ML20058E639

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Discusses 931123 Meeting W/Util in PA to Re Util Emergency Preparedness Program
ML20058E639
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 11/24/1993
From: Joyner J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Reid D
VERMONT YANKEE NUCLEAR POWER CORP.
References
NUDOCS 9312070086
Download: ML20058E639 (12)


Text

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i LNOV 2 4 YM License:

DPR-28 Docket: 50-271 Mr. Donald A. Reid j

Vice President, Operations Vermont Yankee Nuclear Power Corporation RD 5, Box 169 Ferry Road Brattleboro, Vermont 05301

Dear Mr. Reid:

Subject:

EMERGENCY PREPAREDNESS MANAGEMENT MEETING On November 23,1993, Mr. E. Porter and Mr. J. Sinclair of your staff met with members of NRC regional staff in King of Prussia, Pennsylvania to discuss the Vermont Yankee Emergency Preparedness program. Items discussed were Emergency Preparedness Program overview, Emergency preparedness initiatives, self assessment program, proposed notification procedure changes, and other program issues. Copies of the information you provided during the meeting are enclosed.

We imlieve that the mccting was beneficial to our understanding of your improvements and direction of your emergency preparedness program.

No response to this letter is required. Your cooperation with us is appreciated.

Sincerely, Original Signed By:

Ebc C. McCabe l"41 James H. Joyner, Chief NkU70086931124ADOCK0500Q1'-

Facilities Radiological Safety

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F and Safeguards Branch Division of Radiation Safety and Safeguards

Enclosures:

As Stated OFFICIA1. RECORD COPY

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9. P o

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w Vermont Yankee Nuclear Power 2

Corporation cc w/encls:

R. Wanczyk, Plant Manager J. Thayer, Vice President, Yankee Atomic Electric Company L. Tremblay, Senior Licensing Engineer, Yankee Atomic Electric Company-J. Gilroy, Director, Vermont Public Interest Research Group, Inc.

D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire Chief Safety Unit, Office of the Attorney General, Commonwealth of Massachusetts R. Gad, Esquire G. Bisbee, Esquire R. Sedano, Vermont Department of Public Service T. Rapone, Massachusetts Executive Office of Public Safety Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

K. Abraham, PAO (2)

NRC Resident Inspector State of New Hampshire, SLO Designee i

State of Vermont, SLO Designee

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Commonwealth of Massachusetts, SLO Designee j

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OFFICIAL RECORD COPY

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Vermont Yankee Nuclear Power 3

Cor}x> ration bec w/encls:

Region 1 Docket Room (with concurrences)

E. Kelly, DRP J. Shedlosky, DRP M. Oprendek, DRP bec w/enci (VIA E-MAIL):

W. Dean, OEDO D. Dorman, NRR W. Butler, NRR RI:DRSS RI:DRSS RI:DRSS 2nW sieb

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Keimig Joyn,er 11/d(93 -

11/2V93 11M/93 OFFICIAL P.ECORD COPY

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Vermont Yankee - NRC Region I Emergency Preparedness Program Discussions Region I Offices, King of Prussia, PA November 23,1993 INTRODUCTION Purpose of Visit f

PROGRAM OVERVIEW a

EP at VY I

EPC Involvement Technical Staff Addition EPZ CURRENT INITIATIVES 4

Strengthening State Interface Self Assessment Program PNS Siren Refurbishing EP Interface Enhancement Work Controls Process (IFI 92-1941)

Review of 9/3/.93 Notification of Unusual Event i

Request for Additional Information (RAI) (IFI 92-14-01)

Miscellaneous ROUTINE INSPECTION #93-24, October 4-8,1993 OTIIER

EXTERNAL AFFAIRS DEPARTMENT Guideline No.14 i

SUBJECT Emergency Preparedness Self-Assessment Program PURPOSE To provide guidance and criteria for self-assessment within the Emergency Preparedness Department (EPD) consistent with the intent of VYP:115, Vermont Yankee Self Assessment Policy.

SCOPE Gis guideline has been developed to evaluate and improve the quality of Emergency Preparedness programs. The guideline provides a mechanism for the EPD to utilize their EP experiences and expertise to further enhance program through self-assessment activities. De self-assessment mechanism takes advantage of audit, inspection, and surveillance processes already in place, and includes such tools as: OQG surveillances, INPO assist visits, general observation, walk-throughs, and a review of real event responses, i

The Self-Assessment Program was developed to meet the following objectives:

1.

Monitor and maintain high quality work practices in maintenance, drill / exercise, and j

implementation activities associated with the Vermont Yankee Emergency Plan.

2.

