ML20205P019
| ML20205P019 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/09/1987 |
| From: | Decker T, Kreh J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205N883 | List: |
| References | |
| 50-327-87-10, 50-328-87-10, IEB-79-18, NUDOCS 8704030158 | |
| Download: ML20205P019 (7) | |
See also: IR 05000327/1987010
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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 STREET,N.W.
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ATI.ANTA, GEORGI A 30323
MAR 181987
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Report Nos.: 50-327/87-10 and 50-328/87-10.
Licensee:. Tennessee: Valley Authority
6N38 A Lookout' Place
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1101 Market Street
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Chattanooga, TN 37402-2801
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Docket Nos.: 50-327 and 50-328-
. License No'.: -DPR-77~and DPR-79'
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Facility Name: Sequoyah Nuclear Plant.
Inspection-Condtlcted: February 23-27, 1987
Inspector:
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Approved by: I
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T. R. Decker, Chief
Date Signed
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Emergency Preparedness Section
Division of Radiation Safety and Safeguards
SUMMARY
Scope:
This routine, unannounced inspection involved review and evaluation of
the licensee's emergency preparedness program.
Results:
One violation was identified involving an inadequacy 'in the-
radiological emergency response training program for licensed operators.
No
deviations were identified.
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8704030158 870318
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ADOCK 05000327
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REPORT DETAILS-
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1.
Persons Contacted
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Licensee Employees
- H. L. Abercrombie, Site Director
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- L. M. Nobles, Acting Plant Manager
- M. R. Harding, Site Licensing Manager
- H. B. Rankin, Project Manager
- T. H. Youngblood, Emergency Preparedness Program Manager:(Site).
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- H. R. Rogers, Supervisor, Plant Reporting
- D. E._ Crawley, Radiological Field Operations Manager.
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- F. C. Mashburn, Compliance Licensing Engineer-
- B. K. Marks,- Supervisor, ~ Emergency ' Preparedness (Corporate)
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- R. J. Kitts, Chief, Emergency Preparedness Branch (Corporate):
J. L. Laney, Site Training Supervisor
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D. P. Ormsby, Nuclear Engineer
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0. S. Richardson, Shift Engineer-
H. J. Ricks, Shift Engineer
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H. D. Thomas, Assistant Shift Engineer
W. E. McQueen, Instrument Foreman
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NRC Resident Inspectors
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K. M. Jenison
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- D. P. Loveless
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- Attended exit interview
2.
Exit Interview
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The inspection scope and findings were summarized .on. February 27, 1987,
with- those persons indicated in Paragraph 1 above.
The : inspector-
discussed in detail the violation described below in Paragraph 6 (failure
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to provide adequate training for licensed operators in the area of ~
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emergency classification).
Licensee management representatives took
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exception to this finding.
The licensee did not identify as proprietary
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any of the materials provided to or reviewed by the inspector.during this
inspection.
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3.
Licensee Action on Previous. Enforcement Matters
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This subject was not addressed in the inspection.
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4.
Emergency Detection and Classification (82201)
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Pursuantto10CFR50.47(b)(4)andSections.IV.BandIV.CofAppendixEto-
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10 CFR Part 50, this program area was inspected to determine whether the
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licensee used and understood a'. standard emergency classification and
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action level scheme.
The inspector. reviewed the licensee's classification procedure (IP-1,
" Emergency Plan Classification Logic").
The event classificotions in the
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procedure were consistent with those required by regulation.
Selected
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emergency--action levels (EALs) delineated .in Appendix A ot- the.
Radiological Emergency Plan (REP) were reviewed.
The reviewed .EALs-
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appeared -to be consistent with the initiating events specifiet in-
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Appendix 1 of-NUREG-0654.
The inspector noted that some of the EALs were
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based on parameters obtainable from Control -Room instrumentation.
The
classification logic -for certain of ~ the event categories _ in IP-1. lacked-
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the detailed criteria found in REP Appendix A.
However, a note on Page 2
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of IP-1 informed the user that REP Appendix A contained " additional-
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information or detail related to emergency classifications or emergency
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action levels." When used in appropriate conjunction with REP Appendix A,
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IP-1 did not appear to contain impediments or errors which could lead to
incorrect or untimely classification.
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The inspector verified that the licensee's notification procedures (IP-2,
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-4, and -5) included criteria for initiation of offsite notifications
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and for development of protective action recommendations.
