed by
John T. ColliDS
John T. Collins
Regional Administrator
Enclosures:
1.
Appendix A, "Significant Appraisal Deficiencies"
2.
Appendix B " Preparedness Improvement Items"
,
3.
Letter to Public Service Company of Colorado,
dated January 21, 1982.
4.
Office of Inspection and Enforcement Appraisal
Report No. 267/82-01
,
cc w/ enclosures:
D. W. Warembourg, Manager Nuclear Production
Fort St. Vrain Nuclear Station
P. O. Box 368
Platteville, Colorado
80651
J. W. Gahm, Quality Assurance Manager
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V
APPENDIX A
SIGNIFICANT APPRAISAL DEFICIENCIES
The results of the NRC's appraisal of the Fort St. Vrain Nuclear Generating
Station (FSV) emergency preparedness program identified a number of
significant deficiencies which were discussed in detail with the licensee's
senior management on January 15, 1982, and for which commitments were obtained
from the licensee for corrective action on January 19, 1982.
Six areas were identified which had significant deficiencies and the areas
are presented below, along with the specific finding number (s) from the
appraisal report which are covered by each significant deficiency area
(references are to the sections in Office of Inspection and Enforcement
Appraisal Report No. 50-267/82-01).
Significant Deficiencies
1.
Emergency Action Levels
Related specific findings: 267/82-01-77 (see section 5.1)
267/82-01-78 (see section 5.1)
267/82-01-79 (see section 5.1)
267/82-01-82 (see section 5.2)
2.
Respiratory Protection
Related specific findings: 267/82-01-40 (see section 4.1.1.2)
267/82-01-52 (see section 4.1.2.1)
267/82-01-71 (see section 4.2.2.1)
267/82-01-72 (see section 4.2.2.1)
267/82-01-116 (see section 5.4.4)
3.
Offsite Radiological Monitoring Capability
Related specific findings: 267/82-01-73 (see section 4.2.6)
267/82-01-74 (see section 4.2.6)
267/82-01-90 (see section 5.4.2.1)
267/82-01-91 (see section 5.4.2.1)
4.
Radiation Monitoring
Related specific findings: 267/82-01-37 (see section 4.1.1.1)
267/82-01-39 (see section 4.1.1.2)
267/82-01-44 (see section 4.1.1.3)
267/82-01-51 (see section 4.1.2.1)
267/82-01-107 (see section 5.4.3.2)
5.
Develop Emergency Plan Implementation Procedures
Related specific findings: 267/82-01-48 (see section 4.1.1.5.5)
267/82-01-49 (see section 4.1.2.1)
267/82-01-50 (see section 4.1.2.1)
267/82-01-57 (see section 4.1.2.3)
267/82-01-92 (see section 5.4.2.1)
267/82-01-93 (see section 5.4.2.2)
267/82-01-94 (see section 5.4.2.2)
267/82-01-97 (see section 5.4.2.5)
267/82-01-98 (see section 5.4.3.1)
267/82-01-99 (see section 5.4.3.1)
267/82-01-134 (see section 5.6)
6.
Emergency Coordinator Authority
Related specific findings: 267/82-01-02 (see section 1.6)
267/82-01-16 (see section 2.3)
267/82-01-20 (see section 2.3)
267/82-01-86 (see section 5.4.2)
267/82-01-110 (see section 5.4.3.3)
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APPENDIX B
PREPAREDNESS IMPROVEMENT ITEMS
In addition to the significant appraisal deficiencies identified in
Appendix A, the results of the NRC's appraisal of the Fort St. Vrain Nuclear
Generating Station (FSV) preparedness program identified the following items
as needing consideration for improvement in order to achieve an adequate
!
emergency preparedness program.
References are to sections in the Office of
Inspection and Enforcement Appraisal Report No. 50-267/82-01.
