IR 05000271/1987007

Emergency Preparedness Insp Rept 50-271/87-07 on 870413-15. Two Unresolved Items Noted.Major Areas Inspected:Changes to Emergency Preparedness Program,Reviews & Audits & Security/ Emergency Preparedness Program Interface

ML20209J554
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	04/24/1987
From:	Conklin C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20209J519	List: IR 05000271/1987007 ML20209J513
References
50-271-87-07, 50-271-87-7, NUDOCS 8705040309
Download: ML20209J554 (8)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No.

50-271/87-07 Docket No.

50-271 License No.

DPR-28 Priority Category C

Licensee:

Vermont Yankee Nuclear Power Corporation RD 5. Box 169 Brattleboro, Vermont 05301 Facility Name: Vermont Yankee Nuclear Power Station Inspection At:

Brattleboro, Vermont Inspection Conducted: April 13-15, 1987 4 /24 f 8'

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Inspectors:

i ConYlin, Emergency Preparedness date pecialist, EP&RPB, DRSS W. Thomas, EPS, EP&RPB, DRSS Approved by:

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W. f,Vazarutit,) Chief Emergency

' date Preparedness Section, EP&RPB, DRSS Inspection Summary:

Inspection on April 13-15, 1987 (Report No. 50-271/87-07)

Areas Inspected:

Routine announced emergency preparedness inspection. The inspection areas included: changes to the emergency preparedness program; licensee reviews / audits; protective action decision-making; shift staffin8 and augmentation; security / emergency preparedness program interface; training; and follow-up on previously identified inspection findings.

Results: Two unresolved items were identified. The licensee's audit program did not recognize or identify apparent weaknesses in the emergency preparedness program and weaknesses in the licensee's ability to notify and augment their on-shift staff in a timely manner.

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DETAILS 1.0 Persons Contacted

• R. Smith, Assistant to the President

• R. Spinney, Training Manager

• E. Porter, Emergency Preparedness Coordinator

• E. Wojnas, Emergency Preparedness Engineer

• E. Salomon, Emergency Preparedness Engineer

• R. Wanczyk, Operations Superintendeat

• J. Pelletier, Plant Manager

• S. Jefferson, Assistant to the Plant Manager

• R. Leach, Radiation Protection Superintendent

• W. Riethle, Manager Radiation Protection J. Babbitt, Emergency Preparedness Training T. Watson, I & C Supervisor B. Metcalf, S'aift Supervisor R. Faupel, Se nior Reactor Operator

• Denotes those present at the crit interview 2.0 Licensee Action on Previous Inspection Findings During the inspection, the inspectors reviewed the licensee's progress concerning the items opened during previous inspections (Inspection Reports 50-271/85-13, 50-271/85-20, 50-271/86-16 and 50-271/86-26. The status of these items is as follows.

The inspectors reviewed the modifications made to the TSC. The existing space has been doubled in size, with a folding wall available to close off l

the space if necessary. The Field Monitoring Team Radio Operator has been l

relocated to an adjacent office. Gaitronics paging units are available in

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the TSC, however they can be controlled as desired. There appears to be sufficient space to allow the licensee and NRC staff to operate effectively

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in the TSC. Additional space is available for support personnel adjacent to the TSC. The following items will remain open pending a subsequent evaluation during the annual exercise.

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- (OPEN) 50-271/85-13-01: Control Room personnel took action independently and were slow to pass information to the TSC.

- (OPEN) 50-271/85-13-05: Overall direction of plant sctivities (TSC) did not appear to be fully coordinated.

- (OPEN) 50-271/85-13-06: Excessive noise levels in the TSC.

- (OPEN) 50-271/85-13-07: TSC did not aggressively follow-up and coordinate plant activities.

- (OPEN) 50-271/85-13-08: Technical reviews in the TSC were inadequate.

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- (OPEN) 50-271/86-26-02: The TSC Coordinator was not actively involved in EAL discussions with the Control Room and EOF and at one point declined to participate in an EAL discussion.

