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{{Adams | |||
| number = ML20210J009 | |||
| issue date = 09/17/1986 | |||
| title = Insp Rept 50-267/86-22 on 860804-08.Violation Noted: Failure to Correct Previously Identified Emergency Preparedness Deficiencies | |||
| author name = Baird J, Yandell L | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000267 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-267-86-22, NUDOCS 8609260390 | |||
| package number = ML20210J003 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 13 | |||
}} | |||
See also: [[see also::IR 05000267/1986022]] | |||
=Text= | |||
{{#Wiki_filter:. . | |||
APPENDIX B | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION IV | |||
NRC Inspection Report: 50-267/86-22 License: DPR-34 | |||
Docket: 50-267 | |||
Licensee: Public Service Company of Colorado (PSC) | |||
P. O. Box 840 | |||
Denver, Colorado 80201-0840 | |||
Facility Name: Fort St. Vrain Nuclear Generating Station (FSV) | |||
Inspection At: Fort Lupton and Fort St. Vrain, Colorado | |||
Inspection Conducted: August 4-R, 1986 | |||
Inspector: O /d MM | |||
J/'B. Baird, NRC Team Leader | |||
T//7/f4 | |||
Dat( ' | |||
Other Inspectors: C. Hackney, RIV, NRC | |||
W. Bennett, RIV, NRC | |||
D. Perrotti, OIE, NRC | |||
E. Hickey, Pacific Northwest Laboratories | |||
G. Bryan, Comex Corporation | |||
Approved: , , | |||
'7// 7/86 | |||
I L. A. Yandell, Chief, Emergency. Preparedness Date' | |||
and Safeguards Programs Section | |||
Inspection Summary | |||
Inspection Conducted August 4-8, 1986 (Report 50-267/86-22) | |||
Areas Inspected: Routine, announced inspection of the licensee's emergency | |||
response capabilities during the annual exercise.of the emergency plan and | |||
procedures. | |||
Results: Within the emergency response areas inspected, one apparent violation | |||
was identified (paragraphs 3, 4, 6, 8, and 9 - failure to correct deficiencies). | |||
Three emergency preparedness deficiencies were ident,ified by NRC inspectors. | |||
; | |||
: B609260390 86c?24 | |||
PDR | |||
G | |||
ADOCK 05000267 | |||
PDR | |||
_ | |||
. . | |||
-g- | |||
DETAILS | |||
. | |||
1. Persons Contacted | |||
Principal Licensee Personnel | |||
*F. Borst, Support Services Manager | |||
*H. Brey, Manager, Nuclear Licensing and Fuels | |||
*0. Clayton, Technical Services Engineer | |||
*K. Collins, Quality Assurance Technician | |||
*R. Cook, Quality Assurance Technician | |||
*R. Doyle, Quality Assurance Engineer | |||
*D. Evans, Superintendent of Operations | |||
*M. Ferris, Quality Assurance Operations Manager | |||
M. Fisher, Engineer, Special Projects | |||
*J. Fuller, Vice President, Engineering and Planning | |||
*C. Fuller, Station Manager | |||
J. Gahm, Manager, Nuclear Production | |||
*A. Greenwood, Supervisor, Quality Assurance Auditing | |||
J. Hak, Shift Supervisor | |||
*M. Holmes, Nuclear Licensing Manager | |||
A. Horsechief, Health Physics Technician | |||
R. Husted, Supervisor, Nuclear Fuels | |||
*M. Joseph, Technical Advisor | |||
*B. Langsteiner, Quality Assurance Engineer | |||
*0. Lee, III, Quality Assurance Technician | |||
*W. Ledford, Quality Assurance Engineer | |||
*H. Olson, Member, Nuclear Facility Safety Committee | |||
*D. McCue, Technical Services Engineer | |||
*R. Millison, Technical Services Technician | |||
*F. Novachek, Technical / Administrative Services Manager | |||
*L. Pierce, Manager, Media Relations | |||
*J. Sills, Technical Services Supervisor | |||
*L. Singleton, Manager, Quality Assurance | |||
*G. Toner, Quality Assurance Technician | |||
*R. Walker, Chairman | |||
*D. Warembourg, Manager, Nuclear Engineering | |||
*R. Williams, Jr., Vice President, Nuclear Operations | |||
State of Colorado | |||
*J. Everitt, Division of Disaster Emergency Services | |||
*M. Hanrahan, Department of Health | |||
NRC | |||
*P. Michaud, Resident Inspector | |||
: | |||
! | |||
, | |||
. - - _ _ _ _ . | |||
. . | |||
-3- | |||
Other Personnel | |||
' | |||
H. Bluder, Stone and Webster | |||
*B. Matheney, Member, Nuclear Facility Safety Committee, NUS | |||
J. Rodell, Stone and Webster | |||
* Denotes thase present at the exit interview. | |||
2. Licensee Action on Previous Inspection Findings | |||
(0 pen) Deficiency (267/8518-01): The NdC inspector noted internal | |||
inconsistencies in the scenario impacted the demonstration of some | |||
exercise objectives (see paragraph 3). This item remains open. | |||
(0 pen) Deficiency (267/8518-02): The NRC inspector noted that controller | |||
weakness in the control room impacted the demonstration of some exercise | |||
objectives (see paragraph 4). This item remains open. | |||
(Closed) Deficiency (267/8518-03): The NRC inspector determined that | |||
adequate habitability checks were made in the control room. This item is | |||
closed. | |||
(Closed) Deficiency (267/8518-04): The NRC inspector determined that | |||
adequate habitability checks were made in the technical support center. | |||
This item is closed. | |||
(Closed) Deficiency (267/8518-05): The NRC inspector determined that | |||
licensee training on information flow had addressed the problems | |||
identified in this deficiency; however, see related deficiency in | |||
paragraph 6. This item is closed. | |||
(Closed) Deficiency (267/8518-06): The NRC inspector noted that exercise | |||
observers did not identify any field monitoring team data record | |||
weaknesses. This item is closed. | |||
(Closed) Deficiency (267/8518-07): The NRC inspector observed | |||
radiological precautions by health physics technician and repair team | |||
members to be adeo,uate. This item is closed. | |||
(Closed) Deficiency (267/8510-08): The NRC' inspector did not observe any | |||
prepositioning of station personnel for accountability. The licensee | |||
created a printout list of personnel inside the protected area and station | |||
personnel were accounted for against the station list. This item is | |||
closed. | |||
(0 pen) Deficiency (267/8518-09): The NRC inspector observed similar | |||
weaknesses in first aid and decontamination during the exercise (see l | |||
paragraph 9). This item is open. ' | |||
l l | |||
\ l | |||
1 | |||
I | |||
. . | |||
-4- | |||
(0 pen) Deficiency (267/8518-10): The NRC inspector observed similar | |||
weaknesses in command and control of the forward command post during this | |||
exercise (see paragraph 8). This item is open. | |||
3. Exercise Scenario | |||
The PSC exercise scenario was reviewed prior to the exercise to determine | |||
that provisions had been made for the required level of participation by | |||
state and local agencies, and that all major elements of emergency | |||
response would be exercised by PSC in accordance with the requirements of | |||
10 CFR 50.47(b), 10 CFR Part 50, Appendix E, paragraph IV.F, and the | |||
guidance criteria in NUREG-0654, Section II.N. | |||
Comments from this review were transmitted to the scenario coordinator | |||
prior to the inspection date and satisfactory resolution was obtained | |||
prior to the exercise. In general, the scenario was found to be | |||
significantly improved over the previous exercise in internal consistency | |||
and completeness of scenario data and instructions for players and | |||
controllers. However, the NRC inspectors determined during the exercise | |||
that weaknesses in the scenario were still present and impacted the | |||
demonstration of some exercise objectives. Examples of these weaknesses | |||
were as follows: | |||
- | |||
Scenario data indicated higher fuel damage initially than planned for | |||
in the exercise timeline. This caused the control room to initially | |||
select the Alert classification instead of Notice of Unusual | |||
Event (NOVE) as planned. Later, scenario data inadequacies | |||
contributed to a delay in making the Alert classification. | |||
- | |||
No thermal data were provided to permit prestressed concrete reactor | |||
