IR 05000259/1982031
| ML20027E572 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 10/12/1982 |
| From: | Jenkins G, Cline W NRC Office of Inspection & Enforcement (IE Region II) |
| To: | |
| Shared Package | |
| ML20027E562 | List: |
| References | |
| 50-259-82-31, 50-260-82-31, 50-296-82-31, NUDOCS 8211150501 | |
| Download: ML20027E572 (18) | |
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OCT 131992 Report Nos. 50-259/82-31, 50-260/82-31 and 50-296/82-31 Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401 Facility Name: Browns Ferry Docket Nos. 50-259, 50-260 and 50-296 License Nos. DPR-33, 52, 68 Inspection at Brown Ferry Nuclear Plant near Athens, Alabama Inspptor: dd . Mud /d//2- [2 2_ 7C W. E. C i Date ' ign d i Approved by k /0 M f '
'GT R. Jen-Chief Da'te Signed Emergency reparedness Section EPOS Divi ion SUMMARY Inspection on September 13-17, 1982 Areas Inspected This routine, unannounced inspection involved 34 inspector-hours on site in the areas of emergency preparedness.
Results Of the areas inspected, no violations or deviations were identified.
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. . . OCT 131982 REPORT DETAILS 1.
Persons Contacted Licensee Employees
- G. Jones, Plant Superintendent J. Hufham, Chief Emergency Preparedness and Protection Branch
- J. Pittman, Assistant Plant Superintendent
- T. Chinn, Compliance Staff Supervisor A. Sorrell, Health Physics Supervisor E. Cargill, Health Physics Shift Supervisor E. Sliger, Supervisor REP Staff R. Jackson, Chief of Security G. Lard, Security Captain J. Ingwersen, Supervisor REPP Group
- R. Tibi, Compliance Specialist C. Rozear, Compliance Specialist E. Wobb, Project Engineer, REP Staff T. AtKins, Engineer, REP Staff C. Wallace, Health Physicist Other licensee employees contacted included technicians, operators, security force representatives, and office personnel.
Other Organizations S. Black, Director Limestone County CD D. Barker, Deputy Director Limestone County CD ' G. Mangum, Director, Lauderdale County CD L. Wood, Director, Lawrence County CD NRC Resident Inspector J. Chase, Senior Resident Inspector G. Paulk, Resident Inspector !
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on September 17, 1982, with those persons indicated in paragraph 1 above.
3.
Licensee Action on Previous Enforcement Matters (Closed) Violation: Establish a means for alerting and promptly providing public instruction within the plume exposure pathway of the Emergency Planning Zone within 15 minutes. The inspector verified the corrective
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actions that were taken as stated in TVA's letter to NRC dated October 13, 1981 (Details, paragraph 17).
(Closed) Violation (81-19-29): Develop procedures for use by offsite monitoring team during an emergency and develop procedures for implementa-tion of drills and exercises. The inspector verified that corrective action had been taken as stated in TVA's letter to NRC dated December 7, 1981 (Details, paragraph 19 & 22).
(Closed) Deficiencies (81-19-02 and -03): Specify the emergency organiza-tion in detail down to the working level and specify the onshift capability available to staff the emergency organization. The inspector verified that the licensee had taken the corrective action as stated in TVA, letter to NRC dated December 7,1981 (Details, paragraph 6).
(Closed) Deficiencies (81-19-06, 07 and 08): Revise TSC ope.ations to provide for adequate work space, communications, and exchange of data with the control room. The inspector verified that the licensee had taken the corrective actions as stated in TVA's letter to NRC dated December 7, 1981 (Details, paragraph 8).
(Closed) Deficiency (81-19-15): Provide instrumentation or procedures in the control room to quantify radionuclides released to the environment should the stack monitor fail or read offscale. The inspector verified that the licensee had taken the corrective actions as stated in TVA's letter to NRC dated December 7,1981 (Details, paragraph 14).
(Closed) Deficiencies (81-19-24 and 25): Provide a procedure for accident classification which relates radiation effluent monitor parameter to site boundary exposure rates and provide a methodology to evaluate release rates if monitors fail or read offscale.
The inspector verified that the licensee had taken corrective action or stated in TVA's letter to NRC dated December 7,1981 (Details, paragraph 18).
.. The inspector also verified the licensee had met the commitments related to improvements in TVA emergency response capability which were discussed in enclosure 1 of NRC Report 81-24. This matter is closed (81-24-04) (Details, paragraph 6 & 8).
The inspector also reviewed the licensee actions on emergency preparedness improvement items identified during the emergency preparedness appraisal and the licensee actions and commitments documented in the TVA letters to NRC dated December 7, 1981, March 11, 1982, and September 1, 1982. The status of these items is discussed in the details of this report.
4.
Unresolved Item No new unresolved items were identified during this inspection.
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5.
