ML20212K184
| ML20212K184 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 08/13/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Walker R PUBLIC SERVICE CO. OF COLORADO |
| References | |
| NUDOCS 8608190227 | |
| Download: ML20212K184 (6) | |
Text
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o AUG 13156 In Reply Refer To:
Docket: 50-267 Public Service Company of Colorado ATTN:
R. F. Walker, President P.O. Box 840 Denver, Colorado 80201-0840 Gentlemen:
We have reviewed the scenario for the emergency preparedness exercise scheduled for August 1986, which you transmitted to us with your letter dated June 20, 1986.
The review was to determine if all the major elements of response required by 10 CFR 50.47(b)(14) and Appendix E to Part 50,Section IV.F were addressed as stated in your exercise objectives. Our comments which were transmitted to you by facsimile on July 17, 1986, are contained in the enclosure to this letter.
If you have any questions in regard to this matter, please contact Mr. J. B.
Baird at (817) 860-8185.
Sincerely,
.'1 herd S;g;cd by;"
J. E. Gagliardo, Chief Reactor Projects Branch
Enclosure:
Scenario Comments J. W. Gahm, Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 19 Platteville, Colorado 80651 L. Singleton, Manager, Quality Assurance Division (same address)
Colorado Radiation Control Program Director Colorado Public Utilities Commission FEMA Region VIII (F. Shoemaker)
Federal Regional Center, Bldg. 710 Denver, CO 80225 p')h RIV:EP&SP gb C:EP&Sf5 C:R&SPB9y' SP/A C:RPB JBBaird:c LAYande WLFisher JPJaudon JEGaglf'rdo 8/li/86 8/ n /86 8/IN86 8/y/86 8// Pfe0 h;
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FORT SAINT VRAIN EXERCISE SCENARIO REVIEW A.
OBJECTIVES 1.
There was no objective for self-evaluation or critique as required.
2.
The objective for dose assessment should include timely dose projections for populations in the EPZ.
B.
SCENARIO EVENTS 1.
Page 4.2.1 indicates the controller / observer assignments are deferred as they are to be provided at the NRC/ FEMA briefing on 8/5/86. This appears to be inconsistent with the Figure 1-1 requirement that all controllers and observers must have attended the June 16 and 17 training.
2.
Card 65 anticipates simulation of first aid, decontamination, and transportation to the hospital.
Table 2-1 does not reflect this as it indicates the only simulation will be transport to the hospital.
3 The next to last paragraph on 4.3-2 requires that " prior to commencement (of the exercise), all telecommunications should be tested...".
This requirement should be deleted; it is artificial and inconsistent with the concept of maintaining continued readiness 24 hrs / day, with periodic communications testing verification.
4.
The scenario should contain some instruction concerning use of protective clothing outside the owner controller area.
5.
The simulation listed on page 4.1-2, para 4 should be added to Table 2-1.
6.
Cue card 28 is inconsistent with the narrative.
Cue card 28 anticipates the shift supervisor will declare an alert about 2045; the narrative anticipates a SAE.
7.
The scenario anticipates downgrading the emergency classification to SAE at 0100 based upon plant conditions, dose projections, and environmental field monitoring (per narrative).
The scenario will not support down-grading at this time as shown below:
- The 0100 process and effluent monitor readings (pages 7.1-2 & 3) are equal to or greater than the 2345 readings.
- The 0100 primary coolant activity is identical to taat at 2345 (pages 7.2-2 & 3).
- Wind direction, sigma theta, and delta T are constant.
- 0100 WB and thyroid projections are > 2345 values.
- 0100 field data is > 2345 data for all distances.
- Primary coolant pressure has decreased from 600 to 400 psia.
- Only the inplant radiation data values are Y.
8.
The means of de-escalating from one emergency classification to the preceding classification should be reviewed in procedures prior or during the exercise.
Emergency classifications frequently support only an escalation in classification.
9.
The timing of the coolant sample analysis does not appear to be reasonable, especially considering that actual demonstration of this activity is included as an objective.
The results of the 2010 sample are to be available at 2010 which seems too soon.
In addition, more information is necessary for dose rates from the withdrawn sample.
- 10. The initial conditions package provided to the operators should include the results of the last primary coolant sample.
11.
Prepositioned dose projection sheets accompany cue cards and are provided for time periods 2045, 2130, 2315, 2345, and 0100. Data such as radio-logical monitor readings, meteorological data, stack flow rates, reactor temperatures, and reactor pressures are already filled in on the sheets simplifying the user's data acquisition problem significantly.
The -
controllers are led to anticipate dose projections at only those times.
This-should be improved because:
- The utility should be capable of dose projections every 15 minutes.
- ERF staff should control dose projection timing, not the controllers.
Data should not be filled in on a special user-friendly projection sheet but should be transmitted to the user by the normal or backup processes in use at the utility.
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_ The scenario shculd be capable of supporting dose projection data i
requests made at any time during the exercise.
It would be useful to rework the data package to provide ERF personnel with periodic dose data, along with other parameters, according to the utility's normal information pathway (e.g., via phone or computer), to eliminate special formatted data sheets, and to allow the ERFs to decide when a projection is required.
C.
CONTROLLER MESSAGES t
1.
The repetitive cue cards accompanying all messages are confusing.
Some i
cards carry the same message but have different cue card numbers (e.g.
cards 1 and 2).
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2.
Cue cards should not present or highlight data prior to normal conditions.
Cue card 6 delivers 1915 data to the R0 at 1910.
The data logger printout #1293 accompanies Message 8.
3.
Several cue cards messages are incomplete (e.g., 13, 20, 21, 22, 23, etc.).
4.
Delete "due to thermocouple malfunction" from cue card 3.
The data printout will not provide that cue; therefore, it is prompting. The operators should be allowed to reach their own conclusions.
i 5.
Messages 49 and 50 are prompting for the results of accountability 30 minutes after it is ordered. This prompt is not required and should be deleted. Accountability should be allowed to proceed unprompted to conclusion as nothing else in the scenario hinges on it.
6.
Cue card 61 should not be delivered directly to the RO.
Because it informs him of the injured contaminated man and provides the specific location, it is artificial and should be eliminated in favor of a message delivered at the scene of the injury to the next person passing by.
If no one passes by, the report should not be delivered until the control room attempts to maintain accountability of EOs.
If the E0 is not located, then a search and rescue team will be dispatched. At any time, the lead controller may decide to prompt the situation in order to carry on with the injured man scenario.
7.
Rather than having it delivered directly to the R0, cue card 79 should be delivered to a guard who would phone the message into the Control Room.
8.
Cue card 89 should be delivered to the emergency coordinator and not the shift supervisor.
9.
Message #65 for the injured / contaminated worker should be for the controller only.
Information should not be presented to the players l
in this format as it constitutes prompting.
Information should be given to the players as requested or normally obtained.
10.
Change " hit" to " lit" on cue card 18. Assuming that the data logger would not be able to identify the scram as spurious, delete "this is a spurious scram" as it is prompting.
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- 11. As previously mentioned, the operator should be required to determine the cause of the scram and it should not be provided by a prompting message.
Therefore, delete " spurious" on cue card 25.
D.
CONTINGENCY MESSAGES 1.
On the next to last paragraph of Page 4.3-1, it states that " Contingency messages are noted with a number followed by a capital C."
This is not true in all cases (e.g. cue cards 10, 11, 14, 24, etc.).
Label all I
contingency cue cards with a C.
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2.
Except for Cue card 89, no contingency messages are provided to prompt the emergency coordinator in the event of failure to classify correctly or in a timely fashion.
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