ML20055B500
| ML20055B500 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 06/28/1982 |
| From: | Crocker H, Eklund S, Essig T, Mckenna T, Palmiter C, Sakenas C, Stoetzel G, Terc N, Zalcman B Battelle Memorial Institute, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20055B474 | List: |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 50-029-81-20, 50-29-81-20, NUDOCS 8207220428 | |
| Download: ML20055B500 (42) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No.
50-29/81-20 Docket No. 50-29 License No. DPR-3 Priority Category C
Licensee:
Yankee Atomic Electric Company 1671 Worcester Road Framington, Massachusetts 01701 Facility Name:
Yankee Nuclear Power Station (YNPS)
Inspection at:
Rowe, Massachusetts Inspection conducted: December 1-9, 1981
/o / M [ & -
Team Members:
Thomas J. McKe'nna, EPLB,gEP '
C /
Appraisal Team Leader Sharyn Eklund, EPLB, DEP Cheryl A. Sakenas, DEPOS, RI Barry Zalcman, EPDB, DEP Gregory L.' Stoetzel, Battelle NN Laboratories Thomas H. Essig, Battelle NN Laboratories Claire C. Palmiter, Battelle NN Laboratories Reviewed by:
M
[S/&
N Nemen M. Terc,l eniof Radiation
'date sighed Specialist, DEPOS, RI Approved by M
[O/Y/N H. W.' Crgcker, ef, Emergency Preparedness date signed Section, DEPOS, RI L
i 8207220428 820630 PDR ADOCK 05000029 i
G PDR
TABLE OF CONTENTS Page
SUMMARY
iv 1.0 ADMINISTRATION OF EMERGENCY PLAN...............
1 2.0 EMERGENCY ORGANIZATION....................
1 2.1 Onsite Organization.......
1 4
2.2 Augmentation Organization................
3 3.0 EMERGENCY PLAN TRAINING / RETRAINING..............
3 3.1 Program Establishment.
3 3.2 Program Implementation 4
4.0 EMERGENCY FACILITIES AND EQUIPMENT..............
5 4.1 Emergency Facilities 5
4.1.1 Assessment Facilities 5
4.1.1.1 Control Room 5
4.1.1.2 Technical Support Center (TSC) 5 4.1.1.3 Operations Support Center (OSC).....
6 4.1.1.4 Emergency Operations Facility (EOF)...
6.
4.1.1.5 Post-Accident Coolant Sampling and Analysis 7
4.1.1.6 Post-Accident Containment Air Sampling and Analysis 7
4.1.1.7 Post-Accident Gaseous and Particulate Effluent Sampling and Analysis 7
4.1.1.8 Transfer and Storage of Post-Accident Liquid Waste 8
4.1.1.9 Offsite Laboratory Facilities.
8 4.1.2 Protective Facilities 8
4.1.2.1 Assembly / Reassembly Areas........
8 i
4.1.2.2 Medical-Treatment Facilities 9
4.1.2.3 Decontamination Facilities 9
4.1.3 Expanded Support Facilities 10 4.1.4 News Center 10 4.2 Emergency Equipment 10 4.2.1 Assessment Equipment 10 l
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l TABLE OF CONTENTS (Continued)
Page 4.2.1.1 Emergency Kits and Portable Instrumentation 10 4.2.1.2 Area and Process Radiation Monitors 11 4.2.1.3 Non-Radiation Process Monitors....,.
12 4.2.1.4 Meteorological Instrumentation......
12 4.2.2 Protective Equipment 13 4.2.2.1 Respiratory Protection-.
13 4.2.2.2 Protective Clothing 13 4.2.3 Emergency Communications Equipment 13 4.2.3.1 Public Alerting and Notification System..
14 4.2.4 Damage Control Corrective Action and Maintenance Equipment and Supplies 14 4.2.5 Reserve Emergency Supplies and Equipment 15 4.2.6 Transportation 15
- 5.0 PROCEDURES 15 5.1 General Content and Format.
15 5.2 Emergency, Alarm and Abnormal Occurrence Procedures 16 5.3 Implementing Instructions 16-J' 5.4 Implementing Procedures 19 5.4.1 Notification 19 5.4.2 Assessment Actions 20 5.4.2.1 Offsite Radiological Surveys.......
22 5.4.2.2 Onsite (Out-of plant) Radiological Surveys 22 5.4.2.3 In plant Radiological Surveys 22 5.4.2.4 Post-accident Primary Coolant Sampling and Analysis..
23 i
5.4.2.5 Post-accident Containment Air Sampling and Analysis...............
23 5.4.2.6 Sampling and Analysis of Post-accident Gaseous and Particulate Effluents 23 5.4.2.7 Sampling and Analysis of Post-accident 24 Liquid Wastes 5.4.2.8 Radiological and Environmental Monitoring Program (REMP) 25 a
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g TABLE OF CONTENTS (Continued) w-Page 5.4.3 Protective Actions................
25
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5.4.3.1 Rad:ation Protection During T-Emeigencies
-25 5.4.3.2 Evacuation of Owner Controlled Areas..
25 "
5.4.3.3 Personnel Accountability.
26 5.4.3.4 Personnel Monitoring and s
Decontamination 26 5.4.3.5 Ons ite First Aid / Search and Rescue.'s.
27
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5.4.4 Security Durt ig Emergencies 27 5.4.5 Repair and Co*rective Actions 27
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5.4.6 Recovery.....................
27
'i, s s.,
s 5.4.7 Public Information............
28 5.5 Supplementary Procedures
' 28 2,
5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies'...
28 5.5.2 Drills and Exercises........... s 28 29 5.5.3 Review, Revision and Distribution 5.5.4 Audit 29 COORDINATION WITH OFFSITE GROUPS...........,...'
30 6.0 s
6.1 Offsite Agencies
................'.... s 30 6.2 General Public 30 o(
6.3 News Media 30 i
s 7.0 DRILLS, EXERCISES AND WALK-THROUGHS
', 31
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7.1 Program Implementation 31' 7.2 Walk-Through Observations................
-31' 7.2.1 Accident Classification
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31 s
7.2.2 Dose Assessment 32 x '2 7.2.3 Offsite Notification and Protective Action Decision Making 32 7.2.4 Post-accident Sampling and Radiation Protection...............'.....
33 J
i 7.2.5 EOF 33 7.2.6 Offsite Monitoring................
34 8.0 Individuals Contacted.................'...
'35 9.0 List of Procedures Reviewed 36 i ii s
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SUMMARY
The appraisal of the state of onsite Emergency Preparedness at Yankee Rowe involved seven general areas: administration of the Emergency Preparedness Program, emergency organization, emergency training, emergency facilities and equipment, procedures which implement the emergency plan, coordination with 1
of f site agencies, and, walk-throughs of emergency duties.
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The most outstanding single feature of Yankee Rowe, related to emergency plan-ning, was the unshielded containment. Due to the absence of shielding, Regulatory Guide 1.4 type releases into the containment, could result in dose l
rates greater than 1000 R/hr throughout the site.
Such levels of radiation would interfere with co rective or emergency response actions onsite. To prevent this conditio-an early classification of emergencies and a prompt response are essentia,.
This was understood by management and by the onsite operational staff, bu'. was not formally incorporated into their training program.
1 The emergency organization was generally well defined, but augmentation capa-d P'
bilities did not meet the augmentation goals of NUREG-0654.
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The training program was found to be adequate and emergency personnel inter-viewed sho'wed that their knowledge was consistent with their emergency responsibilities, and performed well durino walk throughs.
Emergency facilities and equipment were satisfactory, but some deficiencies were noted (e.g., post-accident sampling).
Implementing procedures and instructions were generally adequate, but deficiencies were identified in several areas (e.g., post-accident 'mpling and analysis; emergency action levels; transmittal of protective acolon recommendations to local officials and public).
The auditors concluded that an adequate state of emergency preparedness existed at Yankee Nuclear. Power Station (YNPS) at the time of the appraisal.
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I 1.0 ADMINISTRATION OF EMERGENCY PLAN 1
4 The auditors reviewed the Emergency Plan for the Yankee Nuclear Power Station (hereafter referred to as the Emergency Plan) and the Emergency Planning Coordinator (EPC) job description, and noted that an EPC was included on the onsite plant staff.
The EPC was made responsible for the development and maintenance of the Emergency Plan and coordination of drills and exercises, but would report to the Training Manager having no direct access to the Plant Superintendent.
The position of EPC was not filled at the time of the appraisal.
Licensee management stated that the previous EPC had left the job several months before i
the appraisal. The duties of the EPC were being performed by the Technical Services Manager and Radiation Protection Manager, who reported to the Technical Director. These managers were on the Plant Operational Review Committee (PORC) and based on discussions with licensee staff, the auditors concluded l
that they were receiving adequate management support.
The Corporate Organization had an EPC responsible for emergency planning as it related to interfaces with State and local offsite agencies. Discussion with the licensee onsite staff indicated that daily contact was maintained with the Corporate EPC.
Licensee management stated that the plant training budget contained funds for EPC training and attendance at appropriate State, Federal 1
and industry meetings, and indicated that the onsite EPC position may be placed under the Technical Directcr, as he was responsible for development and j
implementation of emergency planning measures.
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Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Assign an individual to the position of onsite EPC.
(29/81-20-01)
Provide, administrative mechanisms for the EPC to have direct access to the Plant Superintendent as needed for resolving emergency planning issues.
(29/81-20-02) 2.0 EMERGENCY ORGANIZATION 2.1 Onsite Organization The auditors reviewed Section 8 of the Emergency Plan and emergency implementing instructions OP-3300, OP-3301, OP-3302, and OP-3304 which coordinate emergency I
response actions by plant personnel.
In addition, the auditor reviewed personnel i
lists that specified for each plant employee their normal plant and emergency assignments.
These corresponded to the emergency organization alements shown i
i in the Emergency Plan (Figures 8.2, 8.3, 8.4, and 8.5).
The auditors concluded that most of tne functional areas of emergency response were included in their emergency organization.
Exceptions were:
licensee representation at the offsite EOF; first aid; personnel monitoring; decontamination; and radwaste operation.