Correct the RERP and EPIP's to accurately reflect changes to the licensee's
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existing organizational structure (267/82-01-01) (see section 1.6);
Develop and implement explicit and specific functional responsibilities
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and authorities for all persons assigned duties for the various emergency
preparedness planning and coordination functions (267/82-01-03) (see
section 1.6);
Develop and implement a program for training individuals, who are
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assigned emergency planning responsibilities, which will enable them to
attain and maintain a state-of-the-art knowledge in the field of
emergency preparedness (267/82-01-04) (see section 1.6);
Evaluate the adequacy of existing staff assigned responsibility for
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emergency preparedness planning and coordination, and develop a means to
augment existing staff when necessary (267/82-01-05) (see section 1.6);
Develop and implement methods to provide substantive input from plant
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staff, down to the working level, to the development of emergency
preparedness plans and procedures (267/82-01-06) (see section 1.6);
Develop and implement specific selection and qualification criteria for
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individuals assigned to perform emergency preparedness development
activities (267/82-01-07) (see section 1.6);
Develop and implement quality assurance procedures to evaluate the
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effectiveness of the emergency planning development training (267/82-01-08)
(see section 1.6);
Provide formal assignment of all individuals held responsible to perform
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emergency planning duties (267/82-01-09) (see section 1.6);
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Augment existing general employee training (GET) to ensure that all site
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personnel are adequately trained in the general provisions of the RERP,
their responsibilities during an emergency, and how to provide input to
correcting deficiencies they identify (267/82-01-10) (see section 1.6);
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Unambiguously define the authorities, responsibilities, and duties of
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all individuals, down to the working level, assigned to the licensee's
emergency organization (267/82-01-11) (see section 2.3);
Develop a program for training individuals who are assigned emergency
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action responsibilities which will enable them to attain and maintain a
state-of-the-art knowledge in the field of their assigned emergency
action areas (267/82-01-12) (see section 2.3);
Include a list of approved licensee personnel (by name) in the EPIP, who
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have been selected and are qualified to perform activities within the
functional areas of the licensee's emergency organization to which they
are assigned (267/82-01-13) (see section 2.3);
Develop and implement specific selection and qualification criteria for
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all individuals assigned to perform emergency actions and decisionmaking
(267/82-01-14) (see section 2.3);
Develop quality assurance procedures to evaluate the effectiveness of the
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emergency action training for the various functional areas (267/82-01-15)
(see section 2.3);
Develop and implement a method of formal assignment of all personnel in
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the emergency response organization down to the working level
(267/82-01-17) (see section 2.3);
Develop and implement procedures to ensure that all emergency response
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functions, as identified in Table B-1 of NUREG-0654, Revision 1, will be
performed in the control room until the other emergency centers are
manned and operational (267/82-01-18) (see section 2.3);
Correct the RERP and EPIP's to properly reflect the true nature of the FCP
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and the TSC relationship and the authorities and responsibilities of
their respective directors (267/82-01-19) (see section 2.3);
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Develop and implement specific procedures to govern the use and
coordination of all outside support organizations and contractors during
emergencies (267/82-01-21) (see section 2.3);
Correct the RERP and EPIP's to unambiguously identify the authorities,
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responsibilities, and limits of actions of the corporate, contractor,
private organizations, and local services support groups during
emergencies (267/82-01-22) (see section 2.3);
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B-3
Establish and implement a formal radiological emergency response training
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program to provide specialized training and annual retraining for all
individuals assigned to each of the functional areas of the emergency
organization (267/82-01-23) (see section 3.3);
Provide in the new training program:
formal classroom instructions and
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practical demonstration drills; walk-throughs; formal lesson plans; and a
means of evaluating student performance; i.e., written tests as well as
evaluations of individual performance in drills and walk-throughs.
