IR 05000327/1993007
| ML20035F199 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah |
| Issue date: | 03/18/1993 |
| From: | Barr K, Kreh J, Wright F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20035F193 | List: |
| References | |
| 50-327-93-07, 50-327-93-7, 50-328-93-07, 50-328-93-7, NUDOCS 9304210020 | |
| Download: ML20035F199 (14) | |
Text
_ _ _ _ _ _ _ _ _ _ _ __ ________ -
_
-
.
t j#"
%g UNITED ST ATES
-
g,.
. fg NUCLE AR REGULATORY COMMisslON
'-
e.
R EGION 11
.$
101 MARIET TA STRE ET.N.W.
[
ATL ANT A. GEORGI A 30323
%,
f
MAR 181993 Report Nos.:
50-327/93-07 and 50-238/93-07 Licensee: Tennessee Valley Authority 6N 38 A Lookout Place Chattanooga, TN 37402-2801 Docket Nos.:
50-327 and 50-328 License Nos.: DRP-77 and DRP-79 Facility Name: Sequoyah I and 2 Inspection Condbcted:
February 16-19, 1993 Inspectors:
4I/>M -,
'LL 3 - h lI3 F.
Wright
.
Date Signed hpM-f,
wf~--.
3 j)
t)3 J. L.y Qeh Date Signed
~
, ) (,. m 3- //- 93
~
Approved by:
K. P. 'Barr, Ctiikf) ~ ~
Date Signed Emergency Preparedness Section Radiological Protection and Emergency Preparedness Branch
!
}
Division of Radiation Safety and Safeguards l
t i
SUMMARY Scope:
This routine, announced inspection was conducted to assess the operational readiness of the site emergency preparedness program, and included a review of the following program elements: (1) Emergency Plan and associated implementing procedures; (2) facilities, equipment, instrumentation, and supplies; (3)
organization and management control; (4) training; and (5) independent and internal audits and reviews.
Results:
In the areas inspected, one non-cited violation was identified for failure to maintain emergency response training for an individual having emergency response duties. No deviations were identified.
Off-hout emergency staff augmentation drills were a program strength.
The overall conclusion of this inspection was that the emergency preparedness program was being maintained in a state of operational readiness.
9304210020 930318 PDR ADOCK 05000327 G
,
'
.
.
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- L. Bryant, Maintenance Manager
- L. Bush, Plant Operations Manager
- N. Catron, Site Emergency Preparedness & Planning Manager
- M. Cooper, Site Licensing Manager
- R. Drake, Project Management / Controls Manager
- R. Fenech, Sequoyah Vice President
- T. Flippo, Site Quality Manager
l
- C. Kent, Radiological Controls Manager R. King, Operations Training Manager
- R. Kitts, Corporate Emergency Preparedness Programs Manager P. Lawrence, Shift Operations Supervisor W. Ludwig, Regulatory Licensing Engineer
- B. Marks, Corporate Emergency Preparedness Program and Implementation Manager H. Tirey, Shift Operations Supervisor K. Walker, Radiological Controls Specialist
- P. Wallace, Site Support Manager
- J. Ward, Engineering and Modifications Manager D. Webb, Shift Operations Supervisor i
l E. Webb, Nuclear Quality Audit and Evaluation Team Leader
'
- C. Whittemore, Licensing Engineer
- H. Williamson, Site Emergency Preparedness & Planning Other licensee employees contacted during the inspection included instructors, operators, security force members, technicians, and
'
administrative personnel.
Nuclear Regulatory Commission
- W. Holland, Senior Resident Inspector S. Shaeffer, Resident Inspector
- Attended exit interview 2.
Emergency P1an and Implementing Procedures (82701)
This area was inspected to determine whether significant changes were made in the licensee's emergency preparedness program since March 1992 (the date of the last inspection of this area), to assess the impact of any such changes on the overall state of emergency preparedness at the facility, and to determine whether the licensee's actions in response to actual emergencies were in accordance with the Radiological Emergency Plan (REP) and its implementing procedures.
Requirements applicable to this area are contained in 10 CFR 50.47(b)(16), 10 CFR 50.54(q), Appendix E to 10 CFR Part 50, and the licensee's RE a
.
-
l
.
.
