ML20062C497
| ML20062C497 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 07/22/1982 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Jackson E VERMONT YANKEE NUCLEAR POWER CORP. |
| Shared Package | |
| ML20062C501 | List: |
| References | |
| NUDOCS 8208050264 | |
| Download: ML20062C497 (32) | |
See also: IR 05000271/1982005
Text
F
JUL 2 21932
Docket No. 50-271
Vermont Yankee Nuclear Power Corporation
' s
Mr. E. W. Jackson
Manager of Operations
411 Western Avenue
Drawer 2
West Brattleboro, Vermont 05301
Gentlemen:
Subject:
Emergency Preparedness Appraisal 50-271/82-05
To verify that licensees have attained an adequate state of onsite emergency
preparedness, the Nuclear Regulatory Commission is conducting special appraisals
at each power reactor site.
These appraisals are being performed in lieu of
certain routine inspections normally conducted in the area of emergency prepared-
ness.
The objectives of the appraisal at each facility are to evaluate the
overall adequacy and ef fectiveness of emergency preparedness and to identify
areas of weakness that need to be strengthened. We use the findings from
these appraisals as a basis not only for requesting individual licensee action
to correct deficiencies and effect improvements, but also for effecting improvements
in NRC requirements and guidance.
During the period of March 16-24, 1982, the NRC conducted an appraisal of the
emergency preparedness program for the Vermont Yankee Nuclear Power Station.
Areas examined during this appraisal are described in the enclosed NRC Region
I Inspection Report No. 50-271/82-05. Within these areas, the appraisal team
reviewed selected procedures and representative records, inspected emergency
facilities and equipment, observed work practices, and interviewed personnel.
The findings of this emergency preparedness appraisal indicate that certain
corrective actions are required in your emergency preparedness program.
These
are discussed in Appendix A, "Significant Emergency P_reparedness Findings".
Significant findings for which you have made acceptable commitments to resolve
were discussed in the Confirmatory Action Letter dated April 28, 1982 and a
clarification letter dated May 7, 1982. All significant findings, except
Appendix A, Item 10 were addressed in this letter. Copies of the letters are
enclosed (Enclosures 5 and 6).
Other areas needing improvements are discussed in Appendix B, " Emergency
Preparedness Improvement Items."
.
OFFICIAL RECORD COPY
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JUL 2 21932
Vermont Yankee Nuclear Power Corporation 2
In conjunction with the aforementioned appraisal, emergency plans for your
facility were reviewed by the Emergency Preparedness Licensing Branch, Division
of Emergency Preparedness, Office of Inspection and Enforcement.
The results
of this review indicate that certain deficiencies exist in your emergency
plan. These are discussed in Appendix C, " Emergency Preparedness Evaluation
Report."
Appendices A, B, and C of this letter contain an inclusive listing of all
outstanding emergency preparedness items at your facility at this time.
We recognize that an explicit regulatory requirement pertaining to each item
identified in Appendices A, B, and C may not currently exist.
Notwithstanding
this, you are requested to submit a written statement within tMrty (30) days
of the date of this letter, describing your planned actions for improving each
of the items identified in Appendix A and the results of your consideration of
each of the items in Appendix B.
This description is to include, (1) actions
which have been taken, (2) actions which will be taken, and (3) a schedule for
completion of actions for each item. With regard to Appendix C, you are
requested to provide to this office within 120 days of the date of this
letter, page changes to the emergency plan correcting each deficiency or
provide written justification as to why you believe a revision should not be
made. Copies of these changes are to be submitted in accordance with the
procedures delineated in Section 50.54(q), Part 50, Title 10, Code of Federal
Regulations.
With regard to item 10 in Appendix A, based on a telephone conversation
between Mr. E. W. Jackson of your staff and Mr. H. W. Crocker of this office
on July 6, 1982, we understand that you will revise your Emergency Plan within
120 days from the date of this letter.
Notwithstanding your previous commitments to take corrective actions for the
items contained in Appendix A, additional time may be made available if there
is good cause.
Problems experienced during and subsequent to the event on
April 24, 1982 may result in the need for additional revisions to your Emer-
gency Plan and implementing procedures, for example. As was discussed by our
Regional Administrator, Mr. Ronald C. Haynes. with you and Mr. Conway on July
9,1982, if your present commitments to upgrade your plan and procedures do
not provide adequate time for a thorough job, then we will give prompt consid-
eration to a request for additional time.
In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosure
will be placed in the NRC Public Oc;ument Room, unless your notify this office
by telephone within ten days of the date of this letter and submit written
application to withhold information contained therein within thirty days of
the date of this letter.
Such application must be consistent with the require-
ments of 2.790(b)(1).
The telephone notification of your intent to request
withholding, or any request for an extension of the 10 day period which you
believe necessary, should be made to the Supervisor, Files, Mail, and Records,
USNRC Region I, at (215) 337-5223.
OFFICIAL RECORD COPY
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Vermont Yankee Nuclear Power Corporation 3
The reporting requirements contained in this letter affect fewer than ten
persons and, therefore, are not subject to Office of Management and Budget
clearance as required by PL 96-511.
