ML20058B678

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IE Insp Repts 50-327/82-11 & 50-328/82-11 on 820524-28.No Noncompliance Noted.Major Areas Inspected:Followup on Emergency Preparedness Findings
ML20058B678
Person / Time
Site: Sequoyah  
Issue date: 07/02/1982
From: Huffman G, Jenkins G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20058B666 List:
References
50-327-82-11, 50-328-82-11, NUDOCS 8207260103
Download: ML20058B678 (10)


See also: IR 05000327/1982011

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETTA ST., N.W., sulTE 3100

ATLANTA, GEORGIA 30303

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Report Nos. 50-327/82-11 and 50-328/82-11

Licensee: Tennessee Valley Authority

500A Chestnut Street Tower II

Chattanooga, TN 37401

Facility Name:

Sequoyah Nuclear Plant

Docket Nos. 50-327 and 50-328

License Nos. DPR-77 and DPR-79

Inspection at the Sequoyah site near Soddy-Daisy, Tennessee

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G. R. Jenkins, Chief "

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Emergency Preparedness Section

EPOS Division

SUMMARY

Inspection on May 24-28, 1982

Areas Inspected

This routine, unannounced inspection involved 34 inspector-hours on site in the

area of follow-up on emergency preparedness findings.

Results

In the area inspected, no violations or deviations were identified.

8207260103 820702

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REPORT DETAILS

1.

Persons Contacted

Licensee Employees

  • J. McGriff, Assistant Plant Superintendent
  • R. Kitts, Health Physics Supervisor
  • D. Craven, Electrical Maintenance

E. Craigge, Safety Supervisor

L. Nobles, Operations Supervisor

J. Ingwerson, Emergency Planning Supervisor

B. Childs, Health Physics Shift Supervisor

J. Taylor, Chemical Unit Supervisor

W. Watson, Special Projects Maintenance Supervisor

M. Harding, Nuclear Compliance Supervisor

M. Halley, Preoperations Testing Supervisor

T. Crittenden, Security Chief

  • W. Webb, Jr., Project Engineer
  • C. Mills, Nuclear Engineer
  • A. Carver, Nuclear Compliance Engineer

NRC Resident Inspector

E. Ford

  • Attended exit interview

2.

Exit Interview

The inspection scope and findings were summarized on May 28, 1982, with

those persons indicated in paragraph 1 above.

3.

Licensee Action on Previous Inspection Findings

(Closed) Violation (327/80-34-07):

Fire Brigade training.

An inspector

reviewed and verified the corrective actions as stated in TVA's letter of

October 20, 1980.

(Details, Paragraph 6.b)

(Closed) Violation (327/81-20-03, 328/81-24-03):

Inadequate emergency

implementing procedures. An inspector reviewed and verified the corrective

actions as stated in TVA's letter of September 24, 1981.

(Details,

Paragraph 9)

(Closed) Deficiency (327/81-20-12, 328/81-24-12):

Inadequate procedure for

accident classification. An inspector reviewed and verified the corrective

action as stated in TVA's letter of September 24, 1981.

(Details, Para-

graph 10.a)

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(Closed) Deficiency (327/81-20-10, 328/81-24-10): Vent assessment proce-

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dures and monitor. An inspector reviewed and verified the corrective action

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as stated in TVA's letter of September 24, 1981.

(Details, Paragraph 10.a)

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(Closed) Deficiency (327/81-20-01, 328/81-24-01): Assignment of specific

emergency responsibilities. An inspector reviewed and verified the correc-

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tive actions as stated in TVA's letter of September 24, 1981.

(Details,

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Paragraph 5.a)

(Closed) Deficiency (327/81-20-02, 328/81-24-02):

Emergency training

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program. An inspector reviewed and verified the corrective actions as

stated in TVA's letter of September 24, 1981.

(Details, Paragraph 6.a)

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In addition to the above, the inspector reviewed actions taken by the

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licensee on emergency preparedness improvement items as addressed in TVA's

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letter of October 30, 1981. The status of these items is discussed in the

Details of this report.

4.

Unresolved items

Unresolved items were not identified during this inspection.

5.

