IR 05000259/1981019
| ML20039B607 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/08/1981 |
| From: | Andrews D, Jenkins G, Kantor F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20039B584 | List: |
| References | |
| 50-259-81-19, 50-260-81-19, 50-296-81-19, NUDOCS 8112230301 | |
| Preceding documents: |
|
| Download: ML20039B607 (63) | |
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d UNITED STATES
't, NUCLEAR REGULATORY COMMISSION g
a REGION 11
101 MARIETTA ST., N.W., SUITE 3100 o,
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ATLANTA, GEORGIA 30303
Report Nos. 50-259/81-19, 50-260/81-19 and 50-296/81-19 Licensee: Tennessee Valley Authority 500A Chestnut Street Tower II Chattanooga, TN 37401 Facility Name: Browns Ferry Docket Nos. 50-259, 50-260 and 50-296 License Nos. DPR-33, DPR-52 and DPR-68 Inspection at Browns Ferry site near Decatur, Alabama Inspector:
,0. / d.dmd N/1/P/
D. L. Andrews (Team Leader)
Date Signed
b. ! $xclui d A1/7/9/
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.fu F. Kantor Date Signed Accompany ing Personnel:
J. L. Kenoyer, C. D. Corbit, G. T. Gibson, K. M. Clark B.
. Zalcman Approved b - -
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D.~,'J e ns, ief, EPS Section Date Signed SUMMARY Inspection on July 13-24, 1981 Areas Inspected This routine, announced inspection involved 502 inspector-hours on site.
Results In the area inspected, one apparent violation was identified: Failure to provide procedures which implement the Radiological Emergency Plan in accordance with Technical Specification 6.3, A.8 paragraph 5.4.2.1 and 5.5.2.
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TABLE OF CONTENTS INTRODUCTICN DETAILS 1.0 Administration 2.0 Emergency Organization 2.1 Onsite Organization 2.2 Augmentation Organization 3.0 Training / Retraining 3.1 Program Establishment 3.2 Program Implementation 4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Room
!.1.1.2 Tec"nical Support Center (TE.')
4.1.1.3 Operations Support Center (OSC)
4.1.1.4 Emergency Operations Facility (EOF)
4.1.1.5 Post-Accident Coolant Sampling and Analysis 4.1.1.6 Post-Accident Contai.iment Air Sampling and Analysis 4.1.1.7 Post-Accident Gaseous and Particulate Effluent Sarpling and Analysis 4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis 4.1.1.9 Offsite Laboratory Facilities 4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas
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4.1.2.2 Medical Treatment Facilities 4.1.2.3 Decontamination Facilities 4.1.3 Expanded Support Facilities 4.1.4 News Center 4.2 Emergency Equipr.ent 4.2.1 f;sessment 4.2.1.1 Emergency Kits and Portable Instrumentation 4.2.1.2 Area and Process Radiation Monitors 4.2.1.3 Non-Radiation Process Monitors
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4.2.1.4 Meteorological Instrumentation 4.2.2 Protective Equipment 4.2.2.1 Res iratory Protection 4.2.2.2 Protective Clothing 4.2.3 Communications 4.2.4 Corrective Action 4.2.5 Reserves 4.2.6 Transportation 5.0 Procedures 5.1 General Cortent and Format 5.2 Emergency, Alarm and Abnormal Occurrence Procedures 5.3 Implementing Instruction 5.4 Implementing Procedures 5.4.1 Notifications 5.4.2 Assessment Actions 5.4.2.1 Offsite Radiological Surveys and Radiological Environmental Monitoring Program j
'4 5.4.2.2 Onsite (Out-of-Plant) Radiological Surveys 5.4.2.3 In plant P _Jini J cal Surveys i
5.4.2.4 Post-Accident Primary Coolant Sampling 5.4.2.5 Post-Accident Primary Coolant Analysis 5.4.2.6 Post-Accident Containment Air Sampling 5.4.2.7 Post-Accident Containment Air Sampling Analysis 5.4.2.8 Post-Accident Gasecus and Particulate Effluent Sampling 5.4.2.9 Post-Accident Gaseous and Particulate Effluent Sample Analysis 5.1.2.10 Liquid Effluent Sampling 5.4.2.11 Liquid Effluent Sample Analysis 5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies 5.4.3.2 Ev: ;ation of Owner Controlled Areas 5.4.3.3 Personnel Accountability 5.4.3.4 Personnel Monitoring and Decontamination 5.4.3.5 Onsite First Aid / Search and Rescue 5.4.4 Security During Emergencies 5.4.5 Repair / Corrective Actions 5.4.6 Recovery 5.4.7 Public Information 5.5 Supplementary Procedures t
5.5.1 Inventory, Operational Check and Calibration of Emergency Facilities and Equipment 5.5.2 Drills and Exercises 5.5.3 Review, Revision, and Distribution of Emergency Plan and Procedure
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5.5.4 Audits of Emergency Preparedness 6.0 Coordination with Offsite Groups 6.1 Offsite Agencies 6.2 General Public 6.3 News Media 7.0 Drills, Exercises and Walk-Through 7.1 Drill and Exercise Program Implementation 7.2 Walk-Through Observation Attachment:
Persons Contacted
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INTRODUCTION The purpo:- 4 this special appraisal was to perform a comprehensive evaluation of. the licensee's emergency preparedness program. This appraisal included an-
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. evaluation of the adequary and effectiveness of areas for which explicit regulatory reyvirements may not currently exist. The appraisal effort was directed towards evaluating the licensee's capability and performance rather than
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the identification of specific violations.
The appraisal scope and findings were sunmarized on July 24, 1981, with those persons indicated in the attachment to this report, and in a conversation on September 11, 1981 with Mr. J. Bynum.
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.1.0 Administration of the Emergency Plan Emergency planning rssponsibilities at the Browns Ferry Nuclear Plant (BFNP)
were reviewed with respect to the reluirements of 10CFR50.47(b)(16),
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l 10CFR50, Appendix E, paragraph IV.g, criteria in NUREG-0654,Section II.P.
and licensee commitments in the preface to the BFNP Radiological Emergency Plan (REP). Overall responsibility far emergency response planning at BFNP
has been delegated to the Radiological Emergency Planning Group which reports to the Director, Division of Nuclear Power.
These overall and specific offsite responsibilities are described in detail in OIE Report No.
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50-327/81-20; 50-328/81-24.
At the BFNP site, the Compliance Staff
Supervisor has been formally designated the onsite Emergency Planning
Coordinator (EPC) by Standard Practice BF 22.1. His assigned duties include coordination of all Radiological Emergency Plan activities at the Browns
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Ferry site and implementing procedure development, review and revistuns appropriate to maintain adequate emergency response capability.
Other individuals at BFNP, such as the Health Physics Supervisor, Chemistry
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Supervisor, Results Supervisor, Operations Supervisor, Public Safety i
Supervisor and Maintenance Supervisor provide assistance and input to emergency plan training, procedure development and related emergency response areas. All changes to the BFN-REP and Implementing Procedures are reviewed and approved by the Plant Operations Review Committee (PORC) prior
to issuance.
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The Emergency Plan Coordinator reports directly to the Plant Superintendent and coordinates all emergency planning activities with the Division of
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Nuclear Power, Emergency Planning Group and other offsite TVA components I
involved in the overall emergency response planning for Browns Ferry.
No specific criteria for selection of the Emergency Planning Coordinator were l-in effect; however, the incumbent had attended NRC/ EPA and ORAU sponsored courses dealing with emergency management and preparedness and appeared to j
be qualified for the designated position.
No professional development courses had been provided for the Emergency Plan Coordinator to maintain his i
state-of-the art knowledge in the area of emergency preparedness.
Based on the above findings, this portion of the licensee's orogram appears to be acceptable; however, ';.he following should be considered for improve-ment:
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Professional development training through formal courses or seminars in the area of emergency oreparedness should be provided to the Emergency
Planning Coordinator to maintain state-of-the art knowledge. (50-259/
81-19-01; 50-260/81-19-0'; 50-296/81-19-01)
2.0 Emergency Organization
2.1 Onsite Organization
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The onsite emergency organization was reviewed with respect to the requirements of 10CFR50.47(b)(1) and (2),
10CFR50, Appendix E, paragraph IV. A. and criteria in NUREG 0654,Section II.B.
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l The BFNP Radiological Emergency Plan (REP),
Section 4.0 and i
Implementing Procedures IP-6, IP-7,. IP-10 and IP-12 were reviewed and L
discussions were held win licensee representatives to determine that i
the onsite emergency organization had been established, that responsi-l bilities are unambiguously defined and that adequate staff has been provided to mainta.in emergency response capability at all times.
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The Shift Engineer has been identified as the interim Emergency Director and was delegated the authority and responsibility to imme-
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diately and unilaterally initiate any emergency actions, including
providing protective action recommendations to authorities responsible i
for. implementing offsite c'nergency measures. Upon the arrival, at the plant site, of the Superintendent or his alternate, the Shift Engineer i
will be relieved of the puttion of Emergency Director. In discussions with licensee representatives, it swas found that there are normally two
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Shift Engineers on duty. The intention is that the Shift Engineer who
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j is not directly responsible for the af fected unit would assume the duties of the interim Emergency Director. Although this arrangement is
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generally understood by plant personnel, Implementing Procedure IP-19 does not clearly assign this responsibility.
There appears to be a
potential for confusion as to whom is actually responsible for assuming the Emergency Director functions with the above arrangement and some j
clarification in IP-19 is needed.
The emergency organization is identified in Section 4.0 of the REP and Table 1 of Section 4.0 compares functional responsibilities in emergencies to the normal shift staffing complement. Table 1 does not
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accurately reflect the normal shift organization in that there are
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normally two Shift Engineers on duty as noted above, there are normally
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three Assistant Shift Engineers on duty and 14 Assistant Unit Operators on shift. No attempt has been made to assign essential personnel from
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these groups to the emergency organization as outlined in Table 1.
In addition, Table 1, Section 4.0 identifies seven Health Physics Technicians available for emerg<ency response in several areas; however,
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among the technicians actuall, on duty none had been assigned, nor were they generally aware of spec'fic duties or responsibilities that they might be assigned during an emergency.
This lack of assignment was
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reflected in the training program (see Section 3.1).
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i A licensee representative stated that the number of personnel ava!1able in each functional group identified in Table 1 varied to some extent
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and that the Table reflects.the minimum number required for the emergency response organization.
l The REP defines the supervisory responsibilities for the emergency response organization but assignnent of duties and responsibilities for those individuals at the working level had not been made.
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Based on the above findings, the following deficiencies were identified.
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Specific emergency responsibilities had not been assigned down to the work level for all functional areas of the emergency organiza-tion. (50-259/81-19-02; 50-260/81-19-02; 50-296/81-19-02)
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Revise Table 1, Section 4.0 of the REP to clarify tne actual onshift parsonnel required for the emergency organization and relat these individuals by job or position title to functional responsibilities in the emergency organization. (50-259/81-19-03; 50-260/81-19-03;50-296/81-19-03)
2.2 Augmentation of the Emergency Organization The onsite emergency organization is augmented by various TVA organizations including the Central Emergency Control Center (CECC) in Chattanooga, the Division of Nuclear Power Emergency Center in Creattanooga, the Knoxville Emergency Control Center in Knoxville and the Muscle Shoals Emergency Control Center in Muscle Shoals, Alabama.
Additional augmentation assistance is provided by other TVA facilities as necessary.
These include the Sequoyah Nuclear Plant, Watts Bar Nuclear Plant and other TVA Nuclear Facilities under construction. The augmentation organization is described in more detail in OIE Report No.
50-327/81-20; 50-328/81-24.
Based en the above findings, this portion of the licensee's program appears to be acceptable.
3.0 Training / Retraining 3.1 Program Established The onsite portion of the Browns Ferry Station training program is designed for use in two parts, general training and specific training.
General training is covered by Browns Ferry (BF) instruction BF 4.5 and specific training by BF 4.6.
The offsite Corporate environmental monitoring, support groups and agencies and emergency staff training at the various TVA emergency control centers are delineated in the Browns Ferry Implementing Procedures Documents under:
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Central Emergency Control Center (CECC); IP-11, 2.
Division of Nuclear Power Emergency Center (DNPEC); IP-8, 3.
Muscle Shoals Emergency Control Center (MSECC); IP-5, and 4.
Knoxvi le Emergency Control Center (KECC); IP-3.
These four procedures cover the training of the emergency control center cadres, define the responsibilities for training and documentation and specify provisions for periodic retraining.
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Tha inspectors reviewed t,ie onsite and of fsite t i. N ng programs as j
they are currently structured. The onsite program includes an initial orientation and annual retraining of onsite personnel.
This training requires about one hour (during the initial eight hour orientation for all employees) and about 30 minutes for the annual retrain Sg (during the four hour orientation).
The Browns Ferry (BF) Emergency Director and his alternates are retrained at one year intervals as scecified by scandard practice BF 22.1, Radiation Emergency Plan. All members of the emergency staff are required to read attachment 1 of BF 2T.1, and sign off on the
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attachment to indicate that they have read and understand the contents.
Each time a revision is made to BF 22.1, changes are issued with a review and sign off seuion for cach emergency team member.