Should you have questions concerning this inspection, we will be pleased to
discuss them with you. Should have questions concerning the items of Appendix
C, please contact Mr. R. Van Niel, Emergency Preparedness Licensing Branch at
(301) 492-4535.
Sincerely,
Original Signed W
k
George H. Smith, Director
Division of Emergency Preparedness
and Operational Support
Enclosures:
1.
Appendix A, Significant Emergency Preparedness Findings
2.
Appendix B, Emergency Preparedness Improvement Items
3.
Appendix C, Emergency Preparedness Evaluation Report
4.
NRC Region I Inspection Report Number 50-271/82-05
5.
Confirmatory Action Letter, dated April 28, 1982
6.
NRC Region I Letter dated May 7, 1982
cc w/encis:
Mr. Warren P. Murphy, Plant Manager
Mr. W. F. Conway, President and Chief Executive Officer
Mr. J. B. Sinclair, Licensing Engineer
Mr. L. H. Heider, Vice President
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
State of New Hampshire
State of Vermont
NRC Resident Inspector
bec w/encis:
Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encis)
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APPENDIX A
SIGNIFICANT EMERGENCY PREPAREDNESS FINDINGS
Based on the results of the NRC's appraisal of the Vermont Yankee Emergency.
Preparedness Program conducted March 16-24, 1982, the following improvements
are required:
(References are to Sections in NRC Region I Inspection Report
No. 50-271/82-05).
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 emer-
gency. 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.
(See
Section 2.2)
2.
Inspect and repair as necessary the reach rod couplings for the post-accident
reactor water sampling panel to ensure proper valve manipulation.
(See
Section 4.1.1.5)
3.
Evaluate whether containment samples are representative because of iodine
plate-out in the sample vials and correct any deficiencies identified.
Provide a written report on the results to the NRC Region I office.
(See
Section 4.1.1.6)
4.
Resolve the problems with the meteorological sensor resulting from foliage
growth in the vicinity of the meteorological tower.
(See Section 4.2.1.4)
5.
Revise the implementing procedures to direct the Emergency Director,
Emergency Coordinator or Recovery Manager, as appropriate, to recommend
either shelter or evacuation as core conditions or projected doses dictate
to all the plume EPZ States (Vermont, New Hampshire, and Massachusetts)
and provide the criteria for making these recommendations.
Provide
training for those individuals on the criteria for making protective
action recommendations relating to offsite consequences and provide
offsite officials with an opportunity to review these criteria and their
bases (see NUREG/CR 1131).
(See Sections 5.3, 5.4.2, 6.1)
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6.
Revise the procedure containing Emergency Action Levels (EALs) to address
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the requirements of NUREG-0654, Appendix 1.
Train the Control Room staff
and other appropriate individuals on the revised procedures.
(See Section
5.3.1)
7.
Provide a backshift call-in documented method for notifying all appropriate
emergency organization personnel down to the working level.
(See Section
5.4.1)
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Appendix A
2
8.
Revise the assessment procedures to:
provide for initially obtaining an
estimate of thyroid dose rate when plant conditions indicate that an
offsite problem may exist (this should include the criteria used to
indicate when to perform this function); provide a method for making
initial dose projections if installed Control Room instrumentation is
inoperable; provide a criteria for recommending protective actions based
on core conditions; and provide Control Room personnel with the relationship
of high-range containment readings to core condition (i.e.,' gap release
or core melt).
(See Section 5.4.2)
.
9.
Provide new procedures or revise existing ones to include methods to
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distinguish radiciodine from noble gases for in plant, site boundary, and
offsite radiological air sampling.
such procedures should include:
trigger levels for purging and counting of characoal cartridges on a high
'
resolution system and for alternate use of silver zeolite cartridge.
(See Section 5.4.2.3)
10.
Provide the NRC with a revised Emergency Plan which contains a description
of the systems and procedures used to assure that plume EPZ State / local
officials have the capability to make a public notification decision
within 15 minutes for situations requiring urgent sheltering or evacuation.
(See Section 6.1)
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OFFICIAL RECORD COPY
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APPENDIX B
EMERGENCY PREPAREDNESS IMPROVEMENT ITEMS
Based on the results of the NRC's appraisal of the Vermont Yankee Emergency
Preparedness Program conducted March 16-24, 1982, the following items should
be considered for improvement:
(References are to Sections ir. NRC Region I
Inspection Report No. 50-271/82-05)
1.
Provide, in the onsite EPC job description, the authority to contact the
Plant Manager directly as needed on emergency planning items.
(See
Section 1.0)
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2.
Formalize the provisions for ongoing training of the plar.t EPC.
(See
Section 1.0)
3.
Provide for notifying appropriate personnel when key emergency functions
(e.g., offsite protective action recommendation) are transferred to the
Recovery Manager.
(See Section 2.1)
4.
Provide a procedure to maintain the Emergency Personnel Assignment List
to ensure that personnel are qualified; that the appropriate emergency
functions are addressed, and sufficient coverage is maintained.
(See
Section 2.1)
5.
Provide specifically for radwaste operations and representation at the
State EOCs (if requested) in the emergency organization.
(See Section 2.1)
6.
Offer emergency training to the officers of fire, police and ambulance /-
rescue companies who have mutual aid agreements with licensee's primary
support companies.