vessel (PCRV) failure risk. | |||
- | |||
Reactor building louvers were opened although peak pressure data was | |||
insufficient to cause opening. | |||
- | |||
Scenario dose assessment data was based upon release option 4 | |||
although release option 1 (via the louvers) was appropriate. This | |||
resulted in the re-boot of the dose assessment program and reentry of | |||
data, causing a significant delay in producing dose assessment | |||
projections. | |||
- | |||
The method of providing data-logger information to players was new | |||
and the scenario did not make adequate provisions for training | |||
players to use this data in the same way as they would the | |||
data-logger. | |||
The exercise scenario weakness observed appears to constitute the same | |||
general deficiency in this area that was identified during the last annual | |||
exercise (267/8515-01). The failure to correct this deficiency is | |||
. | |||
. | |||
. | |||
-5- | |||
an apparent violation of 10 CFR 50.47(b)(14), which requires the correction | |||
of exercise deficiencies (267/8622-01). The licensee also identified this | |||
deficiency in the post-exercise critique. | |||
No other violations or deviations were identified. | |||
4. Contr a Room | |||
Initial plant conditions and events of the scenario were provided to | |||
the control room staff at about 7:00 p.m. by the exercise controllers. | |||
The initial event was decreasing core outlet temperatures which could not | |||
be corrected by adjusting the flow orifice control valves, followed by | |||
erratic thermocouple readings. At about 7:30 p.m., a rise in primary | |||
coolant activity was shown and a NOUE was declared at approximately | |||
7:52 p.m. A spurious reactor scram, rise in primary coolant moisture, and | |||
a main steamline rupture with the reactor building louvers open resulted | |||
in the declaration of an Alert at about 8:47 p.m. and a Site Area Emergency | |||
at about 9:05 p.m. A rise in primary coolant radioactivity and the | |||
assessment of offsite dose consequences resulted in the declaration of a | |||
General Emergency at about 12:06 a.m. | |||
During the initial part of the exercise, the NRC inspector noted that | |||
scenario problems (see paragraph 3) were impacting the demonstration | |||
of emergency classification. The controllers in the control room did | |||
not maintain contact with the players and make the necessary | |||
scenario / player action corrections to get the exercise back on the | |||
time line and permit adequate evaluation of control room response. | |||
After a delay of about 30 minutes, one of the lead controllers | |||
informed the control room staff that the scenario required | |||
declaration of a NOVE. The classification problera persisted for the | |||
Alert also. The shift supervisor (SS) consulted with the operations | |||
superintendent by telephone and questions about whether or not the | |||
data given required the declaration of Alert caused this | |||
classification to be delayed until the operations superintendent | |||
arrived at the plant. | |||
The NRC inspector in the control room observed the appropriate use of | |||
emergency implementing procedures (EIPs) for classifying events and | |||
noted that initial notifications to state and local agencies were | |||
made promptly by the SS. No notification was made'for Alert because | |||
a Site Area Emergency was declared about 15 minutes later, preempting | |||
the Alert notification. The subsequent notifications were timely. | |||
It was noted that the SS had to leave the control room often to make | |||
calls and notifications. During the times the SS was out of the | |||
control room it was not clear who was in charge of operations. | |||
In addition, the NRC inspector observed that there was good | |||
communication and interaction in the control room during the | |||
exercise, that the SS was properly relieved by the control raom | |||
director (CRD), and that control room personnel were kept well | |||
informed of events by the CRD as the information became available. | |||
. | |||
~ | |||
. . | |||
-6- | |||
' | |||
However, it was noted that communications outside the control room | |||
were weak in that the control room did not know the status of | |||
accountability, if the personnel control center was staffed, or if | |||
the onsite radiation monitoring team had been dispatched. | |||
The control room controller weakness observed appears to constitute | |||
the same general deficiency in this area that was identified during | |||
the last annual exercise (267/8515-02). The failure to correct this | |||
deficiency is an apparent violation of 10 CFR 50.47(b)(14), which requires | |||
the correction of exercise deficiencies (267/8622-01). The licensee also | |||
identified this deficiency in the post-exercise critique. | |||
Based on the above, the following additional item is considered to be | |||
an emergency preparedness deficiency: | |||
Information flow to the control room was deficient in that the | |||
SS 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. (267/8622-02) | |||
The following are observations for the licensee's attention. These | |||
observations are neither violations nor unresolved items. These items are | |||
recommended for licensee consideration for improvement, but they have no | |||
specific regulatory requirement. | |||
- | |||
Provisions should be made for making notifications from the control | |||
room and consideration given to delegation of the calls to a person | |||
other than the SS. | |||
- | |||
Consideration should be given to providing a status board to display | |||
plant conditions and system status for the control room staff. | |||
No other violations or deviations were identified. | |||
5. Personnel Accountability | |||
The NRC inspector noted that personnel were requested to report directly | |||
to their emergency response facilities by the control room following the ' | |||
declaration of an Alert class. According to administrative Procedure G-5, | |||
titled " Personnel Emergency Response," Section 4.1, "In the event that an | |||
Alert or higher level classification event occurs, the Technical Support | |||
Center (TSC), Personnel Control Center (PCC) . . . . will be activated | |||
immediately after initial accountability is completed." In addition, | |||
Section 4.4 of Procedure G-5 states that personnel other than operations | |||
and health physics shall report to the lunchroom for initial | |||
accountability. This caused some initial confusion. During the | |||
accountability process all but two persons were accounted for in | |||
approximately 30 minutes; however, two persons could not be accounted for | |||
in the assembly area. It was subsequently determined by the licensee that | |||
the two persons had left the area and were not key carded out of the | |||
- | |||
. . | |||
-7- | |||
. | |||
protected area. The NRC inspector noted that Section 4.'4 of the | |||
accountability procedure did not address what to do on backshifts or | |||
weekends if personnel were missing, who to report missing persons to, or | |||
who would and how to initiate search and rescue. These deficiencies were | |||
also identified by the licensee during the post-exercise critique. | |||
No violations or deviations were identified. | |||
6. Technical Support Center | |||
The NRC inspector observed that the technical support center activation | |||
was not timely. The Alert was declared about 8:47 p.m. and the TSC | |||
activation was accomplished at about 10:56 p.m. The NRC inspector noted | |||
that this was in excess of the general goal of 60 minutes stated in | |||
Section 8.2.1 j. of Supplement 1 to NUREG-0737 and the specific goal of | |||
90 minutes authorized for Fort St. Vrain. The deficiency in demonstration | |||
of timely staff augmentation and TSC activation was also identified in the | |||
