ML20151R774

Forwards Emergency Operating Procedure Insp Rept 50-271/88-200 on 880601-10

ML20151R774
Person / Time
Site:	Vermont Yankee
Issue date:	08/10/1988
From:	Varga S Office of Nuclear Reactor Regulation
To:	Murphy W VERMONT YANKEE NUCLEAR POWER CORP.
Shared Package
ML20151R777	List: IR 05000271/1988200 ML20151R774
References
NUDOCS 8808120297
Download: ML20151R774 (5)

See also: IR 05000271/1988200

Text

_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _

. i ,Y

UNITED STATES

.

.? ' 'r.

j '* , j NUCLEAR REGULATORY COMMISSION

w ASHING TON, D. C. 20555

k

% , , . . ',[ August 10, 1988

Docket No. 50-271 f

Mr. Warren P. Murphy

Vice President and Manager of Operations

Vermont Yankee Nuclear Power Corporation

R.D. 5, Box 169

Ferry Road

Brattleboro, Vennont 05301

Dear Mr. Murphy:

SUBJECT: EMERGENCY OPERATING PROCEDURE (EOP) INSPECTION (50-271/88-200)

This letter forwards the report for the Emergency Operating Procedure (EOP)

Inspection performed by an NRC inspection team during the period of June 1-10,

IS88, involving activities authorized by NRC Operating License No. DPR-28

for the Vermont Yankee Nuclear Power Station. This inspection was conducted

by members of the NRC Office of Nuclear Reactor Regulation, Region I and

contractors. At the conclusion of the inspection, the findings were discussed

with the members of your staff identified in Appendix A of the enclosed inspec-

tion report.

The inspection effort involved a review of your program for E0P development, a

validation and verification of issued E0Ps and an evaluation of your training

activities for E0Ps. The inspection team accomplished these tasks through use

of your site specific simulator, walkthroughs of E0Ps with operators, interviews

with key plant staff and review of E0Ps and supporting documentation.

Two documents are enclosed with this letter: the Executive Sumary of this

inspection is enclosed to provide an overview of the inspection team's findings

in each area reviewed; a more detailed explanation of the team's findings is

provideo in the enclosed inspection report. The report includes findings that

may result in enforcement action, which would be the subject of separate

correspondence from the NRC Region I Office.

The inspection team was impressed with the material condition and cleanliness

of your plant, the knowledge level of your operators and the supplemental

activities you have taken for managing events that go beyond the guidelines

provided by the owners' group. However, it also appears that you have cbsen

not to develop certain areas of your E0Ps in conformance with the NRC approved

.

owners' group guidelines and these deviations were not properly disclosed to the

l NRC in the Plant Specific Technical Guidelines (PSTGs) submitted in your

6

Procedure Generation Package (PGP). Additionally, the inspection team con-

l firmed the findings of your own independent audit which indicated that your PGP

Writer's Guide development, verification and validation programs were not

properly accomplished. Please respond within 60 days of receipt of this report

( with your schedule for resubmitting your PGP, including the PSTGs with justifi-

cations for deviations from the Emergency Procedure Guidelines (EPGs). Your

8808120297 seosto < I

{DR ADOCK 05000271

PDC hk1 '(

-

.

'

..

.f

. .

.

.

Mr. Warren P.' Murphy -2- August 10, 1988

schedule should be independent of NRC issuance of a generic safety evaluation

report for Revision 4 of the EPGs.

.*

In accordance with 10 CFR 2.790(a) a copy of this letter and the enclosures

will be placed in the NRC Public Document Room.

Should you have any questions concerning this inspection, we would be pleased

to discuss them with you.

Si rely, (5

hM ire b

Division of Reactor Pr , cts I/II

Office of Nuclear Reactor Regulation

Enclosures:

1. Executive Summary

2. Inspection Report 50-271/88-200

cc w/ encl: See next page

.

I

i

,

, .

- --. . . . . .-. - -

'. 8

,

f

l

.

. .

.

1

-

l

Mr. Warren P. Murphy -3- August 10, 1988

cc w/ enclosures: Institute of Nuclear Power Operations

Mr. J. Gary Weigand 1100 Circle 75 Parkway

President & Chief Executive Officer Suite 1500 g

Vermont Yankee Nuclear Power Corporation Atlanta, Georgia 30339'

R.D. 5, Box 169

Brattleboro, Vermont 05301

Mr. John DeVincentis, Vice President

Yankee Atomic Electric Company

1671 Worcester Road

Framingham, Massachusetts 01701

Mr. J. Peletier

Plant Manager

Vermont Yankee Nuclear Power Corporation

R.D. 5, Box 169

Brattleboro, Vermont 05301

Mr. C. Richardson

Vermont Public Interest Research Group, Inc.