(See Section 3.1)
7.
Provide for training workers on major emergency procedure and equipment
changes to include hands-on training if applicable.
(See Section 3.1)
8.
Provide additional training to Emergency Directors / Shift Supervisors in
classifying accidents and in initiating dose calculations (i.e., either
doing the calculations themselves or delegating to an HP tech or STA).
(See Section 3.2)
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9.
Provide additional training to individuals who perform dose calculations
including use of the offsite dose rate nomogram and TI-59 calculator.
(See Sections 3.2)
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Appendix B
2
10.
Provide additional training to personnel who would perform post-accident
sampling / analysis and main stack sampling / analysis to include typical
exposure rates that may be encountered during the above nrocedures and in
methods for counting high-level samples using the GeLi system.
(See
Section 3.2)
11.
Review the responsibilities of the Radiological Assistant and determine
the need for delegating some of the individual's duties during an emergency.
(See Section 3.2)
12. Assure that records are kept on training of offsite medical personnel.
(See Section 3.2)
13.
Provide thyroid dose nomograms in the Control Room (See Section 4.1.1.1)
14.
Complete the study evaluating the need for HEPA and charcoal filtration
of the Control Room ventilation system and document the conclusions to
the Nuclear Regulatory Commission.
(See Section 4.1.1.1)
15.
Provide designated office space for each major TSC functional subgroup;
and take steps to reduce crowding in the TSC communications center.
(See
Section 4.1.1.2)
16. Designate and equip an alternate E0F sufficiently distant from the site
that it would not be rendered uninhabitable by shifting meteorology
..
conditions (following review of the proposed AEOF location by NRC:HQ).
f.hb
(See Section 4.1.1.4)
17.
Establish a location for the Eberline SAM-II air sample counter such that
it need not be unplugged, thereby eliminating the required warm-up/stabili-
zation time.
(See Section 4.1.1.4)
18.
Provide adequate shielding for transporting high-activity reactor coolant
samples to the analysis laboratory.
(See Section 4.1.1.5)
19.
Determine the maximum reactor coolant sample concentrations that could be
analyzed under worst-case accident conditions.
(See Section 4.1.1.5)
20.
Determine the maximum containment sample concentrations that could be
analyzed under worst case accident conditions.
(See Section 4.1.1.6)
21.
Develop plans and procedures for post-accident sampling and analysis of
liquid from systems known to be contaminated or normally contaminated
with radioactive material. The procedure should contain the following
guidance: whether the liquids can or should be transferred to other
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storage facilities, processed or discharged; precautions to be taken
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during sampling; and immediate actions required to evaluate the radiation
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levels of the liquids.
(See Section 4.1.1.8)
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Appendix 8
3
22.
Provide an assembly area outside of the site area that could be used
under conditions requiring immediate evacuation of the nearby site and as
a reassembly area for reentry operations.
(See Section 4.1.2.1)
23.
Provide for showering contaminated persons at the alternate EOF and for
liquid waste disposal.
(See Section 4.1.2.3)
24.
Provide copies of decontamination procedures at each decontamination
location.
(See Section 4.1.2.3)
25.
Conduct a survey to identify local resources that could be used to support
the expanded emergency organization that would respond to an emergency.
(See Section 4.1.3)
26.
Provide backup instruments at the EOF for the offsite monitoring teams.
(See Section 4.2.1.!)
27.
Ensure that adequate procedures for calibration of the high-range stack
and containment monitors are in place prior to the next scheduled calibration.
(See Section 4.2.1.2)
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28.
Improve the display of the temperature difference parameter in the Control
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Room.
The size and scale of the recorder was insufficient to determine
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differences in stability class.
(See Section 4.2.1.4)
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29.
Provide for a dedicated system of communications among the CR, TSC, EOF
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and OSC.
(See Section 4.2.3)
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30.
Ensure that action will be completed on the pager system to correct
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deficiencies identified during backshift tests.
(See Section 4.2.3)
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31.
Relocate the emergency communication equipment in the Control Room such
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that it will not interfere with Control Room immediate actions.
(See
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Section 4.2.3)
32. Review the emergency procedures to ensure that they contain sufficient
,
precautions and caution statements.
(See Section 5.1)
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33.
Review the Control Room emergency alarm, abnormal occurrence procedures
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to ensure that all references to other procedures are correct.
(See
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Section 5.2)
34.
Review the Control Room emergency alarm, abnormal occurrence procedures
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to identify those procedures where direct event classifications can be
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made and to ensure that the direct classifications are correct.
(See
Section 5.2)
35.
Reference the procedure containing the emergency phone numbers or provide
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the appropriate numbers at the steps ia the implementing procedures
requiring their use.
(See Section 5.4.1)
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, _ _ . _ _ . _ . _ . _ . _ . _ _ . . _ _ _ _ _ _ . . _ _ _ _ _ _ _ . _ _ _ _ _ . . _ _ _ _ _ _ , _ _ _ _ _ . _ _ . ___
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Appendix B
4
36.
Provide information in the offsite monitoring procedure for obtaining a
vehicle for use during site boundary and offsite monitoring.
(See
Section 5.4.2.1)
37.
