IR 05000271/1990007

Insp Rept 50-271/90-07 on 900716-20.No Violations Noted. Major Areas Inspected:Emergency Preparedness & Partial Participation in Emergency Exercise Conducted on 900718

ML20059D793
Person / Time
Site:	Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date:	08/20/1990
From:	Amato C, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20059D791	List: IR 05000271/1990007 ML20059D788
References
50-271-90-07, 50-271-90-7, NUDOCS 9009070185
Download: ML20059D793 (14)

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U. S. Nuclear Regulatory Commission j Region I )

Report N /90 07 ,

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Docket N :

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License N DPR 28 Licensee: Vermont Yankee Nuclear Power Corporation ~ ,

RD. 5, Box 169 Brattleboro, Vermont 05301 Facility Name: Vermont Nuclear Power Station Inspection Conducted: July 16-20,1990 Inspection At: Brattleboro and Vernon, Vermont Inspectors: [,J. der a 8(M u d / f /P/8

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C. G. Amato,(Emergency Preparedness // date Specialist, Region I G. Arthur, Sonalyyts, I J. W' S5n. yst nc

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Approved by:jW Jdzarus 'let,Jheney Preparedness date J Se ion, Faci t.Rtidiological Safety and Safeg r ranch, Division of Radiatior: Safety and Safeguards Inspection Summary: Inspection on July 16 20,1990 (Inspection Report No. 50 271/90-07)

Areas Inspected: Routine, announced, emergency preparedness inspection and observation of the licensee's partial participation emergency preparedness exercise conducted on July 18,1990. There was limited participation by personnel of the States of New Hampshire and Vermont, and the Commonwealth of Massachusetts. NRC Region I Base and Site Teams participated in the exercise. The inspection was performed by a team of three Region I and NRC contractor personne Results: No violations or exercise weaknesses were identified. The licensee response actions provided adequate protective measures for the health and safety of the public.

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DETAILS 1.0 PERSONS CONTACTED

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The following Vermont Yankee Nuclear Power Corporation (VYNPC), or Yankee Atomic Electric Company (YAEC) staff members attended the exit meeting on July 19,1990 or the supplemental exit on July 20,199 J. Babbitt, Technical Training Instructor, VYNPC

" G. Bristol, Community Relations Coordinator, VYNPC

" T. Burda, Consulting Emergency Planner, Stone and Webster

• A. Chesley, Simulator Training Supervisor, VYNPC

• J. Hawxhurst, Senior Engineer, YAEC

• S. Jefferson, Assistant to the Plant Manager, VYNPC  !

• E. Lindamood, Radiation Protection Supervisor, VYNPC

" W. Murphy, Senior Vice President, Operations, VYNPC J. Morarity, Security Supervisor, VYNPC

• R. Pagodin, Technical Services Supervisor, VYNPC

• D. Porter, Technical Programs Manager, VYNPC

" E. Porter, Emergency Preparedness Coordinator, VYNPC

• D. Reid, Plant Manager, VYNPC

" E. Salomon, Senior Engineer, YAEC '

• M. Schneider, Manager of Communications, VYNPC

" J. Sinclair, Director of External Affairs, VYNPC

• R. Sojka, Operations Support Manager, VYNPC

" M. Sontag, Operations Training Instructor, VYNPC

• R. Wanczyk, Operations Support Supervisor, VYNPC

• G. Weigand, President and Chief Executive Officer, VYNPC

• D. Weyman, Senior Environmental Program Manager, VYNPC

• Denotes those personnel who attended the exercise exit meetin " Denotes those personnel who also attended tne exit meeting for the routine, i

emergency preparedness inspection.

l The inspectors also interviewed and observed the actions of other licensee personnel.

l l 2.0 EMERGENCY EXERCISE The Vermont Yankee Nuclear Power Station announced, partial participation exercise l was conducted on July 18,1990, from 7:00 a.m. to 2:55 p.m. The States of New Hampshire I

and Vermont, and the Commonwealth of Massachusetts participated to a limited degree, degree.

