ML20127F984

Insp Repts 50-327/85-13 & 50-328/85-13 on 850325-29. Violation Noted:Failure to Provide Adequate Training to Shift Engineers in Offsite Protective Action Decisionmaking & Failure to Test Public Notification Sys Per Procedure

ML20127F984
Person / Time
Site:	Sequoyah
Issue date:	04/23/1985
From:	Cline W, Marston R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127F841	List: ML20127F838 ML20127F984
References
50-327-85-13, 50-328-85-13, NUDOCS 8505200625
Download: ML20127F984 (9)

See also: IR 05000327/1985013

Text

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9 Ct!g UNITED STATES

fo,, NUCLEAR REGULATORY COMMISSION

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o REGION il

3* j 101 MARIETTA STREET.N.W.

• ATLANTA. GEORGI A 30323

\...../ MAY 0 31985

Report Nos.: 50-327/85-13 and 50-328/85-13

Licensee: Tennessee Valley Authority

500A Chestnut Street

Chattanooga, TN 37401

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah 1 and 2

Inspection Co eted Marchf5- N 985

Inspector: et /

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Rf R. Marston (06te Signed

Accompanying Per onn . S tt

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Approved by: // /5

E E. Cline, 5ection Chief

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Date S1Qned

Division.of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection involved 69 inspector-hours on site

in the areas of emergency preparedness.

Results: Two violations were identified - failure to provide adequate training

to Shift Engineers in the area of offsite protective action decisionmaking; and

failure to test the Public Notification System at a frequency specified in the

emergency plan.

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8505200625 850503

PDR ADOCK 05000327

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• P. R. Wallace, Plant Manager

R. J. Kitts, Chief, Risk Protection Branch

B. Marks, Supervisor, Emergency Preparedness

• W. S. W11 burn, Technical Services Supervisor

A. Schenk, Supervisor - REP State Programs

D. C. Craven, Plant QA Staff Supervisor

R. L. Moore, Group Head - Plant Evaluation Group

D. W. Cross,.S_hift Engineer _ _ . ..

D. S. Richardson -Shift Engineer

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B. C. Lake, Shift Engineer

• T. H. Youngblood, Project Engineer (REP)

W. E. Webb, Project Engineer

Lt. W. H. Daniel, Security Training Officer

H. Williamson, Project Administrator

M. Brock, Electrical Engineer

D. P. Ormsby, Plant Compliance Staff

D. L. Cowart, Plant QA Staff

Other licensee employees contacted included two technicians, and two

mechanics.

NRC Resident Inspectors

• E. J. Ford

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on March 29, 1985, with

those persons indicated in paragraph 1 above. Enforcement items in

paragraphs 4 and 5 were discussed at that time. The licensee agreed that

the violation discussed in paragraph 5 occurred, but did not agree to the

violation in paragraph 7. The licensee did not identify as proprietary any

of the materials provided to or reviewed by the inspector during the

inspection. A meeting was held in Atlanta at the Regional Office between

Tennessee Valley Authority (TVA) and Regional representatives to discuss

these matters.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

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4. Protective Action Decision-Making (82202) i

Pursuant to 10 CFR 50.47(b)(9) and (10) and 10 CFR Part 50, Appendix E, ,

Section IV.D.3, this area was inspected to determine whether the licensee ,

l had 24-hour per-day capability to assess and analyze emergency conditions '

and make, recommendations to protect the public and onsite workers, and

whether offsite officials had the authority and capability to initiate

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prompt protective action for the public.

The inspector discussed responsibility and authority for protective action

decision-making with licensee representatives and reviewed pertinent

portions of the licensee's emergency plan and procedures. The plan and

procedures clearly assigned responsibility and authority for accident

assessment and protective action decision-making. Interviews with members

of the licensee's emergency organization revealed that these personnel

understood their authorities and responsibilities with respect to accident

assessment and protective action decisionmaking. '

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Walk-throughs were conducted. Problems were noted. See Paragraph 7 for l

details. l

No violations or deviations were identified in this program area.

5. Notification and Communication (82203)

Pursuant to 10 CFR 50.47(b)(5) and (6) and 10 CFR 50, Appendix E,

Section IV.D, this area was inspected to determine whether the licensee was

maintaining a capability for notifying and communicating (in the event of an

emergency) among its own personnel, offsite supporting agencies and

authorities, and the population within the emergency planning zone (EPZ),

The inspector reviewed the licensee's notification procedures; SQN IP-2,

IP-3, IP-4, IP-5 and DNPEC IP-2, IP-3 and IP-5, and appropriate SQN-REP's. .

The procedures were consistent with the emergency classification and

emergency action level scheme used by the licensee. The inspector

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determined that the procedures made provisions for message verification.

