IR 05000259/1999004

Insp Repts 50-259/99-04,50-260/99-04 & 50-296/99-04 on 990613-0724.Violations Noted.Major Areas Inspected:Licensee Operations,Maint,Engineering & Plant Support

ML18039A860
Person / Time
Site:	Browns Ferry
Issue date:	08/23/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18039A859	List: IR 05000259/1999004 ML18039A858
References
50-259-99-04, 50-260-99-04, 50-296-99-04, NUDOCS 9908310322
Download: ML18039A860 (56)

Text

July 24, 1999

SUBJECT:

BROWNS FERRY NUCLEAR PIANT RESPONSE TO BIENNIALEXERCISE ISSUE FROM NRC INTEGRATED INSPECTION REPORT 50-259/99-03, 50-260/99-03, AND 50-296/99-03

Dear Mr. Scalice:

This refers to your letter dated January 18, 2000, regarding the exercise issue discussed in Section P4.2.b.4 of the. subject NRC report.

Your letter expresses disagreement with our conclusion that the second protective action recommendation (PAR) provided to State. authorities during the exercise on May 26, 1999, was incorrect, and that exercise objective D.4 was therefore not demonstrated.

Exercise objective D.4 stated, "Demonstrate the ability of the CECC [Central Emergency Control Center] to provide emergency classification, protective action recommendations, plant conditions, and dose assessment information to the State in a timely manner.

Based on further review of this matter, we agree with the statement in your letter that "CECC objective D.4 is multifaceted in nature, and, as such, a perceived PAR oversight should not represent a total failure to successfully perform the objective." We conclude that objective D.4 was adequately demonstrated from an overall perspective.

However, we are not dissuaded from our original conclusion that the second PAR was incorrect and not in accordance with CECC EPIP [Emergency Plan Implementing Procedure] -1, "CECC Alert, Site Area Emergency, and General Emergency," Revision 27, effective May 20, 1999.

Nothing in your procedures or in NRC regulations or guidance absolves you from the responsibility to provide an appropriate and timely PAR, irrespective of actions that may have already been taken by offsite authorities.

Because of the State's prior decision to evacuate the sector in question, public health and safety likely would not have been affected in this set of circumstances.

Our concern is that an incorrect PAR was provided, and your critique should have identified this inaccuracy.

This PAR error represents a failed opportunity in the Performance Indicator (Pl) for Drill/Exercise Performance (DEP). The data you previously submitted for the DEP Pl should be revised accordingly.

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Should you have any further questions regarding this matter, please contact me.

Sincerely,

/RA/

Paul E. Fredrickson, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-259, 50-260, 50-296 License Nos.: DPR-33, DPR-52, DPR-68 CC:

Karl W. Singer Senior Vice President Nuclear Operations Tennessee Valley Authority Electronic Mail Distribution Jack A. Bailey, Vice President Engineering and Technical Services Tennessee Valley Authority Electronic Mail Distribution John T. Herron Site Vice President Browns, Ferry Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution General Counsel Tennessee Valley Authority Electronic Mail Distribution (cc cont'd - See page 3)

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(CC cont'd)

N. C. Kazanas, General Manager Nuclear Assurance Tennessee Valley Authority Electronic Mail Distribution Robert G. Jones, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority Electronic Mail Dis'tribution Mark J. Burzynski, Manager Nuclear Licensing Tennessee Valley Authority Electronic Mail Distribution Timothy E. Abney, Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority Electronic Mail Distribution State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P. O. Box 303017 Montgomery, AL 36130-3017

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Subject:

BROWNS FERRY NUCLEAR PLANT (BFN)

RESPONSE TO 1999'MERGENCY PREPARED NESS (EP)

EXERCISE DISCREPANCY IDENTIFIED IN NRC INTEGRATED INSPECTION REPORT 50-259, 260, AND 296/99-03.

Body.:

Docket:

05000259, Notes:

N/A Docket:

05000260, Notes:

N/A Docket:

05000296, Notes:

N/A Page

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Tertrtessee Valley Authortty. Post Office 8ox 2000, Decatur, Atacama 36609 January 18, 2000 Mr. P.

