IR 05000029/1981020
| ML20055B473 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 06/30/1982 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Tribble J YANKEE ATOMIC ELECTRIC CO. |
| Shared Package | |
| ML20055B474 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8207220405 | |
| Download: ML20055B473 (33) | |
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JUN 3 01982 Docket No. 50-29 Yankee Atomic Electric Company ATTN:
J. E. Tribble, President 1671 Worcester Road Framingham, Massachusetts 01701 Gentlemen:
Subject:
EMERGENCY PREPAREDNESS APPRAISAL (50-29/81-20)
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To verify that licensee's have attained an adequate state of onsite emergency preparedness, the Office of Inspection and Enforcement is conducting a special appraisal at each power reactor site. The objectives of the appraisal at each facility is to evaluate the overall adequacy and effectiveness of emergency preparedness and to identify areas of weakness that need to be strengthened.-
We will use the findings from these appraisals as a basis not only for requesting individual licensee action to correct deficiencies and effect improvements, but also for effecting improvements in NRC requirements and guidance.
During the period of December 1-9, 1981, the NRC conducted an appraisal of the emergency preparedness program at the Yankee Nuclear Power Station. Areas examined during this appraisal are described in the enclosed report (50-29/81-20).
Within these areas, the appraisal team reviewed selected procedures and represen-tative records, inspected emergency facilities and equipment, observed work practices and interviewed personnel.
The findings of this emergency preparedness appraisal indicate that certain corrective actions are required in your emergency preparedness program. These are discussed in Appendix A, "Significant Emergency Preparedness Findings."
Significant findings for which you have made acceptable commitments to resolve were discussed in the Confirmatory Action Letter dated February 25, 1982, a copy of which is enclosed for your convenience.
These findings are included in Appendix A.
Other areas needing improvement are discussed in Appendix B, " Emergency Pre-paredne.ss Improvement Items."
In conjunction with the aforementioned appraisal, emergency plans for your facility were reviewed by the Emergency Preparedness Licensing Branch, Division of Emergency Preparedness, Office of Inspection and Enforcement. The results of this review indicate that certain deficiencies exist in your emergency plan. These are discussed in Appendix C, " Emergency Plan Evaluation Report".
Appendices A, B, and C of this letter contain an inclusive listing of all g
outstanding emergency preparedness items at your facility at this time.
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JUN 3 01332 We recognize that an explicit regulatory requirement pertaining to each item identified in Appendices A, B and C may not currently exist. Notwithstanding this, you are requested to submit a written statement within thirty (30) days of the date of this letter, describing your planned actions for improving each of the items identified in Appendix A and the results of your consideration of each of the items in Appendix B.
This description shall include:
(1) actions which have been taken; (2) actions which will be taken; and (3) a schedule for completion of actions for each item. This request is made pursuant to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
You are further requested to provide to this office, within 120 days of the date of this letter, page changes to your Emergency Plan correcting each deficiency identified in Appendix C or provide written justification as to why you believe a revision should not be made. Copies of these changes are to be submitted in accordance with the procedures delineated in 10 CFR 50.54(q) and 10 CFR Part 50, Appendix E(V).
The items requiring correction in our Confirmatory Action Letter of February 25, 1982, have been subdivided into related findings in Appendix A.
This is to inform you that if there are any remaining Appendix A items which are not corrected within 120 days from tne date of this letter, the Nuclear Regulatory Commission will determine whether enforcement action is aopropriate.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold information contained therein within thirty days of the date of this letter.
Such application must be consistent with the require-ments of 2.790(b)(1). The telephone notification of your intent to request withholding, or any request for an extension of the 10 day period which you believe necessary, should be made to the Supervisor, Files, Mail and Records, USNRC Region I, at (215) 337-5223.
The reporting requirements contained in this letter affect fewer than ten (10)
persons and are, therefore, not subject to Office of Management and Budget clearances as required by PL 96-511.
Should you have any questions concerning this inspection, we will be pleased to discuss them with you.
Should you have any questions concerning the items of Appendix C, please contact Mr. R. Van Niel Emergency Preparedness Licensing Branch at (301) 492-4535.
Sincerely, Gjgg L. fMW&
George H. Smith
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Director, Division of Emergency
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Preparedness and Operational Support OFFICIAL RECORD COPY
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Yankee Rowe EP Appraisal
June 30, 1982 Attachments:
1.
Appendix A, Significant Emergency Preparedness Findings 2.
Appendix B, Emergency Preparedness Improvement Items 3.
Appendix C.. Emergency Plan Evaluation Report 4.
NRC Region I Inspection Report No. 50-29/81-20 5.