Administration of the Emergency Preparedness Program A review of the emergency preparedness program was conducted. The review consisted of review of licensee emergency plans and procedures and discussions with licensee representatives. The Compliance Staff Supervisor is currently designated as the plant Emergency Preparedness Coordinator. An emergency preparedness staff also exists within the Division of Nuclear Power. This staff provides emergency planning general support to all TVA nuclear power facilities.
A review of licensee records showed that selected members of the plant and Division of Nuclear Power emergency planning staff had participated in professional development training through attendance at a FEMA sponsored planning course. The inspector discussed the merits of such training and emphasized the need for continued participation in professional development training. A licensee management representative indicated that professional development training for emergency preparedness personnel would be continued. The previously identified improvement item in this area (81-19-01) is closed.
6.
Emergency Organization a.
Onsite and Offsite Organization The area of emergency organization was reviewed by the inspector. The licensee's procedure BFNP, IPD, IP-20 which relates to emergency organization was reviewed. This procedure described the emergency organization and specified duties of the onsite emergency organization.
The inspector also reviewed the licensee's Standard Practice, BF22.1 which specified the qualification for key members of the emergency organization. The inspector also reviewed selected training records which showed that members of the onsite emergency organizatiori had received training on their responsibilities and duties.
It was noted in the review of the organization of the TSC that the position of Technical Assessment Manager had ten individuals reporting to hin. The inspector indicated that the Technical Assessment Manager's span of control might be too great to be effective in an emergency situation.
Licensee representatives agreed to evaluate this matter during the upcoming exercise.
The inspector also reviewed CECC procedure IPD, IP-4 which related to the operation of the CECC.
The procedure addressed the major functions of the CECC and specified responsibilities for certain key personnel.
The inspector had no further questions on this matter.
Based on the above findings the previously identified emergency preparedness deficiency in this area (81-19-02) is close. . .
Section 4.0 of the emergency plan was reviewed concerning the licensee's onshift capability to staff the emergency organization. The licensee had revised Section 4.0 of the plan, to include Table 1, to show the actual minimum onshift staffing levels. The table now shows a listing of major functional areas, lists typical tasks within each major area, specifies the title and position of the responsible individual, and indicates the number of personnel normally on-shift for each position. The number of on-shift personnel appear to meet the criteria provided in NUREG 0654. Based on these findings the previously identified emergency preparedness deficiency in this area (81-19-03) is closed.
b.
Augmentation and Augmentation Management The inspector reviewed Table 1A of Section 4.0 of the emergency plan.
This table specifies the licensee's capability for providing additional personnel to staff the emergency organization. The licensee's program for augmentation and augmentation management was discussed with licensee representatives. The inspector noted that the licensee's procedures CECC, IPD, IP-4 and IP-5 had been revised to require that a senior management representative from the Office of Power will be dispatched to the nuclear plant to act as a senior advisor to the plant Site Emergency Director. A review of the licensee's Division of Nuclear Power procedure, DNPEC, IPD, IP-6 shows that during an emergency situation that the Director of Nuclear Power will dispatch necessary technical personnel to the site. Also plant procedure BFNP, IPD, IP-6 provides a summary type listing of technical resource personnel available at the plant. Based on these findings those portions of the previously identified open item (81-24-04) relating to emergency organization augmentation are closed.
7.
Training l The licensee's training program for emergency organization members was.
reviewed. The review consisted of a review of licensee training records, lesson plans, selected procedures and interviews with licensee representa-tives.
The offsite environmental monitoring training program was discussed with licensee management representatives and members of the environmental monitoring team. The inspector reviewed internal licensee memoranda dated December 4,1981, which indicated training had been given. The inspector I selected two individuals who were assigned roles on the monitoring team and questioned them concerning team activities. Both individuals indicated they had been given instruction in offsite monitoring methods. Both individuals appeared to be knowledgeable of their duties on the team and appeared to be aware of the supply and equipment resources available to them in an i emergency. Based on these findings the previously identified improvement item in this area (81-19-04) is closed.
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The licensee has implemented a training program for plant health physicists and health physics technicians. The inspector reviewed selected records pertaining to the training given. Lesson plans were also reviewed.
According to the records reviewed and based on interviews with licensee representatives the training consisted of lectures and demonstrations relating to high radiation areas in the plant, monitoring systems in the plant, response of radiation detection instruments, anticipated hazards in the plant, and operational lessons learned. Based on these findings the previously identified improvement item in this area (81-19-05) is closed.
The inspector discussed training of personnel from supporting offsite hospitals with licensee representatives and reviewed licensee plans for such training. According to licensee representatives training was provided to supporting hospital personnel in September 1981, and additional training is scheduled for the staffs at Colonial Manor Hospital (Florence, Alabama) and Decatur General Hospital in late September 1982 and October 1982 respec-tively. Licensee representatives indicate that training is tailored to the needs of the hospital staff but does contain some refresher type instruc-tion. The inspector pointed out the importance of the continuation of training for offsite hospital personnel. Based on these findings, the previously identified open item in this area (81-24-10) is closed.