Provide instructions in the offsite monitoring procedure for determining
when the monitoring team is located in the plume (GM open -- closed
window).
(See Section 5.4.2.1)
38. Develop a simple checklist of radiation protection concerns and precautions
for in plant survey teams under post-accident conditions.
Such a checklist
could be appended to an existing procedure or issued as a new in plant
survey procedure.
(See Section 5.4.2.3)
39.
Provide high-range (0-25R, 1-100R) pocket dosimeters for special monitoring
situations.
(See Section 5.4.2.3)
40.
Establish provisions for rapidly supplementing the onsite supply of
silver zeolite cartridges.
(See Section 5.4.2.3)
41. Add the Control Room to the list of areas requiring radiological habitability
assessment contained in Appendix VI to procedures OP 3501, 3502, and
3503.
(See Section 5.4.2.3)
42.
Revise procedure OP 3530 " Post Accident Sampling" to include the following
items:
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Table of Contents and Listing of Equipment;
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precautions concerning expected dose rate using NUREG-0737 source
terms;
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data sheets and provisions for reporting and returning all original
data sheets to the appropriate emergency organizational elements;
and
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reference to procedure DP 2630 to perform conductivity measurements
!
on post-accident reactor coolant samples.
(See Sections 5.4.2.4
through 5.4.2.9)
43. Address the assignment of duties for REMP samples to be collected during
an emergency, and reference applicable Environmental Laboratory procedures
in station procedure OP 3509.
(See Section 5.4.2.12)
44.
Establish criteria for distribution of potassium iodine for thyroid
blocking.
(See Section 5.4.3)
45. Develop a procedure for immediate evacuation to a predetermined location
and to provide a reassembly area to be used by personnel reporting to the
site if conditions warrant.
This should include a revision to the call-up
procedures to allow directing offduty augmentation personnel to this
location.
(See Section 5.4.3.2)
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Appendix B
5
46.
Provide forms or a log at the E0F and alternate EOF for recording names
of contaminated individuals, contamination levels, decon method used and
results of the decon.
(See Section 5.4.3.4)
47.
Establish contamination action levels which would require further assessment
(i.e., whole-body counting, urinalysis).
(See Section 5.4.3.4)
48.
Provide additional survey instruments at the EOF dedicated for personnel
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monitoring or make provisions for supplementing supplies during an emergency.
(See Section 5.4.3.4)
49. Make the emergency exposure criteria for emergency workers consistent
with the EPA Emergency Worker and Lifesaving Activity Protective Action
Guides given in EPA-520/1-75-001.
(See Section 5.4.3.5)
50. Develop a repair / corrective action procedure for use by OSC, TSC, and EOF
personnel which would identify items necessary for consideration, planning,
and briefing of teams prior to task performance.
(See Section 5.4.5)
51.
Provide for backshift exercises, and for a backshift test of the offduty
emergency organization call-in system.
(See Section 5.5.2)
52. Provide for additional communications test in accordance with 10 CFR 50, Appendix E, III.(E)(9).
(See Section 5.5.2)
53. As part of the audit process, observe drills and exercises, conduct
followup to ensure that corrective actions have been actually performed
and interview / walk-through personnel to check the adequacy of training.
(See Section 5.5.4)
54. Review the Emergency Plan and procedures to ensure compatibility with the
anticipated USNRC Region I response to the site during an emergency.
(See Section 6.1)
55.
Expand the public information mailout/ posters to include sheltering
information, improvised respiratory protection, and forms of releases and
their relationship to protective actions.
(See Section 6.2)
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APPENDIX C
EMERGENCY PREPAREDNESS EVALUATION REPORT
t
BY THE
DIVISION OF EMERGENCY PREPAREDNESS
OFFICE OF INSPECTION AND ENFORCEMENT
U.S. NUCLEAR REGULATORY COMMISSION
,
IN THE MATTER OF
.
VERMONT YANKEE NUCLEAR POWER STATION
DOCKET NO.
50-271
APRIL 1982
INTRODUCTION
The Vermont Yanke ... clear Power Corporation f* led with the Nuclear Regulatory
Commission a revision to the Vermont Yankee Emergency Plan dated February
1982.
The plan was reviewed against the requirements in Section 50.47 of 10 CFR Part
50, the requirements in Appendix E to 10 CFR Part 50, and the guidance of
Regulatory Guide 1.101, Revision 2, October 1981.
This evaluation report follows the format of Part II of NUREG-0654 in that
each of the Planning Standard titles are listed and followed by a summary of
,
the applicable portions of the plan and the deficiencies that relate to that
specific standard.
The final section of this report provides our conclusions.
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A.
ASSIGNMENT OF RESPONSIBil.ITY (ORGANIZATIONAL CONTROL)
Emergency Plan:
The Federal, 5 tate, local and private sector organizations that are
intended to be part of the overall response organization for the Emergency
Planning Zones are identified.
A concept of operations and its relationship to the total effort is
specified.
For Site Area and General Emergencies the Recovery Manager will report to
the site where he will be responsible for the direction of the total
emergency response.
.
Written agreements referring to the concept of operations developed
between Federal, State and local agencies and other support organizations
having an emergency response role within the EPZs are appended to the
plan.
