ML043490156
| ML043490156 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 12/07/2004 |
| From: | Shadis R New England Coalition |
| To: | Reyes L NRC/EDO |
| References | |
| 2.206, G20040831 | |
| Download: ML043490156 (7) | |
Text
I EDO Principal Correspondence Control FROM:
DUE: 01/14/05 Raymond Shadis New England Coalition EDO CONTROL: G20040831 DOC DT: 12/07/04 FINAL REPLY:
Reyes, EDO FOR SIGNATURE OF :
- GRN CRC NO:
Dyer, NRR DESC:
ROUTING:
2.206 - Degraded Emergency Notification System at Vermont Yankee Nuclear Power Station DATE: 12/10/04 Reyes Virgilio Kane Merschoff Norry Dean Burns Zimmerman, NSIR Collins, RI Cyr, OGC Skay, NRR Goldberg, OGC ASSIGNED TO:
NRR CONTACT:
Dyer SPECIAL INSTRUCTIONS OR REMARKS:
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Raymond Shadis 207-882-8013 P. 2 New England Coalition I--
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>OS'T' OFFICE: BOX r545. BlRATlT'lIl3L3ORO. VERMONT 05302 on Nuclear Pollution By U.S.Mail, FAX [301-415-2700J and by e-mailflarlnrc.govJ December 7. 2004' Mr. Luis A. Reyes Executive Director for Operations Mail Stop 016E15 1U.S. Nuclear Regulatory Commission Washington, DC 20555
SUBJECT:
REQUEST FOR EXPEDITED NRC ACTION UNDER 10 CFR 2.206 TO ADDRESS DEGRADED EMERCENCY NOTIFICATION SYSTEM AT VERMONT YANKEE NUCLEAR POWER STATION (DKT. 50-271)
Dear Mr. Rcyes As you are aware, NRC has recently cited Entcrgy Nuclear Vermont Yankee Power Station for failure to keep complete and accurate records with respect to members of the public purportedly served by the station's emergency warning system.
Of much greater importance is the fact that presently physical components or the public warning system arc inoperable. This system depends. in large part, upon special radio receivers that are set to alarm on signal in the event of an emergency pending, or actual radiological release.
To our best knowledge only the Vermont towns of Vernon and Brattleboro utilize emergency warning sirens.
Remaining towns within the Emergency Planning Zone ("EPZ') all rely on cmcergency alert radios. Those towns include: Vermont towns of Guilford, Halifax, and Dummerston, and Marlboro; New Hampshire towns of Chesterfield, Hinsdale.
Winchester, Richmond, and Swanzcy; and Massachusetts towns of Lcyden.
Bernardston, Gill. Northfield, Warwick, Colrain, and Greenficld.
Recently residents of the EPZ have drawn our attention to the fact that many radios, if not most or all radios. are not working, are not receiving or annunciating a periodic test signal. and lack simple, inexpensive contemporary reliability and safcty EDO -- G20040831
Raumond Shadis 207-882-8013 P.
3 NEC 2.206 December 7. 2004 Page 2 features. Ncws of this situation has ben confirmed by Vermont's Emergency Management Agency. which adds that the problems are perennial, in some cases intermittent, mid so far without solution.
Noticc New England Coalition herein notifies NRC that EntergyNuclear's Vermont Yankee Powcr Station public warning system is not operable and cannot at this time pass minimum standards of operability under 10 CFR 50, Appendix E, § (D)', (E), and other applicable regulation. The public warning system certainly is not in any condition where, in the event of an accident, public safety could be adequately assured. If an accident resulting in a large early release of radionuclides where to take place today, there would be no way to give timely warning to a significant number of FP7Z residents.
Repeated failures over time of both physical components and human performance in the area of emergency response/emcrgcncy notification at Entergy Nuclear Vermont Yankee arc cumulatively sufficient for a detcrmination that Entergly Nuclear's Vermont Yankee Power Station is operating without a functional Emergency Response Plan and that there are serious systemic Ilaws in licensee management and operations. These summary statements of notice arc further discussed below.
Rcqucst for Action New England Coalition, a non-profit membership organization incorporated in the State of Vermont, now requests under provisions set forth in the Code of Federal Rcgulations (10 CFR 2.206). that the U.S. Nuclear Regulatory Commission act immediately to restore reasonable assurance of adequate protection of public heath and safety that is now degraded by the failure of emergency public warning systems. which may be lband described in Entergy Nuclear Vermont Yankee Power Station Emergency Response Plans as required under 10 CFR 50.47 (b). 2
- 10 CPR S0. Appendix F. ()) statcs, - The design objective of the prompt public notification system shall be to have the capability lo essentially complete the initial notification of the public within the plume exposure pathway EPZ within about 15 minutes. Thc use orf his notification capability will rangc from immediatc notification (within 15 minutes of the time that Statc and local offlcials are notified that a situation exists requiring urgent action) to the morc likely cvcnts where a more substantial amount oftimc is available for the State and local government officials to make a judgment whethcr or not to activatc the notification system."
