IR 05000271/1993024
| ML20058A507 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 11/12/1993 |
| From: | Keimig R, Lusher J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058A503 | List: |
| References | |
| 50-271-93-24, NUDOCS 9312010104 | |
| Download: ML20058A507 (8) | |
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U. S. Nuclear Regulatory Commission
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Region I Docket / Report No.: 50-271/93-24 License: DPR-28 Licensee:
Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Brattleboro, Vermont 05301-0169 Facility Name:
Vermont Nuclear Power Station Inspection:
October 4-8,1993 Inspection At:
Brattleboro and Vernon, Vermont Inspectors:
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J. Lusher, (yherg$ncy Preparedness (EP) Specialist date D. Silk, Emergency Preparedness (EP) Specialist G. Bryan, NRC Contractor (COMEX)
Approved:
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I dale R. *cimig, Ch%f, n%fgency Preparedness Section f
sion of Radia on Safety and Safeguards Areas Inspected i
Vermont Yankee Nuclear Power Station (VY) emergency preparedness (EP) program changes, emergency facilities, equipment and supplies, organization and management control, emergency response organization (ERO) training, staff knowledge and performance, and independent reviews / audits.
Results Overall, the inspectors found proper implementation of the EP program, although some program weaknesses were identified. For example, the inspectors noted discrepancies in document control aspects of the emergency plan and implementing procedures and in the inventories of the j
emergency equipment. Also noted by the inspectors was that while there were a multitude of
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EP-related courses developed and conducted, there were no position-specific training prerequisites for assignment to the Emergency Response Organization. Further, the inspectors j
concluded that the notification process was cuinbersome, which reduced the probability of the
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licensee meeting the 15-minute requirement for notifying the states and local communities within the emergency planning zone of the declaration of an emergency, as specified in 10 CFR 50, -
Appendix E, IV.D.3. Meeting this p'anning standard might be particularly difficult wiien declarations are made from a staff-limited Emergency Response Facility, such as the control room. This conclusion was reinforced by the fact that the last declaration of an Unusual Event made from the licensee's control room exceeded this goal.
No violations of regulatory
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9312010104 931112 DR ADOCK 05000271
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Tnble of Contents l
1.0 Persons Contacted
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2.0 Emergency Plan and Implementing Procedures...................... 2 3.0 Emergency Facilities, Equipment, Instrumentation and Supplies
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4.0 Organization and Management Control........................... 4
5.0 Training
............................................4 5.1 Training Prerequisites...............
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5.2 Notification Process.................................. 5 6.0 Independent and Internal Reviews and Audits....................... 5 7.0 Review of 0 pen Items..................................... 6
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8.0 Exi t M ee tin g........................................... 7
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DETAILS 1.0 Persons Contacted The following individuals were interviewed during the inspection and attended the exit meeting.
G. Bristol, Community Relations Coordinator T. Burda, Stone and Webster Engineering, Corporation, Emergency Planner A. Chesley, Technical Support Training Supervisor E. Porter, Emergency Planning Coordinator D. Reid, Vice President Operations E. Salomon, Senior Engineer, Yankee Atomic M. Schneider, Manager of Communications J. Sinclair, Director, External Affairs R. Wanczyk, Plant Manager P. Harris, NRC Resident Inspector The inspectors also contacted other licensee personnel.
2.0 Emergency Plan and Implementing Procedures The inspectors reviewed changes *o the Emergency Plan (E Plan) and its implementing procedures (EPIPs) made since the last inspection to determine if any adversely affected the emergency preparedness program and whether the changes had been properly reviewed,
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approved, and distributed. That review concluded that the changes made did not decrease program effectiveness.
During the review, the inspector noted the following controlled document problems:
There was no list of effective pages in the emergency plan
Two controlled copies of the emergency plan contained an out of date " contact
list" bound within the plan under a tab, and the list was not sho. a on the table of contents Although referenced in emergency plan text, figure 8.3 and table 8.2 were
missing from each of two controlled copies of the plan and, The heading of the first column of page two of the Emergency Action Level
(EAL) table contained in the emergency plan and the classification procedure is incorrectly titled " Event" (the title should be " Unusual Event").
Section 12.3 of the emergency plan indicates that the plan and associated implementing procedures are to be reviewed annually, During the review of the implementing pmcedures it was noted that some of the review dates on the procedures were every two years instead of annually (i.e. OP 3504: issue date 07/20/92, review date 07/20/94; OP 3510: issue date 01/29/93, review date 01/29/95).
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It was also noted by the inspector that the 10 CFR 50.54(q) reviews were documented and performed by the emergency preparedness staff and the Plant Operating Review Committee (PORC), but there was no formal checklist to ensure that the review was sufficiently thorough to ensure that the effectiveness of the emergency plan was not changed. The licensee agreed to consider developing a checklist.
This program area was assessed as being adequate.