licensee's post-exercise critique. | |||
After the TSC was activated, the NRC inspector noted that command, control | |||
and communications in the TSC were deficient at times. For example, the | |||
TSC director did not announce taking charge of the TSC when he arrived, | |||
and briefings of TSC staff were infrequent, often incomplete (missing key | |||
players and important information), and hampered by high noise levels | |||
which included that of the TSC air sampler. These deficiencies were also | |||
identified in the licensee's post-exercise critique. | |||
In addition, the initial status board entries were not timely and dose | |||
assessment information flow to the TSC director was slow. No running | |||
accounts of limiting conditions for operations (LCOs) or inoperative | |||
equipment were made. The NRC inspector also noted that, for approximately | |||
1 hour, information unavailability apparently led the TSC staff to | |||
incorrectly believe the release rate had been decreased significantly by. | |||
venting primary coolant to the bottle farm. Additionally, no provisions | |||
were made for displaying the protective action recommendations implemented | |||
by state and local agencies. | |||
The NRC inspector noted that the TSC formulated the General Emergency | |||
classification and directed the control room to announce a General | |||
Emergency at approximately 12:05 a.m., and informed the forward command | |||
post (FCP) of that declaration and protective action recommendations at | |||
about 12:08 a.m. At this time the FCP had been activated and the | |||
corporate emergency director (CED) had been responsible for classification | |||
and protective action decisionmaking for about an hour. | |||
The decisionmaking weakness observed appears to constitute the same | |||
general deficiency in this area identified during the licensee's critique | |||
of the last annual exercise and documented in paragraph 5 of NRC Report | |||
No. 50-267/85-15. The failure to correct this deficiency is an apparent | |||
violation of 10 CFR 50.47(b)(14), which requires the correction of | |||
exercise deficiencies (267/8622-01). The licensee also identified this | |||
deficiency in the post exercise critique. | |||
. . | |||
-8- | |||
The following are observations for the licensee's attention. These | |||
observations are neither violations nor unresolved items. These items are | |||
recommended for licensee consideration for improvement, but they have no | |||
specific regulatory requirement. | |||
- | |||
The Radiological Emergency Response Plan (RERP), Section 6, indicates | |||
the emargency alarm is to be sounded at Alert and all higher | |||
classifications. Procedure RERP-CR stated the alarm is sounded at | |||
Alert, Site Area, and General Emergencies unless previously sounded. | |||
This should be made consistent. | |||
- | |||
RERP-CR and RERP-PHONE lists only one of the four alternate telephone | |||
numbers for the NRC operations center. The additional numbers should | |||
be provided. | |||
- | |||
RERP-TSC, 2.4.2, requires the control room director's concurrence | |||
prior to commanding a data-logger printout of " Alarm Types." This | |||
should be reviewed to determine if concurrence is necessary. | |||
- | |||
Emergency response personnel coming into the plant were delayed at | |||
security awaiting telephone authorization for entry. This practice | |||
should be reviewed to determine if a more efficient procedure can be | |||
provided. | |||
- | |||
A display of protective action recommendations made by the licensee | |||
and actually implemented by offsite authorities should be provided. | |||
No other violations or deviations were identified. | |||
7. Personnel Control Center | |||
The Alert classification was declared at about 8:51 p.m. and the first | |||
person arrived at the PCC at approximately 9:37 p.m. The PCC director | |||
arrived at the PCC at about 9:44 p.m. and most of the other PCC personnel | |||
arrived at approximately 10:06 p.m. The PCC director began conducting a | |||
radiological survey to determine facility habitability and requested that | |||
the emergency implementing procedures be removed from the library and used- | |||
by PCC personnel. The NRC inspector noted that the PCC director did not | |||
announce when the PCC was activated and did not conduct any PCC staff | |||
briefings during the exercise. The emergency director in the control room | |||
made emergency class declarations over the paging system from the control' | |||
room; however, there were areas in the PCC where one could not hear the | |||
announcements. The NRC inspector heard the emergency class announcements | |||
but did not hear the reasons announced for the change in emergency | |||
classes. | |||
The NRC inspector noted that personnel arriving at the PCC assisted in | |||
setting up a system for personnel monitoring and decontamination, and | |||
checked themselves for contamination prior to entering the main PCC work | |||
area. The NRC inspector also noted, however, that two persons went from | |||
the PCC to the TSC without the PCC director checking with the control room | |||
. | |||
. - . -. - -- - | |||
. . | |||
-S- | |||
' | |||
for onsite radiological conditions. At this time, the station emergency | |||
director had previously declared an Alert and there had been a | |||
radiological release. | |||
Telephone and radio communications were established with the TSC and both | |||
were maintained throughout the exercise. The NRC inspector noted that the | |||
offsite radiological monitoring personnel rectived the keys to the offsite | |||
monitoring vehicles and were prepared to depart shortly after PCC | |||
activation; however, the teams were not dispatched in a timely manner. | |||
The exclusion area boundary monitoring (EAB) team was dispatched in | |||
2 hours 38 minutes and the emergency planning zone (EPZ) monitoring team | |||
was dispatched in 3 hours 25 minutes after the declaration of an Alert. | |||
In addition to the slow dispatch, the failure to restart and stalling of | |||
the vehicle for the EPZ team contributed to this problem. This deficiency | |||
was also identified by the licensee during the post exercise critique. | |||
The following are observations for the licensee's attention. These , | |||
observations are neither violations nor unresolved items. These items are 1 | |||
recommended for licensee consideration for improvement, but have no | |||
specific regulatory requirement. | |||
- | |||
Control room, TSC and PCC personnel should be notified when the PCC | |||
is activated. | |||
- | |||
The PCC and alternate PCC should have emergency lighting in the event | |||
of a power failure. | |||
- | |||
Personnel should sign in at the PCC under their functional areas so | |||
that the PCC director is aware of personnel that have arrived. - | |||
- | |||
All personnel should be made aware of plant radiological conditions | |||
prior to departing for the TSC or control room. | |||
- | |||
The public address system in the PCC should be upgraded so that all | |||
, | |||
PCC personnel can hear accident related messages. | |||
- | |||
PCC personnel should receive periodic emergedcy related information | |||
from the PCC director. | |||
No violations or deviations were identified. | |||
i | |||
8. Forward Command Post l | |||
l | |||
The licensee's forward command post, which is the emer9ency operations I | |||
facility, is located in the licensee's Fort Lupton service center ' | |||
i | |||
building. The NRC inspector noted that the facility was laid out per | |||
Procedure RERP-FCP, Issu'e 13, as amended by PDR 86-895. The NRC inspector | |||
noted that the FCP was not activated within the 90 minutes time from the | |||
declaration of an Alert (synonymous with the start of the fan-out | |||
notification) as committed to by the licensee. The NRC inspector noted | |||