Organizations included are the States of Vermont, Massachusetts
and New Hamsphire, NOAA, Peter Bent Brigham Hospital, Town of Vernon,
Brattleboro Hospital, fire department, and rescue and ambulance service.
The Administrative Supervisor will be responsible for assuring continuity
of resources.
DEFICIENCIES
The plan requires revision and/or c'ditional information as follows:
1.
Provide copies of the final State and local plans for those jurisdictions
within the plume EPZ.
2.
Provide a copy of the portion of the New York State plan that deals with
their interface with Vermont Yankee on ingestion pathway actions.
In
addition, discuss how the appropriate New York officials will be notified
of conditions requiring ingestion pathway protective actions to include
the criteria for such notification.
3.
Provide a map that shows the exact plume EPZ boundary in relationship to
the factors specified in Section 50.47(c)(2) of 10 CFR 50 (e.g., jurisdic-
tional boundaries or access roads etc.).
4.
Identify each step in the protective action decision making and implementation
process (e.g., siren activation /NOAA message) to demonstrate 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
capabilities.
B.
ONSITE EMERGENCY ORGANIZATION
Emergency Plan:
The onsite emergency organization structure and its relationship to
emergency management responsibilities and normal staff titles is specified.
The Plant Emergency Director is always on shift and has the authority and
responsibility to immediately and unilaterally initiate any emergency
actions.
For Unusual Events and Alerts the TSC Coordinator will be
responsible for directing the plant emergency organization upon his
arrival.
For Site Area and General Emergencies the Recovery Manager has
this responsibility upon his arrival.
Lines of succession for the Plan Emergency Director, TSC Coordinator and
Recovery Manager are provided.
The functional responsibilities of the key members of the emergency
organization are established.
Corporate administrative and technical support personnel and assistance
are provided through the Nuclear Services Division (NSD) Engineering
Support Center (ESC) in Westboro, Massachusetts.
Technical assistance to and augmentation of the emergency organization
are available from the Yankee Mutual organization and INPO.
The services to be provided by local agencies for handling emergencies
including fire-fighting and medical services are identified. Copies of
letters of agreement are appended to the plan.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Specify the relationship between the emergency organization and the
normal staff complement down to the working level.
2.
Specify the conditions under which higher level utility officials assume
the responsibilities of the Plan Emergency Director, in particular the
function of recommending offsite protective measures.
In addition,
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specify that all appropriate authorities will be informed when these
responsibilities are transferred to assure there is no confusion.
3.
Specify the responsibilities that cannot be delegated by the Plan Emergency
Director.
In addition, clearly indicate who, at all stages augmentation,
has the authority to make protective action recommendations offsite
(i.e., Plant Emergency Director, Recovery Manager, TSC Coordinator, EOF
Coordinator).
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4.
Provide sufficient information to demonstrate that the emergency organization
goals of NUREG-0654, Table B-1 are met.
In addition, provide a discussion of the relationship of normal assignments
and emergency assignments to include use of the tag board and the relation-
ship of emergency assignments and the training categories discussed in
plan Section 12.
Provide a schedule for meeting the NUREG-0654, Table
B-1 goal s.
5.
Illustrate, by a block diagram, the interfaces between and among the
onsite functional areas of emergency activity, licensee headquarters
support, local services support, and State and local gorbrnment response
organizations.
For State / local governments show the interface points
for, protective action recommendations, monitoring result coordination,
plant access control, plant evacuee processing, and public information
release.
6.
Provide a letter of agreement that specifies INP0's role.
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C.
EMERGENCY RESPONSE SUPPORT AND RESOURCES
Emergency Plan:
The Plant Emergency Director will notify the NRC in accordance with the
Federal Master Plan.
The expected Federal resources are specified.
Radiological laboratories and their general capabilities and availability
are discussed in Appendix 0 of the plan, " Yankee Emergency Mutual Assistance
Plan."
New England nuclear power plants (Vermont Yankee, Maine Yankee) and other
facilities and organizations that can be relied upon in an emergency to
provide assistance are identified.
DEFICIENCIES:
The plant requires revision and/or additional information as follows:
1.
Provide the expected items of arrival of Federal resoarces.
2.
Discuss resources available to support the Federal response.
3.
Provide for dispatching a representative to principal offsite government
emergency operations centers if requested.
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D.
EMERGENCY' CLASSIFICATION SYSTEM
Emergency Plan:
An emergency classification and emergency action level scheme compatible
with the scheme in Appendix 1, NUREG-0654 has been established.
.
The emergency action levels (EALs) in the plan addressed most of the
example initiating conditions listed in Appendix 1, NUREG-0654 as well as
all postulated accidents in the FSAR.
However, in some cases they did
not address the initiating conditions adequately.
.
DEFICIENCY:
The plan requires revision and/or additional information as follows:
1.
Revise the EALs as discussed in Section 5.3.1 of the Emergency Preparedness
Appraisal Report No.
50-271/82-05.
E.
NOTIFICATION METHODS AND PROCEDURES
Emergency Plan:
Procedures which describe mutually agreeable bases for notification of
response organizations with the emergency action level schemes are
established.
The initial information to be supplied to tne plume EPZ States is specified.
Procedures for alerting, notifying and mobilizing emergency response
personnel are established.
