IR 05000271/1997001

EP Insp Rept 50-271/97-01 on 970318-20.No Violations Noted. Major Areas Inspected:Licensee Emergency Response Organization Performance During EP Exercise

ML20140E791
Person / Time
Site:	Vermont Yankee
Issue date:	04/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20140E785	List: IR 05000271/1997001 ML20140E780
References
50-271-97-01, 50-271-97-1, NUDOCS 9704290277
Download: ML20140E791 (11)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

I Docket No: 50-271

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Report No: 50-271/97-01

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Licensee: Vermont Yankee Nuclear Power Corporation I

Facility: Vermont Yankee Nuclear Power Station i

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Location: RD 5, Box 169 Brattleboro, Vermont 05301-0169 Dates: March 18-20,1997 l

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Inspectors: J. Laughlin, Emergency Preparedness Specialist, Region 1 J. Lusher, Emergency Preparedness Specialist, Region i D. Silk, Sr. Emergency Preparedness Specialist, Region 1 J. O'Brien, Emergency Preparedness Specialist, NRR W. Cook, Sr. Resident inspector, Vermont Yankee Approved by: Richard R. Keimig, Chief Emergency Preparedness and Safeguardu Branch Division of Reactor Safety 9704290277 970423 PDR ADOCK 05000271 0 PDR xe

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EXECUTIVE SUMMARY Vermont Yankee Full-Participation Emergency Preparedness Exercise Evaluation Inspection Report 50-271/97-01 This inspection evaluated the licensee's emergency response organization's (ERO)

performance during its biennial full-participaticn emergency preparedness (EP) exercise.

\ The inspectors observed emergency response facility (ERF) staffing, procedure g

implementation, effectivenees of mitigation actions, communications, command and b

control, emergency classificction, offsite notifications, and protective action

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recommendation (PAR) formulatio The overall onsite performance of the ERO was very good. The ERFs were staffed and activated in a prompt manner. Event classifications were correct and timely and offsite

notifications were completed within the required time period. However, the operations crew did not identify the loss of the control room panel annunciators for seven minutes, and subsequently did not realize that one panel was still deenergized when most E annunciator power was restore Facility directors exhibited good command and control. Damage control efforts were g

L appropriately prioritized, and closely tracked. Repair team performance was generally good, but there were some delays in dispatching teams. The Site Recovery Manager (SRM) in the Emergency Operations Facility performed well, which included the issuance o an appropriate PAR within 15 minutes of the General Emergency declaratio Two issues regarding emergency operating procedure (EOP) implementation were identified. One has been identified as an unresolved item, while the second is an inspector follow-up ite The licensee's post-exercise critique was very good, in that it was appropriately self-critical and identified all NRC findings.

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I Report Detai!s l

IV. Plant Support

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P4 Staff Knowledge and Performance Exercise Evaluation Scooe (82301)

I During this inspection, the inspectors observed and evaluated the performance of the licensee's emergency response organization in the biennial full-participation, emergency preparedness exercise by conducting observations in the simulator control room (SCR), technical support center (TSC), operations support center (OSC), and emergency operations facility (EOF). The inspectors assessed the ERO's I recognition of abnormal plant conditions, classification of emergency conditions, ;

notification of offsite agencies, development of protective action recommendations j (PARS), command and control, communications, and the overallimplementation of ;

the emergency plan. In addition, the inspectors attended the post-exercise critique l to evaluate the licensee's self-assessment of the exercise, Emeraency Response Facility (ERF) Observations and Critiaue b.1 Simulator Control Room (SCR)