In addition, special training for designated teams on postulated emargency events is conducted in accord with lessa plans, and drills are given on each shift to assure that team members understand how the emergency organization would function and their responsibilities within the organization.
The emergency organization is, in terms of the pe: sons and responsi-bilities assigned, identical to the normal operating organization.
Consequently, individual cualifications are identical in both normal
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and emergency organizations. The major changes, from normal opera-tions, in the emergency organization include communications, emergeocy assessment, corrective and protective act ions.
These changes are specified in the Radiologica! Emergency Plan (REP) and t% Browns Ferry Implementing Procedures Document (BFIPD).
Training on the REP and BFIPD qualifies the normal orgaaization personnel for postulated emergency event assignments.
Drills are used to eva'uate the effectiveness of the REP, BFIPD and training, and the annual exercise allows evaluation of the interrelationships and interactions be %een the various portions of the REP and BFIPD.
The onsite emergency training program was designed by Browns Ferry Station and corporate personnel who are skilled in training, knowledgeable in operations and/or have participated in emergency plan and procedures design.
Lesson plans for '. aining are dev,.',oped in accord with REP and BFIPD previsions. Selection of the training course content results fror interactions between service groups (e.g. nurses, public safety officers, safety engineers, health physicists and the emergency coordinator) with members of plant operations.
Scheduling and records on inplant emergency training are, for the most part, coordinated by the station Training Officer. This latter aspect is currently in a period of transition as all training records are not fully centralized, but plans are to centralize them with the Training
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Officer.
Specific onsite emergency preparedness training bicludes firefightig, first aid, personnel decontamination, and the reactor operator
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certification program.
For radiological emergencies, health physics technicians receive training as part of the fire brigade, medical first aid team and decontamination. The onsite first aid training / retraining is an eight hour course conducted by the TVA's onsite nurses. Both the health physics and chemical technicians receive annual retraining in first aid for their roles during rescue /first aid team operations.
The auditors reviewed the content of the training provided to workers for postulated radiological emergency situations. The training content for health physics technicians lacked: (1) estimates of dose rates on a location-by-location basis within the plants, (2) use of respiratory protection involving large amnusts of I-131 in breathing air, (3) where to obtain self-reading penci t aosimeters ccmmensurate with 611 owed emergency once in a lifetime dose commitments, and (4) locations where breathing air contamination with fission radionuclides are most likely to be present.
Further, no training course for plant personnel was available for emergency offsite surveillance / environmental monitoring.
Important portions of the existing emergency training program are dcsigned by the Radiological Hygiene Branch (RHB) located in Muscle Shoals.
The Radiological Emergency Planning and Preparedness, and Radiological Assessment groups of the RHB design the offrite environmental monitoring and assessment program portions, and training for offsite support and government agency personnel in two states. As described above, the training requirements for this portion of the
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program are defined in MSECC IP-15.
A previous infraction concerning the failure to provide training for designated Emergency Directors was reviewed and corrective actions have been taken. Item (50-259/80-16-02; 50-260/80-13-02) is closed.
The training for offsite support personnel, including the Sheriff, ambulance and hospital staffs, is offered annually by invitational letters. Corrently, training for the fire Station in Athens, Alabama, is conducted by Browns Ferry Health Physics personnel. The training is conducted by walk throughs that focus on entrance into the Station Facilities, what 8;uipment is available, compatability of equipment with that of the Fire Station and the radiological precautions that would be taken during any facility entrance. The assistance that would be provided would backup tne fire truck currently owned and operated by Browns Ferry personnel. No formal agreement exists between the Athens Fire Department and TVA.
The Muscle Shoals environmental teams have a training tourse for sampling and analysis under field conditions. However, training does not include specific dose limitation guidance, face mask fitting and use for protection against I-131 exposure, plume monitoring, selection of the proper self-reading dosimeters, nor possible dose rates at pre-established environmental sampling stations for the full spectrum of postulated radiological releases from accident li Based on the above findings, the following areas should be considered for improvement:
An offsite environmental monitoring training program at Browns
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Ferry, including lectures and walk-through field demonstrations on:
(1) collection and movement of essential radiological equipment and instruments to the dedicated Enviionmental Van, (2)
plume monitoring, (3) dose limitations, (4) communications, (5)
possible dose rates from (in) plumes and at pre-established monitoring stations, and (6) use of the single channel analyzer for determining I-131 concentrations in the field had not been implemented. (50-259/81-19-04; 50-260/81-19-04; 50-296/81-19-04)
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Provisions for an in plant Browns Ferry health physics training course, for both health physicists and technicians, including lectures and walk-through demonstrations covering:
(1) possible
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increa'.as in dose raras (on a location-by-location basis), (O dose limitations and the appropriate rupporting dosimeters and instruments applicable to the fuli range of postulated accidents.
(50-259/81-19-05; 50-260/81-19-05; 50-296/81-19-05)
3.2 Program Implemented The inspectors conducted several walk-throughs with shift / control room engineers, radiation and chemistry technicians, station emergency organization directors (and their alternates) and public service (security) personnel.
Persons contacted knew and understood their responsibilities for emergency situations, and the functions of the emergency organization as a whole. The use of radiological instruments, protective clot':ing and survey forms is a daily task. Thus, all personnel that migFt. 5e called on during a postulated emergency event are trained for see emergency radiological conditions (See Section 3.1).
Review of the records of drills and discussions with the Emergency Planning Coordinator showed that emergency procedures have been modified to reflect inefficiencies and/or errors that were pinpointed during the drills and followed up on during the drill critiques. The focus of these drills was organizational, responsibilities, communica-tions and postulated loss of coolant accidents (LOCAs). In addition six to eight drills per quarter on fire and/or w dical emergencies have been conducted for some time.
During the evaluation of tne effectiveness ;. the emergency training i
program, certain weaknesses were found. Members of the health physics
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staff were not rertain that communications with Muscle SFaals would be
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possible du~ ing offsite monitoring from the emergency van radio.
l Further, t was determined that no formal offsite monitoring procedures j
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and training on such procedures was available for the Browns Ferry staff (See Section 3.1 and 5.4.2.1).
Evaluation of the Muscle Shoals offsite monitoring training also had a few weaknesses, as described in Section 3.1.
As discussed in Section 2.1, there appears to be a lack of instruc-tions/ procedures to clearly identify who is responsible for assuming Emergency Director responsibilities. However, the drill results reviewed anJ walk-through discussions indicated that personnel understand who will assume this function.
4.0 Emergency Facilities and Equipment 4.1 Emergency Facilities 4.1.1 Assessment Facilities 4.1.1.1 Control Rooms There are two control rooms at BFNP both located in the control bay of the Control and Service Building at elevation 617'
The controls for Units 1 and 2 are located at opposite ends in one large control room.
The controls for Unit 3 are located in a separate control room a short distance away through
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two controlled access doors. The Shift Engineer's office is located immediately adjacent to Control Room 1 and 2 through a controlled access door.
Communication facilities in the control rooms include Plant Automatic Exchange (PAX) telephones, Bell commercial telephones, sound powered telephones, a ring-down line to the Operations Duty Specialist in Chattanooga, Tennessee, and the NRC Emergency Notification System telephone. Communi-caticn between the control rooms and the Shif t Engineer's office is by the PAX telephona.
Meteorological information including wind speed and direction and temperature at three different levels is dispic ed in Control Roca 1 and 2.
Radiological r
effluent monitors for all of the plant release points are located in the Unit 1 part of Control Room 1 and 2.
The control bay is servsd by an engineered safety feature ventilation system and is shielded to allow occupancy during radiological emergencies.
There are emergency supplies and respiratory protectier.
equipment available in the control rooms for the operations persor.nel. A backup control panel with
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sufficient controls to shut down the plant is located in a separate room in the control bay between the control rooms.
A copy of the REP and the IPD is kept at each of the three control areas and in the Shif t Engineer's office. No other decisional aids, maps, overlays, or nomograms for performing dose assessment calculations are maintained in the control rooms.
Based on the above findings, this portion of the licensec's program appears to be acceptable.
4.1.1.2 Technical Support Center Ihe Power System Operations (PS0) office, the relay room, and the relay lunchroom in the control bay between Control.9oom 1 and 2 and Courcl Room 3 ct elevation G17' have been design m J as the Technical Suppcrt Center (TSC). An area in the middle of Control Room 1 and 2 has been designated r2 the Emergency Control Center (ECC).
The Site E.tergency Direct.or (SED) and his staff report to the ECC. It is from this area that the SED directs the overall plant emergency response.
The TSC has the same radiological habitability under accident conditions as the control rooms and is a short walk, much less than two minutes, through a controlled access door from each of the control rooms. The PS0 office, which is considered the main part of the TSC,11 normally occupied by up to eight PS0 perstmnel who vacate the office when the TSC is activated. There are eight desks and two tables in the PS0 office which had a crowded, cluttered appearance when toured by the auditors.
Most of the working surfaces were covered with manuals, drawings, and ebetrical equipment. The relay room, with the exception of one corner with a table, is for the most part filled with relay equipment and thus not available to TSC personnel.
The operator's lunch room has about 600 square feet of usable space with three
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office type tables.
The activation of the TSC is covered in IP-6. The d!".ciplines or activities represented in the TSC are: Nuclear, Chemical / Radiochemical, Mechanical, Electrical, Communications, Health Physics, Instrumentation, Computecs, and Quality Assurance.
The call list attached to IP-6 indicates that 22
persons will staff the TSC but the discipline or activity each person will be engaged ir. is not given nor is there any indication whether an alternate is available or necessary.
The operation of the TSC is addressed in IP-20.
This procedure lists the equipment and systems for which each discipline will be responsible.
However, it was noted that the disciplines in IP-6 ds not correlate with the responsible areas in IP-20.
For example, " Computers" and " Quality Assurance" in IP-6 are not shown in IP-20 while
" Engineering and Test Unit" and
"Rerctor Engineering Unit" in IP-20 are not listed in IP-6.
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The operation and staffing of the ECC is addressed in IP-i? and IP-19, respectively. Th SED directs the eriargency operations and communications from the ECC.
The Engineering Section Supervisor directs the TSC. The call list in IP-12 indicates that 12 people will report to and staff the ECC.
While presumably known to plant personnel, the disciplines and functional areas represented by the ECC staf f are not described in the REP and IPD.
IP-19 states that the responsibilities of individuals in the ECC will be provided later.
It is likely that in addition to the 22 persons assigned to the TSC, some of the 12 persons on the ECC staff will be directed to the TSC due to lack of working space in the ECC in Control Room 1 and 2.
Further, it is stated in Stop 6.4 of IP-14, the Health Physics procedure, that !f it is necessary to evacuate the HP Laboratory, an alternate HP Laboratory will be established within the TSC.
The TSC, as stated in Section 7.1.12 of the REP, serves as the primary communications interface with the control room as well as a plant communications interface with all other TVA smergency control centers. The communication systems in the TSC (PS0 oi W e) include two PAX lines, one Bell commercial j
l i r., ring-down lines to the Chattanooga, Muscle Shoals, and Knoxville ECCs, and the NRC Emergency Notification System line.
An NRC Health Physics Network telephone is not installed in the TSC.
A VHF radio is in the TSC which is used by PS0 personnel to contact other local TVA generating facilities and mobile PS0 crews. The PAX lines are the principal means for commmunicating with the
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control room and to other functional areas within the plant. There are no dedicated telephone l hks between the TSC and local government response agencies.
In the TVA concept of emergency response operations, the Central Emergency Control Center (CECC) Director in Chattanooga is the primary contact with State and Federal agencies.
A copy of the REP and IPD was avail;ble in the TSC (PS0 of fice).
A set of plant drawings was also located in the PSD affice.
Other plant reference documents such as technical specifications, operating procedures, and emergency operating instructions are not maintaind in the TSC; however they are available in the Shift Engineer's Office.
There were no provisions other than the PAX telephone lines for transferring plant data from
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the control room to the TSC nor were there any means for storing and displaying plant data in the TSC.
While the TSC has the same radiological habita-bility as the control rooms, no installed or portable monitoring equipment was available to indicate radiation dose rates and airborne activity concentrations inside the TSC.
In a letter to the NRC dated June 2, 1981, the licensee submitted a conceptual design of an upgraded TSC to meet the requirements of NUREG-0696. The proposed implementation date for the TSC includino the TSC data system, is July 1, 1984.
This date is not consistent with the NRR letter to licensees, dated February 18,1981, which specified that upgraced emergency response facilities shall be operational by Oct;ber 1,1982.
Based on the above findings, the following deficiencies were identified:
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Potential overcrowding and congestion in Control Room 1 and 2 with the assignment of 12 ECC personnel there during an emergency.
(50-259/81-19-06; 50-260/81-19-06; 50-296/
81-19-06)
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Inadequate working space and communications for assigned plant personnel in the TSC.
(50-259/81-19-07; 50-260/81-19-07; 50-296/
l 81-19-07)
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Lack of adequate conimunications from TSC to ECC and lack of control room parameter information to the TSC staff.
(50-259/
81-19-08; 50-260/81-19-08; 50-296/81-19-08)
4 1.1.3 Operations Support Center The hallway in the powerhouse control bay at
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elevation 593' in the Centrol and Service Building has been designated the Operations Support Center (OSC).