The inspector reviewed the licensee's system for making changes to the REP and the emergency plan implementing procedures. Through selective review of applicable documents, the inspector confirmed that licensee
,
management approved revisions to the REP and Emergency Plan Implementing Procedures (EPIPs), as required. The inspector selected several recent implementing procedure changes and made random checks
!
of controlled copies of procedures in emergency response facilities (ERFs) to verify copies of the procedures were being properly
,
maintained.
Copies of the Emergency Plan and EPIPs which were available for use at the Control Room, Technical Support Center (TSC),
,
Operations Support Center (OSC), and Central Emergency Control Center
'
(CECC) were checked and found to be current revisions.
-
'
The version of the REP in effect at the time of the current inspection was Revision (Rev.) 11, dated November 25, 1992. This was one of the
,
!
two changes made to the REP since the aforementioned March 1992 inspection. The NRC's licensing review of Revision 10, dated May 5, j
1992, and Rev. 11 were in progress at the time of the current
,
inspection.
]
'
The inspector verified, through a review of licensee documentation,
'
that the required annual review of emergency action levels with offsite agencies was made in 1992.
The documentation indicated the i
State was satisfied with the review.
j Regulatory guidance of Section II.E of NUREG-0654, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Rev. I stated, in part, that procedures should be established for notifying the State and local response organizations. The initial notifications should contain information about the class of the emergency, whether a release is taking place, potentially affected population and areas, and whether protective measures may be necessary. The licensee should also have procedures for follow-up messages from the facility to offsite authorities. The follow-up messages should contain additional information concerning the emergency if it is known and appropriate.
Section 5.2.2 of the REP listed additional information to be reported to offsite agencies hourly, or more often as necessary.
The licensee's emergency procedure SQN-EPIP-1, " Emergency Plan Initiating Conditions Matrix," Rev. 7, dated October 29, 1992, was the procedure the Shift Operations Supervisor or Site Emergency Director would use in determining the classification of an accident based upon plant conditions. Depending upon the classification determined by SQN-EPIP-1 the Shift Operations Supervisor would enter one of the following procedures:
SQN-EPIP-2, " Notification of Unusual Event," Rev. 7, dated
-
February 12, 1993 SQN-EPIP-3, " Alert," Rev. 7, dated February 12, 1993
-
l l
l l
.
SQN-EPIP-4, " Site Area Emergency," Rev. 7, dated February 12,
-
1993 SQN-EPIP-5, " General Emergency," Rev. 7, dated February 12,
-
1993 SQN-EPIPs 2 through 5 contained a form (Attachment 1) for the Shift Operations Supervisor or Site Emergency Director to use in reporting event information to the Operations Duty Specialist from the Control Room. The licensee's procedures required the Shift Operations Supervisor, in the Control Room, to complete the information/ notification form and report the information to the Operations Duty Specialist. The Operations Duty Specialist was located in an office adjacent to the licensee's CECC in Chattanooga, Tennessee. The position was continuously staffed, seven days a week, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. The Operations Duty Specialist was then responsible for reporting the information to the State and local agencies.
Depending upon the classification reported by the Site Emergency Director, the Operations Duty Specialist was required to enter one of the following CECC procedures:
CECC-EPIP-2, " Operations Duty Specialist Procedure For
-
Notification of Unusual Event," Rev.11, dated December 23, 1992 CECC EPIP-3, " Operations Duty Specialist Procedure For Alert,"
-
Rev. 13, dated January 25, 1993 CECC EPIP-4, " Operations Duty Specialist Procedure For Site
-
Area Emergency," Rev. 14, dated January 25, 1993 CECC EPIP-5, " Operations Duty Specialist Procedure For General
-
Emergency," Rev. 13, dated January 25, 1993 In accordance with the REP, the CECC was activated at Alert, Site Area and General Emergency classifications. Once the CECC was activated, the Center's director assumed responsibility for making notifications
to State and local agencies.
The inspector determined that the licensee's emergency procedures did not address the notification process for a period when the TSC was activated and the CECC was not.
SQN-EPIPs 2-5 addressed the notification process; however, each contained a statement that the procedure was not to be utilized when the TSC was activated.