The State Police will be notified within 15
minutes of emergency classification.
However, a method for notifying
working level off-duty plant personnel is not described.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Discuss the verification of messages.
2.
Discuss the administrative and physical means for notification and instruc-
tion of the public within the plume exposure pathway EPZ in sufficient
detail to allow for evaluation against the criteria set forth in Appendix
3 to NUREG-0654.
Include a schedule for operation readiness.
Provide
the results of the system test to demonstrate that it meets the design
goals.
3.
Provide formats for written messages intended for the public.
Messages
instructing the public to take shelter and to evacuate should be provided.
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4.
Describe the method for notifying off-duty plant emergency personnel.
F.
EMERGENCY COMMUNICATIONS
Emergency Plan:
24-hour per day notification to the State Police of Massachusetts, New
Hampshire, and Vernon is provided.
Communications as needed with Federal emergency response organizations
are provided.
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Communications with backups are provided between the nuclear facility,
State EOCs and radiological monitoring teams.
Provisions are made for alerting or activating emergency response management
personnel.
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Communication by the licensee with NRC Headquarters and NRC Regional
Office EOCs is provided.
Periodic testing of communications systems is provided.
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DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Since all the steps in the protective action decision making chain are
not clearly specified, it can not be concluded that adequate communications
links are provided with these authorities on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis (See NUREG-0654,
Appendix 3, page 34).
Provide the organizational titles and alternates
for both ends of the communication links which would be involved in
initiating emergency response actions to demonstrate that such station
will be manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
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2.
Provide a coordinated communication link for fixed and mobile medical
support facilities.
3.
Provide a communications link with the local EOCs.
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G.
PUBLIC EDUCATION AND INFORMATION
Emergency Plan:
The points of contact and physical locations for use by news media during
an emergency (Media Center) are designated.
The Director of Communications is authorized to be spokesperson for
Vermont Yankee.
Annual programs to acquaint news media with the emergency plans, information
concerning radiation and points of contact for release of public information
in an emergency are offered.
Arrangements are established for timely exchange of information among
designated spokespersons.
DEFICIENCIES:
Ine plan requires revision and/or additional information as follows:
1.
Provide coordinated arrangements for dealing with rumors.
2.
Provide a description of the information to be provided to the public to
demonstrate compliance with NUREG-0654 Criterion G.1 and G.2.
This
should include provisions for annual distribution; inclusion of information
on all protective actions to include improvised respiratory protection;
posting of information for transients; providing the information in a
form that will likely be available during an emergency (e.g., phonebook)
and a description of the nature of a release (gas) to demonstrate the
need for taking the protective actions recommendations.
3.
Provide a sample copy of the public information brochure to the NRC.
4.
Provide space for a limited number of news media representatives at the
EOF.
H.
EMERGENCY FACILITIES AND EQUIPMENT
A Technical Support Center (TSC) and an Operational Support Center (OSC)
have been established on the second and first floors of the administration
building respectively.
The TSC will be radiologically habitable to the
same degree as the Control Room for postulated accidents. The TSC is in
close proximity to the Control Room.
The T3C has the capability to
monitor various plant parameters needed to evaluate accident conditions.
The TSC has access to the appropriate records and provisions have been
made to assess habitability.
The TSC will be the main communications
link with the Control Room and will provide technical-assistance during
an accident.
A primary Emergency Operations Facility (EOF) has been established at the
Governor Hunt House located .35 miles Southwest of the plant vent stack.
A back-up EOF is located at the Town Hall of Vernon, Vermont.
However,
the back-up is also located within one mile of the stack.
The EOF will
provide information need by Federal, State and local officials for imple-
mentation of offsite response.
The EOF will direct site access control,
offsite and monitoring and decontamination efforts.
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The TSC, EOF and OSC are activated for Alerts, Site Area and General
Emergencies.
Back up radiological testing facilities are being provided by the Nuclear
Services Division's Environmental Laboratory in Westboro, Massachusetts.
In addition, Vermont Yankee has full access to the Yankee Nuclear Services
Division Mobile Environmental Laboratory.
Wind speed, direction and temperature are measured at the 33 ft. and 295
ft. levels of the meteorological tower. An alternate meteorological
tower is located onsite should the primary tower fail.
Provisions to
access offsite weather data are provided.
For a further discussion to
the interim meteorological system see Section 4.2.1.4 of the Emergency
Preparedness Appraisal, Report No. 50-271/82-05.
Provisions have been made to inspect, operationally check, and inventory
emergency equipment / instruments once each month and after each use.
There are sufficient reserve instruments to replace those removed from
service for repair or calibration.
Appendix B of the plan identifies emergency kits by location, content and
type.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
The plan appears to address only the interim centers.
Provide sufficient
information on the final EOF and TSC to allow for an evaluation against
the guidance of NUREG-0696. The licensee has submitted additional information
on these facilities by letter and this is undergoing review; however, the
plan must be expanded to fully describe the EOF and TSC to include a
schedule for full operation of the final centers.
2.
Specify that the activation goals of the TSC and EOF are 30 and 60 minutes.
This must be coordinated with the information provided on offsite augmentation
times provided in response to comments in Section B of this report.
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3.