Ltr to Yankee Atomic Electric Company dated February 25, 1982 cc w/ enc 1:
H. Autio, Plant Superintendent J. E. Tribble, President Public Document Room (PDR)
Local Public Document Room (LPDR) (NSIC)
Nuclear 56fety Information Center Commonwealth of Massachusetts (2)
NRC Resident Inspector bec w/ encl:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encis)
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APPENDIX A Significant Emergency Preparedness indings Based on the results of NRC's appraisal of the Yankee Nuclear Power Station Emergency Preparedness Program conducted December 1-9, 1981, the following improvements are required:
(References are to sections in the NRC Region I Inspection Report No. 50-29/81-20.)
1.
Perform a study to determine how the intent of the augmentation goals of NUREG-0654, can be achieved after the declaration of an emergency.
(See Section 2.1)
2.
Modify the post-accident sampling systems as required to ensure that coolant samples can be collected within the exposure limits of NUREG-0737.
(See Section 4.1.1.5)
3.
Modify the post-accident containment sampling system as required to ensure that samples of the containment atmosphere can be collected within the exposure limits of NUREG-0737.
(See Section 4.1.1.6)
4.
Modify the stack effluent sampling system as required to ensure that samples can be collected within the exposure limits of NUREG-0737.
(See Section 4.1.1.7)
5.
Evaluate the need for:
retention, transfer, storage, sampling and analysis of highly radioactive wastes that could be generated as a result of severe accidents.
(See Section 4.1.1.8)
6.
Conduct a study to identify expanded support facilities required to process, train, and shelter incoming support personnel.
(See Section 4.1.3)
7.
Provide backup means for obtaining estimates of high-range PVS noble gas and main steam line releases during severe accidents.
(See Section 4.2.1.2)
8.
Ensure that State / local officials have the capability to make prompt protective action decisions, (e.g., evacuation), and that they can promptly activate the public alerting system and provide public instruction and direction once a decision has been made.
(See Section 4.2.3.1)
9.
Review Implementing Instructions to ensure that they contain specific references to other procedures needed to perform specific actions.
(See Section 5.1)
10.
Revise procedure OP-3310, " Evaluation of Radiological Data" to clearly indicate when each part of the procedure is to be implemented and who will be responsible for its implementation.
(See Section 5.1)
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Appendix A
11. Revise the procedures containing EALS to adequately address the require-ments of NUREG-0654, Appendix 1.
(See Section 5.3)
12. Hold a meeting between NRC, FEMA and State officials responsible for protective action decision making.
The purpose of the meeting is to discuss protective action recommendations; to develop assurance that the licensee can make protective action recommendations; and to demonstrate that the State officials have the capability to make a public notification decision promptly on being informed by the licensee of an emergency condition.
(See Section 5.4.1)
13.
Revise procedure OP-3310 to incorporate means to compensate for the potential uncertainty associated with plume trajectories.
(See Section 5.4.2)
14. Write a procedure and implement for estimating noble gas, radioiodine and particulate releases from the PVS under major accident conditions. (See Section 5.4.2)
15. Conduct a study to determine the maximum radioactive concentrations of post-accident liquid wastes that could be sampled, the need for special sampling equipment, and shielding, and make any improvements as necessary.
(See Section 5.4.2.7)
16. Develop an overall procedure addressing recovery and reentry which includes the need to evaluate operational and radiological conditions prior to entering the recovery phase.
(See Section 5.4.6)
17. Develop a comprehensive and objective audit program to evaluate all emergency preparedness areas.
(See Section 5.5.4)
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e APPENDIX B Emergency Preparedness Improvement Items Based on the results of NRC's appraisal of the Yankee Nuclear Power Station Emergency Preparedness Program conducted December 1-9, 1981, the following should be considered for improvement:
(References are to sections in the NRC Region I Inspection Report No. 50-29/81-20.)
1.
Assign an individual to the position of onsite EPC.
(See Section 1.0)
2.
Provide, administrative mechanisms for the EPC to have direct access to the Plant Superintendent as needed for resolving emergency planning issues.
(See Section 1.0)
3.
Describe when and how emergency functions (e.g., making protective action recommendations) are transferred to the Recovery Manager. This should include the notification of selected personnel concerning the transfer of authority.
(See Section 2.2)
4.
Provide training to employees on emergency radiation protection considera-tions due to the unshielded containment.
(See Section 3.1)
5.
Complete the training of all individuals assigned emergency functions.
(See Section 3.2)
6.
Complete the installation of the HEPA filters in the Control Room Complex.
(See Section 4.1.1.1)
7.
Limit the number of individuals to the Control Room complex, or provide a mechanism to prevent them from interfering with control room operators during emergencies.
(See Section 4.1.1.1)
8.
Provide backup voice communication links between the OSC, Control Room, and the TSC.
(See Section 4.1.1.3)
9.
Modify the Emergency Plan to reflect the proper location of the OSC.
(See Section 4.1.1.3)
10.
Provide remote assembly and reassembly areas.
(See Section 4.1.2.1)
11.