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The licensee indicated that on-shift H.P. technicians had been first-aid trained and that personnel monitoring and decontamination of injured indivi-duals would be performed by an Emergency Radiation Control Team.
Radwaste operations fell under the Operations Supervisor in the TSC. The licensee would send a representative to the State EOCs only at their request and this representative would be dispatched from the Yankee Nuclear Services Division (YNSD), of the Yankee Atomic Electric Company (YAEC).
The immediate on-shift emergency organization in the Emergency Plan (Figure 8.1),
states that the Shift Supervisor has the immediate authority and responsibility to initiate emergency actions and to make protective action recommendations off-site, and that he will act as Emergency Coordinator (EC) until relieved by the incoming Emergency Coordinator who will actiwte the EOF. Once onsite, the Technical Support Center (TSC) Coordinator assumes overall control of the emergency response with emphasis on onsite actions until the Recovery Manager arrives. The Recovery Manager is a corporate level officer (either the Vice President of Engineering or the Manager of Operations). Upon his arrival, the Recovery Manager would have the overall responsibility for managing the accident response. However, the responsibilities assumed by the Recovery Manager were not specified, nor was the scheme for informing other members of the emergency organization when the Recovery Manager assumed these responsibilities.
(See Section ?-))
The licensee minimum backshift organization was shown in Emergency Plan Figure 8.1.
The backshift fails to meet the minimum guidelines of NUREG-0654, Table B-1 by the following: one Senior Reactor Operator (SRO); one communi-cator; and one chemistry technician.
The licensee intends to fill the SR0 position by July 1, 1981; but does not intend to supply a Chem Tech, or Com-municator within 30 minutes in accordance with NUREG-0654, Criteria B-5.
A letter dated April 10, 1981 identified, by normal job assignment, the number of personnel living within 15, 30, 45 and 60 minutes from the site and stated that radiological duties expected at the beginning of an accident could be supplied by the current on-shift staff. Since the above letter failed to specify the time required to notify offsite personnel, and their specific emergency functions, the auditors could not perform an evaluation against the augmentation goals of NUREG-0654. The auditors could not find support for concluding that the onshift staff would be sufficient to perform all the actions required during the early time frame-following an accident. An analy-sis of this submittal was made by NRR in a letter dated March 9, 1982.
Based on the above findings, improvements in the following areas are required to achieve an adequate program:
j Perform a study to determine how the intent of the augmentation goals of l
NUREG-0654, can be achieved after the declaration of an emergency.
(29/81-20-03) 1 2
2.2 Augmentation Organization The auditors reviewed Section 8 of the Emergency Plan, and Technical Admini-strative Guideline 12, which specified by name, emergency support personnel to be provided by YNSD.
In addition, the auditors interviewed members of YNSD management including the Radiation Protection Manager and noted that YNSD personnel were located in Framingham, Massachusetts, about a 3-heur drive from the site. YNSD support is coordinated through the Engineering Support Center (ESC) locate.d in Framingham, Massachusetts, and is activated from the Control Room by a pager system.
YNSD augmentation addressed all the major emergency functional areas and the interfaces with onsite emergency centers.
YNSD personnel were assigned to functions according to their work experience.
Licensee personnel would be supported by Westinghouse and INP0 personnel in accordance with the emergency response plans of these organizations.
Twenty-four hour offsite H.P. support was available through the Yankee Mutual Support Agreement from YNSD, Vermont Yankee, and Maine Yankee.
The licensee maintained a list of Vermont Yankee and Maine Yankee personnel and the emer-gency function for which they were qualified. The licensee had not specified criteria for assigning personnel to emergency functions; but indicated that assignments corresponded to normal work experience and were supported by training.
The auditors interviewed personnel who would perform the functions of the Recovery Manager, TSC Coodinator, and Emergency Coordinator, who properly described their roles during an emergency, but showed some confusion concerning who would be responsible for making offsite protective action recommendations once the Recovery Manager had arrived.
Based on the above findings, this portion of the ifcensee's program appears to be adequate, but the following matters should be considered for improvement:
Describe when and how emergency functions (e.g., making protective action recommendations) are transferred to the Recovery Manager. This should include the notification of selected personnel concerning the transfer of au tho ri ty.
(29/81-20-04) 3.0 EMERGENCY PLAN TRAINING / RETRAINING 3.1 Program Establishment The auditors reviewed Section 12 of the Emergency Plan and Procedure OP-3340 and interviewed personnel who developed and implement this procedure (e.g.,
Training Manager, Radiation Protection Manager, and Plant Chemistry Manager).
The auditors determined that the Emergency Plan specified qualification criteria for the key functional areas of emergency response, and annual training / retraining frequencies.
The training program included instructions on all functional areas of emergency activity.
Lesson plans were in place, appeared adequate, 3
and included performance objectives. The training program consisted of lecture material concerning emergency organization authorities and responsibilities, hands-on'use of specific equipment, aids, and applicable procedures. Drills and walk-through were used to evaluate performances, and records were available and well kept.
The auditors notec that while most employees were aware that direct radiation levels from the ccntainment structure would be excessive during a serious accident, and that there was a need for prompt response early during an accident, the training program did not address these issues.
Annual training of support personnel (fire and medical) included basic radiation protection and their expected response. The training for the State authort-ties included infcrmation on source terms, meteorology, and dose assessment.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Provide training to employees on emergency radiation protection considera-tions due to the unshielded containment.
(29/81-20-05) 3.2 Program Implementation The auditors reviewed training records for individuals assigned emergency functions, and interviewed licensee personnel who were listed as being trained to perform various emergency functions.
The auditors determined, from a review of the available training records, that many individuals had been trained in their emergency functions; although some individuals listed as having a primary emergency function had not completed training (e.g., Communications Assistant and Manpower Assistant).
The auditors also found some cases where personnel assigned as backups for various emergency duties had not been trained.
In addition, the licensee had not conducted backshift drills to identify any problems with the augmentation of the on-site organization.
The auditors noted in discussions with emergency personnel, that their training was consistent with that outlined in the plan and procedures. Those interviewed were knowledgeable of their emergency responsibilities and functions.
The auditors noted during walk-throughs that additional training was required for personnel assigned as backup Emergency Coordinators, radio operators at the EOF and monitoring team communications.
In addition, backshift HPs were not trained in the use of the Ge(L1) system, which could delay counting charcoal cartridges; and backshift HPs had difficulties using thyroid nomograms and SCBA packs (See Sections 7.2.1, 7.2.2, 7.2.3 and 5.4.2).
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
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Complete the training of all individuals assigned emergency functions.
1 (29/81-20-06) 4.0 EMERGENCY FACILITIES AND EQUIPMENT 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room The Control Room was located as indicated in the Emergency Plan, and contained updated copies of the Emergency Plan and implementing procedures. Emergency equipment and decisional aids specified in the procedures and Plan were in place and operable.
The Control Room contained the operating staff on duty, the TSC, the Secondary Operations Support Center, and a room for approximately 5 NRC personnel.
The auditors determined that the number of individuals assigned within the Control Room could distract the operators reducing their effectiveness in mitigating the consequences of an accident.
Particulate (HEPA) filters had not been installed in the Control Room complex ventilation system, but in a letter of August 31, 1981, the licensee informed the NRC of its plans to provide a filtration system during the 1982 Fall refueling outage.
Based en the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Complete the installation of the HEPA filters in the Control Psom Complex.
(29/81-20-07)
Limit the number of individuals to the Control Room complex, or provide a mechanism to prevent them from interfering with control room operators j
dur" j emergencies.
(29/81-20-08)
/ 4.1.2 Technical Support Center (TSC)
The TSC was located within the Control Room in the Reactor Engineer's Office, so that personnel could move safely and easily between the TSC and the Control Room. Working space was available for TSC assigned personnel and data displays, records, and communications equipment were adequate. The TSC had the same radiation shielding capability and ventilation system as the Control Room and subject to the lack of a filtration system (See Section 4.1.1.1).
There were no designated commercial telephones available for NRC within the TSC, but operable ENS and HPN extensions were in place.
Radio communications were available between the TSC and field monitoring teams through the Secondary Alarm Station (SAS) located in the Control Room.
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Based on the above findings, this portion of the licensee's program appears to be adequate.
4.1.1.3 Operations Support Center (OSC)
The primary OSC was not located as stated in the Emergency Plan; but was located on the turbine floor.
The secondary OSC was located within the Con-trol Room complex.
The Primary OSC was large enough to accommodate assigned personnel, but did not offer personnel protection due to direct radiation from the containment or from airborne contaminants. The habitability of this area could be determined by an area radiation monitor on the turbine floor. When uninhabitable, assigned personnel would go to the secondary OSC in the Control Room.
The primary OSC i
contained six telephone units.
They could not transmit but only receive information on the plant page system. There were no backup voice communication links between the OSC, Control Room, and the TSC.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Provide backup voice communication links between the OSC, Control Room, and the TSC.
(29/81-20-09)
Modify the Emergency Plan to reflect the proper location of the OSC.
(29/81-20-10) 4.1.1.4 Emergency Operations Facility (EOF)
The EOF was located 2500 ft southwest of the the plant in a frame house, as specified in the Emergency Plan. The alternate EOF (AEOF) was located at the lower Deerfield Hydro Headquarters of the New England Power Company, Buckland, Massachusetts, about 12 miles from the plant.
The EOF was equipped with the appropriate procedures, plans, maps, monitoring equipment, and communications. There was a readout of meteorological data, backup power for lighting and communications, and provisions for counting of samples.
The AEOF had telephone and Nuclear Alert System Communications in place and other supplies, required to activate the AEOF, would be transferred from the EOF using the emergency van. The EOF provided sufficient space to perform all of its assigned functions.
The auditors concluded that the EOF would allow the direction, coordination and evaluation of all licensee's activities during emergencies.
Based on the above findings, this portion of the licensee's program appears to be adequate.
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4.1.1.5 Post-Accident Coolant Sampling and Analysis The auditors noted that the only means available for the collection of post-accident coolant. samples was the normal reactor coolant sample sink, located on the upper level of the Primary Auxiliary Building (PAB).
No modifications (e.g., shielding) had been made to allow reactor coolant sampling using the design basis accident conditions of NUREG-0737.