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2.1 Pre-exercise Activities The exercise objectives submitted to NRC Region I on April 19,1990, were reviewed and, following revision, determined to be adequate to test the licensee's Emergency Plan. On May 19,1990, the licensee submitted the complete scenario package for NRC review and evaluation. Region I representatives had telephone conversations with the licensee's emergency preparedness staff to discuss the scope and content of the scenario. As a result, minor revisions were made to the scenario which allowed adequate testing of the major portions of the Vermont Yankee Nuclear Power Station Emergency Plan and Implementing Procedures and also provided the opportunity for the licensec to demonstrate those areas previously identified by the NRC as in need of corrective action. NRC observers attended a licensee ,

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briefing on July 16, 1990. Suggested NRC changes to the scenario made by the licensee were discussed during the briefing. The licensee stated that certain emergency response activities would be simulated and that controllers would intercede in exercise activities to prevent disruption to normal plant activitie .2 Exercise Scenario The exercise scenario included the following events:

' Declaration of an Unusual Event due to an operating basis earthquake sensed on site; i Declaration of an Alert as the result of a failure of the reactor protection system l

to accomplish a required scram (anticipated transient without scram (ATWS)); <

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3. l.oss of both control rod drive pumps; , Main condenser vacuum lost resulting in closure of the Main Steam Isolation l Valves and loss of the turbine condenser as a heat sink; 5. A Site Area Emergency declaration is made due to the ATWS and loss of the main turbine condenser; Use of the residual heat removal system in the torus cooling mode; i Large steam line break inside containment; L

l Rapid depressurization of the reactor cooling system resulting in release of the fission product gap fraction inventory;

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. . Failure of the torus purge valve to close; 10. Declaration of a General Emergency (loss of two out of three fission product barriers with potential loss of the third);

11. Release of the fission product inventory to the environment; and, 12. Closure of the torus purge valve resulting in termination of the releas !

2.3 Activifa Observed l

During the conduct of the licensee's exercist , NRC inspection team members made I detailed observations of the activation and a sgmentation of the Emergency Response *

Facilities and the Emergency Response Org .nization staff and actions of the Emergency Response Organization staff during operation of the Emergency Response Facilitie The following activities were observed:  ; Correct use of control room procedures; Detection, classification, and assessment of scenario events; Direction and coordination of emergency response; Noti.'ication of licensee and Massachusetts, New Hampshire, and Vermont !

! personcel and communication of pertinent plant status information to State 1 personnel; , Communications /information flow, and record keeping; Assessment and projection of off. site radiological dose and consideration of protective actions; Accident analysis and mitigatio .0 CIASSIFICATION OF EXERCISE FINDINGS Emergency preparedness exercise findings are classified as follow .1 Exercisc Strengths Exercise strengths are areas of the licensee's staff response that provide strong rw r-y+- w - - - -p.m ++e -, s

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positive indication of their ability to cope with abnormal plant conditions and implement the emergency plan implementing procedure .2 Exercise Weaknesses Exercise weaknesses are areas of the licensee's response in which the performance was such that it could have precluded effective implementation of the emergency plan implementing procedures in the event of an actual emergency in the area being observed. Existence of an exercise weakness does not of itself indicate that overall response was inadequate to protect public health and safet .3 Areas for improvement An area for impi mcment is an area which did not have a significant negative impact on the licensee's ability to implement the Emergency Plan Implementing Procedures and response was adequate. However, it should be evaluated by the licensee to determine if corrective action could improve performanc .0 EXERCISE OBSERVATIONS The NRC team noted that the licensee's activation of the Emergency Response Organization, Emergency Response Facilities, and use of these facilities were generally consistent with their Emergency Plan and Emergency Plan Implementing Procedure The following strengths, and areas for improvement were identifie .1 Simulator Control Room The following exercise strengths were identifie . The Shift Supervisor / Plant Emergency Director (SS/ PED) displayed excellent command and control. He tracked accident information closely and assigned, or reassigned, personnel to follow-up new developmen . The operators used all required control room procedures promptly and correctl No exercise weaknesses were identifie The following areas for improvement were identifie . Transfer of accident management responsibility should be clarified. The SS/ PED believed he was relieved of this responsibility when the Technical Support Center (TSC) was staffed and activated. Procedures specify this responsibility passes from the SS/ PED to the Duty Call Officer and then to