E. Fredrickson, Branch Chief U.S. Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth Street S.W.

Suite 23T85 Atlanta, Georgia 30303 Gentleman:

In the Matter of

)

Tennessee Valley Authority

)

Docket Nos.

50-259 50-260 50-296 BROWNS FERRY NUCLEAR PLANT (BFN)

RESPONSE TO 1999 EMERGENCY PREPAREDNESS (E P)

EXERCISE DISCRE PANCY IDENTIFIED IN NUCLEAR REGULATORY COMMISSION (NRC)

INTEGRATED INSPECTION REPORT 50-259, 260, and 296/99-03 The purpose of this letter is to present TVA's views regarding a 1999 EP exercise discrepancy contained in NRC Integrated Inspection Report (IR) 99-03.

In the Executive Summary of the inspection report, NRC noted "the second of the licensee's two protective action recommendations was erroneous, and constituted a failure to meet one of the established emergency preparedness exercise objectives."

Furthermore, in section P.4.2, Plant Support, NRC noted that TVA failed to demonstrate Central Emergency Control Center (CECC)

EP exercise objective D.4.

Objective D.4 requires the CECC Director to provide the following four actions to the Alabama Department of Public Health (ADPH) personnel in a timely manner:

(1)

emergency classifications, (2) protective action recommendations, (3) plant conditions, and (4)

dose assessment information.

The issue, that led to the staff's conclusion was that Sector E5 of the BFN-5 mile emergency planning zone was omitted from a protective action recommendation.

While TVA acknowledges that Sector E5 was not included in Notification Message Ce>4O~'~ >~

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Mr. P.

E. Fredrickson Page

January 18, 2000 Number (NMN)

PAR, TVA believes that this omission was a

result of extensive and thorough communications between TVA and ADPH personnel.

At 1206 hours0.014 days <br />0.335 hours <br />0.00199 weeks <br />4.58883e-4 months <br />, NMN 4 PAR was provided to ADPH personnel based on the prevailing wind direction.

However, at this time, ADPH personnel had used wind projections for 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> (see the enclosed letter from the ADPH).

As a result of the use of a different wind direction, ADPH personnel evacuated Sector E5.

Extensive discussions occurred between TVA CECC staff and ADPH personnel to resolve this problem.

Following the resolution of the problem, ADPH personnel began to use the meteorological data which coincided with the progress of the exercise scenario.

At approximately 1225 hours0.0142 days <br />0.34 hours <br />0.00203 weeks <br />4.661125e-4 months <br />, TVA provided another PAR which did not include the evacuation of Sector E5.

Having the foreknowledge that ADPH personnel had evacuated Sector E5, 19 minutes before, a deliberate, well researched PAR which did not include Sector E5 was provided in NMN 6 in a timely manner.

Since NMN 6 did not include the evacuation of Sector E5, NRC construed this decision as a deviation from CECC Emergency Plan Implementing Procedure (EPIP)-1, Revision 27. Step 6.2.3 of the procedure states, in part,,

"The CECC Director is responsible for making appropriate public protective action recommendations to State authorities."

As can be seen from the above, the omission of evacuating Sector E5 in NMN 6 did not constitute a failure to meet the exercise objective CECC, D.4.

First, CECC objective D.4 is multifaceted in nature, and, as such, a perceived PAR oversight should not represent a total failure to successfully perform the objective.

'Secondly, NRC Inspection Procedure 82301, Evaluation Of Exercises For Power Reactors, provides guidance to ensure that protective action decision making in the CECC considers evacuation time estimates.

The 1225 hour0.0142 days <br />0.34 hours <br />0.00203 weeks <br />4.661125e-4 months <br /> protective action decision did consider the ADPH's evacuation of Sector E5.

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'Mr.

P'.

E. 'Fredrickson Page

January 18, 2000 Therefore, the requirements and intent of procedure CECC EPIP-1 were met.