SQN-EPIP-6, " Activation and Operation of the Technical Support Center,"
Rev. 7, dated July 27, 1992, stated that prior to the activation of I
the CECC, the Site Emergency Director had the responsibility for
recommendations of protective actions to State and local agencies
!
through the Operations Duty Specialist. The procedure also stated that the Site Emergency Director had the responsibility for emergency classification and periodically reevaluating the classification and was responsible for reporting the classifications to the CECC
4 Director.
However, SQN-EPIP-6 did not include a form similar to the one utilized in SQN-EPIPs 2-5, to notify the Operations Duty Specialist; and the procedure did not contain a systematic or controlled method for reporting changing emer5ency classifications, radiological conditions, or protective actions to the Operations Duty Specialist. The inspector noted that the Operations Duty Specialist did have a procedure (CECC-EPIPs.2-5) that would require him to determine appropriate information whenever he was contacted by the Site Emergency Director to report changing conditions. The inspector discussed the procedure deficiency with site and corporate staff responsible for the development and maintenance of the emergency preparedness program.
Licensee representatives reported that experience in exercises and drills showed the CECC staffing and activation time was about the same as the TSC (one hour) and once the CECC was activated it would provide information to the State and local agencies. The inspector was advised that the licensee will revise the emergency procedures to include provisions for the Site Emergency i
Director in the TSC to use in making systematic notifications of changing emergency classifications, protective action measuret ed other appropriate information to the Operations Duty Specialist. The inspector stated that a review of the licensee's corrective actions and changes to the emergency plan implementing procedures, concerning offsite notification information provided to the Operations Duty Specialist from the Site Emergency Director in the TSC, would be reviewed in a future NRC inspection as an inspector follow-up item (IFI).
IFI 50-327, 328/93-07-01:
Review the licensee's procedures, methods and controls for reporting emergency notification information from the Site Emergency Director to the Operations Duty Specialist in the time period between TSC and CECC activations.
During the 1992 NRC-evaluated exercise, the inspector noted that the licensee's procedures for notifying State and local agencies were cumbersome. The inspector noted that it had taken the Shift Operations Supervisor longer to complete and forward the Operations Duty Specialist Information/ Notification forms than the five minutes suggested by the procedures.
It took the Site Emergency Director 8 and 12 minutes to complete the two notification forms and report their content to the Operations Duty Specialist during the exercise. The Operations Duty Specialist was then able to report the information to
,
the State and local agencies in another 5 minutes, resulting in i
notification times of 13 and 17 minutes.
Licensee representatives committed to review the notification process for improvements in timeliness and the inspector made the review an IFI.
During this inspection, the inspector determined that the licensee had made some improvements in the notification process. The licensee met with representatives of the States of Tennessee and Alabama to discuss the content and type of information provided to states in initial emergency notifications. The States agreed to a reduction in the information initially provided by the licensee, and the notification forms utilized by the Shift Operations Supervisor and the Operations l
i i
. _ _.
.
,
Duty Specialist were reduced to a checklist to reduce completion time.
l The inspector reviewed the changes to the appropriate site and CECC t
procedures and determined that the revised forms appeared to represent
!
a more efficient method of reporting the information.
During a tour of the CECC, the inspector noted posted maps which
contained specific numbered environmental monitoring locations.
L Sccording to licensee representatives the numbered points represented i
environmental sampling and emergency siren locations.
Licensee
.
representatives reported that the locations could be utilized by the Environmental Assessor in directing environmental field monitoring teams to specific sampling locations.
During an inventory of emergency monitoring van equipment at the Sequoyah site, the inspector noted that the van contained similar maps. The maps along with other road maps were to be utilized by the van driver in locating sampling
locations as directed by the Envircnmental Assessor. The inspector
also found a notebook which contained a written description of the specific environmental sampling locations. The inspector learned that i
the descriptions had been written to help monitoring personnel locate
specific environmental monitoring locations. The document was not controlled or referenced by procedures. The inspector discussed the
'
use of the document with licensee representatives and determined that
,
it was a useful document for environmental monitoring personnel.
Licensee representatives stated they would review the document for
,
inclusion into controlled procedures or by reference as a controlled document. The inspector stated that a review of the licensee's
,
actions to establish document controls for written environmental j
monitoring location descriptions utilized by environmental monitoring i
teams would be reviewed in a future inspection as an IFI.
IFI 50-327, 328/93-07-02: Review licensee efforts to establish
,
l document controls for written descriptions of environmental monitoring locations utilized by environmental monitoring teams.