Improve radio communications between the hospital and ambulance.
(See Section 4.1.2.2)
12. Provide means for ensuring the availability of emergency decontamination kits.
(See Section 4.1.2.3)
13. Provide security for the News Center.
(See Section 4.1.4)
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Appendix B
14.
Include high range survey instruments in reentry team kits; provide additional instruments at the E0F for monitoring personnel; and a method of protecting the offsite air sample monitors from inclement weather (e.g., rain, snow).
(See Section 4.2.1.1)
15. Assure that calibration procedures for area and process monitors are finalized and that installation of the containment main steam iine and high-range PVS monitors is completed.
(See Section 4.2.1.2)
16.
Establish a substantiated alternate data source of meteorological information during accidents.
(See Section 4.2.1.4)
17.
Include OSC N otective clothing supplies in the Control Room supplies checklist.
(See Section 4.2.2.2)
18.
Provide means to ensure higher reliability of the Nuclear Alert System.
(See Section 4.2.3)
19.
Provide an operational backup radio system for communicating with the monitoring teams that will have sufficient range to cover the plume EPZ.
(See Section 4.2.3)
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Provide an adequate location for the retrieval of repair / corrective action tools, supplies and equipment that may be needed during severe
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(See Section 4.2.4)
21.
Review Control Room emergency alarm, abnormal occurrence procedures to identify and direct emergency classification whenever possible, and to ensure that all references are maintained current.
(See Section 5.2)
22.
Revise the event classification procedure to remove redundant listing of EALs.
(See Section 5.3)
23.
Provide the control room with a flow chart to allow for prompt classifica-tion of emergencies.
(See Section 5.3)
24.
Revise implementing instructions to reference the call-list contained in OP-MEMO 2E-5.
(See Section 5.4.1)
25. Keep the NaI detector system (SAM-2 RD-22) power on to eliminate any warm-up time.
(See Section 5.4.2)
26. Revise procedure OP-3311 to:
specify means for sample disposition (e.g.,
responsibilities, coordination, logistics); specify alternate means of communication; and provide monitoring techniques for ascertaining sampling locations relative to the plume.
(See Section 5.4.2.1)
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Appendix B
27.
Revise a procedure OP-3300 to include:
equipment, survey forms, communica-tion methods, and radiation protection guidance.
In addition, provide diagrams showing expected doses in selected areas (e.g., motor control areas, OSC), as a function of the Accident Area Radiation Monitor levels.
(See Section 5.4.2.3)
28.
Revise procedure OP-9450 to:
identify the manner in which samples are to be transported to the laboratory and the precautions appropriate during such transport; provide a schematic of valve line-up and indicate the need for a timely relay of results to personnel in charge of making protective action recommendations.
(See Section 5.4.2.5)
29.
Revise procedures OP-8740 and OP-8741 to:
identify the transporting devices for PVS iodine and particulate samples; specify the means of quantifying activity on the charcoal and particulate filters; address handling problems assoicated with highly radioactive particulate and charcoal filters; specify criteria for aborting taking the sample based on information available in the Control Room (e.g., AARM levels), and specify locations for quantifying noble gas releases due to steam generator tube failure.
(See Section 5.4.2.6)
30.
Review OP-3300 and OP-8700 to include guidance on accident dose rates resulting from the unshielded containment.
(See Section 5.4.3.1)
31. Clarify responsibility to authorize the use of KI for all shifts.
(See Section 5.4.3.1)
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Develop a procedure for immediate evacuation of nonessential personnel to a predetermined remote location and include instructions in the call-up
procedures to direct augmentation personnel to these remote assembly areas.
(See Section 5.4.3.2)
33.
Revise OP-3344 to account for individuals who may be at the Training j
Center during site evacuation, and identify individuals responsible for accounting evacuees at the Boiler Feed Pump Room.
(See Section 5.4.3.3)
l 34.
Describe the location to be used for retrieving repair / corrective action tools / supplies and other equipment that may be needed during severe accidents.
(See Section 5.4.5)
35.
Revise procedure OP-3341 to include a quarterly communication test with the ingestion EPZ states, post-accident sampling drills, and backshift j
drills.
(See Section 5.5.2)
36.
Develop means for verifying and updating emergency phone numbers found in procedures and call lists on a quarterly basis. (See Section 5.5.3)
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37. Complete the distribution of site specific public information and provide a copy to the NRC of the information when distributed.
This should include information for posting for the transient populations.
(See Section 6.2)
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Revise OP-3340 to make provisions to document the training received by members of the news media.
(See Section 6.3)
39. Conduct the required semiannual health physics drill.
(See Section 7.1)
40.
Test the aspects of message content and understanding during communications drills.
