IR 05000029/1988099
| ML20154N292 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 09/15/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154N047 | List: |
| References | |
| 50-029-88-99, 50-29-88-99, NUDOCS 8809290260 | |
| Download: ML20154N292 (67) | |
Text
October 7, 1986
SUBJECT:
Comments on the Systematic Assessment of Licensee i
Performance (SALP) Report l
Dear Sir:
l Reference (b) transmitted the Systematic Assessment of Licensee Performance (SALP) Report.
We have ccmpleted our
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review of the SALF report and find the report to be reflective of the assessed areas during the SALP period, with one exception; the Emergency Preparedness Area.
A meeting was held July 14, 1988 at the Region I Headquarters to discuss the report.
At that time, we discussed, in detail, i
issues in the Emergency Preparedness area.
We expressed our i
concern that the SALP Board may not have been fully aware i
of the initiatives that have occured during the SALP period in Emergency Preparedness.
Some of these actions were summarized briefly in Reference (c) and discussed in detail during the meeting.
The attached information highlights these actions, which involved significant resource commitments on the part of Yankee.
We request that the SALP Board amend the SALP report to reflect these actions ano, in light of this additional information, consider a SALP rating of one (1) in the Emergency Preparedness Area.
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} hDR 8809290263 880915 ADOCK 05000029 l
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William T.
Russell FYR 88-ld)
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July 15, 1988 Page 2 l
l At the meeting we also outlined our initiatives to improve
our performance in the Radiological Controls area as requested
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in Reference (b).
These initiatives include:
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Implementation of our "hot partical" control program, i
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i Daily checks of high radiation area and radiation t
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area barricade posting and labeling,
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t Implementation of a Plant wide observation program, l
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Strengthening of the R.P.
technician and General Employee
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Training programs, l
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Develcpment of a new prototype radiation monitor,
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strengthening the ALARA program.
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We will also continue to monitor industry progress in
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radiological developments.
We appreciate the frank and open dialog that occured during our meeting.
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I sin ely urs,
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B.L. Drawbri ge
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Vice President and
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Manager of operations BLD/mem
1 Attachment
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SALP ANALYSIS SUMMARY
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WEAKNESSES STRENCTHS
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o March 1987 Exercise acceptable performance
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no significant deficiencies
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effective command & control
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prompt state notification
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prompt personnel augmentation
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PAR's appropriate & conservative
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o err Appraisal one deviation on SPDS parameters generally verified facilities
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met 100FR50 and orders o
_E m e_r_g e n cy P l a n n i tio c oo r d i n a t o r_
hired quickly
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aggressive training program
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o Emergency Plan and Procedu*1e s
completed rewrite of E-plan & Procedures
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completed lessen plans
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o Emergency Action Level review EAL's to gcidence
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quantiflod EAL symptoms
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re' structured EAL's for human factors
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short-term corrective reasures
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aggressive and timely long-term integrate EAL's with ECP's
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use has been conservative & tirely
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o Emergency Plan Trainino reorganized training organization
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3 instructors from NSD
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trained all personnel for April esercise
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o Nuclear Alert System repeated equipment failures increased testing
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alow to fiz
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e offsite Agencies relationship generally good
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NSD responsible for training & coordination
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working with local towns to upgrade
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and train working with Massachusetts to upgrade
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o Summary several key programs not tosplete demonstrated effective oversight
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and control responsive to sost NRC initiatives 1.
EPC training
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final integration of EAL's & E0P's improved ability for self-eammination
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demonstrated commitment 3.
final review of offsite plans
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expended a great deal of ef fort and procedures
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to upgrade
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Examples of lack of fully effective April '88 exercise demonstrated
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improvements oversight 1.
1988 scenario problems
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high f ailure rate of NAS OVERALL RATING 2 (improving)
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Reccesendation: Continue ef forts to resolve concerns involving EAL's
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offsite Planning _ Activities
o Yankee, in conjunction with State and local officials, updated the plans for the eleven towns in the Yankee E=ergency Planning Zone (EPZ). Nine of the c.leven towns have of ficially approved and signed their respective plan. T1e remaining two towns will sign their plan upon completion of minor revisions.
o Plans for the two reception centers in the Yankee EP: vere also updated.
This involved substantial work with officials from the reception centers and host com= unities.
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Yankee commenced development of plans for the nineteen schools in the eleven
'o Massachusetts towns in the Yan)ce EPZ.
This effort should be completed by Septe=ber of this year. Yankee also worked with the State of Vermont in developing plans fer the six schools in the Vermont towns in the Yankee EPO.
Yankee in conjuction with the State, updated the Massachusetts Civil Defense o
Agency Area IV Plan. This included revisions to the base plan and various State agency procedures.
o Yankee is a cecbor of a state / utility task force on revising the Massachusetts State Plan.
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o Yankee conductet. training for State and local emergency response personnel.
This program was far more comprehensive than had been done previously in i
the past. The training consisted of four training modules:
1) Overviev 2) Radiation and Dosimetry 3) Radiological Mon,itoring and Decentamination and 4) Emergan;y Orarations Center Tabletop (DOC rundamentals and Procedures).
