ML20129D571

Insp Rept 50-271/85-09 on 850225-0301.No Violation Noted. Major Areas Inspected:Changes to Emergency Preparedness Program,Knowledge & Performance of Duties & Licensee Audits & Emergency Response Facilities Visit

ML20129D571
Person / Time
Site:	Vermont Yankee
Issue date:	05/03/1985
From:	Craig Gordon, Harpster T, Hawxhurst J, Rich Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129D409	List: ML20129D405 ML20129D571
References
50-271-85-09, 50-271-85-9, NUDOCS 8506060171
Download: ML20129D571 (8)

See also: IR 05000225/2003001

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-271/85-09

Docket No. 50-271

License No. DPR-28 Priority Category C

Licensee: Vermont Yankee Nuclear Power Corporation

RD 5, Box 169, Ferry Road

Brattleboro, Vermont 05301

Facility Name: Vermont Yankee

Inspection At: Vernon, Vermont

Inspection Conducted: February 25 - March 1, 1985

Inspectors: bh

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Preparedness Section Leader

Inspection Summary:

Inspection on February 25 - March 1,1985 (Report No. 50-271/85-09)

Areas Inspected: Routine unannounced emergency preparedness inspection of

areas described in IE Inspection Procedures: Changes to the Emergency

Preparedness Program, Knowledge and Performance of Duties & Licensee Audits.

Also, the present emergency response facilities and proposed EOF were visited.

The inspection involved 125 inspector hours by three NRC region-based

inspectors.

Results: No violations were identified. Three previously opened items were

closed.

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DETAILS

1. Persons Contacted

• J. Des 11ets, Operations Supervisor

• S..J. Jefferson, Assistant to the Plant Manager

N. Gibson, Training Records Clerk

D. Golonka, QA Engineer (YNSD)

P. Klaski, Shift Supervisor

• B. N. Leach, Chemistry and Health Physics Supervisor

G. LeClair, Assistant Operations Supervisor

B. Lindquist, Shift Supervisor

T. Linn, Training Instructor

• T. McCarthy, Emergency Plan Coordinator

A. Parker, QA Engineer (YNSD)

J. Pelletier, Plant Manager

B. Pichette, Senior Control Room Operator

• S. Skibniowsky, Plant Training Supervisor

B. Sojka, Simulator Manager

A..Tatro, Training Instructor

D. Tuttle, Senior Control Room Operator

• R. J. Wanczyk, Technical Services Superintendent

D. Weyman, Senior Chemistry and Health Physics Engineer

• Denotes those present at the exit interview.

2. Licensee Action on Previous Inspection Findings

a. Closed (50-271/83-03-01) Review licensee evaluation of emergency

response facility (EOF) radiological habitability.

The inspectors visited the licensee's current EOF (Governor Hunt

Building), held discussions with licensee personnel and noted that

the new primary EOF in Brattleboro, 8.75 miles from the plant site,

will have a radiation protection factor of 5 and a ventilation

system, equipped with HEPA filters, which can be isolated. In a

letter to the licensee, dated 2/27/84, the Commission approved the

new primary E0F. The planned completi n date for the new EOF is

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September 1985.

b. Closed (50-271/83-12-01) Provide a more specific description of

prompt notification system in emergency plan.

The inspectors reviewed Appendix H (Revision 5, 10/83) in the

emergency plan which provides a description of the public notifi-

cation system.

c. Closed (50-271/83-12-02) Provide specific location of sirens in the

emergency plan.

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The inspector reviewed Appendix H attachments 1-6 (Revision 5, 10/83)

in the emergency plan which includes a map of the specific locations ,

and a description of the types of sirens in the Vermont Yankee (VY) I

emergency planning zone.

3. Changes to the Emergency Preparedness Program

Review

The inspectors reviewed the licensee's records for distribution of revi-

sions to the VY Emergency Plan and Emergency Plan Implementing Procedures

(EPIPs). The inspector also reviewed VY Emergency Plan Section 8 specif-

ically to determine if the VY emergency organization was well defined and

responsibilities clearly identified through all levels of an emergency.

The inspectors interviewed several licensee personnel to determine if

changes have been made to the VY emergency preparedness program since the

last inspection and evaluated how these changes affected the state of VY's

emergency program. In addition, this area was specifically evaluated

against compliance with 10 CFR 50.54(q) and the references listed below.

