ML20215E552
| ML20215E552 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 12/17/1986 |
| From: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Robert Williams PUBLIC SERVICE CO. OF COLORADO |
| References | |
| NUDOCS 8612220400 | |
| Download: ML20215E552 (2) | |
Text
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DEC I T 1986 In Reply Refer To:
Docket: 50-267/86-22 1
Public Service Company of Colorado
. ATTN:
Robert 0. Williams, Jr.
Vice President, Nuclear Operations P. 0. Box 840 Denver, Colorado 80201-0840 Gentlemen:
Thank you for your letters of October 28 and November 7,1986, in response to our letter and attached Notice of Violation dated September 24, 1986. As a result of our review, we find that additional information is needed.
Specifically, you need to address what actions you have taken or will take to assure that deficiencies identified during an annual exercise are corrected and will not be repeated in the subsequent exercise.
With regard to your discussion of the specific deficiencies noted, we find that your response adequately addressed deficiencies A, B, and E.
Regarding deficiency C, we agree that the circumstances of the scenario and PSC personnel actions do not support a clear finding that this was an uncorrected deficiency from the previous exercise.
For deficiency D, however, our review finds that your reply fails to establish an adequate basis to support your contention that a deficiency did not occur.
Therefore, your response should include specific commitments and completed actions to assure that control of PSC emergency response actions will be exercised from the forward Command Post.
Please provide supplemental information to address the above concerns within 30 days of the date of this letter.
Sincerely, ORIGINAL SIGNED BY:
J. E. Gagliardo, Chief Reactor Projects Branch cc:
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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)
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Company of Colorado 2420 W. 26th Avenue, Suite 1000, Denver, Colorado 80211 October 28, 1986 Fort St. Vrain Unit No. 1 P-86609
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Region IV U. S. Nuclear Regulatory Commission
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Attention: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Docket No. 50-267
SUBJECT:
I&E Inspection Report 86-22
REFERENCE:
NRC letter Gagliardo to Williams, dated September 24, 1986 (G-86512)
Dear Mr. Gagliardo:
In the reference above, PSC was asked to respond to I&E Inspection 86-22 within thirty days of the date of the letter. While reviewing the draft of this letter, the Nuclear Licensing Department has identified several items which need to be resolved before the letter is sent to the NRC. As agreed to by Mr. J. Jaudon of your office in a telephone conversation on this date, PSC will submit its response to this inspection on or before November 7, 1986.
Should you have any questions concerning this request, please contact Mr. M. H. Holmes (303) 480-6960 for further information.
Very truly yours, N..f. Bf ?r/W19ega H. L. Brey, Manager Nuclear Licensing and Fuels HLB /DCG:kb
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w Attn: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Docket No. 50-267
SUBJECT:
I&E Inspection Report 86-22
REFERENCES:
(1) NRC Letter, Gagliardo to Williams, dated 09/24/86 (G-86512)
(2) PSC Letter, Gahm to Gagliardo, dated 08/27/86 (P-86533)
(3) PSC Letter, Gahm to l
Gagliardo, dated 08/29/86 (P-86535) l
Dear Mr. Gagliardo:
This letter is in response to the Notice of Violation received as a result of inspections conducted at Fort St. Vrain during the period August 4-8, 1986.
Public Service Company's responses to the three l
identified deficiencies in Inspection Report 86-22 are also included.
l The following response to the items contained in the Notice of Violation is hereby submitted:
Failure to Correct Deficiencies l
10 CFR 50.54(q) requires that licensees shall follow and maintain l
in effect emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements in Appendix C (1985), the l
violation is listed below:
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. 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.
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)
A.
During the 1985 exercise, internal inconsistencies and lack of completeness in scenario data and instructions for players and controllers resulted in a failure to fully demonstrate some exercise objectives.
During the 1986 exercise, NRC inspectors identified scenario inconsistencies which impacted the demonstration of emergency classification and dose assessment, indicating that this deficiency had not been fully corrected.
(1) The reason for the violation if admitted:
Insufficient input and review from experienced plant personnel, during the scenario development phase, resulted in some erroneous data. values.
Unfortunately, one such value was the key to escalating to an alert classification.
Likewi se, the offsite radiological data was developed utilizing an inappropriate release option on the dose assessment program.
This error was also overlooked due to the lack of an effective, technical review of the final scenario draft.
A post-exercise review of the scenario verified the stated scenario errors, however, it is believed that the scenario was workable, if controllers would of made immediate resolutions to the errors.