'The decision of the CECC Director not to include the evacuation of Sector E5 in NMN 6 did not impact the response of ADPH personnel during the exexcise.

Thirdly, the inspection report noted:

(1) offsite notifications of emergency classifications were made in a timely manner, (2)

protective action recommendations were satisfactory;ly researched prior to providing a recommendation to ADPH personnel, and (3) the identified discrepancy (i.e., not recommending evacuation of Sector E5 in a protective action recommendations (PAR)) would not have adversely affected the public health and safety in a real emergency because ADPH personnel had previously ordered the evacuation of that sector.

Finally, the enclosed letter from the ADPH clearly supports the conclusion that. communications between the CECC staff and ADPH personnel were excellent and there was no confusion with the State decision makers.

Therefore, TVA concludes that CECC objective D.4 was met and no deficiency should have 'been reported.

Reporting this: deficiency in IR 99-03 as a total failure to meet CECC objective D.4 does not appear to meet the intent of the guidance in NRC Inspection Procedure 82301.

There are no commitments contained in this letter.

If you have any questions please contact me at (256)

729-2636.

S'nce T. E.

y Manag r of Site Licensing and Industry A fairs cc:

Se'e page

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Mr. P..E. 'Fredrickson Page

January 18, 2000 Enclosure cc (Enclosure):

Mr. William O. Long, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville 'Pike Rockville, Maryland 20852 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C..

20555 NRC Resident inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, A'labama 35611 D. E. Williamson, M.D.; 'State Health Officer State Of Alabama Department OF Public Health The RSA Tower 210 Monroe Street Montgomery, AL 36130-3017

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ENCLOSURE TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT SUPPORTING LETTER FROM STATE OF ALABAMA (See Attached)

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PUBLIC HEALTH Donald E. Williatnson, MD State Health Off':er September 3, 1999 Ronnie Kitts Tennessee Valley Authority 1101 Market Street Chattanooga, Tennessee 37402-2801

Dear Mr. Kitts:

1 would like to offer my comments regarding the difference in protective action recommended by the CECC and the action ordered by the State ofAlabama Department ofPublic Health during the May 26, 1999 exercise.

ln follow-up discussions with staff, there appears to have been some miscommunication in interpreting the g~ngzig weather forecast timeline. Specifically, did timelines represent actual time W

d i.lii ii dp ii Biy g~.Hi'i weather forecasts" been used, I believe that this problem would have been avoided.

Based upon information available at the time and our interpretation ofthat information the State decided to include Sector E-5 in evacuation order number 004 issued Il~i~and not include Sector A-5 as recommended by CECC. At 1208 l discussed the order with the CECC director. At that time it was discovered that scenario weather was not being interpreted the same.

AAer discussing the matter with the meteorologist in the CECC, a new order, evacuation order number 006, was issued at'1225, only seventeen minutes from the issuance oforder number 004.

Sector E-5 was ordered to be evacuated at 1206 and this was communicated to the CECC by telephone and fax. The fact that Sector E-5 was not included in later CECC recommendations in no way affected decisions made by thc State ofAlabama. Although no formal recommendation was made to evacuate Sector E-5 by CECC, both the GECC and the State were aware that Sector E-5'had been ordered evacuated at 1206. This, in no way caused any confusion with state decision makers.

Neither would it have placed citizens in Sector E-5 in any danger in a real emergency.

A review ofexercise notes indicates that communication between the CECC and the State of Alabama Radiation Control was excellent.

There were lengthy discussions of issues and t

subsequent actions taken based upon those discussions.

The RSA Tower ~ ZOI Monroe Strrct ~ Morttt, energy, AL 36104 PO. 8ox 3030l7 ~ Moot@>m~; hL 36i 30.30l 7

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Ronnie Kitts Page 2 September 3, 1999 The efforts made by you and the entire TVAstaff in.making sure that the citizens ofthis State willbe protected in the event ofan accident at Browns Feny Nuclear Plant are recognized,and

. appreciated.

Sincerely, Kirksey E. %hatley, Director OfGce ofRadiation Control KEW/rnwf

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