(See Section 7.1)
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APPENDIX C
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EMERGENCY PREPAREDNESS EVALUATION REPORT
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DIVISION OF EMERGENCY PREPAREDNESS OFFICE OF INSPECTION AND ENFORCEMENT U.S. NUCLEAR REGULATORY COMMISSION
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YANKEE NUCLEAR POWER STATION DOCKET NO. 5029 N
APRIL 1982
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INTRODUCTION Yankee Atomic Electric Company filed with the Nuclear Regulatory Commission the Yankee Rowe Emergency Plan dated April 1, 1982.
The plan was reviewed against the requirements in Section 50.47 of 10 CFR Part 50, the requirements in Appendix E to 10 CFR Part 50, and the guidance of Regulatory Guide 1.101, Revision 2, October 1981.
This evaluation report follows the format of Part II of NUREG-0654 in that each of the Planning Standard titles are listed and followed by a summary of the applicable portions of the plan and the deficiencies that relate to that specific standard.
The final section of this report provides our conclusions.
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EVALUATION A.
ASSIGNMENT OF RESPONSIBILITY (ORGANIZATIONAL CONTROL)
Emergency Plan:
The Federal, State, and local organizations that are intended to be part of the overall response organization for Emergency Planning Zones are identified. The roles of the States of Vermont and Massachusetts are described by reference to the appropriate State plans.
The concept of operations and its relationship to the total effort is described and a block diagram which shows the interfaces between and among the principal licensee response organizations is provided.
The Plant Emergency Director is the individual who is in charge of the emergency response onsite.
The Shift Supervisor acts as the Plant Emergency-Director.
The Plant Emergency Director reports to the Recovery Manager, who is a corporate (Nuclear Services Division) Vice President stationed at the Emergency Operations Facility (EOF) during a serious emergency.
Certain written agreements referring to the concept of operations developed
between Federal, State, and local support organizations having an emergency response role within the Emergency Planning Zones (EPZs) are provided.
Organizations included are: Rowe & Monroe Fire Department, Peter Bent Brigham Hospital, Williamstown Medical Associates, North Adams Regional Hospital, and Department of the Air Force Westover Air Force Base.
The licensee is capable of continuous (24-hour) operations for a protracted period. The individual responsible for assuring continuity of resources is the Manpower Assistant.
DEFICIENCIES:
The Plan requires revision and/or additional information as follows:
1.
Individuals at the State and local level responsible for making protective action recommendations should be identified.
2.
The offsite interface for each organization and sub-organization should be clearly indicated for the following:
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(a) protective action decision making, (b) coordinating of monitoring results, and (c) coordinating onsite and offsite evacuation.
This should include a block diagram that shows these interfaces with onsite centers.
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All of the steps required to implement protective action decisions should be clearly specified.
4.
Copies of the final State and local plans should be provided in accordance with 10 CFR 50.47. This should include that portion of the NY plan dealing with the ingestion pathway protective response.
5.
Copies of letters of acreement with Charlemont Ambulance Service, and New England Power Company should be provided.
6.
All agreements should be reviewed and certified as current.
7.
Provide a map showing the exact plume EPZ boundary in relationship to the factors specified in Section 50.47(c)(2) of 10 CFR 50.
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B.
ONSITE EMERGENCY ORGANIZATION Emergency Plan The onsite emergency organization structure for all shifts is specified.
- The Plant Emergency Director is on shift at all times and has the required authority and responsibility to immediately initiate any emergency actions.
- A line of succession from the Plant Emergency Director to higher level utility officials is described and the functional responsibilities of the Plant Emergency Director are established.
- The normal positions or titles, and major tasks to be performed by the persons assigned to the emergency management functional areas are specified.
Corporate administrative and technical support and personnel are provided through the Nuclear Services Division (NS0), Emergency Support Center (ESC) in Westboro, Massachusetts.
Emergency support personnel are assigned by the Manpower Assistant; tech-nical support is provided by the Technical Support Center Coordinator; interface with Federal Government authorities is provided via the Federal Master Plan; and release of information to the news media is provided by the Public Information Representative.
The contractor (s) and private organizations who may be requested to provide technical assistance and augmentation of the emergency organization are listed. Organizations listed include INPO and the Yankee Mutual Assistance Organization.
The services to be provided by local agencies for handling emergencies, including firefig:-*ng and medical services, are identified.
Copies of agreements are appended to the plan.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
The relationship between the working level emergency organization and the normal plant staff should be specified.
2.
Upon arrival of the Recovery Manager there is a transfer of responsibility from the Plant Emergency Director to the Recovery Manager.
However, the criteria for this transfer of responsibility should be clearly indicated to all appropriate officials (onsite offsite) to facilitate the smooth transfer of the overall responsibility for the direction and control of the integrated emergency response effort. Also, the licensee should
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6-specify which responsibilities assigned to the Emergency Director may not.
.be delegated to other elements of the emergency organizations.