When the operations crew informed the Shift Supervisor (SS) of the loss of control rocm panel (CRP) annunciators, the SS assumed the duties of the Plant Emergency Director (PED) and declared an Alert condition. The inspectors noted that seven minutes elapsed between the loss of the annunciators and the identification of the loss by the operators. At the time of the loss, the operators were in the process of performing the single loop abnormal operating procedure. When power was restored to the annunciator panels, the operators validated the alarms that appeared, but did not perform a complete annunciator panel test to ensure proper operation. As a result, they did not notice that CRP 9-3, which contains the emergency core cooling system (ECCS) alarms, was still deenergized. This was not identified until about 40 minutes later, four minutes after the reactor was manually shutdown (scrammed). The inspector concluded that the oversight had no negative impact on the outcome of the exercise, but could have been detected in a more timely manner. The State and local notifications of the Alert condition were made within the required time period (15 minutes), and the NRC notification was made within the required one hour time period. The licensee str.ted that the procedure for loss of annunciators would be revised to require an annunciator test when power is lost and subsequently restore The SS exercised good command and control in the SCR. He and the Supervisory Control Room Operator (SCRO) regularly briefed the operations crew on plant status and mitigation actions. Further, the SS promoted effective tecrowork by soliciting the input of his staff and that of the TSC engineering staff in dealing with the situations. He also provided a detailed briefing to the TSC Coordinator (TSCC) and the Site Recovery Manager (SRM) in the EOF before turning over his responsibilities to the SR .

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'The inspector noted good discussions among the PED, SCRO and the operations  !

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crew when bus DC-3 was lost. The loss of DC-3 caused the annunciator loss, and  !

also caused the loss of the main transformer cooling fans, which, by procedure,

, required a manual reactor scram. The loss of +5e cooling fans was not anticipated

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by the scenario developer. Therefore, an exercise controller intervened to prevent ;

the manual scram in order to maintain the integrity of the scenario time-line so that

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]_ offsite objectives could be achieved.

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The SCRO effectively directed' mitigation efforts by coordinating Emergency j Operating Procedure (EOP) implementation. He often consulted with the SS and the j ' TSC staff on the best courses of action and regularly briefed the crew on EOP i l applicabilit J

) Overall, the response and performance of operations crew was good. There was

good teamwork and use of procedures, and personnel consistently used repeat- ,

backs in face to-face communications to ensure clear understandings. There was a professional atmosphere in the SCR, and effective mitigation of the simulated

] accident.

i i b.2 Technical Support Center (TSC)

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following the Alert declaration, the TSC was fully staffed and activated in a timely-

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i thJ Duty Control Officer (DCO) conducted a turnover with the TSCC. The DCO i verified that the OSC coordinator (OSCC) was assigned, the OSC staffed, and that

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the necessary communication pathways and telephone lines were established, prior to being relieved of his initial emergency response duties by the TSC !

. The TSCC exercised very good command and control. His briefings were clear and concise with appropriate emphasis on priority activities. Requests for technical !

l evaluations by the engineering group were clearly communicated and properly  ;

tracked via the status board. Technical evaluation progress reports were thorough j

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j and provided in a timely manner. Contrc! af OSC repair teams was, good, and there

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were frequent status updates of repair team efforts.

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-Simulated accident assessment was good. A dedicated and knowledgeable i individual closely monitored Emergency Action Levels (EALs) for potential evant l escalations. The TSC operations staff closely monitored the SCR staff's EOP usage , .!

and appropriately supported EOP implementatio : Radiological monitoring for plant personnel was appropriate, with proper decision-

making for evacuating personnel when radiation levels increased due to the loss of !

i coolant accident. Repair team activities were properly modified for the known or

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projected radiological conditions and teams were assigned appropriately

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conservative stay times based bn those condition i

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Communications between the TSC and the SCR were good, with a dedicated ope line continuously staffed by an experienced senior reactor operator. Frequent calls via two other dedicated telephone lines facilitated discussions between the TSCC and the SRM, and between the Operations Manager and the S Communications among the TSC staff was good. The TSCC briefed the staff every half-hour and disseminated vitalinformation to support simulated accident mitigation and repair efforts. Use of the Gaitronics system for plant staff updates was appropriate. On a few occasions, the TSC staff prompted the SCR staff to make ,

plant announcements in a more timely manne l l

However, maintaining the status of ECCS and important electrical distribution components was not fully effe'ctive. The inspector determined that the mimic status boards of the ECCS and the electrical systems were not kept up-to-date and did not lend themselves to provide current operational status of equipment. The same observation was made during the 1995 exercise, in neither case did it detract from the exercise but, if corrected, could enhance performance. On a few occasions, equipment status had tc be determined by communication with the SCR ]