Onsite Emergency Organization

The inspector evaluated this area of the licensee's program through discus-

sion with licensee representatives and review of Section 4.0 of the Sequoyah

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Radiological Emergency Plan (SQN-REP); SQN-REP Implementing Procedure 6

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(SQN, IP-6), Activation of the Technical Support Center; SQN, IP-7,

Activation of the Operations Support Center; SQN, IP-14, Health Physics

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Procedures; and TI-66, Post Accident Sampling and Analysis Methods.

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a.

The Emergency Plan now provides a clear description of functional

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responsibilities for the emergency organization down to the working

level.

SQN, IP-6 provides procedures for the OSC staff, SQN, IP-14

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defines the functions of the Health Physics group, and TI-66 provides

procedures for the Radio-Chemistry group. No onsite organizational

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chart had been assembled; however, the licensee agreed to complete one

by August 2, 1982.

Based on the above findings, the previously iden-

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tified deficiency in this area (50-327/81-20-01; 50-328/81-24-01) is

closed. The completion of the onsite emergency organization chart will

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be evaluated during a subsequent inspection (50-327, 328/82-11-01).

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b.

The licensee has revised SQN, IP-7 to assign responsibility to the

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Assistant Shift Engineer (ASE) for briefing and dispatching teams from

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the OSC. The Shift Engineer is assigned overall responsibility for the

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operation of the OSC and briefing the ASE. Based on the above find-

ings, the previously identified improvement item (50-327/81-40-02;

50-328/81-49-02) is closed.

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6.

Training

The inspector evaluated this area of the licensee's program through discus-

sion with licensee representatives, review of SQN, IP-19, Radiological

Emergency Plan Training, and review of Administrative Section Instruction

Letters (ASILs), Radiation Control Instructions (RCIs), Health Physics

Section Instruction Letters (HPSILs), Dosimetry and Training Section

Instruction Letters (DSILs), Physical Security Plan Implementing Procedure

13 (PHYSI-13), and selected individual training records.

a.

Emergency Response Personnel

SQN, IP-19 is the basic document for emergency organization training.

This procedure requires that all station personnel who require unes-

corted access to the Sequoyah Nuclear Plant (SNP) must be trained in

the SQN-REP as part of their health physics training. This training is

updated biennially.

Key personnel are also specified in SQN, IP-19 and

they must be trained annually.

In addition, it states that anyone else

with specific emergency response duties must be retrained annually.

Training for all the above must include:

(1) The Radiological Emergency Plan (SQN-REP)

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The Implementing Procedures (SQN-IPs)

(3

The Emergency Management Organization

(4

Communications Systems Familiarization

(5) Emergency Conditions

(6) Emergency Facilities and Equipment

(7) Emergency Preparedness

(8) Recovery

Beyond SQN, IP-19, the specific training tailored to meet the emergency

needs of each group is specified by separate documents and individual-

ized lesson plans.

For example, training for the Site Emergency

Director and his alternates is specified in Administrative Section

Instruction Letter 14 (ASIL-14) and that for Health Physicists is

covered by ASIL-9. The ASILs appear to be the basic training documents

for all training at the site. The lesson plans for each functional

group must be reviewed.

For example, ASIL-9 and ASIL-14 specify what

SQN-IPs must be included in the training for the above groups. ASIL-9

further specifies that all Health Physicists must review and sign off

on a long list of documents semi-annually which bear on their ability

to respond to an emergency. This includes other ASILs, Radiation

Control Instructions (RCIs), Health Physics Section Instruction Letters

(HPSILs), and Dosimetry and Training Section Instruction Letters

(DSILs).

From a review of all of the above mentioned documents, it

appears that the SQN-REP training meets the criteria of NUREG-0654.

To determine if the above training had been provided as required, the

records were checked for several individuals at different levels in the

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Emergency Response Organization. The records were fragmented, but it

appears from the sample that the training and retraining meets the

criteria of NUREG-0654.

Based on the above findings, the previously identified deficiency

(50-327/81-20-02;50-328/81-24-02) and inspector followup items

(50-327/80-34-05; 50-327/80-34-06) in this area are closed.

b.

