ML20127F984
| 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: |
| References | |
| 50-327-85-13, 50-328-85-13, NUDOCS 8505200625 | |
| Download: ML20127F984 (9) | |
See also: IR 05000327/1985013
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARIETTA STREET.N.W.
ATLANTA. GEORGI A 30323
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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
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Inspector:
et
Rf R. Marston
(06te Signed
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Accompanying Per onn
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Approved by:
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E E. Cline, 5ection Chief
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
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8505200625 850503
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
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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)
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Pursuant to 10 CFR 50.47(b)(9) and (10) and 10 CFR Part 50, Appendix E,
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Section IV.D.3, this area was inspected to determine whether the licensee
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had 24-hour per-day capability to assess and analyze emergency conditions
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and make, recommendations to protect the public and onsite workers, and
whether offsite officials had the authority and capability to initiate
prompt protective action for the public.
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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
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details.
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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,
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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
determined that the procedures made provisions for message verification.
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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
Sections
II.E.3
and
II.E.4.
Licensee
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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
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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
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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
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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
made to the program since the last routine inspection August 27-30, 1984 and
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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
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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.
The inspector reviewed the licensee's program for distribution of changes to
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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
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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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-(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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