IR 05000029/1985008

Insp Rept 50-029/85-08 on 850513-16.No Violation Noted. Major Areas Inspected:Annual Emergency Exercise Performed on 850515

ML20127L533
Person / Time
Site:	Yankee Rowe
Issue date:	06/11/1985
From:	Craig Gordon, Harpster T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127L507	List: IR 05000029/1985008 ML20127L501
References
50-029-85-08, 50-29-85-8, NUDOCS 8506280049
Download: ML20127L533 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-08 Docket N License No. OPR-3 Priority --

Category C Licensee: Yankee Atomic Electric Company 1671 Worchester Road Framingham, Massachusetts 01701 Facility Name: Yankee Nuclear Power Station Inspection At: Rowe, Massachusetts Inspection Conducted: May 13-16, 1985 Inspectors: /{hS *\ (.-4-$f C. Z. BoVdon, DRSS, EP&RPB, EPS date Team Leader I. Cohen, RI H. Eichenholz, Resident Inspector P. Gaul, RI E. Smith, RI J. Tanner, Battelle, PNL G. Weal , Battelle, PNL Approved by- **M d ff T. L/farpstfj, Chief 7 date EmerTency Preparedness Section l

Inspection Summary: Inspection on May 13-16, 1985 (Report No. 50-29/85-08)

I Areas Inspected: Routine, announced, followup inspection and observation of the licensee's annual emergency exercise performed on May 15, 1985. The inspection involved 163 inspector hours onsite by a team of seven NRC Region I and NRC contractor personne Results: No violations were identified. The licensee's emergency response actions for this exercise were adequate to provide protective measures for the j health and safety of the public.

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DETAILS 1. Persons Contacted The following licensee representatives attended the exit meeting held on May 16, 1985:

G. M. Babineau, Radiation Protection Manager R. L. Boutwell, Technical Services Supervisor C. R. Clark, QA Engineer B. L. Drawbridge, Assistant Plant Superintendent T. Fuller, Emergency Planner D. J. Hadlock, H.P. Foreman L. H. Heider, Vice President T. K. Henderson, Technical Director T. La Flam, Chief of Security D. F. McDavitt, Emergency Planner R. W. Poeton, Radiation Protection Engineer D. Rice, Plant Engineer W. E. Riethle, Manager, Radiation" Protection YNSD J. G. Robinson, Director, Env. Engineer N. N. St. Laurent, Plant Superintendent E. H. Salomon, Radiation Protection Engineer R. H. Sedgwick, Security Supervisor M. J. Vandale, Radiation Protection Engineer E. Wojnas, Senior Engineer The team observed and interviewed several licensee emergency response personnel, controllers, and observers as they performed their assigned functions during the exercise. Discussions were also held with corporate representatives regarding deficient areas of the Emergency Pla . Emergency Exercise The Yankee Nuclear Power Station partial exercise was conducted on May 15, 1985 from 8:00 a.m. until 3:00 Pre-Exercise Activities Prior to the emergency exercise, NRC Region I representatives held meetings and had telephone discussions with licensee representatives to discuss objectives, scope, and content of the exercise scenari As a result, minor revisions were made in order to clarify certain objectives and ensure that the scenario provided the opportunity for

' the licensee to demonstrate those areas previously identified by NRC l as in need of corrective action.

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( NRC observers attended a licensee briefing on May 14, 1985, and

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participated in the discussion of emergency response actions expected i during the various phases of the scenari The licensee stated that

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certain emergency response activities would be simulated and that i

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controllers would intercede in exercise activities to prevent scenario deviation or disruption of normal plant operation The exercise scenario included the following events:

• Steam generator tube leak causing an increase in the condenser air ejector monitor above technical specifications;

• Reactor scram causing degradation in fuel integrity and increased primary coolant activity level;

Release of radioactivity to the atmosphere due to reseating failure of the low pressure safety valve;

• Declaration of unusual event, alert, and site area emergency classifications; and

• Plant stabilization, cooldown, and discussion of recovery effort The above events caused the activation of the licensee's onsite emergency response facilitie b. Activities Observed During the conduct of the licensee's exercise, seven NRC team members made detailed observations of the activation and augmentation of the emergency organization, activation of emergency response facilities, and actions of emergency response personnel during the operation of the emergency response facilities. The following activities were observed:

• Detection, classification, and assessment of the scenario events; l

• Direction and coordination of the emergency response; i

l * Notification of licensee personnel and offsite agencies of pertinent plant status information;

• Communications /information flow, and record keeping;

• Assessment and projection of radiological dose and consideration j of protective actions; l

• Provisions for in plant radiation protection;

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• Performance of offsite and in plant radiological surveys;

• Maintenance of site security and access control; l

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• Performance of technical support;

Performance of repair and corrective actions;

• Assembly and accountability of personnel; and

• Management of ac$ident recovery operation Exercise Observations The NRC team noted that the licensee's activation and augmentation of the emergency organization, activation of the emergency response facilities, and use of the facilities were generally consistent with their emergency response plan and implementing procedures. The team also noted the following actions of the licensee's emergency response organization that were indicative of their ability to cope with abnormal plant conditions:

• Dose assessment methodologies used in the Control Room and EOF provided accurate projections of radiological dose to affected population * Direction and control provided by managers of each emergency response facility was effectiv * Emergency response personnel were knowledgeable in use of Emergency Plan Implementing Procedures (EPIP) and carried out duties and responsibilities efficientl * Although the EOF is not conducive for providing optimum information flow, offsite telephone and radio communications were adequat Communications between the TSC, OSC, Control Room, and in plant teams were also effectiv Open Items The NRC team identified the following areas which need to be evaluated by the licensee for possible corrective action (the licensee conducted an adequate self-critique of the exercise which also identified some of these areas):

• (0 pen) 50-29/85-08-01: Based upon plant conditions during the Unusual Event classification, no release should have been expected but the notification message provided to the State of Vermont indicated that a release was anticipate * (0 pen) 50-29/85-08-02: The on-shift HP technician did not know the location where the air ejector sample was to be obtaine * (0 pen) 50-29/85-08-03: The need for obtaining a primary coolant sample was not immediately recognized by TSC staff. Once the

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sample was requested, the extent of fuel damage could not be determined since delays were encountered in obtaining sample result *

(0 pen) 50-29/85-08-04: After assembly, security sent visitors and contract personnel to the E0F without accounting for their dosimetr * (0 pen) 50-29/85-08-05: Procedure OP-3311, " Emergency Offsite Radiation Monitoring" does not provide for contamination surveys

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of vehicles upon return to the EO As a result, offsite monitoring teams did not have the opportunity to demonstrate vehicle decontamination after plume tracking was complete (0 pen) 50-29/85-08-06: Ensure that all controllers and observers are provided with adequate scenario training in order to clarify unexpected actions and handle any deviation which may arise during the exercis Recurring Items The licensee provided adequate demonstrations of deficient areas which were identified by NRC during the previous emergency exercise with the following exception:

(0 pen) 50-29/85-08-07: The amount of actual performance and demonstrations associated with use of radiation protection pro-cedures was inadequat Excessive simulation was observed in the use of radiation detection instruments, dress out procedures, contamination control techniques, and use of ALARA principles. Consequently, the NRC team could not determine the overall effectiveness of the training program in this area. The licensee acknowledged this finding and indicated that additional demonstrations will be provided in future exercise f. Licensee Actions on Previously i f_entified Items

! During the period January 30 - libruary 7,1984, NRC Region I personnel conducted a review of the licensee's Emergency Plan as it relates to the standards of 10 CFR 50 Appendix E.IV and NUREG-0654 criteria and identified the deficient areas in Report No. 84-03. The licensee has evaluated each recommendation and taken corrective actions by making revisions to the Emergency Plan. The inspectors held discussions with licensee site and corporate representatives and determined the status of each item to be as follows:

(0 pen) 84-03-10 The minimum staffing requirements are deficient with respect to the guidance set forth in Table B-1 of NUREG-0654.

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Although Section 8.0, " Organization" of the Emergency Plan has been revised to indicate that the major tasks of Table B-1 of NUREG-0654 are addressed through cross-training, the minimum staffing requirements for on-shift personnel and the capability for additions within 60 rainutes is not described. The licensee indicated that the plan will be revised to include the on-shift and 60 minute minimum staffing requirement . (Closed) 84-03-11 The Plan indicates that there are provisions to incorporate federal response capabilities into the Yankee Rowe Emergency Plan. This section should be expanded to include information requested in NUREG-0654, Criteria C.I.a, C.1.b, C.I.c, and C. Section 8.5, " Coordination With State Government Authorities",

of the Emergency Plan has been revised to satisfy criteria C.1.a C.1.b, C.2.b. Appendix E, " Letters of Agreement", Table 8.4 provides a listing of area airports to satisfy criteria C. * (Open) 84-03-18 Specify the organizational titles and alternates for both ends of the communication link which would be involved in initiating emergency response actions and to indicate that such stations will be manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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).