The transfer of emergency response functions from the control room to the TSC and EOF should be in accordance with that specified in NUREG-0696.
3.
The minimum staffing _ requirements are deficient with respect to the guidance set forth in Table B-1 of NUREG-0654.
Provide the additional information requirad in the March 9, 1982 letter from Dennis M. Crutchfield NRC/NRR to James A. Kay, Senior EngineerLicensing, YAE *
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C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES Emergency Plan:
i The NRC will be notified through the direction of the Plant Emergency Di-
rector and the NRC will then implement the Master Federal Plan.
- Each principal offsite organization may dispatch representatives to the licensee's nearsite E0F.
- Radiological laboratories identified include Yankee Nuclear Services Division Mobile Environmental lab which can respond to the site in about 2 or 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and labs at other nuclear power plants designated through the Yankee Mutual Assistance Plan (Vermont Yankee, Maine Yankee).
DEFICIENCY:
The plan requires revision and/or additional information as follows:
1.
-The plan indicates that there are provisions to incorporate Federal re-sponse capabilities into the Yankee Rowe emergency plan.
This section should be expanded to include information requested in NUREG-0654, criteria C.1.a, C.1.b, C.1.c, and C.2.b.
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EMERGENCY CLASSIFICATION SYSTEM Emergency Plan:
An emergency classification and emergency action scheme compatible with the scheme in Appendix 1 of NUREG-0654 has been established. Under core melt accident conditions the shine from unshielded containment (Vapor Container (VC) would prevent access to most site areas. Therefore, the General Emergency EALs at this site must be revised to insure that emergency actions are initiated in time to allow for taking corrective actions.
The emergency action levels in the plan addressed most example initiating conditions listed in Appendix 1 of NUREG-0654, as well as the postulated accidents in the F5AR. However, in some cases they did not address the initiating conditions adequately.
DEFICIENCY:
1.
Revise the EALs as discussed in Section 5.3.1 of the Emergency Preparedness Appraisal Report No. 50-29/812.
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4 E.
NOTIFICATION METHODS AND PROCEDURES Emergency Plan:
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Procedures and means for notification of response organizations, are
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Procedures for alerting, notifying, and mobilizing emergency response personnel by emergency class are established.
The initial information to be supplied to the Department of Public Health of Vermont and Massachusetts is specified, f
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The initial notification is made within 15 minutes of emergency classifi-cation to the Vermont and Massachusetts State Police.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Discuss means for verifying the initf al messages.
2.
Section 9.2.1 states that a radiopaging system and activation of call lists will be used to alert, notify, and mobilize emergency response personnel. However, as noted during the Emergency Preparedness appraisal, there have been no drills to evaluate response to call list activation (i.e., the system is untried and may not work).
Provide for an annual
test of the off-duty personnel call in system.
3.
Provide sample formats for the initial and followup messages which should include the information specified in criterion E.4 of NUREG-0654.
4.
Provide a complete description of the administrative and physical means for prompt alerting and notification of the public within the plume EPZ in sufficient detail to allow for evaluation against the criteria set forth in Appendix 3 of NUREG-0654.
s 5.
Provide sample formats of written messages intended for release to the public in the event of a serious emergency.
These messages should cover such items as stated in Criterion E.7 of NUREG-0654.
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EMERGENCY COMMUNICATIONS Emergency Plan Communications with Federal emergency response organizations are provided.
- Communications, that are not vulnerable to loss of normal power or over-loading, are provided between the licensee emergency centers, State E0C's, State Police and radiological monitoring teams.
- Communications between the licensee and NRC headquarters and the NRC Regional Office are provided.
A page system combined with a call fan-out system is used to activate the site emergency organization.
DEFICIENCIES The plan requires revision and/or additional information as follows:
1.
Specify the organizationi titles and alternates for both ends of the communication links which would be involved in initiating emergency re-sponse actions, and to indicate that such' stations will be manned 24-hours per day and provided with the appropriate communications backups. (i.e.,
delineate all the steps followed from the initial notification of the State Police to activation of the public warning system and providing public information messages on a range of protective actions).
2.
Provide a coordinated communication link for fixed and mobile medical support facilities.
3.
Provide communication between the EOF and local E0C.
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G.
PUBLIC EDUCATION AND INFORMATION Emergency Plan:
The Shelburne Falls area is indicated as the site to be used by the news media during an emergency.
The Public Information Representative is designated as the principal spokesperson during a crisis.
Annual coordinated programs will be established to acquaint news media representatives with the licensee's emergency plans, information concerning radiation, and points of contact for release of public information in an
emer gency.
The States of Vermont and Massachusetts have developed brochures that contain general information on radiation and nuclear power plant accidents.
DEFICIENCIES:
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The plan requires revision and/or additional information as follows:
1.