Based on the above findings, improvement in the following area is required to achieve an adequate program:
Modify the post-accident sampling systems as required to ensure that I
coolant samples can be collected within the exposure limits of NUREG-0737.
(29/81-20-11) 4.1.1.6 Post-Accident Containment Air Sampling and Analysis The licensee's interim containment air sampling system was located in the l
Switchgear Room (immediately below the Control Room) and was tied into the containment hydrogen monitoring system. A gas sample is collected via a septum added to an existing unshielded line.
The Switchgear Room was expected by the licensee to be habitable following a major fuel melt accident. The area was monitored with an Area Radiation Monitor having a local readout.
i Based on the above findings, improvement in the following area is required to achieve an adequate program:
Modify the post-accident containment sampling system as required to ensure that samples of the containment atmosphere can be collected within the exposure limits of NUREG-0737.
(29/81-20-12) 4.1.1.7 Post-Accident Gaseous and Particulate Effluent Sampling and Analysis Stack sampling and monitoring equipment included a three-channel monitor j
(particulate, iodine, and noble gas) used for detecting routine effluent i
activity from the primary vent stack (PVS). All radioactive effluents, with the exception of the steam generator blowdown tank vent, were routed through HEPA and charcoal filter banks (located in the PAB) and then to the PVS. The stack sampling and monitoring equipment was located on top of the PAB and l
would be subjected to high post-accident radiation levels from the unshielded containment.
Based on the above findings, improvements in the following area is required to achieve an adequate program:
Modify the stack effluent sampling system as required to ensure that i
samples can be collected within the exposure limits of NUREG-0737.
(29/81-20-13) i 7
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4.1.1.8 Transfer and Storage of Post-Accident Liquid Wastes The auditors reviewed Section 6 of the Emergency Plan; relevant procedures (see Sections 5.4.2.7 of this report) and interviewed personnel responsible for this area, and noted that sampling facilities had not been modified, nor had a study been conducted for transfering, and storing post-accident liquid wastes.
Based on the above findings, improvement in the following area is required to achieve an adequate program:
Evaluate the need for:
retention, transfer, storage, sampling and analysis of highly radioactive wastes that could be generated as a result of severe accidents. (29/81-20-14) 4.1.1.9 Offsite Laboratory Facilities The auditors reviewed Section 6 of the Emergency Plan, interviewed members of the licensee staff, visited the offsite laboratory facilities during a previous appraisal, and noted that there were provisions for fixed or mobile laboratory facilities to support isotopic analyses of environmental samples.
Laboratory instrumentation was maintained, calibrated, routinely checked and repaired, by the Yankee Atomic Environmental Laboratory, located at Westboro, Massachusetts.
The mobile laboratory can be transported to the site within several hours.
Based on the above finding, this portion of the licensee's program appears to be adequate.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas The auditors noted that the Emergency Plan did not discuss assembly or reassembly areas; but that, the licensee had made provisions for assembly of personnel.
In case of a Site or General Emergency, licensee employees would report to their department areas or, when directed, to the boiler feed pump area, or the Health Physics Control Point.
Instructions for selecting the assembly areas during an evacuation were posted in the Control Room and were based on radiation levels from the containment.
The offsite assembly area was outside the Emergency Operations Facility; but no provisions were made for a remote assembly area.
The assembly area in the boiler feed pump area provided shielding from the containment and ventilation.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Provide remote assembly and reassembly areas.
(29/81-20-15) 8
r 4.1.2.2 Medical Treatment Facilities The auditors reviewed Section 10 of the Emergency Plan, Procedure OP-3305, and interviewed members of the licensee's staff and members of the North Adams Regional Hospital staff. The auditors also inspected decontamination facilities equipment and treatment rooms at the site and the hospital.
The licensee had contract arrangements with the Charlemont Ambulance Service for emergency evacuation of injured or contaminated employees on the site renewed on an annual basis.
In addition, the licensee had contractual arrangements with the North Adams Regional Hospital to care for injured or contaminated employees. The licensee staff stated that there were problems communicating between the ambulance and the hospital.
The auditors inspected the North Adams Hospital treatment room equipment and their methods for storing contaminated liquid / solid waste and concluded that they were adequate.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Improve radio communications between the hospital and ambulance.
(29/81-20-16) 4.1.2.3 Decontamination Facilities The auditors reviewed Section 10 of the Emergency Plan, Procedure OP-3305, held discussions with licensee staff members, inspected the onsite decontami-nation facilities and equipment, and determined that there was adequate instrumentation and decontaminants in close proximity to the onsite medical facility, and at each assembly area.
Procedures for decontamination were found readily available. A source of water was also available as described in the procedures.
There were provisions for replacement clothing and for disposal of solid and liquid waste.
The auditors inspected decontamination kits located at the Health Physics Control Point, and noted that kits had been pilfered or were missing from their assigned location.
Licensee staff members indicated that pilfering of the emergency kits had taken place in the past and the only way to prevent this was to lock the kits in a cabinet.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Provide means for ensuring the availability of emergency decontamination kits.
(29/81-20-17) 9
4.1.3 Expanded Support Facilities The licensee indicated that the only support facilities available for offsite nonlicensee personnel were located at the EOF. The licensee had not conducted a survey to identify other possible locations or other facilities to support
,c.e emergency response.
Based on the above findings, improvements in the following area is required to achieve an adequate program:
Conduct a study to identify expanded support facilities required to process, train, and shelter incoming support personnel. (29/81-20-18) 4.1.4 News Center The auditors toured the news center located in the Oxbow Motel in Charlemont, Massachusetts. The area designated as the main briefing room was large enough to accommodate a sufficient number of media representatives. A public address system and telephones were in service. The licensee had arrangements in place to install additional telephones on demand.
Security functions for controlling access to and from the News Center had not been considered.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provide security for the News Center.
(29/81-20-19) 4.2 Emergency Equipment 4.2.1 Assessment Equipment 4.2.1.1 Emergency Kits and Portable Instrumentation The auditors confirmed that emergency kits, equipment, and supplies were pre-positioned as specified in the Emergency Plan and implementing procedure OP-3325.
Kits were available for:
emergency centers,-road barrier teams, reentry teams, and the three offsite monitoring teams. However, the auditors noted that reentry team kits did not contain any high range (e.g., in the order of -
100 R/hr) survey instruments that would be needed to enter certain plant areas under severe accident conditions.
In addition, only one G-M instrument for surveying personnel was found at the E0F.
A SAM II portable radiation detector was available for counting iodine cartridges.
in the EOF. A unit for heating and purging the charcoal filters was also avail-able. There was another SAM II in the H.P. Control Point. Portable GM and ion i
chamber instruments were available for offsite monitoring teams. Calibrations f
and operational checks were adequate. The auditors found the above instruments to be operable.
There were, however, no means for protecting air samplers from l
inclement weather conditions in the field.
(See Section 7.2.2)
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Based on the above findings, this portion of the licensee's program appears to be adequate, but the following should be considered for improvement:
Include high range survey instruments in reentry team kits; provide additional instruments at the E0F for monitoring personnel; and a method of protecting the offsite air sample monitors from inclement weather (e.g., rain, snow).
(29/81-20-20) 4.2.1.2 Area and Process Radiation Monitors During the appraisal, the auditors noted an ongoing upgrading of the plant radiation monitoring system.
Several monitors described in the plan and procedures for emergency detection, classifica'.on, and assessment were not operable.
These were:
two containment high-range area monitors, the four main steam line monitors and a high range PVS noble gas monitor.
The licensee had an area radiation monitor located in the turbine hall available for a backup to the VC high-range area monitors during accidents.
Backup means involved readings by personnel using a portable survey meter, but during a major accident, high radiation levels from the containment would preclude personnel from obtaining readings.
Area Radiation Monitors (ARMS) that would be relied upon for emergency detection (e.g., turbine hall, main steam line, and high-range noble gas monitors) had ranges consistent with NUREG-0737 and ANSI-N320 (Performance Specification for Reactor Emergency Radiological Monitoring Instrumentation) criteria.
The containment dome monitor had a maximum range of 10" R/hr.
Other ARMS had a maximum range of 10' R/hr.
The auditors noted that ARMS being relied.upon for emergency detection, were located and shielded so that their readouts would not be affected by elevated background radiation levels.
In addition, monitors in use had been certified by the manufacturer to function properly for expected temperature and humidity conditions.
The licensee had conversion factors as needed (e.g. cpm to R/hr, etc.) to perform offsite dose projections.
Two containment high-range monitors were supplied power from the plant's vital instrument bus as required by NUREG-0737 and the power to other process and area monitors would be transferred to the vital bus in case of a power failure.
Calibration procedures for process and area radiation monitors OP-4813, OP-4814, OP-4815, and OP-4816, were available only in draft form. The auditors reviewed such drafts and noted they were adequate.
Based on the above findings, improvement in the following area is required to achieve an adequate program:
Provide backup means for obtaining estimates of high-range PVS noble gas and main steam line releases during severe accidents.
(29/81/20-21) 11 L
In addition to the above findings, the following matter should be considered for improvement:
Assure that calibration procedures for area and process monitors are finalized and that installation of the containment main steam line and high-range PVS monitors is completed.
(29/81-20-22) 4.2.1.3 Non-Radiation Process Monitors The non-radiation process monitors (e.g., in-core temperature, pressure, etc.)
relied on for accident classification as specified in the OP-3400 Emergency Action Levels were available and operational.in the Control Room, and had the required range.
Based on the abeve findings, this portion of the licensee's program appears to be adequate.
4.2.1.4 Meteorological Instrumentation The auditors inspected meteorological instrumentation in place and noted that they provided the basic parameters (i.e., wind direction and speed and an estimator of atmospheric stability) necessary to perform dose assessment.
Data from the primary system was available on analog and digital displays in the Control Room and was readily accessible to the TSC, and the E0F.
All meteorological instruments were operational and calibrated. The licensee's preventive maintenance program consisted of a multi-tiered, graded-set of checks, surveillance, and calibration activities which gave reasonable assurance that appropriate data would be available during emergencies.
The auditors reviewed the maintenance and data reduction programs, and deter-mined that the licensee's meteorological capabilities address the requirements of NUREG-0737, TAP III.A.2 and the criteria set forth in Appendix 2 to NUREG-0654, Revision 1, in adopting the interim compensating measures to Milestone 3.