- | |||
that the CED arrived approximately 90 minutes after the fan-out (AF+90). | |||
1 | |||
) | |||
_. - _ _ . . . - . . | |||
. | |||
. | |||
. | |||
-10- | |||
However, at this time no plant status was available from the TSC, so the | |||
FCP remained staffed, but essentially unable to perform its primary | |||
function of command and control of the licensee's emergency response. It | |||
was observed by the NRC inspector that a FCP communicator passed | |||
information on to the TSC that the FCP was fully manned at AF+97. | |||
However, the CED had made no decision on activation at this point. At | |||
AF+120 the TSC and FCP still had not been declared fully operational. | |||
The NRC inspector also noted that Procedure RERP-FCP provides no detailed | |||
instructions for the CED as to when or how the responsibility for command | |||
and control of the emergency response should be transferred from the TSC to | |||
FCP. The initial plant status briefing for the PSC FCP staff was | |||
conducted by the CED. However, from that point on the licensee | |||
demonstrated weaknesses in the command and controi of emergency response | |||
activities, as evidenced by the following examples: | |||
- | |||
The CED attempted a premature activation and announcement of PSC FCP | |||
operability before the condition of the plant was fully known. | |||
- | |||
There was nc, announcement made by the CED to the PSC FCP staff that | |||
the FCP was considered to be activated and fully operational, that | |||
the CED was in charge, and that the responsibility for notifying and | |||
making protective action recommendations (PARS) to offsite | |||
authorities had been transferred from the TSC to FCP. | |||
- | |||
For the most part the station technical liaison (STL) briefed the | |||
staff and appeared to be the decisionmaker for PSC. | |||
- | |||
When asked for a protective action recommendation by the state, the | |||
CED was indecisive as to what to recommend. Scenario events finally | |||
overtook this situation when the emergency escalated from a Site Area | |||
Emergency to a General Emergency. | |||
- | |||
Press releases were not reviewed and concurred in by the~CED, and | |||
made available to the NRC for review prior to issuance. | |||
During the exercise the NRC inspector noted several instances where | |||
approved procedures were not followed: | |||
- | |||
RERP-PAG, Issue 4, specifies that the decision for PARS is.to be- | |||
based, in part, upon plant system parameters. However, at the Site | |||
Area Emergency level no consideration was given to protective actions | |||
based on deteriorating plant conditions (even though an uncontrolled | |||
release was in propress). | |||
- | |||
RERP-PAG states that this procedure is to be implemented (i.e., | |||
protective actions are to be developed) whenever there is an Alert or | |||
higher emergency class event in progress. Howev'er, when the state | |||
requested a PAR (during the Site Area Emergency class) the licensee | |||
failed to provide a PAR. | |||
__. _ _ _ .. .. | |||
P | |||
,. . | |||
e | |||
-11- | |||
. | |||
- | |||
RERP-FCP, Issue 13, specifies that data for radiological updates is | |||
to be obtained from, and reviewed by, the radiological assessment | |||
coordinator (RAC) prior to posting. However, the status board keeper | |||
repeatedly posted data announced over the TSC speaker without a prior | |||
review and concurrence by the RAC. At one point this resulted in | |||
confusion as to the status of offsite doses (measured vs. projected). | |||
RERP-FCP states that media relations will provide assistance to the | |||
' | |||
- | |||
FCP public information team in the preparation of news and related | |||
i media releases. However, the media relations personnel informed the | |||
inspector that they had not provided assistance in the preparation of | |||
news releases, but had distributed the releases as they were issued. | |||
. | |||
I | |||
The process used in this exercise precluded concurrence in the | |||
technical content of the news releases by the CED as discussed above. | |||
l | |||
Although certain aspects of the physical capability of the FCP appeared to | |||
be substandard and detracted from the exercise, this matter will be | |||
: deferred until the review of the Fort St. Vrain facilities under the NRC's | |||
l program of post-implementation review of the emergency response facilities | |||
i | |||
. | |||
is conducted as discussed in a letter from G. L. Madsen, RIV to 0. R. Lee, | |||
Vice President, Electrical Production, Public Service Company of Colorado | |||
dated August 16, 1983. | |||
The FCP command and control weakness observed appears to constitute the | |||
same general deficiency in this area that was identified during the last | |||
annual exercise (267/8515-10). The failure to correct this deficiency is | |||
an apparent violation of 10 CFR 50.47(b)(14), which requires the correction | |||
of exercise deficiencies (267/8622-01). The licensee also identified this | |||
: | |||
, | |||
deficiency in the post-exercise critique. | |||
Based on the observations above, the following additional items are | |||
, | |||
considered to be emergency preparedness deficiencies: | |||
i | |||
The FCP was not activated and operational in 90 minutes after | |||
declaration of an Alert emergency classification. (267/8622-03) | |||
i | |||
' | |||
Certain provisions of RERP implementing procedures controlling | |||
emergency response activities at the FCP were not followed. | |||
J. | |||
(267/8622-04) | |||
The following are observations for the licensee's attention. These | |||
observations are neither violations nor unresolved items. These. items are | |||
recommended for licensee consideration for improvement, but have no | |||
specific regulatory requirement. | |||
- | |||
RERP-FCP needs revision to provide clear instructions on the transfer | |||
; of command / control from TSC to FCP. ; | |||
i | |||
- | |||
RERP-FCP and RERP-PAG need clarification with regard to the | |||
difference in meaning of protective action recommendations and | |||
protective action guides (PAGs). | |||
l | |||
l | |||
l | |||
. - , _ i- _ . - _ _ , _ - _ | |||
' | |||
.. . | |||
-12- | |||
- | |||
The functions of dose assessment (primary responsibility), control of | |||
field monitoring tean.s and associated activities should be | |||
transferred to the FCP when that facility is declared operational. | |||
The TSC should continue to perform dose assessment as backup- | |||
capability. | |||
- | |||
Responsibility for event classification and determination of PARS | |||
should be clarified as to when transfer of these functions is to take | |||
place along with the transfer of the responsibility for notification | |||
of offsite authorities. | |||
- | |||
RERP-PAG should be revised to fully conform to IE Information | |||
Notice 83-28 regarding PARS based on plant status. | |||
- | |||
Status boards should be reviewed to provide capability for trending, | |||
site evacuation status, to tell new data from old since all | |||
information on the board is not updated at the same time, and posting | |||
protective actions implemented by the state / local agencies. | |||
No other violations or deviations were identified. | |||
9. First Aid and Inplant Radiation Protection | |||
The inplant monitoring and first aid portion of the exercise began at | |||
approximately 9:20 p.m. with a team preparing to enter the reactor | |||
building for valve lineup to depressurize the PCRV. The team was | |||
subsequently dispatched at about 9:40 p.m., followed by one of the | |||
operators falling and simulating the breaking of his leg and becoming | |||
contaminated. The NRC inspector noted that the scenario for the medical | |||
emergency was expected to require search and rescue, but was timed such | |||
that the individual injured was never alone, and therefore never missing. | |||