2 New England Coalition is aware of the four month period allowed for the correction of emergency plan deficiencies in I OCFR 50.54(sX2), however, based upon Information and bclicf, wc assert that Entergy Nuclear Vermont Yankee has been aware this Vystcm and component failure, as well as the encompassing
Raumond Shad is 207 -882-801 3 p. 4 NIC 2.206 Dtcembcr 7,2004 Page 3 Specifically, Ncw England Coalition requests. for the avxwe siated reasons and on the basis of information set forth below, that until such time as the licensee has provided a workable emergency warning or alert system and NRC has verificd its operability. NRC order cold shutdown of the Entergy Nuclear Vermont Yankee reactor and/or take other such action as is within NRC's discretion to restore reasonable assurance of adequate protection of public health and sarety.
- Also, New England Coalition asserts, upon information and belief that the licensee has cstablished in reccnt years an extremely poor record in the area of emergency response with wholly inadequatc quality assurance, root-cause analysis. and corrective action following procedural, human error, and system failures. For example, the most recnt emergency exercise was shot through with organizational and communications failures that duplicated those of the previous cxercise. During the April 2004 transformer fire, operators displayed a shocking unfamiliarity with use of the dedicated emergency notification telephones; ultimately abandoning them to use ordinary phones. In another recent instance, an cmergcncy transmitter generator was inadvertently activated when a utility lineman disconnected power supply lines. The generator then ran until partially filled fuel tan;ks were exhausted; all without being detected by the licensee.
We believe that the perennial and widespread nature of these many failures would lead any competent rcvicwer to reasonably conclude that the origin of these failures is systemic.
- Therefore. New England Coalition also requests that NRC undertake a review of all inspection Findings and licensee documents related to emergency response and notification and take other such other steps as proletssionalism, NRC guidance, and regulation dictate to detennine extent of condition, including, but not limited to. extent of condition as it may affect emergency response, quality assurance, root cause analysis, and the licensee's corrective action program.
The preponderance of evidence shows that Fntergy Nuclear's Vermont Yankee Power Station does not now have an effective and functional Emergency Response Plan, systemic failures since due diligence examination of the plant and plant operations preceding ElnTergy's purchase ofthe plant in July, 2002.
Ratimond Shadi 2207-882-8013 p. 5 NEC 2.206 December7.2004 Pagc 4 nor has it been able demonstrate an c0lectivc and functional E mergency response plan for morc than two years.
Therefore. New England Coalition requests that the licensee be required to provide for an independent audit of the Emergency Response plan (including its assumptions. methodologies, human and component performance) to determine the extent to which the plan is functional and the degree to which it provides reasonable assurance of adequate public health and safety through all the various gradients of accidents assumed in 10 CFR 50. Appendix E.
By way of example, New Fngl and Coalition respcctfully directs NRC's attention to an August 2, 2002 report of a study on the functional quality of emcrgency repose plans for the Indian Point Energy Center perlonned by James Lcc Witt Associates and commissioned by the State of New York.
Additional Considerations Additionally. it should be noted NRC tolerance of such poor licensee practices, as exhibited by poorly planned and executed emergency plans, cncouragcs poor, and possibly unsafe, licensee practices in general.
In restoring the emergency notification system, irit is decided lo continue with the radio alert systems, certain practicalitics and improvements should be considered.
a Licensee personnel should be periodically test radios in their functional locations and conditions. The burden of checking radio batteries and replacing them falls to the affected public and it is a fact that many people forget to maintain the radios.
Replacement radios should include a "chirp" function, similar to that in smoke detectors, that will warn users when batteries are low.
Rugged weatherproof compact personal alert radios should be provided for those citizens who work in the outdoors.
a Distribution of new alert radios also provides an opportunity, which should be seized, for the distribution of potassium iodide thyroid blocking tablevs and printed emergency instructions.
Perniitting Entcrgy Nuclcar's Vennont Yankee Power Station to continue operation with a seriously flawed Emergency Response Plan is to put the licensee's
Raumond Shadi s 207-882-8013 p.6 NEC 2.206 December 7, 2004 Page 5 convenience and economic well-being in higher priority than the obvious increase in risk to the health and safety of EPZ residents.
Conclusion Of primary interest, is that US NRC takes immediate and decisive action.
If in your opinion, prompt action cannot be taken through the 10 CFR 2.206 process, then Ncw England Coalition urges that the NRC exercise its statutory discretion to halt power operation if emergencey warning system operability cannot be assured and to do so prior to screening New England Coalition's letter for acceptance into the 2.206 process.
New England Coalition now eagerly awaits a response. Please address all correspondence on this matter to my address below.
Thank you for your prompt attention, Raymond Shadis Staff Technical Advisor New England Coalition Post Office Box 98 Edgccomb, Maine 04556 shadiseprexar.com Cc: Chairman Nils J. Diaz, US NRC US Senator Patrick.eahy US Senator James Jelfords US Representative Bernie Sanders Governor James Douglas
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POST OFFICE BOX 545. 131RA1TI' I3BORO, VERMON 1-0-5302 NVuclear POIfAlon0f FAX-6 PAGES, INCLUDING THIS ONE.
12/09/04 MR LUIS A. REYES, EDO USNRC 301-415-2700 FROM. R.SHAD1S 207-882-780 1 Please confirm receipt via c-mail to shadis)prexar.com Thank y Raymond Shadis