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the TSC Coordinator (TSCC) whether the TSC is activated or not, provided the TSCC accepts control before TSC activatio . There was no formal turn ov:r of the responsibility for off site notificatio The procedure for this action should be reviewed for clarity and the associated training should also be reviewe .2 Technical Support Center

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The following exercise strengths were identifie . The ad hoc Engineering Support Group (ESG) worked effectively. They maintained on going communication with the engineering staff of the Yankee Atomic Service Division, responded to TSC requests to address specific problems, asked "what i if" questions, and undertook resolution of these question ll 2. The TSC Coordinator directed augmented security patrols to check the switchyard, transmission lines on and visible from the site, and the plant stack l for earthquake induced damag l No exercise weaknesses were identified, l The following xercise areas for improveme.nt were identifie . The responsibility and control for the ad hoc ESG should be proceduralize . The TSC Coordinator should not place priority on continuing staff meetings and delay consideration of new information bearing on plant status. As a :

result of this practice, the recognition of the release pathway was delaye ,

3. Emergency repair team emergency dose approvals were not entered in the TSC log boo i 4.3 Operations Support Center (OSC)

The following exercise strength was identifie '

l L There was good use of the OSC staff. The OSC Coordinator, following each TSC staff meeting, briefed OSC staff member No exercise weaknesses were identifie ,

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The following areas for improvement were i.ientifie . The OSC repair team tracking board was sery cryptic. This board should be expanded to provide additional infoncation such as team mission and results, and cumulative and mission team member dose. The licensee should consider duplicating this board in the TS . OSC staff awaiting team assignment left the Administration building during i periods when a Site Area Emergency and General .

Emergency were in effect to smoke and ea 'l 4.4 Emergency Operations Facility l l

The following exercise strengths were identifie . Support of the Massachusetts, New Hampshire and Vermont representatives 1 was excellen . The dose projection group developed " trigger points"which correlated Protective Action Recommendations with r. tack monitor release rate . The dose projection group undertook "what if" calculations based on a ground release resulting from earthquake induced containment failur No exercises weaknesses were identifie The following areas for improvement were identified.

l 1 Completion of accountability was not poste . Off site monitoring teams should be briefed as to changes in Emergency Action Level classification.

l De escalation versus recovery procedures should be reviewe Exercise Control No exercise strengths or weaknesses were identifie The following area for improvement was identifie . Declaration of a General Emergency may have been delayed in part by a tardy report of an in-plant team inspecting the atmospheric control valve , - . . , . _ .

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Controller action may have been the cause of the dela .0 LICENSEE ACrlONS ON PREVIOUSLY IDENTIFIED ITEMS The following items were identified during a previous inspection. Based on observations  :

made by the NRC inspectors, rmiew of the Hmergency Plan and Implementing Procedures and interviews with Vermont Yankee staff, these items were satisfactorily addressed by the licensee and are close (Closed) 50 271/86-12-02 The licensee's Protective Action Recommendation methodology is not consistent with federal guidance. The inspectors reviewed classification procedure AP 3125,"Emergenci Plan Classification and Action Level Scheme", revision 8 and pending revision 9 and OP 3511. "Off Site Protective action Recommendations", revision :