3.0 Emergency Facilities, Equipment, Instnnnentation and Supplies The inspector used licensee procedure OP 3506, Emergency Equipment Readiness Check, to evaluate the completeness and readiness of the licensee's Emergency Response Facility (ERF)
equipment. The inspector completely inventoried the Emergency Operations Facility (EOF),
general Operations Support Center (OSC) material, the OSC site boundary team and Governor Hunt House monitoring kits, the main control room kit, and the entire Technical Support Center (TSC). All equipment and material were available and ready for use. Calibrations were found to be within specification (although one calibration sticker was missing - see below) and battery checks demonstrated operable radiation monitoring equipment.
Several anomalies where discovered through the use of OP 3506. The site boundary kit dosimeter charger battery was low (as identified by the Radiation Protection (RP) technician who assisted the inspector.) The tech subsequently informed the appropriate personnel to initiate correction of the problem. The high range dosimeter rack at the OSC contained a dosimeter with an expired calibration as indicated by the green band rather than a red band. The color of the band indicates which dosimeters are within their calibration period. The inspector questioned several individuals about details of the band, (i.e., what color indicates the current calibration and how long the calibration lasts). The answers were not consistent, indicating that personnel were unfamiliar with the coding process.
The inventory checklist did not specify the number and type of tags included among the position title name tags used by those manning the TSC. Also, the checklist did not specify the number of RM-16 radiation detectors that were to be present. One of the four RM-16s in the.TSC did not have a calibration sticker. The TSC contained a charger for use with the high range dosimeters located in the TSC, but the checklist did not include the charger. In the main control room there was an emergency logbook that also was not on the checklist.
In the EOF, phones 21 and 29 were found to be plugged into their appropriate jacks even though the checklist showed them being in Cabinet #1. While inventorying Cabinet # 7, phones 14 and 15 were found inside the cabinet, contrary to the checklist. Phones 14 and 15 were to be found plugged into their appropriate jack. The Recovery Planning Boards were found in the Site Recovery Manager's (SRM) office instead of the Sprinkler Room. Also noted in the EOF (as well as the other locations that contained potassium iodide (KI) solution) was the absence of a device near the KI to ensure that it was properly dispensed.
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Tne inspector reviewed the monthly surveillance records for control room emergency communications, emergency equipment, and the Brattleboro Memorial Hospital emergency equipment for the past year. The surveillance were well documented and performed on a timely basis.
In conclusion, the ERP equipment was found to be available and in good working order, f
although minor discrepancies with the checklist existed.
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This program area was assessed as being good.
4.0 Organization and Management Control The inspectors reviewed the Emergency Response Organization (ERO) and the Emergency Preparedness staff. The ERO was fully staffed with a minimum of three qualified individuals in each position. The Emergency Preparedness staff remained stable since the last inspection.
The licensee indicated that at of the beginning of 1994, a new person from the Yankee Nuclear Services Division would be added to the staff.
i This program area was assessed as being good.
5.0 Training The inspector reviewed emergency preparedness training lesson plans and examinations, class and drill attendance records, ERO assignments, emergency preparedness and training procedures, and applicable sections of the E Plan.
No operating crew walk-throughs were conducted. Nine interviews were held with individual Plant Emergency Directors (PEDS), TSC Coordinators and EOF Site Recovery Managers (SRMs) to assess their knowledge. To facilitate assessment, each person was presented with essentially the same accident scenario and question set. Emphasis was placed on accident classification and determination of Protective Action Recommendations (PARS). The interviews lasted from 45 minutes to over two hours. A total of 105 classification requirements were presented. Most of the classification decisions were timely. Only one error was made. All PARS were correct. Although it was difficult to extrapolate from the small sample population, it appeared that the greater the time elapsed since the individual had operating shift training, the more difficult the classification decisions became, particularly for the Unusual Event and Alert categories. The inspector concluded that classification training for the TSC Coordinators and
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-SRMs was not sufficiently frequent in those areas and recommended that the licensee consider enhancing their trainin.
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5.1 Training Prerequisites The inspector noted that AP 3532, Emergency Preparedness Organization, assigned the Training Manager the responsibility to implement E Plan guidance and define and conduct the training.
Although a multitude of EP-related courses have been developed and conducted, there were no
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training prerequisites for specific positions in the ERO. The same problem had been noted
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l during a June 1993 QA audit. The licensee stated that this matter would be reviewed.
The licensee's actions in response to this finding will be reviewed in future inspections (IFI 50- -
271/93-24-01).
5.2 Notification Process The inspector found that the process for notifying States within the 10-mile emergency planning zone of the declaration of an emergency was accomplished by repeating three times several i
pages of steps contained in the appropriate procedure (OP 3500, 3501, 3502, or 3503, depending upon classification), once for each state involved in the VY E-Plan. Each State notification was essentially identical.
