ML20039B598
| ML20039B598 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/05/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20039B584 | List: |
| References | |
| 50-259-81-19, 50-260-81-19, 50-296-81-19, NUDOCS 8112230287 | |
| Download: ML20039B598 (5) | |
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i APPENDIX A NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-259, 50-260, 50-296 Browns Ferry 1, 2, 3 License Nos. OPR-33, CPR-52, OPR-68 As a result of the inspection conducted on July 13 to July 24, 1981, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7,1980),
the fc? lowing violation was identified.
Technical Specification 6.3. A.8 requires that written procedures be estab-lished, implemented and maintained covering Site Radiological Emergency Plan implementation.
I Contrary to the above, the Technical Specification requirement for written procedures that implement the Site Radiolegicai Emergency Plan was not met in that:
a.
There was no written procedure for use by the plant's Emergency Offsite Monitoring Team tu provide initial offsite environmental assessment following an accident as required by Section 6.2.2.1 of the Brown's Ferry Site Emergency Plan.
b.
There was no written procedure addressing im'plementation of exercises and drills required by Section 9.2.2 and 9.2.3 of the Brown's Ferry Site Emergency Plan.
This is a Severity Level V Violation (Supplement I),
l Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged viola-tion; (2) the reasons for the violation if admitted; (3) the corractive steps which have been taken and the results achiev vi; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause shown.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
Date:
f l
A 8112230287 8112A -
PDR ADOCK 05000259 I O
PDRi
APPENDIX B ECERGENCY PREPAREDNESS DEFICIENCIES Based on the results of the NRC's appraisal of the Browns Ferry Nuclear Plant Emergency Preparedness Program, conducted July 13-24, 1981, the following deficiencies are identified.
(References are to sectans in 0IE Report No.
50-2E]/81-19; 50-260/81-19; 50-296/81-19).
1.
The Browns Ferry onsite emergency organization had not been specified, in detail, down to the working level, and the functi?nal responsibilities of on-site personnel were net well-defined below the supervisory level. Due to the lack of specific functional responsibility assignments, specific a
training in radiological response had not been provided to all emergency organizational personnel.
This deficiency is discussed in paragrapFs 2.1 and 3.1 of the enclosed report.
2.
In the interim TSC, there was not sufficient work space available for the number of personnel assigned, there was inadequate communication to the control room and offsite centers, and there were no provisions to obtain control room data for analysis by the TSC staff.
This deficiency is discussed in paragraph 4.1.1.2 of the enclosed report.
3.a With regard to the Browns Ferry methods and equipment for monitori.3 and assessing release of radioactive materials to the environment through the plant stack, there was no instrument available t9 monitor high activity releases through the plant stack in order to determine the magnitude of the release. This deficiency is discussed in paragraph 4.2.1.2 of the enclosed report.
3.b The Browns Ferry classification and emergency action level scheme did not provide procedures to relate radiation effluent monitor parameters to site boundary exposure rates in order to properly classify an accident conditica in accordance with Procedure IP-1.
This deficiency is discussed in paragraph 5.4.2 of the enclosed report.
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APPENDIX C APPRAISAL IMPROVEMENT ITEMS Bawd on the results of the NRC's appraisal of the Browns Ferry Nuclear Plant Eiaergency Preparedness Program, conducted July 13-24, 1981, the fellowing items are to be evaluated and considered for improvement. (References are to sections in 0IE Report No. 50-259/81-19; 50-260/81-19; 50-296/81-19).
j 1.
Professional development training through formal courses or seminars in the area of emergency preparedness was.not provided to the Emergency Planning Coordinator to maintain state-of-the art knowledge. (1,0) 2.
An offsite environmental monitoring training program had not been imple-mented to include lectures and walk-through field demonstrations on:
(1) 4 collection and movement of essential radiological equipment and instruments to the dedicated Environmental Van, (2) plume monitoring, (3) dose limitations, (4) communications, (5) rossib?e dose rates from (in) plumes and at pre established monitoring stations, and (6) use of the single channel analyzer for determining I-131 concentrations in the field.
3.