Findings

'The licensee has identified several changes to the VY emergency

organization. For example, the TSC Coordinator or Site Recovery Man-

ager (SRM) will relieve the Plant Emergency Director of key emergency

responsibilities following initial augmentation. However, the current VY

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Emergency Plan does not include provisions for the delegation of overall

authority to the TSC Coordinator. In the discussion of VY's Emergency

Plan Section 8.2.1.1, " Site Recovery Manager", however, it is clear that

the SRM will assume the responsibility of direction and control of the

accident, emergency management for plant restoration to a safe condition,

and coordination of accident information to provide protective measures to

offsite authorities. The inspector discussed the need for more clearly

defining the duties, responsibilities, and lines of authority of the TSC

Coordinator and other emergency personnel, with the licensee. The licensee

is reevaluating this area. The inspector will review licensee action in

this area in a subsequent inspection (50-271/85-09-01).

Changes to EPIPs are made routinely by the site EPC. All changes to the

EP and EPIPs are submitted annually and reviewed by the Plant Operations

Review Committee (PORC) and dispatched through controlled distribution.

Records are maintained on where each revision was sent and whether

verification of receipt was acknowledged. Approved changes remain on

file for five years. The inspectors, based on a review of major

revisions, determined that changes were made in accordance with the

provisions of 10 CFR 50.54(q).

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References

10'CFR50.54(q)

IE Inspection Procedure 82204 (12/27/82)

VY Emergency Plan, Section 8 (Revision 10,12/84)," Organization"

4. Knowledge and Performance of Duties (Training)

Review

The inspectors reviewed Section 12.2, " Training", of the VY Emergency Plan

and the EPIPs listed under references, which also included parts of pro-

cedures used for classification, notification and protective action

recommendations. The inspectors also reviewed the 22 lesson plans used

for emergency training and held discussions with two of the training

instructors and six operations personnel. The discussions with operations

personnel, specifically those trained as Plant Emergency Directors (PED),

included table-top exercises.

Training records for offsite response personnel and the licensee's emer-

gency response personnel were reviewed for calendar year 1984 and consisted

of class attendance, and/or drill records, and written tests for about 200

individuals. Saveral individuals participated in training for more than

one emergency crganization position or more than one drill. This area of

the emergency program was evaluated igainst the references listed below,

specifically '.o determine:

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if a training program is established and maintained in accordance

with 10 CFR 50.47(b)(15);

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that the amount and type of training received by key emergency

response personnel (plant emergency director) since the last

-inspection is appropriate; and

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that key emergency response personnel (plant emergency director)

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understand their emergency responsibilities and can perform their

assigned duties.

Findings

The licensee's emergency preparedness training program is conducted,

scheduled, and maintained by the Training Department for both onsite and

offsite personnel. The training is accomplished by classroom instruction,

demonstrctions, workshops, and by participating in drills. The training

program appeared adequate to ensure that members of the emergency response

organization maintain familiarity with their specific assigned duties.

However,- the. inspectors noted some areas of concern which could poten-

tially degrade overall emergency preparedness.

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Three licensee personnel who may be called on to assume the PED respon-

sibility participated in a radiological table-top discussion, all had

received the requi_ red 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of plant emergency director training.

The table-top included discussions on: . dose assessment, classification,

notification and protective action decisionmaking. The inspector noted

the following items of concern:

• difficulty in using the nomogram in Figure 1 of 0.P. 3513;

- inoperable dose assessment equipment (T1-59 calculator printer);

• lack of familiarity with procedures as shown in PED's inability to

find the default release duration;

• _use of a dose rate value in 0.P. 3511 comparison to Table 1, instead

of a dose commitment (one individual);

• nomogram procedure 0.P. 3513(A) is an imprecise method to determine

dose rates shown by three different answers - 700, 800 and 1000 MR/HR

- to the same initial conditions;

• - misclassification of a stability class; and

• - an overall difficulty in locating information in procedures.

The inspectors noted during the debriefing discussions, that the indi-

viduals were knowledgeable in the areas discussed but lacked confidence

and felt uncomfortable with the emergency procedures. .The licensee will

further evaluate this area to identify weaknesses and better define

appropriate corrective actions. Licensee actions in this regard will be

reviewed in a subsequent inspection (50-271/85-09-02).

The results of testing following classroom training showed that all

personnel received a passing grade of at least 70%. In two cases of

test failures, there was documentation of retraining and retesting which

resulted in passing grades.

The inspectors determined that the training conducted for State and

Government officials was well attended by representatives from Vermont,

Massachusetts and New Hampshire and included discussions of Emergency

Action Levels, Notifications, and Dose Assessment. Training sessions

have been scheduled for 1985.

The Training Department in conjunction with the Emergency Planning

Coordinator provides required training in the event of significant changes

to procedures, equipment, or facilities. Training plans are being devel-

oped for the required training prior to using the new Emergency Operations

Facility.

No, violations were identified.