The OSC meets the same habitability requirements as the control rooms. The Operations Section Supervisor will direct the OSC.
As indicated in IP-7, 19 persons will be called to staff the OSC. There appears to be adequate space in the hallway to accommodate the assigned personnel.
Three PAX lines are located in the
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hallway and additional PAX lines are in the individual rooms off the hallway.
There is no installed or portable radiological monitoring equipment in the OSC.
Based on the above findings, this portion of the licensee's program appears to be adequate; however, the following matter should be considered for improvement.
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There were no portable radiation survey instruments located in the emergency kits available to OSC personnel and there were no provisions to make health physics technicians and pectable instrumuts readily available to teams which may be dispatched from the OSC.
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(50-259/81-19-09, 50-260/31-19-09; 50-296/
81-19-09)
4.1.1.4 Emergency Operations Facility (EOF)
This area was reviewed with respect to the require-ments of 10 CFR 50.47(b)(3),10 CFR 50, Appendix E, paragraph IV.E, and NUREG 0654, Sections II.G. and II.H.
TVA Ccmmittments for Emergency Operations Facilities are contained in Appendices A, B, C and
D of the BFN-REP and a letter from L. M. Mills to j
H. Denton dated June 2, 1981. TVA has proposed a j
concept of a centralized EOF for all TVA nuclear
facilities.
The centralized E0F consists of the
CECC, KECC, DNPEC and MSECC as previously described in Section 2.2 of this report Based on this concept, TVA has requested e.empt;on from the require.ments in 10 CFR 50.47(b) and 10 CFR 50,
.
Appendix E to provide a near-site EOF, In lieu of a near-site EOF TVA has proposed a facility at the Browns Ferry site, known as the Local Recovery Center (LRC), to provide facilities and aquipment for TVA recovery management, NRC emergency response team and other emergency and/or recovery personnel who may need ready access to the Browns Ferry Plant.
The LRC is located within the protected area and consists of the NRC Resident Inspector's Office and the adjacent TVA operations training facility which provide combined floor space area of about 3100 square feet.
These twa facilities are semi-permanent trailers immediately adjacent to the plant proper. Air conditioning and heating are provided but no special protective measures have been incorporated into the facility structure. The direct radiation protection factor is very low and
'
is estimated to be no greater than about 1.5, and there are no provisions for protection against airborne radioactivity. No alternate facility has been identified should the LRC become uninhabit-able. There was no radiation monitoring equipment at the LRC and no permanent installation of radiation monitoring equipment is planned. The NRC Resident Inspector's office has a portable radiation detector but no capability to assess airborne radioactivity nor to differentiate between radioiodine and noble gases in the atmosphere. No respiratory protective devices nor other protective equipment has been provided.
The LRC proposal includes adequate communication equipment, access to the TSC data base with SPDS display capability and access to the CECC central processer.
Some communications equipment, including NRC ENS and HPN, Bell telephone lines and PAX phones are currently installed. The additional equipment is to be provided when available; the TSC data base and SPDS are not yet functional within the plant. Plant drawings, documents and manuals are available from the document control center near the NRC Resident Inspector's office.
Due to the location of the LRC, within the pro-tected area, access to the facility is limited.
Discussions with Public Safety Officers (Security)
indicate that no special provisions have been made for access of NRC or other non-TVA personnel to the protected area in an emergency. Since NRC
.
.
,
Region II management are not normally included on the access list, there would be a significant delay in gaining access to the LRC. Upon gaining access only a visitor's type badge, escort required at all times, could be issued to those personnel which would severely limit their movement within the GFNP complex.
-This limitation would apply to NRC Headquarters persur%1 and those arriving from other regional offices to provide assistance.
i The LRC is a conceptual proposal and, as ;uch, has not been included in the BFN-REP nor the Imple-menting Procedures.
As of the date of this appraisal, there had not been a response from the NRC on the proposal and a completion date for this facility had not been identified.
4.1.1.5 Post Accident Sampling and Analysis thru 4.1.1.8 Post accident sampling and analysis involves coolant samples (4.1.1.5), containment air samples (4.1.1.6), gas and particulate effluent samples (4.1.1.7), and liquid ef fluent samples (4.1.1.8).
The facilities and equipment available for post accident sampling and analysis were evaluated against 10 CFR 50.47(b)(8), 10 CFR 50, Appendix E, paragraph IV.E, and the criteria in NUREG-0654, Section II-I.
The locations of all of the post-accident sampling areas are accessible during accident conditions and are monitored for high levels of radiation.
The design and shielding of the sampling area are such that the user should not receive excessive radiation doses from the surrounding equipment; however, in order to keep the radiation doses to the user while taking the samples as low as reasonably achievable, additional thielding for the sampling lines, dilution systems, and collection containers is necessary.
There are shielded containers, lead shielding, and remote handling
tools available for use in transporting the sample.
However, shielding for the coolant sample is the only protection used; the other samples are presently returned to the counting laboratory unshielded. This lack of protection of the user during the sample collection and transport is a deficiency in the procedures and is discussed in sections 5.4.2.4 - 5.4.2.11.
...
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The sample analysis facility should be accessible during accident conditions; however, if it is not, there are provisions to move analytical equipment to another location. Instruments and detectors for
analysis which could be used and other equipment and tools described in the procedures are available. The licensee has committed to obtain, install and test remote post-accident sampling equipment, for chemical and radiological analysis of reactor coolant liquid and gas samrles in accordance with item II.B.3.(2.1.8.a) of the TMI Action Plan.
This equipment will be operable in mid 1982.
The interim sampling techniques for the post-accident samples should provide for representative samples.
Each sample measurement and analysis should be able to be performed within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. It could take longer than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> if the equipment for
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analysis needed to be moved to the alternate location. Licensee representatives feel that the measurement and analysis could be completed within
_
the 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> guideline.
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Based on the above findings, this portion of the
'
licensee's program appears to be acceptable.
4.1.1.9.
Offsite Laboratory Facilities The TVA health physics program has its own offsite fixed laboratory for monitoring and analysis at m
Muscle Shnals, Alabama.
The laboratory is routinely used for normal environmental sample analysis, and would be activated for processing
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emergency samples within 30 minutes; faster than the samples could be brought to the facility. In
,
c
. addition,. four mobile units with field estimate capabilities are available (See Section 4.2.1.1).
The instrumentation for this laboratory is-s
, _
maintained, calibrated and routinely used for analytical purposes.
,
Based upon the above findings, this portion of the licensee's emergency preparedness program appears
_
.
to be adequate.
4.1.2 Protective Faciliti'es
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.
4.1.2.1 Assembly / Reassembly Areas
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b
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A*
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The employee parking lots adjacent to the front (main gate) and rear portals are identified in IP-8 as the plant assembly areas.
There are no designated assembly areas inside the plant structures. The Site Emergency Director, using the public address system and siren, will order the evacuation of all persons within the plant con-trolled areas if necessary. All plant employees (except those assigned emergency duties) and visitors are to proceed to the parking lot adjacent to the main gate for accountability and further instructions. Small white signs affixed to stakes in this area indicate by organization section where each group of plant personnel is to assemble.
Outage personnel are to proceed to the rear portal of the plant. Signs inside the plant direct people toward the assembly areas.
In IP-9, Division of Construction personnel and visitors are instructed to assemble at the construction gatehouse or at the construction office area in warehouse Nos. 14 and 15.
No guidance is given on how the decision will be made as to which of these assembly areas will be used.
IPs 8 and 9 indicate that Health Physics check-points are to be set up in the assembly areas to survey for personal and vehicle contamination prior
to release.
The establishment of these Health Physics checkpoints is not explicitly covered in the procedures.
The Health Physics procedure IP-14, Step 5.4, states that Health Physics personnel should be sent to the assembly areas to survey for contamination but does not specify who will be responsible for this effort, how many Health Physics technicians will be needed, or what instrumentation will be required.
If radiation levels at the employee parking lots are unsafe for occupancy, IP-8 states that the assembly point will be moved to a location specified by the Site Emergency Director based on local radiation and contamination conditions.
Discussions with plant management personnel indicated that no alternate assembly areas have been preselected in case of high radiation levels at the designated assembly areas or inclement weather.
The procedure further states that the Site Emergency Director may recall evacuated people as needed but it is not clear how this will be
_
_
accomplished especially if it is necessary to move the evacuees from the original assembly area.
Based on the above findings, this portion of the licensee's progra:n appears to be acceptable, but the following matters should be considered for improvement:
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Specify in IP-14 the procedures to be followed by Health Physics personnel to set up check-points at the assembly areas.
(50-259/
81-19-10; 50-260/81-19-10; 50-296/81-19-10).
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Consider alternate assembly areas for use in the event of high radiation levels at the designated assembly areas or inclement weather.
(50-259/81-19-11; 50-260/81-19-11; 50-296/81-19-11).
4.1.2.2 Medical Treatment Facilities A medical treatment area is located in the service bay area on elevation 565'
The auditors toured the facility and spoke to the nurso on duty. The medical treatment area includes a waiting area, treatment room, emergency room, a room with a bed, supply room, and lavatory. A registered nurse is on duty around the clock and an ambulance is stationed onsite at all times.
The medical treatment area appeared to be well stocked with supplies including potassium iodide for thyroid blocking of emergency workers. Carts with medical supplies and equipment were ready for immediate use
'
in the plant.
Adequate supplies to perform preliminary decontamination were also maintained in the medical treatment area.
However, due to the difficulty of handling a contaminated person on a stretcher, a personal decontamination room had been established in the Health Physics area down the corridor from the medical treatment area.
Arrangements for backup support for the treatment of injured and contaminated persons have been made with Colonial Manor Hospital and Decatur Hospital.
'
Arrangements have also been made for additional ambulance service if needed.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
l l
4.1.2.3 Decontamination Facilities l
.
The facilities and equipment available for the purpose of decontamination were evaluated against the requirements in 10 CFR 50.47(b)(8), 10 CFR 50, Appendix E, paragraph IV.E, and the criteria in NUREG-0654, Section II-J and II-K.
Personnel decontamination washroom and showers with chemical decontamination agents are provided onsite in. lase proxiiity to the medical facility.
Primarf instruments used for detection of contam-ination are GM, RM-14, and alpha survey meters.
The chemical decontamination agents available include water, soap, corn meal, Calgon, carboxymethyl-cellulose and Versene; if necessary, potassium permanganate could be used under the direction of the Health Physics supervisor or assistant Health Physics supervisor. Decontamina-tion procedures are available at the decontamina-tion facility.
Provisions for disposal of solid and liquid waste exist and replacement clothing is available.
There are no provisions for dacontamination at the personnel assembly / reassembly areas.
The REP states that evacuation of onsite contam-inated individuals would take place along a westbound evacuation route to the Wilson Hydro Plant utility building.
Based on the above findings, this portion of the licensee's pre cam appears to be acceptable.
However, the following item should be considered for improvement.
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Provisions for decontamination should be established at a location closer to the plant that the Wilson Hydro Plant to accommodate the re entry of necessary personnel onsite.
(50-259/81-19-12; 50-260/81-19-12; 50-296/
81-19-12)
4.1.3 Expanded Support Facilities The licensee has space available for expanded corporate and contractor personnel.
Following the Browns Ferry fire many support personnel were accommodated at the site for an extended period of time.
Currently, one staf f member from the General Electric Company works on site.
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The licensee has allotted space in the Technical Support Center (TSC) for NRC personnel.
The emergency Implementing Procedure BFN, IP-14 specifies that the Health Physics (HP)
laboratory equipment would be relocated to the TSC should the existing HP laboratory become uninhabitable. As pointed out in Section 4.1.1.2, the TSC would be too crowded even before considering the HP laboratory equipment.
Based upon the above findings, this portien of the emergency preparedness plan appears to be adequate.
However, the following space problem should be recansidered:
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The overcrowded TSC will not properly accommodate the relocation of the HP laboratory and associated pe rsont.e l.
(50-25w 81-19-13; 50-260/81-19-13; 50-296/
81-19-13).
4.1.4 News Center News Centers have been established near the Browns Ferry site. One is at the Calhoun State Junior College (a formal use agreement exists between TVA and the College) and a secondary or back-up news center has been established at the Decatur High School. Both far.ilities have adequate space and some communications equipment available.
TVA has been negotiating with the telephone company to provide advanced measures for the rapid installation of additional telephone lines at the news center.
These negotiations were not complete at the time of this appraisal.
Communications between the Morgan County Civil Defense Haadquarters in Decatur, Alabama, which is identified as the State Forward Emergency Operations Center, and the TVA news statf are adequate.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2 Emergency Equipment 4.2.1 Assessment 4.2.1.1 Emergency Kits and Emergency Survey Instrumentation The inspectors, escorted by a member of the health physics staf f, reviewed the emergency kits and survey instrumentation.
The kits were found at locations specified in the Brews Ferry Imple-menting Procedures Document (BFIPD) in procedure i
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BFN, IP-17.
The contents of the kits had been l
inventoried and the few missing components replaced l
__ _ _ _ _ _ _
on July 7, 1981, in accordance with the procedural requirements for a quarterly inventory.
Emergency Vans, for.offsite monitoring, are equipped with specified supplies. Three vehicles, dedicated to emergencies, are available at Muscle Shoals, Alabama (about one hour's drive from the Browns Ferry Station) and one at Browns Ferry.