8.
Emergency Response Facilities a.
Technical Support Center (TSC) The licensees TSC operations and plans were reviewed. The review consisted of a tour of the TSC, inspection of equipment and supplies, and a review of licensee procedures.
The inspector observed that the TSC had been expanded and re-arranged.
The TSC is divided into two main areas which are adjacent to each other and are connected via two door openings. A large window is also located in the wall between the two areas. The larger work area has approximately 400 square feet of work space.
Personnel assigned work functions in this area include but are not limited to the Site Emergency Director, Technical Assessment Manager, Operations Manager, and Maintenance Manager. The smaller work area, which has approxi-mately 200 square feet of work space, has been designated for NRC use and for use by the licensee in communicating and transmittal of vital information. The layout of the TSC appears to lend itself to ease of movement and observation of status boards. Communication systems available in the TSC include a Dimension phone system, commercial telephones, dedicated ENS system, and a PAX system. The inspector noted over 30 telephone instruments in the TSC. AT least five phones are provided for NRC use. All commercial phones in the TSC have a preprogrammed dialing capability. The licensee also has an Emergency Data System consisting of a CRT and line printer located in the TSC.
This system has the capability to provide plant status, meterological, and radiological release rate data upon request. A facsimile system is also installed in the TS. .
The inspector discussed information flow between the TSC and other ERF's with licensee representatives. Besides using the Emergency Data System for transfer of information the licensee has a communicator assigned to the TSC.
Plant status information can be provided to the communicator using standardized data sheets. The TSC is readily assessible to the control rooms for each unit and can be reached within two minutes.
During the tour of the TSC it was noted that FSARS, Technical Specifi-cations, Emergency Procedures, Emergency Plans, and Process and . Instrumentation Diagrams were available.
Evacuation Zone maps and maps showing the 10 and 50 mile Emergency Planning Zones were available. A TSC organization chart was posted in the TSC.
i Based on the above findings the previously identified emergency preparedness deficiencies in this area (81-19-06, -07, and -08) are closed.
The inspector discussed the necessary improvements in the TVA emergency response capability which were pointed out in NRC Inspection Report 81-24.
Licensee representatives stated that the TSC staff had been reorganized and the Site Emergency Director now reports to the TSC when it is activated. The licensee has revised procedure BFNP, IPD, IP-20 entitled TSC Operation to show that the Site Emergency Director and his three subordinate managers report to the TSC upon its activation. The inspector also reviewed the licensee actions relative to upgrading technical support to the TSC. As mentioned in paragraph 6.b. above technical resource personnel will be made available to the plant from the Division of Nuclear Power. Also the licensee has assigned responsibility to the Radiochemical Engineer for providing dose projection information and meteorological information to the Site Emergency Director. The Radiochemical Engineer may usa manual methods for the dose projection or may rely on the computerized Emergency Data System. The inspector also verified that the licensee had upgraded communications in the TSC as the commitments were documented in the October 8, 1981 letter from NRC to TVA. Based on the above findings those portions of the previously identified open item c'oncerning management of the TSC, upgraded techincal support and communications (81-24-04) is closed.
b.
Operational Support Center (OSC) The licensee has relocated the OSC. According to licensee procedure BFNP, IPD, IP-21 entitled OSC Operation, the OSC is located ir, the electrical, instrumentation and control, and mechanical maintenance shops. The alternate OSC location as designated by IP-21 is in the Control Bay Hallway. The licensee provisions for communications and direction / control are specified in IP-21. The OSC is organized into three functional groups, namely electrical, instrumentation and mechanical. The Assistant Maintenance Supervisors for electrical, instrumentation, and mechanical maintenance will supervise their . --. .
respective group from their designated OSC work location. According to IP-21 the supervisors report to the maintenance manager, who is the OSC Director. The OSC Director is located in the TSC. The OSC Director plans to maintain contact with subordinate managers by telephone.
Based on these findings, the previously identified open items in this area (81-24-02 and 81-24-08) are closed.
The inspector discussed storage of radiation detection equipment in the health physics area with licensee representatives as opposed to storing instruments in the OSC. The licensee has amended BFNP, IPD, IP-14 to specify that health physics personnel with appropriate instrumentation will be dipatched from the health physics statioc. The procedure states that health physics personnel will accompany teams dispatched from the OSC and provide the necessary surveys and health physics support.
Based on these findings the previously identified improvement item in this area (81-19-09) is closed.
9.
Assembly / Reassembly Areas This area was reviewed by discussions with licensee representatives, review of procedures, and a physical inspection of the assembly areas. The licensee has revised procedure BFNP, IPD, IP-14 to specify that site access points established by the security force during an emergency will be used by the health physics staff to survey personnel and equipment leaving the site.