,
The inspector reviewed records pertaining to the seven emergency declarations which occurred between January 1, 1992 and the date of the current inspection. With the sole exception of the Alert i
declaration on June 10, 1992, all were declared at the Notification of i
Unusual Event level, and are summarized as follows:
J TIME DECLARED DATE AND TERMINATED DESCRIPTION OF EVENT 03/18/92 10:10 p.m.
Commencement of Unit I shutdown 03/20/92 02:05 a.m.
required by TSs because of problems with opening some ice condenser lower inlet doors 04/29/92 10:42 p.m.
Actuation of Unit 1 Emergency Core 04/30/92 03:30 a.m.
Cooling System due to steam line low pressure i
_
-
.
__
.
_
_
I a
.
.
06/10/92 11:12 a.m.
Alert declaration for Unit 2 11:12 a.m.
Coolant System leakage exceeding 50 gpm 08/21/92 01:36 p.m.
Actuation of Unit 1 Emergency Core 05:22 p.m.
Cooling System due to false pressurizer low-pressure signal generated by stray radio-frequency energy 09/04/92 02:30 a.m.
Fire lasting longer than 10 02:50 a.m.
minutes (Unit 2)
12/31/92 10:00 p.m.
Trip of the Reactor and turbine 11:48 a.m for both units, due to loss of pcwer from the 500-Kv Switchyard 02/05/93 06:39 a.m.
Manual trip of Unit I reactor 06:39 a.m.
required by TSs due to failure of control rods to insert into the core The emergency preparedness staff routinely reviewed the response to each emergency declaration in order to identify problems or inconsistencies which may have occurred with respect to the requirements of the REP implementing procedures.
The inspector's assessment concluded that each of the listed events was correctly classified based on the licensee's Emergency Action Levels (EALs).
'
However, the Alert declaration was made retroactively 20 minutes after an initial Notification of Unusual Event declaration and simultaneous termination. A subsequent revision to SQN-EPIP-1 clarified that a higher classification should not be declared following an initial classification at a lower level if the condition warranting such higher classification has already been terminated or exited.
In this situation, the revised procedure specified instead that the State and the NRC would be notified that a higher classification existed for a short time but was exited prior to any declaration. This approach was consistent with NRC guidance. Notifications to State and local governments and the NRC of these seven emergency declarations were made in accordance with applicable requirements, according to information recorded in the licensee's completed EPIPs for the events.
No violations or deviations were identified.
3.
Emergency Facilities, Equipment, Instrumentation, and Supplies (82701)
i This area was inspected to determine whether the licensee's ERFs and associated equipment, instrumentation, and supplies were maintained in a state of operational readiness, and to assess the impact of any changes in this area upon the emergency preparedness program.
Requirements applicable to this area are contained in
!~
.
--
.-
_
,_. - _.
.-
_- -
---. --_.
. _..
. -
_~
.__. - -
---
_.
'
.
-
F i
,
j
,
f i
!
10 CFR 50.47(b)(8) and (9), 10 CFR 50.54(q),Section IV.E of
!
Appendix E to 10 CFR Part 50, and Sections 6 and 8 and Appendix B of i
the licensee's REP.
I
.
The inspector toured the OSC, TSC, and CECC. Selective examination of l
emergency equipment and supplies.therein indicated that an adequate
state of. readiness was being maintained.
]
Discussions were also held with licensee representatives concerning
'
l modifications to facilities, equipment, and instrumentation since the last inspection. With the exception of the OSC, the inspector
l determined that the licensee's emergency preparedness facilities had i
not changed significantly since the previous inspection in 1992, and
!
no immediate changes were proposed. The licensee moved the OSC out of l
the Turbine Building into a portion of the plant's cafeteria located
-
in the Plant Service Building in 1992. The new facility significantly.
!
-
'
increased the work space of the center and permitted better communications within the facility. The Center was utilized
effectively during the 1992 NRC-evaluated exercise and the new
.
facility was considered a program improvement.
i
The inspector reviewed completed documentation for SQN-EPIP-17,
)
" Emergency Equipment and Supplies," Rev.- 4, dated April 30, 1992,
!
d addressing surveillances of various emergency response equipment and
!
supplies made after March 1992. This review indicated that the equipment was being properly maintained in a state of operational readiness.