These vans have standarized supplies and radios that communicate through a radio transciever located at the meteorology tower.
The TVA radio system includes transmission to Muscle Shoals, the Browns Ferry control room and the TSC.
See Section 5.5.1 of this report for operational checks and calibrations of equipment, facilities and supplies.
Included in the emergency kit supplies are silver zeolite cartridges for field collection of I-131, appropriate air samplers and a single channel analyzer for I-131 measurement. The system can provide field estimates of I-131 down to 1E-07 uCi/cc.
The availability of the zeolite cartridges are not specified in the inventory sheets, nor are proce-dures modified for use of these cartridges. Work on inventory listing and procedural modification is currently in progress.
Offsite capability for quanti fying particulate activity by field survey teams is available.
Ion-chamaer instruments and contamination detec-tion portable instruments are available for use in measuring both inplant and offsite radioactive gases (plumes) and surface contamination levels.
Based upon the above findings, this portion of the licensee's emergency preparedness program appears to be adequate. However, the following item should be considered for improvement:
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The inventory list and procedures should be modified to include silver zeolite for iodine collection.
(50-259/81-19-14; 50-260/
81-19-14; 50-296/81-19-14)
4.2.1.2 Area and Process Radiation Monitors The FSAR and Technical Specifications describe the fixed radiation area and process monitors used at i
the Browns Ferry plants.
The description covers the location, name, type, range and number of the
.
J
monitors, along with the environmental design characteristics.
The design characteristics adequately define the temperature, relative humidity, pressure and radiation background conditions for which the systems were designed.
Directs readout capability in the control room for these monitors is also defined.
The Technical Specifications provide for out-of-service, functional checks and calibration requirements for 'he. area and process monitors.
The cai'brations are conducted by the licensee's maintenance organization in accordance with procedures.
Technical Instruction (TI) 38, Section 2100, Appendix A references the stack monitoring system procedures.
The Browns Ferry Emergency Operating Instruction 12 (BF E01-12) is the referenced procedure. BF E0I-12, Section E. states "Mp ntain close check of ventilation systems radiation leveis.
See E01-2/ it off gas activity shows in ventilating system", following indication of stack activity. E0I-12 Section IV.F. states: " Place the selector switch for stack dilution fans in the OFF position and start the standby dilution fan. This dilution flow should keep RM-90-147 and RM-90-148 on scale. NOTE: If the radiation monitor does not remain on scale *, start the standby dilution fans on the other units in a similar manner." Following this instructica would allow an unquantified release of radienuclides to the enviNament. The licensee has committed to obtain, install and test a high range noble gas effluent monitor by January 1, 1982, although some "nonclass IE" effluent elements and monitors will be used for an interim period.
This installation will be in accordance with Item II.F.1.(2.1.8.b) of the TMi Action Plan.
BFN, IP-4, Table 7, provides a worse case exposure rate at a speci fied location at the site bes ndary.
The inspectors requested a enmputer print-out to determine the accuracy of 'he exposure rates assigned to the projected uCi/sec stack releases.
It was found that, using the licensee's com iter modeling program, the values used in IP-4 we re incorrect.
" Underlining added by the inspector
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The full capability of the ARMS to aid in assess-ment of serious LOCA/ loss of containment events is not currently recognized in the licensee's proce-dures (See Section 5.4.3.1).
The licensee has committed to obtain, install and test high range (1E8 R/hr) radiation monitors in containment in accordance with item II.F.1.(2.1.8.b) of the TMI Task Action Plan. This equipment is to be operable in mid 1982 Based upon the above findings, thc following deficiency was identified:
Therd are no identified instruments or proce-
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dures readily available in the Control Room to quantify radionuclides released to the environment should the stack monitors fail to work, or read off-scale.
(50-259/81-10-15; 50-260/81-19-15; 50-296/81-19-15).
Based upon the above findings, the following itens should be considered for improvement:
The note in E0I-12 Section E allows the
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radiation monitor to go off scale before operator actions are taken.
(50-259/81-19-16; 50-260/81-19-16; 50-296/81-19-16).
There is no " note" in E0I-12 to call Chemistry
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for a confirmatory measurement should the stack monitor fail to work, or read off-scale.
(50-259/81-19-17; 50-260/81-19-17; 50-296/
81-19-17)
4.2.1.3 Non-Radiation Process Monitors Non-Radiation process monitors, including system pressure, temperatures, flow rates, meteorological instrumentation and seismic monitoring instruments were available in the control rooms. Meteoro-logical instrumentation is described in Section 4.2.1.4 of this report.
Seismic instrumentation is installed in accordance with the FSAR and consists of strong motion accelerograph, seismic switches and inertial mass etch recorders.
Alarms are provided on the control board for actuation of the l
strong motion accelerograph, at 0.01g ground acceleration and actuation of the triaxial seismic triggers at 0.1q ground acceleration. No other in-plant alarms are available.
For actual characterization of earthquake magnitudes the
accelerograph record must be removed and sent to Chattanooga for analysis. A potential problem was identified in the procedure (IP-1) for classifying an emergency condition based on ground acceleration values.
This area is discussed further in Section 5.2 of this report.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
.
4.2.1.4 Meteorological Instrumentation The bases for the auditors review of the licensee's meteorological measurements program ir,cludeo Regulatory Guides 1.23 and 1.97 and the criteria set forth in NUREG-0654, NUREG-0696, and NUREG-0737.
The description of the licensee's meteorological measurements program was outlined in the Browns Ferry SAR.
The auditors determined that the licensee's meteorological capabilities address the requirements of NUREG-0737, Task Action Plan III. A.2 and the criteria set forth in Appendix 2 to NUREG-0654, Rev. 1 in adopting the compensating measures to milertone 3.
Instrumentation on the Browns Ferry meteorological tower provide the basic parameters necessc.ry to perform the dose assessment function. Strip chart recorders for these data are located at the meteorological station proximate to the tower and in the control room (s) serving Units 1 and 2.
The Meteorological Forecast Center (MFC) in Muscle Shaals automatically polls the minicomputer at the moteorological station to retrieve data on a continuing basis.
These data can also be transmitted to offsite authorities through ringdown te l.,p ho n e s,
dedicated telephones, and CRT terminals. In the event the meteorological system becomes inoperable, the MFC has the capability to combine available information from the National Weather Service with their knowledge of the area to provide meteorological information that is needed for dose projections.
The personnel responsible for the maintenance and operation of the meteorological measurements have duty stations at the tower site.
The system is checked Monday through Friday for proper operation and personnel are available for weekend main-
tenance. The MFC staff continually scrutinize the data so that, in combination with the frequent site checks, equipment malfunction can be detected and corrective measures taken quickly.
The instru-mentation is calibrated bimonthly following detailed procedures.
The overall preventative maintenance program and capability existing at the MFC provides adequate assurance that data recovery goals are attainable.
Site personnel are advised of the potential or existence of severe weather conditions in the site vicinity by a combination of measures.
These include notification by the load dispatcher, the MFC, and a NOAA weather warning radio.
Meteorological data can be appropriately integrated into the transport and diffusion portion of the dose projection by the staff at Muscle Shoals.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but.
the following matters should be considered for improvement:
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The meteorological data recorders i t.
the cor. trol room area should be properly main-tained (e.g.,
timing) anc; annotated to facilitate the use of data (e.g., wind direc-tion from which the wind is blowing and atmospheric stability conditions.
Engineering units should be u ed rather than percent of scale).
(50-259/81-19-18; 50-260/81-19-18; 50-296/81-19-18)
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The temperature difference measurements are recorded on inappropriate recorders; ie, range: -
to + 30 C in a 6 inch wide chart.
These -
aid be replaced with recorders that woulc'.Ilow a user to differentiate among atmospheric stability conditions; eg, -5 C to
+ 10 C on a 12 inch wide chart.
(50-259/
81-19-19; 50-260/81-19-19; 50-296/81-19-19)
4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection.
The facilities and equipment availabic for respira tory protection were evaluated against the require-ments of 10 CFR 50.47(b)(11) and 10 CFR 50,
..
Appendix E, paragraph IV.E and the criteria in NUREG-0654,Section I.
i Self-contained breathing apparatus (SCBA) are reserved for emergency use. There are units in the appropriate emergency kits and additional units are located throughout the radiation-controlled area.
A minimum of 75 SCBA units are available for emergency use. A total of 194 air bottles are on reserve. Capability for refilling the SCBA devices exists and this equiprent is usable under condi-tions in which the internal areas of cr.e plant have high airborne / direct levels of radiation.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.2.2 Protective Clothing The equipment available for use as protective clothing was evaluated against the requirements of 10 CFR 50.47(b)(11) and 10 CFR 50, Appendix E, paragraph IV.E and the criteria in NUREG-0654, Section II-J.
Specific numbers of protective clothing are reserved for emergency use and are stored with the emergency equipment at the locations listed in implementing procedure IP-17. The auditors visited the storeroom and reviewed the procedures with the Stores Supervisor which insure that an adequate stock of protective clothing is available onsite at all times. Stock levels, inventories and requist-tion of items are maintained by the Power Stores Office and were found to be up-to-date and acceptable.
Minimum stocking levels that are maintained should be sufficient for initial and continuing response to an accident.
dothing stocks are maintained outside the reactor building and should be accessible under emergency condi-tions. Reserves are also located at Muscle Shoals and other TVA sites and are available for use if needed.
Based on the above findings, this portion of the licensee's progrn appeat s to be acceptable.
4.2.3 Emergency Communications Equipment The emergency equipment specified in the Emergency Plan and I:nplementing Procedures were not complete; however, the
licensee is in the process of completing installation of several communications systems and these additions should meet or exceed the criteria of NUREG-0654 and NUREG-0696.
The inspector examined the Browns Ferry Nuclear Plant communications system in the Control Room, Health Physics office, Operations Support Center (ie, hallway in control tay), and Technical Support enter.
The inspactor checked operability and Icytions for the follosir.c syst2ms:
Technica! apport Center
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A "ringdown" circuit (5 way tie to the CECC, MSECC,
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KECC,andSequoyahTSC)
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Commercial Bell ;ine (1)
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NRC ENS VHF Radio System (In Control Room)
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Operations Support Center
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Plant PAX Phones (3)
Health Physics Office NRC HPN
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Plant PAX Phones (2)
Control Room
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NRC ENS
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Main Telephone Console with plant PAX phone interrupt VHF Radio
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Commercial Lines (There are approximately 39 circuits
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available)
TVA Tie line and "ringdown" to CECC
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The inspector also examined the communications equipment at the TVA Muscle Shoals Environmental Center.
The inspector checked operability of the following MSECC equipment:
Dedicated "ringdown" telephane line to the following loca-tions:
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- ECC (2 lines)
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KECC
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State of Tennessee EOC in Nashville (2 separate lines)
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State of Alabama EOC (1 lir e to Montgomery and 1 to Decatur)
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Sequoyah Meteorological Station (2 separate lines)
Watts Bar Mete,.ological Station (2 separate lines)
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Norris, TN
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Public Information Office line to Chattanooga, TN, and
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Knoxville, TN A S-way tie circuit between the tiSECC, CECC, KECC,
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Sequoyah TSC, and Browns Ferry TSC
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Morgan County E0C Connercial Bell Lines (10)
Federal Telecommunications Systems (on 10 Commercial Lines)
TVA Microwave System (2 Circuits)
VHF Radio to Browns Ferry CRT Disp'.sy of NOAA Weather Line Printer for Dose Projections Paging System The inspector noted that the TSC and f1SECC facilities did not have NRC HPN and NRC, HPN and ENS, respectively. Action has been initiated within the NRC to have these extensions pro-vided based upon locations selected with licensee personnel.
The inspector examined several plant alarm / evacuation sirens, and discussed inplant communications with licensee personnel.
The inspector was informed by licensee personnel that recent alarms / sirens were successful in promptly alerting onsite personnel.
The Prompt Notification System at Browns Ferry had not been installed at the time of this appraisal. TVA's response to a July 1,1981 letter frcu Region II requesting information concerning the status of the system was in draft form and a copy was given to the inspector on July 20, 1981. The system will consist of fixed sirens, mobile sirens and tone alert radios for institutional use within the 10 mile EPZ.
The fixed siren system is pmjected to be complete by October 30, 1981; the tone alert radios are projected to be in place and operational by October 30, 1981; and, the mobile sirens are under development. These mobile sirens will be used to cover a portion of the 10 mile EPZ where the population density is low.
In the interim a public notification system developed by the local Civil Defense Agencies will remain in effect.
Based on the above findings, the following matter should be considered for improvement:
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Emergency communications systems at the Browns Ferry TSC, the ilSECC and the CECC are not yet complete.
(50-259/81-19-20; 50-260/81-19-20; 50-296/81-19-20).
4.2.4 Damage Control / Corrective Action and Maintenance Equipment and Supplles
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Specific needs for onsite damage control, corrective action, and maintenance equipment and supplies were not identified in the REP. The licensee did not maintain reserves of equipment specifically far this purpose. However, the fact that Browns Ferry is a three unit site requires that a large amount of maintenance equipment and supplies be normally kept available onsite.