Fire Brigade Members

To assure compliance with PHYSI-13, the Safety Section reviews the

training of all potential Fire Brigade members quarterly.

In addition,

as the Duty Roster is posted each day, a clerk in the Operations

Supervisor's office and another clerk in the Shift Engineer's office

check the records to assure the personnel assigned to the Fire Brigade

are qualified. Also, on one day, the training records of all five

personnel assigned to the Fire Brigade on that day were reviewed. All

five were qualified by having successfully completed retraining no more

than seven months previously.

Based on the above findings, the pre-

viously identified deficiency in this area (50-327/80-34-07) is closed.

a.

Emergency Operations Facility (E0F)

The inspector discussed this area with licensee representatives and

reviewed pertinent correspondence.

In a letter dated May 1, 1980 from

Mr. L. M. Mills, Manager, Nuclear Radiation and Safety, TVA, to Mr. L.

S. Rubenstein, Acting Chief, Light Water Reactors Branch No. 4, NRC, it.

was proposed that the Central Emergency Control Center (CECC) be used

as an EOF for all TVA sites. The NRC accepted this proposal with

certain specifications, by letter of March 19, 1981 from Mr. D. G.

Eisenhut, Director, Division of Licensing, to Mr. H. G. Parris, Manager

of Power, TVA. Based on the above findings, the previously identified

inspector followup item in this area (50-327/80-34-01) is closed.

b.

Offsite Laboratory Facilities

The inspector discussed this area with licensee representatives. The

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licensee's position is that both the radiochemistry laboratory where

routine analyses are normally processed and the laboratory at the

Training Center are under the Director, Division of Nuclear Power, and

the Training Center Laboratory would be made available in an emergency,

if needed. Based on the above findings, the previously identified

improvement item in this area (50-327/81-20-04; 50-328/81-24-04) is

closed.

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8.

Emergency Communications Equipment

a.

Data Transmission and Handling

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The inspector discussed this area with licensee representatives and

inspected c';mmunications facilities and equipment.

To eliminate problems in transmitting data, times, and dose assessment

information, the licensee has decided to depend solely on computer

Videoterminals (CVs) for the transmission of critical information.

There are from one to three CVs at each emergency facility and they can

be used for the electronic transmission of messages as well as receiv-

ing real-time data readouts from such sources as the meterological

towers.

Each site is also equipped with a digital printer for the

hard-copy recording of any data received via the CVs.

The computer

system supporting the CVs is user-friendly and an operating manual

accompanies the CVs at each location.

Dose assessment data will soon be transmitted via a separate Plume

Tracking and Dose Assessment System which is in place, but not yet

connected for real-time readout from the vent monitors and metero-

logical towers at Sequoyah. When fully operational, dose assessment

data and trend analysis will be immediately available at each location.

In the interim, the data is developed by the MSECC monitoring team and

can be transmitted via the CVs. Reporting units have been standardized

on the new system; however, this system is very sophisticated and can

not be operated by untrained personnel, ever though an operator manual

is kept with the equipment.

To solve the time problem, the licensee has standardized on Central

Daylight Time (CDT) at all emergency facilities.

Each location has a

readily visible clock on CDT and the computers for the above system are

programmed for CDT.

Based on the above findings, the previously identified inspector

followup items for this area (50-327/81-26-03; 50-328/81-33-03 and

50-327/81-26-08; 50-328/81-33-08) are closed,

b.

Emergency Power for NRC Telephones

The inspector discussed this area with licensee representatives,

reviewed records, and inspected the applicable equipment. As per

Workplan No. 9092, emergency power was connected to the NRC ringdown

telephones on April 15, 1981.

Based on the above findings, the IE

Bulletin item for this area (50-327, 328/80-BU-15) is closed.

c.

Alarm audibility

The inspector discussed this area with licensee representatives and

reviewed records of licensee surveys and upgrade conducted since 1979.

Although there was evidence of several surveys being performed, there

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was no indication that all suspect sites, such as the Charging' Pump

Room and Ice Condenser Rooms, had been surveyed.

In addition, there

was no evidence of an additional survey since December 17, 1981, as

agreed to by the licensee (Item 50-327/81-40-06;50-328/81-49-06).