The inspector determined by review of applicable procedures and by

discussion with licensee representatives that adequate procedural means

existed for alerting, notifying, and activating emergency response

personnel. The procedures specified when to notify and activate the onsite

emergency organization, corporate support organization, and offsite

agencies. Selected telephone numbers listed in the licensee's procedures

SQN-IP-6, IP-7, IP-10 and the Radiological Emergency Notification Directory

for emergency response support organizations were checked in order to

determine whether the listed numbers were current and correct. No problems

were noted, however a major relocation of TVA personnel was scheduled from

the Knoxville Emergency Center and the Muscle Shoals Emergency Center to

Chattanooga and various reactor sites which could have an impact on

maintaining a current Emergency Notification Directory,

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The content of initial emergency messages was reviewed and discussed with

licensee representatives. The initial messages appeared to meet the

, guidance of NUREG-0654, Sections II.E.3 and II.E.4. Licensee

representatives stated that the format and content of the initial emergency

messages had been reviewed by State and local government authorities.

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The licensee's management control program for the prompt notification system

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was reviewed. According to licensee documentation and discussions with

licensee representatives, the system consisted of 34 fixed sirens, mobile

sirens which included county police vehicles running predetermined routes in

the 5-10 mile EPZ area, and tone-alert radios maintained and activated by

county agencies and placed in stations where there were concentrations of

people. A review of the licensee records verified that the system as

installed was consistent with the description contained in the emergency

plan. Maintenance of the system had been provided for by the licensee. The

inspector reviewed siren test records for the period Augdst' 8,1983, to

March 26, 1985. The records showed that silent tests were not being

conducted every two weeks. The licensee had determined that silent testing

i of the sirens should be included as part of a monthly test which was

conducted by Tennessee Emergency Management Agency (TEMA) to check all

sirens. This testing change had been initiated approximately 7 months prior

to this inspection. The change for silent testing of sirens from two weeks

to a month was not consistent with SQN-REP 7.1.12.2. This constituted a

violation: Failure to Implement the Site Radiological Emergency Plan as

required by Paragraph 6.8.1.e of the Technical Specifications (50-327,

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328/85-13-01). Growl tests were being conducted quarterly, and a full-cycle

test annually as specified in NUREG-0654, Appendix 3.

Communications equipment in the Control Room, Operations Support Center

(OSC), Technical Support Center (TSC), and Chattanooga Emergency Control

Center (CECC) was inspected. Provisions existed for prompt communications

among emergency response organizations, to emergency response personnel, and

to the public. The installed communications systems at the emergency

response facilities were consistent with system descriptions in the

emergency plan and implementing procedures.

The inspector conducted operability checks on selected communications

equipment in the Control Room, TSC, OSC, and CECC. No problems were

observed. The inspector reviewed licensee records for the period

September 7, 1984 to March 5, 1985 which indicated that communications tests

were conducted at the frequencies specified in NUREG-0654,Section II.N.2.a.

Licensee records also revealed that corrective action was taken on problems

identified during communications tests.

Redundancy of offsite and onsite communication links was discussed with

licensee representatives. The inspector verified that the licensee's

primary means of communication was the Bell Telephone Company private lines

and that the licensee had established a backup communications system. The

backup system was augmented by the public address exchange and regular Bell

Telephone system, plant paging and intercom system, and a radio network

system. The inspector requested and observed an unannounced communications

and notification check using the backup system. The inspector noted that

the system operated properly and that the notification message used by the

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licensee representative followed the format prescribed in the licensee's

procedures.

6. Changes to the Emergency Preparedness Program (82204)

Pursuant to 10 CFR 50.47(b)(16), 10 CFR 50.54(q), and 10 CFR 50, Appendix E,

Sections IV and V, this area was reviewed to determine whether changes were

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made to the program since the last routine inspection August 27-30, 1984 and

l to note how these changes affected the overall state of emergency

preparedness.

The inspector discussed the licensee's program for making changes to the

emergency plan and implementing procedures. The inspector reviewed the

licensee's procedure SQN AI-4, " Plant Instructions - Document Control,"

governing review and approval of changes to the plan and procedures. The

inspector verified that changes to the plan and procedure were reviewed and

approved by management. It was also noted that all such changes were

i submitted to NRC within 30 days of the effective date, as required.

Discussions were held with licensee representatives concerning recent

modifications to facilities, equipment, and instrumentation. By review of

selected procedures, the inspector verified that procedural and plan changes

were made to reflect the recent modifications to SQN IP-6, which involved a

March 20, 1985, revision involving Activation and Operation of the TSC,

communication, material and equipment changes and responsibilities of

emergency personnel assigned to the TSC.

The organization and management of the emergency preparedness program were

reviewed. The inspector verified that there had been no significant changes

in the organization or assignment of responsibility for the plant and

corporate emergency planning staffs since the last inspection. The

inspector's discussion with licensee representatives also disclosed that

there had been no significant changes in the organization and staffing of

the offsite support agencies since the last inspection.

