ML20071H517
| ML20071H517 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/12/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, NUDOCS 8203080444 | |
| Download: ML20071H517 (6) | |
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t' TENNESSEE VALLE;Y AUTHORITY cH ATTA NOOG Al JihN N E$5 bI ol 400 Chestnut Street Tower II I O heb ef b, 1982 g
a U.S. Nuclear Regulatory Commission ED RIAR g3 I982h:
Region II
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- firea, Attn: James P. O'Reilly, Regional Administrator
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Dear Mr. O'Reilly:
y SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II EMERGENCY PREPAREDNESS APPRAISAL 327, 50-328 - RESPONSE TO VIOLATION AND DEFICIENCIES - REVISED FINAL REPORT The subject appraisal dated August 20, 1981 cited TVA with one Severity Level IV Violation and four deficiencies. Our initial response was provided to you on September 24, 1981. A supplemental response was submitted on November 20, 1981 to extend the completion date for revision of the Sequoyah Radiological Emergency Plan (REP) from November 15, 1981 to December 15, 1981. As discussed with D. Quick of your staff in a telephone conversation on February 4, 1982, TVA was unable to complete all corrective actions by the schedule provided in the September 24, 1981 response.
Enclosed are revised responses for the violation (Enclosure 1) and deficiences (Enclosure 2).
If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Regulation and Safety Enclosure cc:
Mr. Richard C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 C203080444 820212 PDR ADOCK 05000327 s ':
-S-PDR OFFICIAL COPY '
w An Equal Opportunity Employer C_
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ENCLOSURE 1 SEQUOYAH NUCLEAR PLANT UNITS
'e AND 2 RESPONSE TO VOLATION REVISED FINAL REPORT Viointfnn Technical Specification 6.8.1 requires that written procedures be -
established, impicmented, and maintained covering Site Radiological Emergency Plan impicmentation.
Contrary to the above, the Technical Specification requirement for written procedures that impicment the Site Radiological Emergency Plan was not met in that:
There was no written procedure covering the activation, staffing, a.
and operation of the Interim Emergency Operations Facility defined in Section 3.1.2.5 of the Sequoyah Site Emergency Plan.
b.
Sequoyah Technical Instruction TI-66, Post Accident Sampling and Analysis Methods, was not implemented in that equipment' required by TI-66 to reduce personnel exposure during post accident sampling 'was not available; also TI-66 was found to be inadequate in that it did not address post accident sampling of high activity liquid effluents.
There was no written procedure for use by the Plant's Emergency c.
Offsite Monitoring Team to provide initial offsite environmental assessment following an accident as required by Section 6.2.2.1 of the Sequoyah Site Emergency Plan.
d.
There was no written procedure addressing implementation of exercises and drills required by Section 9.2.2 and 9.2.3 of the Sequoyah Site Emergency Plan.
This is a Severity Level IV Violation (Supplement I).
Admission or Denial of the Alleced Violation Item a.
TVA admits the violation occurred as stated.
Item b.
TVA denies the violation.
j Item c.
TVA admits the violation occurred as stated.
Item d.
TVA adnits the violation occurred as stated.
Reasons for the Violatinn
. Item a.
An operating procedure for activation, staffing, and-operation of the interim emergency operations facility was in-f draft form at the time of the emergency preparedness appraisal but had not been submitted as a formal change to
.the Sequoyah_ Implementing Procedures Document.
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i ut v Item b.
Tbers are two distinct i ssues in item b.
The first issus deals with O -
equipmsnt ussa solely for obtaining postaccident sampics for analysis.
As discussed in item 4.1.1.7 of the report, all equipment required by the procedure was available except a transport cart for which we believe an acceptable alternative could be nade available. The second issue deals with providing procedures for postaccident sampling of liquid effluents in plant systems before release to the environment.
(See section 4.1.1.8 of the report.)
Concerning the issue of providing ' sole use' equipment, TVA denies the violation occurred as stated.
TVA disagrecs with the finding that implies that because ' sole use' equipment was not available a violation exists.
TVA contends that the equipment would be availabic as discussed with the auditor.
Concerning the issue of postaccident liquid effluent sampling procedures, TVA denies the violation occurred as stated.
TVA disagrees with the report's finding concerning inadequate postaccident sampling procedures for high activity liquid e f fluents. Liquid ef fluents in this violation are those other than in the Reactor Coolant System. TVA cannot find any requirement relating to postaccident sampling of liquid ef fluents in systems other than the Reactor Coolant System in the regulations or guidance previously supplied by the Commission.
Should an incident occur in which auxiliary systems become highly contaminated, any possible release of liquid ef fluents would be very deliberate and require coordination between TVA and other State and Federal agencies.
Since there would be no need to release these liquid effluents to the environment immediately, this planning process may take several days and even months.
Procedures specific to the situation would be developed at that time in conjunction with other authoritics before release of the liquid.
Item c.
It was TVA's intent that offsite monitoring teams would all use the same procedure provided in the Muscle Shoals Emergency Control Center (MSECC) implementing procedures.
The procedures were not included in the emergency response kits for the plant teams as intended.
Item d.
A procedure to provide internal tracking for this and other Radiological Emergency Plan (REP) commitments was in draf t form at the time of the emergency preparedness appraisal but had not been formally implemented.