BNFP, IPD, IP-8 also indicates that security and health physics personnel will be collocated at the site access point. Based on these findings, the previously indentified improvement item in this area (81-19-10) is closed.
Alternate assembly areas were discussed with licensee representatives.
BFNP, IPD, IP-8 has been revised to specify the location of alternate assembly areas. The procedure indicates that the west and east parking lots are designated as the primary and alternate assembly areas respectively.
The procedure further states that if for any reason one assembly aiea becomes unsuitable then the other may be used. Based on these findings the previously identified improvement items in this area are closed (81-19-11 and -32).
10.
Decontamination Facilities The area of decontamination facilities was discussed with licensee representatives. Currently the licensee has no location closer to the plant than the Wilson Hydro Plant Complex to accommodate decontamination and re-entry of necessary onsite personnel. This matter was discussed at length with licensee representatives. Licensee representatives agreed to give consideration to using the on-site radwaste storage area as decontamination facility. This improvement item (81-19-12) remains open pending the outcome of the licensee's evaluatio. . .
11.
Expanded Support Facilities The inspector discussed the previously identified improvement item (81-19-13) concerning relocation of HP personnel to the TSC. The licensee has taken action to correct this situation by amending procedure BFNP, IPD, IP-14 to designate the primary work station for HP personnel as the HP lab and the alternate location as the mechanical room in the control bay of Unit 3.
According to licensee representatives the alternate location has the same habitability characteristics as the control room. Based on these findings the previously identified improvement item in this area (81-19-13) is closed.
12.
News Media Coordination The licensee's program for coordination and dissemination of news releases , was reviewed. The licensee has procured and installed facsimile equipment ! in the ERF's and near site E0C's according to licensee representatives. The inspector noted such equipment in the TSC and MSECC. The facsimile equipment will be used to transmit news releases and to coordinate the ' release of information. A licensee representative indicated that instruc-tion had been given to personnel involved in news information dissemination concerning use of equipment and coordination procedures required prior to release of information.
Licensee representatives also stated that they ' believe that news information coordination and dissemination will be improved in the future due to the overall upgrade of TVA's emergency communication system. The inspector indicated that this matter would be reviewed during future exercises.
Based on these findings, the previously identified improvement item in this area (81-24-07) is closed.
13.
Emergency Kits and Survey Instrumentation The inspector discussed use of emergency kits and emergency survey instru-mentation with licensee representatives and inspected selected emergency supplies and equipment.
It was noted that licensee procedure BFNP, IPD, IP-17 which addresses emergency supplies and equipment had been modified to list recent supply and equipment additions to include silver zeolite air sample cartridges. The licensee has revised invenbry listings to reflect the actual content of emergency kits. The inspector examined emergency supplies and equipment in the licensee's REP van. The inspector noted that the van was radio equipped, contained an environmental emergency kit, and contained air samplers and silver zeolite air sample cartridges. Based on these findings the previously identified improvement item in this area (81-19-14) is closed.
14. Area and Process Radiation Mo'nitors The inspector inquired about licensee action on the previously identified emergency preparedness deficiency concerning quantifying releases when the stack monitor fails to work or reads offscale. The licensee has developed .. _ - .
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an interim procedure for estimating releases in case of such monitor failures. A licensee representative stated that the interim method would be used until the permanent higher range monitoring system is installed. The licensees interim procedure is documented in Technical Instruction (TI) 67.
TI 67 is referenced based on action limits in procedures BFNP, IPD, IP-3, -4, and -5.
The inspector reviewed TI 67 and internal TVA memoranda from the Radiological Hygiene Branch which served as a basis for the TI 67. The procedure requires that a measurement be made with a telescoping type detector inside the base of the plant stack. The measured value is used in the release rate calculation. The TI appears to be explicit in describing the desired positioning of the individual taking the measurement, location of monitoring device, health physics controls, and disposition of data obtained. Based on these findings the previously identified emergency preparedness deficiency (81-19-15) is closed.
The inspector also discussed changes to Emergency Operating Instrcction (E01)-12 concerning response action to monitor failure. The licensee has modified E01-12 to require surveillance of radiation monitors and to prevent monitors from going offscale by providing dilution flow to decrease the concentration of radioactive material passing through the detector. E01-12 was also changed to require that radiochemistry personnel be notified in the event of stack monitor failure or offscale reading so that a gaseous sample could be obtained to confirm high activity levels. Based on these findings the previously identified improvement items in this area (81-19-16 and 17) are closed.
