IR 05000327/1990033
ML20028H195 | |
Person / Time | |
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Site: | Sequoyah ![]() |
Issue date: | 10/31/1990 |
From: | Kreh J, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
To: | |
Shared Package | |
ML20028H194 | List: |
References | |
50-327-90-33, 50-328-90-33, NUDOCS 9011160077 | |
Download: ML20028H195 (7) | |
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ATLANTA,OLORCIA 30323
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NOV 0 ? 1990 i
Report Nos.:
50-327/90-33 and 50-328/90-33 Licensee:
Tennessee Valley Authority 6N38 A Lookout Place
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1101 Market Street
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Chattanooga, TN 37402-2801 l
Docket Nos.:
50-327 and 50-328 License Nos :- DPR-77 and DPR-79
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facility Name:
Sequoyah Nuclear Plant inspection Conducted: -October 9-12, 1990
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- Approved by:
Emergency Preparedness Section i
Emergency Preparedness and Radiological i
Protection-Branch i
Division of Radiction Safety and Safeguards I
SUMMARY l
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. Scope:
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This special, unannounced inspection was conducted to determine the adequacy of
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(1) emergency detection ard classification, (2) protective action
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3-decision-making, and (3) shif t staffing and augmentation.
Particular attention
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was given to the licensee's response to an event on September 11, 1990, for
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which an emergency classification of Alert was declared, t
Results:
In the areas inspected, no violations or deviations were identified.
The
.following positive findings were noted:
(1)thelicensee'sclassificationsof,
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and responses to, plant emergencies were timely and. appropriate; (2) three Shift Operations Supervisors demonstrated good capabilities in emergency
classification and protective action decision-making during walk-throughs; and
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(3) the licensee.had im)1emented a " duty roster" system for staffing onsite
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emergency response facilities, using three teams on weekly rotation.
Minor
. inconsistencies in the emergency classification scheme were noted (see Paragraph 2 for details) and will be. tracked by the NRC to verify appropriate corrective action, 9011160077 901102
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REPORT DETAILS i
1.
Persons Contacted
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Licensee Employees
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G. Carroll, Shift Operations Supervisor i
- N.Catron,EmergencyPreparednessProgramManager(Site)
D. Cross, Shift Operations Supervisor
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- T. F11ppo, Quality Assurance Manager R. Hill, Shift Technical Advisor L. Hodges, Shift Operations Supervisor
- R. Kitts, Manager.. Emergency Preparedness (Corporate)
- D. Marks, Manager,EmergencyPreparednessProgramPlanning(Corporate)
- T. Noble, Emergency Preparedness Specialist W. Payne, Lead Instructor - Requalification
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- J. Proffitt, Compliance Licensing Manager
- J. Robinson, Manager, Site Programs and Support
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- C..-Vondra, Plant Manager N. Welch, Shift Operations Supervisor
- C, Whittemore, Licensing Engineer Other licensee employees ' contacted during this inspection included
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engineers, operators, security force members, and administrative personnel.
NRC Resident inspector
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- S. Shaeffer
- Attended exit' interview
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2.' _ ReviewofEmergencyDeclarations(82201)
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Licensee ' records: of actual emergency declarations: during the period.
l January 1-October 11, 1990, were reviewed. :These records included Control
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Room-logs, completed Emergency Plan Implementing Procedures, initial and-
follow-up notificotion message forms, and Licensee Event Reports -(LERs).
- Duringithis. period, the' licensee made eight Notification of Unusual Event (NOVE)- declarations and one Alert declaration.
These - emergency
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declarations were determined to have been' consistent with the licensee's
Emergency Action Levels -(EALs) and were made =in a timely manner, as were-
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subsequent required notifications of State and NRC officials.
- On September 11, 1990, an Alert was declared (and terminated) at.
1407. hours following loss of both trains of the Residual Heat Removal-(RHR) system on Unit 2 for-five minutes.
Since this constituted loss of i
ability to remain in cold shutdown (Mode 5), Alert EAL SA2 was satisfied.
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This EAL was-consistent with NRC guidance as contained in Appendix 1 to
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NUREG-0654, which states that " Complete loss of any function needed for plant cold shutdown" is an exarrple initiating condition for the Alert class.
The inspector interviewed the Shift Operations Supervisor (505)
who declared the Alert.
The SOS stated that he briefly considered that EAL SA2 had not been met since the reactor unit had remained in Mode 5
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(the reactor coolant temperature increased from 127'F to 132*f during the
5-minute loss of the RHR function).
However, immediate review of the event with his staff resulted in a determination by the SOS that EAL SA2 criteria, had indeed been met.
Since the transient had already been terminated by this time, the SOS conferrtd with plant management prior to declaring the Alert in order to avoid the normally required staffing of a
onsite einergency response facilities at Alert.
The actual emergency
declaration was made 34 minutes after the initiating event.
The NOVE declarations thus far during 1990 are sunenerized below based on information provided by the licensee.