The inspectors discussed with the licensee the importance of the TSC Coordinator being actively involved in accident classification. The TSC should be continuously evaluating plant conditions, and making recommendations for classification, as well as accident mitigation, regardless of where the final classification authority lies. These activities are very important to overall accident management given the expertise of the TSC staff and their proximity to the Control Room. The licen ee agreed that those activities should continue to be performed in the TSC during all phases of operation. This item will remain open pending evaluation in the annual exercise.

- (CLOSED) 50-271/85-20-04: Evaluate the effectiveness of the pager notification system.

The effectiveness of the pager system for personnel notifications was questioned during an Unusual Event on June 20, 1985 when at least fifty percent of the personnel did not respond to the page. A memo was issued by tha Emergency Preparedness Coordinator (EPC) emphasizing the importance of pager usage and re-emphasizing the notification method. A call-in drill was conducted on October 10, 1985 and met the staffing objectives. A subsequent call-in drill was conducted on August 15, 1986 and also met the staffing objectives.

Based upon the above review, this area is acceptable.

- (CLOSED) 271-50/86-16-01: Modification of the training program for key managerr. is complete, but the training cycle was not completed.

The inspector noted that the licensee is currently in the 1987 emergency preparedness training cycle. The previous training cycle was completed for all emergency response personnel.

Based upon the above review this area is acceptable.

- (OPEN) 50-271/86-16-02: The licensee's off-site protective action recommendations do not consider NRC guidance.

OP-3513, " Evaluation of Off-site Radiological Conditions", was revised to consider the guidance of Information Notice 83-28. The inspector noted that the procedure is inconsistent with the guidance in that it fails to consider the option of imminent / actual containment failure and plume arrival time. The procedure presently recommends evacuation regardless of whether evacuation can be effected prior to the arrival of the plume. This item will remain open pending a review in a subsequent inspection.

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3.0 Operational Status of the Emergency Preparedness Program 3.1 Changes to the Emergency Preparedness Program There have been no significant changes to the licensee emergency preparedness program since the last inspection. Changes which have taken place have been minor and have not adversely affected the licensee's overall state of emergency preparedness. The licensee has in place appropriate procedures and mechanisms to assure that changes to the plan and procedures which could affect the overall state of emergency preparedness will be identified. All changes to the emergency plan and implementing procedures receive review by the Plant Operations Review Committee (PORC), approval by station management, and distribution in accordance with approved procedures and NRC requirements prior to implementation. The inspector noted.

that there is no mechanism to ensure that procedures other than emergency preparedness (but which may have the potential to affect the level of preparedness) are reviewed by the EPC. The licensee agreed that these areas should be reviewed and a mechanism provided for EPC review as appropriate.

Based upon the above review, this area is acceptable.

3.2 Knowledge and Performance of Duties (Training)

The following documents were reviewed: OP-3712, Emergency Preparedness Training; lesson plans and practical walk-through scenarios; attendance sheets; and test results.

Emergency preparedness training requirements are well documented.

The inspector noted that all Emergency Preparedness lesson plans are current, approved and on fi.'s.

The lesson plan for Post Accident Sampling, conducted by.the Chemistry Department, was current but not approved. The current training cycle is approximately 70% complete, with scheduling of remaining personnel on-going. The records system is easy to use. Hard copies of all records are maintained in the emergency preparedness training section. All training modules require that a written test be passed ~or that practical walk-throughs be demonstrated. Personnel who fail these tests are prevented from participating in the Emergency Response Organization (ERO) until successful results are achieved. The inspector noted that none of the lesson plans currently in use are routed through the EPC for review and

approval. The licensee indicated changes are being made to allow

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for the EPC review and approval of all Emergency Preparedness l

1esson plans.

l The inspector interviewed several individuals selected on a sampling basis from within the emergency organization. Two senior licensed individuals who may be called upon to be Plant Emergency Director, and one individual trained as Duty and Call Officer who may be called upon to be TSC Coordinator, were chosen. Scenarion

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were chosen to provide events with security implications and a fast breaking event, and were given to each individual.