Declaration of a Guneral Emergency would be baed on plant conditions, barrier breech analysis and projected doses. Declaration of a Geretal Emergency is the entry condition for Figure 1 to OP 3511. A predetermined Protective Action Recommendatian of sheltering in the two closest communities and downwind to f ve miles is made. Further analysis is then required to determine core damage status and the likelihood of containment failure. The licensee, follewing the last emergency preparedness inspection, agreed to modify the flow diagram so ne recommendation would be sheltering or evacuation as appropriate. The inspectors concluded revision 4 to Figure 1 of OP 3511 has been appropriately modified. The irspectors compared the logic of this diagram against <

the guidance of NRC Information Notice 83-28 and NUREG-0654, Appendix 1 and concluded it is consistent with federal guidance and in compliance with the requirement of 10 CFR 50.47(b)(10).

(Closed) 50-271/87-17-01 The Site Area Emergency (SAE) classification for explosions and crash impacts is based on the operating status of undefined " safe shut-down equipment". .

Annunciator loss is the basis for an Alert. The licensee lacks the capability to directly determine the magnitude of an Operating Basis Earthquake and to classify it as an Aler The licensee has added a note to revision 8 of the EALs which refers the operator to Figure 2 4 of the " Vermont Yankee Nuclear Power Plant Safe Shutdown Capability Analysis". This is a satisfactory response. The inspectors noted tha*. Table 21 is a better reference and should be used since it is more system specific. Loss of annunciators

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has been deleted as an SAE basis. The licensee conducted a Sosmic Instrument Study

and concluded that the existing system will be moved to the reactor building and connected to a faster analyzer. Use of this modified system has been included in the ,

operator's training syllabus.

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6.0 OPERATIONAL STATUS OF EMERGENCY PREPAREDNESS (EP)

6.1 Responsibility for the Emergency Preparedness is assigned to the Director of External Affairs. This Director reports directly to the President and Chief Executive Officer of the Vermont Yankee Nuclear Power Corporation. EP is an activity and not an organizational unit. The Emergency Preparedness Coordinator (EPC) is responsible for the operation of this activity and has the de facto status of a manage The EPC reports directly to the Director of External Affairs and may be considered a s:cond level manager. He is supported in this activity by a full time Vermont Yankee staff member with responsibility for Community Relations Coordinatio Additional support is provided by two consultants one of whom is a physician with

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a part time appointment. The Yankee Electric Service Division (YASD) will assign, l J

upon request, one or more of their 11 Emergency Preparedness staff to the site j or executive offices or address problems at their Bolton, Massachusetts offic !

Operations input needed to develop scenarios is provided by the members of the Scenario Development Committee who are licensed Senior Operators. The Plant, through the Radiation Protection Program, maintains all Emergency Response Facilitie The EPC interfaces with the plant, plant security and training as well as governmental representative .2 The disciplines represented by the staff and consultants include health physics, I chemistry, engineering (YASD), operations (scenario committee) and meteorolog With the exception of security and operations, EPP staff have extensive emergency preparedness experience.

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6.3 YASD staff disciplines include operations, health physics, emergency preparedness

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training, meteorology, and off site emergency planing and training. Support efforts may include staff augmentation, scenario development, and participation in drills and the annual exercise. Staff are badged and subject to fitness for duty requirement The Yankee Engineering Support Center is activated during some drills and all exercises and provides support upon request or by exercising their own initiative. This center may provide input for core damage assessment, thermal hydraulics and probabilistic l risk assessment. The primary computer dose assessment methodology, METPAC, is a YASD produc Based on the above review, this portion of the licensee's emergency preparedness program is acceptabl .0 ORGANIZATION AND MANAGEMENT CONTROL 7.1 The organizational structure was discussed in Section 6.1 above. Executives and managers have varying background and experience in emergency preparedness.