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The inspector reviewed the licensee's program for distribution of changes to

the emergency plan and procedures. Document control records for the period

September 1,1984 to March 12, 1985 showed that appropriate personnel and

organizations were sent copies of plan and procedural changes, as required.

No violations or deviations were identified in this program area.

7. Knowledge and Performance of Duties (Training) (82206)

Pursuant to 10 CFR 50.47(b)(15) and 10 CFR Part 50, Appendix E, Section

IV.F this area was inspected to determine whether emergency response

personnel understood their emergency response roles and could perform their

assigned functions.

The inspector reviewed the description (in the emergency plan) of the

training program, training procedures, and selected lesson plans, and

interviewed members of the instructional staff. Based on these reviews and

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interviews, the inspector determined that the licensee had established a

formal emergency training program.

Records of training for key members of the emergency organization for the

period June 1984 to March 1985 were reviewed. The training records revealed

that personnel designated as alternates or given interim responsibilities in

the emergency organization were provided with appropriate training.

According to the training records, the type, amount, and frequency of

training were consistent with approved procedures.

The inspector conducted walk-through evaluations with selected key members

of the emergency organization. During these walk-throughs, individuals were

given various hypothetical sets of emergency conditions and data and asked

to talk through their response as if an emergency actually existed. The

individuals demonstrated familiarity with emergency procedures and

equipment, and no problems were observed in the areas of emergency detection

and classification, and assessment action to include plant conditions.

Walk-through evaluations involving protective action decision-making were

conducted with three Shift Engineers. Personnel interviewed appeared to be

cognizant of appropriate onsite protective measures and aware of the range

of protective action recommendations appropriate to offsite protection.

Personnel had difficulty in making protective action decisions for offsite

protection, however. This appeared to be due to inadequate training. The

protective action decisions made by the Shift Engineers were not always

consistent with Federal guidance and in some cases were not consistent with

each other. The flow chart used in the procedure (Attachment 1, IP-5) made

provisions for decisions based on core and containment status, but not on

offsite radiclogical dose rates or total doses.

It was also noted that the flow chart used by the Muscle Shoals center for

protective action decision-making (MSEC IP-10, Attachment 7) provided for

radiological releases, but was not always consistent with the flow chart

used by the Shift Engineers at Sequoyah. This constitutes a

violation: failure to provide emergency response training to those who may

be called upon to assist in an emergency as required by 10 CFR 50.47(b)(15)

(50-327,328/85-13-02).

This violation and the one in paragraph 5 were discussed with licensee

representatives in the Regional Office on April 11, 1985. The NRC position

on protective action recommendations was explained and problems with the

licensee's program were discussed.

8. Licensee Audits (82210)

Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area was

inspected to determine whether the licenseu had performed an independent

review or audit of the emergency preparedness program.

Records of audits of the program were reviewed. The records showed that

independent audits of the program were conducted by the TVA Plant Evaluation

Group during May - July 1984 and by the Quality Assurance Staff Surveillance

Section during January - February 1985. These audits fulfilled the 12-month

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frequency requirement for such audits. The audit records showed that the

State and local government interfaces were evaluated. Audit . findings and

recommendations were presented to plant and corporate management. A

discussion of past audit reports with licensee representatives indicated

that the licensee complied with the five year retention requirement of such

reports.

Licensee emergency plans and procedures required critiques following

exercises and drills. Licensee documentation showed that critiques were

held following periodic drills as well as the annual exercise. The records

showed that deficiencies were discussed in the critiques, and

recommendations for corrective action were made.

The licensee's program for follow-up action on audit, drill, and exercise

findings was reviewed. Licensee procedures required follow-up on deficient

areas identified during audits, drills, and exercises. The inspector

reviewed licensee records dated July 1984 which indicated that corrective

i action was taken on identified problems, as appropriate. The licensee had

established a tracking system as a management tool in following up on

actions taken in deficient areas.

The annual audit conducted by the Plant Evaluation Group also covered the

Browns Ferry Emergency Preparedness Program.

No violations or deviations were identified in this program area.

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j. -(Closed) IFI 390/84-55-11 and 391/84-43-10, concerning a review of the

ACR by the licensee to determine if additional instrumentation, (such

as. condensate storage tank level, refueling water storage tank level,

etc.) is needed. The licensee has performed ~a review of the ACR

instrumentation and determined that all the instrumentation NRC

considers necessary for alternate or dedicated shutdown (identified in

NRC IE -Information Notice No. 84-09 dated _ February 13, 1984) has not

been provided -in the ACR. The licensee _ has submitted a deviation

request (letter from TVA to NRC dated January 4, 1985) with justifica-

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tion concerning the ACR instrumentation. This inspector followup item

is considered closed.. Followup on resolution of the deviation request

will be tracked by Inspector Followup Item (390/85-29-05), Deviation

From Providing the Required Appendix R Nuclear Instrumentation In the

Auxiliary Control Room.