For those instraments used as part of the accident classification system
(EALs), specify location, type and range.
4.
Discuss the capability to obtain hydrologic and seismic data.
5.
Demonstrate, that as a minimum, the NRC Radiological Assessment Branch
Technical Position for the Environmental Radiological Monitoring Program
has been met.
6.
List and identify the location of supplies and equipment for the OSC to
demonstrate compliance with NUREG-0654, Criterion H.9.
7.
Provide sufficient information concerning coordination of monitoring data
to demonstrate compliance with NUREG-0654, Criterion H.12.
8.
Provide an alternate EOF that is beyond the immediate plant area and
describe the provisions for transfer to the alternate of the command
control functions without interruptions.
9.
Address the long term measures described in Appendix A of NUREG-0654, to
include a schedule for full operational capability and how the influence
of the valley terrain and changes in meteorological conditions will be
considered.
I.
ACCIDENT ASSESSMENT
The EALs, discussed in Section D of this report, provide some parameter
values characteristic of off normal conditions.
There are provisions to relate releases to plum center line whole body
dose rate out to 10 miles under various stability classes and wind speeds.
Provisions to project thyroid doses based on air-samples are also provided.
Meteorological information is available in the Control Room and EOF.
Dose rates will be compared to the EPA PAGs by offsite officials.
DEFICIENCIES:
1.
Provide a discussion of how the results of post-accident sampling will be
integrated into the dose projection method.
2.
Provide the method to be used to determine release rates and projected
doses if the PVS monitor and meteorological instruments are inoperable.
3.
Provide sufficient information concerning offsite monitoring to demonstrate
compliance with NUREG-0654, Criterion I.7 and I.8.
4.
Describe the method used to measure radiciodine concentrations in air as
low as 10-7 uCi/cc and how it was determined that the described system
has this capability.
5.
Provide for immediately (i.e., in the Control Room) estimating the distance
from the site to which the EPA PAGs may be exceeded (not just 10 miles)
and recommending the appropriate protective measures.
6.
Describe the provisions for promptly determining radioiadine release
rates to include the criteria for conducting offsite monitoring and
monitoring response times.
7.
Provide plots which show containment radiation monitor readings vs time
for various accident conditions (e.g., 100% release of gap activity, and
1% and 10% of release of fuel inventory).
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J.
PROTECTIVE RESPONSES
Emergency Plan:
The licensee has established the means to warn or advise onsite employees,
contractors, and visitors of an emergency. All visitors, contractors,
and unassigned personnel will be evacuated for Site Area and General
Emergencies.
Provisions have been made for site egrees control.
Provisions have been made for radiological monitoring and decontamination
of people evacuated from the site.
A means for accountability for all individuals onsite has been provided.
Criteria for the use of protective equipment and supplies for individuals
remaining onsite have been provided.
Evacuation time estimates for the plume exposure EPZ are provided.
Maps showing population distribution around the plan are given in Plan
Figures 4.3, 4.4, 4.5, 4.6.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
State that the goal is to account for personnel within 30 minutes and
discuss the measures to be taken to meet this goal.
2.
Provide maps showing plume EPZ evacuation routes, sampling and monitoring
points, relocation centers and shelter areas as prescribed by NUREG-0654
Criterion J.10.
3.
Specify who has the authority and responsibility for ordering distribution
of KI.
In addition, discuss the time required to make radioiodine measure-
ments, and how it will be assured that KI and other onsite protective
measures will be taken in time to be effective.
4.
Commit to recommend offsite protective measures (shelter and evacuation)
based on:
a.
the distance from the plant at which the EPA PAGs are exceeded (not
just .35 miles),
b.
plant / core conditions under core melt conditions (existing or projected)
recommend evacuation of 2 miles around the site and 5 miles down
wind,
c.
use of the keyhole approach (not just in a down wind direction) and
d.
offsite factors such as evacuation times of special facilities that
may effect the effectiveness of the actions recommended.
5.
Provide sufficient information to demonstrate that offsite officials have
capability to make public notification decisions for a full range of
protective actions (e.g. shelter and evacuation) leading to activation of
the public alerting systera within 15 minutes for situations requiring
urgent action. This should include provisions to act promptly on all the
protective action recommendations to be provided by the licensee in
accordance with their procedures.
6.
Provide, and integrate into the protective action discussion recommendation
methodology, the expected protection afforded by local structures.
7.
Provide for an assembly area for plant evacuees beyond the area of the
site (5 miles) to which personnel can be evacuated immediately without
monitoring if conditions warrant.
Provision for monitoring at this
location should be provided.
K.
RADIOLOGICAL EXPOSURE CONTROL
Onsite exposure guidelines have been established for removal of injured
persons, undertaking corrective actions, performing assessment actions,
and providing first aid.
The licensee has an ensite radiation protection program which will be
implemented during emergencies.
The TSC Coordinator (Plan Manager) has
the authority to approve doses in excess of 10 CFR 20 limits.
Before the
arrival of the TSC coordinator the Shift Supervisor (Plant Emergency
Director) will administer the radiation protective program.
Provisions have been made for the distribution of self reading and permanent
record dosimeters.
Provisions have been made for maintaining dose records for emergency
workers.
Action levels are specified for radiological decontamination.
