ML20137A122
| ML20137A122 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/08/1986 |
| From: | Terc N, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20137A097 | List: |
| References | |
| 50-267-85-29, NUDOCS 8601140177 | |
| Download: ML20137A122 (7) | |
See also: IR 05000267/1985029
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APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report:
50-267/85-29
Docket:
50-267
License: DPR-34
Licensee:
Public Service Company of Colorado
P. O. Box 840
Denver, Colorado 802C1-0840
Facility Name:
Fort St. Vrain Nuclear Generating Station
--Inspection At:
Fort St. Vrain, Colorado
' Inspection Conducted:
September 23-27, 1985
Inspector:
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NemenM.Terc,-EmergencyPrepar/dness
Date
Analyst,EmergencyPreparedn(ss.and
Safeguards Programs Section
Accompanying' Personnel:
W. Hansen, PNL, Comex
Approved:
7O
L. A. Yandell, Chief, Emergency Preparedness-
Date
~and Safeguards Programs Section
Inspection Summary
Inspection Conducted:
September 23-27, 1985 (Report 50-267/85-29)
' Areas Inspected:
Routine,' unannounced inspection of the licensee's-emergency
preparedness program including followup of previously identified items,
personnel proficiency, training, and audits. The inspection ~_ involved 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />
by one NRC inspector and one NRC contractor.
Results: Within the three areas inspected, two violations were identified
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(failtre to provide adequate training
paragraph 3; failure to perform
Ladequate emergency program audit
paragraph 4).
Eleven ~open items from
previous inspections'were closed.
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DETAILS
1.
Persons Contacted
Public Service Company of Colorado
- F'. Borst, Support Services Manager
P. Burck, Supervisor, Quality Assurance Auditing
- 0. Clayton, Technical Services Engineer
- M. Deniston, Acting Supervisor of Operations
D. Evans, Operations Supervisor
- C
Fuller, Station Manager
- J. Gahm, Manager, Nuclear Production Division
- M. Holmes, Nuclear Licensing Manager
R. Moller, Instructor
- F. Novachek, Technical / Administrative Services Manager
-R. Rivera, Training Supervisor
- J. Sills, Technical Services Supervisor
- L. Singleton, Manager Quality Assurance
J. Switzer, Supervisor Training Support
S. Wilford, Technical Support Supervisor - Training
R. Wadas, Fossil-Quality Assurance Manager
During the inspection, the NRC inspectors also contacted other licensee
personnel such as:
shift supervisors, technical advisors, senior reactor
operators, shift health physics technicians, and reactor operators.
- Denotes -those present during the exit interview.
' 2.
Followup of Previously Identified Items
(Closed) Open Item (267/8313-10): The NRC inspectors noted-that the
status boards used during emergencies at the Forward Command Post had been
enlarged.
In addition, a Data Logger display was added.
(Closed) Open Item (267/8314-05): The NRC inspectors agreed with the
-licensee that reporting thyroid dose rates as zero instead of 0.0001 rem /hr.
would constitute no grounds for confusion.
(Closed) Open-Item (267/8419-01): The NRC inspectors noted that pro-
cedures RERP-CR and RERP-PCC had been revised to prompt emergency response
center supervisors so that they keep personnel informed of chances in
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plant status.
In addition, new status boards were provided.
(Closed) Open Item (267/8419-02): The NRC inspectors noted that relevant
. procedures such as RERP-TSC, RERP-CP, and RERP-PCC were revised to direct
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supervisory personnel to delegate certain administrative tasks during
emergency conditions.
(Closed) Open Item (267/8419-03): The NRC inspectors noted that relevant
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procedures had been revised to incorporate checklists and that retraining
was conducted to increase the certainty that emergency procedures will be
followed.
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(Closed) Open Item (267/8419-04): The NRC inspectors determined that
RERP-TSC had been revised to include instructions for assigning personnel
to updating status boards in the Technical Support Center.
In addition,
retraining of selected engineers and technicians for this task was
accomplished.
(Closed) Open Item (267/8419-05): The NRC inspectors noted that
procedure RERP-PCC was revised to instruct the Personnel Control Center
director to delegate responsibilities for accountability of emergency
workers and exposure control.
(Closed) Open Item (267/8419-06): The NRC inspectors verified that a
study was conducted by a contractor to identify the needs for determining
habitability conditions of the assembly areas for nonessential personnel.
As a consequence of this study, frisker alarms will be set at
100 disintegrations per second and a portable air sampler will verify
airborne concentrations.