The licensee had no provisions for an alternate meteorological data source likely to be characteristic of the site vicinity.
Neither the Vermont Yankee meteorological system nor the Albany-NWS station, which would be relied on, had been substantiated as an acceptable alternate data source.
Information regarding severe weather conditions that may impact the site could be obtained by calling the dispatcher.
The dispatcher had the NOAA Weather Wire and access to an alternate-source of NWS data.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Establish a substantiated alternate data source of meteorological infor-mation during accidents.
(29/81-20-23) 12
i 4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection The auditors observed that sufficient numbers of self-contained breathing apparatus (SCBA) and rescue tanks were available for emergency use. The licensee indicated that monthly operational checks were made on all SCBAs.
However, as discussed later in Section 4.2.4, access to SCBAs during severe accident conditions may not be possible in some cases.
J The auditors noted that capability for refilling SCBA devices onsite was available, and if conditions during an accident prevented access to the refilling area, refill tanks could be obtained from the Vermont Yankee site (located 20 miles away).
Air quality, available through onsite equipment', conformed to ANSI 88.2 according to an analysis performed by the licensee.
Full face respirators were available for personnel at the EOF.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.2.2 Protective Clothing The auditors inventoried emergency protective clothing supplies and found sufficient supplies were dedicated to emergency use for personnel onsite and offsite (EOF), and for emergency teams.
Emergency protective clothing supplies for the OSC were located in the Control Room, but were not listed in the Control Room supplies check-list.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Include OSC protective clothing supplies in the Control Room supplies checklist.
(29/81-20-24) 4.2.3 Emergency Communications Equipment The auditors noteo that communications equipment was located as stated in the Emergency Plan and Procedures. There were alarms having specific meanings.
In addition, instructions were available for announcements over the plant's PA system. Alarms were audible in high-noise areas. Appropriate communications to be provided to offsite agencies were available at the emergency centers.
These included the Nuclear Alert System (NAS).
During walk-throughs the auditors found that the NAS was not operable (See Section 7.2.3).
A review of drill and exercise records also showed frequent problems with the NAS.
This communication system was backed up by several microwave telephone ties independently of the local phone system, and had a backup power supply.
As discussed below (See Sections 7.2.2 and 7.2.3), the radio system used for communications between the EOF and monitoring teams had a 4 mile range, and was not operational.
13
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Provide means to ensure higher reliability of the Nuclear Alert System.
(29/81-20-25)
Provide an operational backup radio system for comunicating with che monitoring teams that will have sufficient range to cover the plune EPZ.
(29/81-20-26) 4.2.3.1 Public Alerting and Notification System The auditors observed a portion of the tests of the public alerting system and interviewed the C rporate Emergency Planning Coordinator who was responsible for installing the aublic alerting system.
The system consists of a combination of sirens and tone-alert radios.
Sirens were being used in high density areas and the tone-alert radios elsewhere.
The siren system was being tested during the appraisal and the tone-alert radios were being distributed.
The licensee stated that the system was scheduled for completion by January 1982. The licensee indicated that administrative proce-dures and agreements used to promptly activate the notification system and provide a coordinated (all three states) message to the public was still under -
development.
In addition, as discussed in Section 7.2 of this report, the offsite officials had not finalized the procedures for making protective action decisions and activation of the system in accordance with 10 CFR 50, Appendix E.
The licensee stated that a complete description of the system as installed, and the procedures for its activation, would be submitted to the NRC following its installation and testing.
Based on the above findings, improvements in the following areas are required to achieve an adequate program:
Ensure that State / local officials have the capability to make prompt protective action decisions, (e.g., evacuation), and that they can promptly activate the public alerting system and provide public instruction and direction once a decision has been made.
(29/81-20-27) 4.2.4 Damage Control, Corrective Action and Maintenance Equipment and Supplies The auditors found no dedicated reserves of equipment for maintenance activities (e.g., repair / corrective action tools) that may be required during an emergency.
Equipment routinely in the maintenance shop (e.g. SCBA) could be inaccessible during severe accidents due to high radiation levels from containment.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
14 i'
Provide an adequate location for the retrieval of repair / corrective action tools, supplies and equipment that may be needed during severe accidents.
(29/81-20-28) 4.2.5 Reserve Emergency Supplies and Equipment The auditors found dedicated supplies of sufficient numbers of survey instru-ments, protective clothing, environmental TLDs and other equipment needed to support emergency operations. Supplies were readily available, and controls such as minimum stock levels and periodic verification of stocks were in place to ensure adequate reserves.
In addition, there was access to equipment and instruments of the same type or with equivalent operational characteristics from the Vermont Yankee Power Station. The licensee also had lists of emergency supplies available from Vermont and Maine Yankee Nuclear Power Stations.
Based on the above findings, this portion of the licensee's program appears to be adequate.
4.2.6 Transportation The auditors found one vehicle dedicated to/for transporting emergency equip-ment to the EOF.
The licensee plans to use additional utility or private vehicles for transportation of offsite monitoring teams.
Private vehicles were found equipped for local weather conditions (e.g., snow tires, etc.).
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.0 PROCEDURES 5.1 General Content aad Format The auditors reviewed all emergency procedures and implementing-instructions.
The majority of the procedures clearly specified individuals responsible for the various response actions; however,-Procedure OP-3310, " Evaluation of Radiological Data" involved reading a lengthy discussion to determine who performed the various actions and when their performance was required.
In addition, Implementing Instructions for Site-Area and General Emergencies did not provide a basis on which to recommend protective actions offsite.
Procedures were organized in a step-by-step sequential fashion and check-offs that were included were necessary.
Procedures contained scope, enclosures, references, discussion and caution notes, but Implementing Instructions, did not refer to other more detailed procedures.
Based on the above findings, improvements in the following areas are required to achieve an adequate program:
Review Implementing Instructions to ensure that they contain specific references to other procedures needed to perform specific actions.
(29/81-20-29) 15
.L
._-.m
_s--
)
Revise procedure OP-3310, " Evaluation of Radiological Data" to clearly indicate when each part of the procedure is to be implemented and who will be responsible for its implementation.
(29/81-20-30) 5.2 Emergency, Alarm, and Abnormal Occurrence Procedures The auditors reviewed procedures used by Control Room operators to respor d to alarms and abnormal occurrences and found that all but one of the abnorms.1 occurrence procedures contained only a general instruction to " Initiate OP-3300, Classification of Emergencies", but gave no specific instructions on how to classify emergencies.
The abnormal occurrence procedure used in response to a
" Loss of Coolant," OP-3106, instructed the operator.to declare a General Emergency if the Accident Area Radiation Monitor (AARM) was greater than 500 R/hr and a Site-Area Emergency if the AARM was less than 500 R/hr.
The auditors concluded that a direct classification could also be made in Procedure OP-3053, " Inadequate Core Cooling,"; since, this procedure would be initiated if the in-core thermocouple readings were greater than 650 degrees F.
This condition represents a General Emergency (EAL) if the thermocouple reading is increasing.
There were several other abnormal occurrence procedures such as: OP-3017
" Fire Emergency," OP-3010 " Fire or Force Evacuation of the Control Room," and OP-3109 " Process Radiation Monitor High Radioactivity Level Indicated" that could include specific instructions for emergency classification.
The auditors found that OP-3117, " Refueling Accidents," instructed the user to implement procedures that had been eliminated or renumbered.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following area should be considered for improvement:
Review Control Room emergency alarm, abnormal occurrence procedures to identify and direct emergency classification whenever possible, and to 4
ensure that all references are maintained current.
(29/81-20-31) 5.3 Implementing Instructions The auditors reviewed implementing instructions OP-3301, OP-3302, OP-3303, and OP-3304 for Unusual Events, Alerts, Site, and General Emergencies.
These procedures contained instructions for the Emergency Director, Security, Emer-gency Coordinator, TSC Coordinator, etc., and specified their responsibili-ties.
Specific action levels were also specified.
Emergency Procedure OP-3304 indicated that plant personnel would evacuate to the EOF if the Plant Emergency Director declared a General Emergency with an Accident ARM reading of < 500 R/hr, and plant personnel would be directed to assemble in the Boiler Feed Pump Room for an Accident ARM reading > 500 R/hr.
16
The Boiler Feed Pump Room was used as an assembly area since it was the only (n-site location other than the Control Room protected from containment shine.
Tae implementing procedures, as is discussed in Section 5.1 of this report, did not delineate how or on what basis offsite protective action recommenda-tions were made.
The auditors reviewed Appendix A of the Emergency Plan, Procedure OP-3300, and interviewed personnel who were responsible for the development and use of the EALs.
The following NUREG-0654, Example Initiating Conditions, were not addressed:
Unusual Events 1, 14e, 17; Alerts 6, 14, 19; Site Area 1, 9, 15, 16, 17; and General 3
In addition, the following revisions would be needed to adequately address the guidance of NUREG-0654, Appendix 1.
License EAL Number Comment Unusual Event 4
Add a low subcooling margin indicator.
6 Specify the specific indicator of failure of the valve to close.
10 Revise to include any onsite fire.
Alert 1
Declare the alert based on chemistry results or monitor readings.
The monitor readings can be confirmed by any method that can be accomplished within 15 minutes. However, the method used to confirm the monitor reading must be specified as part of the EAL.
2 Follow the guidance of NUREG-0818 for this condition (Site Area 2, page 50) 4 Follow the guidance of NUREG-0818 for this condition (Site Area 4, page 55) 12 Revise to declare the emergency based on visual observation "or" monitor levels.
13 Revise to declare the emergency if there is a potential to affect the safety system.
17
License EAL Number Comment Site Area 2
Follow the guidance of NUREG-0818 for this condition (Site Area 3, pages 53-55) 4 Follow the guidance of NUREG-0818 for this condition (Site Area 4, pages 56, 57) 8 Provide specific monitor levels (PVS, Accident ARM) that correspond to 500 mR/hr at 1/2 mile under a set of predetermined adverse meteorolog-ical (back calculate) conditions. Provide EALs for the lower limits of the EPA PAGs to include a default release duration for use in determining dose.
