ML18029A672
| ML18029A672 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry |
| Issue date: | 06/21/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8507110674 | |
| Download: ML18029A672 (7) | |
Text
TENNESSEE VALLEYAUTHORlTY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II Jgy@
June 21, 1985
> ng.'z~
U.S. Nuclear Regulatory Commission Region II ATTN:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NM, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
BROWNS FERRY AR PLANT UNITS 1, 2, AND 3 NRC-OIE REGION II INSPECTION REPORT 50-259/ 5-23, 0-260/85-23, 50-296/85 RESPONSE TO VIOLATION Enclosed i.s our response to R.
D. Walker's May 21, 1985 letter to H.
G. Parris transmitting IE Inspection Report Nos. 50-259/85-23, 50-260/85-23, and 50-296/85-23 for our Browns Ferry Nuclear Plant which cited TVA with one Severity Level IV Violation.
On June 20, 1985, Bob Alsup of my staff and Floyd Cantrell of your staff discussed an extension to June 27, 1985 for responding to the violation.
If you have any questions, please get in touch with R.
E. Alsup at FTS 858-2725.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY J. A. Domer, Chief Nuclear Licensing Branch Enclosure cc:
Mr. James Taylor, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.
20555 85D7ii0674 85Dh21 PDR AMCK O5DOOa59 e
PDR'n Equal Opportunity Employer
I jl W
W <<
P Il WW, III l, v
I I
I W
I W jl W WW jh
<<I V lW V
ll.
II I
W<<
W
~
WVC W
I l
V V
X4 wv "WW v,,f 'j<<W V
V
)
I, I
W
~
V l1
<<P W ~
W li<<I j<<W l h
l ji'l II, W 'l l j WW
~,,
I W
I<<<<
I I
+W<< IW%A 4
ENCLOSURE
RESPONSE
NRC INSPECTION REPORT NOS.
50-259/85-23, 50-260/85-23, AND 50-296/85-23 ROGER D. WALKER'S LETTER TO H. G.
PARRIS DATED MAY 21, 1985 Enclosure Item 1
10 CFR 50.54(q) requires that nuclear power reactor licensees follow and maintain in effect emergency plans which meet the requirements of Appendix E-to 10 CFR 50 and the planning standards of 50.47(B).
10 CFR 50.47(b)(15) requires that those who may be called on to assist in an emergency be provided radiological emergency response training.
Section 4.l.l of the Browns Ferry Nuclear Plant Radiological Emergency Plan states, in part, that it is the responsibility of the Site Emergency Director to initially make recommendations for protective actions to State and local agencies if necessary.
Section 4.1 of the Plan states that the Shift Engineer on duty may be designated the Site Emergency Director and acts for him until relieved.
Contrary to the above, Shift Engineers'erformance during walkthrough interviews indicated that emergency response training was inadequate in the area of protective action decisionmaking.
Specifically, the Shift Engineers were not capable of consistently determining when and what type of protective action recommendations wer e appropriate to protect the health and safety of the public.
This is a Severity Level IV violation (Supplement VIII).
l.
Admission or Denial of the Alle ed Violation TVA admits that a violation occurred with the following clarification.
The violation was not the consequence of inadequate training of shift engineers in their duties as site emergency directors.
TVA does admit that its Protective Action Guide (PAG) differed from the specific guidance contained in NUREG 0654.
This procedural content difference, not adequate training, caused the apparent inconsistency of shift engineer response.
The shift engineers followed a procedure which did not address two of the problems posed in the walk-through interview.
Therefore, there was no possibility of a consistent response.
2.
Reasons For the Violation TVA's PAG did not cover all the specific situations postulated by NUREG 0654.
~
i),
Page 2
Item 1 (continued) 3.
Corrective Ste s Which Have Been Taken and Results Achieved A revised PAG recommendation has been prepared and discussed with NRC Region II REP personnel.
This revised PAG will be incorporated in the BFN-REP Implementing Procedures Document (IPD).
All personnel designated as potential site emergency directors will be thoroughly trained in the use of the revised PAG prior to its incorporation in the BFN-REP-IPD.
Corrective Ste s Which Will Be Taken to Avoid Further Violations The steps of No.
3 in conjunction with the established periodic REP retraining will prevent futur e violations.
5.
Date When Full Com liance Will Be Achieved All personnel designated to serve as site emergency directors will receive training by July 10, 1985.
The new PAG will be implemented by July 10, 1985.
BROWNS FERRY RADI L EMERGENCY PREPAREDNESS AUDIT SHI INEER WALKTHROUGH PROTECTIVE ACTION RECOMMENDATIONS APRIL 17, 1985 L
~
PROBLFM NO.
Shift Engineer General Energency No Date'/14t/~
Loss of Control of the Plant I
2 Building Re(ease 3.4x10 uCI/sec.
Stack Release 1.8x10 uCi/sec 3
4 CnFp,Melt bo Significant Fission Prod.
in Contain=ant No Release Likely Core Melt Significant Fission Prod.
in Contain ent No Release Likely Core Melt Fission Prod in Conrain No Release Izninent Core Melt Fission Prod.
in Contain.
I Release Inninent EPA Action Cuidc Problen 10 I
EPA Acticn Guide
'roblen I
3 2
'tandby for
'econnenda-
- r. ions I
3 1
Standby to Evacuate 3
3 I
3
=D 3
\\
r I
~ '
1y.