The licensee had two environmental monitoring vans which could be i
'
utilized during an emergency to make environmental surveys.
Each van was configured and dedicated for that purpose. The latest van was placed in service in 1991 and was significantly improved in size and capabilities.
Examples of van upgrades included additional internal room and storage, better lighting, a personnel air lock for gross contamination control, and a port for taking external air samples' from
,
the inside of the vehicle. The inspector _ requested a demonstration of the operability of the latest environmental monitoring van 'and
.
observed an inventory of its contents as described in licensee procedure CECC-EPIP-9, " Emergency Environmental Radiological Monitoring Procedures," Rev. 10, dated November 23, 1993. The Radiation Contamination Specialist successfully demonstrated the operation of various equipment and how the vehicle could be utilized during an emergency to monitor for radiological releases. The licensee planned to replace the other and older environmental monitoring van with another new van in 1993. The inspector found the newer environmental monitoring van was an excellent emergency monitoring vehicle which was more capable than most allotted for that purpose.
i I
-
..
.
- -
--
-.
.
.
i
The inspector reviewed the licensee's reports of monthly testing results and system availability for the sirens included in the Prompt Notification System. The 1992 siren reliability rating was
!
99.6 percent and was based on an average of all tests, including
quarterly growl tests, monthly soundings, and silent tests. During the review the inspector noted that the number of sirens included for i
test varied.
According to licensee representatives, a siren had been i
added to the system for a new home community and other sirens had been taken out of service for various reasons including test, road work project and an accident. Sirens removed from service were not originally included in the licensee's availability calculations as
such sirens were not tested during those periods.
The availability,
>
including those out-of-service as calculated by the licensee, was
,
'
greater than the 90 percent recommended by the Federal Emergency Management Agency (FEMA).
'
Based upon ERF walk-downs, review of changes to the EPIPs, inspection of completed surveillance procedures, and statements by licensee
!
representatives, the inspector mncluded that no degradation of ERF l
capabilities had occurred since A rch 1992.
l No violations or deviations were identified.
4.
Organization and Management Control (82701)
,
This area was inspected to determine the effects of any changes in the licensee's emergency organization and/or management control systems on
the emergency preparedness program, and to verify that any such changes were properly factored into the REP and EPIPs.
Requirements applicable to this area are contained in 10 CFR 50.47(b)(1) and (16),
Section IV.A of Appendix E to 10 CFR Part 50, and Section 3 and Appendix B of the REP.
The licensee had three onsite emergency response teams which were
,
designated as the Blue, Green or Red Teams. As designed, each team i
had the capability of meeting site emergency response requirements and
,
'
duties, and each was scheduled to play in an annual NRC-reviewed exercise during a three-year period. The inspector noted the licensee had trained a large number of site personnel for emergency response
,
duties and had utilized different personnel in key positions during l
the previous graded exercises. As a result, the licensee's emergency response organization appeared to have considerable depth.
'
The organization and management of the emergency preparedness program were reviewed and discussed with licensee representatives. There were no significant organizational changes in either the plant or corporate emergency planning groups since March 1992. However, there had been several personnel changes in key plant positions. Since the licensee had good depth in the emergency response organization, the changes had j
not significantly....pacted the licensee's ability to respond to a radiological emergency.
l l
l
,
,
i l
.
-
l
The inspector reviewed the licensee's management strategy for ensuring compliance with the Emergency Plan requirements addressing the planning standard of 10 CFR 50.47(b)(2), which specifies that " timely augmentation of response capabilities is available." The applicable requirements were contained in Appendix B of the REP. The plan required the onsite emergency response organization be augmented with additional emergency response personnel within 60 minutes.
In addition to normal-hour staff augmentation drills,- the licensee
,
l conducted two off-hour staff augmentation drills in 1992, in which
'
employees were required to travel to the site and activate ERFs. The licensee demonstrated the ability to augment the emergency response staff and meet the REP objectives in the drills.
However, the licensee identified some problems with the response of radiation protection personnel. The inspector determined the licensee had taken corrective actions to improve the response capabilities of the radiation protection staff. The most realistic test of emergency response organization staff augmentation response is the off-hour drill in which personnel are required to report to the site and activate the ERFs. The licensee's practice of performing such drills annually was considered a program strength.