General Emergencies
- The auditors found that the licensee needed to:
reorganize General Emer-gency EALs so that the EAls associated with loss of 2 of 3 fission product barriers (e.g., Accident ARM, thermocouple) and those associated with offsite dose rates stand alone and address each of the containment failure modes (e.g., overpressure, failure to isolate, steam explosion).
- Reestablish the Accident ARM level corresponding to a General Emergency (currently 500 R/hr) at a level that indicates conditions may be approaching levels that will restrict plant repair / corrective actions, etc.
- Provide EALs that are indicators of the NUREG-0654, Example PWR Core-melt Sequences. Note these must be early indicators,.before there is core damage; and
The auditors also noted that the EALs in the event classification procedure (OP-3300) were organized such that there was a specific set of EALs for each initiating condition.
This resulted in redundant EAL listings.
For example, all the General Emergency EALs contained in the same listing of the AARM, thermocouple and dose rate EAls. The procedure could be greatly simplified by removing the redundancy. During a Control Room walk-through (see Section 7.2.1 of this report), it was noted that a flow chart could be useful for classifying emergencies.
Based on the above findings, improvements in the following area is required to achieve an adequate program:
18
Revise the procedures containing EALS to adequately address the require-ments of NUREG-0654, Appendix 1.
(29/81-20-32)
In addition to the above findings, the following matters should be considered for improvement:
Revise the event classification procedure to remove redundant listings of EAls.
(29/81-20-33)
Provide the control room with a flow chart to allow for prompt classifica-tion of emergencies.
(29/81-20-34)
S.4 Implementing Procedures 5.4.1 Notification Emergency implementing instructions OP-3301, OP-3302, OP-3303 and OP-3304 provided the sequence of notification to:
alert, mobilize, and augment onsite emergency organizations and supporting offsite agencies.
Procedures OP-3302, OP-3303 and OP-3304 directed the Emergency Director to instruct the Secondary Alarm Station (SAS) Operator to implement applicable sections of the emergency plan call list and designated Control Room personnel to notify the Massachusetts and Vermont State Police agencies via the Nuclear Alert System (or telephone backup).
Based on the classification, the SAS operator would initiate a procedure to activate the off-duty emergency organization.
In addition, a pager system would be activated by the Control Room to notify the emergency organization management.
Paged personnel would then call the Control Room to determine what action was required of them.
In addition a pager system, also activated from the Control Room, would be used to activate corporate (NSD) organizational support.
The following discrepancies were noted:
- The SAS operator (s) indicated that they would be receiving callbacks from the paged emergency response personnel on 2 of 4 Control Room phone lines and that this could tie up limited Control Room phone lines and delay augmentation of the onsite organization.
The SAS operator (s) also indi-cated that the precedure to initiate the telecommunication and NSD paging system was new and untried; furthermore, OP-Memo 2E-5, " Emergency Plan Call List," was not referenced in the implementing procedures.
- For a Site or General Emergency, the initial notification to the State Police, if a radioactive release was projected, recommended only that the public seek shelter. There was no provision to recommend evacuation of people within the plume EPZ or for recommending other actions based on plant conditions.
(See Section 5.1.)
Planned messages and announcements for notifying station personnel and the State Police, were found to be adequate.
19
b i
Evacuation of onsite personnel during an Alert or General Emergency was based 1
I on AARM readings.
Procedures directed initial notifications within 15 minutes l
to the State Police, but did not specify that organizations and individuals responsible for offsite protection action decisionmaking would be contacted within 15 minutes.
Based on the above findings, improvements in the following areas are requirec to achieve an adequate program:
i Hold a meeting between NRC, FEMA and State officials responsible for protective action decision making.
The purpose of the meeting is to discuss protective action recommendations; to develop assurance that the licensee can make protective action recommandations; and to demonstrate 1.
that the State officials have the capability to make a public notifica-tion decision promptly on being informed by the licensee of an emergency condition.
.(29/81-20-35)
In addition to the above, the following matter should be considered for improve-ment:
Revise implementing instructions to reference the call-list contained in OP-MEMO 2E-5.
(29/81-20-36) 5.4.2 Assessment Actions The auditors reviewed Section 10 and Appendix C of the Emergency Plan, and procedures OP-3300, OP-3310, OP-3303, OP-3304, OP-8701, and OP-8741 and inter-viewed personnel responsible for this area.
Procedure OP-3310 gave instructions to assess offsite radiological hazards during an accident, using a system of nomograms for rapidly determining whole-body and thyroid dose rate at 1/2 mile offsite, and included adequate instruc-tions for determining dose rate at distances greater than 1/2 mile using diffusion factors.
During Control Room walk-throughs (see Section 7.2.1) control room personnel used the whole-body dose rate nomogram in a timely manner, but were less familiar with the use of the thyroid dose rate nomogram.
The only thyroid nomogram available in the Control Room was too small, and i
difficult to read.
In addition, meteorological considerations had not been factored into the dose assessment scheme, nor the influence of terrain effects on the potential trajectory of the plume.
There were no provisions for initially estimating integrated doses at offsite locations to include a default release duration.
i Procedures OP-3303 and OP-3304 required that the Shift Supervisor recommend l
"no protective action" or "take shelter" to the State Police authorities i.
within 15 minutes of the declaration of the emergency. After the initial notification, the Emergency Coordinator would be responsible for coordinating protective action recommendations with State authorities, and for updating them.
OP-3303 and 3304 stated that recommendations would be based on in plant indications and/or EPA Protective Action Guides, but there were no criteria on 20
which to base recommendation on plant conditions.
Examples of.such criteria are given in NUREG-0654, Appendix 1 (e.g., loss of physical control of the facility - consider 2-mile precautionary evacuation). During Centrol Room walk-throughs (see Section 7.2.1 of this report), the auditors noted confusion among Control Room personnel concerning the basis for making protective action recommendations. Control Room personnel stated that the State authorities were responsible for making protective action recommendations based on offsite dose rates, supplied by the licensee.
Initial offsite dose rate estimates were based on:
the turbine hall accident area, main steam line, high-range Primary Vent Stack (PVS) noble gas monitors, and the PVS iodine and particulate sampling system, but the main steam line monitors and high-range PVS noble gas monitor were not operable at the time of the audit.
The auditors also noted that backup methods (use of portable survey meter readings) would be inadequate during a major accident due to high exposure rates in the PVS and main steam line area.
Similarly, collection of charcoal cartridges and particulate filters would be prohibited during a major accident.
The licensee had two methods of analyzing charcoal cartridges retrieved from the PVS during less severe conditions--the plant GeLi or Sam II/NaI detector system.
The auditors noted three conditions, during a Control Room walk-through (see Section 7.2 of this report), which could delay analyses of the cartridges:
lack of HP technician training (discussed in Section 3.2 of this report) on the use of the plant GeLi detection system; keeping the NaI detector system off (2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> warm-up required); and insufficient training of HP staff in the use of the noble gas purge system (Section 3.2).
The accident classification scheme used Area and Process Radiation Monitors for initially classifying accidents and escalating them as conditions warranted.
In addition, ARMS would be used to determine personnel access / habitability in various plant locations during an accident.
Procedure OP-3310 provided a general listing of the data required from the radiological environmental monitoring program.
Specific environmental monitoring procedures were found in OP-4802.
Based on the above findings, improvements in the following areas are required to achieve an adequate program:
Revise procedure OP-3310 to incorporate means to compensate for the potential uncertainty associated with plume trajectories.
(29/81-20-37)
Write a procedure and implement for estimating noble gas, radioiodine and particulate releases from the PVS under major accident conditions.
(29/81-20-38)
In addition to the above findings, the following matters should be considered for improvement:
Keep the NaI detector system (SAM-2 RD-22) power on to eliminate any warm-up time.
(29/81-20-39) 21
-- _ - _ _ _ - _ = _.
J i
5.4.2.1 Offsite Radiological Surveys Procedure OP-3311 specified the methods and equipment needed to perform surveys i
and contained a map indicating specific sample locations.
Forms to record survey results were included, but instructions on sample and survey form disposition were not available.
The procedure instructed the user to report survey results via other means if the radio were lost; but failed to indicate alternative means of communicatfor..
In addition, OP-3311 did not consider monitoring techniques to enable the users to determine his location relative to the plume (i.e., whether readings were taken while immersed in the plume, under it or away from it), and where i
to take air samples.
i Based on the above findings, this portion of the licensee's program appears to i
be adequate, but the following matters should be considered for improvement:
Revise procedure OP-3311 to:
specify means for sample disposition (e.g.,
responsibilities, coordination, logistics); specify alternate means of communication; and provide monitoring techniques for ascertaining sampling i
locations relative to the plume.
(29/81-20-40) 5.4.2.2 Onsite Radiological Surveys t-i (and) i 5.4.2.3 In plant Radiological Surveys Procedure OP-3300 addresses radiation protection aspects but failed '.o indicate which instruments should be used.
In addition,'it did not indicate <f air 1
samples would be needed, and did not include survey record forms. Batte ry-operated air samplers and data sheets for air-sampling results, were available.
l Procedure OP-3300 did not make reference to evacuation routes,-nor to methods j
for estimating, based on Control Room instruments, onsite doses for any area outside of the Control Room.
Based on the above findings, this portion appears to be adequate, but the following matter should be considered for improvement:
i Revise a procedure OP-3300 to include:
equipment, survey forms, com-munication methods, and radiation protection guidance.
In addition, 1
provide diagrams showing expected doses in selected areas (e.g., motor control areas, OSC), as a function of the Accident Area Radiation Monitor levels.
(29/81-20-41) l f
i I
i 22
5.4.2.4 Post-Accident Primary Coolant Sampling and Analysis (and) 5.4.2.5 Post-Accident Containment Air Sampling and Analysis Procedure OP-9450 addressed hydrogen sampling and analysis of containment air samples, boron analysis of primary coolant samples, and radioactivity analysis of both types of samples. The procedure was written for use by the chemistry staff and contained radiation protection precautions, prerequisites, coordina-tion with health physics personnel and emphasized proper personnel precautions for sample collection but had no schematic showing the relative position of the valves in the sample train. Color photographs of sample points and asso-ciated equipment and valving were available and required the operation of certain valves in a sequence.
