ML20207J766

Emergency Preparedness Insp Rept 50-267/86-15 on 860519-22. Violation Noted:Inadequate Emergency Response Training Program Evidenced by Lack of Records

ML20207J766
Person / Time
Site:	Fort Saint Vrain
Issue date:	07/02/1986
From:	Baird J, Hackney C, Hogan R, Yandell L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20207J759	List: ML20207J754 ML20207J762 ML20207J766
References
RTR-NUREG-0654, RTR-NUREG-654 50-267-86-15, NUDOCS 8607290249
Download: ML20207J766 (11)

See also: IR 05000267/1986015

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APPENDIX B

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

NRC Inspection Report: 50-267/86-15 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 St. Vrain, Colorado

Inspection Conducted: May 19-22, 1986

Inspectors:

J. 3. Baird, Emergenc, P

~ hM \ bbO$iN

aredness Analyst

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rs. 5 and 6)

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C. A. Hackney, Emergency Preparbdness Analyst

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Date

(pars. 3 and 4)

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M ...u d [ Q T I L y._._ ,/,/n,

R. T. Hogan, Emerget Preparedifes Specialist Date

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(pars. d 8)

Approved: Ou '7d/f/,

L. A. Yandell, Chief, Eoergency Preparedness Date '~

and Safeguards Progrisms Section

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Inspection Summary

Inspection Conducted May 19-22, 1986 (Report 50-267/86-15)

Areas' Inspected: Routine, unannounced emergency preparedness inspection in the

areas of emergency, detection and classification, protective action

decisionmaking, dose calculation and assessment, notification and

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communication', public information program, and shift staffing and augmentation.

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Rhsults: Within the emergency response areas inspected, one violation was

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- identified (inadequate' training paragraph 3).

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DETAILS

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- 1. Persons Contacted ~

Principal Licensee Personnel

• F. Borst, Support Services Manager

• 0. Clayton, Technical Services Engineer

• R. Craun, Nuclear Site Engineering Manager, PSC

M. Denniston, Shift Supervisor

D. Evans, Superintendent of Operations

• M. Ferris, Quality Assurance Operations Manager

J. Fuller, Vice President, Engineering and Planning

• C. Fuller, Station Manager

J. Gahm, Manager, Nuclear Production

J. Hak, Shift Supervisor ,

S. Hofstetter, Nuclear Licensing

C. Holland, Lead Security Officer

J. Hunter, Shift Supervisor

• T. McIntire, Supervisor, Nuclear Site Engineering

• F. Novacek, Technical / Administrative Services Manager

W. Peggram, Training Instructor

G. Reeves, Manager Media Services

M. Severts, Director of Media Relations

• L. Singleton, Manager, Quality Assurance

T. Slaby, Document Clerk

C. Stolley, Training Instructor

D. Stuart, Technical Services Engineer

J. Switzer,. Training Support Supervisor

State of Colorado

f **M. Hanrahan, Principal Health Physicist

• • C. Matson, Assistant Director, Radiation Control Division

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NRC

• R. Farrell, Senior Resident Inspector

R. Cooley, Chief, Operator Licensing Section

• J. Pellet, Operator Licensing Examiner

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• Denotes those present at the exit interview.

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• • Telephone contact.

2. Licensee Action on Previous Inspection Findings

! (Closed) Open Item (267/8314-06): The NRC inspectors determined that an

unannounced,-full scale shift and augmentation drill had not been

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conducted to confirm the staff augmentation time estimates. This item is

closed by escalation to an emergency preparedness deficiency (see

paragraph 5 of this report).

3. Emergency Detection and Notification

The NRC inspector reviewed the appropriate sections of the Radiological

Emergency Response Plan, hereafter called the Plan, and the Radiological

Emergency Response Procedures (RERPs) as they related to the emergency

action levels (EALs) and emergency classification. Additionally, the NRC

inspector compared selected EALs from NUREG-0654 to those in the Plan. Of

the EALs selected, the licensee used wording in the RERPs which was

similar to that appearing in NUREG-0654. The NRC inspector also conducted

interviews with seven selected representatives of the licensee's emergency

response team.

Personnel interviewed included three selected shift supervisors, three

technical support center (TSC) directors and one corporate emergency

director (CED). The interviews included discussions concerning previous

training in dose assessment and post Three Mile Island accident radiation

monitoring facilities, EALs, offsite notification, protective action

recommendations, authorities and responsibilities, responsibilities which

could not be delegated, evacuation of nonessential personnel, assignment

of duties, activation of emergency response facilities, NRC notification

and making a protective action recommendation given the EALs and emergency

class. Six of the seven personnel interviewed were able to respond to

most of the questions in a timely manner. Responses to the questions by

the person who may assume the role of CED during an emergency indicated

some weakness in the training for this individual.