instead of by observing the available equipment status boards. In contrast, status boards for repair team efforts, chronology of events, and plant parameter trending were maintained accurate and up-to-date throughout the exercis Overall, the TSC staff provided effective technical assistance to the SCR staff and the SRM. The TSCC appropriately managed the TSC staff and maintained effective oversight of the OSC repair teams and engineering group. The TSC staff team-work and communications were goo ;

b.3 Ooerations Suooort Center (OSC)

The OSC was staffed and activated in a timely manner. Despite the multi-office I layout of the OSC, intra facility communications were good as individuals effectively relayed information by person-to-person and/or telephone conversation Throughout the exercise, there was good command and control in the OSC over activities and personne The performance of repair teams was generally good. The teams were assembled and dispatched in a timely manner. The radiation protection (RP) and technical briefings for the teams were informative. . Some teams directly contacted SCR personnel to obtain last minute equipment status or alarm indications before entering the plant to investigate or repair equipment. The inspectors observed good interaction between teams on one occasion when the egressing 3T1' electrical breaker team debriefed the entering 13 breaker team regarding electrical bus and breaker statu However, there were some delays in dispatching teams. The team that was ,

designated to go to the motor control center (MCC) for the residual heat removal (RHR) 13 valve was detained for several minutes until the team members'

qualifications to wear self-contained breathing apparatus were confirmed. Also, RP

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! 4 l personnel were slow to initiate dose calculations based upon. airborne radiological 1:-

concentrations to determine stay times and/or the need for respirators. This j

[ contributed to the delay of multiple teams, including the one dispatched to the

. MCC. Despite the delays, repair team performance was good, the teams were well L monitored, and RP support was good.

i The command and control demonstrated by the OSC coordinator assistant (OSCCA)

l was excellent. The OSCCA remained cognizant of plant conditions and mitigation

} activities by monitoring to the conference telephcne line and by making direct calls to the SCR or the TSC. The OSCCA was aware of job status and team location i throughout the exercise. Also, the OSCCA was proactive in developing mitigation

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strategies. For example, when the RHR pump sealleak occurred, he prompted the SCR staff to close the suction valve to that pump. When the valve'did not close,

, the OSCCA inquired into _the power supply and the existence of a load shed relay j for the sump pumps in the " corner room" of the reactor building, in an effort to de- i

energize the sump pumps to prevent the spread of contaminated water out of the )

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" corner room" to the waste collector tank in the radwaste buildin l I

i The inspectors observed minor controller and scenario issues. Electrical bus 1 was !

j~ prematurely re-energized when the SCR staff closed the 13 breaker before a repair ,

team identified and repaired the breaker. The SCR and OSC controllers did not j coordinate the simulated breaker repair and closure, however, this had no impact on ;

the scenario. Later in the exercise, radiological data was presented to the RP '

personnel in units of micro-curies per cubic centimeter instead of the usual derived

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. air concentration (DAC) hours. .The RP personnel were accustomed to receiving the data in DAC hours. This required RP personnel to take additional time to calculate doses, which resulted in delaying the dispatch of the team to the RHR-13 valve MCC. However, the inspectors noted that one controller did an excellent job of utilizing spare equipment in the switchgear room to describe the condition of and simulate the repair of the 3T1 breake Overall, the performance of the OSC staff was very good as the OSCCA demonstrated strong command and control and the assembly and dispatch of teams was generally goo b.4 Emeraency Operations Facility (EOF) .

The EOF was efficiently activated 52 minutes after the Alert classification, and the SRM assumed command and control of the simulated emergency. Throughout the exercise, facility management and control was very good. The EOF staff exhibited excellent team work. Congestion and noise in the EOF was controlled wall so as not to adversely impact emergency response. Communications within the EOF were excellent. Staff briefings were given every 30 minute .