Detection, recognition and classification was prompt and correct for the given situations. Notifications, and any associated protective action recommendations, would have been prompt. The operators were aware of the safety implications of events caused by sabotage. There are security procedures in place and the operator / security interface is established and adequate. There were minor inconsistencies between operators on dealing with events with security implications.

Although the operator's actions were correct, there was not a strong effort made to ensure that other safety systems / vital areas were cicared by security personnel. The licensee has agreed to provide additional training to address this area.

Based upon the above review, this area is acceptable.

3.3 Organization and Management Control The inspectors reviewed the emergency preparedness normal staffing organization and noted that there has been a major organizational change. The Emergency Preparedness Coordinator (EPC) now reports to the Assistant to the President vice the Chemistry and Health Physics Superintendent. The inspectors noted that this change increases the visibility of the EP program and improves the interface with upper level management. The inspector also noted that this decreases the EPC's presence on-site, and the licensee indicated that the EPC job description would include goals for on-site time. The EPC responsibilities are also being strengthened to ensure that the EPC is the single point of contact for all on-site and off-site activities relating to emergency preparedness. The EPC has no staff, however support personnel are contracted from Yankee Atomic Electric Corporation for off-site support and scenario development, and the Assistant to the Plant Manager provides support as the exercise coordinator.

Based upon the above review, this area is acceptable.

3.4 Independent Reviews /Andits The Quality Assurance Group from Yankee Atomic Power Corporation performs the annual emergency preparedness audits. The audit was conducted on September 15-18, 1987.The audit team consisted of two individuals experienced in QA audits. There were no personnel assigned to the team with expertise in emergency preparedness. The audit did not identify the following:

Procedure revisions were made as a result of the 1985 audit

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regarding combining of certain drills with the annual exercise, however a review of the objectives for the 1986 exercise did not indicate that these drill requirements had been included with the

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exercise, and the procedure does not specify that these activities should be documented.

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The audit indicated that the licensee's Emergency Action Level (EAL) scheme was verified against NRC regulations and guidance, however the inspector noted that three initiating conditions contained in the guidance are in fact not included in the EAL scheme. These are Unusual Event for turbine rotating component failure and security threat, attempted entry or attempted sabotage, and Alert for ongoing security compromise.

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The audit examined the results of station drills. Although the call-in drills were successful from a staffing standpoint, these drills indicate there are paging system and administrative problems associated with pager notification. Other records, such as the weekly pager system tests conducted by the I&C Department were apparently not reviewed.

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The audit verified that written agreements with off-site agencies are valid and current, however the audit did not evaluate the adequacy of the interfaces between the off-site agencies and the licensee, nor did it provide this part of the evaluation to the affected off-site agencies.

The above review indicates that the audit team that conducted the audit did not identify the above noted problems or potential weaknesses in the emergency preparedness program, and was therefore ineffective. The question of audit effectiveness had been previously brought to the licensee's attention and the inspector noted that several actions have been taken to resolve these weaknesses in future audits. This is an unresolved item (UNR 50-271/87-07-01). The results of the corrective actions will be reviewed in a subsequent inspection.

The inspectors reviewed the licensee's drill and testing program.

The licensee has conducted all drills and tests in accordance with their impicmenting procedures. Follow-up and corrective actions for identified weaknesses have been timely and effective. However, the licensee needs to formalize this process. As an example, it was difficult for the inspectors to determine that all drill commitment, such as radiological monitoring or semi-annual health physics drills, were in fact performed when they were combined within the annual exercise.

Based upon the above review, this area is acceptabic.

