IR 05000271/1988011

Emergency Preparedness Insp Rept 50-271/88-11 on 880816-18. No Violations Noted.Major Areas Inspected:Emergency Preparedness Program,Emergency Action Levels,Independent Reviews/Audits & Notifications & Communications

ML20205K238
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	09/30/1988
From:	Christopher R, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20205K196	List: IR 05000271/1988011 ML20205K191
References
50-271-88-11, NUDOCS 8811010034
Download: ML20205K238 (7)

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U.S. NUCLEAR REGULATORY C0lHISSION REGION I-

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Report No. 50-271/88-11

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Docket No.

50-271 (

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Licensee:

Vermont Yankee Nuclear Power Corporation

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.Bratt'<eboro, Vermont 05301 h

I Facility Name:

Vermont Yankee Nuclear P;we Station

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Inspection At:

Brattleboro, Vermont Inspection Conducted:

August 16-18, 1988 Inspector:

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R. Keith Christopher, Emergency Preparedness vue

Specialist, FRSSB, DRSS Approved by: /

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W. J arus hief. Emergency date i

Pr ednel ection, FRSSB, DRSS I

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I Inspection Sum < nary: Inspection on August 16-18, 1988 (Report No. 50-271/88-11)

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Areas Inspected:

Routine announced emergency preparedness inspection, i

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Inspection areas included:

Changes to the emergency preparedness program; i

i Emergency Action Levels; inoependent reviews / audits; notifications and l

communications; knowledge and performance of duties (training); and open items I

identified in previous inspection reports.

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'Results: No violations were identified.

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DETAILS 1.0 Persons Contacted

• J. Pelletier, Plant Manager

• R. Pagodin, Technical Services Superintendent

• E. Porter, Emergency Planning Coordinator

• R. Geippardi, Quality Assurance Supervisor

• R. Smith, Vice President, External Affairs-

• W. Deterson, Manager of QA Audits, YNSD

• F. Deal, Plant Training Supervisor

• S. Jefferson, Assist. to Plant Manager

• M. Schieder, Community Relations Coordinator for Emergency Planning J. Babbit, Emergency Preparedness Training D. Labarge, Senior Operations Engineer W. Lindquist, Shift Supervisor W. King, Senior Reactor Operator

• Denotes those present at the exit interview.

2.0. Licensee Action on Previous Inspection Findings During the inspection, the inspectors reviewed the licensee's progress concerning open items identified during previous inspections (Inspection Reports 50-271/87-17 and 50-271/87-07).

The status of these items are as follows.

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

OP 3513, "Evaluatior,of Off-site Radiological Conditions" was revised to include referencing a decision-making flow chart which calls into consideration the option nf imminent /cetual containment failure and plume arrival time when making a protective action recommendation.

However this decision making process is in conflict with OP 3511, Appendix I, "Offsite Protective Action Recommendations" and OP 3505 Figure 1 (General emergency), in that these procedures recommend sheltering only which may not be appropriate based on existing conditions.

The -licensee has agreed to modify these procedures to recommend "shelter or evacuation as appropriate." This item will remain open pending a review in a subsequent inspection.

-(Open) 87-17 01: Emergency Action Levels (EAL's) are not consistent with the guidance of NUREG 0654, Apper. dix 1.

The inspectors reviewed the licensee's EAL's which have been revised to a symptom based EAL configuration, as well as to make the EAL's consisterit with the guidance of NUREG 0654, Appendir 1.

Substantial j

progress has been made in the revised EAL reconfiguration to ensure i

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consistency with NRC guidance and for increased efficiency of use by the operators. However, the following areas require additional evaluation by the licensee:

-The Site Area Emergency classification for explosions and crash impacts

refers to the operating status of "safe shutdown equipment".

It is not clear what equipment is included within the scope of this phrase.

Confusion as to the definition of these terms was also indicated during operator walkthroughs when the operators expressed uncertainty as to what systems fell within the meaning of "safe shutdown equipment" when attempting to make a proper event classification;

-The loss of annunciators as a basis for the declaration of a Site Area Emergency should be deleted; and-The Alert classification for natural phenomenon will likely occur at

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the Operational Basis Earthquaka (OBE).

However the licensee does not

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have the capacity to directly measure the magnitude of the earthquake in order to make this classification in a timely manner.

The licensee has agreed to evaluate these issues. This area will be reviewed in a subsequent inspection, i

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3.0 Operational Status of the Emergency Preparedness Program

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3.1 Changes to the Emergency Preparedness Program As documented in Section 2.0, the licensee has completed a review of the EAL's to ensure that they are consistent with the guidance of NUREG 0654 Rev. 1.

The licensee has also moved the News Media Center to corporate headquarters in Brattleboro, Vermont.