During this part of the exercise scenario, it was also noted that there | |||
were many uses of the radios without stating that the activity was a | |||
drill. | |||
The NRC inspector noted that the team providing first aid made | |||
radiological surveys, but did not keep a written record of the surveys. | |||
In addition, the injured person was asked to " hop" out without benefit of | |||
a splint being applied to his broken leg. A trauma kit containing a | |||
splint was available, but since the individuals responding were not | |||
qualified emergency medical technicians (EMT's), they did not use the kit. | |||
The NRC inspector also noted that after the injured person was removed to | |||
the health physics control point, his protective clothing was not cut off | |||
to remove the majority of contamination, and to give him relief from the | |||
heat. ! | |||
, | |||
l | |||
The NRC inspector noted that the radiological protection by health physics ! | |||
technicians and repair team personnel appeared to be adequate. | |||
Anticontamination clothes and respirators were properly used and dosimetry | |||
was checked after leaving the radiation area. l | |||
I | |||
1 | |||
I | |||
J | |||
. . . | |||
-13- | |||
The first aid and decontamination weakness observed appears to constitute | |||
the same general deficiency in this area identified during the licensee's | |||
last annual exercise (267/8515-09). The failure to correct this | |||
deficiency is an apparent violation of 10 CFR 50.47(b)(14), which | |||
requires the correction of exercise deficiencies (267/8622-01). The | |||
licensee also identified this deficiency in the post-exercise critique. | |||
No other violations or deviations were identified. | |||
10. Exercise Critique | |||
The NRC inspectors attended the post-exercise critiques by the licensee's | |||
staff on February 26 and 27, 1986, to evaluate the licensee's | |||
identification of deficiencies and weaknesses as required by | |||
10 CFR 50.47(b)(14) and Appendix E of Part 50, paragraph IV.F.5. The | |||
first critique was conducted immediately following the exercise and | |||
included observations from players, controllers, and observers. The | |||
second critique was a debriefing of exercise audit findings by the quality | |||
assurance audit team under the cognizance of the Nuclear Facility Safety | |||
Committee. It was noted that most of the observations by the NRC | |||
inspectors during the exercise were also independe'ntly made and reported | |||
during these critiques. Deficiencies which were identified by both | |||
licensee personnel and NRC inspectors are described in the preceding | |||
sections of this report. Corrective action for identified deficiencies | |||
and weaknesses will be examined during a future NRC inspection. | |||
No violations or deviations were identified. | |||
11. Exit Meeting | |||
The NRC inspector met with licensee representatives (denoted in | |||
paragraph 1) at the conclusion of the inspection'on June 27, 1986. The | |||
NRC inspector summarized the purpose and the scope of the inspection and { | |||
the findings. The NRC inspection team leader stated that although a | |||
number of deficiencies were identified during the exercise,' implementation | |||
of the Plan and procedures in many of the areas observed was improved over | |||
the previous annual exercise, as was the exercise-scenario? The NRC | |||
inspector also stated that the failure to correct deficiencies from the | |||
previous exercise was an apparent violation of NRC requirements and the | |||
; | |||
' | |||
deficiencies identified during this exercise. indicated a lack of effective | |||
demonstration of some of the major exercise objectives. ~~ | |||
# | |||
r | |||
i | |||
l | |||
l | |||
! | |||
. - - . __ - . | |||
}} |
Latest revision as of 08:29, 19 December 2021
ML20210J009 | |
Person / Time | |
---|---|
Site: | Fort Saint Vrain |
Issue date: | 09/17/1986 |
From: | Baird J, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | |
Shared Package | |
ML20210J003 | List: |
References | |
50-267-86-22, NUDOCS 8609260390 | |
Download: ML20210J009 (13) | |
See also: IR 05000267/1986022
Text
. .
APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-267/86-22 License: DPR-34
Docket: 50-267
Licensee: Public Service Company of Colorado (PSC)
P. O. Box 840
Denver, Colorado 80201-0840
Facility Name: Fort St. Vrain Nuclear Generating Station (FSV)
Inspection At: Fort Lupton and Fort St. Vrain, Colorado
Inspection Conducted: August 4-R, 1986
Inspector: O /d MM
J/'B. Baird, NRC Team Leader
T//7/f4
Dat( '
Other Inspectors: C. Hackney, RIV, NRC
W. Bennett, RIV, NRC
D. Perrotti, OIE, NRC
E. Hickey, Pacific Northwest Laboratories
G. Bryan, Comex Corporation
Approved: , ,
'7// 7/86
I L. A. Yandell, Chief, Emergency. Preparedness Date'
and Safeguards Programs Section
Inspection Summary
Inspection Conducted August 4-8, 1986 (Report 50-267/86-22)
Areas Inspected: Routine, announced inspection of the licensee's emergency
response capabilities during the annual exercise.of the emergency plan and
procedures.
Results: Within the emergency response areas inspected, one apparent violation
was identified (paragraphs 3, 4, 6, 8, and 9 - failure to correct deficiencies).
Three emergency preparedness deficiencies were ident,ified by NRC inspectors.
- B609260390 86c?24
G
ADOCK 05000267
_
. .
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DETAILS
.
1. Persons Contacted
Principal Licensee Personnel
- F. Borst, Support Services Manager
- H. Brey, Manager, Nuclear Licensing and Fuels
- 0. Clayton, Technical Services Engineer
- K. Collins, Quality Assurance Technician
- R. Cook, Quality Assurance Technician
- R. Doyle, Quality Assurance Engineer
- D. Evans, Superintendent of Operations
- M. Ferris, Quality Assurance Operations Manager
M. Fisher, Engineer, Special Projects
- J. Fuller, Vice President, Engineering and Planning
- C. Fuller, Station Manager
J. Gahm, Manager, Nuclear Production
- A. Greenwood, Supervisor, Quality Assurance Auditing
J. Hak, Shift Supervisor
- M. Holmes, Nuclear Licensing Manager
A. Horsechief, Health Physics Technician
R. Husted, Supervisor, Nuclear Fuels
- M. Joseph, Technical Advisor
- B. Langsteiner, Quality Assurance Engineer
- 0. Lee, III, Quality Assurance Technician
- W. Ledford, Quality Assurance Engineer
- H. Olson, Member, Nuclear Facility Safety Committee
- D. McCue, Technical Services Engineer
- R. Millison, Technical Services Technician
- F. Novachek, Technical / Administrative Services Manager
- L. Pierce, Manager, Media Relations
- J. Sills, Technical Services Supervisor
- L. Singleton, Manager, Quality Assurance
- G. Toner, Quality Assurance Technician
- R. Walker, Chairman
- D. Warembourg, Manager, Nuclear Engineering
- R. Williams, Jr., Vice President, Nuclear Operations
State of Colorado
- J. Everitt, Division of Disaster Emergency Services
- M. Hanrahan, Department of Health
NRC
- P. Michaud, Resident Inspector
!
,
. - - _ _ _ _ .
. .
-3-
Other Personnel
'
H. Bluder, Stone and Webster
- B. Matheney, Member, Nuclear Facility Safety Committee, NUS
J. Rodell, Stone and Webster
- Denotes thase present at the exit interview.
2. Licensee Action on Previous Inspection Findings
(0 pen) Deficiency (267/8518-01): The NdC inspector noted internal
inconsistencies in the scenario impacted the demonstration of some
exercise objectives (see paragraph 3). This item remains open.
(0 pen) Deficiency (267/8518-02): The NRC inspector noted that controller
weakness in the control room impacted the demonstration of some exercise
objectives (see paragraph 4). This item remains open.
(Closed) Deficiency (267/8518-03): The NRC inspector determined that
adequate habitability checks were made in the control room. This item is
closed.
(Closed) Deficiency (267/8518-04): The NRC inspector determined that
adequate habitability checks were made in the technical support center.