(Closed) Open Item (267/8419-07): The NRC inspectors determined that the
licensee conducted an evaluation of the Personnel Control Building and
concluded that the present design was the only feasible one to adequately
. control ingress and egress of personnel while minimizing the spread of
radioactive contamination.
(Closed) Open Item (267/8427-01): The NRC inspectors noted that the shift
supervisor in question had been retrained.
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(Closed) Open Item (267/8427-03): The NRC inspectors determined that the
licensee had revised his retraining policy to minimize the use of
self-study lesson plans.
3.
Personnel Proficiency and Training
The NRC inspectors reviewed sections of the Radiological Emergency Response
Plan. (RERP) for Fort St. Vrain Nuclear Generating Station RERP Implementing
Procedures, Technical Specifications, the Training Procedures Administrative
-Manual (TPAM), and lesson plans.
In addittor., the NRC inspectors reviewed
training records, and conducted interviews and walkthroughs with on-shift
emergency response personnel such as:
shift supervisors, reactor operators,
technical advisors, health physics, and chemistry technicians.
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The NRC inspectors tested the performance of four of the five available
shift organizatior.s by means of individual emergency response scenario
walkthroughs corJucted in the control room.
Each walkthrough lasted about
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, end the same accident scenario was used for each shift. The
scenario ~ required. classification of emergency events, initial notifica-
tions, and dose projections.
In addition, the NRC inspectors interviewed
seven on-shift health physics technicians. These were presented with a
scenario designed to test their performance in determining the habitabil-
ity of the control room and the radioiodine content of a radioactive
plume.
Base'd on above activities, the NRC inspectors made the following findings:
a.
Initial notification to State and local authorities and to NRC
were made in an improper sequence.
In six out of eight notifications,
the NRC was notified prior to State and local authorities. With
regard to timeliness, the initial notifications were outside the
required time frame only once out of nine times.
The NRC inspectors
noted that the notifications procedure RERP-CR, issue 6, contained
checklists that instructed the user to notify NRC before the
Colorado State Department of Health. Other errors in the procedure
made it ambiguous and difficult to follow.
b.
Health physics technicians that have on-shift assignments were unable
to (1) determine the habitability of the control room and
(2) determine the radiciodine content of a radioactive plume.
Six out of seven health physics technicians examined by the NRC
inspectors failed to recognize existing procedural guidance
necessary to ascertain habitability conditions in the control
room and ignored whether a criterion of habitability existed.
Three of seven technicians failed to recognize or acknowledge
that one of their major responsibilities was the protection of
emergency workers.
Five out of seven indicated they did not
know what actions they would take or how they would prioritize
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the same. One out of seven technicians indicated that if the
shift supervisor was too busy to direct him, he would return to
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his routine work location and activities.
The NRC inspectors required some health physics technicians to
explain the techniques to determine whether a radioactive plume
contained radioiodine. All of six technicians tested were
unable to carry out this task and could not properly interpret
results. The NRC inspectors noted that the procedure offered no
guidance for determining whether the individual taking the
airborne sample in the field was immersed in a radioactive
plume.
Several technicians stated that they needed walkthroughs
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on back shifts and more in-depth training on tasks involving
their principal emergency duties.
c.
Training was not given to individuals according to their specific
functional role during emergencies, but rather training lessons were
structured to the various emergency response facilities as a whole.
In addition, the NRC inspectors determined that corporate personnel
having supervisory responsibilities in the emergency response
organization were ylven only a 90-minute lecture every 12 to 15 months.
Moreover, the licensee
training documents exempted corporate
personnel from any written or oral examination.
e.
PSC training program failed to establish emergency preparedness
training requirements for technical advisors and corporate personnel
commensurate with their duties and responsibilities.
The above examples of insufficient training and an inadequate training
program are an apparent violation against the requirements of
.10 CFR 50.47(b)(15), which states that " Radiological emergency response
training is provided to those who may be called on to assist in an
emergency." (267/8529-01).
The NRC' inspectors noted that the EPTM did not soecify the applicability
-of emergency training to specific emergency organization positions, and as
a consequence, a correlational matrix between emergency organization team
titles and required training was not available. The overall emergencyL
plan training program was discussed with the plant training staff and the
NRC inspectors suggested that_the licensee conduct a thorough review of
the program and its implementation.
No other violations or deviations were identified.
4.