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Emergency Operations Facility is also located at the corporate headquarters. As a result of the pt;sical movement of the Media L

Center, as well as the proximity to the EOF, there should be an overall improvement in Media Center effectiveness. Media Center operations will be reviewed during the annual exercise.

An additional staff position has been added to tne Emergency

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Preparedness Program to address off-site local agency problems and concerns in the EP area.

This permits the EPC to devote moro

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time to the in plant emergency preparedness program, t

Other changes to the emergency preparedress program have been minor and do not affect the overall state of emergency j

preparedness. Any changes to the emergency plan or implementing i

procedures are properly reviewed in accordance with station

procedures and the requirements of 10 CFR 50.54q prior to

implementation.

AP 0028, (Commitment Tracking), has been revised

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to ensure that station procedures which may have a potential effect on the level of emergency preparedness are reviewed by the EPC and tracked to their conclusion.

Based on the above review, this area is acceptable.

3.2 Knowledge and Performance of Duties (Training)

The inspectors reviewed OP-3712, (Emergency Preparedness Training),

as well as lesson plans, overlays, attendance sheets and test results.

The licensee is on a calendar year cycle for training, although the yearly EP exercise is the driving force for completion of the emergency preparedness training cycle.

The training module packages were well organized and sufficient to meet the stated objectives of the modules.

The actual training documentation, while somewhat antiquated in form, reflects that the required EP training is current and properly documented to ensure sufficient depth of trained personnel at all emergency response organization (ERO) positions.

In response to previous NRC comments, the EP training procedures and course outlines are now reviewed by the EPC to ensure conformance with both station requirements and training objectives.

It was noted that by pass examinations which are given as an exception to the routine training module, are not reviewed by the EPC.

The inspectors recommended that these examinations be included in the EPC's review of the training modules. It was also noted that a training matrix, cross referencing ERO position and applicable trainfrg aedules, is nearing completion which will improve the licensee's ability to ensure that all applicable ERO position training is completed in a timely manner.

The inspectors interviewed several individuals selected on a sampling basis from within the ERO including a Senior Reactor Operator and a Shift Supervisor.

Two scenarios were presented to datermine the ability of the individuals to properly detect and classify events and to make appropriate protective action recommendations (PAR). While the operators promptly and correctly assessed the events and made timely PAR recommendations, they expressed a less than clear understanding as to what constitutes "safe shutdo.' equipment" as used in the EAL's under the Site Area Emergency classification for "other hazards and conditions".

See Section 2.0 Based on the above revie5, this area is acceptabl. - _ _ _ _. -_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _

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3.3 Independent Reviews / Audits J

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The Quality Assurance group from Yankee Atomic Power Corporation performed the annual emergency preparedness audit on June 27-July 6, 1988. At the time of this inspection, the audit results had not yet been presented to licensee management for evaluation and follow-up, nor has the licensee had the opportunity to provide the evaluation of the adequacy of the interface with state and local governments to the appropriate representatives of those entitier as required by 10 CFR 50.54(t).

The EPC indicated that this would be accomplished as soon as the report is formally transmitted to licensee management.

The Audit team consisted of two individuals, one experienced in quality assurance and the other in emergency preparedness. The scope of the audit was comprehensive and in conformance with NRC requirements.

Several areas of concern were identified and corrective actions recommended.

Based on the above review, this area is acceptable.

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3.4 Notification and Communications The inspectors reviewed 09 3500 thru OP 3503 which are the implementing procedures for carrying out required actions based on the errergency action level classifications. The licensee's notification and verification requirements within these procedures are consistent with the emergency classification and action schenie. The content of the initial emergency messages to off-site authorities are appropriate; however, OP 3503 (General Emergency)

arbitrarily recommends sheltering as a protective action concurrent with the declaration of the general emergency.

This decision may or may not be an appropriate recommendation depending on overall conditions and could result in misleading or confusing the public if a contrary PAR (i.e. evacuation) is recommended shortly thereafter. The licensee has agreed to review this area.

The inspectors also reviewed the communications phone list in OP 3504 (Emergency Communications), verifying that the contact points are correctly identified and current.

Based on a review of the emergency plan, the inspector also verified that the licensee's principal systems for off-site and on-site communications have redundant / backup power supplies as required by 10 CFR 50.47 Appendix E IV. (8) and that communications with off-site agencies within the plume exposure pathway are tested monthly.

Based upon the above review, this area is acceptabl _ _ _ _ _ _ _ _ - - - -

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4.0 Exit i

The inspectors met with the licensee personnel denoted in Section

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1 at the conclusion of the inspection. The licensee was informed i

as to the status of the open inspection follow-up items.

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inspectors also discussed areas for improvement (such as updated

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training documentation methods and integration of Emergency

Operating Procedures and the EAL's).

The licensee acknowledged l

the findings and agreed to evaluate them and institute corrective

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actions as appropriate.

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