15. Meteorological Program The licensees meteorologial program was reviewed. The review consisted of discussions with licensee representatives, review of procedures, inspection ^ of equipment, and observation of a test of the Emergency Data System as related to meteorological parameters. Meteorological parameters are recorded on strip charts in the control room. An inspection of the charts showed that they were maintained by the control room staff and the time axis of the charts were synchronized with current time. Based on this finding the previously identified improvement item in this area (81-19-18) is closed.
The inspector inquired about licensee action on the previously identified improvement item concerning recording temperature difference data on inappropriate recorders. A licensee representatives indicated that a design change request and engineering change notice are in effect on this matter.
The licensee expects completion of modifications by late November 1982.
This matter remains open (81-19-19) pending the licensee's completion of the modification.
l Meterological data for the site can be obtained from the Emergency Data System (EDS). A licensee representative demonstrated how such parameters are obtained from the EDS. The EDS print out showed windspeed, direction, ! and stabil'ity class as a function of time. The inspector had no comment concerning the system.
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16. Emergency Communication The inspector reviewed the licensee's communication program. A physical < inspection of facilities and communication equipment was made at the TSC and the MSECC. The inspector noted that over 30 pre-programmed telephones were installed in the TSC.
Pre-programmed telephones were also installed at principal work stations in the MSECC. Both the TSC and MSECC are equipped with facsimile capability and the Emergency Data System. A licensee representative indicated that the CECC was also equipped with communication equipment at least comparable to that of the TSC. Based on these findings the previously identified improvement item (81-19-20) is closed.
The inspector discussed corrective action taken by the licensee on the previously identified inspector followup item (81-24-05 and -06) concerning communications. A licensee representative stated that NRC's concerns regarding exchange of technical information between the TSC, CECC, DNPEC, KECC, and MSECC would be resolved to a large degree by use of the Emergency Data System which has been installed at each of these emergency facilities.
Also licensee representatives stated that electronic blackboards had been installed in the CECC, DNPEC, XECC, and the MSECC. The licensee has revised BFNP, IPD, IP-20 entitled TSC operation to provide a standard essential parameter listing (data sheet). Tiiis standard listing can be transmitted to the various energency facilities by facsimile. The need for close coor-dination between the licensee and the NRC was discussed. The licensee has established a position on the TSC staff as NRC Coordinator. The NRC Coordinator duties are to assist NRC by providing status updates and obtaining information needed by NRC. The inspector also discussed problems noted in the exercise concerning communication of field monitoring and dose projection information. The licensee has developed a computerized dose projection methodology and a manual backup method. The licensee will provide a representative to the Forward Control Center for the purpose of coordinating and exchanging monitoring data with state and local government representatives. Communication difficulties between the OSC and teams dispatched from the OSC were also discussed. The licensee has reviewed l BFNP, IPD, IP-21 entitled OSC operation to require briefings on plant status and conditions to the OSC team leader by the Maintenance Manager. The licensee has revised BFNP, IPD, IP-14 to require HP coverage of operations in potentially hazardous areas. The inspector also discussed communications difficulties noted in the exercise between: (1) the TVA ambulance and the medical facility and (2) TVA and the Morgan County E0C.
In both of the cases TVA has taken action to ensure existing communication equipment is used properly according to licensee representatives. The licensee repre-sentatives further stated that an internal evaluation of the problem indicated that lack of understanding of existing procedures was the principal contributor to the communication difficulties. Licensee repre-sentatives indicated that instruction had been given to those individuals involved concerning use of communication equipment. Based on the above findings, the previously identified inspector followup items in this area (81-24-05 and -06) are closed.
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17, Prompt Notification System The licensee has provided an emergency alerting / notification system within the 10 mile emergency planning zone (EPZ). The system consist of fixed, permanently mounted sirens and mobile sirens. According to licensee records there are 52 permanently mounted sirens, and seven mobile sirens in the four counties within the 10 mile EPZ.
The inspector conducted a physical inspection of selected siren stations, and discussed siren system operation with Civil Defense Directors from 3 of the 4 counties in the 10 mile EPZ.
Based on these findings the previous violation concerning installation of the prompt notification system is closed.
(Notice of Violation issued with letter from Victor Stello, 0IE, dated September 22,1981.)
The inspector reviewed licensee records concerning development of the prompt notification system. Records maintained by the licensee and local govern-ment agencies showed that the system was in place by February 1982. During the physical inspection of the installed sirens, the inspector noted that the sirens were the rotational type and all components of the system were mounted high enough above ground level to prevent tampering.
The inspector visited with the Civil Defense Directors from Limestone, Lauderdale, and Lawrence County for the purpose of discussing the prompt notification system. During these visits the inspector discussed procedural aspects related to activation of the system.
In all cases the Civil Defense Directors appeared to understand the TVA and State of Alabama notification process and had made provisions for authorizing activation of the system.