In the Yankee F.PZ, a total of 415 individuals attended 39 classes totalling 102.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of instruction.
o Yankoo is working with the State to develop a standardized training program for State and local emergency response personnel for use throughout the entire State.
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In the pcst ext.xcise critique, TEMA noted the excellent participation and o
perforrance of the local EP towns including the two reception centers.
FEMA cited that this vas due to the upgraded plan and intensive trainLng.
o Yankee is working with the Massachusetts Civil Defense Agency and Office of Handicapped Affairo to conduct a survey of the special needs population f
in the Yankee EP2 in order to verify the existing data.
o Yankee provided Area IV MCDA with additional telephone lines and a word processing systea.
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Yankee provided communications equipment decon supplies and other material
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assistance to each EPZ town and receptior, center.
Yankee maintains, tests, and repairs Area IV and local EOC radio communications o
networks (RE.RP radios, etc).
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Yankee purchased and installed a radio communication system for the State's o
NIAT monitoring teams.
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The State has submitted the revised local Area IV plans to FEMA for an i
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informal technical review.
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SUSJECT: Emergency Preparedness Improvements l
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j EP Implementing Procedures Upgrade
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- Addition of activation procedure for emergency facilities i
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- All procedures are now facility based incorporating all functions l
into one procedure for each facility l
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- Reformatted EAL procedure
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EP Training i
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- Extensive revision of overall training prograa
- Program developed in accordance w/INPO accreditation process esploying
a thercugh job-task analysis to develop lesson plans.
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racilities e
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- Icproved telephone com=unications in Forward Control Point (FCP)
- Improved radio communications in Forward Control Point
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- Improved telephone communications in Media Center j
- Added copier capability in Emergency Operations racility
- Improved status boards in Technical Support Center and Emergency i
operations racility
- Addition of MET Data Terminal in the Emergency Operations racility i
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Augmentation
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- Revision of OP Memo 2E-4 that improved the timely notification of l
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Emergency Response Organization personnel.
(Noted as a strength l
during exercise)
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j Nuclear Alert System (NAS)
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- Revised OP Memo to quantify a significant loss of capability. Provided j
j instructions to ensure timely notification in the event of a significant
loss.
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- Frequency of testing exceeds requirements
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- Hardware taprovement to station that was most unreliable (Since 4/22/88 l
no failures)
Deergency Action 24vels l
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- Completed comprehensive review of basis (plant superin-
- Completed compliance review, comparing EALa to NUREG 0654 tendent personali)
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- Restructured EAL format incorporating improved human factors conducted EAL I
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- ongoing - Integration w/iaplementation of new ECPs in 1989 training for Additional human factor engineering operators)
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Summary: The extensive E Plan revision, EPIP revisions, staff augmentation
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j plan revision and improved training program all contributed to a successful i
graded exercise in 1988. Personnel response time laproved, activation of
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the ERTs was extremely timely and all 1987 deficiencies were corrected.
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demonstrating the effectiveness of the improvements.
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1987 EXERCISE ITEMS
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The process of ERT activation and subsequent transfer / relief of
responsibilities should be formalized in the activation procedures I
and appendices (50-29/87-03-01).
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Response - The EPIPs were redesigned as "facility" based procedures, f
l utilising appendices in a checklist format. The procedures
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clearly delineate individual responsibilities including
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activation of facilities and subsequent transfer / relief i
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Field team results were not displayed or distributed to response
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personnel in the ECP.
(50-29/87-03-02).
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I Respense - During the 1988 Exercise data from Field Teams through the
coc=unications system flowed well. The data was analyzed,
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states received the data and the data was used to modify
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Emergency response personnel in transit from the ERFs to the Access control Point, or other areas of the plant, are normally not given
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i self reading dosimeters (50-29/87-03-03).
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Response - Section 10.3 of the Plan, and procedure OP-3324 were revised
to ensure all onsite emergency response persortnel are issued l
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sglf-reading dosimeters when they arrive at their respective i
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Emergency Acticn Levels (EALa) should be evaluated for inctasistencies and to the guidance of NUREG-0654, Appendix 1.
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Response - The EALS were revised to be consistent with the guidance
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I of NUREG 0654 and to add quantitative values where appropriate.
The EALa were also reformatted to allow for their use from
highest classification to lowest. EALa are stand alone
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sympton based indicators of plant condition for the purpose
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l of energency declaration. As a self initiated recommendation I
EALs will be integrated with the new BOPS to ensure optimum
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clarity and ease of use.
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Open items drastically reduced at each exercise
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June 86 (full scale)
12 open items (closed)
l March 87 (small scals)
4 open items (closed)
l April 88 (full scale)
2 open itana (1 already closed)
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ERT APPEAISAL ITEMS
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1.
Tne ac eptability of the TSC habitability will depend on the outcoce of the L RR review of the Control Room Emergency Filtration System (50-29/81-05-01)
Response, - The review has been completed.
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NUREG-0737, Application to Emergency Response Facilities, states, in part, that variables that are essential for the performance of the TSC and EOF functions be available in the TSC and EOF (50-29/87-05-02).