The NRC inspectors reviewed training records for the forward command post

(FCP) CED and staff, and determined that seven FCP staff members had

completed retraining and testing on June 6, 1985. However, the licensee

could not oroduce any records for oersons desianated to fill the role of

CED in the emergency organization which showed them having received

initial training or retraining for Module III, which was required by the

Fort St. Vrain TPAM. The failure to provide all required training prior

to-assigning personnel to the emergency preparedness team is an apparent

violation of the training requirements of 10 CFR 50.47(b)(15),

Section 8.1.1 of the Plan and the Fort St. Vrain TPAM. (267/8615-01)

The NRC inspector noted that the Plan referred to emergencies as being

classified into four categories with each category being classified into a

h_igher level of response. The NRC inspector noted during emergency

response training that emergency classes were being discussed as levels

and that most operations personnel were not knowledgeable as to the

difference between EALs and emergency classes. Further, it appeared that

the two terms were used interchangeably and not as they appear in 10 CFR 50,

Appendix E, IV.8 and C.

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During the interviews, the NRC inspector noted that personnel were aware

of notification times for offsite state and local agencies stated in *

10 CFR Part 50; however, the licensee had not updated the Plan or RERPs to

reflect notifying the NRC immediately after state and local agencies, as

stated in 10 CFR 50.72.

Based on the above, the following item is considered to be an emergency

preparedness deficiency:

The Plan and RERPS do not correctly implement the requirements for

notifying the NRC immediately after state or local agencies and within

1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of an emergency classification as stated in 10 CFR 50.72(a)(3).

(267/8615-02)

The following are observations the NRC inspectors called to the licensee's

attention. These observations are neither violations nor unresolved

items. These items were recommended for licensee consideration for

improvement, but have no specific regulatory requirement.

The RERPs appear to be cumbersome and should be reviewed by human

factors engineering personnel to identify changes which should be

implemented to make the procedures " user friendly."

The Plan (section 5.2) and procedures (RERP-CR, 2.1.4, 2.7.1, and

3.1) should be revised to define authorities and responsibilities

which can not be. delegated.

Revise RERPs and personnel training to include defining emergency

action levels as noted in 10 CFR 50, Appendix E, IV.B and the four

' emergency classes as noted in 10 CFR 50, Appendix E, IV.C.

Revise notification procedures to provide a caution note that

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contacting management may be passed over in the procedure if making

_ such contact would impede making the required 15 minute offsite

notifications.

~ Define' EPA Protective Action Guides (PAGs) and protective action

recommendations (PARS) so that emergency response personnel will know

and understand the difference.

Provide a mechanism for certifying that personnel selected to fill

emergency response roles have completed the required training for

that functional role.

Develop a computerized data base which can provide a summary of

training requirements and the status of completion and scheduling of

the training.

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4. Protective Action Decisionmaking

The NRC inspector reviewed appropriate sections of the Plan as it.related

to authorities, responsibilities, and protective action decisionmaking.

The licensee had established a line of succession for overall emergency

response. Following the declaration of an emergency, the shift supervisor

would be in charge of emergency decisionmaking, and that responsibility

would be turned over to the TSC director upon his arrival onsite. The

final transfer would occur upon the arrival of the CED at the forward

command post. The NRC inspector determined by interviews that personnel

were authorized to make offsite protective action recommendations to offsite

agencies. The NRC inspector noted in notification procedure RERP-CR that

the shift supervisor was to call a management contact to jointly confirm

classification. If the emergency classification is an Alert or higher,

station personnel are to be notified and the appropriate personnel control

center (PCC) is selected. Further, a note was inserted that requires that

the state must be notified within 15 minutes after the siren is sounded.

It was noted that 10 CFR 50.72 requires that the state is to be notified

within 15 minutes after ti a emergency has been declared.

The NRC inspector also held interviews with selected individuals'and

discussed onsite protective measures and timely offsite recommendations.

The persons interviewed (with one exception noted above) understood making

timely offsite notifications and protective action recommendations.

Additionally, they were aware of the 15 minute notification requirement'-

for offsite agencies. Personnel were also aware of the relationship of

inplant conditions to offsite consequences. The NRC inspector determined

that most personnel interviewed understood the change of command from the

control room to the TSC and finally to the FCP. Additionally, it was

understood that the licensee would advise the offsite agencies on

protective actions; however, it would be the responsibility of the offsite

agency to make the final decision on protective actions to be implemented

for the public.

No violations or deviations were identified.