, Testing of the permanently installed sirens was discussed with representa-tives from Lawrence and Limestone County. Both representatives indicated that the permanently mounted sirens were operationally tested on a monthly basis. They also indicated that silent tests were performed in addition to full operational tests. A review of licensee maintenance surveillance records also showed that testing of the permanent siren system had been performed. The local government representatives indicated that they report problems encountered during testing to TVA. A review of selected TVA maintenance records showed that corrective actions were taken on problems identified.
Local government representatives also stated that when full siren operational tests are being conducted simultaneous radio broadcasts are made by local radio stations indicating a test of the Browns Ferry Alert and Notification System is being conducted. According to local government representatives the broadcast also asks that any problems noted during the test be reported to responsible local officials.
The inspector discussed the mobile siren system with licensee representa-tives and representatives from Limestone, Lawrence and Lauderdale Counties.
The inspector determined from interviews that at the present time there have been no full scale tests of the mobile sirens; however according to Lawrence County representatives some field operability tests have been conducted with their mobile siren system. An inspection and test of siren audibility was conducted for the mobile sirens in Limestone, Lauderdale, and Lawrence counties.
Lauderdale and Lawrence counties have the " permanent" mobile sirens in place. The Civil Defense Director from these counties
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demonstrated to the inspector that the sirens were operable.
In Limestone County, the " permanent" mobile sirens have not been received and the county currently has for " interim use" four sirens mounted in four TVA vehicles.
On September 15, 1982, the inspector requested the licensee representatives to demonstrate the operability of the vehicles and sirens.
Four vehicles (with sirens mounted) identified by license tag numbers TV-15095, TV-15106, TV-15059 and TV-15085 were tested. Vehicle TV-15106 would not start and the vehicle battery appeared to be dead. As a result of the apparent dead battery the siren would not sound. A licensee representative immediately contacted the TVA maintenance operation and requested that the vehicle be made operable. Based on discussions with licensee and county representa-tives the " interim" mobile sirens do not appear to be on a routine main-tenance surveillance schedule. The need for such a program was emphasized to licensee representatives. The inspector also inquired as to when the " permanent" mobile siren system would be made available to Limestone County.
The Director of the Limestone County Civil Defense program indicated that he expected delivery within the next two weeks. The " permanent" mobile sirens will consist of two vehicular mounted sirens. The inspector questioned whether the two "new" sirens could provide the coverage which is currently to be covered by the four " interim" mobile sirens.
Licensee representatives stated that their initial evaluation of this situation indicates that the two permanent sirens will be of higher output than the interim sirens, thus i the effective coverage will be the same. The inspector indicated that NRC would expect the licensee to conduct sufficient tests of the mobile siren system to demonstrate that the sound level coverage was adequate.
The licensee's program for testing the overall adequacy of the prompt notification system was discussed. Licensee representatives stated that the permanently mounted sirens were placed in the 10 mile EPZ so as to provide-at least a 10 decibel level above background to all receptors in the desired coverage area. The system was designed based on theoretical guidance provided in NUREG 0654 and references specified by NUREG 0654. The inspector questioned the licensee representative concerning testing of the system to verify that sound level coverage was provided as predicted.
Licensee representatives stated that they had not conducted any actual field . testing of the permanent siren system to verify sound level coverage. A ' licensee representative stated that rather than field testing of.the system they planned to do the sound level coverage verification using a computer-ized acoustical model. The model is still in the development stage, but the licensee expects completion of it within the next four to six months. As currently envisioned the licensee plans to conduct some actual field sound measurements around selected siren systems under varied test conditions (weather, seasonal variation, and varied terrain / cover). These test results will be compared against the acoustical model predictive results in order to validate the model. Once the model is validated under varied conditions, it will be used to predict the sound level coverage for the Browns Ferry permanent, fixed siren system. The licensee expects to be able to use the predictive model for thir. work within the next year.
Based on the above findings the inspector expressed concern about the licensee's testing program for sound level coverage from both the fixed and
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mobile sirens. The inspector discussed the need to: document the formal test program to include performance objectives and acceptance criteria, j establish a schedule for testing / evaluating the system, and documenting ~ results upon completion. This matter is identified as an inspector followup item (82-31-1) and will be reviewed during a subsequent inspection.
18.
Emergency Implementing Procedures a.
General Content / Format
The general content and format for emergency procedures was discussed with licensee representatives. The previously identified improvement , i item in this area concerning cross referencing emergency implementing i procedures to health physics instruction was discussed. The licensee j has revised BFNP, IPD, IP-14 to reference HPSIL 56 entitled " Initial Offsite Assessment."
In essence IP-14 states that during site and . general emergencies there may be offsite releases which require HP action, and IP-14 directs HP's to follow instructions in HPSIL 56.
Based on these findings, the previously identified improvement item in thearea(81-19-21) is closed, j b.
Alarm and Abnormal Procedures The inspector reviewed the licensee procedure for seismic events.
BNFP, IPD, IP-1 has been changed to conform to the seismic monitoring system capabilities / operation.