An in plant Browns Ferry health physics training course, for both health physicists and technicians, had not been provided to include lectures and 4
walk-throng' demonstrations covering: (1) possible increases in dose rates n
(on a location-by-location basis), (2) dose limitations and the appropriate supporting dosimeters and instruments applicable to the full range of
)
postulated accidents. (3.1) r l
4.
There were no portable radiation survey instruments located in the emergency i
kits available to OSC personnel, and there were no provisions to make health physics technicians and portable instruments readily available to teams which may be dispatched from the OSC. (4.1.1.3) 5.
BNP-IPD-14 did not specify the procedures to be followed by Health Pnysics personnel in setting up check points at the assembly areas. (4.1.2.1) 6.
Alternate assembly areas were not detignated for. se in the event of high radiation levels e inclement weather at the primary assembly areas.
(4.1.2.1 and 5.4.3.2) 7.
Provisions for decontamination had not been established at a lccation closer to the plant than the Wilson Hydro Plant to accommodate the re-entry of necessary personnel onsite. (4.1.2.3) 8.
The overcrowded TSC will not properly accommodate the relocation of the HP laboratory and associated personnel. (4.1.3) 9.
The Emergency Kit inventory list and procedures did not include silver zeolite for iodine collection. (4.2.1.1) j
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Appendix C 2
10.
The note in E01-12 Section E' allows the radiation monitor to go off scale before operator actions are taken. (4.2.1.2) 11.
There was no " note" in E0I-12 to call Cnemistry for a confirmatory measure-l ment should the stack monitor fail to work, or read off-scale. (4.2.1.2) 12.
The meteorological data recorders in the control room area were not properly maintained (e.g.,iiming) and annotated to facilitate the use of data (e.g.,
wind direction frcm which the wind is blowing and atmospheric stability condidions). Enili.eering units were not used. (4.2.1.4) 13.
The temperature difference measurements a: e recorded on inappropriate recorders; fe, range:
-30 to + 30 C on a 6 inch wide chart. Recorders that allow a user to differentiate among atm; spheric stability conditions; eg, -E C to + 10 C on a 12 inch wide chart, are more appropriate. (4.2.1.4).
a 14.
The emergency communication systems at the Browns Ferry TSC, the MSECC and the CECC are not yet complete. (4.2.3) 15.
BFN-IPD-14 does not reference the applicable Health Physics standard instructions used during postulated emergencies nor the changed provisions i
to assure applicability during an emergency. (5.1) i 16.
The BFN-IPD-1 seismic event criteria did not conform to existing seismic monitoring capabilities nor the operating procedure concerning the 0.2g Action Level criterion. (5.2) l 17.
Guidance was not provided in the notification procedures to maintain the NRC i
ENS line open betwren the control room and the NRC throughout the course of the accident unles: specifically terminated by the NRC. (5,4.1) 4 18.
The action levels and protective action guides did not specify which guides are to be used by assessment personnel to make protective action recommend:
tions. (5.4.2) i
- 19. An overall procedure covering the accident assessment methodology, to include both operational and radiological aspects, was not employed to gather data and to make calculations on which protective action recommenda-i tions are based. (5.4.2) 20.
Emerg:rg/ procedures, training, and instructions for Health Physics personnel defining methods, equipment, communications, and radiation protection guidance for emergency on-site radiological surveys were not available. (5.4.2.2 and 5.4.2.3)
- 21. An accord was not established with the State of Alabama concerning resolu-tion of difference in offsite consequence projections. (5.4.2)
- 22..ALARA dose levels would not be achieved due to the absence of shielding in j
post accident sample collection and transportation. (5.4.3.4) i
Appendix C 3
22.
Procedures were not developed to govern the emergency functions of repair and corrective action teams including team formation, possible operations in high radiation fields, and radiological safety considerations. (5.4.5) 24.
The initiating conditions in BFN-IPD-1 were considered to be ambiguous by the Shift Engineers.
(~i 2) 25.
Implementing procedures and other procedures referred to by Shift Engineers in an erergency such as Special Instructions and Emergency Operating Instructions were not cross referenced. (7.2) 1