Support could also be obtained from other TVA facilities, both nuclear and non-nuclear, in the region.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.5 Reserve Emergency Supplies and Equipment For a serious emergency, the licensee relies on the normal inventory of supplies (e.g., survey instruments, protective clothing, respirators) to support augmen.ad emergency operations.
Adequate quantities of reserve supplies and equipment appeared to be available onsite. Browns Ferry is a three unit site and therefore maintains a higher than normal inventory cf supplies.
An onsite Power Stores facility maintains a large supply of protective clothing and has an established inventory control system with minimum stock
,
l levels identified for Health Physics and other plant sections to ensere that adequate supplies are ordered and available.
Reserve supplies are also available from a large central Power Stores facility in Muscle Shoals and from other TVA facilities.
Coordination of purchasing of instrumentation and centralization of calibration services for portable radiation monitors provide assurance of compatibility of backup instrumentation.
Based on the above findings, this portion of the licensee's program appears to be acceptable, i
4.2.6 Transportation A number of vehicles are available for emergency use. Public Safety Supervisors stated that a minimum of 3 vans would be available for emergencies if necessary.
Keys for these vehicles are controlled by Public Safety.
Communication between vans or between vans and the control point is provided through the use of portable radios.
The Shift Engineer has access to and control of a number of cars which could also be user in an emergency. An emergency van will be utilized for out-of-M ant surveys which is equipped with numerous supplies.
Specific cmergencv equipment which is listed in BFN, IP-14 will be.uken to the van in an emergency.
Two ambulances (plant and outage) and a fire
!
truck are also available for use.
l l
l
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t
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Based on the above findings, this portion of the program appears to be acceptable.
5.0 Emergency Implementing Procedures 5.1 General Content as ormat The Browns Ferry Implementing Procedures Document (BFIPD) contains the procedures that would govern the licensee's actions during postulated emergency events.
These procedures include actions for the four remotely located control centers in addition to the Browns Ferry emergency response facilities. See Section 3.1 for discussion on the training portions of these procedures.
The general procedure content and format for thc. four emergency control centers (ECC), 'ocated at varying distances from the Browns Ferry Station, are essentially identical.
Each ECC procedure covers the purpose, scope, references, abbreviations and definitions, responsi-bilities and procedure requirements.
The general content and format of the Browns Ferry Nuclear (BFN)
Implementing Procedures (IPs) varies.
BFN IP-1 is a systematized method designed for use by the Emergency Director to classify the type of emergency. This procedure is not titled, nor does it contain any guidance on what to do if the symptoms of the potential emergency do not fit into the classification scheme. BFN, IP-2 through IP-9 have two major format divisions; purpose and instructions, and (except for IP-9) notification lists that include titles, names and telephone numbers.
BFN IP-10 uses two major title subdivisions:
purpose and procedure.
IP-11 has two major sections: purpose and instructions. IP-12 is the Emergency Organization Call List.
IP-14 uses eight major sections:
purpose, general, r.otification of unusual event, alert, site emergency, general emergency, issuance of potassium iodide and use of NRC HPN Phone. In addition, IP-14 contains five attachments.
BFN, IP-15 and 16 subdivide the contents into purpose ar.d procedure.
-
BFN, IP-17 is subdivided into scope, responsibilities, frequency and procedures. BFN, IP-18 sections are titled purpose, scope, responsi-bilities and requirement.
The action steps in the BFIPD procedures are in sequential order.
Although it is a generally understood TVA policy that normal procedures and instructions will be used to the extent practical during emergency events, reference to such applicable procedures are not uniformly made in the emergency IPs. Evaluation of reactor operating procedures shows that such references are not necessarily helpful since the IPs are designed for the Reactor Shift Engineer, and the operating procedures, and Emergency Operating Instructions (E0Is) contain the methods to compensate for or correct abnormal reactor conditions.
.
_ - -
Evaluation of the Health Physics procedures / instruction, however, show>
that they did r.ot uniformly consider abnormal conditions.
The impli-cations in BFN, IP-14 are that Health Physics will follow standard practices and procedures during any response work.
(Item 3.4, BFN, IP-14).
Based upon the above findings, the General Content and Format portion fo the procedures program appears to be adequate.
However, the following items should be considered for program improvement:
-
BFN, IP-14 does not reference the applicable Health Physics standard instructions that would be used during postulated emergencies nor the provisions that would be changed to assure applicability during an emergency.
(50-259/81-19-21; 50-260/
81-19-21; 50-296/81-19-21)
5.2 Emergency, Alarm and Abnormal Occurrence Procedures The emergency, alarm and abnormal operating occurrence procedures generally contain steps that require evaluation of EALs as contained in the REP and implementing procedures. However, the operating procedure fe, seismic events defines two levels of grouno acceleration (0.01g and 0.lg) whereas the implementing procedure BFN, IP-1 establishes three levels of ground acceleration (0.01, 0.1 and 0.2g) which are necessary to properly classify an accident condition in accordance with the EAU s.
Based upon the above findings, this portion of the licensee's proce-dures program appears to be adequate.
However, the following items should be addressed to improve the procedures:
-
The BFN IP-1 seismic event criteria does not conform to existing seismic mocr itori ng capabilities nor the operating procedure concerning the 0.2g criterion. (50-259/81-19-22; 50-260/81-19-22; 50-296/81-19-22)
5.3 Implementing Instructions There is an implementing emergency procedure for each REP emergency class. These procedures are in the BFIPD, BFN IPs 2, 3, 4 and 5.
The procedures are designed for t.:e by the Site Emergency Director, who, initially, is the Shift Engineer. See Section 2.1 of this report for the onsite emergency organization and related responsibilities.
The action levels that lead to the classification of the emergency event are defined in BFN, IP-1.
Each of the emergency class IPs (2-5) defines the plant event notifica-tion requircments. Notification of the Operations Duty Specialist in Chattanooga is required for each class of emet a cy.
The procedures for the required follow up notification to state and local agencies by
the Operations Duty Specialist are in the DNPEC IPs portion of the Browns Ferry Implementing Procodures Document.
Based upon the above findings, tnis portion of the licensee's emergency procedures program appears to be adeouate.
5.4 Implementing Procedures
'
A previous infraction concerning failure to prepare, approve and adhere to written procedures which implement the Emergency Plan was reviewed and corrective actions for the six examples cited have been taken.
Item (50-259/80-16-01; 50-260/80-13-01; 50-296/80-14-01) is closed.
During the inspection a new violation concerning the lack of Imple-menting Procedures was identified and is discussed in paragraphs 5.4.2.1 and 5.5.2 below.
This violation is not related to the previous violation noted above.
5.4.1 Notifications The classification of an emergency is done by the Shift Engineer according to the logic diagram in IP-1.
Upon deciding which emergency action level applies, the Shift Engineer goes to the appropriate implementing procedure for notification irctructions.
The sequence of notifications for Notification of Unusual Event, Alert, Site Emergency, and General Emergency are specified in IP-2, IP-3, IP-4, and IP-5, respectively. The notifications in all cases are initiated by the Shift Engineer who is the Site Emergency Director until relieved by the Plant Superintendent or one of his alternates. There are always two Shift Engineers on duty who are assigned to a specific unit or units depending on which units are operating or in an outage condition. The notification procedures did not specify which Shift Engineer becomes the SED and makes the notification calls.
In IP-19, Emergency Control Center Operation, it is stated that "The shift engineer on the unaffected unit will man the ECC until relieved. The other shift engineer will direct activities on the affected unit."
This implies but does not clearly state that the Shift Engineer on the unaffected unit will make the notification calls.
The Shift Engineer relies upon the Shift Engineer's clerk, a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day position, and the Public Safety Service shif t supervisor to place the calls to activate the site emergency organization. The procedures specify the individuals to be called, their work and home telephone numbers, and short, suggested messages to inform the individual of the emergency classificatio i
The Shift Engineer, in accordance with the notification sequence, first contacts the Operations Duty Specialist (ODS)
in Chattanooga by ring-down telephone.
The procedures include the content of the message to be given to the ODS.
For the General Emergency class only, the Shift Engineer instructs the ODS to recommend initial protective actions for the public.
The ODS in Chattanooga performs notifications in accordance with DNPEC procedures. For a Notification of Unusual Event, Alert, or Site Emergency, the ODS notifies the State, the DNP Emergency Dutv Officer, and the Directors of the CECC, DNPEC, MSECC,-and KECC.
In the avent of a General Emergency, the ODS, upon notification from the Browns Ferry SED, notifies the local Civil Defense Agencies in Lawrence, Limestone, and Morgan Counties first and then the State of Alabama before proceeding with the rest of the notification chain. The ODS provides the State and local agencies with standard protec-tive action recommendations; i e.
activate early warning system and advise public to close windows and doors, stay inside, and turn on radio or television for further instructions.
Upon his arrival, the CECC Director becomes the principal point of contact for TVA with State and local agencies.
The Browns Ferry REP, in Section 4.1.1.2, states that one of the responsibilities of the SED is to make recommendations for protective actions to State and local agencies if necessary until the CECC is staffed. However, there are no provisions in the Browns Ferry notification procedures for the Shift Engineer, or SED, to communicate directly with State and local officials.
The Shift Engineer is to notify the NRC over the ENS telephone of all REP events. For the Alert, Site Emergency,
'
and General Emergency action level classes, the procedures instruct the Shift Engineer to maintain an open line until released by the NRC but then go on to state: " Communications with the NRC by ring-down phone will only be used until the CECC is manned. CECC will than handle further communications with NRC."
Shift engineers interviewed by the auditors expressed an understanding that the communication lines from the plant control room to the NRC will not be terminated until approved by the NRC.
Based on the above findings, this portion of the licensee's program appears tc be acceptable; however, the following matters should be considered for improvement:
-
Clarify the guidance in the notification procedures to maintain tne NRC ENS line open between the control room
_
_
and the NRC throughout the course of the accident unless specifically terminated by the NRC.
(50-259/81-19-23; 50-260/81-19-23; 50-296/81-19-23)
5.4.2 Assessment Actions The licensee's procedures for assessirg the poter tial consequences of accidents and the bases for recommending onsite and offsite protective actions were reviewed by the auditors. It was noted that there is no overall procedure which integrates the implementation of the licensee's accident assessment methodology.
Assessment actions are discussed in the Browns Ferry REP, primarily in Chapter 5, Emergency Conditions, and Chapter 6, Emergency Measures, and are implemented in the following procedures:
IP-1, Emergency Plan Classification Logic IP-2, Notification of Vausual Event IP-3, Alert IP-4, Site Emergency IP-5, General Emergency IP-18 Potential Release Evaluation Froceduce MSECC IP-10, BFNP - Emergency Dose Assessment Procedure for Atmospheric Releases of Radioactivity MSECC IP-11, BFNP - Emergency Dose Assessment Procedures for Liquid Releases of Radioactivity The auditors reviewed the procedures for clarity and completeness, conducted walk-through observations of opera-tions personnel, and interviewed plant management and members of the emergency organization both at Browns Ferry and the Muscle Shoals Emergency Control Center.
The findings are discussed below.
\\
The Shift Engineer untilzes IP-1 for guidance in determining the classification of an accident and to select the appro-priate notification and response procedures. Shift Engineers interviewed by the auditors expressed general satisfaction with the logic diagram approach to classifying the severity of incidents; however, some of the action levels were thought to be ambiguous.
For the most part, the action levels in IP-1 are consistent with the EALs in NUREG-0654, Appendix 1, and the reporting requirements of 10 CFR 50.72.
Some inconsistencies were noted between the emergency action
-
levels specified in IP-1 and those given in Section 5.2 of the REP. This was explained as being due to recent revisions in the implementing procedures which weren't reflected yet in the REP. This type of discrepancy was also found in other areas of the REP.
__ _
^
Upon detection of a known or suspected emergency condition, the Shift Engineer on duty, utilizing IP-1, activates the emergency plan.
The implementing procedures for the four accident categories contain specific instructions regarding the notification of the TVA Operations Duty Specialist in Chattanooga and the Browns Ferry permanent SED or his alternate.
The procedures also contain instructions for activating and staffing the plant emergency response facilities.
Technical support at the plant level for assessing the potential consequences and severity of an accident is provided by the TSC staff. Plant personnel in the TSC utilize IP-18 to estimate the radioactive release rate to the atmosphere in the event of a loss of coolant accident. The procedure enables the TSC staff to calculate total iodine release rates based on actual plant measurements and conditions and to project potential release rates based on assumed further degradation of plant conditions.
The procedure does not address releases from other types of plant accidents or accidents more severe than the design basis loss of coolant accident.
The responsibility for calculating plant releases is transferred to the KECC once this center becomes staf fed. The KECC, in coordinatian with the TSC, transmits the release estimates to the i",ECC for the determination of the radiation dose consequences.
The dose assessments and recommended protective actions are provided by the MSECC to the CECC which is the principal TVA point of contact with State and local agencies. A review of the procedures and interviews with plant personnel established that there is no individual or group within the Browns Ferry TSC assigned the responsibility for performing preliminary dose calculations or making an initial assessment of the potential radiological consequences of an accident.
Certain action levels in IP-1, in particular those involving a gaseous release of radioactivity, are given in terms of exposure rates and equivalent dese.
