ML20129D571
| ML20129D571 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| 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: |
| 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.
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
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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
The planned completi n date for the new EOF is
new primary E0F.
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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
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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)
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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:
if a training program is established and maintained in accordance
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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
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);
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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
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an overall difficulty in locating information in procedures.
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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
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:
that an independent review is conducted every 12 months in accordance
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with_10 CFR 50.54(t);
recommendations made by the independent review group were duly.
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considered; and
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the licensee has a program for (a) identifying deficiencies and weak-
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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
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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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