IP-1 also references BFNP, IPD, IP-24 entitled Earthquake Emergency Plan.
In accordance with IP-24 the ' licensee is required to perform a physical inspection of plant i
facilities and equipment following an earthquake. Based on these
findings, the previously identified improvement item in this area ! (81-19-22) is closed.
The inspector discussed cross referencing emergency implementing l procedures and other procedures such as Special Instructions and t Emergency Operating Instructions (E01). A licensee representative j stated that this work was not complete because the licensee is awaiting compilation of a standard set of E01s which is being worked out by the BWR Owners Group. Once a standard set of E01s is developed the
licensee intends to cross reference other procedures as appropriate.
The licensee requested an extension of time on this matter in a letter to NRC dated September 1, 1982. This matter remains open (81-19-35) l pending licensee action. The licensee anticipates action completion by l January 1, 1983.
c.
Notification Procedures / The inspector reviewed BFNP, IPD, IP-2, -3, -4, and -5 as relates to notification. These procedures had been amended by the licensee . concerning notification of the NRC. The procedure states that the NRC is to be contacted by the ringdown phone and that the line will be held , open until authorized to close the line by NRC. Based on these
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,.- , findings the previously identified improvement item in this area (81-19-23) is closed.
Prompt notification of offsite authorities was also discussed with licensee representatives.
The need to amend notification procedures to ' require notification of offsite autnorities within 15 minutes of the declaration of an emergency was discussed. Licensee representatives ! ' stated that prompt notification liad not been a problem at TVA ' facilities but indicated they would revise the notification procedures concerning the 1E minute notification time.
d.
Radiological Assessent Procedure ' Licensee procedures related to accident classification were reviewed.
Licensee procedure BFNP, IPD, IP-1 entitled Emergency Plan Classifica-tion Logic has been revised. The procedure provides radiological and operation parameters associated with the various accident classifica-tions.
It also cross references appropriate technical emergency
instructions. Based on these revisions the previously identified improvement item in this area (81-19-34) is closed. The inspector ,
noted that Table 1 of BFNP, IfD, IP-3, -4, and -5 had been revised to show activity release rates versus site boundary thyroid dose. The table also shows the accident classification associated with each release rate and corresponding thyroid dose. The procedures describe how to convert control rocm' radiation monitor readings to activity release rate.
The method described involves multiplication of control room monitor readings by flowrate indicator readings and then cultiplying the resultant product by a conversion factor. The operator is instructed to use the calculated result as an entry value into Table 1 of either IP-3, -4, or -5 in order to classify the accident.
This procedure allows for a conservative approximation of site boundary , thyroid dose. More detailed projections are available once the \\ licensee's dose assessment staff is set up in the emergency organi-zation. The licensee has also made provision to estimate the radio-logical release rates:1f the effluent monitor for the stack reads offscale or fails. This method involves making dose rate measurements with a survey meter at the base of the stack. Details of how the survey is to be made, controls, cautions, and data reporting are provided in licensee procedure TI-67 (see paragraph 14 above for
details). Based on these findings the previously identified emergen'y preparedness deficiencies in this area (bl-19-24 and -25) are closed.
' The inspector discussed procedures for dose assessment.and protective action decisiot making with licensee representatives. The inspector
! reviewed MSECC, IPD, IP-10 entitled Dose Assessment Staff Activities
during a Nuclear Plant Emergency. The procedure documents responsi-bilities and roles of the MSECC, CECC, and TST staff in dose 'projec-tion / assessment activities. The procedure describes MSECC operations, activation, operation, and information flow. The procedure makes a-commitment to keep the state updated on assessment activities on'an ,. hourly basis.
Provisions are made for using field monitoring data in i . , . -, -. - - .- -,-~- - - -, _ _ _ _ - ,-
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assessment action. The procedure gives instruction on how to make detailed projections for the various exposure pathways and radioactive release conditions. Based on these findings the previously identified
improvement items in this area (81-19-26 and 81-24-03) are closed.
The licensee's guidance on protective action decision-making is also provided in MSECC, IPD, IP-10. Attachment 7 to IP-10 contains a logic diagram which is to be used by decision makers in determining appro-priate protective action recommendations. Factors considered in the logic diagram include status of core considerations, dose rate readings in the environment, fission product level in containment, sheltering, evacuation, and KI administration. Based on these findings the previously identified improvement item in this area (81-19-27) is
closed.
The licensee's action concerning resolution of differences between the State of Alabama dose projection and TVA dose projection was reviewed.
According to licensee representatives the State of Alabama has been provided a computer terminal and now has access to computerized dose projections through the Emergency i'ta System. TVA has modified its
! dese projection methodology to inco,porate the finite cloud method as opposed to the semi-infinite cloud method. According to licensee i representatives this change will cause the TVA methodology to be in better agreement with the State of Alabama especially at close-in distances. TVA representatives also stated that they had provided the State of Alabama with a user manual related to TVA dose projection methods. Based on these findings the previously identified improvement item in this area (81-19-28) is closed.