For example, a site boundary expnsure rate of 50 mR/hr would result in the declaration of a Site Emergency, IP-4, by the Shif t Engineer.
A release of radioactivity corresponding to a dose rate greater than 1 Rem /hr whole body or 5 Rem /hr thyroid would result in the declaration of a General Emergency.
When questioned as to how they would determine the doses at the onset of an accident, the Shift Engineers stated that they would rely upon a Health Physics monitoring tram from the plant to measure the radiation levels offsite. There are no other provisions or decisional aids in the control room to permit the Shif t Engineers or others in the emergency
. _. _.
-
__
- l
organization to project offsite dosa consequences based on installed control room instrumentation.
The inspectors were shown a table which has been developed for insertion into the IPs to allow the Shift Engineers to make a quick estimate of site boundary exposure rate from plant stack releases under worst case meteorology conditions based on stack flow rate and stack monitor readings.
The
,
table was undergoing PORC review at the time. The inspectors had several questions about the table, including how worst case meteorological conditions were defined, and how the exposure rate from a plume exiting the approximately 600-foot stack would be observable at the site boundary (defined in the REP as the security fence). Due to the uncertainties and limited application of the licensee's table relating stack release rate to site boundary exposure rates, the inspectors determined that there is currently no means, based on installed control room instrumentation, to project exposures or exposure rates to the whole body and thyroid of individuals located within the plume exposure Emergency Planning Zone, or to personnel onsite.
The licensee has committed to provide high range noble gas radiation monitors in accordance with NUREG-0578 require-ments.
However, the licensee has not developed an interim method for estimating the amount of radioactivity released and the resulting radiological consequences if the presently installed noble gas radiation stack monitors go off scale.
The licensee's short term actions in this event, as described in Technical Instruction 38, are to (1) shut down all operating reactor units, (2) increase air flow by starting additional dilution air fans, and (3) obtain greb samples. A method involving the use of portable radiation monitors was discussed with the licensee as an acceptable interim solu-tion.
There are at present no provisions for determining tha containment source term using a high range containment monitor in the event of an accidental release of radio-activity inside containment. The licensee has committed to install such a monitor by mid 1982. (see Section 4.2.1.2).
The methodology for estimating potential or actual radiation doses to persons near Brcwns Ferry in the event of accidental releases or radioactivity to the atmosphere is given in MSECC IP-10.
The auditors visited Muscle Shoals and interviewed members of the MSECC staff who were involved in the develop-ment of MSECC IP-10 and would use it in the event the MSECC is activated. The auditors also reviewed technical documents which provide the assumptions and technical beses for dose
,
assessment procedures in MSECC IP-10. The procedures were i
i
- - -
,
-
.
developed to cover a range of accidents from those considered most probable to those involving major core failure and degradation of engineered safeguards. Three distinct source terms are incorporated into the procedures:
(1) a mix of noble gases, (2) iodine-131 only, and (3) a spectrum of 58 mixed fission and activation products.
A straight line Gaussian plume model is used to determine atmospheric dispersion.
Doses to individuals are calculated for the pathways of external plume exposure, inhalation, and drir. king milk.
Site data on radioactive release and meteorology are input to the dose assessment procedures in MSECC IP-10. Input data worksheets in MSECC IP-10 indicate that plant releases may be specified as noble gases, iodine, or mixed fission and activation products. MSECC and plant personnel interviewed by the inspectors indicated that plant releases of radioactive materials to the atmosphere will be determined oy TSC and KECC personnel using the methodology presented in IP-18.
However, as discussed above, the capability to provide release rates other than for noble gases and iodine appears to be beyond the scope of IP-18.
The dose assessment procedures in MSECC IP-10 are essentially a manual technique in which tables, figures, and calculators are employed to obtain the results.
A computerized dose assessment model has been developed by the MSECC staff to augment the dose calculational procedures in MSECC IP-10.
This model will be incorporated into a MSECC implementing
procedure in the near future.
The new computer model also employs a straight line Gaussian plume dispersion model but, in addition to producing dose results quickly, has the advantage that the user can specify a spectrum of isotopes as an input option.
The dosimetry worksheets in MSECC IP-10 include the time to reach a dose limit or a protective action guide (PAG) as a parameter to be considered in the evaluation. However, there is no discussion in the procedures regarding the appropriate action levels and PAGs to be used by assessment personnel as a basis for making protective action recommendations.
The dose assessment procedures in MSECC, IP-10 and the newer computer version are intended for use in short term emergeng situations (up to several days) to obtain dose projections quickly to assist in developing protective action recommenda-tions.
For accidents that continue over a long period of time, or for a detailed post-accident assessment using best j
estimates of actual meteorological conditions and radioactive
~
releases, the TVA computer model RADACC is availabl _
-.
.
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.-_
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- On July'20, 1981 a discussion was held between the inspector
!
and a' representative of the State of Alabama Department of l-Radiological ~ Health (DRH) in which the State representative
!-
expressed concern over the methodology differences in.
assessing the offsite consequences of a major release of radioactive materials from the Browns Ferry site between TVA
.
and the State DRH. The-State had no computer capability and l
uses a calculational projection model which yields signiff-
!:
cantly different results, in some cases, than the TVA method.
i The differences between the two methods are most significant near the site and decrease with distance away from the
!
release point. TVA contends that their approved pmcedure, MSECC-IP-10, yields similar results to that of the State,' bot
'
that their computer method provides flexibility in assessing a spectrum of accident situations and will eventually replace.
IP-10 as their approved method. A TVA representative stated that they have the capability to resolve the differences between their method and the State's method and that TVA will i
keep the State advised of the most accurate projections throughout the course of an accident.
l Based on the above findings, the fo' lowing deficiencies l
were identified:
.
-
Lack of a procedure, based on instrumentation available -
in the control room, to initially project site boundary exposure rates in order to properly classify an accident using Implementing Procedure IP-1.
(50-259/81-19-24;
_50-260/81-19-76; 50-296/81'-19-24)
-
Lack of a methodology to evaluate the radiological releases rates i f the presently installed noble gas effluent radiation monitors in the plant stack become inoperable or go off scale. (50-259/81-19-25; 50-260/
81-19-25;50-296/81-19-25)
Based on the above findings, the following arps should be considered for improvement:
l
-
Develop an overall procedure covering the accident assessment methodology, including 'both operational and radiological aspects, employed to gather data 2nd to make calculations on which protective action recommenda-i, tions are based.
(50-259/81-19-26; 50-260/81-19-26; i
50-296/81-19-26)
i
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Specify the action levels and protective action guides
,
used' by assessment personnel to make protective action
!
recommendations.
(50-259/81-19-27; 50-260/81-19-27:
50-296/81-19-27)
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Estab;ish an accord with the State of Alabama cancerning resolution of dif ference in offsite consequences projec-tions.
(50-259/81-19-2S; 50-260/81-19-28; 50-296/
S1-19-28)
5.4.2.1 Offsite Radiological Surveys This report section includes the radiological and environmental mar.i tori ng program (5.4.2.12)
because the TVA system utilizing Muscle Shoals and Browns Ferry Station surveillance links the environmental monitoring program with offsite emergency surveys.
As stated in the REP, a vehicle is available for radiological surveillance duty which would be dispatched for environmental monitoring for Alert, Site Emergency, and General Emergency classes and would be deployed for the Notification of Unusual Event, if warranted.
The plan stated that the sampling team has the capability to obtain environ-mental samples for analysis, make direct radiation readings, collect air samples and analyze them for radioiodines in the field.
The plan states that the sampling team from the plant can ce deployed within 30 minutes of an accident. At least one additional team from Muscle Shoals can be at the plant within one hour of notification. Additional teams dispatched from the MSECC could be at the plant within two hours of notification; an all weather helicopter was available for use by the MSECC teams.
,
There were no emergency procedures written for the Health Physics personnel from the plant to use'from the time of deployment until time of arrival of the MSECC team, including sampling and analysis methods and equipment to be used in the field, communications, and radiation protection guidance for emergency offsite radiological surveys.
The backup offsite monitoring teams, located at Muscle Shoals, have procedures for assisting the Browns Ferry Station, should the need arise, in the MSECC IP-5 section of the Browns Ferry Implementing Procedures Document. However, these procedures do not address plume monitoring, mask fitting and use for I-131 in breathing air, the possible ranges of dose rates in plumes and at preestablished
,
'
environmental monitoring stations (especially continuous air samples)
or dose commitment limitations.
.
,
____ ___
Ine licensee's environmental monitoring stations are not identical with those of the State of Alabama or the State of Tennessee.
However, in Alabama the licensee changes out some of the State samples and sends them to the State for their cnalysis.
In Tennessee, the licensee has some common environmental statio1 locutions (they both use the same po,ver source) but the samples taken for analysis are independent.
The licensee's cavironmental station sample collection system uses pre printed forms to assure
. proper nmple data on a station by-station basis.
Thus, each sample is uniquely laiaeled for later identification.
The cer. tral collection point for all er.vironmental samples is at the River Oaks Bulding (ROB) in Muscle Shoals, Alabama. There are three dedicated environmental vans equipped for emergency situations, with three more that could be equipped should the need arise.
The vans are equipped with radios that would be used for communications via the Browns Ferry transceiver (located on the meteorological tower) to Muscle Shoals, the Control Room and the TSC.
Four alternative methods of communication are available between the Muscle Shoals Emergency Control Center and the other Corparate and Browns Ferry Control Centers (See Section 3.1).
The failure to provide procedures for of1 site monitoring teams required to be dispatched from the Browns Ferry Site in an emergency is an apparent violation of Technical Specification 6.3.A.8.
(50-259/81-19-29; 50-260/81-19-29; 50-296/81-19-29)
5.4.2.2 Onsite Radiological Surveys 5.4.2.3 The emergency onsite radiological surveys were reviewed against the requirements of 10 CFR 50, Appendix E, paragraph IV.E and the criteria of NUREG-0654, Section II-I.
Emergency on-site radiological surveys are to be taken in areas in plant and on-site (out-of plant).
The surveys would include direct radiation readings, and gas, particulate, and iodine air samples for analysis.
There are presently no emergency procedures writ ten for Health Physics personnel which describe methods, equipment, communications, and radiation protection guidance
.
.
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for emergency on-site radiological surveys.
A licensee representative stated that TVA feels that their routine survey and monitoring procedures are adequate. for all situation.
Based on the above findings, this portion of the licensee's program appears to be acceptable; however, the following should be considered for improvement:
-
Emergency procedures, training, and instruc-tions for Health Physics personnel defining methods, equipment, communications, and radiation protection guidance for emergency on-site radiological surveys were not available. (50-259/81-19-30; 50-260/
81-19-30; 50-296/81-19-30)
5.4.2.4 Poct-Accident Sampling and Analysis thru 5.4.2.11 The interim post-accident sampling and analysis procedures were reviewed by the inspectors and evaluated curing walk-through to determine personnel familiarity with the procedures and procedural applicability.
These procedures were evaluated against the requirements of 10 CFR 50, Appendix E, paragraph IV.E and the criteria in NUREG-0654, Section II-I.
Procedures (Technical Instructions) for post-accident sampling which were reviewed included:
TI-38, Section 2101 (coolant sampling); TI-38, Section 2102 (containment air sampling); and TI-38, Section 2103 A (gas effluent sampling); and TI-38, Section 2104 (particulate effluent sampling).
Liquid effluent sampling was not covered in TI-38; normal procedures for liquid ef fluent sampling were discussed in surveillance instructions 4-8-A-1 and 4-8-A-2.
There are no special procedures estab-lished for analyzing the post-accident samples; normal counting procedures are discussed in TI-38.
All sampling procedures provide detailed instruc-tions for the operation of the necessary equipment.
-
The sampling point locations are clearly decribed and the procedures address the sampling uedia and special equipment to be use i Provisions to limit exposure to sampling personnel and verify the habitability of the areas occupied by sampling personnel are discussed in T H 8.
However, provisions for additional shielding of the
.
sampling systems and containers used for trans-porting the samples would assist in keeping personnel dose levels as los as reasonaoly achievable (ALARA).
After reviewing the proper procedures and con-ducting walk-throughs with the appropriate personnel, the inspector determined that each post-accident sample could be obtained in-one hour or less.
Special analytical procedures are not established for high-level samples; normal counting procedures would be employed.
Dilution of gas and liquid samples is established in the sampling procedures; however, the techniques to be used for further dilution of samples at the counting facility are not discussed. The counting geometry of the liquid and filter samples can be changed to attempt to achieve a counting deadtime of less than 10*/, and calibration curves are established for the different geometries.
TI-38, Section 2106, dis-cusses the procedure to move necessary analytical equipment to an alternate site if the primary counting area has a high background.
The normal counting procedures discuss protection of the counting equipment from contamination.
Data is analyzed using a HP-9830 calculator inter-faced with the counting equipment and employing
-
appropriate software.
The analytical methods should achieve the desired ends and the analyses can be completed in two hours if the counting equipment doesn't have to be moved to the alternate location.
Based on the above findings, this portion of the program appears to be acceptable; however, the following matter should be considered for improvement:
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ALARA dose levels are not achieved due to the absence of shielding in sample collection and transportation.