The form used to document notification was applicable to all classifications, but was found only within the Alert procedure, OP 3501. The inspector concluded that the notification process was cumbersome and decreased the probability of meeting the 15-minute notification requirement specified 10 CFR 50, Appendix E, IV.D.3. Particular difficulty could be experienced when declarations were made from a staff-limited ERF such as the control room. This conclusion was reinforced by the fact that the last declaration of Unusual Event made from the VY control room exceeded this goal. The licensee agreed to review the procedure. The licensee's actions in response to this finding will be reviewed in future inspections (IFI 50-271/93-24-02).
This program area was assessed as being adequate.
6.0 Independent and Interna) Reviews and Audits The inspector reviewed the audits of the EP program for 1992 and 1993, the audit plan and checklist for the 1993 audit, and interviewed the lead auditor for the 1993 audit. The 1993 audit identified that the licensee had no training matrix in place to readily determine required training for ERO personnel. The audit plan and checklist were well prepared and thorough. An interview with the lead auditor found that the he was very experienced and knowledgeable in the area of EP. The remainder of the team consisted of a member with operations experience, another who was an EP director at another plant, and a third with expertise in off-site agency.
interfaces. The audit was planned and performed in accordance with licensee procedure QA-XVIII-2, Audit Program. The observations and recommendations were well documented. No items that were identified in the 1992 audit were identified in the 1993 audit, indicating that the licensee effectively resolved identified items. Licensee management was appropriately informed of the results of the audit. The states (VT, MA, and NH) were sent copies of the executive summary and the portion of the 1992 audit addressing interfaces with off-site agencies. The
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Emergency Planning Coordinator (EPC) indicated that the states disseminated the audit findings to local officials. (The 1993 audit had not been sent to the states as of the end of this inspection.) In conclusion, the audit was performed by individuals independent of the licensee's EP organization, covered the necessary areas, was performed on a timely basis, and the appropriate parties were informed of the audit findings. Thus, the audit met the requirements of 10 CFR 50.54(t).
The inspector reviewed the licensee's tracking system with respect to the EP program. The tracking system status list is printed weekly for plant management attention. The list identifies open items, overdue items, and items closedeut during the current year on a department basis.
Thus, EP progress toward resolving identified items can be monitored by licensee management.
Currently EP has 55 open items (six overdue). Thirty-three items were closed, thus far, in i
1993. The inspector discovered that there was no method available to readily identify and retrieve all EP-related items in the tracking system. EP items could be assigned to other departments (based on the nature of the item) and identified by their codes. Therefore, the tracking system was unable to do a global search and identify all EP items. Thus, there was no method to check the total number of items or their age. Based on a search of EP audits and
NRC EP program inspections starting in 1991, the only items that are not closed and are over a year old are those that will be closed when the NRC closes the item for its tracking purposes.
The inspector also verified that all observations by the licensee pertaining to its 1993 exercise were in the tracking system, indicating the licensee's intent to ensure that identified items are not disregarded.
The licensee invites state and local official to an annual meeting at VY headquarters to review Emergency Action Ixvels (EALs) in accordance with 10 CFR 50, Appendix E, IV.B. The l
meeting includes a review of the EAL classification levels, the licensee's EAL categories, examples of several categories at various classifications, question and answer session, and EP related current events. The meeting concludes with a simulator demonstration in which the state
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and local officials observe the licensee responding to an simulated emergency, making the event declaration, and performing the notifications. The inspector reviewed an approved lesson plan
that was developed for the presentations at the meeting. The meetings are well attended, as l
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evidenced by the 40 attendees at this past September 14th meeting. The inspector confirmed that the licensee is meeting the annual requirement for discussion of EALs with State and local officials.
This program area was assessed as being good.
7.0 Review of Open Items OPEN (IFI 50-271/92-14-01)TSC/CR ventilation systems and TSC shielding. This item will remain open pending disposition by NRC Headquarters.
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CLOSED (IFI 50-271/92-14-02)
Emergency Preparedness has not reviewed LORT scenarios for classification accumcy after each new modification or EAL revision.
Training did not inform the Emergency Preparedness Coordinator (EPC) that Security EP training would be delayed. Plant engineering did not review all operating procedures for changes. Operations Training and Plant Maintenance interface with EP may be inadequate. During this inspection, the inspector verified that the licensee had taken action to ensure that all affected parties were included in respective review chains.
CLOSED (IFI 50-271/92-14-03) concerned four specific indicators that EP training should be strengthened. The E Plan was changed to specify the relationship between SAE/GE and the associated potential for radiological impact on the public, all components of this item have been corrected.
f CLOSED (IFI 50-271/92-14-04) Corrections and improvements to Emergency Action Levels (EALs). The licensee made changes to the specific EALs as discussed in the inspection report.
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8.0 Exit Meeting The inspectors met with the licensee personnel listed in Detail 1.0 at the conclusion of the inspection to discuss the scope and findings.
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