ML20003F099
| ML20003F099 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/16/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0654, RTR-NUREG-0737, RTR-NUREG-737, TASK-3.A.1.2, TASK-3.A.2.1, TASK-TM NUDOCS 8104200148 | |
| Download: ML20003F099 (9) | |
Text
TENNESSEE VALLEY AUTHORITY CH AT T ANOOGA. TENNESSEE 37401 USO Chestnut Street Tower II g
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April 16, 1981 h,
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iES Mr. Harold R. Denton, Director C]W Office of Nuclear Reactor Regulation J
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U.S. Nuclear Regulatory Cosmission
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d Dear Mr. Detitont 3
In the Matter of the Application of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 Enclosed is jnformation pertaining to Radiological Emergency Preparedness for Sequoyah Nuclear Plant units 1 and 2.
Encloeum 1 provides the current status of open items identified in the Sequoyah Safety Evaluation Roport. provides TVA's response to NUREG-0737 item III.A.1.2 which was sent to TVA by letter dated February 18, 1981, from D. G. Eisenhut to H. G. Parris. This information was oriSinally cubmitted to the NRC by letter dated March 31, 1981, from L. M. Mills to A. Schwencer. provides TVA responses to NUREG-C737 itean III.A.2 includfug TVA's program for compliance with NURE0-0654 Appendix 2.
The editorial corrections mquested by M. Gaitannis, including, a mvision to the shift menning table, will be incorporated into the Radiological Emergency Plan (REP). Also, any changes which may recult frca the scheduled REP review of May 1981 will be incorporated.
Very truly yours, i
TEICESSEE VALLEY AUTHORITY h
s L. M. Mills, Nanager Nuclear Regulation and Safety Sworn to d subscribed before me s/[ - ' day of_M 1981 t
Nott.ry Public My Commission Expires Enclosures 8104200 N6 no e,oa, onno,1 unity eme, oyer E
ENCLOSURE 1 SEQU0YAH NUCLEAR PLANT UNITS 1 AND 2 STATUS OF OPEN SER ITEMS SER In a letter dated August 5, 1980, TVA has committed to revise the TVA-REP to include a sumary of shif t manning as described above by August 15, 1980.
TVA This comitment was met by letter dated August 15,1980, and is '
included in the reformatted SQN-REP.
SER The NRC staff position is that the pertinent instrument readings, parameters, and equipment status should be specified in the Emergency Plan itself and TVA has committed to revise the TVA-REP to include such information by August 15, 1980 (see letter
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deted August 1, 1980).
TVA This commitment was met by letter dated August 15,1980, and is included in the reformatted SQN-REP.
SER In a letter dated August 1,1980, TVA comits to a prompt notifi-cation system having the design objective capabi'aity to essen-tially complete the initial notification of the public within the plume expsoure pathway EPZ within about 15 minutes. TVA will expedite procurement of a prompt notification system to be installed and operational in accordance with the following estimated dates:
Order equipment (bid award) - Noveniber 15-December 15, 1980 Receive equipment - April 15-May 15,1981 Install equipment - May 15-June 15,1981 (4) Operational - July 1,1981 TVA TVA is on schedule with procurement of equipment and expects the system to be operational on July 1,1981.
(1) Equipment ordered - February 10-February 24, 1981 (2) Expect to receive equipment - April 1-June 1, 1981 (3)
Installation of equipment - April 1-June 15,1981 (4) Operational - July 1,1981 SER In regards to the Emergency Operations Facility, TVA has agreed i
to prey de an interim facility in a letter from L. M. Mills to H. R. Denton, dated July 28, 1980.
The TVA Radiological Emergency Plan will be revised to include a description of this facility.
This revision will include a description of the facility, location, communications, and manning requirements.
TVA The Interim Emergency Operations Facility was addressed in the refonnatted SQN-REP.
SER In letters dated August 1 and 5,1980, TVA comitted to provide an upgraded Technical Support Center at Sequoyah Nuclear Plant
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by December 31, 1981. This facility will have the capability of providing real ~ime meteorological data to offsite locations. TVA has comitted tt provide for the remote interrogation of meteoro-logical data by LAC (at the incident. response center) and other emergency organizations that require it.
TVA The Technical Support Center will be upgraded and operation and the capability for remote interrogation of meteorological data will be available on a schedule consistent with TVA's commitments to NUREG-0737.
SER TVA has provided information on these capabilities in response to NRC letter dated October 30, 1979, relative to the lessons Learned Program designated in NUREG-0578.
TVA will review the Radiological Emergency Plan to reflect these capabilities.
TVA.
No action is required on this item at this time.
SER In a letter dated August 1,1980, TVA has agreed to provide a more detailed writeup of their recovery operations in the next revision of TVA's Emergency Plan, due January 1,1981.
TVA An expanded reco ery operations section was included in the reformatted SQN-REP.
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ENCLOSURE 2 SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 TVA RESPCNSE TO NUREG-0737 ITEM III. A.1.2 1.
UPGRADED EMERGENCY SUPPORT FACILITIES TVA will provide a conceptual design description of the emergency support facilities (TSC, OSC, EOF) to the NRC by June 1, 1981.