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References

10 CFR 50.47(b)(15)

IE Inspection Procedure 82206 (12/27/82)

NUREG-0654 (Revision 1, 11/80), " Radiological Emergency Response

Training"

VY Emergency Plan, Section 12.2 (Revision 10,-12/84), " Training"

VY Emergency Procedure No. 0.P. 3712 (Revision 8, 2/85), "E ergency Plan

Training"

VY Emergency Procedure No. 0.P. 3513 (Revision 8, 11/84), " Evaluation of

Offsite Radiological Conditions"

VY Emergency Procedure No. 0.P. 3511 (Revision 0, 9/82), "Offsite

-Protective Action Recommendations

5. , Licensee Audits

Review

The inspector reviewed Section 12.1.9, " Emergency Plan Audit", (Revision 5,

8/84) and Yankee Nuclear Service Division (YNSD) audits conducted November

1983, 1984. The inspectors held discussions with two YNSD auditors and

the emergency preparedness coordinator. This area of the emergency

program was evaluated against the references listed below, specifically to

determine:

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that an independent review is conducted every 12 months in accordance

with_10 CFR 50.54(t);

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recommendations made by the independent review group were duly.

considered; and

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the licensee has a program for (a) identifying deficiencies and weak-

nesses discovered during licensee drills and exercises, (b) tracking

these items, and (c) providing appropriate corrective actions in a

timely manner for the items determined to decrease the effectiveness

of the program.

Findings

Annually, personnel from the YNSD group conduct an audit of the emergency

preparedness program referred to as an Emergency Plan Audit. Two audits

were reviewed by the inspectors. The following finding related to the

content of the audit reports.

The 1983 audit used an interrogative method to assess compliance with

10 CFR 50, Appendix E, 10 CFR 20 and a select group of procedures. The

finding to each interrogatory included under ' Comments' in the checklist

used by the YNSD_ auditors, generally did not contain enough detail to

fully support the conclusion. For example, on page 4 of 12 in the YNSD

checklist, 'per training records [were] reviewed,' (Did not state how many

records.); 'results of past drills [were reviewed]' (Did not state which

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ones.); and'the revision of the procedures reviewed were not stated.

Although in a few cases, a detailed procedure description was included

under ' Reference'.

- The 1984 audit scope included verifying implementation of the emergency

plan and procedures and determining the effectiveness of the program.

Four areas were reviewed: Emergency Plan, Emergency Procedures, Emergency

Equipment, and Training and Drills. The YNSD auditor presented the find-

ings in a short discussion, little supporting evidence was included with

the auditor's comments. After further review and discussion with the

auditors, the inspector noted the supporting documentation was available

in handwritten form at YAEC/0QA Framingham. The inspector also noted,after

a discussion on report format with the auditors,that YNSD management had

changed in 1983, and more detailed reports were planned for future audits.

This will be evaluated during the next inspectior of this area.

(50-271/85-09-03)

No violations were identified.

References

10 CFR 50.54(t) .

IE Inspection Procedure 82210 (12/27/82)

NUREG-0654 (Revision 1, 11/80), " Responsibility for the Planning Effort"

VY Emergency Plan (Revision 5, 8/84), Section 12.1.9, "Emerger.cy Plan

Audit"

VY Audie Report No. 84-14, " Emergency Plan"

VY Audit Report No. 83-14, " Emergency Plan"

6. Emergency Response Facility (ERF) Schedule

The inspectors visited the licensee's emergency response facilities, held

discussions with licensee personnel and noted that the new E0F will be

completed in September 1985. Also, the SPDS design reviews, equipment

installation, testing and validation,the last part of the ERF package will

be completed, tentatively, November 1988.

No violations identified.

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References

Letter VYNPC to USNRC, dated February 1, 1985, " Safety Parameter Display

System"

Letter VYNPC to USNRC, dated October 30, 1984, "NUREG-0737, Supp. 1, Reg.

Guide 1.97"

Letter VYNPC to USNRC, dated June 12, 1984, "NUREG-0737, Supp. 1 ...

Emergency Response Facilities"

Letter VYNPC to USNRC dated March 1, 1985, " Communications Requirements ...

EOF Location"

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7. Exit Meeting-

On March.1,- 1985, the inspectors met with the individuals listed in

Paragraph 1 and summarized the scope and findings of the inspection.

-The licensee was requested to further investigate the specialized

training.provided to emergency response personnel,'specifically Plant

Emergency Directors. The licens'ee. agreed to evaluate and attempt to

resolve the problems identified, prior to the exercise scheduled for

April 17, 1985. At no time during the inspection was written material

'provided to the licensee.

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