Lesson
plans shall include student performance objectives (267/82-01-24) (see
section 3.3);
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Develop and implement a formal training program to familiarize all site
employees with the changes in the RERP and EPIP's if and when substantive
changes are made to the respective responses by individuals assigned to
the emergency organization (267/82-01-25) (see section 3.3);
Revise the TPAM to include the new Section 4.6, to remove the redundancy
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between the sections, and to revise Forms G-8 and G-9 to reflect the
current training (267/82-01-26) (see section 3.3);
Rectify the discrepancy between the training requirements of RERP,
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Figure 8.1-1 and TPAM, Forms G-8 and G-9 (267/82-01-27) (see section 3.3);
Rectify the discrepancy between the training requirements of TPAM
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Section 4.1.1.1 and Section 2.2 (267/82-01-28) (see section 3.3);
Develop and implement formal training requirements for the offsita
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organizations and specify those requirements in the RERP and EPIP's
(267/82-01-29) (see section 3.3);
Develop and implement formal training lesson plans which clearly state
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student performance objectives for local support service groups
(267/82-01-30) (see section 3.3);
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Develop and implement formal selection criteria to be used in selecting
training instructors (267/82-01-31) (see section 3.3);
Develop and implement a written examination for the health physics GET
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(8-hour class) (267/82-01-32) (see section 3.3);
Have a member of the Health Physics Department conduct an annual formal
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training program for St. Luke's Hospital emergency response staff
(267/82-01-33) (see section 3.3);
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B-4
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Develop and implement a formal emergency training program for health
physics and radiochemistry technicians (267/82-01-34) (see section 3.3);
Dewelop and implement acceptance criteria to be used in evaluating junior
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HP technician proficiency (267/82-01-35) (see section 3.3);
Establish a method for ensuring that new employees cannot enter a
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radiation zone prior to receiving health physics training (267/82-10-36)
(see section 3.3);
Provide dedicated emergency portable radiological monitoring equipment
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and protective clothing in the control room (267/82-01-38) (see section
4.1.1.1);
Develop and implement a specific listing of all emergency equipment and
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supplies necessary for the full activation and operation of the TSC
(267/82-01-41) (see section 4.1.1.2);
Complete the full installation of HVAC system for the TSC, including
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the necessary detectors and controls to initiate damper and full filter
operation during emergencies (267/82-01-42) (see section 4.1.1.2);
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Revise the RERP and EPIP's to reflect the names, locations, and routes to
the alternate PCC(s) (267/82-01-43) (see section 4.1.1.3);
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Correct the RERP and EPIP's to specifically identify all " Emergency
Stations" and "PCCs" (267/82-01-45) (see section 4.1.1.3);
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Demonstrate that a fixed monitor has a range of at least 5 mci /cc of
mixed noble gases and that ambient radiation fields will not interfere
with this measurement (267/82-01-46) (see section 4.1.1.5.3);
Develop and implement a procedure for transferring appropriate secondary
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and/or primary calibration sources from the FSV Radiochemistry Laboratory
to the Ft. Collins laboratory in the event that the FSV laboratory is not
functional during emergencies (267/82-01-47) (see section 4.1.1.5.5);
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Provide direct, immediate, and unobstructed access to the first-aid
facility (267/82-01-53) (see section 4.1.2.2);
Develop and implement procedures that ensure that dedicated first-aid
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equipment is controlled by a documented inventory program (267/82-01-54)
(see section 4.1.2.2);
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Provide and maintain up-to-date FSV medical emergency procedures in the
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first-aid facility (267/82-01-55) (see section 4.1.2.2);
Incorporate the provisions of the FSV Medical Emergency Plan into the FSV
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RERP and EPIP'S (267/82-01-56) (see section 4.1.2.2);
Upgrade personnel monitoring procedures and station training to ensure
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that all station personnel are aware of the limitations of personnel
monitoring equipment and the proper procedures to be used to self-
monitor themselves (267/82-01-58) (see section 4.1.2.3);
Include provisions for control of radioactive wastes during
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decontamination of personnel at all assembly areas (267/82-01-59)
(see section 4.1.2.3);
Provide cofferdams and shower curtains at the two entries into the
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personnel decontamination shower to prevent the unnecessary spread of
contamination to the adjacent area during use (267/82-01-60) (see
section 4.1.2.3);
Incorporate the "RERP" Public Information Manual (PIM) into the EPIP's
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and docket the PIM as a part of your RERP and EPIP submittals to the NRC
(267/82-01-61) (see section 4.1.4);
Revise and consolidate station procedures so that there is a concise
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nongeneric listing of all dedicated emergency equipment and suppliers and
the quantity necessary to support all areas of endeavor during the
highest classification of emergency event (267/82-01-62) (see section
4.2.1.1);
Develop and implement inventory procedures and emergency use procedures,
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and provide for operational checking of instruments prior to use
(267/82-01-63) (see section 4.2.1.1);
!
