ML20212H869
| ML20212H869 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 01/16/1987 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| P-87030, NUDOCS 8701280042 | |
| Download: ML20212H869 (5) | |
Text
-
=.
O eubiicservice-
- = = = --
16805 WCR 19 1/2, Platteville, Colorado 80651 January 16, 1987 Fort St. Vrain Unit No. 1 P-87030 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 ATTN: Document Control Desk Docket No. 50-267
SUBJECT:
I&E Inspection Report 86-22 Supplemental Information
REFERENCE:
(1) PSC Letter, Gahm to Gagliardo, dated 11/07/86 (P-86604)
(2) NRC Letter, Gagliardo to Williams, dated 12/17/86 (G-86644)
Dear Sirs:
This letter is supplying supplemental information to the previous reply to Notice of Violation No.
8622-01 (Reference 1) per the request of NRC, Region IV (Reference 2).
Only the response to deficiency D is supplemented.
Failure to Correct Deficiencies 10 CFR 50.54(q) requires that licensees shall follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements in Appendix C (1985), the violation is listed below:
10 CFR 50.47(b)(14) and Section IV.F of Appendix E to Part 50 require, in part, that periodic exercises are conducted to evaluate major portions of the licensee's emergency response capabilities and that deficiencies identified as a result of exercises or drills will be corrected.
8701280042 870116 9ol PDR ADOCK 05000267 fy G
PDR a
. ~ _ _ _. _ _ -
P-87030
- January 16, 1987 Contrary to the above, on August 5 and 6, 1986, during the 1986 annual exercise, the NRC inspectors determined that several emergency preparedness deficiencies identified during the previous. annual exercise conducted on June 19, 1985, were not fully and adequately corrected in accordance with NRC requirements as evidenced by the following:
This is a
Severity Level IV violation.
(Supplement VIII)
(267/8622-01)
D.
During the 1985 exercise, the licensee was deficient in fully demonstrating coordination of radiological and environmental assessment, development of protective action recommendations, and management of the utility forward command post (emergency operations facility) activities.
The NRC inspectors observed similar weaknesses in managing the licensee's emergency response activities and formulating protective action recommendations during the 1986 exercise, indicating that the deficiency had not been fully corrected.
(1) The reason for the violation if admitted:
PSC believes that the Corporate Emergency Director (CED) provided adequate control of the Forward Command Post (FCP) activities.
Protective Action Recommendations (PAR) were formulated by the Dose Assessment Coordinator at the FCP and these recommendations were formally discussed with other agencies. The protective action recommendation early in the scenario was to take no protective actions initially.
It is possible that the NRC thought there were no protective action recommendations made.
Staff augmentation problems throughout the emergency response organization also contributed to many problems in the beginning of the scenario.
SUPPLEMENTAL INFORMATION:
PSC agrees that the CED should have provided more positive management of the overall emergency organization.
Factors contributing to this deficiency include staffing problems early in the exercise, lack of formal training walkthroughs (drills) on interface requirements prior to the exercise, the unfamiliarity associated with the addition of several NRC " player" personnel, and the lack of clear definitions within the emergency plan and procedures of assigned emergency management responsibilities.
The combination of these problems contributed to poor emergency organizational command at the Forward Command Post.
.m P-87030 January 16, 1987 (2) The corrective steps which have been taken and the results achieved:
As indicated in PSC's response to the SALP report (Reference 3),
procedures are being reviewed to determine appropriate revisions to clarify the responsibilities of each emergency organization position, and to indicate the need to have dose assessment and associated protective action recommendations completed in a timely manner.
SUPPLEMENTAL INFORMATION:
a)
Staff augmentation procedures have been revised and appropriate training given to all-key members of the augmentation process. The revised methodology and training has improved the response time required for the emergency organization.
b)
A training schedule is being drafted for the calendar year of 1987 which includes more emergency response facility drills to practice interface requirements and identify further control and management improvements in all the facilities, c)
The licensee is now more familiar with the NRC's "co-location" concepts, and is reviewing the current plan and procedures to determine revisions which will implement this process more effectively.
A meeting with
- NRC, Region IV representatives is scheduled for March 6, 1987 (tentatively), to discuss this area further.
d)
The emergency plan and procedures are being reviewed to determine where definitions of responsibility need to be improved.
The Corporate Emergency Director position description is being reviewed to ensure that specific actions and responsibilities are defined for this position.
The physical location of the dose assessment and reactor safety functions are being reviewed to determine the arrangement which will most benefit the Corporate Emergency Director in formulating emergency decisions.
~.
1 P-87030 January 16, 1987 (3) The corrective steps which will be taken to avoid further I
violations:
As indicatud in Reference 3, emphasis on position responsibilities will be given in emergency response training.
The need for effective leadership at the FCP will be stressed, along with the requirements of co-locating with other agencies during decision making processes.
PSC believes that increased frequency of drilling to reinforce the academic process will also benefit these items.
PSC is also considering the use of PAR forms to be signed by the CED and presented to the State officials to prevent future PAR confusion.
SUPPLEMENTAL INFORMATION:
The recommendations which are developed from the various program reviews mentioned previously, will be implemented into the existing plan and procedures.
(4) The date when full compliance will be achieved:
August 31, 1987 SUPPLEMENTAL INFORMATION:
The training / drill schedule will be completed and formally implemented by February 28, 1987, although training and drills i
will be conducted during the interim as previously indicated.
The overall plan and procedure review / rewrite is planned to be completed by August 31, 1987. Specific areas of concentration, such as, dose assessment and reactor safety methodology are planned to be completed and implemented in time for this year's formal exercise. We are scheduling the procedure completion in these two areas by May 1, 1987, with the training upgrade and implementation to be completed by July 17, 1987.
c.
- a; 6
P-87030 ! January 16,fl987 Should you have any further questions, please contact Mr. M.H. Holmes at (303) 480-6960.
Sincerely,
'J
. Gahm Manager, Nuclear Production Division JWG/ojc cc:
Regional Administrator Region IV U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Attention: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Mr. Robert Farrell Senior Resident Inspector Fort St. Vrain C