(50-259/81-19-31; 50-260/
81-19-31; 50-296/81-19-31)
-
a
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5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The TVA policy regaroing procedures and instruc-tions for emergency events, in terms of radiation protection, is to rely on normal operating proce-dures and instructions to the extent practicable.
Where existing procedure: and instructions are not sufficient, emergency Implementing Procedures are developed. However, many of the provisions found in existing normal opqrating procedures and instruc-tions do not con:,ider the high levels of radiation dose rates, contamination and concentrations of radionuclides that could exist over the full range of postulated accidents.
For exan.ple, a Browns Ferry Station Instruction L.ctter (SIL) requires that a Special Work Permit (SWP) be completed prior to entrance into a high radiation area. During an emergency, certain essential functions such as life saving, fire fighting, shutdown of vital equipment or even surveillance of a specified area could be unduly impeded by such advance paperwork.
The existing Implementing Procedures and SILs do not adequately provide precautions, hazards and instructions for assuring the overall protection of the Health Physics technicians and other workers during assessment, corrective and prctective actions.
Walk-through discussions with Health Physics shift supervisors and technicians snow a lack of knowledge in this general area.
Review of the Health Physics Section Instruction letters shows that there are no uniformly developed precautions for conditions that would be expected during the full range of postulated emergency events.
Consideration of the use of data from several area radiation monitoring alarms, that simultaneously might alarm or read offscale following severe loss of coolant accidents (LOCA),
including containment loss, is not specified.
No consideration is given to what types of surveys would be useful following the various LOCA types and what dose rates might be encountered (based upon the percentage of core damage). HP SIL 2 asks the right questions, but does not reference docu-ments that would provide estimates of dose rates
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._
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-
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and contami. nation levels which are needed as a r
basis for Health Physics technicians' decisions.
m.
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The types of dose rate instruments, respiratory profection and self-reading dosimeters necessary for fire fighting, vital equipment repair, and lifesaving activities to the extent possible, need advance ~de'inition which is currently lacking.
BFN, IP-15 provides guidance on the amount of radiation exposure that is acceptable for various types of activities during emergency events. It is specifically mentioned that only volunteers will be selected for emergency exposure (above normal limitations) unless they are members of an emer-
.
gency team and have.previously consented to receive such exposures. ~Tollowing such exposures, BFN,
- IP-I5 specifies that the volunteer must be removed from areas in locations where they could receive
another emergency dose. The decision on the amount
+
of whole body-dose allowed for a given mission is specifically delegated to the Emergency Director.
,
However, the means to control volunteer exoosures
-
within the 100, 25 and 10 rems categories is not
~
specified.
-
Statements undar the site emergency category
~ require " Precautions must be taken to prevent over
~
,
, exposure if there are high concentrations of
-
radioactive _.particulates or radiciodine being
'
released."
Although the precautions are not
-
defined, the-inclusion of a procedure for Thyroblock (potassium iodide)
is attached.
However, there appears to be a conflict in the level of thyFoid dose that would initiate the use
"
.of potassium iodide. In Table 2 of BFN, IP-15, 5 rems is specified as the initiation level, and in OBFN, IP-14,10 rems.
Based upon the above findings, this portion of the licensee's program appear to be acceptable.
5.4.3.2 Evacuation of Owner Controlled Areas There currently are no specific cmergency action
-.
levels that require evacuation of specified areas,
_"
buildings and the site.
However, initiation of area radiation monitor alarms would automatically evacuate a given work location. The only specified
.
.
.
sy
, -
action level (100 mrem of whole body dose commit-ment) is for relocation from normal work areas to the parking lot assembly area.
Once relocation of non-essential personnel to the parking lot assembly area occurs (as specified in IP-3), accountability and contamination checks wcald be initiated. IP-8 states " Employees will be-eleased from their assembly points when the Site Emergency Director determines it is suitable.
He
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will assure that all people and vehicles pass through the Health Physics checkpoint adjacent to the main gate for survey prior to being released.
If the radiation levels at the employee parking lots are " unsafe" for occupancy, the assembly point will be moved to a location specified by the Site Emergency Director." While it can be implied that the same action level (100 mrem of whole t,ody dose commitment to an individual) would apply to reloca-tion from the parking lot, it is not so stated.
Further, since contamination surveys would not be effective in dose rates significantly above background, there is some question as to the validity of the portior, of the procedure requiring contamination checks near the main gate.
No alternative re-assembly are4s are specified for such events, farther from the plant, that would allow judgements that take into account wind direction and continuing releases from the plant.
Although IP-8 states that the Site Emergency Director may recall evacuated people as reeded, no means for communications with evacuating personnel are specifi ?d.
Specific actions for th: Plant Emergency Organiza-tion, Healtn Ihysics Technicians and Public Safety Service Employees are defined in IP-8 (non-essential personnel are described above).
In addition IP-9 describes the locations at which construction personnel will assemble. However, no mention of site evacuation is made. The procedure does require contamination checks for personnel and vehicles.
Provisions exist for announcements over the facility public address system to describe protec-tive actions that are to be taken by persons on the Browns Ferry Sit _
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Based upon the above findings, this portion of the licensee's program appears to be acceptable; howaver, the following matter should be considered for improvement:
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There are no designated alternate assembly areas outside of the security area that would allow accounting for people and checking both persons and their vehicles for contamination.
(50-259/81-19-32; 50-260/81-19-32; 50-296/
81-19-32)
5.4.3.3 Personnel Accountability The personnel accountability system is described in BFN, IP-8 for plant personnel, and BFN, IP-9 for construction personnel.
The Emergency Plan (page 70) states that "The names of any missing indivi-dual should be available within approximately 30 minutes." The account 3bility portion of BFN, IPs 8 and 9 specify the individuals, by position ti tl e,
rcsponsible for accountability.
Ther e are provi-sions for formation of search parties to find missing persons, should that become necessary.
There are, howevar, no provisions for continuing accountability for persons who stay onsite.
Based upon the above findings, this portion of the licensee's emergency procedures program appears to be adequate.
5.4.3.4 Personnel Monitoring and Decontamiation Procedure: Tor personnel monitoring and decontam-s ination were reviewed against the requirements of 10 CFR 50, Appendix E, paragraph IV.E and the criteria of NUREG-0654, Section II-J.
No emergency procedure for personnel monitoring and decontamination is available; however, these areas are addressed in the REP and normal decontamination procedures (Health Physics Section Instruction Letter No. 7) are available and would be used in an emergency.
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The REP states that all people and vehicles must pass through the Health Physics checkpoint adjacent to main gate for survey prior to being released.
This checkpoint will be moved if the radiological conditions require it.
If evr uees require radio-logical decontamination, they will be informed of transportation, sheltering, and decontami.iation arrangements prior to leaving the plant site.
There is a means for recording the names ;f indivi-duals surveyed, the extent of arj contamination found, the instrument used, the methods employed and results of any decontamination efforts.
The procedures contain contamination levels that require decontamination actions and aoove a specific contamination level, thyroid or whole body counos will be required.
Based on the above firidings, this portion of the licensee's program appears to be acceptable.
5.4.3.5 Onsite First-Aid / Rescue The procedure for responding to an onsite medical emergency situation is given in IP-10, Medical Emergency Procedure.
The procedure covers all aspects of a medical emercency including initial reporting, activation of the medical emergency response team, and general patient care guidelines for the handling of radiologically exposeo or contaminated individuals.
The medical emergency response team consists of a Team Leader (Unit 1 Assistant Shift Engineer), a Public Safety Officer, a chemical laboratory analyst, a Health Physics technician, and a Nurse. A Nurse is on duty at all times at the plant and a TVA ambulance is available ensite. Arrangements have been made with two local hospitals and three ambulance services for assist-ance if required. A notification l'st for offsite assistance and maps te the agreement hospitals are provided in the procedure.
The procedure also includes general guidance on evacuating an injured employee from the torus and drywell.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.4 Security During Emergencies Security mea >ures to be placed in effect for a plant emer-gency as declared by the Shif t Engineer are specified in
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IP-11. Security and Access Control.
Public Safety Service (PSS) personnW are relied upon to perform certain predetermined actions including making notification. calls to plant emergency staf f, controlling access to the site, and performing an accountability check.
Interviews with PSS personnel established that they had a clear awareness of their duties in support of the REP. Security proceda es in the event of special emergency situations are also addressed in the PSS administrative document PSS-SIL 19 titled,
" Contingency Plan Security Matrix," A review of this docu-ment indicated that the security procedures to be implemented as part of the REP were developed in accordance with the requirements of 10 CFR Part 73.
Based on the above findings, th:s portion of the licensee's program appears to be acceptable.
5.4.5 Repa t r/ Corrective Actions An implementing procedure for repair and corrective actiins in an emergency has not been developed by the licensee. As indicated in the REP and confirmed in interviews with licensee personnel, the licensee plans to rely on normal operating procedures to govern the actions of plant personnel to correct or mitigate an emergency situation.
Based on the above findings, the foliceing improvement should be considered:
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Develop m ocedures to govern the emergency functions of repair and corrective action teams including team formation, possible operations in high radiation fields, and radiological sa fety consideration..
(50-259/
81-19-33; 50-260/81-19-33; 50-296/81-l'-3?)
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i 5.4.6 Recovery The Implementing Procedure BFN, IP-5 provides the means to notify the various agencies and individuals that a recovery mode is underway.
BFN, IP-8 designates the Site Emergency Director as the authority to authorize reentry. BFN, IP-16 includes guidance for effectively using resources to provide
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limitation and management radiation exposures.
IP-16 specifies that all major post-incident recovery measures will be accomplished via written procedures. Continuous assest-
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ment of radiation dose rates and contamination levels will be accomplished during the recovery mode. Dose limitations will be governed by IP-15 for both external and internal exposure modes.
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Based upon the above findirgs, this portion of the licensee's emergency procedures program appears to be adequate.
5.4.7 Public Information The auditors discussed the area of public information with licensee representatives and observed facilities to be used to disseminate information to the news media and the public during an emergency.
Through their ongoing public informa-tion program there has been wide area coverage of the public through television and radio spot announcements and newspaper publications. Information is provided as to whom to contact for additional information on emergency preparedness around the Browns Ferry site. A " Citizen Action Line" is in place and is staffed with personnel who have been trained in dealing with the public in crisis situations.
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Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5 Supplementary Procedures 5.5.1 Inventory, Operational Checks and Calibratior, of Emergency Equipment, Facilities and Supplies The licensee has procedures covering the inventory checks and calibrations of Emergency Equipment Facilities and Supplies.
Review of the procedures indicated that the inventory portion of the system was adequate.
The review of records on functional checks, calibration and inventory audits showed that the instruments, equipment and other supplies are checked in accordance with established requirements.
Spot checks on telephone operability, along with the licansee's routine checks indicated that the communications are routinely tested for operability. The emergency envirar mental vans are started up weekly, maintained full of gasoline and are in a dedicated state of readiness. Other emergency equipment, such as rimbulance and fire trucks are routinely checked and serviced.
Based upon the above findings, this portion of the licensee's emergency preparedness program appears to be adequate.
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5.5.2 Drills anc' Exercises f
The licensee's program for conducting drills and exercises is described in Section 9.2 of the REF.
The following drills are scheduled:
Medical Emergency - annually Radiological Monitoring - annually Radio-Chemistry - annually
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Transportation periodically Radiological Dose Assessment - semiannually Fire periodically i
This section of the plan was prepared by the Radiological Emergency Planning and Preparedness Group in Muscle Shoals.
The Browns Ferry Standard Practices Manual, BF 22.1, states that the Ccmpliance Staff and Operations Supervisors are responsible for an exercise testing site response and communication once per year for each operations group.
Section 6.1.2 of the REP states that ti sting of the emergency staff notification features of the F an are carried out l
quarterly.
There is no specific procedure available which implements this portion of the Plan.
The inspectors examined drill records and interviewed plant personnel and responsible members of the REPP group in Muscle
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Shoals. An extensive series of drills on familiarizing plant personnel with the new REP has been conducted by the Compliance Staff Supervisor with the full support and involvement of the Plant Superintendent.
Deficiencies identified during these drills have been used to develop improvements in the REP and IPD. However, it was not known whether these drills would be conducted on a regular basis in the future.
Medical and fire drills have been performed periodically by plant personnel during the past year in accordance with written procedures. Radiological assessment and other drills have been performed by Muscle Shoals per-sonnel, however, there has been little, if any, involvement of plant personnel.
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The revien indicated that the licensee's program is frag-mented among several groups onsite and further diluted with the responsibility for' drills divided between the site and Muscle Shoals. The documentation of drills was found to be inconsistent and there were no management controls to ensure that discrepancies identified in the drills would be used to develop corrective actions.
The failure to provide a procedure which implements the drills and exercise requirements o'
the Radiological Emergency Plan is an apparent violation of Technical Specification 6.3. A.8.
(50-259/81-19-29; 50-260/81-19-29; 50-296/81-19-29).
5.5.3 Review, Revision and Distribution The TVA's Radiological Hygiene Branch, located in Muscle Shoals, has developed a management commitments system to track all emergency preparedness items requiring updating, revisions and reviews. The persons responsible, dates due, dates completed and other pertinent items are identified and followed up on by the Radiological Emergency Planning and Preparedness Group. Included in the commitment listings are telephone numbers, persons on distribution, the Radiological Emergency Plan (REP), documentation of drills and exercises and the Implementing Procedures Document.