3.5 Security / Emergency Preparedness Program Interface Discussions were held with the Vermont Yankee Security Supervisor and the Assistant Chief Security Training. The purpose of the discussions was to determine the interface, interaction and the degree of integration of the station security program with the

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emergency preparedness program. Green Mountain Security Services is the security contractor for Vermont Yankee Nuclear Power Station. All security officers receive General Employee Training, Safeguards Contingency Plan Training, Physical Security Plan Training, and Radiological Emergency Plan Training. Security personnel are also assigned membership on the plant fire brigade and emergency search and rescue teams. Fire brigade and emergency medical retraining is required annually. All security officers c e deputized members of the county sheriff's police and mutual aid agreements are in force with off-site law enforcement agencies.

Emergency plan training for security officers covers security plan access for emergency vehicles, accountability, access for the emergency news center and emergency operations center, auxiliary operator security interface, and search and anti-sabotage procedures. Security officers also receive instruction in the use of health physics instrumentation and can be assigned the task of site boundary monitoring. Course content of security responsibilities associated with the station emergency plan also include security events associated with classification and actions required for notification. All security officers are required to requalify annually. Training records, test scores and security progran activity records are maintained by the Security Department.

Based upon the above review, this area is acceptable.

3.6 Shift Staffing and Augmentation The following documents were reviewed: Emergency Plan, Section 8;

" Emergency Call-in Method", dated April 10, 1987; various department call-in method memo's; Duty and Call Officer procedure and list; and the Emergency Assistance Personnel List.

The emergency response organization (ERO), both on-shift and augmentation personnel, are adequately described in the Emergency Plan. The ERO is trained and has a sufficient depth of personnel to be abic to support protracted operations. The licensee utilizes a combination of pager system notifications and subsequent telephone call-outs. The licensee conducts a call-out drill annually. The results of the August 15, 1986 drill indicated that the licensee would have been able to meet their minimum staffing requirements. The drill was announced and did not include actual augmentation to verify response times. During the drill there was a fifty percent failure rate in the pager response (14 of 28 responded). A review of the weekly pager tests (conducted by the I&C Department on one paper) from January 1987 to present revealed a fifty percent failure rate. There is no criteria established as to what constitutes an acceptable test of the pager system.

Additionally, the validity of the test is questionable as only one pager in the system is verified. There are no apparent controls or procedures for pager testing. Although the test consists of

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activation of all the pagers no follow-up is conducted of individuals required to carry pagers to see if each individual pager activated.

Follow-up of problems identified in the weekly tests and corrective actions are not evident. All aspects of notification are performed, however they are contained in several procedures and department call-out lists.

This can result in confusion as to ERO assignments and additionally, there is no review mechanism for the EPC.

In spite of annual tests which the licensee uses as an indication of satisfactory augmentation capability, based upon the performance results of the weekly pager tests, the lack of validation criteria for test results and augmentation times, and the lack of an overall procedure for the notification of the ERO, the inspector expressed a concern regarding the licensee's ability to staff the emergency response organization in a timely manner. The licensee is reviewing this area for appropriate corrective action. This is an unresolved item (UNR 50-271/87-07-02).

3.7 Protective Action Decision-making The following documents were reviewed: OP-3511, "Off-site Protective Action Recommendations"; OP-3513, " Evaluation of Off-site Radiological Conditions"; and OP-3503, " General Emergency".

The licensee has 24-hour capability to assess and analyze plant conditions and make appropriate recommendations to off-site authorities. The Shift Supervisor / Plant Emergency Director makes the initial protective action recommendation (PAR). These PAR's can be based upon plant conditions or projected dose and are based upon EPA guidance. In the event release rate information is not readily available, default release estimates are contained in the procedure. Subsequent PAR's and updates are made by the TSC or EOF staff when activated.

Based upon the above review, this area is acceptable.

4.0 Exit Meeting The inspector met with the licensee personnel denoted in Section 1 at the conclusion of the inspection. The licensee was inforaed that two unresolved items were identified. The inspector also discussed some areas for improvement. The licensee acknowledged the findings and agreed to evaluate them and institute corrective actions as appropriate.

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