ML20006A504

Responds to NRC 891218 Ltr Re Weaknesses Noted in Insp Rept 50-267/89-22.Corrective Actions:During Power Operations Three Licensed Reactor Operators Will Be Present in Control & Short in Emergency Public Address Sys Repaired

ML20006A504
Person / Time
Site:	Fort Saint Vrain
Issue date:	01/19/1990
From:	Crawford A PUBLIC SERVICE CO. OF COLORADO
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
P-90011, NUDOCS 9001290044
Download: ML20006A504 (4)

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SUBJECT:

Response to NRCL W%

Inspection Report 89-22

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REFERENCE:

NRC tetter, Collint to Crawford, dated k'N%%7P

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'This; letterDis in rssporse to the 'neaknesses icientified ih the

'inspe: tion conducted- by.;Dr. D. . B. .Spitzberg- during the~ period 1

%)g , / ' s.. Movember 14-16D98) (Inspection 89-22). Thetinspection included the Q&'

xiuplcnsr,tation of thr; emergestcy plan and, precedures during the traval '

MM i, 5 . emergency (response exercise -(FOSAVEX-U9). -No violations Jor.

wo deviations.were identified. There were, however, .several. weaknesses Wl%'

. :ide'ntified in' the course of the inspection.' The;following is ySC's.

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response and schedule of corrective actions. planned for each admitted h;. "

. weakness, asirequested. '

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,, '"The_ diversion early in the emergency of both the STA and SR0 from f'M f:e activities involving evaluation, analysis, and control .of reactor

. emergency. conditions is' considered an exercise weakness."

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~PSC Response:: ,.

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lPSC considers that a misunderstanding cf the Control Room pp(

organization and duties was responsible for this perceived weakness,

' and that' the following explanation will resolve this issue.

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. ' P 90011 January 19, 1990 During power operations, such as the conditions present for FOSAVEX B9, there are three Licensed Reactor Operators (LRO) in the control Room. Two of these LR0s are assigned strictly to plant evaluation, analysis, and control. The third, called a. Directing  !

Reactor Operator (DRO) maintains the administrative and overview ,

functions associated with Control Room activities. One of the administrative functions of the DP0 is to perform the necessary ,

notifications following any non-emergency or emergency event classification. His activities, in no way, interfere with the proper i evaluation, analysis, and control of the reactor and secondary plant.

Following c plant transient, or emergency situation, the Shift i Supervisor responds to the Control Room to assume responsibilities and duties of the Emergency Coordinator. In order to maintain proper supervision of the LR0s assigned to the " boards", by procedure, he  ;

designates someone (in this case the DRO) to perform the necessary notifi:atices followirg an eineri,ency classification, 1 During F001RX-89, once the Operations Panager arrived and assumed the m.ptnsibilities of Emergency Coordinbtor, clong with the arrival of tbc Supecintendent of Operations, there were a total of five Senior Rea: tor Operators present in the Control Room, two of which (one LP0 and the Shif t Supervisor) had no auxiliary functions outside of plant evaluation, analysis, and control of re6ctor emergency conditions.

Based on thest procedures and proceuses. PSC considers that there was never a leek of necessary evaluation, analysis, and control of reactor emergency conditions by a SRO, therefore, no corrective actions are planred.

The Technical Advisor (TA), upon arriving in the Control Room, performs a review of the Data Logger (plant computer) to bring him or herself "up to speed" on the emergency event. Part of this process involves discussion with counterparts in the Technical Support Center (if manned) and filling in an assessment sheet which highlights key plant parameters and conditions. This process, even though it may seem that the TA is distracted from inanediate plant recovery actions, actually allows the TA to become better informed of the events which led up to the emergency situation. With this knowledge, the TA '

then better assist the Control Room staff in evaluation of what tc, <

place and how to mitigate the consecuences. The TA also assists t:,e Control Room staff with technical evaluations of plant systems, responses, etc.

o P-90011 January 19, 1990 Again, PSC believes that this weakness is partially due to a misunderstanding of the Control Room organization, responsibilities and procedures and that this explanation should clarify the situation and as such, resolve this issue. Considering the staffing size of Fort St. Vrain and the present condition of defueling/ decommissioning, no corrective actions are believed necessary or planned for this weakness. .

