ML20235Y237
| ML20235Y237 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 10/18/1985 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| P-85376, NUDOCS 8710200267 | |
| Download: ML20235Y237 (7) | |
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October 18, 1985 Fort St. Vrain Unit No. 1 P-85376-i i
Regional Administrator l
Region IV CCT 2 2 m
' !l'l U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 l
Arlington, Texas. 76011 ATTENTION:
Mr. Eric Johnson
~~
'"i Docket No. 50-267
REFERENCE:
I & E Inspection Report 85-18 (G-85387)
.)
Dear Mr. Johnson:
' Attached are the Public Service Company responses to the deficiencies identified within I & E Inspection Report,85-18.
4 Sincerely, J.'W.
ahm Manager, Nuc' lear Production Fort St. Vrain Nuclear Generating Station i
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,a Attachment
.f Page 1 of 6 W-F I
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E t267/8518-01:
. Internal inconsistencies and lack of completeness in the scenario data and instructions -for players and f
controllers resulted in various instances of i
' unnecessary simulations, coaching and a lack of realism.
As a consequence, some exercise objectives
-.-Q were not completely demonstrated.
j PSC Response:
As the facility is required to exercise to the level
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-of General ~ Emergency, excessive simulation and unfamilia.' indications had to be implemented to the
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' Operations personnel causing a very unrealistic
" 76 situation.
The facility and the observers seem to have a difference in definition of " coaching".
Since the Operations personnel responded promptly and it -
correctly to initiating situations, the Control Room controllers had to continually interject new factors to allow the exercise to advance to a postulated General. Emergency.
The plant critique identifies, however, the need for increased formal training of 1
controller / observers.
The " lack of realism" will Q,'o continue to be a problem at Fort St. Vrain as long as we are required to exercise to the level of General Emergency.
Further correspondence on the applicability of a General Emergency classification at Fort St. Vrain is pending.
The plant is committing to gathering more scenario experience via industry reviews,
- seminars, etc.
Through the experience gained, scenario improvements will be made for future exercises which will provide means to better evaluate all stated objectives.
267/8518-02:
Controller actions in the control room indicated a
?'
l deficiency in controller and player training for
,i conducting the exercise.
For example, controllers, place (sic) information cards on the control panel j
where the shift supervisor could see repair team messages and the outcome of their actions.
Another instance was that controllers allowed players to depart from the senario and form (sic) actually turn off audible and visual alarms intended for the actual operating staff.
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P-85376-Attachment Page 2 of 6
'PSC Response:
.Through revised and.
planned training for controllers / observers and players, _it will be clearly._
stated that all actual Control Room and plant manipulations must be_
performed by-on-staff Operations personnel (non players) o n l y.,
The controller training will also emphasize.
the
-importance of keeping exercise information froin the exercise players.
Upgraded training and pre-exercise briefings should eliminate these deficiencies in future exercises.
26//8518-03:
Habitability
. surveys were not conducted in the control room.
PSC Response:
Due to the desig:. characteristics of the Control Room ventilation and shielding systems (reference Sections 7.4.1 and 11.2.2.6 of the Updated Fin 6 Safety Analysis Report) and the continuous operation of a.
five point monitor which samples Control Room
- air, independent habitability checks are not required.
If an alarm is received, the onerators are trained to respond.accordingly.
No further action is anticipated for this item.
267/8518-04:
(NOTE:
Mislabeled as -05 in report) Habitability surveys in the TSC were deficient in that the surveys did not include contamination checks.
PSC Response:
All personnel monitor themselves for contamination upon initial entry to the TSC and upon subsequent reentries.
During the exercise, certain personnel l
(players) violated the requirements as posted on the j
entry doors concerning frisking and signing in.
This l
was immediately corrected by the TSC Director.
If 1
contamination would be identified on any entering I
personnel, a more thorough contamination survey would be crdered by the senior Health Physics personnel present in the Technical Support Center.
No further action is considered necessary for this item.
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n P-85376 l
Attachment Page 3 of 6 267/8518-05:
Information flow within the TSC.was deficient.
For example, the communicator did net advise the' TSC Di rector. about a real' contamination event which occurred during the exercise.
Another instance.
demonstrating poor information ' flow occurred when scenario monitoring data indicating high levels of radiation were not reported to decision makers.
PSC Response:
The. plant. personnel critiques have identified that i
some minor information flow problems were evident within the TSC.
- However, the major flow of plant information was performed efficiently.
Through i
continuation of quarterly TSC training with emphasis on the importance of total information flow and proper methods / channels, this deficiency should be eliminated in future exercises.
267/8518-06:
Field monitoring team results were not properly logged on sampling data worksheets as required by procedure.
PSC Response:
Field monitoring team results should be documented per procedure RERP-FIELD.