Review of the REP and changes thereto are covered in the REP Change Control Procedure, REPP Instruction No.
5.
All changes are tracked through acknowledgment of receipt for both the REP and IPD.
Review of the Management Commitment System showed that all items were being tracked by the responsible group.
Based upon the above findings, this portion of the licensee's emergency preparedness program appears to be adequate.
5.5.4 Audit Two corporate and one Browns Ferry Station Quality Assurance groups audit the emergency plans and procedures annually.
These audits include analysis of plans, procedures, exer-cises, drills, and visits (Corporate) at the Browns Fer y Station.
They include equipment, records and document control.
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A previous unresolved item concerning followup on QA audit findings and corrective actions was reviewed. A mechanism is in place to ensure that follow up and corrective actions are taken for all QA audit items identiffed.
Item (50-259/
80-16-03; 50-260/80-13-03; 50-296/80-14-03) is closed.
6.0 Coordination with Offsite Groups 6.1 Offsite Agencies The insoector discussed offsite support agencies with licensee repre-sentaitves and reviewed support agreement letters centained in Appendix E of the Browns Ferry REP.
Agreements have been concluded with various offsite groups to provide assistance in an emergency and the letters of agreement were current. Training has been provided for all offsite support groups who may be called on to assist in an emergency.
In general, all of fsite groups responding to the site will be accom-panied by Public Safety Of ficers while inside the protected area bounda ry.
On July 22, 1981, the inspector and licensee representatives visited the Decatur General Hospital, AAA Ambulance Service in Decatur and the Limestone County Sheriff's Office to discuss emergency response to an accident at Brown: Ferry with representatives of those agencies.
The individuais contacted at each of the ab3ve agencies were cognizant of their expected role in an emergency at the Browns Ferrv site, had been provided training relative to their respective roles, and were satisfied that adequate communications concerning emergency response i
between their organizations and TVA have been provided.
It was noted that TVA no longer has a written agreement with the Athens Fire Departemnt although training is still baing provided to Athens by site personnel and there is a general understanding that the Athens Fire Department would provide assistance if needed. Since the Browns Ferry site now has its own modern fire truck, trained Fire Brigade and provisions to augment the Fire Brigade with off duty personnel who are trained in fire fighting, the lack of agreement with an offsite fire agency for assistance does not appear to be significant.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
6.2 General Public TVA meets the requirement to provide for dissemination of emergency planning irformation to the public within the plume exposure EPZ. This has been accomplished by issuance of a brochure to every locatable
household within a 10-mile radius of the Browns Ferry plant which includes:
a.
Information to the public as to how they will be notified.nd what action they should take in the event of an emergency. Evacuation zones are shown along with information on relocatien centers.
b.
Information about radiation that is accurate -- but not technical
-- and should be easy for the layperson to understand.
c.
A TVA cortact fur adc".tico41 information.
In addition TVA has issued follow-up announcements for the Browns Ferry area newspaper and radio and television stations consisting of public service announcements to inform area residents of the brochure's existence, and how to obtain a copy if it has been misplaced or missed in the mail. The TVA information action plan calls for annual updating and annual dissemination of emergency information.
The licensee's program appears to the acceptable.
6.3 News Media TVA has an active program for familiarizing news media with:
points of contact for release of public information space allocated for media use information about radiation normal plant operation versus accident operation
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accident sequences
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This has been accomplished through the conduct of media seminars held by TVA at the utility's training center near Chattanooga. The presence of control room simulators and other equipment for use in these seminars increases their value to media representatives in attendance.
TVA also has er information officer assigned to each operating nuclear plant site and plans to continue this practice as new sites come on line.
Brochures for use by media representatives are made available at seminars and will be pres (nt in news centers during the course of an accident.
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TVA has conducted these media seminars for Browns Ferry during the i. cst
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year and plans to cont!aue annually at a similar pace for all nuclear power plant sites.
Based on the above findings, this portion of the licensee's program
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appears to be acceptable.
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7.0 Drills, Exercises and Walk-Through 7.1 Program Implementation Drills required by the REP have been conducted during the past year. A full scale exercise involving offsite agencies is scheduled for September, 1981.
A series of drills has been performed under the supervision of the Compliance Staff Supervisor, the designated EPC, to familarize plant personnel with the new REP.
Drills including those involving radioledcal dose asses ment and environmental monitoring have been conducted by the Radiological Emergency Planning and Preparedness Group in Muscle Shoals, the TVA organization with responsibility in this area.
Howeter, there has been little involvemant or coordination between plant personnel and those in Muscle Shoals regarding the drill program. A major problem in this area, which has been identified in Section 5.5.2, is the lack of a unified procedure which implements the driil and exercise requirements of the REP.
To ensure a cohesive program in this area, on onsite individual should be assigned the responsibility to direct and coordinate the drill and exercise program.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
7.2 Walk-Through Observation The inspectors conducted interviews and walk-throughs in emergency detection, accident classification, and notifications with three Shift Engineers (SEs). The SE is the senior operations person on sh!ft and, in the event of an emergency, is the acting Site Emergency Director (SED) urtil relieved by the Plant Superintendent or one of his alternates.
There are always two SEs on duty; typically, one SE is assigned to the operating units while the other SE is assigned to the outage unit. The SEs were questioned as to which one would assume the position of SED in an emergency situation.
They stated that it was their understanding the SE on the unaffected unit, most likely the unit in outage, would assume the duties of SED while the other SE would concentrate his attention on the operation of the affected unit. Words to this effect have been 'ncluded in a new procedure, IP-19, Emergency Control Center Operation (see Section 5.4.1).
The SEs, when given postulated initiating events and instrument readings by the auditors, displayed no hesitation in going to the radiological emergency implementing procedures document. The SEs had a
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each participated in several drills involving the use of IPD and it was evident they were f amiliar with the document. The SEs indicated they were pleased with the logic diagram appraach to classifying accidents
given in IP-1.
By followicg the diagram, they were able to rapidly classify the accident and select the appropriate implementing procedure. One SE stated that the use of IP-1 relieved the SEs of having to decide whether or not to declare an emergency; now, once the initiating condition is recognized, the emergency actions are standardized in the procedures.
Although there was general satisfication with the accident classification scheme, the SEs thought that some of the initiating conditions were ambiguous or not realistic.
An example cited was the complete loss of the annunciator system which required the declaration of a site emergency.
Several of the initiat'ng conditions refer to other plant documents and procedures.
Some confusion was evidenced by the SEs in trying to relate the initiating conditions in the IPD to information in the plant technical specifications, special instructions, and emergency operating instructions.
One of the sis on emergency actions in the Shif t Engineer's office was noted to be out of date, but was removed during the appraisal. Quick reference card files both in the Shift Engineer's office and in the control room also contained out of date emeraency information.
Some of the initiating conditions related to gaseous radioactivity releases are g;ven in terms of offsite dose; e.g., an offsite dose rate of 1 R/hr whole body or 5 R/hr thyroid would require the the declara-tion of a general emergency.
Offsite dose calculations are the responsibility of the MSECC staff in Muscle Shaals.
There are currently no provisions for the SE to make initial dose projections based on effluent monitor readings in the control room, nor are there any provisions for quantifying the release if the plant stack noble gas radiation monitors go off scale.
(These deficiencies have been identified in previous sections of this report). The SEs were asked how they would determine offsite doses in the esent gaseous radio-activity was being released from the plant. The SEs stated that they would dispatch a Health Physics survey team from the plant to measure the offsite doses at the site boundary.
Although not explicitly stated, the impression given to the aud' tors was that there would be some hesitancy on the part of the SEs to activate the emergency van which is kept on standby at the plant for use by the HP survey team; however, the overall responsibility for offsite monitoring in the event of an accident is assigned to the emergency response group at Musc.le Shoals.
The SEs indicated that they had little difficulty in performing the required notifications for an emergency. The SE's clerk and the Public Service Safety Office, both available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, make the majority of calls. The SEs are responsible for notifying the Operations Duty Specialist in Chattanooga who in turn activates the TVA Corporate
response.
In the TVA centralized amergency management concept, the Browns Ferry SED is not responsible for making protective action recommendations to the State and local officials.
Protective action recommendations, based on the assessment of the actual and potential radiological consequences of the accident, are provided by the Muscle Shoals ECC to the Central ECC in Chattanooga.
Only if a general emergency is declared by the SE does the Operations Duty Specialist contact State and local officials directly to give them a prepared standard message regarding protective actions. The SEs interviewed by the auditors demonstrated a clear uderstanding of the notification scheme and their responsibilities.
Walk-throughs were performed with Radiochemistry Lab Analysts who would be responsible for obtaining post-accident samples and analyzing them for specific isotopic content in order to observe their knowledge of and familiarity with the proper procedures. The analysts were familiar with the procedures for post-accident coolant sampling, gas and particulate effluent sampling, and liquid effluent sampling.
Any impediments to timely and effective performance in +hese areas would be due to weaknesses in the procedures and not due to lack of expertise of the analysts. The analysts were familiar with proper counting techni-quas Walk-throughs were also performed with Health Physics personnel so that they could demonstrate their knowledge of survey procedures in poten-tial " hot-spots" in the plent and we of proper detection equipment.
The technicians showed gmd familiarity with the operation of the detection equipment and preper survey techniques. The technicians also ware familiar with the possible " hot-spots" in the plant which could occur post-accident. The technicians were somewhat confused as to what their exact duties would be after an accident occurred; however, this is probably due to the lack of emergency survey procedures and definition of the emergency organization.
Walk-through discussion with Health Physics technicians and Health Physicists concerning offsite environmental plume monitoring demon-strated a general lack of knowledge concerning methodology. However, two of the Browns Ferry technicians and one Health Physics shift supervisor were generally knowledgeable about plume monitoring. These interviewed persons had previous experience with plume monitoring following nuclear detenation tests at the Nevada Test Site.
The auditors visited Muscle Shoals and interviewed members of the MSECC staff who are responsible for perforining dose calculations and making protective action recommendations. These individuals described how the MSECC would function in an emergency and performed example dose cal-culations for the auditors on the CRT system in the MSECC. The MSECC staff personnel appeared to be well qualified and knowledgeable in their areas of responsibilit n_
Based on the above findings, this por tion of the licer.see's program 4ppears to be acceptable, but the following matters should be con-
..idered for improvement:
Clarification of the initiating conditions in IP-1 considered to
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be ambigca.: by the Shift Engineers.
(50-259/81-19-34; 50-260/
81-19-34; 50-296/81-19-34)
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Implementing procedures and other procedures referred to by Shift Engineers in an emergency such as Special Instructions and Emer-gency Operating Instructions should be cross re ferenced.
(50-259/81-19-35; 50-260/81-19-35; 50-296/81-19-35)
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ATTACHMENT TO REPORT NOS.
50-259/81-19; 50-260/81-19; 50-296/81-19 Persons Contacted
- G. F. Stone, Director, Division of Occupational Health and Safety
- H. L. Abercrombie, Plant Superintendent R. E. Maxwell, Chief, Radiological Hygiene Branch
- E. K. Sliger, Supervisor, REP Staf f
- J. L. Ingwersen, Supervisor, REPP Group
- W. E. Webb, Project Engineer, REP Staff L. J. Politte, Supervisor, Radiation Control Group
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- C. E. Kent, RE&P Group Health Physicist
- S. R. Howard, Health Physics Supervisor
- R. G. Metke, Results Supervisor J. R. Lobdell, Supervisor, QA/ALARA Staff
- T. L. Chinn, Compliance Staff Supervisor T. H. Youngblood, Health Physicist J. T. Millsap, Health Physicist R. Hunkapollar, Operations Supervisor J. D. Glover, Shift Engineer
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J. W. Burton, Chemical Engineer
- W. A. Roberts, Jr., Mechanical Engineer K. Mastich, Nurse W. E. Brown, Shif t Engineer H. L. Hatton_, Shif t Engineer R. Abercrombie, Shift Engineer
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G. Tarp, Radiochemical Laboratory ' supervisor A. L. Clemont, Chemical Engineerin1 ' nit Supervisor J
J. R. Phifer, Safety Engineering Supervisor B. H. Weeks, Power Stores Superv kor R. J. Ashcraft, Health Physics, Shift Supervisor E. G. Thornton, Shift Engineer
- 0. C. Cummin, Assistant Health Physics Supervisor H. G. States, Public Safety, Shift Supervisor W. Cottles, Public Safety, Shif t Supervisor R. W. Miller, Public Safety, Line Supervisar W. C. Thomison, Assistant Engineering Section Supervisor E. L. Hensley, Health Physics, Shift Supervisor T. J. Sharpe, Chemical Engineer, Nuclear J. A. McCrary, Jr., Unit Operator H. Kemp, Supervisor, Western Area Radiological Laboratories J. Price, Training Officer R. L. Smith, Administrator, Decator General Hospital E. D. Edmonds, Director, Environmental Services, Decatur General Hospital J. Parsons, AAA Ambulance Service H. Hagan, Limestone County Sheriff
- f. R. Sullivan, NRC Senior Resident Inspector v. W. Chase, NRC Resident Inspector
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l In addition to the above representatives of operations, mainte v nce, public j
safety and administrative groups were interviewed.
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