This item is closed.
(Closed) Deficiency (267/8518-05): The NRC inspector determined that
licensee training on information flow had addressed the problems
identified in this deficiency; however, see related deficiency in
paragraph 6. This item is closed.
(Closed) Deficiency (267/8518-06): The NRC inspector noted that exercise
observers did not identify any field monitoring team data record
weaknesses. This item is closed.
(Closed) Deficiency (267/8518-07): The NRC inspector observed
radiological precautions by health physics technician and repair team
members to be adeo,uate. This item is closed.
(Closed) Deficiency (267/8510-08): The NRC' inspector did not observe any
prepositioning of station personnel for accountability. The licensee
created a printout list of personnel inside the protected area and station
personnel were accounted for against the station list. This item is
closed.
(0 pen) Deficiency (267/8518-09): The NRC inspector observed similar
weaknesses in first aid and decontamination during the exercise (see l
paragraph 9). This item is open. '
l l
\ l
1
I
. .
-4-
(0 pen) Deficiency (267/8518-10): The NRC inspector observed similar
weaknesses in command and control of the forward command post during this
exercise (see paragraph 8). This item is open.
3. Exercise Scenario
The PSC exercise scenario was reviewed prior to the exercise to determine
that provisions had been made for the required level of participation by
state and local agencies, and that all major elements of emergency
response would be exercised by PSC in accordance with the requirements of
10 CFR 50.47(b), 10 CFR Part 50, Appendix E, paragraph IV.F, and the
guidance criteria in NUREG-0654,Section II.N.
Comments from this review were transmitted to the scenario coordinator
prior to the inspection date and satisfactory resolution was obtained
prior to the exercise. In general, the scenario was found to be
significantly improved over the previous exercise in internal consistency
and completeness of scenario data and instructions for players and
controllers. However, the NRC inspectors determined during the exercise
that weaknesses in the scenario were still present and impacted the
demonstration of some exercise objectives. Examples of these weaknesses
were as follows:
-
Scenario data indicated higher fuel damage initially than planned for
in the exercise timeline. This caused the control room to initially
select the Alert classification instead of Notice of Unusual
Event (NOVE) as planned. Later, scenario data inadequacies
contributed to a delay in making the Alert classification.
-
No thermal data were provided to permit prestressed concrete reactor
vessel (PCRV) failure risk.
-
Reactor building louvers were opened although peak pressure data was
insufficient to cause opening.
-
Scenario dose assessment data was based upon release option 4
although release option 1 (via the louvers) was appropriate. This
resulted in the re-boot of the dose assessment program and reentry of
data, causing a significant delay in producing dose assessment
projections.
-
The method of providing data-logger information to players was new
and the scenario did not make adequate provisions for training
players to use this data in the same way as they would the
data-logger.
The exercise scenario weakness observed appears to constitute the same
general deficiency in this area that was identified during the last annual
exercise (267/8515-01). The failure to correct this deficiency is
.
.
.
-5-
an apparent violation of 10 CFR 50.47(b)(14), which requires the correction
of exercise deficiencies (267/8622-01). The licensee also identified this
deficiency in the post-exercise critique.
No other violations or deviations were identified.
4. Contr a Room
Initial plant conditions and events of the scenario were provided to
the control room staff at about 7:00 p.m. by the exercise controllers.
The initial event was decreasing core outlet temperatures which could not
be corrected by adjusting the flow orifice control valves, followed by
erratic thermocouple readings. At about 7:30 p.m., a rise in primary
coolant activity was shown and a NOUE was declared at approximately
7:52 p.m. A spurious reactor scram, rise in primary coolant moisture, and
a main steamline rupture with the reactor building louvers open resulted
in the declaration of an Alert at about 8:47 p.m. and a Site Area Emergency
at about 9:05 p.m. A rise in primary coolant radioactivity and the
assessment of offsite dose consequences resulted in the declaration of a
General Emergency at about 12:06 a.m.
During the initial part of the exercise, the NRC inspector noted that
scenario problems (see paragraph 3) were impacting the demonstration
of emergency classification. The controllers in the control room did
not maintain contact with the players and make the necessary
scenario / player action corrections to get the exercise back on the
time line and permit adequate evaluation of control room response.
After a delay of about 30 minutes, one of the lead controllers
informed the control room staff that the scenario required
declaration of a NOVE. The classification problera persisted for the
Alert also. The shift supervisor (SS) consulted with the operations
superintendent by telephone and questions about whether or not the
data given required the declaration of Alert caused this
classification to be delayed until the operations superintendent
arrived at the plant.
The NRC inspector in the control room observed the appropriate use of
emergency implementing procedures (EIPs) for classifying events and
noted that initial notifications to state and local agencies were
made promptly by the SS. No notification was made'for Alert because
a Site Area Emergency was declared about 15 minutes later, preempting
the Alert notification. The subsequent notifications were timely.
It was noted that the SS had to leave the control room often to make
calls and notifications. During the times the SS was out of the
control room it was not clear who was in charge of operations.
In addition, the NRC inspector observed that there was good
communication and interaction in the control room during the
exercise, that the SS was properly relieved by the control raom
director (CRD), and that control room personnel were kept well
informed of events by the CRD as the information became available.
.
~
. .
-6-
'
However, it was noted that communications outside the control room
were weak in that the control room did not know the status of
accountability, if the personnel control center was staffed, or if
the onsite radiation monitoring team had been dispatched.
The control room controller weakness observed appears to constitute
the same general deficiency in this area that was identified during
the last annual exercise (267/8515-02). The failure to correct this
deficiency is an apparent violation of 10 CFR 50.47(b)(14), which requires
the correction of exercise deficiencies (267/8622-01). The licensee also
identified this deficiency in the post-exercise critique.
Based on the above, the following additional item is considered to be
an emergency preparedness deficiency:
Information flow to the control room was deficient in that the
SS 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. (267/8622-02)
The following are observations for the licensee's attention. These
observations are neither violations nor unresolved items. These items are
recommended for licensee consideration for improvement, but they have no
specific regulatory requirement.
-
Provisions should be made for making notifications from the control
room and consideration given to delegation of the calls to a person
other than the SS.
-
Consideration should be given to providing a status board to display
plant conditions and system status for the control room staff.
No other violations or deviations were identified.
5. Personnel Accountability
The NRC inspector noted that personnel were requested to report directly
to their emergency response facilities by the control room following the '
declaration of an Alert class. According to administrative Procedure G-5,
titled " Personnel Emergency Response," Section 4.1, "In the event that an
Alert or higher level classification event occurs, the Technical Support
Center (TSC), Personnel Control Center (PCC) . . . . will be activated
immediately after initial accountability is completed." In addition,
Section 4.4 of Procedure G-5 states that personnel other than operations
and health physics shall report to the lunchroom for initial
accountability. This caused some initial confusion. During the
accountability process all but two persons were accounted for in
approximately 30 minutes; however, two persons could not be accounted for
in the assembly area. It was subsequently determined by the licensee that
the two persons had left the area and were not key carded out of the
-
. .
-7-
.
protected area. The NRC inspector noted that Section 4.'4 of the
accountability procedure did not address what to do on backshifts or
weekends if personnel were missing, who to report missing persons to, or
who would and how to initiate search and rescue. These deficiencies were
also identified by the licensee during the post-exercise critique.