5. Shift Staffing and Augmentation

The NRC inspector reviewed the Plan, discussed shift staffing and

augmentation with licensee representatives and reviewed selected personnel

qualification records to determine if the goals and criteria of Table B-1

of NUREG-0654 could be met. A review of two notification fanout procedure

tests was also conducted. In addition, the NRC inspector reviewed

licensee correspondence providing staffing and augmentation commitments to

the NRC, dated August 28, 1980, April 8 and December 7, 1981. These

reviews indicated that the licensee had made adequate provisions for shift

staffing and augmentation to deal with emergencies. However, it was noted

that the licensee's staff augmentation completion times for the 30-minute

and 60-minute categories of Table B-1 of NUREG-0654 were stated in one

goal of 90 minutes to achieve staff augmentation equivalent to Table B-1.

The NRC inspector noted that the augmentation goals committed to were not

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stated in the Plan. The NRC inspector also determined that no unannounced

augmentation drills had been conducted by the time of the inspection.

This area will be reviewed again during a future inspection after an

augmentation drill has been conducted.

The NRC inspector determined that contact of emergency response personnel

needed to augment the onshift staff would be by telephone contact

initially by the on-duty shift supervisor with designated plant

management, who in turn would contact other plant management personnel

having key roles in staffing the emergency response organization. The

callout would proceed by tiers until sufficient staff would be notified to

staff the emergency response facilities communicator. Each of the key

responders, including the plant manager and offsite emergency planning

staff were assigned pagers. The licensee depended on having a number of

personnel qualified and assigned to emergency response positions for

availability to. respond to an augmentation call. The NRC inspector noted

that an emergency response organization telephone book was maintained with

home and work telephone numbers for station and offsite staff. The call

list was updated once per quarter.

Based on the above, the following item is considered to be an emergency

preparedness deficiency:

An unannounced drill has not been conducted to determine if the emergency

staffing augmentation goal commitment can be achieved. (267/8615-03)

The following is an observation the NRC inspectors called to the

licensee's attention. The observation is neither a violation nor an

unresolved item. This item was recommended for licensee consideration for

improvement, but it has no specific regulatory requirement.

Shift staffing and augmentation goals committed to in correspondence

to the NRC should be stated in the Plan.

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No violations or deviations were identified.

6. Dose Calculations and Assessment

The NRC inspector toured the emergency response facilities, examined dose

assessment equipment and procedures, and held discussions with selected

station personnel to determine what provisions the licensee had made for

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dose calculation and assessment during a radiological emergency.

Representatives of the state of Colorado were also contacted to discuss

the state capability and compatibility of dose calculations. This

discussion indicated that the state had experienced good cooperation with

PSC on establishing dose assessment techniques and no significant

compatibility problems had been identified during previous drills and

exercises.

A review of dose assessment procedures showed that the licensee had

provided manual and computerized methods for rapidly performing emergency

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dose projections. The dose assessment techniques were implemented in

procedure RERP-DOSE. The dose assessment methodology included assessment

of both monitored and unmonitored releases. Four methods were provided:

manual calculation, TI-59 programmable calculator, Data Logger computer

and the company IBM-360 mainframe computer. Dose assessment could be

performed in all of the emergency response facilities. The methods

provided were capable of making rapid dose projections as well as

assessing the radiation doses received offsite during the emergency.

The NRC inspector observed demonstrations of the manual, TI-59

programmable calculator and Data Logger Procedures in the FCP, TSC, and

control room. It was determined that the staff selected for the

demonstrations were proficient in use of the procedures and that each of

the dose assessment methods could be performed in a timely manner. The

NRC inspector noted, however, none of the dose assessment methods provided

the capability to incorporate field monitoring data into the assessments

and dose projections.

Based on the above, the following item is considered to be an emergency

preparedness deficiency:

No procedural methods had been provided to incorporate radiological field

monitoring data into dose assessment and projections. (267/8616-04)

No violations or deviations were identified.

7. Notifications and Communications

The NRC inspector reviewed appropriate procedures for notifying and

communicating with offsite agencies during an emergency. The Plan and

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associated RERPs were consistent with 10 CFR 50.72 notification

requirements with the one exception previously noted in paragraph 3. The

requirement states that the licensee shall notify the NRC of an emergency

i:=cdiately after notificatien of the appropriate state and 1 Mal

agencies, and not later than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> after declaration of an emergency.

The NRC inspector noted that several places in the RERP procedures,

including Sections 2.1.3, 2.6.5, and 2.7.7 of Procedure RERP-CR, stated

only that the NRC is to be notified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of declaration of an

emergency.

In addition, the NRC inspector noted a discrepancy in one of the

procedures. Part 50, Appendix E, Section D.3., states that state and

local agencies should be notified within 15 minutes after declaring an

emergency. However, checklist 2 of Procedure RERP-CR, Item Nos.1 and 5

for the emergency coordinator, stated that the notification must be made

within 15 minutes of sounding the plant emergency alarm.

