IR 05000029/1986006

Insp Rept 50-029/86-06 on 860610-12.No Violations Noted. Major Areas inspected:860611 Annual Emergency Exercise. Deficiencies Noted:Overall Command & Control Not Provided by Single Individual & Protective Measures Deficient

ML20203E505
Person / Time
Site:	Yankee Rowe
Issue date:	07/11/1986
From:	Craig Gordon, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203E488	List: IR 05000029/1986006 ML20203E482
References
50-029-86-06, 50-29-86-6, NUDOCS 8607240163
Download: ML20203E505 (9)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-06 Docket N License No. DPR-3 Priority --

Category C Licensee: Yankee Atomic Electric Company 1671 Worcester Road Framingham, Massachusetts 01701 Facility Name: Yankee Nuclear Power Station Inspection At: Rowe, Massachusetts Inspection Condu t d: June 10-12, 1986 Inspectors: u,d #

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. . e m Leader date T. Guilfoil, Battelle, PNL F. Kantor, DEPER, IE G. St etzel, Battelle, PNL Approved by: _ c g,ty '7 '

W.g/Taz s, Chief date -

Erergenc Preparedness Section Inspection Summary: Inspection on June 10-12, 1986 (Report No. 50-29/86-06).

Areas Inspected: Routine, announced, followup inspection and observation of the licensee's annual emergency exercise performed on June 11, 1986. The inspection was performed by a team of five NRC Region I and NRC contractor personne Results: No violations were identifie The licensee's emergency response actions for this exercise were adequate to provide protective measures for the health and safety of the public. However, observations made by the NRC team revealed deficiencies in two major program areas. We found that throughout the exercise overall command and control was not provided from a singic individual ,

and that turnover of authority to direct the response was not clea In addi-tion, the licensee's methodology used to provide protective measures to offsite authorities does not consider NRC guidance of focusing on the potential for plant and core degradation prior to recommending sheltering or evacuation of populations around the facilit e60716 PDR ADOCK 0D000029 G PDH

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DETAILS 1. Persons Contacted The following licensee representatives attended the exit meeting held on June 12, 1986:

G. Babineau, Radiation Protection Manager W. J. Doll, Radiation Scientist, Mass. Dopartment of Public Health V. Burnham, Training Instructor E. Chatfield, Training Manager B. L. Drawbridge, Assistant Plant Superintendent H. Farr, ALARA Coordinator T. P. Fuller, Radiation Protection Engineer J. Gedutis, Senior Chemist L..Heider, Vice President / Manager of Operations T. K. Henderson, Technical Director

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K. Jurentkuff, Assistant Operations Manager J. Kay, Technical Services Manager D. McDavitt, Lead Emergency Planner W. J. McGee, Public Affairs Director R. M. Mitchell, Maintenance Support Supervisor D. O'Donnell, Health Physics Training Instructor W. E. Riethle, Manager, Radiation Protection J. G. Robinson, Director, Environmental Engineering N. N. St. Laurent, Plant Superintendent E. H. Salomon, Engineer, Radiation Protection Group R. Sedgwick, Security 'iupervisor G. M. Stratton, YAEC Radiation Engineer E. J. Wojnas, Emergency Preparedness Engineer The team observed and interviewed several licensee emergency response personnel, controllers, and observers as they performed their assigned functions during the exercise. Discussions were also held with corporate representatives regarding deficient areas of the Emergency Pla . Emergency Exercia The Yankee Nuclear Power Station full-scale exercise was conducted on June 11, 1986 from 8:15 a.m. until 2:00 Pr e-Exercise Activities

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i Prior to the emergency exercise, NRC Region I representatives held

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meetings and had telephone discussions with licensee representatives

to discuss objectives, scope, and content of the exercise scenario.

l As a result, minor changes were made in order to clarify certain

objectives, revise certain portions of the scenario, and ensure that I

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. 3 the scenario provided the opportunity for the licensee to demonstrate those areas previously identified by NRC as in need of corrective actio NRC observers attended a licensee briefing on June 10, 1986, and par-ticipated in the discussion of emergency response actions expected during the various phases of the scenario. The licensee stated that certain emergency response activities would be simulated and that controllers would intercede in exercise activities to prevent sce-nario deviation or disruption of normal plant operation The exercise scenario included the following events:

Steady increase in leak rate from main coolant system;

Reactor scram due te low main coolant pressure;

Release of radioactivity to the atmosphere;

Calculation of offsite dose projections in excess of EPA protective action guidelines;

Declaration of Unusual Event, Alert, Site Area Emergency, and General Emergency classifications: and

Recommendations of protective measures to state and local authorities; The above events caused the activation of the licensee's onsite and offsite emergency response facilitie b. Activities Observed During the conduct of the licensee's exercise, five NRC team members made detailed observations of the activation and augmentation of the emergency organization, activation of emergency response facilities, and actions of emergency response personnel during the operation of the emergency response facilities. The following activities were observed:

Detection, classification, and assessment of the scenario events;

Direction and coordination of the emergency response;

Notification of licensee personnel and offsite agencies of pertinent plant status information;

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! Communications /information flow, and record keeping;

l Assessment and projection of radiological dose and consideration of protective actions;  !

