BVY 05-020, Reply to a Notice of Violation; EA-04-173
| ML050670440 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 03/03/2005 |
| From: | Thayer J Entergy Nuclear Northeast, Entergy Nuclear Operations |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| BVY 05-020, EA-04-173 | |
| Download: ML050670440 (6) | |
Text
Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.
Vermont Yankee P.O. Box 0500 Entergy 185 Old Ferry Road Brattleboro, VT 05302-0500 Tel 802 257 5271 March 3, 2005 Docket No. 50-271 License No. DPR-28 BVY 05-020 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001
References:
(a) Letter, USNRC to Entergy, "NRC Emergency Preparedness Program - Vermont Yankee Inspection Report 05000271/2004009; Preliminary White Finding," NVY 04-125, dated November 12, 2004.
(b) Letter, Entergy to USNRC, "Response to NRC Inspection Report 2004-09, Preliminary White Finding," BVY 04-135, dated December 15, 2004.
(c) Letter, USNRC to Entergy, "Final Significance Determination for a White Finding (NRC Inspection Report 05000271/2004009),"
NVY 05-011, dated February 2, 2005
Subject:
Vermont Yankee Nuclear Power Station Reply to a Notice of Violation; EA-04-173 This letter is written in respionse to Reference (c), which documents a finding from an inspection conducted from July 26 to July 30, 2004. The inspection identified a violation of regulatory requirements. As stated in Reference (b), Vermont Yankee (VY) acknowledges that our methods of communication, distribution and maintenance of tone alert radios (TARs) to designated households did not provide for a verifiable accounting method that people in the emergency planning zone had radios or had refused radios.
We have thoroughly investigated the issues surrounding this topic and this letter describes the identified root causes and summarizes the corrective actions to address these causes, as well as additional actions to further strengthen the public notification process. Our response to the cited violation is provided below.
Statement of Violation:
10 CFR 50.54(q) requires a licensee authorized to possess and operate a nuclear power reactor to follow and maintain in effect emergency plans which meet the standards in 10 CFR 50.47(b).
10 CFR 50.47(b)(5) requires in part, that means to provide early notification and clear instruction to the populace within the plume exposure pathway emergency planning zone (EPZ) have been established.
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BVY 05-020 Docket No. 50-271 Page 2 of 5 The Vermont Yankee Emergency Plan, Section 11.2, "Public Notification," refers to Appendix H for details concerning the prompt public notification methods for the Vermont Yankee area. Appendix H describes equipment necessary to alert the public within the Vermont Yankee EPZ as sirens and tone alert radios.
Contrary to the above, as of September 23, 2004, the licensee failed to follow its emergency plan to establish the means to provide early notification and clear instruction to the populace within the plume exposure pathway EPZ. Specifically, a portion of the populace within the EPZ, who are outside of the range of sirens, did not have tone alert radios.
Response
(1) Reason for the violation:
An investigation team was formed to identify the causes for the finding. The team's report was approved and issued on December 13, 2004. The two root causes identified by our investigation team were:
(a) "Lack of a formal process," in that the standards, expectations and requirements for controlling the distribution of TARs were not properly developed (formalized), documented or maintained.
(b) "Lack of Management Oversight," in that management response, ownership, oversight, self-assessments and a questioning attitude were not adequate for ensuring VY's regulatory obligations were met.
(2) Corrective steps that have been taken and the results achieved:
(a) As an immediate measure, the surrounding towns are prepared to implement automatic route alerting to ensure those residents outside of siren coverage, who may not have a TAR, are notified in the event of an emergency.
(b) In September 2004, VY completed a card mailing to all residences in the 10-mile Emergency Planning Zone (EPZ) to obtain requests for new TARs from the EPZ residents. This was a conservative measure since many in the EPZ are within the range of sirens.
(c) In December 2004, VY completed the annual calendar mailing of emergency information to residences in the EPZ. As a result of this mailing and the previously listed card mailing, requests for approximately 1300 TARs were received. VY is in the process of distributing the TARs to all who requested them, with instructions for use. This will be complete by 3/31/05. The instructions contain a toll-free telephone number that can be used to report problems. TARs are activated weekly by the National Weather Service as a test of the system. The tone alert packages will be distributed by receipt confirmation mailing.
BVY 05-020 Docket No. 50-271 Page 3 of 5 (d) VY has met with the town Emergency Management Directors to gain an understanding of the historical and current processes used to maintain and track the households in possession of TARs.