Although procedure OP-9450 did not include sample data sheets, discussions with licensee personnel and the walk-through (see Section 7.2) indicated that supplemental log sheets used had appropriate work sheets attached.
Sample results were not, however, related to Emergency Action Levels (EALs), and prompt notification of results to personnel in charge of making protective action recommendations was not included and made no reference to sample trans-port or to a shielded container.
All samples were counted at a distance of one meter so that each sample could be approximated to a point source. An efficiency curve for this geometry was available for calculating sample activity.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Revise procedure OP-9450 to:
identify the manner in which samples are to be transported to the laboratory and the precautions appropriate during such transport; provide a schematic of valve line-up and indicate the need for a timely relay of results to personnel in charge of making protective action recommendations.
(29/81-20-42) 5.4.2.6 Sampling and Analysis of Post-accident Gaseous and Particulate Effluents Procedure OP-8740 is used when particulate, iodine or noble gas stack monitor readouts in the Control Room are off scale. Although the procedure contained a number of radiation protection precautions, it did not sufficiently emphasize problems associated with retrieving and handling sampling media containing the source terms of NUREG-0737, and under high radiation fields from the unshielded containment. Sample transport devices and sample storage locations were not identified. The means used for: quantifying activity on these samples, selecting appropriate counting geometries and shielding were not identified.
23
f Procedure OP-8740 addressed means for quantifying noble gas releases using the I
interim high-range noble gas monitor to quantify release rates at (or above) 70 Ci/sec.
(See Section 4.2.1.2)
Since the low-range noble gas monitor would go off scale at a release rate of about 0.2 C1/sec, the only means of quantifying release rates available in the range of 0.2 - 70 Ci/sec would be by sample collection. A gas septum had been installed for this purpose, but the auditors noted that the high-range monitor had a local readout that would not be acces-sible during major accident conditions due to high radiation from the unshielded containment. As discussed in Section 5.4.2, the licensee did not have a feasible method of determining iodine release levels under accident conditions.
i OP-8740 made reference to a radiation field of 10 R/hr, for-aborting the taking of samples. This value was inconsistent with the NRC design criterion of 25 R/hr for direct radiation emanating from containment.
4 Procedure OP-8741 entailed measuring radiation exposure rates at certain locations beneath the reactor containment to quantify noble gas releases from t
the secondary side in the event of a steam generator tube failure, but did not elaborate on the location or exposure rates which would be grounds for aborting the mission (e.g., 25 R/hr).
]
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
- Revise procedures OP-8740 and OP-8741 to:
identify the transporting devices for PVS iodine and particulate samples; specify the means of quantifying activity on the charcoal and particulate filters; address l
handling problems associated with highly radioactive particulate and charcoal filters; specify criteria for aborting taking the sample based on information available in the Control Room (e.g., AARM levels), and j
specify locations for quantifying noble gas releases due to steam generator tube failure.
(29/81-20-43) 5.4.2.7 Sampling and Analysis of Post-Accident Liquid Wastes i
Routine radioactivity concentrations in radwaste sample tanks should not be high enough to preclude the collection and handling of radwaste samples but the location of many, if not all, of tha sample collection points, however, would be impacted by direct radiation from containment. Assuming that the samples could be collected, analyses would be performed in the Hot Chemistry Laboratory.
The licensee had not conducted a study to ascertain the maximue concentration of radioactivity that could be sampled and analyzed (e.g., in 1
i post-accident liquid wastes).
Based on the above findings, improvements in the following areas are required to achieve an adequate program:
Conduct a study to determine the maximum radioactive concentrations of post-accident liquid wastes that could be sampled; the need for special-sampling equipment; and shielding, and make any improvements as necessary.
(29/81-20-44) 24 1
5.4.2.8 Radiological and Environmental Monitoring Program (REMP)
The auditors reviewed Section 10 of the Emergency Plan, and Procedure OP-3310, Appendix 0, and also interviewed licensee personnel who would implement this procedure to include Radiological Evaluation Assistants and an Environmental Sample Assistant.
The auditors determined that provisions existed for collecting and analyzing environmental samples under emergency conditions and for evaluating the results of analyses. A mobile van (See Section 4.1.1.9) equipped with gamma spectrometer and TLD processing equipment would be available upon request within several hours. Additional analysis would be performed at the Yankee Environmental Lab in Westboro, Massachusetts or at the Vermont Yankee Nuclear Pcwer Station.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The auditors reviewed Section 10 of the Emergency Plan, and procedures OP-3330 and OP-8700, and interviewed personnel who would implement these procedures. A walk-through using this procedure was conducted and is detailed in Section 7.2.
The auditors noted that the procedures gave adequate guidance on exposure limits, including criteria for selection of volunteers and the relationship between dose rates and exposure times.
In addition, OP-3330 gave instructions for limiting exposure and assigned individuals to maintain exposure records.
No specific guidance, however, was given pertaining to direct exposure from containment, nor to announce over the PA system that precautions were needed due to the unshielded containment.
In addition, procedures contained no references to responsiblity for authorizing the use of KI.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Review OP-3300 and OP-8700 to include guidance on accident dose rates resulting from the unshielded containment, (29/81-20-45)
Clarify responsibility to authorize the use of KI for all shifts.
(29/81-20-46) 5.4.3.2 Evacuation of Owner Controlled Areas Procedures OP-3302 through OP-3304 specified action levels requiring evacua-tion of the site.
If the Accident ARM reads over 500 R/hr, evacuees are directed to the Boiler Feed Pump Room (BFPR).
For levels below 500 R/hr, they are evacuated directly offsite, however, specific means for evacuation of the BFPR had not been identified.
25
r There were predetermined PA announcements for each emergency class describing actions to be taken by nonessential personnel.
The Procedures made reference to accountability, personnel monitoring / decontamination procedures at each of the assembly locations. The auditors noted that there were no instructions.
for immediate evacuation to a predetermined remote location nor to direct off-duty augmentation personnel to a remote reassembly location before reentry when conditions warranted such actions.
(See Section 4.1.2.1)
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Develop a procedure for immediate evacuation of non essential personnel to a predetermined remote location and include instructions in the call-up procedure to direct augmentation personnel to these remote assembly areas.
(29/81-20-47) 5.4.3.3 Personnel Accountability The Emergency Plan Sections 5, 6 and 10, and procedures OP-3302, 3303, 3304 and 3344 described the elements in the emergency organization responsible for accountability of individuals at each emergency center and for individuals evacuated from the protected area.
The auditors determined that individuals located in, or evacuated from the Training and Information Center were not included in the accountability system, although individuals in this location could, under severe accident conditions, be subjected to radiation from the containment.
In addition, procedures failed to address who would be responsible for performing accountability and directing personnel assembled in the Boiler Feed Pump Room.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Revise OP-3344 to account for individuals who may be at the Training Center during site evacuation, and identify individuals responsible for accounting evacuees at the Boiler Feed Pump Room.
(29/81-20-48) 5.4.3.4 Personnel Monitoring and Decontamination Procedures OP-3302, 3303, 3304 and 3311 used for personnel monitoring and decontamination, provided means for recording:
names of individuals, extent of contamination, instruments used, methods for decontamination, and results.
Contamination levels requiring decontamination and specific decontamination methods (including skin ' contamination with radioiodine) were included.
Diffi-cult cases would be assessed by the Radiological Evaluation Assistant.
In addition, the decontamination procedures directed the user to provide results
.to the organizational element responsible for radiation protection during emergencies.
26
3 s
Based on the above findings, this portion of the licensee s. program appears to 8
~
be adequate.
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5.4.3.5 Onsite First-Aid / Search and Rescue Procedure OP-3305 addressed methods for receiving, recovering, t.ransporting, i
and handling injured persons who may be contaminated; and. described the inter-x i
face and criteria for using offsite medical treatment facMities. Radiation
?
protection guidance for teams recovering injured or cont'amir.ated personnel,
~
was also included in OP-3305.
y 1 -
Based on the above findings, this portion of the licensee's program app'ars to ^
e be adequate.
i 5.4.4 Security During Emergencies
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The auditors reviewed Emergency Plan Sections 8 and 12, procedures OP-3344, AP-0402, AP-0404; the Safeguards Contingency Plan, and interviewed personnel 4
wno would implement these procedures.
i s
The auditors concluded that security measures to be. implement d4Juring the' i
four emergency classes were adequately specified in the station emergencyund security procedures.
Basedontheabovefindings,thisportionofthelicensee'sprogramappeirsto i
be adequate.
5.4.5 Repair and Corrective Actions y
Procedure OP-3330 addressed repair / corrective action activities, and specified
^
instructions for selecting and briefing repair crew members concerning radio-logical conditions and precautions. However, the procedure did not address access to repair / corrective action tools / supplies during accidents involving-4 high radiation from containment.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement: ~
s.
Describe the location to be used for retrieving repair / corrective action tools / supplies and oth' eqalpment that may be needed during severe accidents.
(29/81-P' 4v 5.4.6 Recovery i
l The auditors found no procedure addressing overall recovery / reentry operations, but the authority for declaring that a recovery phase is to be entered was defined in Section 8.3 of the Emergency Plan. The Recovery Manager is respon-sible for notifying federal, state and -local agencies before a recovery phase is entered. The auditors noted that the procedure did not specifically address the evaluation of operational and radiologicai conditions, in the decision process.
H 27
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Based on the above findings, improvement in the following area is required to
~
t achieve an adequate program:
Develop an overall procedure addressing recovery and reentry which includes the need to evaluate operational and radiological conditions-prior to entering the recovery phase.
(29/81-20-50) 5.4.7 Public Information The auditors reviewed Section 8, 2, and 11 of the Emergency Plan, procedures n
OP-3343, AP-0019; and the Yankee Atomic Electric Company Emergency Public Information Plan.
l The Emergency Plan specified the authority, responsibilities, and duties of the Public Information Representative. The Manager of Nuclear Information was i
designated as Public Information Representative who would be the company spokesman responsible for disseminating public information, coordinating information releases among Federal, State, and local agencies, and for activa-ting / operating the News Center.
s The procedures identified:
Federal, State, media organizations involved in news dissemination, their locations, and means for contacting the same.