19. Radiological / Environmental Surveys The inspector reviewed the licensee's program relating to onsite and environmental surveys. The review involved discussion with licensee representatives, review of procedures, review of licensee training records, and physical inspection of monitoring equipment.
The inspector determined that the licensee had developed procedures for use
by offsite (environmental) monitoring teams. The procedure HPSIL 56 establishes precaution to be taken, discusses how surveys will be made, ' addresses air sampling requirements, and discusses control of the monitoring team. The inspector questioned team members concerning conduct of offsite surveys. All members questioned appeared knowledgeable of their duties and indicated they had received instruction on offsite monitoring.
Based on these findings, the previous violation in this area (81-19-29) is closed.
The need for and use of maps compatible with environmental surveillance maps used by the States of Alabama and Tennessee were discussed. According to a licensee representative actions have not been completed in obtaining a standard map. A licensee representative indicated that progress was being made but was unable to give an expected completion date. This matter
remains open (81-24-09) pending licensee action.
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With respect to onsite monitoring activities, licensee representatives indicated that although HPSIL 56 had applicability to offsite monitoring, it also provided guidance on certain onsite inplant, monitoring activities.
The inspector noted in a review of licensee training records that health physics personnel had been given training concerning their role in providing health physics services (including surveys) in an emergency. According to training records and lesson plans personnel received instruction on instrumentation, precautions, and measurement nethods. Based on these findings the previously identified improvement item in this area (81-19-30) is closed.
20.
Post Accident Sampling , The licensee procedures for post accident sampling were discussed.
In particular the licensee's means for implementing the ALARA concept during y sampling and transport of high level samples were discussed. The inspector reviewed a licensee evaluation of this problem in a memorandum dated December 13, 1981. The licensee has obtained portable shields which can be used during sampling and transport of samples.
The licensee has also made provisions to obtain additional shielding on short notice. Based on these findings the previously identified improvement item in this area (81-19-31) is closed.
21. Repair and Corrective Action The licensee has elected not to develop detailed implementing procedures relative to repair and corrective action due to the wide variation in types of repair and corrective actions which could be necessary in an accident situation. The licensee does provide broad guidance on this issue in Section 11.0 of the Radiological Emergency Plan.
In addition licensee procedure BFNP, IPD, IP-16 indicates that following an incident that a course of action will be determined and unique procedures will be established which give consideration to such factors as decontamination, disassembly of equipment, waste disposal, damage evaluation, and repair methods. Based on these findings the previously identified improvement item in this area (81-19-33) is closed. However the licensee's system for managing and controlling repair teams will be reviewed during a future exercise.
22. Drills and Exercises A review was conducted of the licensee's program for drills and exercises.
The inspector reviewed selected portions of the TVA Radiological Emergency Plan concerning drills and exercises, reviewed selected licensee Standard Practices, and reviewed and discussed implementing procedures for drills and exercises. This review of the program did not included review of TVA's amended plans and schedules referenced in the NRC Region II letter to TVA of August 19, 1982. The licensee has established a commitments tracking system which includes provision for tracking exercise and drill items. The system is described in licensee procedure CSIL-7. The procedure assigns responsi-bilities for initiating tracking action and describes the methods to be
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followed in tracking and closure of an item. All action and commitments to be tracked are entered on the computerized Commitments Work Item list. The inspector reviewed a printout of emergency preparedness tracking / commitment items for September 1982. The inspector noted that drill and exercise items were identified and responsibility for action and action dates were assigned. The inspector noted that the system can be used to warn a responsible individual or group that a commitnent date, test date or report date is approaching.
The system has built-in warning dates, review due dates, and final deadline dates. The system and procedure appear to be consistent with the corrective action stated in the licensee's letter to NRC dated December 7, 1981. Based on these findings the previously identified violation in this area (81-19-29) is closed.
The inspector discussed utilization of controllers and technical data input into exercise scenarios with licensee representatives. This matter was identifiedasaninspectorfollewupiteminapreviousinspection(81-24-1).
An interview was held with representatives of the licensee's emergency planning staff having responsibility for scenario development for the November 1982 exercise. Licensee representatives stated that they recognized the need for controllers and adequate technical data input to the exercise. The inspector reviewed a draft of the upcoming exercise scenario.
The inspector discussed the proposed technical aspects of the scenario with the licensee planners.
It appears that over 10 major areas will be tested and approximately 15 offsite agencies will be involved in the exercise. The inspector emphasized that controller involvement and technical data flow would be evaluated by NRC during the upcoming exercise. Based on these findings the previously identified improvement item in this area (81-24-01) is closed. }}