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t Provisions for in plant radiation protection; i

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Performance of offsite and in plant radiological surveys; i *

Maintenance of site security and access control; -

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{ Performance of technical support;

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Performance of repair and corrective actions;

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l Assembly and accountability of personnel; and

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l Management of accident recovery operation ;

c. Exercise Observations 1

1 The NRC team noted that the licensee's activation and augmentation of the emergency organization, activation of the emergency response

facilities, and use of the facMities were generally consistent with

their emergency response plan ond implementing procedure The team also noted the following actions of the licensee's emergency response l organization that were indicative of their ability to cope with ,

abnormal plant conditions

I Presentation and display of data ir the Control Room allowed players to easily access any plant information needed for operational assessment.

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! Arrangement of the series of step-off pads in the Operations l Support Center (OSC) is an efficient way of controlling conta- '

l mination when protective clothing is removed, i

! Radiation Work Permits (RWP) were written for all teams entering j the plant and the information on each RWP served as the basis j for team briefings prior to team dispatc t P

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Information flow within the Technical Support Center (TSC) and 1 between the TSC, Control Room, and Emergency Operations Facility t

(EOF) was effective and responses by TSC personnel provided timely problem resolution.

! Of rection and control of offsite field teams were handled l effectively and allowed adequate plume definition.

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The final recovery and reentry briefing provided to all person-nel by the Recovery Manager was complete and thoroug d. Open Items The NRC team identified the following areas which need to be eva-luated by the licensee for corrective action:

(0 pen)50-29/86-06-01: Self-reading pocket dosimeters (SRD) were not issued and dosimetry records were not maintained for control room and TSC staff during the early stages of the scenario. Also, OP-3330, " Emergency Radiation Exposure Control" implies that two types of SRD's are used but dose ranges are not specified for each typ (0 pen) 50-29/86-06-02: An official log to allow reconstruction of major events and provide historical information was not maintained throughout the exercise in either the control room, OSC, or E0 (0 pen) 50-29/86-06-03: The size and space limitations of the TSC will inhibit an integrated and coordinated response by both augmented licensee staff and outside support personnel if a prolonged emergency should occur. The specific capabilities of the TSC as an Emergency Response Facility (ERF) will be evaluated in greater detail during the ERF Appraisa (0 pen) 50-29/86-06-04: TSC habitability was deficient in that a high range dosimeter was not available and survey results were not docu-mented for review by the TSC Coordinato (0 pen) 50-29/86-06-05: Briefings provided in the TSC were informal and not well organized to a point where a summary of key technical information was able to be conveyed to all staff member (0 pen) 50-29/86-06-06: No criteria is established in procedure OP-3330, Appendix II that considers specific environmental and radiological conditions when selecting respiratory protection equipment (SCBA, full-face respirators) for entry into airborne radiation area (0 pen) 50-29/86-06-07: Identification and functions of all players could not be determined since identification badges were issued only to those personnel with major response dutie (0 pen) 50-29/86-06-08: The procedure used for accountability is inefficient and delayed identification of the names of the missing individuals until well after the 30 minute criteri (0 pen) 50-29/86-06-09: Initial radio transmission problems were observed during communication of information between the Forward Command Post, mobile radios, offsite teams, and the EOF, I

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. 6 (0 pen) 50-29-86-06-10: The initial setup, arrangement, and initiation of key functions within the EOF was not efficient due to the lack of an EOF actuation procedur (0 pen) 50-29/86-06-11: During escalation of the scenario, turnover between individuals in charge of the emergency was not explici Also, during any specific time of the accident it was not clear that overall direction and control was provided from one sourc (0 pen) 50-29/86-06-12: Formulation of protective action recommenda-tions (PAR) to offsite authorities lacks structure and is not pro-cedurally complete in that the basis is made on dose projections, and does not consider NRC guidance (plant conditions). The key-hole concept is not used when developing the PAR and prior to meeting with the States a specific recommendation was not established. In addi-tion, Vermont personnel in the EOF are not authorized to discuss and consider the technical aspects of the recommendation. Finally, the licensee does not followup and obtain from the States,the status of implemented protective action . Licensee Actions on Previou_ sly __ Identified Items The following item was found to recur from the previous exercise:

(0 pen) 50-29/85-03-01: Eased upon plant conditions during the Unusual Event classification, no release should have been expected but the notification message provided to the State of Vermont indicated that a release was anticipate During this exercise, a similar deficiency was observed in the licensee's call-out procedure in that the notification message made to Vermont for the Alert contained inaccurate informatio The message indicated that a loss of coolant accident was in progress when in fact only a small main coolant system leak had occurre The following items relate to the licensee's actions taken to correct

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deficient areas of the Emergency Plan:

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(Closed) 50-29/84-03-10: The minimum staffing requirements are deficient with respect to the guidance sat forth in Table B-1 of NUREG-065 Figure 8.2 to the Emergency Plan, dated February 1986, was revised to provide a specific number of emergency personnel for the 60 minute augmented emergency organization. The licensee indicated that Figures 8.2-8.6 would be further modified to uniformly describe major duties, position title, reporting location, numbers of on shift and augmented response personnel, for each major functional area.