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During the exercise, the EOF staff was continually cognizant of plant condition The EOF communicator did an excellent job of obtaining plant information and passing it on to the staff. Graphic displays in the EOF were good and the status boards were maintained with current information. The wiring diagrams, EAL enlargements and computer graphics were well-designed and very useful to the EOF staf The SRM looked ahead to see which EALs were applicable and promptly made the Site Area Emergency (SAE) and General Emergency (GE) classifications, after consulting with the SCR and TSC. Similarly, the SRM proactively evaluated and made the appropriate protective action recommendation (PAR) after the GE declaration. Timely event notifications were made to the States within the plume exposure emergency planning zone (EPZ) and the EOF remained cognizant of protective actions implemented by the State At one point during the exercise, the SRM and TSCC discussed whetner or not to invoke 10 CFR 50.54(x) to deviate from the EOP for altsnate level control to avoid entering the primary containment flooding EOP, which requires containment ventin The EOF staff decided not to invoke 50.54(x) because adequate core cooling could not be ensured. Therefore, the containment flooding EOP was entered. The EOF staff did not conduct additional engineering analysis to determine the margin of safety associated with the core cooling conditions specified in the EOP in order to assess whether adequate core cooling could be achieved. Neither the EOF staff or '

the TSC engineering staff was aggressive in obtaining additional engineering resources to assess the core cooling issue, which would have precluded the need to flood and vent the containment. Overall, EOF performance was assessed as very good, b.5 Dose Assessment Early in the exercise, the licensee performed three "what if" dose projection calculations on the Meteorological Post Accident Computer (METPAC). The radiological assessment coordinator (RAC) performed "what if" hand calculations using the Vermont Yankee nomogram to estimate site boundary radiation readings based on the source term in the containment. However, the METPAC "what if" calculations were performed without increasing the source term to provide an upper I limit for the radiological release which could result from the simulated accident. The l only parameter that was varied was meteorological conditions due to shifting wind l direction and changing stability class. This did not impact the exercis l When the radiological release began, it was immediately detected by the dose assessment team, who began to perform real-time METPAC dose projections every )

15 minutes, track the projected plume, and make appropriate recommendations to 1 the SRM. Good "what if" projections were also made. Additionally, during the l period from release initiation to exercise termination, there was very good i discussion of the radiological conditions, both within and outside the 10-mile EPZ, by the SRM, the RAC, and other dose assessment staff member ,

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. The offsite field monitoring teams were appropriately placed for tracking the plume ,

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there were no major radiological impacts beyond the site boundar !

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Overall, the performance of the dose assessment staff was assessed as good.

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, b.6 Mcensee Exercise Critiaue

- Immediately following the exercise, the licensee began its critique process. Players i and controllers assembled in their assigned facilities and critiqued their exercise

performance. These findings were collected and presented to the NRC on

! _ March 20,1997. This formal critique was assessed as very good. Findings were .

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characterized as strengths or areas for improvement. The critique was appropriately i self-critical and identified all the items identified by the inspector ;

Overall Exercise Conclusions l The licensee's overall performance was very good. The facilities were staffed and ;

activated in a prompt manner. Event classifications were timely and accurate, and '

offsite notifications were completed within the required time period (15 minutes).

Good command and control was observed at all of the emergency facilities. The PAR was appropriate for the existing plant conditions and was timely. There were ,

good discussions of radiological conditions for both within and outside the 10-mile !

EPZ. Two issus concerning EOP implementation were identified that require l further NRC review. The formal critique was appropriately self-critical. ideritified all i NRC findings, and was assessed as very goo l l

P8 Miscellaneous EP issues l l

P8.1 Emeroency Operatina Procedure imolementation:  !