8. Licensee Identified Items - Construction Deficiency Reports (CDRs)

a. (Closed) CDRs 390/85-09 and 391/85-09, Unqualified Fire Protection

Equipment for the Emergency Gas Treatment System and Auxiliary Building

Gas Treatment Filter Housings. This item was initially reported to_NRC

Region II on January 25, 1935. The final report was submitted on -

February 25, 1985. In this report the TVA indicated that based on a

design review, it was identified that the closed head fire protection

spray nozzles in the Emergency Gas Treatment Filter System (EGTS) were

rated to fuse at a temperature of 175'F. However, air being passed

through this filter could reach 170'F, this design condition does not

provide sufficient margin to provide adequate assurance that the

installed spray nozzles would not inadvertently operate during EGTS

operation. In addition, the smoke detectors installed downstream of

the EGTS and auxiliary building gas treatment system (ABGTS) are

ionization type detectors. These detectors are not qualified for

operation in high radiation areas. Under Work Plans 5480 and 5185 TVA

replaced the 175*F rated spray nozzle in the EGTS and ABGTS with Star

Model E spray nozzles which have a 150' water spray pattern and a

operating temperature setpoint of 286*F. In addition, the' fire

detection system for the EGTS and ABGTS have been modified to perform

an alarm and annunciation function only. The automatic functions

associated with the Fire Protection Deluge Valve, the Fire Pump Start

Circuit and the Filter Fan Shutdown have been changed to manual

actuation. These fire protection design changes have been implemented

through engineering change Notice 5430 and 5588. At the time of this

inspection the installation of the spray nozzles in the EGTS and ABGTS

filter housing was not complete and this item was provided to the

resident inspector for followup.- On April 8, 1985, the resident

inspector verified that the proper spray nozzles had been installed in

the subject filter housing. This item is closed.

b. (Closed) CDRs 390/85-03 and 391/85-03, Failure of Electro Thermal Links

to Function Properly. The subject deficiency was initially reported to

NRC Region II on December 17, 1984. The final report was submitted on

March 15, 1985. In this report TVA indicated that during the initial

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performance of Surveillance Instruction (SI) L601,14 of the 47. fire /

smoke dampers tested under this procedure failed to .close. .It was

determined by TVA and the vendor that some of the dampers failed to

close due to improper installation the Electro Thermal Link'(ETL) which

-resulted in less than 21bs of tension applied to the ETL assembly. . In

addition, it was determined that improper orientation of the S-Hooks

which are used to mount the ETLs and fusible links. to the dampers

contributed,to the failure of the dampers to go closed. TVA analyzed

.the functional requirements of all the dampers included in the scope of

Nonconformance Conformance Reports W-210-P and .W-220-P. This analysis

determined that. 0-XFD-31-74,.168,181, and 182 were not required for

smoke control. These dampers.have been locked.open by removing the ETL

and - replacing -it with aircraft cable. The analysis indicated that

dampers 0-XFD-31-78A, 788, 79, 92A, 928, 159', 233, 234, 235, 236, 237,

238,. 239 and 248 are not required for smoke control however, they are

required for fire control. Therefore,. the ETL have been removed from

these' dampers and replaced with standard fusible links. The inspector

reviewed the modifications to the above dampers and verified that these

modifications had been completed. This item is closed.

c. (Closed) CDR 50-390/85-07 and 50-391/85-06 Emergency Gas Treatment

System (EGTS) Controls Not Qualified to Calculated Radiation Levels.

This item was reported to RII on December 31, 1984, and a final report

' was submitted on February 7,1985. In the EGTS filter housing area the

calculated integrated _ dosage may be on the order of IX10' rads rather

than the 3X10' rads as indicated on environmental drawing 47E235-78.

The licensee relocated replacement controls for - the EGTS on the

opposite side of an outside wall of the room containing the EGTS per

Work Plan 2788. This item is closed.

d .- .(Closed) CDR 50-390/85-08 and 50-391/85-08, Erroneous Radiation Level

'Used on Auxiliary Building Gas Treatment System (ABGTS) Environmental

Drawings. This item was reported to RII.on January 23, 1985, and the

final report was submitted ' on February 25, 1985. The failure to

recognize the significance of the filter as a source of radiation to

equipment in the area or the higher. radiation level for the filter

being inadvertently omitted from environnental drawings were given as

the'causes for the error. A reanalysis was performed resulting in the

heater controls for the ABGTS being relocated to the opposite side of

an outside wall of the gas treatment room per Work Plan 2788. This

item is closed.

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