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. (Closed) 50-29/84-03-18: Specify the organizational titles and alter-nates for both ends of the communication link which would be involved in initiating emergency response actions and to indicate that such

! stations 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 and provided with the appro-priate communications backups (i.e., delineate all the steps followed from the initial notification of the State Police to activation of the Public Warning system and providing public information messages on a range of protective actions).

The licensee previously took adequate corrective action for this item

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with the exception of communication arrangements between the licen-see, FEMA, and other Federal organizations. Figure 7.1 of the Emer-gency Plan was revised August 30, 1985 to clarify these arrangements.

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i (0 pen) 50-29/84-03-21: Provide sufficient information to demon-strate compliance with the guidance of Criteria G.1 and G 2 of NUREG-0654 (i.e., an example of the information to be trarsmitted

, annually to the public, explaining the rationale for protective l actions). Commit that information will be distributed on an annual I

basis.

I Section 11.3.2 of the Emergency Plan, dated August 30, 1985 was

! revised to provide for annual distribution of the public information i brochur In order to determine that the NUREG criteria have been

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implemented, the licensee's public information program will be

evaluated during the next scheduled inspection.

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(0 pen) 50-29/84-03-22: Provide annual dissemination of information to i transients within the plume EP ! The inspectors discussed notification of the transient population

with the licensee and determiaed that written brochures are distri-l buted to campgrounds, motels, and hotels in the EPZ. A revision to

{ the Emergency Plan to provide for notification of transients was i i agreed on and will be made by the licensee.

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(Closed) 50-29/84-03-25: Indicate how exchange of information will l be coordinated between the licensee's spokesperson and the respective i spokespersons for offsite orgtnizations. Also, there should be coordinated arrangements for dealing with rumor Section 11.3.1 of the Emergency Plan dated August 30, 1985, has been

, revised to provide arrangements for rumor control. The revision also l indicates that State / Government spokespersons will assemble at the i

Media Center to coordinate public information. The licensee stated i

that clarification would be provided as to which government agencies may be involved in coordinating public information, i

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o 8 (0 pen) 50-29/84-03-52: Describe the action levels used in determin-ing the need for decontamination and the means for decontaminating personnel wound Discussions with licensee representatives indicated that a procedure manual to handle and treat personnel who may become radioactively contaminated and/or injured was under development. The manual will be reviewed and evaluated following its completio The following open items were identified during the previous exercise (Inspection Report 50-29/85-08). Based upon discussions with licensee representatives, additional training has been provided to members of the emergency response organization in these areas. Ob-

, servations made by the NRC team during the exercise revealed that inadequate procedures have been revised and Open Items 85-05-02 through 85-05-07 were not repeated. The status of each item is as follows:

(Closed) 50-29/85-08-02: The on-shift HP technician did not know the location where the air ejector sample was to be obtaine (Closed) 50-29/85-08-03: The need for obtaining a primary coolant sample was not immediately recognized by TSC staff. Once the sample was requested, the extent of fuel damage could not be determined since delays were encountered in obtaining sample result (Closed) 50-29/85-08-04: After assembly, security sent visitors and contract personnel to the EOF without accounting for their dosimetr (Closed) 50-29/85-08-05: Procedure OP-3311, " Emergency Offsite Radia-tion Monitoring" does not provide for contamination surveys of vehi-cles upon return to the EOF. As a result, offsite monitoring teams i

did not have the opportunity to demonstrate vehicle decontamination after plume tracking was completed.

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(Closed) 50-29/85-08-06: Ensure that all controllers and observers

are provided with adequate scenario training in order to clarify

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unexpected actions and handle any deviation which may arise during the exercis (Closed) 50-29/85-08-07: The amount of actual performance and demon-strations associated with use of radiation protection procedures was inadequate. Excessive simulation was observed in the use of radia-tion detection instruments, dress out procedures, contamination control techniques, and use of ALARA principles.

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. 9 Licensee Critique The NRC team attended the licensee's post-exercise critique on June 12, 1986, during which the key licensee controller discussed observations of the exercise. The critique superficially addressed both areas for im-provement (which the licensee indicated would be evaluated and appropriate actions taken), and areas in which improvements have been made.

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Specific improvement areas which were identified related to accountability l in the Technical Support Center, documentation and recordkeeping in the

Operations Support Center, communications problems in the EOF, and ac-l curacy of press release . Exit Meeting and NRC Critique Following the licensee's self-critique, the NRC team met with the licensee representatives listed in Section The team leader summarized the observations made during the exercis The licensee was informed that previously identified exercise items were adequately addressed with the exception of the item described in Section 4.a and no violations were observed. Although there were areas identified for improvement, the NRC team determined that within the scope and limita-tions of the scenario, the licensee's performance demonstrated that they could implement their Emergency Plan and Emergency Plan Implementing Procedures in a manner which would adequately provide protective measures for the health and safety of the publi Licensee management acknowledged the findings and indicated that appro-priate action would be taken regarding the identified open items following receipt of this report. At no time during this inspection d.id the inspec-tors provide any written information to the licensee.

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