(2) The corrective steps which have been taken and the results achieved:
PSC is surveying the nuclear industry to determine good practices which can be adapted to Fort St. Vrain in the area of scenario development and control.
. (3) Corrective steps which will be taken to avoid further violations:
As PSC indicated in Reference 3, guidelines for scenario preparation and review will be developed to ensure sufficient input and technical reviews are provided to the packages.
Complete " table-top" walkthroughs of scenarios are also being planned for future exercises.
(4) The date when full compliance will be achieved:
August 31, 1987 B.
Controller actions in the control room during the 1985 exercise were found to be deficient in allowing player to depart from the exercise scenario.
During the 1986 exercise, this deficiency was found not to have been fully corrected, in that weak controller action in the control room failed to correct scenario weaknesses and impacted the demonstration of emergency classification in the early stages of the exercise.
(1) The reason for the violation if admitted:
As stated in the response to Section A, incorrect data and inability of controllers to effectively steer the situation lead to a delay in making the initial emergency classification. This delay contributed to allowing the scenario to get off its
" time line".
The Control Room and Lead Controllers discussed these problems following the exercise.
It was determined that a lack of assertiveness on the part of the Control Room controllers caused the delay.
Even though the data error was recognized by the Control Room controllers, no positive corrective actions were taken to keep the scenario "on-track".
(2) The corrective steps which have been taken and the results achieved:
During the performance of the exercise, a Lead Controller arrived in the Control Room to determine what was causing the delay.
Upon recognizing that wrong data was included in the scenario and I
that the Control Room controllers had not properly handled the delay, a discussion with the emergency Control Room Director was held.
Following this discussion, the Control Room Director 4
escalated the event to an Alert classification and the exercise continued. No other actions have been taken on this deficiency.
i
. (3) Corrective steps which will be taken to avoid further violations:
Licensed Operators will be used as Control Room controllers to the extent possible. Also, a more thorough " walk-through" of the exercise package with all controllers ahead of exercise time will help to stress the importance of keeping the exercise on the scenario time line.
During controller training, it will be emphasized to the controllers that they have the authority to direct the scenario, and not allow such delays to occur during an exercise performance.
(4) The date when full compliance will be achieved:
August 31, 1987 C.
During the 1985 exercise, a deficiency in the training of rescue personnel for first aid and personnel decontamination was identified. The NRC inspectors observed a similar lack of attention to first aid and personnel decontamination considerations during the 1986 exercise, indicating a failure to correct this deficiency.
(1) The reason for the violation if admitted:
Even though PSC feels that the medical response actions were adequate, sufficient decontamination actions were not performed to fully satisfy a stated scenario objective.
It is felt that too low of contamination levels were provided to effectively indicate the need for formal decontamination procedures. The training associated with decontamination and medical response had been upgraded prior to the exercise, however, was not enforced with " hands-on" drilling prior to the exercise.
All Nuclear Production Division personnel receive annual multi-media, equivalent, first aid training, including the use of splints.
During the exercise, the patient indicated to the medical response team that he had pain and may have broken his leg, however, no major medical complications, beside the minor fracture, were proposed within the scenario. The decision of the medical response team, with concurrence of the injured, not to transport the victim via a stretcher from the radiation area (Reactor Building) to the Health Physics Access Area is in PSC feelings, an unjustified " finding".
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6 5-(2) The corrective steps which have been taken and the results achieved:
i The current level of training in decontamination was reviewed by the Training Department staff and PSC believes that sufficient academic training is in place. Walk-throughs and/or " drills" of the required procedures need to be implemented to reinforce the.
r academic process.
(3) Corrective steps which will be taken to avoid further violations:
As indicated in PSC's response to the SALP report (Reference 3),
a formal schedule of emergency training,. including frequent drilling, will be developed and implemented via the Training Department. This emphasis on the " hands-on" exercising of the academic process should prevent further discrepancies in the medical and decontamination procedures.
l (4) The date when full compliance will be achieved:
The revised training schedule, including emphasis on drills, will be implemented during the first quarter of 1987.
The system l
should be fully inplace by April 1, 1987.
D.
During the 1985 exercise, the licensee was deficient in fully demonstrating coordination of radiological and i
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 2
protective action recommendations during the 1986 exercise, indicating that the deficiency had not been fully corrected.
i (1) The reason for the violation if admitted:
i 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 i
Dose Assessment Coordinator at the FCP and these recommendations f
j were formally discussed with other agencies. The protective action recommendation early in the scenario was to take no i
protective actions initially.