Provide sufficient information to demonstrate compliance with the guidance of Criterion G.1 and G.2 of NUREG-0654 (i.e., an example of the information to be transmitted annually to the public, explaining the rational for 4.
protective actions).
Commit that information will be destributed on an
annual basis.
2.
Provide for annual dissemination of information to transients within the j
plume EPZ.
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Designate specific points of contact and physical locations for use by
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the media during an emergency.
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Provide space for a limited number of news media representatives at the nearsite EOF.
5.
Indicate how the exchange of information will be coordinated between the
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organizations. Also, there should be coordinated arrangements for dealing with rumors.
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H.
EMERGENCY FACILITIES AND EQUIPMENT Emergency Plan:
Arrangements have been made to acquire laboratory services from offsite sources with capabilities to count environmental and high level samples.
The li:ensee's interim EOF, which is located in a frame house just beyond the plant entrance, is the central point for receipt and coordination of sample media, analysis of field monitoring data and interface with offsite officials. An alternate EOF is provided about 12 miles from the site.
The licensee's TSC is located adjacent to the Control Room and is habitable to the same degree and has the capability to monitor various plant parameters.
It will serve as the main communcations link with the Control Room and from here post-accident evaluation will be directed.
l The OSC was located in the turbine hall, with the Control Room foyer as a backup.
This is not as stated in the Plan.
Provisions have been made to inventory, inspect, and operationally check emergency equipment / instruments each quarter and after each use. There are sufficient reserves to replace equipment / instruments removed for calibration or repair.
Calibration is performed according to supplier recoramendations.
The Technical Support Center (TSC), Operational Support Center (OSC),
Emergency Operation Center (EOF), Engineering Support Center (ESC), and Media Center will be activated for Alerts, Site Area and General Emergencies.
Contents of emergency kits are identified in Appendix B of the plan.
The licensee meteorological capabilities address the criteria set forth
.in Appendix 2 of NUREG-0654 by adopting the interim compensatory measures to Milestone 3.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
The plan appears only to address the TSC and interim EOF. The licensee's plan does not contain enough information to allow for an evaluation of the EOF, TSC and OSC against NUREG-0696.
The licensee has submitted additional information on these facilities by letter and this is undergoing review; however, the plan must be expanded to fully describe the TSC, OSC and EOF to include a schedule for full operation of the final centers.
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2.
Specify the time required to achieve operational readiness of the emergency response facilities.
Reference should be made to the fact that depending on the extent of core damage, the EOF may be activated first due to the shine from the Vapor Container.
3.
Identify the onsite radiological and process monitoring systems in accordance with criteria H.5.a.& b of NUREG-0654 to include instrument identification, ilocation, and range.
The monitors identified should include those used for obtaining Emergency Action Levels for the appropriate initiating conditions listed in Appendix 1 of NUREG-0654.
4.
Include provisions for obtaining offsite information regarding geophysical phenomena as specified in criterion H.6.a of NUREG-0654.
5.
The plan refers to Table 92 for manning of the EOF, TSC and OSC but the table was not provided in the plan.
6.
Provide sufficient information to establish that there is offsite dosimetry capability and that it will meet the requirements of the NRC Radiological Assessment Branch Technical Position for the Environmental Radiological Monitoring Program.
7.
The analysis of the interim meteorological measurement system against criteria in Appendix 2 of NUREG-0654 is covered in Section 4.2.1.4 of the Emergency Preparedness Appraisal report No. 50-29/8120.
However, the plan must be revised to address the long term measures described in Appendix 2 of NUREG-0654, to include a schedule for full operational capability and how the influence of the valley and changes to meteorological conditions will be considered.
8.
The OSC is inadequate in that it is an unshielded two tier set of rooms which will be uninhabitable due to Vapor Container shine. Consider relocating the OSC to provide better habitability.
9.
Explain how offsite monitoring results will be coordinated with offsite officials in accordance with NUREG-0654, criterion H.1.
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ACCIDENT ASSESSMENT
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Emergency Plan:
The licensee has identified and established emergency procedures based on plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents and has identified the plant parameter values, etc. which correspond to NUREG-0654, Appendix 1 example initiating conditions.
The methods and techniques for determining the radioactive release source terms based on plant system parameters and effluent monitors are addressed.
There are provisions to relate releases to plume center line whole body dose rates out to 10 miles under various stability classes and wind speeds.
Dose rates will be compared to the EPA PAGs by offsite officials.
- Depending on the extent of core damage, Vapor Container shine could preclude taking any post-accident samples.
DEFICIENCIES:
a The plan requires revision and/or additional information as follows:
1.
Delineate the methods and techniques used in post-accident sampling. This
,
additional information should encompass the guidance material given in NUREG-0737, Items II.B.3, II.F.1, and III.D.3.3.
2.
Provide for immediately estimating the distance from the site to which the EPA PAGs may be exceeded (not only to 10 miles).
