ML20028G411
| ML20028G411 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 01/13/1983 |
| From: | Heider L YANKEE ATOMIC ELECTRIC CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20028G409 | List: |
| References | |
| FYR-83-7, NUDOCS 8302090313 | |
| Download: ML20028G411 (4) | |
Text
Ttlephone (617) 872-8100 TWX 710380u1619 YANKEE ATOMIC ELECTRIC COMPANY 2.C.2.1 FYR 83-7 LLb 1671 Worcester Road, Framingham, Massachusetts 01701
\\. YANKEE Janua ry 13, 1983 United States Nuclear Regulatory Commission Office of Inspection and Enforcement Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Ronald C. Haynes, Director Region I Office of Inspection and Enforcement
References:
(a) License No. DPR-3 (Docket No. 50-29)
(b) YAEC Letter to USNRC, dated December 16, 1982 (FYR-82-118)
Subject:
Proposed Change to Emergency Plan Exercise Concept and Format
Dear Sir:
Introduction We have had a great deal of experience, both pre and post-TMI, with emergency plan exercises.
This experience includes both exercise execution and detailed scenario development and preparation.
The process of scenario development and exercise execution has become increasingly difficult because of the natural desires to maximize realistic in plant technical challenges to licensee emergency response personnel while simultaneously presenting a simulated radiologiu condition for the off-site plume EPZ that meets the desires of local, state and FEMA emergency response authorities. We submit l
there is a fundamental difficulty with this process which needs resolution.
l In the discussions that follow, this difficulty will be explained and a resolution proposed.
Current Exercise Concept Problem As mentioned above, emergency plan exercises have become attempts to l
simultaneously present maximum challenges to all organizations as they perform the emergency response activities specified by their plans.
The fundamental problem is that our attempts to simulate a sequence of system f ailures which pose significant technical challenges for the licensee staff to diagnose and solve are not easily translated into meaningful off-site radiological conditions which challenge state and local authorities.
8302090313 830202 PDR ADOCK 05000029 F
United States Nuclear Regulatory Commission January 13, 1983 Attention:
Mr. Ronald C. Haynes Page 2 4
The exercises we have conducted to date have been structured such that the emergency classification has escalated through each category up to a General Emergency.
The time sequence of the escalation and de-escalation process has been governed by the time line imposed on the exercise process by state and local authorities. This restraint exists so that activation cnd notification in accordance with their emergency plans may be adequately tested, particularly on protective action decision-making and simulated imp l ement a t ion.
Yankee, in conjunction with our offsite authorities, has in the past implemented this well-intentioned process that balances on-site technical and of f-site radiological features. We now feel there is a method available to actually improve the process in a significant fashion.
Problem Resolution In a January 5,1983 telephone conference between Yankee, NRC Region I and FEMA Region 1, we proposed to improve on our past practices. We specifically proposed and discussed an exercise concept whereby the on-site emergency preparedness test is somewhat disconnected from the off-site emergency preparedness test. We explained and mutually critiqued a concept by which off-site emergency preparedness together with. licensee interface and interaction would be tested in an " EOF-Out" exercise.
Similarly, on-site emergency preparedness together with state interface and interaction would be separately tested in an " EOF-In" exercise.
This concept and the merits it offers are described below:
" EOF-Out" Exerc ise In this exercise, the licensee would initiate an emergency condition c la ss i fic ation, plant and company emergency response po sonnel notification, and off-site authority notification.
These actions woald be executed in accordance with emergency implementing procedures from the control room.
The licensee response to this emergency plan initiation would be a staff activation of the EOF, whose principle mission and involvement would be to accumulate and diagnose on-site source term and release information and to deploy off-site monitoring teams for their full range of expected duties. All the information gathered through these efforts together with licensee prognoses of emergency condition mitigation and termination would be continually relayed to our off-site authorities for their use in their plan activation and exercise.
This " EOF-Out" exercise would be fully controlled and observed, as usual, by a licensee-related exercise team.
The control function for this exercise would be performed from the Technical Support Center (TSC) by a controller / observer.
In this way, the TSC-EOF communication arrangements can be exercised and EOF personnel would be taxed, as they would be in an actual eme rgency, from both in plant and off-site directions. This was a point mentioned in the January 5,1983 telecon, and we feel would be adequately addressed in this way.
L
United States Nuclear Regulatory Commission Janua ry 13, 1983 Attention:
Mr. Ronald C. Haynes Page 3 The off-site radiological conditions for this " EOF-Out" exercise could be whatever was desired by NRC, FEMA and the states. There would be no difficulty created with the need for direct connection between off-site radiological conditions and on-site technically-justified radioactivity production and release mechanisms.
This connection has proven to be a very difficult one to' make in the past and will get even more difficult in the future, given the full spectrum of off-site emergency preparedness that FEMA needs to see exercised and evaluated (including ingestion pathway considerations).
" EOF-In" Exercise This exercise would bc primarily an on-site effort, except that the EOF and communication channels from it to State and Federal authorities could be activated. All emergency facilities on site and in the EOF would be fully operational.
The emergency condition simulated would be a technical scenario that involved on-site systems problems and interactions that the licensee emergency response organization would be challenged to diagnose and respond such that the energency condition is termina ted with the plant stablized.
While the technical challenges of this simulation would be executed on-site, the EOF staff would interface for condition diagnosis and prognosis with our state authorities. At a minimum, this interface would consist of information transfer over our established licensee-to-state emergency communication channels.
It could, at the states' option, consist of direct licensee-state interface at the EOF.
Conc lus ion The above represents a resolution of a number of difficulties that all organizations associated with exercises have and will continue to experience in the future. We think the proposal described herein has definite merit and is worth trying. This was the conclusion of NRC and FEMA regional personnel in the January 5, 1983 conversation and was concurred in with enthusiam by the Civil Defense authorities of the State of Vermont and Commonwealth of Massachusetts (the two states associated with the Yankee Plume EPZ) and by New Hampshire (associated with the Vermont Yankee Plume EPZ), in our joint nieeting on Janua ry 6,1983.
Time is of the essence. The planning process for the April 6, 1983 exercise at Yankee must start very shortly. The scenario objectives are due to be formulated and submitted with the next few days. We and all the organizations related to such an exercise would very much appreciate an expedited review and consideration of this new concept and format.
9 1
United States Nuclear Regulatory Commission January 13, 1983 Attention:
Mr. Ronald C. Haynes
- Page 4 We expect you may want to talk to us and possibly FEMA personnel to further explore this description. We stand ready for any further discussion you desire.
Very truly yours,
)
Q N/ Of L. H. Heider Vice President JAM /Imm cc: FEMA-Region I Massachusetts Civil Defense Agency Vermont Civil Defense Agency New Hampshire Civil Defense Agency 1
1 J
i 1
4 f
I l
I i
l 1
3 4
e i
i
-s---v m--v,e
--en---ws---e-v-e,,
.,n----ne-
,--.+-,.4-enan
-e,,.,,-w7g.
_,,-,-y, y-r-pr--+-,-m.mm,>, _ <g m-
-g,------
e,-
er
,v-r,
-