The Emergency Plan indicates that the Shift Supervisor relays messages to State authorities, that both will be available around-the-clock, and that State protective action decision-making chains are contained in the Vermont and Massachusetts Emergency Response Plans. However, there is a concern in the Emergency Plan regarding Criterion F.1.c of NUREG-0654 which requires a provision for licensee communications with Federal emergency response organizations. Since the Plan indicates that FEMA will be responsible for such capability, the arrangement between the licensee, FEMA, and the Federal organizations in-volved in emergency response should be clarified. The licensee stated that they will reevaluate the communications arrangements between the affected organizations and will revise the plan accordingl * (0 pen) 84-03-21 Provide sufficient information to demonstrate compliance with the guidance of Criteria G.1 and G.2 of NUREG-0654 (i.e., an example of the information to be transmitted annually to the public, explaining the rationale for protective actions). Commit that information will be distributed on an annual basi _

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The inspectors reviewed the overall public information program and determined that written brochures were dictributed in the States of Vermont and Massachusetts during March and April 198 The licensee representative stated that the Plan would be revised to show annual distributio * (0 pen) 84-03-22 Provide annual dissemination of information to transients within the plume EP .

The. inspectors discussed notification of the transient popula-tion with the licensee and determined that written brochures are distributed to campgrounds, motels, and hotels in the EPZ. The licensee representative also stated that transients in wooded areas would be informed of emergencies by low flying aircraf A revision to the Emergency Plan to provide for notification of transients was agreed on and will be made by the license * (0 pen) 84-03-25 Indicate how exchange of information will be coordinated between the licensee's spokesperson and the respective spokespersons for offsite organizations. Also, there should be coordinated arrangements for dealing with rumor The inspectors determined that the above information is contained in the " Media Center Emergency Procedures". The licensee representative stated that the information would be included in the next revision of the Emergency Pla * (Closed) 84-03-32 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. 50-29/81-20. However, the Plan must be

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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 cooditions will be considere Section 10.1.2, " Variable Trajectory Dispersion / Dose Projection Capability" of the Emergency Plan was revised to include a l computerized dose assessment methodology which considers a wide range of changing meteorological conditions to calculate dose projection * (Closed) 84-03-35 Delineate methods and techniques used in

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post-accident sampling. This additional information should encompass the guidance material given in NUREG-0737, Items II.8.3, II.F.1, and III.D. Section 6.2.5. " Post-Accident Sampling" has been revised to provide for sampling systems for VC atmosphere, PVS radioiodine, and primary coolant sample collection. The methods and

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techniques used in post-accident sampling are adequate and are covered in Report No. 85-0 *

(Closed) 84-03-37 Provide means for determining release rates / projected doses if the instrumentation used for assessment is off scale or inoperabl Section 6.2.2, " Radiological Monitors", of the Emergency Plan has been revised so that offsite field measurements, plant area monitor responses, and main coolant sample results would be used in concert to provide an indication of radiological dose projectio '

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(Closed) 84-03-38 Elaborate on the capability and resource for

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field monitoring within the plume EPZ. This section should also specify the estimated deployment times and the means of trans-y portation for offsite radiological assessment of liquid or gaseous release Section 10.1.3, " Evaluation of Offsite Samples" of the Emergency Plan has been revised to indicate that four (4) offsite monitor-

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ing teams are available at the plant to provide initial field monitoring. Emergency personnel use their own vehicles for this function. Team deployment times are adequately covered in Procedure DP-3311, "Offsite Monitoring".

(Closed) 84-03-40 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).