This should include default release durations for integrating dose rates.
3.
Provide a means for determining release rate (s)/ projected dose (s) if the instrumentation used for assessment is offscale or inoperable.
i 4.
Elaborate on the capability and resource for field monitoring within the plume EPZ. This section should also specify the estimated deployment times and the means of transportation for offsite radiological assessment
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l of liquid or gaseous releases.
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5.
Provide more detailed information concerning the methodology for detecting airborne radiciodine concentrations within the plume EPZ without noble gas interference and for relating measured field radiation / contamination i
levels to dose rates for the isotopes listed in Table 3 of NUREG-0654.
6.
Describe the provisions for promptly determining radioiodine release
rates, if the stack sample locations are inaccessible due to Vapor Container
shine, to include the criteria for conducting offsite monitoring and the expected response time.
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Provide plots which show high range containment radiation monitor readings
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and 1% and 10% of release of full inventory) and incorporate these into I-the EAls.
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PROTECTIVE RESPONSE
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Emergency Plan:
The licensee has established the means necessary to warn or advise onsite employees, contractors, and visitors of an emergency. All visitors, con-tractors, and unassigned personnel will be evacuated from the plant under Site Area and General Emergencies.
Provisions have been made for site. egress control.
Provisions have been made for radiological monitoring and decontamination of plant evacuees.
A means for accountability for all individuals on site has been provided.
Criteria for the use of protective equipment and supplies by individuals remaining on site have been provided.
Evacuation time estimates for the plume exposure EPZ are provided.
Maps showing the population distribution around the plant are provided.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Specify the means and time required to warn or advise onsite individuals and individuals who may be in the ownercontrolled areas.
2.
The boiler feed pump room is used as an onsite assembly area during evacuations. Depending on the degree of core damage, Vapor Container shine may preclude people exiting offsite from the boiler feed pump room.
Discuss evacuation from the boiler feed pump room under accident conditions.
3.
Provide additional information pertaining to the accountability process to show how the 30 minute accountability goal will be met.
4.
Provide the information set forth in NUREG-0654, criteria J.10.a.,
c.,
d., and m.
5.
Specify who has the authority and responsibility for ordering distribution of Potassium Iodide (KI).
In addition, discuss the time required to make radiciodine measurements, and how it will be assured that KI and other onsite protective measures will be taken in time to be effective.
6.
Commit to recommend offsite protective measures (shelter or evacuation)
based on:
(a) the distance from the plant to which the EPA PAGs are exceeded (not just.35 miles),
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(c) use of the keyhole approach (not just in a down wind direction) and (d) offsite factors such as evacuation times or special facilities that may effect the effectiveness of the action recommended. Commit to
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i review this methodology with offsite officials annually.
7.
Provide for an assembly area, out of the valley, at which plant evacuees can relocate immediately without onsite monitoring if conditions warrant.
Provide monitoring at this location.
l 8.
Discuss the impact of possible Vapor Container shine on plant accident
response, such as taking repair.and corrective actions.
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RADIOLOGICAL EXPOSURE CONTROL Emergency Plan:
Exposure guidelines, consistent with EPA standards, have been established
for removal of injured persons, undertaking corrective actions, performing assessment actions and performing first aid.
Implementation of a radiation protection program is discussed. The Radiological Evaluation Assistant is responsible for developing and expanding radiological protection programs for the plant staff and support personnel.
The Recovery Manager and/or the TSC Coordinator have the authority to approve radiation doses in excess of 10 CFR 20 limits.
The licensee has made provisions to distribute selfreading and permanent record type dosimeters and to determine, on a 24-hour a day basis, the doses received by emergency response personnel.
Records will be kept accordingly.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Include emergency exposure guidelines for individuals involved in personnel decontamination, ambulance service, and medical treatment.
2.
The licensee should elaborate on the emergency radiation protection
program to include distinctions from the normal radiation protection
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program, how it is initiated and implemented, and how the high Vapor Container shine will be considered.
3.
Describe the action levels used in determining the need for decontamination and the means for decontaminating personnel wounds.
4.
Discuss the provisions for onsite contamination control'and address the criteria for permitting return of areas and items to normal use.
5.
Discuss the use of decontaminants suitable for the contamination expected, giving particular attention to radioiodine skin contamination.
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MEDICAL AND PUBLIC HEALTH SUPPORT
Emergency Plan:
Arrangements have been made for local hospital and long term medical services having the appropriate capabilities.
- Onsite first aid capability is provided.
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Arrangements for transporting radiological accident victims to medical support facilities have been made.
DEFICIENCY:
The plan requires revision and/or additional information as follows:
1.
Provide a letter of agreement between the licensee and the Charlemont Ambulance Service.
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M.
RECOVERY AND REENTRY PLANNING AND POSTACCIDENT OPERATIONS
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Emergency Plan:
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The plan decribes the key positions / titles, authority, and responsibilities of individuals in the facility recovery organization.