The NRC inspector determined that the licensee had provisions for message

verification by the state and county authorities upon notification.

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Telephone numbers for all licensee and offsite support emergency response

personnel and facilities were listed in the RERP Phone Lists. This

procedure was checked quarterly for accuracy. The NRC inspector noted

that the primary means of alerting and notifying the public in the plume

exposure emergency planning zone (EPZ) is by tone alert radios. The

licensee verified the operability of this system weekly. As a result of

the deficiency in the effectiveness of the system, which was identified by

the Federal Emergency Management Agency during a test conducted August 15,

1984, a siren has been installed in Platteville as a backup alerting

system. Although the installation of the siren in Platteville has<been

completed, the siren was not considered to be operational at the time of

the inspection. A description of the siren as a part of the prompt public

notification system had not been included in the plan and procedures had

not been developed for operability testing.

The NRC inspector reviewed communication links and equipment as described

in the Plan and procedures. The description of communication links in the

Fort St. Vrain RERP was found to be inconsistent with the description in

the Colorado State plan.

The NRC inspector noted that the licensee performs communication drills

periodically and had a mechanism in place to correct any deficiencies

noted. Primary and backup communication links for command centers,

" outside assistance agencies and the visitor center were checked quarterly.

Primary communications links were by commercial telephone lines while

portable radios were used as backups. Portable radios were used between

the TSC and offsite monitoring vehicles. Monthly system checks of the

emergency notification system (ENS), health physics network (HPN) and the

Weld County Communications Center communication links were also performed.

A review of selected records of these tests between April 1985 and

May 1986 verified that repairs and retest were scheduled as necessary.

One communication link from the control room through the security office

and the Weld County Sheriff to the Weld Communication Center was available

as a backup link. The operability of this link was not verified as Dart

of the emergency communication system.

The following are observations the NRC inspectors called to the licensee's

attention. These observations are neither violations nor unresolved

items. These items were recommended for licensee consideration for

improvement, but have no specific regulatory requirement.

A description of the siren system should be included in the Plan when 4

operational and procedures for maintenance and testing should be

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Coordinate with the state on communication links to ensure

descriptions of the links are consistent and understood by both

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Revise checklist 2, RERP-CR, Item Nos. 1 and 5, to be consistent with

the wording in 10 CFR 50, Appendix E, Section D.3.

No violations or deviations were identified.

8. Public Information Program

The NRC inspector reviewed the emergency preparedness information made

available to the public and discussed the public information program with

PSC public information personnel. It was noted that a public information

packet had been prepared and was distributed annually to all residences

and establishments within the EPZ. Appropriate information was included

and updates were prepared as needed. The transient population consists of

agriculture workers who are to be notified by the landowner in case of

emergency. It was noted that information in Spanish was provided in

appropriate locations throughout the EPZ and from the Public Service

District Representative for Platte Valley. Additional information was

available from the visitor's center and a telephone number was supplied

with the annual distribution of public information. Additional

information on emergency preparedness was provided by an annual radio and

newspaper advertising campaign and a newsletter which was distributed

quarterly.

The NRC inspector noted that although the Public information brochure

stated that Weld County officials will alert schools by telephone, there

was no information provided to parents regarding what will happen to their

children if protective actions are implemented. In addition, it was noted

that the brochure directed the public to listen to emergency broadcasts

for specific instructions regarding evacuation. The section entitled

"Where Do I Go" described evacuation routes, but did not include how

, evacuees will determine the specific destination.

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The following are observations the NRC inspectors called to the licensee's

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attentinn. Thaco nhcorvatinne are noithor vinlatinnc nnr unresolved

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items. These items were recommended for licensee consideration for

l improvement, but have no specific regulatory requirement.

The public information brochure should provide information on where

their children will go, how they will be reunited and what the

parents should do.

The public information brochure should specify that the relocation

I center location will be announced on the emergency broadcasts.

Consideration should be given to inserting a statement in Spanish in

the public information mailing to solicit new resident non-English

speaking population information.

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Prior to the next revision of the public information brochure, PSC

should submit a copy to the Federal Emergency Management Agency for .

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review and suggestions.

Nb violations or deviations were identified.

9. ExitIntihview' ,

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The NRC inspecto'rs and NRC senior resident inspector met with licensee

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. representatives'(denoted in paragraph 1) at the conclusion of the,

,' inspection on:May 22, 1986. The NRC inspectors summarized the purpose and

scops70f?ths' inspection, and reported the findings which included three

.deficienci'es in~the. emergency preparedness program.

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