Identify precursors to, and correct any actual weaknesses / deficiencies identified in the i

Emergency Plan, Implementing Procedures, policies, and work practices in an effort to ensure continuous program improvements.

3.

Ensure compliance with the VY Emergency Plan, related procedures, regulations, policies, 1

and commitment items.

Reduce the number and significance of f' dings by external auditors and inspectors.

4.

m REFERENCES 1.

VYP:ll5, Vermont Yankee Self-Assessment Policy 2.

Vermont Yankee Emergency Plan 3.

Vermont Yankee Emergency Plan Implemendnt, Procedures 4.

AP-0028, Operating Experience Review and Assessment / Commitment Tracking GUIDELINE 1.

Planning i

i i

Annually, the Emergency Plan Coordinator (EPC) shall establish a plan of self-assessment i

i activities to be implemented during the year. The details of assessment activity plans for the year shall be outlined in the "Self Assessment Planning Form", DEAF 14.01. Included in this plan shall be the program elements to be assessed, the acceptance criteria, the self-assessment mechanism to be used, and the frequency and proposed schedule of the activity.

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2.

Preparation l

Preparation necessarily includes a review of applicable procedures, policies, directives, and regulatory requirements concerning the program element being assessed. In addition, recent audits, inspections and self-assessments of the program element shall also be reviewed. The assessment criteria may be as simple as a comparison of performance with some previous look at the same program element, or as rigorous as conducting a scenario driven drill. Finally, Appendix A provides questions which should be considered when formulating the scope of the' self-assessment.

3.

Implementation Details of each self-assessment activity, upon performance, shall be documented on DEAF 14.02, " Emergency Preparedness Self-Assessment Documentation Form".

Upon completion of the self-assessment the EPC shall determine the performance rating and trend. The determination shall be based on comparing the findings to the acceptance criteria.

Ratings include the following:

l Ratine of 1 Superior level of performance. The program element is determined to fully meet all Emergency Plan, procedure and regulatory compliance. Previous program element weaknesses -

have been effectively addressed and continue to prove effective.

No new significant program element weaknesses are evident.

Ratine of 2 Good to very good level of performance. The program element typically meets all Emergency Plan, procedure and regulatory compliance. Some weaknesses may exist but corrective actions i

are in process.

Rating of 3 Acceptable level of performance. Assessment of the program element identifies significant weaknesses which require immediate attention. Or, the assessment identifies several minor issues which combine to indicate that the program element needs immediate and focused attention.

Ratine of 4 Unacceptable performance. The assessment determines that the program element is unsatisfactory and could or does result in a determination that we could not adequately provide for the health 3

and safety of the public.

Rating of N Insufficient information exists to make a determination. This rating would be assigned to a new program element where limited data exists.

Trends are as follows:

+

Trend is improving.

Trend is declining.

Trend is unchanged.

=

4.

Corrective Actions Areas needing improvement resulting from self-assessment activities will be dispositioned in accordance with AP-0028.

5.

Overall Emergency Preparedness Program Assessment.

The EPC shall use recent inspection, audit and self-assessment results to determine an overall ranking of the Emergency Preparedness Program, using the rating and trend criteria in step 3 of this section.

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APPENDIX A The areas listed below have been extracted form a number of sources, including the last SALP report, QA surveillances/ audits, trend reports and Performance Review meetings. The list is intended to sdmulate thought when developing self-assessment plans.

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Is the responsibility for program or procedure tasks / actions clear? Who has ownership? Is their scope of responsibility clear?

Are there any similarities between problems recently discovered and other programs or procedures implemented by your department?

- same contractor / vendor?

- similar equipment?

- same orocedure of pmccss used?

When responsibilities are shifted between individuals or departments, is the level of instruction / turnover / training and supervisory oversight appropriate?

Are " deep" self-assessments being done or are they superficial? Are references reviewed in detail? Are requirements effectively captured in implementing documents (e.g., E Plan to EPIPs)?

Are corrective actions reviewed for genetic application? Are the corrective actions i

appropriately factored into the training programs?

Do actions occur based on assumptions of fact? Do people attempt to validate information

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obtained from other sources (computer data base, informal conversation, etc.).

Are significant issues raised to the appropria:e level in the appropriate timeframe?

i Do personnel clearly understand managements' expectations? Are there any management expectations? How do you find out if people are aware of managements' expectations?

Are corrective actions timely and effective?

Do individuals raise concerns to management? Do they get feedback?

Are procedures followed? Are procedures results reviewed and discrepancies identified for follow-up?

Is feedback available or solicited from other departments on the quality of support you provide? Are working relationships between departments reviewed?

Are "old" issues revisited? How do you know what might have been " good enough" in the past is still good enough?