This deficiency will be resolved by continued training of appropriate personnel along with the review of the procedure to asses's the need for a simpler field data information form.
267/8518-07:
The NRC inspector observed that a repair team, cocsisting of two maintenance employees and a health physics technician failed.to adequately implement radiological precautions, in that they removed their respirators, failed to check pocket dosimeters, and
^
removed their potentially contaminated y
anticontaminatien clothing within the control room office space.
inis is considered to be a deficiency in training of personnel in radiological control procedures.
PSC Response:
The plant will evaluate the functions of Damage Control, Search and Rescue and Medical Emergency l
i teams and upgrade the training for such teams giving emphasis on radiological controls and associated procedures.
P-85376 Attachment Page 4 of 6 267/8518-08:
The NRC inspector noted that approximately 50 percent of plant personnel that would report to the main building lunch room during site accountability were repositioned in the lunch room r
' r to the sounding of the site evacuation ai-Others were repositioned in adjacent areas.
In addition, the accountability method used was inadequate in that it was accomplished by visual identification only.
Accountability of all site personnel was therefore not demonstrated under realistic conditions.
This in (sic) considered to be a deficiency in demonstration of site accountability.
PSC Response:
The initiation time of the drill was 0945 hours0.0109 days <br />0.263 hours <br />0.00156 weeks <br />3.595725e-4 months <br />. The personnel present in the lunchroom at that time were completing their normal morning break (0930-0945),
and not repositioned as speculated by the NRC inspector.
A visual accountability was performed by station personnel familiar with other employees.
It is recognized that NRC observers could not assure that accountability was being made due to unfamiliarity with station personnel.
This is considered more of a deficiency in "drillsmanship" Personnel accountability procedures have been repeatedly scrutinized and revised as the result of NRC and station criticisms.
It is felt that the current procedure is the most effective means seen thus far. This pro.cedure was a recent major revision implemented just prior to the annual exercise, and as such, there were many personnel somewhat uncertain as to their required actions.
The plant is presently undergoing the annual General Employee Retraining and personnel rebadging, which includes training on the current accountability system.
The new badges also have the respective person's accountability station identified on the badge.
The training and new badges should reduce tne number of personnel errors concerning accountability.
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k P-85376 Attachment Page 5 of 6 i
It should also be noted that Fort St. Vrain performs a " positive accountability" system.
Upon initiation of a station alarm, the plant security computer prints a listing of all personnel who are present within -the protected area boundary.
The listing is=
sorted accordingly to accountability stations and delivered by the security force to the respective stations. The person conducting the accountability only-has to ascertain the presence of the' personnel on that listing. All other personnel who are outside of. the protected area boundary are not accounted for during the initial accountability.
267/8518-09:
The NRC inspector observed that no decontamination of the-victim was attempted during the 30 minute period elapsing between the arrival of the victim in the decontamination facility and his subsequent placement in the vehicle.
This is considered to be a deficiency in the training of personnel to handle injured and contaminated persons.
PSC Response:
Enhanced training in Damage Control, Search and Rescue and Medical Emergency teams will be evaluated and implemented, as identified in response to 8518-07. Associated with this training, an emphasis will be placed on control.and handling of potentially contaminated personnel and equipment.
267/8518-10:
The.NRC inspector noted that the physical layout and licensee support staffing of the FCP (the licensee's near-site emergency operations facility) required that the Corporate Emergency Dirvctor acted more as a communicator between the TSC and the state representative than the manager of overall licensee emergency response.
Because of this, the licensee failed to fully demonstrate coordination of radiological and environmental assessment, development of recommendations for public protective
- actions, and management of onsite and emergency operations facility activities.
This is considered to be a deficiency in the direction and control of the licensee's emergency response activities.
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P-85376 Attachment Page 6 of 6 m
PSC Responset The current FCP arrangement is-the result of PSC and the State of. Colorado Division of Disaster Emergency.
Services (D0 DES) working cooperatively to arrive at a i
floor plan with each. organizations' concept of I
organization and control in radiological emergency response taken into account.
The Corporate Emergency Director (CED) is in command of PSC emergency I
operations, and as such communicates extensively with site emergency response forces through the onsite-offsite link (the Technical Support Center and the-TSC Director).
Additionally, due to the sensitive nature of recommendations for protective
- actions, it is felt that any'such recommendations to the State must come from the CED.
Radiological and environmental assessment, protective action recommendation development, and the management of onsite emergency operations facilities are appropriately delegated.
Public Service Company will explore the need for layout and staffing changes at the FCP with D0 DES personnel in 'a future meeting. We do not however, agree that the Corporate Emergency Director is failing to direct and control PSC's emergency response activities.
The items identified by plant personnel during the post-exercise j
critique (as outlined in Item 5 of the referenced report) will be reviewed and appropriate corrective actions initiated, as required, i
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