120 State Street

Montpelier, Verwent 05602

Mr. William Steinhurst, Acting Commissioner

Public Service Board

State of Vermont

120 State Street

Montpelier, Vermont 05602

Mr. R. W. Capstick

Vermont Yankee Nuclear Power Corp.

1671 Worcester Road

Framingham, Massachusetts 01701

Mr. P. Agnes

Assistant Secretary of Public Safety

Commonwealth of Massachusetts

One Ashburton Place

Room 213

Boston, Massachusetts 02108

Office of the Attorney General

cnvironmental Protection Bureau

State House Annex

25 Capitol Street

Concord, NH 03301-6397

l

_ -.

_ _. . ._

_ ___ .-- _.. ... .. . . _ _ _ . . _ _ _ _

,

". ,

.s

. . ,

.

'i 9.

i EXECUTIVE SUMMARY

INSPECTION REPORT 50-271/88-200

VERMONT YANKEE NUCLEAR POWER CORPORATION

A team of NRC inspectors and contractor personnel inspected the Vermont Yanket

Nuclear Power Corporation to evaluate its pro

mentation of Emergency Operating Procedures (gram

EOPs), as for development

required by Generic and imple-

Letter 82-33, "Supplement I to NUREG-0737 - Requirements for Emergency Response-

Capability". The inspection. team performed this evaluation by accomplishing the

. following activities:

Reviewed the E0P development process as described in the Procedure

Generation Package (PGP) submitted to the NRC.

>

Compared the E0Ps and deviation documentation to the Boilin

Owners' Group Generic Emergency Procedure Guidelines (EPGs)g Water Reactors

.

Validated the E0Ps using the site specific simulator and through plant

walkthroughs of E0P appendices and procedures.

Independently verified selected E0Ps and appendices for conformance with ,

the PGP Writer's Guide.

Reviewed operator requalification training on E0Ps.

'

The inspection team concluded that plant operators would be able to properly

implement the Yemont Yankee E0Ps to manage the postulated casualty

, scenarios. However, the E0Ps were not in conformance with the.NRC approved

EPGs and further licensee attention was required to identify and justify the

deviations to the NRC. The following observations led the team to these

l

conclusions:

!

(1) The E0Ps went beyond the guidance of the EPGs in some areas of event

control. Additional E0P appendices had been developed to manage station

blackout and some severe accident scenarios. The licensee had also

perfomed supplemental studies for containment safety and venting. The

team concluded that these activities enhanced safety.

(2) The material condition of the plant supported accomplishment of the E0Ps.  !

Plant cleanliness was exceptional, allowing unrestricted access to remote

areas whcre E0P supporting tasks could be performed. The team found no

significant material deficiencies with equipment and components that would

prevent E0P accomplishment.

(3) Plant operators demonstrated an excellent knowledge of the E0Ps during '

i plant walkdowns and interviews. The team noted some deficiencies during

the simulator validation of E0Ps for the more complicated casualties. These

deficiencies were-traced to a lack of simulator training on these particular

l scenarios and deficiencies with procedural guidance.

(4) The PGP submitted by the licensee to the NRC did not contain Plant Speci- .

fic Technical Guidelines (PSTGs) and, therefore, did not fulfill the '

requirements of NUREG 0737 (Supplement 1). This omission was significant

i

._ , _ . . _ _ _ . .

1._...___.__.,_-__,~.-____._._._.~,_.._-.___---

.

. e

,

.

.

4

because the licensee had made several devictions from the NRC approved

EPGs and the justifications were not submitted for NRC review.

,

(5) The validation and verification of E0Ps conducted by the licensee did

not appear to ensure that the procedures wera prepared properly. The

team identified examples of unjustified deviations from the EPGs, incon-

sistent application of the PGP Writer's Guide and deficiencies with the

PGP. The licensee w6s already aware of these types of problems from an

independent audit conducted in December 1987 and had initiated corrective

actions before the NRC inspection began.

The licensee had scheduled a major revision to the E0Ps to implement Revision 4

of the EPGs and correct deficiencies from the independent audit. The inspec-

tion team was concerned because the licensee was delaying implementation of

this major revision until Revision 4 of the EPGs was approved by the NRC,

and known problems with the E0Ps were not being corrected.

l

.

mm

3 - -- -- - . - - - --

e n -