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in response to the exercise scenario, the SCR and TSC staffs implemented the EOPs to mitigate the accident conditions. Late in the scenario, EOP OE-3102, 2/3, ;

'" Alternate Level Control," revision 13, steps ALC/FRI-6 and ALC/FRI-8, directed the ;

operators to proceed to primary containment flooding. The inspector examined the licensee's decision-making and accident mitigation strategies involving the use of this EO ,

At one point in the exercise scenario, the ERO staff had established an injection l l

flow-rate from the core spray system in excess of 6,000 gallons per minute (gpm),

but reactor pressure vessel (RPV) level indication was unreliable due to the high temperature in containment. Because of the 6,000 gpm injection rate and the )

cycling (periodic lifting and reseating) of safety relief valves (SRVs), the operations crew in the SCR determined that there was adequate core cooling, but they were l bound procedurally to proceed through the containment flooding sequenc j

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Containment flooding step ALC/CF-4 in EOP OE-3102,2/3 states, " vent the RPV with the concurrence and assistance of the TSC, defeating isolation interlocks if necessary, using one or more of the following: MSIVs; main steam line drains; HPCI steam line; RCIC steam line - only as required to maintain RPV water level above TAF."

The inspector observed that the ERO staff concluded the cycling SRVs were providing an RPV vent path and that the wording of the EOP step afforded them the latitude to not vent the RPV via one of the four prescribed flow paths.- In addition, the ERO staff concluded that it was better to contain the radioactive liquids within i primary containment than to vent them to the condenser (per step ALC/CF-4), l where they could more easily escape to the environment. The inspector observed ;

that the TSCC, SRM, and SS considered invoking 10 CFR 50.54(x) to deviate from i procedural compliance, but this was rejected because the wording of ALC/CF-4 (i.e., " concurrence and assistance of the TSC") was interpreted by them as

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authority to exercise discretion in selecting the RPV vent path if the TSC did not ;

concur with the prescribed pat l The inspector interpreted this step in the EOP to mean that one or more of the four )

vent paths prescribed should be used, and that TSC assistance and concurrence ,

was necessary to facilitate defeating the isolation logic signals, if needed, and I prepare for the consequences of potential offsite releases of radioactive materia However, the~ decision to credit SRV cycling to accomplish RPV venting appeared to !

be reasonably well-founded, but in conflict with the EOP. Therefore, the staff's I decision to deviate from procedural compliance with EOP OE-3102, step ALC/CF-4 is unresolved, pending further NRC review. (URI 50-271/97-01-01)

A second issue involving EOP usage was the ERO's decision to proceed to primary'

containment flooding and the associated technical evaluation for this decision performed by the TSC engineering group. Once flooding is initiated, the primary containment level is unknown until the level alarm setpoint is reached (87.5 feet, reset at 82.1 feet from torus bottom invert). Therefore, the TSCC tasked the engineering group with providing a reliable means to convert the drywell pressure indication to primary containment flood level. During this process, the engineering staff found that drywell pressure may exceed the torus rupture disc setpoint (59 i

~ 3 psig) before the EOP requires action to vent primary containment to maintain pressure below the 62 psig design pressure limi The torus bottom invert (217 ft.) experiences the highest primary containment pressure due to the additive effect of the torus, and potentially flooded drywell water column. For example, with water level in the primary containment at the top of active fuel (296 ft. elevation), the water head (pressure) on the torus bottom invert _would be approximately'34.21 psig. Thus, a drywell pressure gauge (298 f elevation) reading of greater than 27.79 psig (monitoring the airspace pressure in the containment) may result in exceeding the primary containment design pressure (i.e.,34.21 psig due to water head + 27.79 psig airspace pressure = 62 psig, the design pressure limit). In addition, the torus over-pressure protection rupture disc is located at the 249 ft. elevation and has a setpoint of 59 i 3 psig. If submerged

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due to containment flooding, the rupture disc could actuate before the EOP directs containment venting, particularly if the setpoint were at the lower end of the allowed tolerance band (i.e., 59-3 = 56 psig). The licensee initiated an Event Report (No. 96-0273) to document and investigate this issue. The inspectors concluded that the engineering staff's review was excellent in identifying this potential conflict between the EOPs and plant design setpoints. The NRC will review the results of the licensee's investigation, when completed. (IFl 50-271/97-01-02)