Develop and implement instructions for the proper storage and maintenance
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of charcoal and silver zeolite filters (267/82-01-64) (see section
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4.2.1.1);
Install a high-range radiation monitor on the reactor refueling floor
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(267/82-01-65) (see section 4.2.1.2);
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Establish the level of uncertainty associated with the use of
meteorological information from the proposed primary system in the dose
projection process and provide direction such that recommended protective
actions are adequate (267/82-01-66) (see section 4.2.1.4);
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Identify within the RERP and EPIP's how to gain access to alternate
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meteorological sources, how to use (e.g., adjust) available information,
and how documentation of data sources (other than primary system) will be
achieved (267/82-01-67) (see section 4.2.1.4);
Facilitate the input of the transport and diffusion data into the dose
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projection process for manual assessment methods (267/82-01-68) (see
section 4.2.1.4);
Formalize the meteorological measurements preventative and corrective
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maintenance program and data qualification program to provide reasonable
assurance that meteorological data will be available for use during a
radiological emergency (267/82-01-69) (see section 4.2.1.4);
Formalize the procedure to inform the control room staff of impending
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severe weather conditions that may impact the site area (267/82-01-70)
(see section 4.2.1.4);
Develop a method for referencing the section in the EPIP's that pertains
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to the E0P's being used and ensure that the method is workable through R0
training and drills (267/82-01-75) (see section 5.1);
Retitle the RERP's (Station, Plant, and State) so as to clarify which
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document is being referenced (267/82-01-76) (see section 5.1);
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Revise the current procedure process to clarify or remove the discrepancy
between the APH and ADM (267/82-01-80) (see section 5.1);
Clarify the purpose of the FSV procedure classification system to remove
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the confusion of policy procedures having a higher classification than
the RERP (267/82-01-81) (see section 5.1);
Correct the EPIP's to ensure that all appropriate and applicable emergency
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actions are defined and properly referenced in the FSV E0P's and the
EPIP's (267/82-01-83) (see section 5.3);
Correct the EPIP's to include reference to all supporting procedures
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necessary to perform the required tasks (267/82-01-84) (see section 5.3);
Correct all appropriate procedures to ensure that all of the necessary
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information is available to enable all outside notification calls to be
made (including special code numbers, prefix numbers, and telephone
numbers), and ensure that this information is kept up to date on at least
a quarterly basis (267/82-01-85) (see section 5.4.1);
Revise the EPIP's to improve the timeliness of offsite notifications
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(267/82-01-87) (see section 5.4.2);
Revise the guidance for protective actions to include plant system
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parameters and offsite monitoring in the decision basis (267/82-01-88)
(see section 5.4.2);
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B-7
Provide for use of isotopic release data in dose assessment procedures
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(267/82-01-89) (see section 5.4.2);
Correct all procedures intended for use under emergency conditions to
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include specific guidance in additional health physics aspects needed
to maintain personnel exposures ALARA (267/82-01-95) (see section 5.4.2.3);
Develop and implement procedures for health physics and radiochemistry
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which are compatible and define responsible functions for postaccident
sample analysis (267/82-01-96) (see section 5.4.2.4);
Develon and implement emergency exposure work sheets that provide for -
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signature concurrence on all personnel exposures that may exceed
10 CFR 20 exposure limits (267/82-01-100) (see section 5.4.3.1);
Develop stay-time determination calculations (whole-body and extremity),
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including a method of enforcement and acknowledgment (267/82-01-101)
(see section 5.4.3.1);
Correct the EPIP's to include the criteria used to determine the need to
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initiate the evacuation of owner-controlled areas (267/82-01-102) (see
section 5.4."1.2);
Develop and implement procedures to ensure positive control of all
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persons in the owner-controlled areas during evacuation (267/82-01-103)
(see section 5.4.3.2);
Develop and implement procedures to ensure evacuation of all non-
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essential personnel from owner-controlled areas, including the visitor's
center and to verify, within 30 minutes of the initiation of the
evacuation, that all nonessential persons have been removed from the
owner-controlled areas (267/82-01-104) (see section 5.4.3.2);
Provide clear and conspicuous markings for primary and secondary
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evacuation routes both within the plant and outside the plant
(267/82-01-105) (see section 5.4.3.2);
Correct the RERP and EPIP's to specifically identify the location of
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all assembly / reassembly areas (267/82-01-106) (see section 5.4.3.2);