The inspector determined through discussions and documental reviews that the following NRC Information Notices (ins) applicable to emergency planning were received by the licensee since the aforementioned March 1992 inspection and were distributed to cognizant personnel, and that any appropriate corrective actions identified by
,
the licensee were completed or scheduled-l IN 92-08:
" Revised Protective Action Guidance for Nuclear
-
.
Incidents" j
" Problems Identified With Emergency Ventilation
-
Systems for Near-Site (Within 10 Miles) Emergency Operations Facilities and Technical Support Centers" IN 92-38:
" Implementation Date for the Revision to the EPA
-
Manual of Protective Action Guides and Protective Actions for Nuclear Incidents" IN 93-06:
" Potential Bypass Leakage Paths Around Filters
-
Installed in Ventilation Systems" IN 93-07:
" Classification of Transportation Emergencies"
-
Through interviews with licensee personnel, the inspector determined that the emergency preparedness program appeared to be receiving an appropriate level of management support and commitment.
No violations or deviations were identified.
i l
g
--
- -
pr3rM P-
__
.
-
5.
Training (82701) and Knowledge and Performance of Duties (82206)
This area was inspected to determine whether the licensee's key emergency response personnel were properly trained and understood their emergency responsibilities.
Requirements applicable to this area are contained in 10 CFR 50.47(b)(2) and (15),Section IV.E of Appendix E to 10 CFR Part 50, and Sections 14 and 15 of the REP.
The training program for emergency response organization personnel, as delineated in the REP, was implemented by means of corporate procedure TRN-30, entitled " Radiological Emergency Preparedness Training,"
Rev. 1, dated September 17, 1991. Appendix E to TRN-30 contained a matrix which specified the " subject area elements" for each emergency response organization position at the Sequoyah facility. The inspector conducted a review to determine whether individuals were being trained in accordance with TRN-30. Names of individuals designated for key positions in the emergency response organization were selected on the basis of recent changes in assignment, and their training records were reviewed against TRN-30 requirements. The inspector also reviewed the licensee's training objectives and lesson plans for these key emergency response organization positions.
The training material content appeared appropriate relative to tia need to address the duties and responsibilities of each of the selected positions. The review of training records for the selected individuals revealed that, with one exception, personnel had received training and/or retraining in accordance with applicable requirements.
The exception involved the individual designated as TSC Technical Assessment Manager for the " Blue" Team. This individual, who had previously served as OSC Manager, received Technical Assessment training on June 19, 1992. At that time, his September 1991 training l
for the OSC Manager position was considered to have equivalently l
addressed the other required subject area elements, which were REP i
Overview, TSC Operations, and Offsite Interface. However, training l
for these elements expired on September 30, 1992, based on the requirements for annual retraining as contained in Section 3.11.1 of l
TRN-30.
Licensee review determined that the manner in which emergency response organization training was tracked in a computer-based system was not adequate to identify this particular type of discrepancy.
Failure to have provided emergency response training to an individual in accordance with the requirements of the REP, as implemented by procedure TRN-30, was identified as a violation of the emergency l
preparedness program requirements.
Based upon licensee commitments to timely corrective action (see below), this violation is not being cited because the criteria specified in Section VII.B of the NRC Enforcement Policy (Appendix C to 10 CFR Part 2) were satisfied.
Non-cited Violation (NCV) 50-327, 328/93-07-03:
Failure to provide emergency response training in accordance with applicable requirements.
I
a
,
.
,
.
.
The licensee documented the training problem in a corrective action program.
The issue was documented in a Problem Evaluation Report and l
assigned a tracking number of SQPER930041.
During a meeting on l
February 19, licensee representatives proposed corrective action for the above violation as follows:
(1) change the methodology for
'
computerized tracking of emergency response organization training so that partially expired position training can be identified, and
!
(2) discontinue the practice of waiving requirements for retraining in
" common" subject area elements when an individual is transferred to a different emergency response organization position. The licensee's implementation of these corrective actions will be reviewed for effectiveness during a future inspection.
In an effort to gauge the effectiveness of the emergency response training program, the inspector conducted separate interviews with three (of six) individuals holding the title of Shift Operations Supervisor, the position designated as interim Site Emergency Director. The purpose of this interview process was to ascertain the Shift Operations Supervisor's understanding of emergency classification, offsite notifications and protective action recommendations, site evacuation, emergency worker dose limits, and nondelegable responsibilities of the Site Emergency Director.