Implementation of NUREG-0696 recommendations for the upgraded emergency support facilities required for Sequoyah cannot be complete by October 1, 1981. A preliminary schedule shows that the earliest date the necessary equipment could be delivered to the site is August 1982. Since the construction and installation of the equipment would have to be coordinated
~ with scheduled unit outages, the preliminary schedule shows that an estimated operational date for upgraded emergency support facilities is July 7, 1984. A more specific schedule will be available when the detailed conceptual design has been completed. TVA is investigating comparable alternatives to the NUREG-0696 recommendations which will expedite this schedule. These alternatives will be addressed in the conceptual design submittal by June 1, 1981.
2.
EXISTING EMERGENCY SUPPORT FACILITIES The information provided to the NRC on the response facilities for Sequoyah unit 1 is applicable to unit 2.
This includes the following.
a.
TECHNICAL SUPPORT CENTER (TSC):
A description of the TSC is included in the Sequoyah Nuclear Plant Radiological Emergency Plan.
Location of Technical Support Center The relay room on elevation 732 in the control building is designated as the site technical support center. See the attached figure.
This location was chosen for the following reasons.
t There is sufficient space available to ac?ommodate up to 25 persons.
The habitability system for this area is the same one provided for the main control room. No added equipment is required. The air supplied to the room is filtered by an E3F system, and it is monitored for contaminants. Stay times for this area are the same as for the main control room.
The use of the relay room as the technical support center reduces the cost of providing plant parameter information in the technical support center due to the close proximity of the main control room. This also has the advantage of allowing technical support personnel access to i
plant instrumentation that may not have been considered necessary caring design conception of the technical support center.
The technical support center will have a communications system that will allow it to co=municate with control room personnel; but, should it fail, the close proximity of the two areas allows for continued operation.
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Experience shows that changing the frequency to quarterly will not result in a significant improvement in either data reliability or data availa-bility. During 1979 and 1980, all temperature sensors removed for routine sensor exchange at BFN and SQN were found to be within Regulatory Guide 1.23 or both air temperature and AT.
All wind speed sensors removed for routine sensor exchange during the same period were also found to be within specifications. Ten wind direction sensors were found to be within three degrees of the correct value throughout their range, and four were found to be between three and five degrees of the correct value for part of their range and within three degrees for the remainder. No temperature, wind speed, or wind direction sensors removed for semiannual sensor exchange were found to be defective. Catastrophic failures (e.g.,
lightning strikes) are identified through the normal inspection and validation process, and sensors are replaced expeditiously.,
Backup meteorological data sources are cited in the BFN Radiological Emergency Plan (REP), paragraph 6.2.2.3, subparagraph 2 and in the SQN-REP, paragraph 6.2.2.3, subparagraph 2.
These procedures apply to any pe,riod of data outage. TVA meets the intent of this requirement.
Item 5: An alternate source of meteorological data for use during periods of systems unavailability shall be identified.
TVA Status: Huntsville NWS data are used as the alternate for BFN, and Watts Bar Nuclear Plant data are used for SQN (BFN-REP, paragraph 6.2.2.3, subparagraph 2; SQN-REP, paragraph 6.2.2.3, subparagraph 2).
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TVA is in compliance.
l Item 6: Maintain a site inspection schedule at a frequency no less than weekly.
TVA Status: Site inspections are currently performed at least weekly (BFN and SQN Station Manuals, Chapter 3).
TVA is in compliance.
Item 7:
Failure to meet the unavailability goal of 0.001 on a quarterly basis shall be a reportable occurrence.
TVA Status: TVA currently meets the 90 percent data recoverability goal established by draft Regulatory Guide 1.23 The recoverability of the current system is further increased by retrieving data from analog strip charts located in the environmental data station at each site. We will continue with the present program until definitive guidance is provided.
Regarding the unavailability goal of 0.001 established in the proposed revision to Regulatory Guide 1.23, two indepencent measurement systems, each with a data unavailability of 0.032, would be required in order to attain a combined unavailability of 0.001.
Based upon operating experience, the proposed 0.001 goal would be difficult to meet, even with both a primary and backup system in operation. We believe that the proposed unavailability goal should be changed to 0.01 which would represent a reason-able and attainable goal and would be consistent with NUREG-0696.
Starring of the Technical Support Center The technical support center will be activated in accordance with the Sequoyah Emergency Plan. In the event that the plan is activated during routine work hours for the plant staff, the following employees will report to and make up the technical support center staff.
Reactor Engineer Mechanical Test and Studies Lead Engineer Chemical Engineer Lead Instrument Maintenance Engineer Lead Mechanical Maintenance Engineer Lead Electrical Maintenance Engineer In the event that the plan is activated at other than routine work hours, the Site Emergency Director will make arrangements to staff the technical support center with available onsite personnel or call in offsite personnel.
The technical support center will be manned until the Site Emergency Director determines that it is no longer needed.
Reference Materials The below-listed reference materials will be provided in the TSC.