(e) An Off-site Emergency Preparedness Support procedure has been developed that describes the responsibilities of VY, state and town personnel with regard to TARs. This includes the process for the distribution, maintenance and testing of TARs.
(f) The computer database has been updated based on inputs from the postcard/calendar mailings as well as inputs from the town emergency directors. The Off-site Emergency Preparedness Support procedure contains guidance for review and updates to the database.
(g) An Emergency Planning (EP) management re-organization and re-alignment of responsibilities has been completed. An Off-site Program Planner position has been established. Additionally, clarification of roles and responsibilities within the EP department has been completed.
(h) An improvement plan has been developed to resolve the remaining issues identified by the investigation team. Corrective actions are formally tracked in our corrective action program to ensure timely completion.
(3) Corrective steps that will be taken to avoid further violations:
(a) Approximately 1300 TARs will be distributed to residences that requested them. This will be complete by 3/31105.
(b) The Final Analysis Report of the Alert and Notification System (FAR) will be reviewed, updated, revised and submitted to FEMA for review and approval. This will be complete by 3131/05.
(c) Oversight activities are being developed to periodically evaluate the TAR distribution, maintenance and testing process. This will include surveillances, periodic audits, evaluations and performance indicators.
This will be complete by 5/31/05.
(d) VY will perform an annual mailing of a replacement battery to those residents who have accepted a TAR. This will also be used as an opportunity to update residents of the use and testing of the TAR system.
This will be complete by 10/31/05.
(e) The EPZ siren system is being upgraded and enhanced. The upgrade includes replacing all of the existing sirens and associated control components. The upgrades will provide improved reliability of the system, minimize required maintenance, allow for remote equipment monitoring and diagnostic capabilities, conform to the latest applicable standards and provide improved area coverage. System installation is in progress with 20 of 21 new sirens already installed and testing in process.
BVY 05-020 Docket No. 50-271 Page 4 of 5 Installation and final testing will be complete by 6/30/05 and implementation will be in conjunction with EPZ state acceptance. In the meantime, the present system is being maintained fully functional.
(4) Date when full compliance will be achieved:
Subsequent to the determination that a problem existed with the prompt alert notification system, VY in cooperation with the EPZ towns implemented the emergency plan established compensatory measure of Route Alerting and thus re-established compliance.
Full compliance will be achieved by the combination of sirens, route alerting and TARs when the additional TARs are distributed to residences in the EPZ by 3/31/05.
Other actions and enhancements, described in sections 2 and 3, will provide a "defense in depth" approach to our public notification responsibility.
Additionally, to provide a higher level of confidence and assurance in the public notification systems, VY has contracted with a company that supplies high speed telephonic emergency message notifications. A pilot program was implemented during 2004 in one of the EPZ towns and lessons learned have been evaluated. In conjunction with the EPZ states, VY intends to implement an automated telephone notification system that is expected to significantly reduce reliance on TARs. This action will be taken consistent with the existing FAR. Implementation status will be communicated to the Region-1 staff to keep NRC informed of progress on this initiative.
If you have any questions or require any additional information, please contact James M.
DeVincentis at (802)258-4236.
Sincerely, J K. Thayer ite Vice President Vermont Yankee Nuclear Power Station
BVY 05-020 Docket No. 50-271 Page 5 of 5 cc: Mr. Richard B. Ennis, Project Manager Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Mail Stop 0 8 B1 Washington, DC 20555 Mr. Samuel J. Collins Regional Administrator, Region 1 U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 USNRC Resident Inspector Entergy Nuclear Vermont Yankee, LLC P.O. Box 157 Vernon, Vermont 05354 Mr. David O'Brien, Commissioner VT Department of Public Service 112 State Street - Drawer 20 Montpelier, Vermont 05620-2601
ENN NON-QUALITY RELATED ENN-LI-106 Revision 1 NUCLEAR ADMINISTRATIVE Entergy MANAGEMENT MANUAL INFORMATION USE Page 1 of 1 Licensee Identified Commitment Form This form identifies actions discussed in this letter for which Entergy Nuclear Operations, Inc. (Entergy) commits to perform. Any other actions discussed in this submittal are described for the NRC's information and are not commitments.
TYPE (Check one)
SCHEDULED COMMITMENT E m8 COMPLETION DATE
. E . (If Required) t< CE As stated in BVY 05-020, "Full compliance will be X 3131/05 achieved by the combination of sirens, route alerting and TARs when the additional TARs are distributed to residences in the EPZ by 3/31/05."