The means for radiological decontamination have been established.
Means for area access control have been established.
The means for decontamination relocated onsite personnel, including
provisions for extra clothing, have been provided.
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Specify the onsite contamination control measures for drinking water and
food supplies.
2.
Specify the criteria for permitting return of areas and items to normal
use.
3.
Specifically address decontamination capability for radioiodine skin
contamination.
L.
MEDICAL AND PUBLIC HEALTH SUPPORT
Local and back-up hospital and medical services having the appropriate
capabilities have been provided.
Onsite first aid capability is provided.
Arrangements have been made to transport contaminated victims of radiological
,
accidents to medical support facilities.
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M.
RECOVERY AND REENTRY PLANNING AND POST-ACCIDENT OPERATIONS
Emergency Plan:
The emergency condition shall be deemed to have terminated when, by
agreement of the States of New Hampshire, Massachusetts and Vermont and
the Vermont Yank Site Recovery Marager, there is no longer a need for
consideration of public protection measures.
The structure, functions and membership of the facility recovery organization
are described.
DEFICIENCIES:
The plan requires revision and/or information as follows:
1.
Provide for a method for periodically estimating total population exposure.
2.
Specify guidelines for down grading an emergency classification and for
determining when consideration of offsite protective measures is no
longer required.
N.
EXERCISES AND DRILLS
Emergency Plan:
An annual emergency preparedness exercise will be conducted that simulates
en emergency resulting in conditions that would call for the mobilization
of offsite authorities to allow for evaluation of their plans and integration
with site planning and response.
A critique of the annual exercise by State observers is provided.
The exercise scenario will include objectives, time, date, simulated
events, a narrative summary and a list of observers.
The scenario for the exercise will be varied from year to year.
Required fire drills and medical drills are provided.
A critique by government observers, resulting in a formal evaluation, is
provided.
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Deficiencies are identified in a post-exercise critique and proper corrective
actions are determined by responsible plan staff.
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DEFICIENCIES:
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The plan requires revision and/or additional information as follows:
1.
Provide for conducting the annual exercise at differing times of day and
with some unannounced.
2.
Provide for testing communications with Federal and State emergency
response organizations within the ingestion pathway quarterly.
Provide
for testing the aspect of understanding the content of messages during
the communication drills.
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3.
Provide communication tests"that.addrsss the requirements of Section E
(9) (b) and (d) of Appendix E of 10'CFR 50.
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4.
Provide for radiation monitoring drills that include collection and
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analysis of all sample media, as well as provisions for communications
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and record keeping.
5.
Provide for health physics drills that include the analysis of inplant
liquid samples with simulated elevated levels on an annual basis.
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6.
Provide for a backshift test (drill) of the off duty personnel call-in
system.
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0.
RADIOLOGICAL EMERGENCY RESPONSE TRAINING
Emergency Plan:
Site specific training is offered to such offsite emergency organizations
as hospital, ambulance, rescue, and fire departments.
Onsite emergency groups receive didactic as well as practical training.
Erroneous performance during drills is addressed and corrected via critique.
Courses equivalent to the Red Cross Multi-Media curriculum are provided
to the licensee's first aid teams.
The licensee has provided for initial and annual retraining of personnel
with emergency response duties.
A specialized training program including initial and periodic retraining
sessions has been established for the following organizational categories:
directors and coordinators, radiation monitoring and sampling, communi-
cations, search and rescue, security, local medical support and local
fire support.
>
DEFICIENCIES:
The plan requires revision and/or additional information as follows:
1.
Provide training for headquarters support personnel (NSD) who will respond.
2.
Provide sufficient information concerning training of offsite support
organization to demonstrate that NUREG-0654, Criterion 0-1 is met.
3.
Provide training to the offsite officials with authority and responsibility
for protective action decisionmaking on the basis on which these recommen-
dations will be made by the site.
4.
Provide training on repair and corrective actions to include use of pro-
tective equipment and work in high radiation areas.
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P.
RESPONSIBILITY FOR THE PLANNING EFFORT:
DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS
Periodic revisions of the plan, as needed, including changes identified
by drills and exercises, are provided.
An independent review and audit of the emergency preparedness program
will be conducted annually.
OEFICIENCIES:
The plan requires revision and/or additional information as follow:
1.
Provide training for individuals responsible for the emergency planning
effort.
2.
Identify the individual with the overall authority and responsibility for
radiological emergency response planning.
3.
Designate an Emergency Planning Coordinator.
4.
Provide a detailed listing of supporting plan.
5.
Provide a listing of all of the procedures used to implement the plan
such as the post-accident sampling and analysis procedures.
6.
Provide for quarterly updating of telephone numbers in emergency procedures.
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CONCLUSION
Based on our review, we conclude that the Vermont Yankee Emergency Plan, upon
satisfactory correction of the previously identified deficiencies, will meet
the requirements of 10 CFR 50.54, 10 CFR 50 Appendix E, and conform to the
guidance of Regulatory Guide 1.101, Revision 2, October 1981.
The NRC evaluation of the overall state of emergency preparedness for the
Vermont Yankee Site will be made f311owing review of the findings and determina-
tions made by FEMA on the State and local emergency response plan.
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