It is possible that the NRC thought there were no protective action recommendations made.
Staff augmentation problems throughout the emergency response l
organization also contributed to many problems in the beginning i
of the scenario.
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. (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.
(3) Corrective steps which will be taken to avoid further violations:
As indicated 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.
(4) The date when full compliance will be achieved:
August 31, 1987 E.
Following the 1985 exercise, during the post exercise critique, the licensee reported a deficiency in which the control room director preempted the corporate emergency director's decision making responsibility by making an emergency declaration.
During the 1986 exercise, the NRC inspectors observed the technical support center director declare a General Emergency and provide protective action recommendations although it was the CED's responsibility to perform these functions.
This indicates a failure to correct this deficiency.
(1) The reason for the violation if admitted:
The Technical Support Center Director did make a declaration to General Emergency without consultation of the Corporate Emergency Director.
The Technical Support Center Director indicated that his declaration was made to ensure that timely actions were taken on site, and that he notified the CED in parallel.
. (2) The corrective steps which have been taken and the results achieved:
The TSC Director was reminded that the Corporate Emergency Director has overall authority for emergency classification once the Forward Command Post is activated.
(3) Corrective steps which will be taken to avoid further violations:
As in the response to Section D, emphasis on position responsibilities will again be given in emergency response training.
The need for effective communications during decision making processes will be stressed.
- Again, PSC believes that increased frequency of drilling to reinforce the academic process will benefit these items.
(4) The date when full compliance will be achieved:
August 31, 1987 c
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. RESPONSE TO DEFICIENCIES 267/8622-02:
Information flow to the Control Room was deficient in that the Shift Supervisor was not informed of the status of accountability, staffing of the Personnel Control Center (PCC), or dispatch of the onsite monitoring team in a timely manner.
PSC Response:
PSC agrees that the final accountability report was not officially transmitted to the Control Room.
This was due to confusion with the accountability procedure. As stated in PSC's response to the SALP report (Reference 3),
the accountability procedure is being revised to include a responsible position to direct and ensure completion of accountability and make subsequent reports to the Emergency Director.
PSC is evaluating the continuing problem of center status reports being delivered to the Control Room.
PSC believes that there is no definite direction given within the Radiological Emergency Response Plan as to who/where the center directors should report their manning status. New status boards have been developed for the primary response centers which include activation times of all of the centers.
This should assist in everyone being familiar with center status.
PSC believes that implementation of an effective drilling schedule to reinforce the academic processes, will benefit the performance of emergency response actions through increased familiarization with the application of existing procedures and practices.
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267/8622-03:
The Forward Command Post was not activated and operational in 90 minutes after declaration of an Alert emergency classification.
PSC Response:
The problem of staff augmentation and subsequent activation of all primary emergency response centers affected the entire performance of the exercise.
Problem resolution in staff augmentation have been focused at two areas of concern:
1)
Lengthy discussions / messages in the first tiers of the telephone "fanout" resulted in delays in contacting personnel on the subsequent tiers.
2)
Too many individuals assigned to specified callers on the telephone fanout process caused a delay in getting personnel to respond to the emergency.
As indicated in PSC's response to IE Inspection 86-15 (Reference 2), PSC is currently revising the telephone fanout system to include more
" callers" for contacting personnel.
This revision will include a greater depth in callers to ensure the process can be completed with unavailable individuals (out of town, vacation, etc.).
Also as indicated in Reference 2, upon final revision of the telephone fanout process, specific training will be initiated for those individuals identified as having a primary responsibility for making calls.
Table-top walkthroughs will be conducted to ensure process adequacy.
Following implementation of the new process, the system will be tested on a routine basis.
PSC is also considering implementing a paging system for Fort St. Vrain's emergency organization.
2 267/8622-04:
Certain provisions of RERP Implementing Procedures controlling emergency response activities at the FCP were not followed.
PSC Response:
As indicated in PSC's response to the SALP report (Reference 3), continued emphasis, in training, on the importance of understanding and following established procedures will be given.
The procedures will also be reviewed to determine if the processes described are still compatible with current emergency organization staffing and actions.
PSC is confident that with a higher emphasis on training, personnel will become more familiar with required actions and responses.
Should you have any further questions, please contact Mr. M. H. Holmes at (303) 480-6960.
Sincerely, JWdd/tm hf M
J. W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG/ojc