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Response - A corrective action plan has been' initiated which will y
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add the 6 variables in question to SFDS during Cycle
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Perform a review and analysis of the telecommunicatons system linking the Control Room and TSC (50-29/87-05-03).
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Response - A review and analysis was performed following the Appraisal
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and found to be a minor AT&T problem that was corrected
immediately. Parther tests of the system following
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the correction were positive.
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The licenseg does not have the capability to calculate a site boundary
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I thyroid dose from the Control F.com and TSC (50-79/87-05-04).
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Response - This capability has been incorporated into the new thyroid dose rate nomograms. They have been developed, trained on and implemented.
This capability will also be incorporated j
in the upgraded calculator methodology.
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The licensee does not have the capability to calculate release
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rates from the Safety Injection (SI) Building, or subsequent whole body and thyroid doses from an 31 Building release (50-29/87-05-05).
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Response - A procedure was developed (OP-3328 App. D) and implemented l
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for estimating release rates from the SI Duilding.
f This was incorporated into the METPAC Version 4.0 model.
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FREVIOUS SALP ITEMS 1.
...there has not been a perr.anently assigned site EPC for YNPS...
Res7>nse - A full-time site EPC has been assigned to the YNPS 2.
... involved a failure of PORC to review a change to the Emergency f
Plan...
Response - An Environmental Engineering Department procedure (YA-RPG-100)
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was written to ensure that the plan will not be issued without PORC approval 3.
... As the emergency escalated, turnover of authority was not clear...
Response - The plan and procedures were rewritten to clearly delineate when and what authorities /responsiblities are turned over as an emergency escalates.
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... PAR cade to Vermont and Massachusetts were primarily based upon I
dose projection without consideration of potential degradation of plant and core conditions...
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Response - The guidance from IEE Inforination Notice 83-28. Criteria for Protective Action Recossendations for General Emergencies, was incorporated into the Plan and procedures. This guidance considers the potential degradation of plant and core conditions.
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...The licensee's post-exercise critique was noted to be somewhat superficial and did not cover the significant deficiencies identified by the NRC Inspection Team...
Response - Due to the upgrade made in this process this critique process was noted as a strength by the NRC Inspection Team in the 1987 and 1988 Exercise Inspection Reports.
Since 1983 manhours committed to emergency planning have increase 3 '
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by 600s.
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YANKEE ATOMIC ELECTRIC COMPANY
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EMERGENCY PREPAREDNESS RESPONSIBILITIES (Normal Operation)
VICE PRESIDENT (WAs RECOVERY MANAGER FOR APRIL EXERCISE)
DIRECTOR - EED
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RADIOLOGICAL ENGINEERING GROUP (REG)
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e RADIATION PROTECTION PUBLIC AFFAIRS DIRECTOR GROUP (RPG)
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PLANT EMERGENCY PLAN COORDINATOR-10-2435R/23.250
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APRIL 1988 EXERCISE, ITEMS
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Scenario As a result of a subtle input error in the scenario dose
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projection model, doses calculated by MI:TPAC were significantly lower than the results "measured" by the field teams.
This posed a significant challenge to the emergency response personnel who sought to determine whether an unmonitored release was under way. After evaluating the data and checking possible release points, the Recovery Manager in consultation with
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the Radiological evaluation team, acted properly and conservatively in that they used the higher field data to recommend protective action. Although the scenario did not intend to challenge the response organization in this manner, proper protection of the public was demonstrated by the emergency response
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Nuclear Alert Syste:
On April 22, 1988 the week link in the NAS was repaired.
d Since that time, there have been no failures on the system which is tested daily.
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ENCLOSURE 5 SAlp MANAGEMENT MEETING ATTENDEES
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July 14, 1988 1.
Licensee Attendees B. Drawbridge, Vice President, Yankee Atomic Electric Company (YAEC)
A. Kadak, Vice President, YAEC J. DeVincentis, Vice President, YAEC N. St. Laurent, Plant Superintendent, Yankee Nuclear Power Station (YNPS)
R. Mellor, Technical Director, YNPS J. Haseltine. Project Msnager, YAEC W. Riethle, Radiation Protection Manager, YAEC 2.
NRC Atterdees S. Collins, Deputy Director, Division of Reactor Projects (DRP), Region I (RI)
J. Wiggins, Chief, Project Branch No. 3, DRP, RI D. Haverkamp, Chief, Reactor Projects Section 3C, DRP RI H. Eichenholz, Senior Resident Inspector, RI C. Carpenter, Resident Inspector, RI R. Wessman, Director, Project Directorate I-3, Office of Nuclear Reactor Regulation (NRR)
M. Fairtile, Project Manager, I-3, NRR
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J. Durr, Chief, Engineering Branch, Division of Reactor Safety (DRS)
W. Lazarus, Chief, Emergency Preparedness Section (EPS), Division of Radiation Safety and Safeguards (DRSS)
C. Conklin, Senior Emergency Preparedness Specialist EPS, DRSS M. Markley, Radiation Specialist, Facilities Radiation Protection Section, DRSS
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