ML20064K217
| ML20064K217 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 12/20/1982 |
| From: | Warembourg D, Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| 82-28, P-82550, NUDOCS 8301180330 | |
| Download: ML20064K217 (5) | |
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z 16805 WCR 19 1/2, Platteville, Colorado 80651 December 20, 1982 Fort St. Vrain Unit #1 P-82550 Mr. John T. Collins Regional Administrator U. S. Nuclear Regulatory Commission 611 Ryan Plaza Dr., Suite 1000 Arlington, TX 76012
SUBJECT:
Fort St. Vrain Unit No. 1 Systematic Assessment of License Performance 4
~
REFERENCE:
NRC Repurt 82-28
Dear Mr. Collins:
As a follow-up to the above referenced report and our site meeting on December 14, 1982, we have the following comments:
A.
Plant Operations As we indicated to you in our discussions, we are concerned with personnel errors and failure-to-follow-procedure events.
We have taken some steps such as establishing the Plart Review Committee, reinstituting QC checks of the surveillance test program, establishin; the Operating Informational Assessment Group (OIAG),
and placing increased emphasis on these areas in plant staff meetings. We have made a concerted effort to rewrite many of our procedures and tests to minimize the chance of errors.
In spite of all these efforts, we have not been able to demonstrate any significant improvement.
As we stated, we feel that plant status has a strong influence on personnel errors due to the challenges of the plant transients, start-ups and shutdowns that we seem to face.
In this respect, our exposure to these types of errors is no doubt higher than one might find throughout the nuclear industry. This has some advantages,
- however, in that the operating staff receives invaluable on the job experience in dealing with transients and abnormal operating conditions.
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. We believe another contributing factor is the overall decrease in experience level as a result of increasing our staff to meet new regulatory requirements.
We have taken disciplinary action on certain occasions for these types of matters.
Disciplinary action iust be used carefully, h';ever, in that such action can prove to be detrimental in the long term, especially when one approaches the situation that personnel are unwilling to act for fear of making an error and exposing themselves to disciplinary action.
We indicated to you that we do not have any immediate answers to personnel errors.
We will reassess our programs such as the Plant Review Committee in an attempt to improve its effectiveness, and, of
- course, our procedure rewrite efforts will also continue. We have also started an additional operator training program under the direction of a Shift Supervisor dedicated to the training effort. We will continue to evaluate methods of communications and corrective action concerning personnel errors and failure-to-follow procedures in an attempt to improve this area of plant operations 8.
Radiological Controls - Radiation Protection The violations received in this area are at least partly attributable to personnel turnover and use of contract personnel on the HP staff. We are now in a much better position in having permanent personnel on the HP staff.
We also initiated a rather extensive departmental training program for the HP staff with the object of improving individual performance.
We have also requested an additional Training Instructor for 1983.
If this addition to our staff is approved, we intend to fill this position with an individual with HP and radiological protection expertise to supplement our training in radiation protection for the general employee training as well as specific departmental training.
C.
Radiological Controls - Radioactive Waste Management We have no specific comments in this area, and we will continue to maintain a high level of attention in this area.
D.
Maintenance As indicated in your report, improvement has been demonstrated in this area.
We agree that the quality control program and the maintenance procedures have contributed to this improvement.
The area of quality control is another area of concern to us in terms of personnel turnover. We have recently experienced some loss of personnel in this area which could have some effect on overall performance.
E.
Surveillance This is an area which has received almost constant attention. We have rewritten the major portion of our surveillance test procedures and are continuing our efforts to complete a total review of surveillarce procedures.
We fully intend to maintain a high level of attention 1.
this area. With the high level of activity in this area (some 4000 surveillance tests are conducted each year) it is virtually impossible to eliminate all errors.
F.
Fire Protection We have no specific comment in this area.
G.
Emergency Preparedness This has been a very difficult area, especially for Fort St. Vrain. As we indicated almost all of the guidance and regulating action issued by the NRC was directed toward the LWR technology.
In addition, the guidelines and regulations have been a moving target, and to some extent are still moving targets today.
Many areas are still subject to a certain amount of over-kill or over-reaction in terms of benefits realized versus economic impact.
We have initiated many changes as a result of the emergency appraisal audit, and we will continue to apply the appropriate level attention to this area.
H.
Security and Safeguards As we indicated to you at our site meeting, we do not agree with your recommendations concerning corporate security.
We believe this comment originated as a result of some specific instances which have subsequently been corrected.
. Our corporate security is involved via participation on the Fort St. Vrain Security Committee, membership in the Nuclear Facilities Safety Committee, and participation in security audits. We do not see the necessity or the benefit of any further involvement at this time.
Based on our recent telephone conversation, we will review our security plan and make revisions, if necessary, to clarify the position of the Manager of Risk Management.
I.
Refueling Ve have no specific comment.
J.
Licensing Activities As we discussed, we believe we have been assertive in our interaction with the NRC staff.
We have on numerous occassions commented on issues before the fact, during official comment periods and after the fact all with about equal success.
Although we were successful in few specific areas, our overall efforts have, in general, been unsuccessful.
We recognize the difficulty in trying to accommodate one gas-cooled reactor in a light water reactor oriented industry.
In this respect, we will continue our efforts in this area.
We are hopeful that the recent regionalization of Fort St.
Vrain will serve to the benefit of both PSC and the NRC in this area.
K.2.
Conclusions In the design, design changes and modifications area, we believe the recent reorginazation has served to improve the relationship between the nuclear engineering division and the nuclear production division.
Perhaps there is still rnom for further improvement as indicated by the specific areas that were discussed at the site aeeting.
We will evaluate these areas further.
- j. T.
Investigations and Allegations l
Your report 82-13 had some minor errors which we would like to correct.
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- Of the three individuals (C, D,
and E) identified, individual E was associated with drug use only by inference of friendship with individuals C and D.
Individual E denied using drugs which was subsequently corroborated by the results of a drug screening test.
Individuals C and D admitted to social, off-the-job use of drugs.
The report (82-13) is not very clear as to on-the-job versus off-the-hb use.
The report also indicates that the indiviauals C and D refused to take drug screening tests which is not the case. Both of these individuals did in fact take drug screening tests which were utilized to corroborate the admission of social use.
The report makes reference to a rehabilitation program which infers a structured program.
For clarification please be aware that there is no structured rehabilitation for a social user of carijuana.
The program consists primarily of periodic drug screening tests over a period of time to confirm discontinued use.
Some counseling is available if the individual needs some help.
General Overall, We appreciated the opportunity to meet with you, and we believe the exchange of information and thcughts was beneficial.
We are looking forward to working with you under the new regionalization concept, and hopefully we will be able to demonstrate improvement in those areas of concern in the upcoming year.
Very truly yours, A w na Don W. Warembourg Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/skr