The
notification procedures required that offsite notifications be made
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promptly after declaration of an emergency.
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The inspector discussed with licensee representatives the coordination of-
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EALs with State officials.
Licensee documentation confirmed that
officials of the Tennessee Emergency Management Agency had reviewed the-
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EALs during July 1986, and that these officials agreed with the. EALs used
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by the licensee.
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The responsibility and authority for classification of emergency events
and initiation of emergency actian were prescribed in licensee procedures
and in the REP.
Interviews with selected key members of the licensee's
emergency organization revealed that these personnel understood their'
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responsibilities and authorities in relation to accident classification,
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notification, and protective action recommendations.
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Walk-through evaluations involving accident classification problems'.were
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conducted with two Shift Engineers and one Assistant Shift Engineer. -
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Several discrepancies were revealed during discussion of the hypothetical
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accident situations with these individuals.
One of these problems was
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identified as a violation of training requirements and is discussed below
in Paragraph 6.
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Another problem was identified during the course of walking through. an
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accident scenario involving an earthquake which exceeded the safe-shutdown
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earthquake (SSE).
There was an annunciator in the Control Room (window 29
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or 30 on XA-55-158) for an earthquake that exceeds 1/2 SSE, and such an
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event would be straightforward 1y classified as an Alert in accordance with
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IP-1, Page 16 (Revision 10).
If an earthquake exceeds the SSE, the
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classification would be Site Area Emergency.
However, there was no
annunciator in the Control Room for an earthquake exceeding the SSE.
In
order to promptly determine whether the SSE had been exceeded, someone
would have to be dispatched to the Unit 1 Auxiliary Instrument Room to
check panel XR-52-86 on console 0-R-113 (seismic monitoring system).
Although IP-1 contained the appropriate criteria for classifying an
earthquake, the procedure was not, on the evidence of the walk-throughs,
sufficiently explicit or directive regarding the need to check XR-52-86 to
either confirm or rule out that the SSE had been exceeded if the Control
Room annunciators indicate that an earthquake exceeded 1/2 SSE.
Correct
classification would require this action.
Instruction A01-9 for
earthquake response was silent on this matter.
The inspector discussed
with licensee representatives the desirability of incorporating directives
or procedural steps, as discussed above, into IP-1 and/or A01-9 to address
the absence of a Control Room annunciator for indicating that an
earthquake has exceeded the SSE.
Licensee management representatives
committed during the exit interview to correct the problem.
Inspector Follow-up Item (50-327, 50-328/87-10-01):
Adding a requirement
in IP-1 and/or A01-9 to check panel XR-52-86 if an earthquake exceeds
1/2 SSE.
No violations or deviations were identified.
5.
ProtectiveActionDecision-Making (82202)
Pursuant to 10 CFR 50.47(b)(9) and (10) and Section IV.D.3 of Appendix E
to 10 CFR Part 50, this area was inspected to determine whether the
licensee had 24-hour-per-day capability to assess and analyze emergency
conditions and make recommendations to protect the public and onsite
workers.
The inspector discussed responsibility and authority for protective action
decision-making with licensee representatives and reviemJ pertinent
portions of the REP and its implementing procedures.
The Plan and
procedures clearly assigned responsibility and authority for accideat
assessment and protective action decision-making.
Interviews with members
of the licensee's emergency organization showed that these personnel
understood their authorities and responsibilities with respect to accident
assessment and protective action decision-making.
Walk-through evaluations involving protective action decision-making were
conducted with two Shift Engineers and one Assistant Shift Engineer, all
of whom appeared to be cognizant of appropriate onsite protective measures
and aware of the range of protective action recommendations appropriate to
offsite protection.
Personnel interviewed were aware of the need for
timeliness in making initial protective action recommendations to offsite
officials through the Operations Duty Specialist.
Interviewees
demonstrated adequate understanding of the requirement that protective
action recommendations be based on core condition and containment status
even if no release is in progress.
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No violations or deviations were identified.
6.
Knowledge and Performance of Duties (Training) (82206)
Pursuant to 10 CFR 50.47(b)(15) and Section IV.F of Appendix E to
10 CFR Part 50, 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 REP and AI-14) of the
training program, training procedures, and selected lesson plans, and
interviewed members of the instructional staff.
Based on these reviews
and 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 December 1985 to December 1986 were reviewed. The training records
revealed that personnel designated as alternates or given interim respon-
sibilities 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 three 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 the response they would make if such an emergency actually
existed.