P8.2 Uodated Final Safety Analysis Report (UFSAR) Review A recent discovery of a licensee operating its facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures, and/or parameters to the UFSAR or the emergency plar.. During this exercise, the inspectors observed the licensee's compliance with the Plan regarding ERO structure, facility activation and usage, classification of simulated events, and notification of offsite agencies. No discrepancies were note P8.3 In-Office Review of Licensee Procedure Chanaes An in-office review of revisions to the emergency plan and its implementing procedures submitted by the licensee was completed. A list of the specific revisions reviewed are included in Attachment 1 to this report. Based on the licensee's determination that the changes do not decrease the overall effectiveness of the emergency plan, and that it continues to meet the standards of 10 CFR 50.47(b) and the requirements of Appendix E to Part 50, NRC approval is not -

required for those changes. Implementation of those changes will be subject to inspection in the futur V. Manaaement Meetinas X1 Exit Meeting The inspector preser.ted the inspection results to members of licensee management at the conclusion of the ir.spection on March 20,1997. The licensee acknowledged the inspectors' finding'L

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. 9 PARTIAL LIST OF PERSONS CONTACTED l.

l Licensee

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R. Barkhurst, President and CEO, Vermont Yankee j K. Bronson, Operations Manager

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T. Burda, Emergency Planner, Stone and Webster

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M. Desitets, Radiation Protection Manager

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F. Englebracht, Acting Director, Public Affairs i B. Finn, Training Manager

! M. Krider, Training Support Supervisor

R. Marcello, Director Environmental Engineering, Yankee Atomic Electric s

G. Morgan, Security Manager

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D. Reid, Vice President, Operations

E. Salomon, Senior Emergency Planner, Yankee Atomic Electric  !

S. Schaltz, Vice President, Yankee Atomic Electric R. Sojka, Licensing Manager R. Wanczyk, Director, Safety and Regulatory Affairs INSPECTION PROCEDURES USED 82301: Evaluation of Exercises for Power Reactors 82302: Review of Exercise Objectives and Scenarios for Power Reactors .

ITEMS OPENED, CLOSED, AND DISCUSSED Opened 50-271/97-01-01 URI deviation from EOP compliance 50-271/97-01-02 IFl potential to exceed containment design pressure

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LIST OF ACRONYMS USED ALC Alternate Level Control CRP Control Room Panel DAC Derived Air Concentration DCO Duty Control Officer EAL Emergency Action Level ECCS Emergency Core Cooling System EOF Emergency Operations Facility EOP Emergency Operating Procedure EP Emergency Preparedness EPZ Emergency Planning Zone ERF Emergency Response Facility ERO Emergency Response Organization GE General Emergency GPM Gallons Per Minute HPCI High Pressure Coolant injection IFl Inspecto' Followup Item MCC Motor Control Center METPAC Meteorological Post Accident Computer MSIV Main Steam Isolation Valve NRC Nuclear Regulatory Commission OSC Operations Support Center )

OSCC Operations Support Center Coordinator j OSCCA Operations Support Center Coordinator Assistant j PAR Protective Action Recommendation l PED Plant Emergency Director RAC Radiological Assessment Coordinator l RCIC Reactor Core Isolation Cooling RHR Residual Heat Removal i RP Radiation Protection i RPV Reactor Pressure Vessel )

SAE Site Area Emergency  !

SCR Simulator Control Room l SCRO Supervisory Control Room Operator SRM Site Recovery Manager l SRV Safety Relief Valve SS Shift Supervisor TAF Top of Active Fuel TSC Technical Support Center TSCC Technical Support Center Coordinator UFSAR Updated Final Safety Analysis Report URI Unresolved item l

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ATTACHMENT 1 I

Emergency Response Procedures Reviewed

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l Document Document Title Revision

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OP 3500 Unusual Event 17 OP 3501 Alert 18 OP 3502 Site Area Emergency 30 OP 3503 General Emergency 32 1 i OP 3505 Emergency Preparedness Exercises and Drills 19 )

OP 3510 Offsite & Site Boundary Monitoring 22 l AP 3532 Emergency Preparedness Organization 5 4 OP 3712 Emergency Plan Training 13 ;

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