Audits
The NRC inspectors reviewed-Technical S'pecifications, Amendment 36,
Administrative Procedure Q-18, " Quality Assurance and Audit Program,"
Procedure QAAP-1, " Guidelines ~for Quality Assurance and Nuclear Facility
Safety Committee Audits," and Nuclear Facility Safety Committee (NFSC)
Audits Reports and Audit Plans for the years 1983-85.
In addition, the
NRC inspectors held interviews with PSC Quality Assurance supervisory
personnel.
10 CFR 50.54(t) states that, as a condition of the license, all nuclear
reactor licensees provide for the development, revision, implementation,
and maintenance of their emergency preparedness program in order to
provide with reasonable assurance that adequate protective measures can
and will be taken in the event of a radiological emergency. To this end,
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10 CFR 50.54(t) states that the licensee provide for an independent review
of their emergency program every 12 months by persons who have no direct
responsibility for implementation of the program. This review shall
include an evaluation for adequacy of licensee drills, exercises,
capabilities, procedures, and interfaces with State and local governments.
The licensee is required to identify weak areas or deficiencies, to
document the same in a report, and to make relevant findings available to
State and local governments.
The NRC inspectors reviewed NFSC Audit Plans and Reports for the
years 1983-85 and determined that the purpose of NFSC audits was to
satisfy the requirements of Technical Specification AC 7.1.3,
Section 7.b(5), which directed the licensee to perform an independent
review of the_ Fort St. Vrain Emergency Plan and Implementing Procedures.
The NRC inspectors noted that none of the reviewed documentation addressed
the requirements of 10 CFR Part 50.
A review of the audit plans, reports, and associated documsstation by the
NRC inspectors indicated that independent reviews of emergerty preparedness
were limited to the observation of the annual exercise. The only exception
was a review of emergency response training in the 1983 audit.
The NRC
inspectors noted that the licensee's audit program was thus designed to
verify procedural adherence and not to evaluate procedural adequacy. The
audit group made no additional effort to perform a systematic in-depth
review of the various emergency areas and tasks associeted with these
areas.
Furthermore, the NRC inspectors noted that PSC audit reports for
the years 1983-1985 failed to identify deficiencies in personnel training
and proficiency such as those identified in paragretb 3 of this report.
As a result, the NRC inspectors concluded that the iicensee's audit
program lacked the necessary depth to ascertain weaknesses and deficiencies
that could result in a degraded emergency response.
The same conditions
were true of the licensee's audit program used to evaluate the adequacy of
interfaces with State and local governments-
The NRC inspectors noted that the NFSC Audit Report dated August 1984, had
identified that excessive time was taken to staff and activate the
emergency response centers.
The Technical Support Center, Forward Command
Post, and Executive Command Post were not fully manned and operational
until 148, 134, and 126 minutes, respectively, after the emergency was
-decla ed. This' situation failed to comply with procedure RERP-Plant,
Section 5.2.1, which required full activation and staffing of emergency
response centers within 90 minutes after classification of an Alert or
higher level emergency.
As a consequence the NFSC auditors concluded that PSC could'not effectively
respond to emergencies occurring during off-hours shifts. The auditors
issued Action Request CAR-080 on August 17, 1984, to address this matter.
'The licensee closed the item because a new call out procedure was used
successfully during the June 1985 exercise. This did not fully address
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the concern raised, because the June 1985 emergency exercise was conducted
during the day shift. NRC finding 267/8314-06, directed.the licensee to
conduct a staff augmentation drill .to' ensure that emergency response
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personnel could in fact activate emergency response centers on;a timely
basis. .The NRC inspectors determined in discussions with the licensee's
' quality assurance staff that the staff augmentation drill had not been
conducted.
These failures to perform adequate audits of the emergency preparedness
program and to resolve a deficiency and weakness identified in an audit
performed constitute an apparent violation against the requirements of
10 CFR 50.54(t) (267/8529-02).
No other violations or deviations were identified.
'5.
Exit Interview
The exit interview was held on September 27, 1985. The interview was
conducted by Mr.-Nemen M. Terc, Emergency Preparedness Analyst, with
Mr.
R.- Farrell, Senior NRC Resident Inspector at Fort St. Vrain Nuclear
Generating Station in attendance. The licensee was represented by
Mr. J. W. Gahm, Division Manager - Nuclear Production, and his staff. The
licensee was given an oral 1 summary of the NRC inspector's findings,
observations, and comments. The NRC inspectors identified two violations
described above (see paragraphs 3 and 4 of this report).
The NRC inspectors
stated that NRC Region IV management would review and determine the final
' status of the-findings.
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