In

response, the licensee agreed to perform another survey.during the

July, 1982 exercise and provide the NRC with their findings and actions

taken to correct any problems by July 16, 1982.

Previously identified

inspector followup items (50-328/81-21-03; 50-327/81-40-06; 50-328/81-

-49-06) and IE Bulletin item (50-327/79-BU-18) remain open.

9.

Implementing Procedures

The inspector evaluated this area through discussion with licensee represen-

tatives, review of Procedures TI-66, MSECC-9, and REPP-15, and inspection of

equipment.

There is no longer a requirement for a procedure for activation and staffing

the nearsite EOF since the need for this facility no longer exists.

The licensee has constructed two carts to transport post accident samples to

the Chemistry Laboratory. Temporary shielding material has also been made

available for use in transporting the samples.

In addition, a pre-

formated, self-sticking label is now provided for post accident samples.

Procedure TI-66 has been revised, and now includes a procedure for high-

activity liquid effluent sampling and makes provision for labeling of post

accident samples.

In addition, TI-66 provides guidance on issuance and use

of dosimetry when taking and processing samples, and provides guidance for

exposures, and designates the Site Emergency Director as responsible for

authorizing exposures above normal limits. A form is provided to be signed

by the Site Emergency Director, specifying the individual and his exposure

limits.

Emergency Offsite Monitoring Teams have been trained in monitoring proce-

dures specified in Procedure MSECC-9, and a Sequoyah Emergency Implementing

Procedure, SQN, IP-20, has been developed based on MSECC-9.

REPP-15, Planning and Conducting Radiological Emergency Exercise, has been

written and the Radiological Emergency Preparedness Appraisal Tracking

System has been established to ensure that the Proce. dure is implemented.

This is a computerized system which publishes printouts once weekly. The

printout lists all licensee and NRC appraisal and audits findings as well as

required actions in support of the REP for each item, the person responsible

for required actions, the date on which the action must be initiated, the

completion deadline, the frequency, the status and references.

Based on the above findings, the previously identified violation in this

area (Item 50-327/81-20-03 and 50-328/81-24-03) is closed.

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10. Assessment Actions

a.

High Range Vent ?!onitor

Overlapping low range and high range monitors are now in place, cali-

brated and operating for both Units 1 and 2.

SQN-IP-1 has been revised

through the addition of pages 32A and 32B so that direct readings from

these monitors result in an immediate classification of an accident

condition based on the monitor readings. Required actions for each

classification are given in SQN-IP-2 through S.

Calculation of the-

offsite dose for initial response and protective action recommendations

is covered by SQN-IP-18.

Based on the above findings, the previously identified deficiencies

(50-327/81-20-10 and 50-328/81-24-10; 50-327/81-20-12 and 50-328/

81-24-12) are closed.

b.

Inplant and Onsite Radiological Surveys

SQN-IP-14 was revised to provide specific guidance for health physics

personnel for each level of accident classification and covers both

in-plant and on-site surveys. This procedure covers methods, equip-

ment, communications and radiation protection guidance under emergency

conditions.

In addition, it covers the issuance of KI, sampling, and

decontamination. Specific procedures and the radiation safety measures

associated with those procedures are provided in TI-66 for all reactor

coolant, containment air and building vent sampling and analysis.

Based on the above findings, the previously identified improvement

items in this area (50-327/81-20-13 and 50-328/81-24-13; 50-327/81-

20-14 and 50-328/81-24-14) are closed.

c.

Offsite Radiological Surveys

Only one Nal detector is designated for sampling during an emergency

and it is calibrated against both the MS-2 scaler in the Health Physics

Laboratory and one on the van.

Efficiency factors for each combination

are provided with the scalers. Calibration is repeated quarterly.

Since there is only one Nal detector specified for field use by the

Health Physics Department, the possibility of mismatched calibration

when equipping the van during an emergency is eliminated.

SQN-IP-17 lists most of the emergency preparedness equipment needed to

support the REP by function and location. Attachment 12 to SQN-IP-17

states that the monitoring station keys are kept at the health physics

laboratory, which was verified during the inspection.