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'1990 Time Emergency Declaredlic,rminated Event bescrijttjo,n d e Date
Feb. 28 1813/1813 Uncontrolled rod bank withdrawal l
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(Unit 1)
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i March 22 1957/2125 Actions by terminated contract l
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employee determined to represent
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security threat
March 23 0243/0320 Contaminated injured individual transported to North park Hospital
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- June 27 0315/0415 Hydrogen leak in Volume Control
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Tank room (Unit 2)
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0327/0428 Both emergency diesel generators
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for Unit 2 out of service August 29 0223/0607 Primary system leakage on Unit 1
of approximately 2.6 gpm exceeded Technical Specification limit
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of 1.0 gpm
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- Sept. 12-13 -
1940/0136'
failure.of meteorological-instrumentation because of
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lightning strike
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Oct. 8 0721/1534 Unit 1 shutdown required by Technical Specifications (failure
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of check valve in main steam line-
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3.
Emergency Detection and Classification (82201)
Pursuant to 10 CFR 50.47(b)(4); 10 CFR Part 50, Appendix E. Sections IV.B and IV.C; and Appendix B to the Nuclear Power Radiological Emergency Plan (NP-REP), this program area was inspected to determine whether the licensee used and understood a standard energency action level and
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classification scheme.
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The inspector reviewed Emergency Plan Implementing Procedure (EPIP)-1,
" Emergency Plan Classification Logic", Revision 5.
The event
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classifications in the procedure were consistent with those specified in
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the NP-REP.
Selected EALs in EPIP-1 were reviewed and found to be consistent with the initiating events specified in Appendix 1 to NUREG-0654 The inspector noted that most of the EAls were based on
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parameters obtainable from Control Room instrumentation, l
Notwithstanding the statements above, internal inconsistencies in the licensee's classification scheme in EPIP-1 were disclosed during the course of the inspection.
An SOS walk-through confirmed a suspected ambiguity in General. Emergency ]EAL FG2, which read as follows:1) entmt
"ECCS
- Emergency Core Cooling System failure... and consider
, containment) failure within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />..
2) significant failed fuel..." One of the scenarios used for the SOS walk-throughs included plant conditions and parameters which clearly met the intent of EAL FG2, as determined by both the inspector and the Emergency Preparedness Program Manager.
Furthermore, two of the three SOSs readily derived the correct classification because they interpreted the word " consider" in EAL FG2 to-be ecuivalent to "both of the following" as intended by the licensee.
The
'thirc SOS became confued and apparently tried at one point to relate the two criteria followin' " consider" to a flowchart for deriving an offsite protective action recommendation (PAR) before determining an emergency classification.
In a discussion following-the walk-through, the SOS acknowledged his confusion over the wording of-the subject EAL.
The licensee agreed -to revise EPIP-1 so as to minimize further confusion regarding - the cited EAL.
This matter will be tracked as an Inspector Follow-upItem(!FI).
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IFI 50-327, 50-328/90-33-01:
Clarification of EAL FG2 in EPlP-1.
The inspector's review of EPlP-1 identified. three
'! natural hazard" categories which contained unintentional discontinuities between the
respective Alert and Site Area Emergency EALs.
The event categories in
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question were flood, high winds, and low reservoir level.
The following example illustrates the type of inconsistency which could arise: With both units in cold shutdown, sustained winds of 90 mph would require an Alert
declaration per EAL HA10 (viz., sustained winds greater than or equal to 85 mph but less than 95 mph as indicated in the Control Room). However, with sustained winds increased to 100 mph, neither the Alert EAL nor Site Area Emergency EAL HS7 (viz., sustained winds greater than or equal-to
' 95 mph as indicated in the Control Room and units not in cold shutdown)
would be met, and the emergency declaration could be terminated. Licensee i
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representatives agreed that the intent of the classification scheme was to retain the Alert declaration as winds increased from 90 mph to 100 mph with both units in cold shutdown.
However, the EALs as written did not fulfill this intent.
Analogous discontinuities existtTfor the other two event categories previously listed.
(It is important to note that the EALs in EPIP-1 were exactly as presented in che NP-REP [ Revision 6], and thus this is not a case of an EPIP failing to adequately implement the Energency Plan.) This matter will be tracked as an IFI.
IFI 50-327, 50-328/90-33-02:
Revision of EAls for high winds, flood, and low reservoir level to preclude nonclassification of significant hazards.
The inspector verified that the EPIPs included criteria for initiation of
. offsite notifications and for development of PARS.
The procedures required that offsite notifications be made (via the Operations Duty
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Supervisor in Chattanooga, TN) promptly after declaration of an emergency.
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The inspector discussed with licensee representatives the coordination of EALs with State and local officials.
Documentation showed that the-licensee had discussed this subject during March 1990 with State of Tennessee officials, and that these officials agreed with the EALs for the r
Sequoyah P.lant.