The inspectors observed shielded equipment which has been in-stalled at the stack sample location thereby reducing radiologi-cal exposures and allowing timely post accident samples to be obtained. This area has been evaluated by NRC in Report N . The evaluation indicates that the sampling station could be used at radiation levels up to 25 J

(0 pen) 84-03-52 Describe the action levels used in determining the need for decontamination and the means fo'r decontaminating personnel wound Although Section 10.4.3 of the Emergency Plan was revised, the action levels used in determining the need for decontamination and the means for decontaminating personnel wounds is not described. The licensee indicated that the procedure covering personnel decontamination would be revised to include this informatio _ _

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(Closed) 84-03-54 Discuss the use of decontaminates suitable for the type of contamination expected, giving particular attention to radioiodine skin contaminatio Section 10.4.3, " Decontamination Capability" and Table 10.3 of the Emergency Plan have been revised to identify Greene's solution, Radiac wash, or soap and water as the decontaminants used for removing contamination on individual * (Open) 84-03-58 Provide for conducting exercises at different times of day and with some unannounce Section 12.1.1 " Radiation Emergency Exercises", of the Emergency Plan has been revised to provide for conduct of exercises on an unannounced basis and at different times of the day. However, Section 12.1.1 should also be revised to provide for NRC observed exercises to be conducted only at a 12 month frequency and include formal critiques in order to identify weak areas as required by 10 CFR 50, Appendix E IV.F.3. The licensee stated that the Emergency Plan would be modified to include this informatio * (Closed) 84-03-60 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 evaluate compre-hension of the messages transmitte Section 12.1.2, " Communication Tests" of the Emergency Plan has been revised to provide for monthly communications tests of the emergency notification link with either NRC Headquarters or NRC Region *

(Closed) 84-03-61 Provide for annual radiological monitoring drills to include analysis of sample media (air, water, soil, vegetation), recording results, and dissemination of dat Section 12.1.5, " Radiological Monitoring Drills" of the Emergency Plan has been revised to provide for radiological monitoring drill * (0 pen) 84-03-63 Provide for testing the communications with ingestion EPZ pathway federal and state emergency response organizations quarterl Although Section 12.1.2 of the Emergency Plan has been revised, further clarification of Section 12.1.2.3 is needed since the revision indicates that communications between the plant and ingestion pathwayestates need not be specified. The licensee stated that Section 12.1.2 will be revised to provide for communications tests with Federal and State organizations within the ingestion pathway on an quarterly basi .

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• (Closed) 84-03-65 Specify the organization responsible for training of first aid personnel Red Cross multimedia technique Section 12.2.6 " Emergency Medical Team" of the Emergency Plan has been revised to provide training for emergency medical team members which is equivalent to Red Cross Multi-Media instructio * (Closed) 84-03-66 Describe the provisions for training offsite police, local Civil Defense Emergency Service personnel, and the licensee's corporate support personnel, including the Recovery Manage Section 12.2, " Training of the Emergency Plan has been revised to provide for YNSD emergency support personnel to receive training in their respective Emergency Plan responsibilities on an annual basis. Other categories of personnel specified by 10 CFR 50 Appendix E.IV.F.(2)a.-i. for specialized training also included in Section 12 of the Pla * (Closed) 84-03-68- Provide for training of individuals

, responsible for the planning effor Section 12.5, " Responsibility of the Planning Effort" has been revised to indicate that the licensee's goal is to. provide sufficient training to emergency preparedness personnel which is necessary to support their dutie * (Closed) 84-03-74 Provisions should be made for updating telephone numbers at least quarterl The licensee uses an OP memorandum to ensure quarterly update of call lists and has agreed to reference this memo in the Emergency Pla .

g. Licensee Critique The NRC team attended the licensee's post-exercise critique on May 15, 1985, during which key licensee controllers discussed r observations of the exercise. The critique adequately addressed both areas for improvement (which the licensee indicated would be evaluated and appropriate actions taken), and areas in which improvement have been made.

. Specific improvement areas which were identified related to misuse of Control Room procedures, delays in response of repair and corrective

! action teams, inadequate exposure control demonstrated by offsite

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monitoring teams, and minor scenario deficiencies relating to format and presentation of operational and radiological data.

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3. Exit Meeting and NRC Critique Following the licensee's self-critique, the NRC team met with the licensee representatives listed in Section The team leader summarized the observations made during the exercis The licensee was informed that previously identified items were adequately addressed with the exception of item described in Section 2.e and no vio-lations were observed. Although there were areas identified for improve-ment, the NRC team determined that within the scope and limitations of the scenario, the licensee's performance demonstrated that they could implement their Emergency Plan and Emergency Plan Implementing Procedures in a manner which would adequately provide protective measures for the health and safety of the publi Licensee management acknowledged the findings and indicated that appropriate action would be taken regarding the identified open items. At no time during this inspection did the inspectors provide any written information to the licensee.

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