Develop and implement a specific single procedure to govern all aspects
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of initial personnel accountability for all persons in the owner-
controlled area (267/82-01-108) (see section 5.4.3.3);
Correct the RERP and EPIP's to properly reference the personnel
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accountablity procedure (267/82-01-109) (see section 5.4.3.3);
Develop and implement spedfic procedures to govern tne establishment
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and operation of a search and rescue team (267/82-01-111) (see section
5.4.3.3);
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B-8
Develop and implement specific procedures to govern the actions necessary
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to ensure continued personnel accountability after the initial personnel
accountability is completed (267/82-01-112) (see section 5.4.3.3);
Specifically identify in the RERP and EPIP's the persons, by name and
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title, who are individually responsible to take personnel accountability
at each emergency station (267/82-01-113) (see section 5.4.3.3);
Provide instructions that ensure each person who is monitored for
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contamination at an assembly area, reassembly area, or exit point during
an emergency event is logged by name; and data is entered on contamination
levels found, minimum detectable activity of instrumentation, and results
of any decontamination (267/82-01-114) (see section 5.4.3.4);
Correct the EPIP's to properly reference the appropriate security
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procedures to be implemented during radiological emergencies
(267/82-01-115) (see section 5.4.4);
Provide permanent radiological monitoring equipment to determine habit-
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ability of CAS and SAS during radiological emergencies (267/82-01-117)
(see section 5.4.4);
Develop and implement specific procedures which govern the formation,
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direction, and control of emergency repair and corrective action teams
during an emergency (267/82-01-118) (see section 5.4.5);-
Develop and implement specific and detailed procedures to govern the
--
functional operations of the recovery organization (267/82-01-119) (see
section 5.4.6);
Expand both the depth and scope of the recovery operations planning in
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the RERP (267/82-01-120) (see section 5.4.6);
Correct the RERP and EPIP's to reflect that the authority and
--
responsibility for activation of the recovery organization rests with the
licensee's Corporate Emergency Director who is the Emergency Coordinator
>
when such a decision would be made (267/82-01-121) (see section 5.4.6);
Develop and implement specific criteria to be used to determine when
--
after an accident, reentry of the facility would be appropriate or when
operation of the plant could resume (267/82-01-122) (see section 5.4.6);
Develop and implement procedures, during recovery operations, to
--
periodically estimate total population exposure and integrated dose
(267/82-01-123) (see section 5.4.6);
Develop and implement methods to inform members of the various response
--
organizations of the initiation of the recovery organization or of any
)
other changes in the licensee response organizational structure or
functions (267/82-01-124) (see section 5.4.6);
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B-9
Add NRC Public Affairs representatives to the list of authorized
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representatives listed in Section SEOC, 2.0 Implementation, paragraph
2.1.2 of the FSV RERP (267/82-01-125) (see section 5.4.7);
Develop and implement procedures that will ensure all radiation,
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contamination control, and area monitors are periodically checked to
verify response to a predetermined value of a known source strength and
include what corrective actions are to be taken when discrepancies are
encountered (267/82-01-126) (see section 5.5.1);
Provide procedures which ensure operational response with check
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sources of the radiological survey equipment during quarterly inventories
and prior to emergency use (267/82-01-127) (see section 5.5.1);
Develop and implement a formal procedure that describes, in detail, the
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drills and exercise program (267/82-01-128) (see section 5.5.2):
Develop and implement a procedure to ensure a thorough annual review and
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documentation of the review of the RERP and EPIP's (267/82-01-129) (see
section 5.5.3);
Remove the reference to the corporate emergency planning personnel
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(267/82-01-130) (see section 5.5.3);
Develop and implement a procedure for the routine audit of the RERP and
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EPIP's (267/82-01-131) (see section 5.5.4);
Evaluate the usability of existing documents and instruments, which would
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be used during an emergency, for human factors engineering corrections
(267/82-01-132); (see section 5.6);
Correct EPIP's to provide that a single individual be responsible for
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actions on any single page of the procedure (267/82-01-133)
(see section 5.6);
Provide actual telephone numbeis and instruction for calling offsite
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assistance (267/82-01-135) (see section 6.1);
Develop a transient p2blic information program as soon as possible nou
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that the decision to install an early warning system has been made
(267/82-01-136) (see section 6.2); and
Review the current arrangements for public inquiry, staffing require-
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ments, telephone capabilities, and consider training requirements for
PIC personnel (267/82-01-137) (see section 6.2).
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