Based on the above findings, this portion of the licensee's program appears to be adequate.
j 5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Equipment, Facilities and Supplies
]
Procedure OP-3325 provided a specific inventory listing of all the equipment reserved for use during emergencies and specified their locations.
The proce -
dure also assigned responsibilities and specified frequencies for:
inventory, operational checks and calibration. The auditor verified that communications equipment, power supplies, batteries, had been inventoried, operationally checked and calibrated.
Based on the above findings, this portion of the licensee's program appears to be adequate.
5.5.2 Drills and Exercises s
The auditors noted that the Emergency Plan and procedure OP-3341 required drills and annual exercises with the exception of a quarterly communication test with-States within the ingestion EPZ, and annual post-accident sampling drills.
OP-3341 required documentation of the exercise scenario, observers comments, PORC review, and assignment and completion of corrective actions.
In addi-tion, it addressed notification of State, Federal, and local offsite agencies, 1
prior to each drill.
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1 OP-3341 made no provisions for backshift drills, and as a consequence, back-shift drills were not conducted.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Revise procedure OP-3341 to include a quarterly communication test with the ingestion EPZ states, and post-accident sampling drills, and backshift drills.
(29/81-20-51) 5.5.3 Review, Revision, and Distribution The auditors reviewed Section 12 of the Emergency Plan, Procedure AP-0223, and noted that the Plant Operations Review Committee was responsible for:
reviewing changes to the Emergency Plan and procedures; updating agreements made with offsite agencies and evaluating deficiencies and corrective measures resulting from drills and exercises.
The auditors confirmed that emergency procedures had been reviewed, certified by the PORC, and dated.
The distribution of procedures was reviewed by the FORC, and spot check was made to ascertain if procedures were distributed in accordance with the distribution list. There were, however, no means for verifying and updating emergency phone numbers found in procedures and call lists.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Develop means for verifying and updating emergency phone numbers found in procedures and r ail lists on a quarterly basis.
(29/81-20-52) 5.5.4 Audit The auditors reviewed procedures QA-18-2, AP-0208, and AP-0228, and the results of licensee's 1979 and 1980 internal audits.
The material reviewed (e.g., audit check lists) did not contain sufficient information to allow the auditors to determine:
the number, scope and depth of training interviews; the types of emergency equipment and supplies checked by the auditors; and the nature and character of verifications performed on corrective actions resulting from drills / exercises.
Internal audits did not include observation of drills or exercises, and were performed by the Corporate Emergency Planning Coordinator, who had immediate responsibility for the emergency preparedness program.
Based on the above findings, improvement in the following area is required to achieve an adequate program:
Develop a comprehensive and objective audit program to evaluate all emergency preparedness areas.
(29/81-20-53) 29
J 6.0 COORDINATION WITH OFFSITE GROUPS 6.1 Offsite Agencies The auditors confirmed that State agencies, medical and police groups had been familiarized with the Emergency Plan and procedures and had participated in drills. Offsite support agencies were aware of their agreements with the licensee and appeared willing to provide the support specified, however, additional training is needed in some areas (See Section 4.2.3.1).
Based on the above findings, this portion of the licensee's program appears to be adequate.
6.2 General Public The auditors noted that Section 11.1 of the Emergency Plan described means used for disseminating emergency planning information to the population in the States of Vermont and Massachusetts, and that Section 11.2 described various methods by which individuals within the EPZ may be notified of an emergency.
The Manager of Nuclear Information stated that booklets for disseminating emergency planning information to the general public had been developed and were being printed, or reviewed by the States, but these were not made avail-able to the auditors. At the time of the appraisal, no information had been disseminated to members of the general population.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Complete the distribution of site specific public information and provide a copy to the NRC of the information when distributed. This should include information for posting for the transient populations.
(29/81-20-54) 6.3 News Media The auditors noted that Section 11.3 of the Emergency Plan described familiari-zation programs on an annual basis to acquaint news media personnel with:
radiation, public information procedures during emergencies, the emergency classification system, and overall plant characteristics.
Procedure OP-3340 made the Manager of Nuclear Information responsible for news media training and documentation.
The Manager of Nuclear Information stated that representatives of newspapers and radio stations had toured the plant facility within the past 12 months, received familiarity training in security and emergency functions, and were provided with press kits and visitor information.
Records at the Information Center showed that a total of 5 reporters had signed in on September and October 1981. Training received by the news media was not documented in accordance with Procedure OP-3340.
30
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matter should be considered for improvement:
Revise OP-3340 to make provisions to document the training received by members of the news media.
(29/81-20-55) 7.0 DRILLS, EXERCISES AND WALK-THROUGHS 7.1 Program Implementation The auditors reviewed the drill and exercise records and interviewed various licensee personnel.
The auditors found the following deficiencies:
only one health physics drill was conducted and it did not include post-accident sampling of primary coolant or containment atmospherc; communications drills that ensured that messages are transmitted correctly are not conducted (communications drills checked the links only); and all the drills were held during normal hours.
Based on the above findings, this portion of the licensee's program appears to be adequate, but the following matters should be considered for improvement:
Conduct the required semiannual health physics drill.
(29/81-20-56)
Test the aspects of message content and understanding during communi-cations drills.
(29/81-20-57) 7.2 Walk-Through Observations 7.2.1 Accident Classification Shift Supervisors classified the accident, and implemented initial actions called by procedure OP-3304; but, could not make protective action recommenda-tions, since the procedures did not provide guidance for making them. During a walk-through, the STA obtained the EPA PAG from the Emergency Plan and stated that they would be used; but, information available (i.e., dose rate) was insufficient.
No guidance was available for making protective action recommendations based on plant parameters (e.g., core, containment conditions).
Consideration of offsite conditions such as the valley and wind direction, were also lacking.
The Control Room staff had to spend valuable time reading a sequence EALs to find out how to correctly classify emergency.
The Control Room staff indicated that a flow chart could be useful for a timely classification.
l The auditors noted that the staff understood the relationship of plant conditions, l
the need for offsite protective response, and the impact of the radiation levels from containment on plant operations and emergency response (e.g., vent stack readout inaccessibility).
The Shift Supervisor stated that under.those conditions ( AARM reading > 500 R/hr) plant evacuees would be held at the boiler pump area until the rates were lower or vehicles were available for prompt evacuatien.
Control Room personnel were not familiar with KI admini-stration procedures.
31 1
7.2.2 Dose Assessment The auditors gave shift operations personnel a set of accident conditions and requested the projected offsite dose.
The Shift Supervisor indicated that either the STA or health physics technician would perform the initial dose calculation. The STA and HP technician demonstrated proper use of the emergency offsite whole-body dose rate nomogram for noble gases, but could not find a nomogram for carrying out a thyroid dose calculation. A copy was found in the Emergency Plan by the STA but it was not useful (numbers and figures were not clear).
The auditors noted that both nomograms provided dose rates but failed to estimate integrated doses.
The auditors noted that although an adequate method for purging noble gases from charcoal cartridges was provided, the backshift HP lacked knowledge of how to use the purging apparatas.
Charcoal cartridges retrieved from the PVS will be counted on a Nal detector system in the Control Room, but The HP tech indicated that it would take 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> for the counting system to stabilize, causing a delay in determining radioiodine release rates. The plant GeLi system was available for counting the cartridges but the HP technician lacked knowledge of how to use the system.
7.2.3 Offsite Notification and Protective Action Decision Making The auditors conducted a test of the Nuclear Alert System (NAS), and in 3 out
~
of 5 attempts, the NAS to the Massachusetts State Police and Vermont State Police was inoperable. The auditors made the initial contact using the licensee's microwave link to the normal telephone systems beyond the site area. The Massachusetts State Police was requested to contact their Department of Public Health (MDPH) duty officer and ask him to contact the Control Room when the MDPH duty officer returned the call (in about 15 minutes) the auditors asked him how he would act on the protective action recommendations from the licensee.
He indicated that he would consult with his management and in turn make recom-mendations to the Massachusetts Civil Defense who would implement the actions.
Similar results were obtained when the auditors t'ied to implement offsite notification via the Vermont State Police. When sked on what basis a protective action decision would be made before there was a radioactive release in progress, the State Officials indicated that no criterion had been developed for such a situation.
The Secondary Alarm Station (SAS) operators in the Control Room complex were walked-through the offsite notification procedures used to activate the emergency organization.
They implemented the appropriate procedure and indicated that they I
would use a call list contained in OP-MEMO 2E-5 " Emergency Plan Call List," but not prescribed by the implementing procedure. The SAS operators indicated that all paged personnel.were required to call the Control Room (SAS) to determine their response, but that the procedure was new and had not been tested. Auditors were concerned that calling back the Control Room may delay personnel from coming into the plant and tie up Control Room telephone lines.
32
4 Findings and observations summarized above (Sections 7.2.1, 7.2.2 and 7.2.3) were evaluated as part of the findings in Sections 3.1, 3.2, 4.2.3, 4.2.3.1,.
5.1, 5.3.1, 5.4.1, and 5.4.3.1.
7.2.4 Post-Accident Sampling and Radiation Protection The auditors conducted a walk-through involving the coliection and analysis of a post-accident primary coolant sample.
Simulated radiological conditions were: Accident ARM reading near sample sink, 10 R/hr; airborne radioactivity
~
levels enroute to sample collection, unknown; exposure rate in counting room, 1 mR/hr; and exposure rate on contact with sample, 30 R/hr.
During the planning stage the Radiological Evaluation Assistant (REA), Emer-gency Coordinator, and the chemist discussed protective clothing, respiratory protection and dosimetry. The HP technician was briefed by the REA on these precautions.
The auditors noted that charcoal canisters were used, although the condition was of unknown airborne activity.
Procedure OP-3330 required the use of SCBA whenever airborne activity was unknown, and specified the use of KI when iodine potential exists.
The auditors noted HP technicians wore appropriate dosimetry and protective clothing for the mission; but needed additional training on the use of the respirator.
The auditors observed health physics practices use of a Teletector, step-off pads, and timing of exposures.
The reactor coolant sample was collected in a timely and effective manner, and following procedures. Analysis of the sample for boron had to be repeated due to a titration error and difficulty was encountered in piercing the sample bottle septum with a syringe, but after numerous attempts, sampling and analysis were successful.