No violations or deviations were identified.
The NRC inspector observed that the technical support center activation
was not timely. The Alert was declared about 8:47 p.m. and the TSC
activation was accomplished at about 10:56 p.m. The NRC inspector noted
that this was in excess of the general goal of 60 minutes stated in
Section 8.2.1 j. of Supplement 1 to NUREG-0737 and the specific goal of
90 minutes authorized for Fort St. Vrain. The deficiency in demonstration
of timely staff augmentation and TSC activation was also identified in the
licensee's post-exercise critique.
After the TSC was activated, the NRC inspector noted that command, control
and communications in the TSC were deficient at times. For example, the
TSC director did not announce taking charge of the TSC when he arrived,
and briefings of TSC staff were infrequent, often incomplete (missing key
players and important information), and hampered by high noise levels
which included that of the TSC air sampler. These deficiencies were also
identified in the licensee's post-exercise critique.
In addition, the initial status board entries were not timely and dose
assessment information flow to the TSC director was slow. No running
accounts of limiting conditions for operations (LCOs) or inoperative
equipment were made. The NRC inspector also noted that, for approximately
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, information unavailability apparently led the TSC staff to
incorrectly believe the release rate had been decreased significantly by.
venting primary coolant to the bottle farm. Additionally, no provisions
were made for displaying the protective action recommendations implemented
by state and local agencies.
The NRC inspector noted that the TSC formulated the General Emergency
classification and directed the control room to announce a General
Emergency at approximately 12:05 a.m., and informed the forward command
post (FCP) of that declaration and protective action recommendations at
about 12:08 a.m. At this time the FCP had been activated and the
corporate emergency director (CED) had been responsible for classification
and protective action decisionmaking for about an hour.
The decisionmaking weakness observed appears to constitute the same
general deficiency in this area identified during the licensee's critique
of the last annual exercise and documented in paragraph 5 of NRC Report
No. 50-267/85-15. The failure to correct this deficiency is an apparent
violation of 10 CFR 50.47(b)(14), which requires the correction of
exercise deficiencies (267/8622-01). The licensee also identified this
deficiency in the post exercise critique.
. .
-8-
The following are observations for the licensee's attention. These
observations are neither violations nor unresolved items. These items are
recommended for licensee consideration for improvement, but they have no
specific regulatory requirement.
-
The Radiological Emergency Response Plan (RERP), Section 6, indicates
the emargency alarm is to be sounded at Alert and all higher
classifications. Procedure RERP-CR stated the alarm is sounded at
Alert, Site Area, and General Emergencies unless previously sounded.
This should be made consistent.
-
RERP-CR and RERP-PHONE lists only one of the four alternate telephone
numbers for the NRC operations center. The additional numbers should
be provided.
-
RERP-TSC, 2.4.2, requires the control room director's concurrence
prior to commanding a data-logger printout of " Alarm Types." This
should be reviewed to determine if concurrence is necessary.
-
Emergency response personnel coming into the plant were delayed at
security awaiting telephone authorization for entry. This practice
should be reviewed to determine if a more efficient procedure can be
provided.
-
A display of protective action recommendations made by the licensee
and actually implemented by offsite authorities should be provided.
No other violations or deviations were identified.
7. Personnel Control Center
The Alert classification was declared at about 8:51 p.m. and the first
person arrived at the PCC at approximately 9:37 p.m. The PCC director
arrived at the PCC at about 9:44 p.m. and most of the other PCC personnel
arrived at approximately 10:06 p.m. The PCC director began conducting a
radiological survey to determine facility habitability and requested that
the emergency implementing procedures be removed from the library and used-
by PCC personnel. The NRC inspector noted that the PCC director did not
announce when the PCC was activated and did not conduct any PCC staff
briefings during the exercise. The emergency director in the control room
made emergency class declarations over the paging system from the control'
room; however, there were areas in the PCC where one could not hear the
announcements. The NRC inspector heard the emergency class announcements
but did not hear the reasons announced for the change in emergency
classes.
The NRC inspector noted that personnel arriving at the PCC assisted in
setting up a system for personnel monitoring and decontamination, and
checked themselves for contamination prior to entering the main PCC work
area. The NRC inspector also noted, however, that two persons went from
the PCC to the TSC without the PCC director checking with the control room
.
. - . -. - -- -
. .
-S-
'
for onsite radiological conditions. At this time, the station emergency
director had previously declared an Alert and there had been a
radiological release.
Telephone and radio communications were established with the TSC and both
were maintained throughout the exercise. The NRC inspector noted that the
offsite radiological monitoring personnel rectived the keys to the offsite
monitoring vehicles and were prepared to depart shortly after PCC
activation; however, the teams were not dispatched in a timely manner.
The exclusion area boundary monitoring (EAB) team was dispatched in
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 38 minutes and the emergency planning zone (EPZ) monitoring team
was dispatched in 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 25 minutes after the declaration of an Alert.
In addition to the slow dispatch, the failure to restart and stalling of
the vehicle for the EPZ team contributed to this problem. This deficiency
was also identified by the licensee during the post exercise critique.
The following are observations for the licensee's attention. These ,
observations are neither violations nor unresolved items. These items are 1
recommended for licensee consideration for improvement, but have no
specific regulatory requirement.
-
Control room, TSC and PCC personnel should be notified when the PCC
is activated.
-
The PCC and alternate PCC should have emergency lighting in the event
of a power failure.
-
Personnel should sign in at the PCC under their functional areas so
that the PCC director is aware of personnel that have arrived. -
-
All personnel should be made aware of plant radiological conditions
prior to departing for the TSC or control room.
-
The public address system in the PCC should be upgraded so that all
,
PCC personnel can hear accident related messages.
-
PCC personnel should receive periodic emergedcy related information
from the PCC director.
No violations or deviations were identified.
i
8. Forward Command Post l
l
The licensee's forward command post, which is the emer9ency operations I
facility, is located in the licensee's Fort Lupton service center '
i
building. The NRC inspector noted that the facility was laid out per
Procedure RERP-FCP, Issu'e 13, as amended by PDR 86-895. The NRC inspector
noted that the FCP was not activated within the 90 minutes time from the
declaration of an Alert (synonymous with the start of the fan-out
notification) as committed to by the licensee. The NRC inspector noted
-
that the CED arrived approximately 90 minutes after the fan-out (AF+90).
1
)
_. - _ _ . . . - . .
.
.
.
-10-
However, at this time no plant status was available from the TSC, so the
FCP remained staffed, but essentially unable to perform its primary
function of command and control of the licensee's emergency response. It
was observed by the NRC inspector that a FCP communicator passed
information on to the TSC that the FCP was fully manned at AF+97.
However, the CED had made no decision on activation at this point. At
AF+120 the TSC and FCP still had not been declared fully operational.
The NRC inspector also noted that Procedure RERP-FCP provides no detailed
instructions for the CED as to when or how the responsibility for command
and control of the emergency response should be transferred from the TSC to
FCP. The initial plant status briefing for the PSC FCP staff was
conducted by the CED. However, from that point on the licensee
demonstrated weaknesses in the command and controi of emergency response
activities, as evidenced by the following examples:
-
The CED attempted a premature activation and announcement of PSC FCP
operability before the condition of the plant was fully known.