I 267/8922-02:

"The failure of emergency response teams to adhere to goper health physics practices is considered an exercise weakness."

PSC Response >

The first part of this cbservation refers to the medical response personnel not using protective gloves during the treatment of the injured individual. A thorough critique was held with the members of the medical emergency tecm following FOSAVEX-E9. It is a0 reed that overall, some HP practices should have been more closely adhered to, she Emergency Medical Technician (EMT) who respcnded to this -

p6rticulcr situation was briefed by the Health Physics Technician concerning contamination problems. It was the decision of the EMT, with the concurrence of the Health Physics Technician, that the irduty hed preference over the contaminattun levels reported and the EM7 elected to Administer first aid without the protective gloves, as the gloves niay have irpaired the EMT's ability to perform proper i first aid. In procedure NEP-FSV, Sections 8.4.1 and 8.4.2 do not dictate that protective clothing must be worn to administer first aid. As mentioned, PSC has discussed the observation that closer attention should be given to health physics practices in future responses. No further corrective actions are planned.

The observation by the NRC Inspector of improper use of respiratory protection equipment is acknowledged. The observed individual did don his protective equipment in the wrong sequence. The plant operator donned his Anti-C hood, then his full-face Scott Air Pack.

However, prior to entering the Reactor Building, the Health Physics Technician assigned to that team noticed this error. He took the steps necessary to determine that the plant operator had a sufficient face seal prior to proceeding with their assignment. It was the decision of the Health Physics Technician, based upon the immediate need for the team in the Reactor Building and the fact that the operator had a good face seal, to proceed with the team entering.

Please note that the personnel involved have indicated that the NRC Inspector had left the area following the initial dress-out and was not present for the final equipment check prior to entering the Reactor Building. Therefore, the Inspector did not observe the determination that the face seal was good.

PSC agrees that the operator donned the equipment in the improper sequence. This observation will be added to the 1990 respirator protection training program to ensure personnel are aware of the potential dangers of donning protective equipment in an improper sequence. No further corrective actions are planned.

c; P-90011 January 19, 1990 267/8922-03 l

l "The inadequate volun,e or coverage of the plant public address system was identified as an exercise weakness.*

PSC Response This concern was also identified as an exercise weakness by the PSC evaluation team and was presented as such at the post-exercise critique. PSC has evaluated the problems with the Gai-Tronics systems at Fort St. Vrain. Just prior to FOSAVEX-89, the plant's Gai-Tronics system had developed a short in one of the transmitting l stations. This short caused a hissing noise to be transmitted over the entire system. This was considered to be irritating in several office and work areas. Even though PSC does not condone turning down the volume of Gai-Tronics speakers, this does cccur on occasior,. Tile Main Warehouse was investigated after FOSAVEX-89 and was found to have the volute turned low. The NRC tbsident Ir.spector hes infoiued i s that his speaker is working properly. The shott in the system was repaired end the irritating hissing no'se has ceased. Gai-Trunics speaters have been returned to fully operational stetus. A memo from executivo menor ment will be issued to all Nuclear Operstions personnet emphas1 ring the importance of maint ain'ing proper Gai-Tronics coverage. A'Juitionally, es the plant de-staffing contir.ue9, the background noise from personnel in all plant areas will decrea';e . No further corrt.ctive actions are planned. >

If you have any questions or comments associated with this inspectiun response, please call Mr. M. H. Holmes at (*303) 400-6960.

Sincerely, CL 6 by Yt A. C. Crawford Vice President Nuclear Operations ACC/0JC/tk cc: Regional Administrator, Region IV ATTN: Mr. T. F. Westerman Chief Projects Section B (2 copies)

Mr. R. E. Farrell Senior Resident Inspector Fort St. Vrain Mr. Rick Hatten, Director Division of Disaster Emergency Services State of Colorado