7 I

DEAF 14.01 SELF-ACCEPTANCE PLANNING FORM Self-A=

=_ =:

Freauency/ Proposed Procram Element Acceptance Criteria Mechanisuds)

Schedule J

1)

ERO Staffing Adequacy

{

2)

E Plan 3)

EPIPs 4)

EALs 5)

EPI Materials 6)

Staff Augmentation 1

7)

State and W Plans j

8)

Effectiveness in Response to Actual Events i

9)

Scenario Development 10)

Drill / Exercise

Response

11)

EOF Reuliness i

12)

OSC Readiness 13)

TSC Readiness f

14)

PNS Readiness 15)

NMC Readiness 16) 17) 18)

Papared by i

EPC Date Approved by

/

DEA Date

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DEAF 14.02 i

EMERGENCY PREPAREDNESS SELF-ASSESSMENT i

DOCUMENTATION FORM q

i Date:

Performed by:

7 Self-Assessment Program Element:

3 Self-Assessment Mechanism:

1 i

Findings:

3 e

Actions Taken:

i r

i Signature /Date i

(To be completed by EPC)

Performance Rating:

Trend:

/

EPC Date

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^[7 EMERGENCY CLASSIFICATION AND PAR PdOTIFICA(IOrd FOR191

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N Follow instructions on back of this form.

[

}

Ii MESSAGE I

This is (Name:

1, (Title:

) at the Vermont Yankee Nuclear Power Station in Vernon, Vermont. Please do not interrupt until the entire message is completed.

a.

We have declared a: (Check one]

e.

At the present time, we recommend the -

following protective actions:

I1 Unusual Event Terminated

}

l]

Unusual Event

[ ] None

[ ] As follows

[]

Alert

[]

Site Area Emergency Sig.tg 12wn Shelter fvan

[]

General Emergency VT Brattle%'o i]

[]

at hours due to 3 " ate the Dummerston

[]

[]

initiating conditions per AF' i t.

g Hahfax l]

[]

[

vemon

[]

I]

l NH Chesterfield I]

!]

7 Hinsdale

!]

[]

[

I Richmond I]

!]

b.

The Plant is : (Check one)

Swanzey

[]

I]

i

( ) continuing normal operation.

Winchester

[]

[]

[ ] reducing present power levels.

MA Bernardston l]

l l'

[ ] shut down.

Coirain

[]

[]

'f Gill I]

[]

c.

A release: (Check one)

Greenfield I]

!]

i

[ ] is anticipated.

Leyden-

[.]

[]

I ] is in progress.

Northfield

[]

l]

E l ] is not expected to occur.

Warwick

[]

l]

I d.

Present meteorological conditions are; f.

Follow your State procedures for the wind speed is mph designated classification.

wind direction is from degrees.

i 2.. AUTHORIZATION-I Authorized by (Name): PED' TSCC SRM Time:

Date:

i

3. INITIAL NOTIFICATION TIMES Time notification initiated: VT NH MA I

,4.

MESSAGE ACKNOWLEDGEMENTS 5

Receipt by:

VT,,,,

NH MA Name

- Time Name Time Name Time

[

i Remark s i

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VYOPF 3504.03 OP 3504 Rev. 25 l

Page 1 of 2 Two-Sided Form

(

i VYOPE 3504.03 fMST RUCTIONS i

STATES NOTIFICATION MUST BE COMPLETED WITHIN 1S MINUTES OF DECLARATION.

(

1.

Prepare message (See Section 1.)

2.

Prior to notifications, get approval of contents of message by getting appropriate signature (See Section 2.1.

3.

Contact states by using appropriate contact number (s) listed below.

Note: 11 NAS is non functional, utilize commercial back-up capability.

4.

Record initial state contact times (See Section 3.1 5.

Af ter transmittal of message, record name of state contact and time (See Section 4.).

f 6.

Af ter all states notifications are completed, inform authorizing individual CONTACT NUMBERS

[

CONTROL ROOM EOF /RC NAS GROUP CALL VT/NH/MA STATE POUCE VT/NH/MA STATE EOC i

111 333 i

NAS INDIVIDUAL VT STATE POUCE VT STATE EOC j

STATION CALL 213 314 NH STATE POLICE NH STATE EOC 212 311 MA STATE POUCE MA STATE EOC r

210 313 l

COMMERCIAL TELEPHONE VT STATE POUCE VT STATE EOC j

BACKUP 802-244-8727 802-244-8721 NH STATE POLICE NH STATE EOC r

603-271-3636 603-271-2231 j

i i

MA STATE POLICE MA STATE EOC 413-586-3166 508 820-2000 1

1 VYOPF 3504.03 OP 3504 Rev. 25 Page 2 of 2 Two-Sided Form

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