Sequoyah Nuclear Plant FSAR Sequoyah Nuclear Plant Technical Specifications Surveillance Instructions (selected)
Technical Instructions (selected)
Radiological Control Instructions Hazard Control Instructions System Operating Instructions General Operating Instructions REP Spill Provention Control Plan Plant Functional Drawings Abnormal Operating Instruations Emergency Operating Instructions b.
OPERATIONAL SUPPORT CENTER (OSC): A description of the OSC is included in the Sequoyah Nuclear Plant Radiological Emergency Plan.
The role of the Operational Support Center is to provide an assembly area for operations support employees during an emergency situation.
The locker and lunchroom space in the powerhouse control bay at elevation 732.0 feet is designated for use as the Operational Support Center. The Operational Support Center is provided with PAX telephone communications to the main control room.
c.
EMERGENCY OPERATIONS FACILITY (E0F):
A description of the TVA program of a centralized emergency operations concept and an interim nearsite EOF is included in the Sequoyah Nuclear Plant Radiological Emergency Plan.
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ENCLOSURE 3 SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 TVA RESPONSE TO NUREG-0737 ITEM III. A.2
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An upgraded Radiological Emergency Plan was provided to the NRC on December 31, 1980.
2.
The upgraded Emergency Implementing Procedures Document was provided to the NRC on March 3, 1981.
3 The TVA program for meeting NRC recommendations of NUREG-0654 Appendix 2 includes the following.
Item 1: A meteorological measurem.ents system shall provide basic mete-orological data to the control room.
TVA Status: TVA currently has a primary meteorological measurements system (Browns Ferry [BFN] FSAR, Section 2.3.7; Sequoyah [SQN] FSAR, Section 2.3.3).
Wind speed and direction at various tower levels and temperature differences for the lower to middle and lower to upper layers are provided to the control rooms (BFN FSAR, Section 2.3.7.3; SQN FSAR, Section 2.3.3.3).
TVA is in compliance with this item.
Item 2: An operable dose calculational methodology (DCM)- shall be in use in the control room and at appropriate emergency response facilities.
TVA Status: Detailed dose assessment is performed by the Muscle Shoals Emergency Control Center (MSECC) which is located in Muscle Shoals, Alabama. The MSECC has a response time of 30 minutes from the notification of an emergency,, which is consistent with the response capability identified in Table B-1 of NUREG-0654, Rev. 1.
Additionally, procedures have been integrated into the site emergency classification scheme to provide for protective action recommendations in the event that a General Emergency develops prior to the staffing of the MSECC.
Item 3: Ensure that routine National Weather Service (NWS) meteoro-logical observations and forecasts can be accessed.
TVA Status: The TVA Meteorological Forecast Center routinely receives NWS observations and forecasts (BFN Implementing Procedures Document (IPD),
MSECC IP-7, paragraph 6.3.1; SQN-IPD, MSECC, IP-7, paragraph 6.3.1).
TVA is currently in compliance with this requirement.
Item 4: Calibration of meteorological instruments shall be done at least quarterly and a source of data for use during calibration outages shall be identified.
TVA Status:
Calibration intervals are cited in the BFN and SQN Station bbnuals, Chapter 4.
Currently, calibration is performed on the meteoro-logical system electronics and sof tware at least every 60 days and the wind and temperature sensors are exchanged every 6 months. The 60-day calibration on the wind and temperature instruments consists of putting a simulated signal into the system at the Environmental Data Station signal box and testing the downstream hardware and software.
_3 Additionally, the Nuclear Regulatory Commission (NRC) has not identified the method of calculating data unavailability or the variables to which the goal would apply. We believe that data unavailability should be calculated individually for wind speed at each level, wind direction at each level, and temperature difference for each layer based upon hourly data. Thus, the unavailability will be based upon missing hourly data per quarter.
Item 8: The DCM shall be consistent with the characteristics of the Class A model.
TVA Status: See status for Item 2.
Item 9: Direct telephone access to the person making the offsite dose projections shall be available to the NRC.
TVA Status: Direct telephone access will be available for NRC for communications on the offsite dose projections.
4.
TVA has an adequate primary meteorological measurement system. The TVA Meteorological Forecast Center will continue to use the National Weather Servicc meteorological observations and forecasts as a secondary source of information.
TVA's dose assessment model which is currently in use equals or exceeds the existing NRC recommendations for Class A and Class B models. The TVA model provides estimates of dose rate and cumulative dose, X/Q values, transit times, and plume widths by sector for various distances from the plant.
The model incorporates terrain features within 10 miles of the plant and provides estimates out to 50 miles. It is capable of using actual or forecast meteorological and release data. Upon resolution of minor hardware problems and completion of user training, the model will be available for near real-time execuvion. The model will be run by emergency staff at the Muscle Shoals Emergency Control Center. Initial execution should be within 30-45 minutes of notification of an accident.
5.
The Operational Support Center (OSF) is primarily a staging area.
Technical Support is provided by the Technical Support Canter. Therefore, meteorological information will not be provided to the OSF. Basic meteorological information will be available for use by the Technical Support Center, Emergency Operations Facility, and NRC responsc organizations.
6.
TVA will review the Dose Calculation Methods to ensure consistency with the operational Class A model throughout TVA.
7 See the response to item 4.
8.
See the response to item 4.
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