Findings and observations summarized above were evaluated as part of the findings in Sections 3.2 and 4.1.1.5.
I 7.2.5 EOF l
The auditors conducted a walk-through of the EOF, in which the licensee staff l
back-ups for the primary Emergency Coordinator and Radiation Evaluation Assis-l tant were chosen. The licensee activated various major emergency functions.
During the course of the walk-through, the following deficiencies were noted:
l
- The Emergency Coordinator did not take charge and failed to direct the primary functions of the EOF in their order of importance.
i l'
not follow radio protocol in his communications.
- The radio operator failed to give clear, consistent instructions, and did i
l
- The portable radio unit taken from a kit for use as a backup in the EOF l
was found to be inoperable.
33
- The radios used by the monitoring teams, as noted in past drills, have a range limited to 2 miles which covers only a fraction of the EPZ.
Findings and observations summarized above were evaluated as part of.the findings in Sections 3.2 and 4.2.3.
7.2.6 Offsite Monitoring The auditors performed a walk-through of two offsite monitoring teams and noted that the teams checked equipment and instrumentation in the monitoring kits before the survey, wore appropriate dosimetry, and took radiation measure-ments enroute to the sampling point. Neither team acknowledged receipt of-radio transmissioas. The specific vehicle used had enough room to position air sampling equipment so that it would be protected during inclement weather conditions. The auditors noted, however, that there was only one dedicated vehicle for transporting offsite monitoring teams.
Findings and observations summarized above were evaluated as part of the findings in Sections 3.2, 4.2.3 and 4.2.1.1.
34
INDIVIDUALS CONTACTED 1.
Licensee Personnel S. ALIX Public Relations
- H. AUTIO Plant Superintendent G. BABINEAU Staff Techn cal Advisor
- W. BILLINGS Plant Chemistry Manager P. CASSEY Associate Er:gineer (YNSD)
E. CHATFIELD Training Manager G. DOUCETTE Tech. Asst. -_ Tech. Serv. Dept.
- B.
DRAWBRIDGE Technical Director M FLAHERTY Records Clerk
- L.
FRENCH Tech. Asst. - Tech. Serv. Dept.
W. HOWE Chief of Security R. J0 DIN Control Room Operator J. JORDON Control Room Operator L. LAFFOND Tech. Asst. - Training Dept.
- J.
MACDONALD Manager Radiation Protection Group (YNSD)
- F.
MCWILLIAMS Eng. Asst. - HP Dept.
- D.
O'DONNELL Eng. Asst. - HP Dept.
R. PETTINGEILL Control Room Operator-E. PETERS Security Shift Supervisor
- J.
ROBINSON Director Environmental Engineering Dept. (YNSD)
D. RICE TecF. Asst. - Chemistry Dept.
- N.
ST. LAURENT Ass', tant Plant Supervisor R. SEDGWICK Security Supervisor
- J.
STAUB Tech. Service Manager E. TAYLOR
. Shift Supervisor
- J.
TREJO Radiation Protection Manager
- M.
VANDALE Eng. Assist. - HP Dept.
F. WILLIAMS Shift Technical Advisor
- Denotes those also present at the exist meeting.
2.
In addition to the above, members of the appraisal team also interviewed members of the plant operations and radiation protection staff, corporate personnel; and local, county and State officials.
35
LIST OF PROCEDURES REVIEWE0 Site Emergency Procedures OP-3300 Classification of Emergencies OP-3301 Unusual Event OP-3302 Alert OP-3303 Site Area Emergency OP-3304 General Emergency OP-3305 Emergency Medical Procedure OP-3310 Evaluation of Radiological Data OP-3311 Emergency Off-Site Radiation Monitoring 0P-3320 On-Site Technical Support Center (TSC) and On-Site Operations Support Center (OSC)
OP-3325 Emergency Equipment Readiness Check-OP-3330 Emergency Radiation Exposure Control 0P-3340 Emergency Plan Training OP-3341 Emergency Preparedness Exercises and Drills OP-3343 Release of Public Information Under Emergency Conditions OP-3344 Security Force Actions Under Emergency Conditions j
OP-3345 Coordination and Communications During An Emergency j
Emergency Health Physics OP-8700 Accident Radiation Survey Procedures for Control Room, TSC and OSC OP-8701 Operation and Source Check of the Eberline SAM-2/RD-22 for Determination of Radio-Iodine Airborne Concentrations OP-8740 Measurement of Radioactive Airborne Release Rates Under Accident l
Conditions OP-8741 Determination of Noble Gas Release Rates From The Main Steam Lines Under Accident Conditions Chemistry l
l OP-9540 Post-Accident Sampling and Analysis i
Security i
AP-0402 Support from Of f-Site Forces AP-0404 Emergency Security Procedures Quality Assurance i
AP-0208 In Plant Audit AP-0223 Document Control AP-0228 Quality Assurance Program l
QA-182 In-Plant Audit Program l-Staff l
AP-0019 Issuance of Media Releases and Communication Concerning Plant Operations j
36 t
L
O O
LIST OF EMERGENCY PLAN SECTIONS Sections 1.0 Introduction 2.0 Definitions 3.0 Summary 4.0 Area Description 5.0 Emergency Classification Sy< tem 6.0 Emergency Facilities and Equipment 7.0 Communications 8.0 Organization 9.0 Emergency Response 10.0 Radiological Assessment and Protective Measures 11.0 Emergency Notification and Public Information 12.0 Maintaining Emergency Preparedness Appendices Appendix A Emergency Classification System and Emergency Action Levels Appendix 8 Emergency Equipment Appendix C Internal Off-Site Whole Body Dose Rate Estimation Appendix 0 Yankee Mutual Assistant Plan Appendix E Letters of Agreement Appendix F Evacuation of Time Estimates Appendix G Emergency Plan Implementing Procedures 37
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%..... f 2 5 FEB 1982 CAL 82-04 Docket No.
50-29 Yankee Atomic Electric Company ATTN:
J. E. Tribble, President 1671 Worcester Road Framingham, Massachusetts 01701 Gentlemen:
This letter refers to a meeting between Mr. H. Autio, Yankee Rowe Plant Superintendent and other members of the Yankee Atomic staff and Mr. T. J.
McKenna, Appraisal Team Leader, and other members of the NRC Emergency Preparedness Appraisai Team, which was held at the Yankee Rowe Power Station on December 9, 1981.
It also refers to telephone conversations between Mr. Donald E. Moody, Manager of Operations, and Mr. McKenna on December 16, 1981, and between Mr.
Gary L. Snydert, Chief, Emergency Preparedness and Program Support Branch, and Mr. H. Autio on d.anuary 13, 1982, and again on February 9, 1982.
Withregardtbthemattersrelatingtoemergencypreparednessdiscussedat that meeting and during the telephone conversations, we understand that you will undertake and complete the following action:
1.
Perform a study to determine how the intent of the augmentation goals of NUREG-0654, Table B-1 can be achieved after the declaration of an emergency.
The results of this study will be documented and a copy forwarded to the NRC Region I office for review and evaluation along with a description of compensatory measures for any augmentation goals not met.
This will be accomplished no later than May 1, 1982.
2.
Prepare a plan and schedule for developing the capability for performing post-accident sampling and analysis of radioactive particulates in the containment atmosphere and Primary Vent Stack (PVS) and justify why chloride analysis of primary reactor coolant is not warranted.
Provide a copy to the NRC Region I Office.
Licensee stated this was accomplished and documented in their letter to the NRC dated December 31, 1981.
3.
Determine whether the diluted coolant sample for boron analysis can be collected and analyzed within the exposure constraints cf NUREG-0737.
If exposure criteria cannot be met, provide a description of necessary remedial actions and a schedule for their completion, and provide a copy to the NRC Region I Office.
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o Yankee Atomic Electric Co.
2 2 5 FEB G82 Licensee stated this was accomplished and documented in their letter to the NRC dated December 31, 1981.
4.
Provide procedures for backup monitoring for the high range PVS noble gas monitor and the main steam line monitors in the event they become inoperable.
This will be accomplished no later than May 20, 1982.
5.
Revise procedures containing description of Emergency Action Levels (EAls) to address the requirements of NUREG-0654, Appendix 1.
This will be accomplished no later than May 20, 1982.
6.
Develop procedures for making protective action recommendations which include the consideration of plant conditions, Environmental Protection Agency Protective Action Guides and results from offsite surveys.
Provide training to individuals in the emergency response organization that will use the procedures.
This will be accomplished no later than March 1, 1982.
7.
Develop a technique to compensate for the potential uncertainty associated with plume trajectories.
This will be accomplished no later than May 20, 1982.
8.
Provide a description of the method to be used for estimating radiciodine releases from the PVS under major accident conditions.
Provide a copy to the NRC Region I Office.
This will be accomplished no later than May 20, 1982.
9.
Develop a procedure for recovery / reentry operations which includes a plan for reducing accident classifications and entering a recovery phase based on an evaluation of stabilized plant conditions.
This will be accomplished no later than March 1, 1982.
10.
Appoint an audit group to evaluate your emergency preparedness (EP) program who are independent from EP staff.
Licensee stated this was accomplished prior to January 1, 1982.
- 11. Arrange a meeting between the NRC, FEMA and State officials responsible for protective action decision making.
The purpose of the meeting is to discuss protective action recommendations; to develop assurance that the licensee can make protective action recommendations; and to demonstrate that the State officials have the capability to make a public notification decision promptly on being informed by the licensee of an emergency condition.
Yankee Atomic Electric Co.
3 2 5 FEB E84 This meeting was held on January 20, 1982.
In addition to the above, with the exception of items 2, 3 and 11, please inform this office in writing when each of the aforementioned actions have been completed.
The response directed by this letter is not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.
If our understanding of your planned actions described above is not in accordance with actual plans and actions being implemented, please contact our office by telephone (215) 337-5000 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of your receipt of this letter.
Sincerely, d.
u Ronald C. Haynes Regional Administrator cc w/ encl:
H. Autio, Plant Superintendent James A. Kay, Senior Engineer - Licensing Public Document Room (PDR) local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector Commonwealth of Massachusetts (2) l i
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