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All consider emergency preparedness an essential function and a*e pleased with the program. The program is tracked by participation in drills and exerc.'ses, review of plans and procedures, taff meetings, one-on-one meeti.1gs, review of audit reports and NRC inspection reports, emergency preparedness requalification training, and use of the Commitment Tracking System. All, to varying degrees, interface with governmental official Based on the above review, this portion of the licensee's emergency preparedness program is acceptabl .0 KNOWLEDGE AND PERFORMANCE OF DUTIES (TRAINING)

8.1 Emergency preparadness training is given by the Vermont Yankee Training Department. One technical trainer is assigned to responsibility. An emergency preparedness traini1g interface is maintained. The Emergency Preparedness Coordinator reviewi and approves lesson plans and examinations. The training schedule goal is to conduct training uniformly throughout the year. At this time this is a goal. Training begins in January and normally ends before the annual exercise. Emergency preparedness training takes one of three forms. These forms are: 1) computer based training for annual requalification; 2) function specific-open reference; and 3) stand up lecture with a written examination. Drills are also scheduled. Operations and security have opted to continue with stand up lectures and exams. All Vermont Yankee employees must requalify and complete emergency preparedness specialized training in assigned functional areas. As a result, almost all of the Vermont Yankee staff are qualified for an Emergency Response Organization position. There have been no tescheduling problems. Three senior managers are qualified for the position of Site Recovery Manager (director of the EOF). Fourteen other staff are qualified as TSC and OSC Coordinators. Fourteen training modules have been developed 8.2 Requalification training is given using a series of computer based modules. Each module is followed by a series of multiple choice questions. These questions are constructed to minimize the possibility that the correct answer might be deduced by the process of elimination. The trainee cannot exit a module until all questions have been answered correctly. The computer command "page up" is blocked so a trainee cannot go back to previously presented material. Time to completion is tracked. If a time appears is excessively long, the trainer interviews the trainee ,

and possibly the tramee's supervisor or manage .3 The function specific-open reference training modality was introduced in 149 These open book tests average ten pages in length with in-depth questions. Tests are graded and, as necessary, the instructor debriefs the trainee. Grades are tracked by htmd and by computer and retained. The passing grade is 70%. If this grade i

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l 11 is not attained, the trainee it. required to take a stand up lecture, written examination Cours Based on the above review, this portion of the licensee's emergency preparedness program is acceptabl .0 INDEPENDENT REVIEWS /AUDTIS 9.1 The 10 CFR 50.54(t) audit / review was made by the Quality Assurance group of Yankee Atomic using Yankee Atomic Quality Assurance Procedures. An audit plan was developed, auditors were independent of the program audited, and the adequacy of the licensee /off site interface was evaluated in addition to other program activities. The interface was determined to be adequate and sections of :

the OA report treating this topic were offered to the Commonwealth and the State No deficiencies were identified. Other issues were resolved. The QA report is routinely distributed to Vermont Yankee >.nanagemen Based on the above review, this portion of the licensee's emergency preparedness program is acceptabl .0 EMERGENCY PREPAREDNESS SECURITY INTERFACE 1 Security Officers are radiation worker trained and are respirator trained and fitted. Training also includes emergency response training to insure timely accountability and actions when they are a member of plant emergency teams ,

which carry out search and rescue operations. Security officers activate the call- .

in pager system, and following declaration of a General Emergency, undertake -

radiological surveys along the site perimete .2 All security notifiulons to the NRC are made via the Control Room. The Central Access Station is not radiation hardened and would be evacuated to one of two alternate locations following direction from the Technical Support Center. This direction would be based on survey data. Accountability is done manually. A replacement for Gatehouse 2 where accountability is done is under *

consideration. A computerized accountability system may be considered for

, the new Gatehouse. Security driven emergency preparedness drills have not

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been hel Based on the above review, this portion of the licen.' se's emert . ..y preparedness program is acceptabl .

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1 OFF-SilE ACTIVirlES 1 Public information material is distributed to 25,000 households in the emergency planing zone (EPZ). This material is in the form of calendars formatted to reflect the needs of Massachusetts, New Hampshire and Vermont. As a result, .