The individuals generally demonstrated familiarity with
emergency procedures and equipment, and no problems were' observed in the
area of protective action decision-making. However, a significant problem
was observed in the area of emergency classification.
Two of the three
interviewees were unable to properly classify an accident scenario
involving a high and increasing containment radiation level, high and
increasing incore thermocouple readings, high letdown radiation level, and
significant hydrogen concentration in containment.
Although the
interviewees recognized that the given plant parameters indicated core
damage, they experienced trouble relating those parameters to the
classification flowchart for fuel damage accidents (IP-1, Page 27,
Revision 9).
The correct classification of this scenario was Site Area
Emergency, based on the specific EALs in Section A.1.3.2 (Revision 22) of
REP Appendix A.
In order to derive this classification solely from the
referenced flowchart, a determination had to be made that there existed a
" degraded core with possible loss of coolable geometry." Only one of the
three interviewees (the Assistant Shift Engineer) correctly judged that
this condition was consistent with the given parameters and that a Site
Area Emergency classification was appropriate; the two Shift Engineers
classified the situation as an Alert.
In spite of the IP-1 reference to
REP Appendix A (see Paragraph 4 above), none of the interviewees sought
additional guidance from the EALs contained therein.
The inspector
concluded that the training of the interviewees did not include
appropriate emphasis upon use of the EALs in REP Appendix A when suitable
classification criteria could not be located in IP-1.
This was considered
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- an inadequacy 'in the radiological emergency response training _ program with
respect to the -requirements of 10 CFR 50.47(b)(15).
Violation (50-327, 50-328/87-10-02):
Inadequate training for licensed-
operators regarding use of REP _ Appendix A as a supplement to.IP-1.
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One violation and no deviations were identified. -
7.
LicenseeAudits(82210)
Pursuant to 10 CFR 50.47(b)(14) and (16) and 10 CFR 50.54(t), this area
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was inspected - to determine whether the-_. licensee - had performed - an
independent review or audit of the emergency preparedness program.
Records of audits of the program were reviewed.
The records showed that
an independent audit of the program was conducted by - the- licensee's
Division of Nuclear Quality Assurance from June 2,1986, to July 25, 1986,
and was documented in Audit Report QSS-A-86-0015, dated August 22,.1986.
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This audit fulfilled the 12-month frequency requirement for such audits.
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The audit ' records showed that the State and local government interfaces
were evaluated.
Audit findings and recommendations were presented to.
plant and corporate management.
Licensee emergency plans and procedures required- critiques following
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exercises and drills.
The inspector reviewed records' of ~ PASS
[postaccident sampling system] drills conducted on~ May 15. May 28, and
June 18, 1986, and a medical drill with Erlanger Medical Center on_ May 22,
1986. The records showed that critiques were held following those drills,
that deficiencies were discussed in the critiques, and that
recommendations for corrective action were made.
The licensee's program for follow-up action on audit, drill, and exercise
findings was reviewed.
The inspector reviewed licensee records for'the
PASS drills and medical drill cited above and for the February 1985
exercise which indicated that corrective action was taken on identified
problems, as appropriate.
The inspector also reviewed the licensee's
November 1986 exercise critique summary, which included - proposed
corrective actions and associated completion schedules' for problems
identified by NRC and TVA.
The licensee had established a Management
Action Tracking System as a management tool in following up on actions
taken in deficient areas.
No violations or deviations were identified.
8.
InspectorFollow-up(92701)
a.
(Closed) Inspector Follow-up Item (IFI) 50-327, 50-328/85-41-02:
Consider high-noise interference with evacuation alarms.
This item
concerns verification of the licensee's corrective actions in
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response to IE Bulletin No. 79-18.
Such verification is being
tracked by IFI 50-327, 50-328/86-03-01 (see Paragraph 8.c below).
b.
-(Closed) IFI 50-327, 50-328/85-41-03:
Perform survey of audibility
of emergency alarms in high-noise areas. _ .This item essentially
duplicates the one discussed above in Paragraph 8.a, and is~ closed on
the same basis,
c.
(0 pen) IFI 50-327, 50-328/86-03-01:
Evaluate licensee's system test
to determine effectiveness of modifications made in response to
Verification tests cannot be performed until
the plant once again achieves full-power operation with the
associated ambient noise levels.
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