Each interview (60-75 minutes in duration) began with technical questions relating to the duties, responsibilities, and functions of the Shift Operations Supervisor during an emergency situation, and then presented six accident scenarios that required event classification and protective action recommendation (PAR) formulation, as appropriate. The inspector delineated the guidelines for the interview at the outset, including the "open book" nature of the evaluation. The Emergency Preparedness Planning Manager was present during each of the interviews to allow for confirmation and firsthand understanding of observations.
Each Shift Operations Supervisor was judged to have demonstrated comprehensive understanding of his duties and responsibilities in the event of an emergency. All emergency classifications and PARS were timely and correct. No problems were identified during these interviews.
>
The inspector reviewed the following licensee exercise and drill reports for the last three quarters of 1992:
Site Emergency Response Organization, Green Team, May 14, 1992
-
Licensee Emergency Response Organization, Green Team, May 20-
-
21, 1992 Table Top Exercise, June 10, 1992
-
Licensee Emergency Response Organization, Green Team, June 18.
-
1992
Annual NRC Observed Exercise, Licensee Emergency Response
-
Organization, Green Team, June 24-25, 1992
- - _ _
l
~\\
l
.
.
.
l
!
Annual Emergency Preparedness Medical Drill - North Park
-
[
Medical Center, August 19, 1992 Post-Accident Sampling, October 7, 1992
-
Annual Emergency Preparedness Medical Drill - Erlanger Medical
-
Center, October 13, 1992 Unannounced Off-Hours, Site Staff Augmentation Drill, Blue
-
l Team, November 19, 1992 Each drill report included a list of objectives, scenario, summary of drill events and critique items. The inspector discussed specific drill findings and determined, through a review of records and interviews with licensee representatives, that improvement areas were identified and corrective actions were taking place.
One NCV and no deviations were identified.
6.
Independent and Internal Reviews / Audits (82701)
This area was inspected to determine whether the licensee had performed an independent audit of the emergency preparedness program, and whether the emergency planning staff had conducted a review of the REP and the EPIPs. Requirements applicable to this area are contained in 10 CFR 50.54(t) and Section 16 of the licensee's REP.
The inspector reviewed documentation of the last annual independent audit of the emergency preparedness program. The audit was conducted by the licensee's Quality Assurance (QA) organization during the period June 8 - July 7, 1993. The review was documented in Audit Report SSA92202, " Emergency Preparedness and Meteorological Monitoring," issued July 31, 1992. The audit examined the emergency response capability for Sequoyah and Browns Ferry nuclear stations and the corporate office. The assessment did not identify any items requiring corrective actions.
The inspector discussed the qualifications of the audit team members with the lead auditor. The inspector determined that the audit teams utilized qualified personnel, including some with emergency planning experience. The qualifications of the team members appeared appropriate for the audit scope. Documentation of the audit results were minimal.
No violations or deviations were identified.
l 7.
Follow-up of Open Items (Closed) IFI 50-327,328/92-20-01:
Review licensee's notification procedures and review measures to improve initial notification times to State and local agencies.
t a
F m
-
.
,
.
The licensee revised the implementing procedures to reduce the Shift Operations Supervisor or Site Emergency Director's effort and time in reporting emergency conditions to the Operations Duty Specialist (Paragraph 3).
8.
Exit Interview t
!
The inspection scope and results were summarized on February 19, 1993, with those persons indicated in Paragraph 1.
The inspector described the areas inspected and discussed in detail the inspection results listed below. Although proprietary information was reviewed during the inspection, none is contained in this report. Dissenting comments i
were not received from the licensee.
l Item Number Description and Reference 50-327, 328/93-07-01 IFI - Review the licensee's procedures, methods and controls for reporting emergency notification information from i
the Site Emergency Director to the Operations Duty Specialist in the time period between TSC and CECC activations i
(Paragraph 2).
i I
50-327,328/93-07-02 IFI - Review licensee efforts to establish
document controls for written descriptions
!
of environmental monitoring locations t
l utilized by environmental monitoring teams (Paragraph 2).
i 50-327, 328/93-07-03 NCV - Failure to provide emergency response training in accordance with applicable requirements (Paragraph 5).
l l
l l
l l
,
\\