-
There was nc, announcement made by the CED to the PSC FCP staff that
the FCP was considered to be activated and fully operational, that
the CED was in charge, and that the responsibility for notifying and
making protective action recommendations (PARS) to offsite
authorities had been transferred from the TSC to FCP.
-
For the most part the station technical liaison (STL) briefed the
staff and appeared to be the decisionmaker for PSC.
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When asked for a protective action recommendation by the state, the
CED was indecisive as to what to recommend. Scenario events finally
overtook this situation when the emergency escalated from a Site Area
Emergency to a General Emergency.
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Press releases were not reviewed and concurred in by the~CED, and
made available to the NRC for review prior to issuance.
During the exercise the NRC inspector noted several instances where
approved procedures were not followed:
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RERP-PAG, Issue 4, specifies that the decision for PARS is.to be-
based, in part, upon plant system parameters. However, at the Site
Area Emergency level no consideration was given to protective actions
based on deteriorating plant conditions (even though an uncontrolled
release was in propress).
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RERP-PAG states that this procedure is to be implemented (i.e.,
protective actions are to be developed) whenever there is an Alert or
higher emergency class event in progress. Howev'er, when the state
requested a PAR (during the Site Area Emergency class) the licensee
failed to provide a PAR.
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RERP-FCP, Issue 13, specifies that data for radiological updates is
to be obtained from, and reviewed by, the radiological assessment
coordinator (RAC) prior to posting. However, the status board keeper
repeatedly posted data announced over the TSC speaker without a prior
review and concurrence by the RAC. At one point this resulted in
confusion as to the status of offsite doses (measured vs. projected).
RERP-FCP states that media relations will provide assistance to the
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FCP public information team in the preparation of news and related
i media releases. However, the media relations personnel informed the
inspector that they had not provided assistance in the preparation of
news releases, but had distributed the releases as they were issued.
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The process used in this exercise precluded concurrence in the
technical content of the news releases by the CED as discussed above.
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Although certain aspects of the physical capability of the FCP appeared to
be substandard and detracted from the exercise, this matter will be
- deferred until the review of the Fort St. Vrain facilities under the NRC's
l program of post-implementation review of the emergency response facilities
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is conducted as discussed in a letter from G. L. Madsen, RIV to 0. R. Lee,
Vice President, Electrical Production, Public Service Company of Colorado
dated August 16, 1983.
The FCP command and control weakness observed appears to constitute the
same general deficiency in this area that was identified during the last
annual exercise (267/8515-10). The failure to correct this deficiency is
an apparent violation of 10 CFR 50.47(b)(14), which requires the correction
of exercise deficiencies (267/8622-01). The licensee also identified this
,
deficiency in the post-exercise critique.
Based on the observations above, the following additional items are
,
considered to be emergency preparedness deficiencies:
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The FCP was not activated and operational in 90 minutes after
declaration of an Alert emergency classification. (267/8622-03)
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Certain provisions of RERP implementing procedures controlling
emergency response activities at the FCP were not followed.
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(267/8622-04)
The following are observations for the licensee's attention. These
observations are neither violations nor unresolved items. These. items are
recommended for licensee consideration for improvement, but have no
specific regulatory requirement.
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RERP-FCP needs revision to provide clear instructions on the transfer
- of command / control from TSC to FCP. ;
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RERP-FCP and RERP-PAG need clarification with regard to the
difference in meaning of protective action recommendations and
protective action guides (PAGs).
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The functions of dose assessment (primary responsibility), control of
field monitoring tean.s and associated activities should be
transferred to the FCP when that facility is declared operational.
The TSC should continue to perform dose assessment as backup-
capability.
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Responsibility for event classification and determination of PARS
should be clarified as to when transfer of these functions is to take
place along with the transfer of the responsibility for notification
of offsite authorities.
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RERP-PAG should be revised to fully conform to IE Information
Notice 83-28 regarding PARS based on plant status.
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Status boards should be reviewed to provide capability for trending,
site evacuation status, to tell new data from old since all
information on the board is not updated at the same time, and posting
protective actions implemented by the state / local agencies.
No other violations or deviations were identified.
9. First Aid and Inplant Radiation Protection
The inplant monitoring and first aid portion of the exercise began at
approximately 9:20 p.m. with a team preparing to enter the reactor
building for valve lineup to depressurize the PCRV. The team was
subsequently dispatched at about 9:40 p.m., followed by one of the
operators falling and simulating the breaking of his leg and becoming
contaminated. The NRC inspector noted that the scenario for the medical
emergency was expected to require search and rescue, but was timed such
that the individual injured was never alone, and therefore never missing.
During this part of the exercise scenario, it was also noted that there
were many uses of the radios without stating that the activity was a
drill.
The NRC inspector noted that the team providing first aid made
radiological surveys, but did not keep a written record of the surveys.
In addition, the injured person was asked to " hop" out without benefit of
a splint being applied to his broken leg. A trauma kit containing a
splint was available, but since the individuals responding were not
qualified emergency medical technicians (EMT's), they did not use the kit.
The NRC inspector also noted that after the injured person was removed to
the health physics control point, his protective clothing was not cut off
to remove the majority of contamination, and to give him relief from the
heat. !
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The NRC inspector noted that the radiological protection by health physics !
technicians and repair team personnel appeared to be adequate.
Anticontamination clothes and respirators were properly used and dosimetry
was checked after leaving the radiation area. l
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The first aid and decontamination weakness observed appears to constitute
the same general deficiency in this area identified during the licensee's
last annual exercise (267/8515-09). The failure to correct this
deficiency is an apparent violation of 10 CFR 50.47(b)(14), which
requires the correction of exercise deficiencies (267/8622-01). The
licensee also identified this deficiency in the post-exercise critique.
No other violations or deviations were identified.
10. Exercise Critique
The NRC inspectors attended the post-exercise critiques by the licensee's
staff on February 26 and 27, 1986, to evaluate the licensee's
identification of deficiencies and weaknesses as required by
10 CFR 50.47(b)(14) and Appendix E of Part 50, paragraph IV.F.5. The
first critique was conducted immediately following the exercise and
included observations from players, controllers, and observers. The
second critique was a debriefing of exercise audit findings by the quality
assurance audit team under the cognizance of the Nuclear Facility Safety
Committee. It was noted that most of the observations by the NRC
inspectors during the exercise were also independe'ntly made and reported
during these critiques. Deficiencies which were identified by both
licensee personnel and NRC inspectors are described in the preceding
sections of this report. Corrective action for identified deficiencies
and weaknesses will be examined during a future NRC inspection.
No violations or deviations were identified.
11. Exit Meeting
The NRC inspector met with licensee representatives (denoted in
paragraph 1) at the conclusion of the inspection'on June 27, 1986. The
NRC inspector summarized the purpose and the scope of the inspection and {
the findings. The NRC inspection team leader stated that although a
number of deficiencies were identified during the exercise,' implementation
of the Plan and procedures in many of the areas observed was improved over
the previous annual exercise, as was the exercise-scenario? The NRC
inspector also stated that the failure to correct deficiencies from the
previous exercise was an apparent violation of NRC requirements and the
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deficiencies identified during this exercise. indicated a lack of effective
demonstration of some of the major exercise objectives. ~~
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