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three different sets of calendars are distributed. Government officials review the calendar proofs. Each calendar contains a tear-off card which is to be completed by citizens with mobility impairments. These cards are returned to government officials who update and maintain the special needs data bas In addition, a second publication is also sent to all EPZ households entitled,

" Emergency Planning at a Glance". Posters are sent to institutions, parks, schools, and the civil defe:ise manager for each Town for redistribution. Brochures have ,

also been developed and distributed. Telephone directory inserts for transients

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are not use .2 Frequent interface meetings are held with government officials including an Emergency Action Level review meeting. Meetings were also held with school principles. Ambulance Corp and fire Company personnel have been trained and Letters of Agreement with these organa.ations are current. The licensee participates in emergency planning zone emergency worker training. The medical staffs at the three support hospitals were trained by a medically qualified contracto The Special Needs list is current. An annual press briefing session is held and a briefing packet for the press has been develope .3 Prompt alerting is made using sirens, Tone Alert Receivers (TARS) and route alerting. Twenty sirens are located in 17 Towns in Massachusetts, New Hampshire and Vermont. They are subject to a monthly " growl" test by a contracto Availability last year was 98.5% This availability exceeds US FEMA specification ,500 TARS have been distributed in the form of NOAA weather radios. TARS

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are powered by alternating current with battery back up. Batteries are replaced annually. Emergency preparedness information is sent with each replacement battery. One connuunity places primary reliance on route alerting.

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, Based on the abow twkw, this portion of the licensee's emergency preparedness program is acceptsh! .0 EMERGENCY ACrlON LEVELS AND ACTUAL CIASSIFICATIONS

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1 Five actual Unusual Events were declared since the last routine safety inspectio All were classified correctly and prompt notification made to off site authoritie However one event was conservatively declared when the reactor was shut-

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down and coolant temperature was less than 212 degrees. The basis was drop in vessel water level due to leak. The UE was declared and terminated fise hours after the drop in water level was noted. Had this event met the EAL criteria, the declaration would have been inexplicably delaye I 1 Revision 8, and pending revision 9, to the EAL Table were reviewed. The inspectors called the following comments to the licensee's attentio . Table 21 rather than figure 2-4 in note 8 to revision 8 and notes 7 and 9 in revision 9 should be referenced since it is more system specifi . ALERT wording for Category 4, FIRE, should contain a side note referring the operator to the Vermont Yankee Nuclear Power Plant Safe Shutdown Capability Analysis. This analysis identifies shutdown systems which could be affected by fir . In the General Emergency Column, a note should direct the operator's attention to fuel damage for loss of 2 out of 3 barriers. This note should appear after the following parameters: primary containment radiation levels,drywell pressure, and reactor building area radintion.

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. The -48 inches water level ALERT should be placed in the Coolant Inventory

, Event Categor l 1 LICENSEE CRITIQUE The NRC team attended the bcensee's exercise critique on July 18,1990 during I which the licensee's lead controllers and observers discussed observations of the exercise. The licensee's critique was constructive and thoroug i

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1 EXIT MEETING L

L Following the licensee's self critique, the NRC team met with the licensee's i

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representatives listed in Section 1 on July 18,1990 to discuss findings as detailed in th~is report. The NRC team leader summarized the observations made during the exercise. The licensee was advised no exercise weaknesses were identifie The NRC team also determined that within the scope and limitation of the scenario,

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the licensee's performance demonstrated the capability to implement their Emergency Plan and Emergency Plan Implementing Procedures in a manner that would adequately ,

provide protective measures for the henith and safety of the public. A second exit

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- t 14 o e meeting was held on July 20,1990 to discuss the routine inspection findings. Most of the licensee's representatives listed in Section 1 attended 'Ihe licensee was advised no violations, deviations or unresolved items were identified. The licensee was also

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informed that previously identified items were close ,

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