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In an effort to determine the adequacy of the event classification procedure (EPIP-1) and to gauge the effectiveness of the emergency response training program, the inspector conducted interviews (approximatelys 90 minutes each) with three 50Ss.
designated as interim Site Emergency Director [ SED](The SOS position was until relieved by the i
Plant Manager or alternate.)
Each interview examined the SOS's general
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knowledge of emergency response nothodology as well as his' specific understanding of emergency classification, onsite protective actions, offsite PARS, and notifications to offsite authorities.
Each SOS was
. given four sets of hypothetical emergency conditions and was asked to talk through the response he would render as SED under the stated conditions.
Except in the one instance previously discussed, each interviewee demonstrated-a good understanding of the general concepts as well as'the specifics of the emergency response program, properly classified.the
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hypothetical accident situations presented to him, and appeared to be
. thoroughly familiar with the emergency classification scheme.
No violations or deviations were identified.
4.
~ProtectiveActionDecision-Making (82202)-
Pursuant to 10 CFR 50.47(b)(9) and (10);.10 CFR Part 50, Appendix E,.
Section IV.D.3; and Section 10 of the NP-REP,~this area was inspected to determine whether the licensee had 24-hour-per-day capability to assess and analyze energency conditions so as to formulate recomendations to protect the public and onsite worker ~
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The inspector discussed responsibility and authority for protective action decision-making with licensee representatives and reviewed pertinent portions of the NP-REP and the EPIPs.
These documents clearly assigned responsibility and authority for accident assessment and protective action decision-making.
Interviews with members of the licensee's emergency i
organization showed that these personnel understood their authorities and responsibilities with respect to accident assessment and protective action decision-making.
Walk-throyh evaluations involving protective action decision-making were conducted with three 50Ss, all of when, appeared to be cognizant of y
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appropriate onsite protective measures and aware of the range of PARS j
appropriate to offsite protection.
Personnel interviewed were aware of l
the need for timeliness in making initici PARS to offsite officials.
Interviewees demonstrated adequate understanding of the requirement that
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PARS be based on core condition anj containment status even if no release is in progress.
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p No violations or deviations were 'dentified.
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5.
Shift Staffing and Augmentation (82205)
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Pursuant 'to 10 CFR SC 47(b)(2) and 10 CFR Part 50, Appendix E,
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Sections IV.A and IV.C, this area was inspected to determine whether shift staffing for' emergencies was adequate both in numbers and in-functional capability, and whether administrative and physical means were
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L Shift staffing levels and func'.ional capability of all shifts were
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reviewed and found to be. consistent with the-guidance of Table B-1 of NUREG-0654.. The licensee had established' an "on-call" system so that'
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essential off-shift personnel would be available to staff the TSC and OSC.
The on-call schedule'used three crews which rotated on a weekly basis.
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The use of such on-call teams,'rather than a call list for each emergency response ' position, was clearly a strength because of the working i
familiarity gained through practice drills.
Coupled with the use of an automated emergency paging system, the licensee's staffing arrangements a
. appeared. to provide an : effective approach to meeting established augmentation goals.
The inspector discussed staff augmentation times with licensee l
representatives.' Availability of' on-call crew personne1'to staff, the TSC following an off-hour emergency declaration at Alert or higher was-tested i
- f by means of-annual unannounced drills. The last such drill was conducted on March 16, 1990 at 5
- 30 a.m., and-involved actual reporting to the plant
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by the on-call crew.
The TSC and OSC were activated 56 minutes after the
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" order" to activate, successfully addressing the 60-minute goal.
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conmitment to conduct such drills annually was informal until it was-t
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= documented in the licensee's July 16, 1990 response to the NRC's latest
Systematic Assessment of Licensee Performance (SALP) report, in addition, j
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the Emergency Preparedness Program Manager informed the inspector that the
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referenced commitment meant that each of the.three on call crews would be t
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drilled annually to confirm the capability to augment the TSC and OSC L
during off-hours.
6.
ActiononPreviousInspectionFindings(92701)
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.(Closed) IFI 50-327, 50-328/90-21-01:
Clarification of Site Area
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Emergency EAL FS6 to preclude misinterpretation or niisapplication.
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The licensee's corrective action was contained in Revision 5 to EPIP-1 and
.was determined to. be fully satisfactory in eliminating the ambiguity L-
'previously noted in the subject EAL, l
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Exit Interview
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The inspection scope and results were summarized on October 12, 1990, with
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those persons indicated.in Paragraph 1.
The inspector described the areas o
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Although proprietary information was reviewed during this inspection, none'
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Dissenting comments were not received from
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the licensee.
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Item Number,,
Category, Dese,rjgtjon,, and Reference on l;-50-327, 328/90-33-01=
IFI: Clarification of EAL FG2 in EPIP-1
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u 50-327,'328/90-33-02 IFI:
Revision of EAls for.high winds, ficod, and
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I low reservoir. level to preclude nonclassification'
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of'significant-hazards,(Paragraph 3).
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