A review of all equipment needed to support offsite, onsite and in-

plant monitoring resulted in the purchase of some equipment, as con-

firmed by a review of documents responding to equipment items in the

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Tracking System (see Section 9.h.).

A review of the equipment lists in

SQN-IP-17 appears to show adequate equipment available. A van is

available at all times.

If a second van or automobile were needed, a

pool exists at the site, from which one could be assigned.

Based on the above findings, the previously identified improvement

items in this area (50-327/81-20-06 and 50-328/81-24-06; 50-327/81-

20-07 and 50-328/81-24-07; 50-327/81-20-08 and 50-328/81-24-08; 50-

327/81-20-11and50-328/81-24-11) are closed.

d.

Offsite Particulate and Radiciodine Monitoring

Procedure SQN, IP-20 covers offsite radiological monitoring with

specific guidance on radiciodine analysis. Specifics on when and why

to use silver zeolite cartridges, along with guidance on sampling in

the rain and the collection efficiency of the cartridges as a function

of flow rate is contained in SQN, IP-14, Health Physics Procedure. The

filter cutter, which is used as part of the radioiodine and particulate

sampling process, originally had long handles and was awkward to use.

It has been replaced with a punch type that appears to be adequate.

Based on the above findings, the previously identified improvement item

(50-327/81-20-09 and 50-328/81-24-09) and inspector followup items

(50-327/81-40-03 and 50-328/81-49-03; 50-327/81-40-04 and 50-328/

81-49-04; 50-327/81-40-05 and 50-328/81-49-05) in this area are closed.

11. Protective Actions

a.

Decontamination

The onsite decontamination facilities are described in SQN-REP-7.1.7.1

with floor plans and the detailed decontamination procedures are in

HPSIL-10.

The approach used is general in nature and is designed to

respond to types and levels of contamination routinely encountered. A

series of decontamination methods are described and should be adequate

for most emergency situations.

The licensee has committed to keeping the door to the decontamination

facility unlocked, and it was found to be unlocked during the inspec-

tion.

In addition, a key is kept in the HP Laboratory about 50 feet

away.

Based on the above findings, the previously identified improvement

items in this area (50-327/81-20-15 and 50-328/81-24-15; 50-327/81-

20-05 and 50-328/81-24-05) are closed.

b.

Evacuation

The owner controlled land outside the Protected Area is under the

control of the Construction Public Safety Department; consequently,

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security guards patrol the area. The area is fenced, entrance is only

by permission and requires that anyone needing access sign in or out.

Section 4.0 of SQN, IP-8 requires that during an evacuation, the names

of personnel leaving the area be checked against the sign in list. Any

persons unaccounted for must be located and evacuated.

Based on the above findings, the previously identified inspector

followup item (50-327/81-26-09 and 50-328/81-33-09) is closed.

12. Drills and Exercises

Section 9.0 of the SQN-REP specifies the types of required drills, who

participates, the frequency and who will critique. REPP-15 assigns the

overall responsibility for developing scenarios and coordinating drills and

exercises to the Manager, Radiological Emergency Planning and Preparedness

Group. He delegates this authority through the Tracking System (see Section

9.), although his group does the followup to assure that the drills and

exercises are conducted as required.

Based on the above findings, the previously identified improvement item in

this area (50-327/81-20-18 and 50-328/81-24-18) is closed.

13. Review of Emergency Plans and Procedures

SQN-REP, Section 10.0 clearly defines the requirements for document control

and review of the REP, who has the responsibility, and how and when to

proceed. The mechanics for accomplishing the task are clearly described in

REPP-5.

Based on the above findings, the previously identified improvement item in

this are (50-327/81-20-16 and 50-328/81-24-16) is closed.

14. Audits of the Emergency Plan

Section 10.0 of the SQN-REP now covers the Emergency Plan, the Emergency

Plan Implementing Procedures, and the implementation of the program. During

the inspection, two current audit reports were reviewed. They appeared to

be both comprehensive and in-depth in nature. The reports reviewed covered

the Emergency Plan, the Implementing Procedures, facilities, equipment and

program implementation.

Based on the above findings, the previously identified improvement item in

this area (50-327/81-20-17 and 328/81-24-17) is closed.

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