Corrective Stens Which llave Been Taken and Results Achieved Item a.
As a result of the letter dated March 19, 1981, from D. G.
Eisenhut to II. G. Parris, the interim emergency operations facility is being replaced by the local recovery center as de scribed in our submittal to H. R. Denton dated June 2, 1981 The Sequoyah Radiological Emergency Plan is being-revised to reflect this change, m
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.O 3 of 3 Item b. ~TVA intends to provide " sole use" equipment as recommended by the auditor. This was provided on November 15, 1981.
Item c.
The procedure (MSECC-IPD, IP-9) has been placed in each emergency response kit at Sequoyah.
Item d.
A procedure for informing each plant of commitments and required" performance dates has been developed. The tracking form was provided for NRC inspection. TVA contends that this tracking system will provide adequate notice to the plant of necessary drills and exercises. The radiological emergency planning I
coordinator has been designated at each plant to provide coordination for commitments involving the plant.
Corrective Steps Which Will Be Taken To Avoid Further Violations Item a.
The local recovery center will not be staffed by TVA as part of the emergency response and therefore requires no procedures.
Item c.
A controlled copy of the MSECC-IPD which contains IP-9, Terrestrial Environmental Sampling Procedures has been assigned to the emergency response van and will be maintained in the van.
Additionally, specific portions of IP-9 which apply to site
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boundary monitoring performed by the plant staff will be incorporated into SQN IP-14, Health Physics Procedure. Additional equipment required by IP-9 will be provided in the Sequoyah emergency response kits. Training will be provided on these procedures.
Item d.
The procedure has been issued for information and has been_ brought up to date on commitments. For every commitment made in the REP, the tracking system will alert the responsible organization 6-12
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If performance
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Date When Full Compliance Will Be Achieved Item a.
Full compliance was achieved on November 15, 1981.
Item c.
Full compliance was achieved on February 5, 1982.
Incorporation of the new procedure was completed on February 5,1982 and necessary training was completed on February 2, 1982.
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D ENCLOSURE 2 SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 RESPONSE TO DEFICIENCIES REVISED FINAL REPORT 1.
Assessment Actions Deficiency 50-327/81-20-12,328/81-24-12 The planning standard in 10 CFR 50.47(b)(4) require-that a standard classification and emergency action level scheme, which includes facility and effluent parameters, be in use by the licensee.
The Sequoyah classification and emergency action level scheme was determined to be deficient in that there were no procedures available to relate radiation effluent monitor parameters to site boundary exposure rates in order to properly classify an accident condition in accordance with Procedure IP-1.
Deficiency 50-327/81-20-10.328/81-24-10 Itc planning standard in 10 CFR 50.47(b)(9) requires that adequate methods, systems, and equipment for assersing and monitoring actual or potential off site consequences of a radiological emergency condition are in use by the licensee.
The Sequoyah methods and equipment for assessing and monitoring release of radioactive materials to the environment were determined to be deficient in that there was no procedure availabic to relate the Unit I high range Shield Building Vent Monitor to release rates of radioactive materials in order to assess offsite consequences of such releases, and there was no high range Shield Building Vent Monitor, nor procedure, provided for Unit 2 to assess releases of radioactive materials in an accident.
2.
Emergency Organization Deficiencies 50-327/81-20-01,02:328/81-24-01,02 The planning standard of 10 CFR 50.47(b)(2) requires, in part, that the onshift facility licensee responsibilities for emergency response be unambiguously defined; 10 CFR 50, Appendix E, paragraph IV.A. requires, in part, that the onsite plant staff cmergency response assignment be described in detail; and, the planning standard of 10 CFR 50.47(b)(15) requires that radiological emergency response training be provided to those expected to assist in an emergency.
The Sequoyah onsite organization for coping with. emergencies is described in Section 4.0 of the Radiological Emergency Plan and Implementing Procedures IP-6 and IP-7.
Training for the onsite emergency organization is addressed in Section 9.0 of the l
Radiological Emergency Plan.
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4 The Sequoyah onsite emergency organization was determined to be deficient in that the organization had not been specified, in detail, down to the working level and the functional responsibilities of onsite personnel were not well defined below the supervisory level. Due to the lack of specific functional responsibility assignments, specific training in radiological response had not been provided to all emergency organization personnel.
Stens Which llave Been Taken Item 1.
The sun-IPD, I-1, Emergency Classification Logic, has been changed to provide for the classification of emergencies based upon radiological effluents. The procedure also provides the capability to estimate site boundary exposure rates based upon radiological ef fluents and worst case meteorology. The procedure utilizes the high-and low-range shield building vent monitors for both units. The unit 2 high-range shield building vent monitor has been installed and is fully operational.
Item 2.
TVA is comparing Sequoyah REP, Table 1, with NUREG 0654, Section IIB, Table B-1, to determine which specific functional responsibilities should be delegated down to the working level.
P Stens Which Will Be Taken Item 1.
This is a completed item.
L Item 2.
Upon determination of specific responsibilities that should
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j be delegated, TVA will make appropriate changes to the Sequoyah REP and plant procedures. Training in the specific j
responsibilities will be provided to assigned personnel.
Schedule for Comnietion of Actions for Each Item Item 1.
This is a completed item.
Item 2.
Required changes to the Sequoyah REP and plant procedures as well as additional training were completed on February 5, 1982.
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