DEFICIENCY:
The plan requires revision and/or additional information as follows:
1.
Provide the following:
(a) general plans and procedures for reentry and recovery and the means
by which decisions are reached to relax protective measures, (b) means for informing members of the response organizations that a
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recovery operation is to be initiated; and (c) a method for periodically estimating total population exposure.
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EXERCISES AND DRILLS Emergency Plan:
An annual joint exercise involving the State and the licensee will be conducted.
- The required monthly ~ communication drills between the licensee and State /
local governments have been established.
- Communication drills bewteen the licensee and Federal emergency response organizations and State agencies within the ingestion EPZ are performed annually.
Fire drills are conducted in accordance with plant technical specifications.
Medical emergency drills involving a simulated contaminated person and local support agency participation are conducted annually.
- The required radiological and health physics drills are conducted.
Exercise and drill scenarios will include objectives, time, data, sim-ulated events, a narrative summary and a list of observers.
A licensee exercise critique, resulting in a formal evaluation of identified deficiencies, is provided.
Comments are discussed in a postexercise / drill critique with deficiencies'
being identified and proper corrective action (s) determined by responsible plant staff.
DEFICIENCIES:
i The plan requires revision and/or additional information as follows:
1.
Provide for varing exercise scenarios from year to year such that all
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major elements of the Emergency Response Plar, and its procedures are evaluated every five years.
2.
Provide for corducting exercises at different times of day, and with some
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unannounced.
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3.
Provide that the exercise scenarios will encompass offsite radiological releases which would require offsite (State and local) participation.
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4.
Provide for monthly communication drills between the NRC and the licensee as per paragraph E.9.d of Appendix E to 10 CFR 50 with provisions to
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evaluate comprehension of the messages transmitte.
5.
Provide for annual radiological monitoring drills to include analysis of sample media (air, water, soil, vegetation), recording results, and dissemination of data.
I 6.
Provide for semiannual health physics drills to include analysis of implant liquid samples and use of post-accident sampling capabilities.
7.
Provide for testing the communication with ingestion EPZ pathway Federal and State emergency response organizations quarterly.
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RADIOLOGICAL EMERGENCY RESP 0NSE TRAINING Emergency Plan
Site specific training is offered to such offsite emergency organizations as hospital, ambulance rescue, and fire departments.
Onsite emergency groups receive classroom as well as field training.
Erroneous drill performance is addressed and corrected via critique.
- Courses, equivalent to the Red Cross Multimedia curriculum, are provided to the licensee's first aid teams.
The licensee has provided for initial and annual retraining of personnel with emergency response duties.
A specialized training program, including initial and periodic retraining sessions has been established for the following organizational categories:
directors / coordinators of response groups, personnel responsible for accident assessment; security; fire fighting; repair and damage control; first aid and rescue; medical support personnel; and personnel responsible for communications.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Indicate that the training for offsite response organizations who may enter the site will include site access procedures.
2.
Specify the organization responsible for training of first aid personnel in Red Cross Multimedia techniques.
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Describe the provisions for training offsite police, local civil defense emergency service personnel, and the licensee's corporate support per-
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sonnel, including the Recovery Manager.
4.
Provide training for the offsite officials with authority and responsi-bility for protective action decision making on the basis on which licensee
recommendations will be made.
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RESPONSIBILITY FOR THE PLANNING EFFORT:
DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION OF EMERGENCY PLANS Emergency Plan Periodic revision of the plan, as needed, including changes identified by drills and exercises, is provided.
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Distribution of plans and approved changes to all organizations and appropriate individuals is provided.
A listing of the procedures required to implement the plan is provided.
- Independent annual audits of the emergency preparedness program are provided.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Provide for training of individuals responsible for the planning effort.
2.
Identify, by title, the individual with overall authority and responsibility for radiological emergency response planning and coordinating these plans with other response organizations.
3.
Designate an Emergency Planning Coodinator.
4.
Provide a detailed listing of supporting plans and their sources.
5.
The listing of implementing procedures should reference the corresponding section(s) of the plan to be implemented.
6.
The results of the independent annual emergency planning audits, along with recommedations for improvements, should be documented, reported to appropriate licensee corporate and plant management, and retrained for a period of five years.
7.
Provisions should be made for updating telephone numbers at least quarterl o
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CONCLUSION Based on our review, we conclude that the Yankee Rowe Emergency Plan, upon satisfactory correction of the previously identified deficiencies, will meet the requirements of 10 CFR 50.47(b) and Appendix E and conform to the guidance of Regulatory Guide 1.101, Revision 2, October 1981.
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l The NRC evaluation of the overall state of emergency preparedness for the Yankee Rowe site will be made following review of the findings and determinations.
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made by TEMA on the State and local emergency response plans.
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