ML20236L951
| ML20236L951 | |
| Person / Time | |
|---|---|
| Issue date: | 07/17/1986 |
| From: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20236L758 | List: |
| References | |
| FOIA-87-531, RTR-NUREG-1198 NUDOCS 8711110143 | |
| Download: ML20236L951 (66) | |
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MEMORANNN FOR: Victor Stello, Jr. . Executive Director for Operations *' i FROM: John C. Davis, Director Office of Nuclear Material Safety and Safeguards
SUBJECT:
STAFF RESPONSES TO THE RECOMMENDATION)!S MADE BY THE ' SEQUOYAH ACCIDENT LESSONS LEARNED GROUP (Wi! REG-1199) 1
- The Office of Huclear Material Safety and Safeguards has developed, in l
coordination with the Office of Inspection and Enforcement, the'0ffice of Nuclear Regulatory Research, the Office of the General Counsel, the Office
-- for Analysis and Evaluation of Operational Data, and the Office of Public
- Affairs, its response to the Seouoyah Lessons Learned Group Peport recom-riendations. A draft of our response is provided in the attachment for your .
. " ' review prior to the July 18 briefing on this subject. We found.the renort to contain constructive recommendations fqr improvements that will be
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considered for the licensing and insoection programs for fuel cycle and w:aterials licensees. As you will see in the attachment, the staff are in I 1C-- ' agrfenent with the intent of these recommendations, and our actions to ~ implement them are either underway, planned, or will be considered as part of . formal rulemaking proceedings. Actions on those recommendations requirino changes tn the regulatory framework will be started following their enordi-nation with the, recommendations of the Materials Safety Regulation Review Study Group. In developing our response to each of the. recommendations, we considered , e actions that should be taken: 1) for the restart of the Seouoyah Fuels
. facility; ?) -to make near term improvements; and 3) to improve the regulator 7 framework. Our actions.for the first two. areas are scheduled and underway. y
- Tentative schedules have' been established for the improvements to the regulatory framework, and our success in meeting these schedules will depend on our ability to apply the required resources, which are largely unbudgeted.
Our actions to identify and implernent further improvements to our licensing and inspection programs will be identified in ' afew months. In addition to our current activities; we expect the 0! investigation ' report of certain aspects of the accidentfand,the OGC legal opinion on NRC jurisdiction over l chemical hazards to both be issued by the end of August, and the report of i the Materials Safety Regulation Review Study Group to be issued in tg fall. l l I I
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f Recommendations in tNse' issuances will be combined with our current efforts ! to prepare 'a complete picture of the adequacy of the- existing licensing and !
'trispection. programs to fulfill, NRC's legal requirements and protect; workeys, l public health and safety, and the environment. v . -l
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' We intend, in the meantime, to pubitsh a modified version of the draft i attachment to this memorandum as 'an . appendix -to the Lessons Learned Group j Report. This will occur in August. l
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.j STAFF RESPONSES TO THE RECOMMENDATIONS ~i MADE BY THE SEQUOYAH ACCIDENT ,
LESSONS LEARNED GROUP IN NUREG-1198 i
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-! l STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS i INTRODUCTION. .
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.On January 4,1986, an accident occurred at tha Sequoyah Fuels Corporation uranium hexafluoride production facility in Gore, Oklahoma, tidtNesulted in .
the death of one plant worker and injuries to several others. The U.S. Nuclear: , Regulatory Commission review of the causes of the accident, the respcnses to , the accident, the effects of the accident on public health, safety, and the l environment, and corrective actions to prevent similar accidents from happening i have been extensive, and are continuing. l4 One component of the NRC_'s review of this accident'has been to identify actions that NRC and its licensees might reasonably take to improvo protection of the ( public health and safety. On February 20, 1966; the Acting Executive Director j
, For Operations formed a Lessons Learned Group to prepare a report based on i % ' experience gained from this accident. The goal of the Lessons Learned Group }
was to identify actions !<RC might reasonably take from a licensing and inspec- { tion' standpoint to prevent similar accidents, as 'well as to clarify NRC's ! regulatory role.regarding facilities of this type. A further goal was to . l r .. assess the adequacy of the NRC response to the accident.as well as the follow- { on. activities. ] The observations and recommendations of the Lessons Learned Groap were published I N- -- - in NUREG-1198, " Release of UFs From A Ruptured Model 48Y Cylinder At Sequoyal'(
. Fuels Corporation Facility: Lessons Learned Report," June 1986. The staff have completed their consideration.of the 58 recommendations mad 2 in this ,
j report, and a response to each is provided in this Appendix. i
. The resource's necessary to implement many of the recommendations are unbudgeted. l Therefore, the staff's ability to implement these-recommendations, particularly 1 those related to changes' in the regulatory framework,' will depend on the ability to reprogram budgeted resources in a way which does'not compromise th'e 7t public health and safety. Schedules may be adjusted depending on the avail . j ability of resources, and additional recommendations such as those expected i {
from the Materials Safety Regulation Ra'iew v Study Groupiwhich may have { recommendations of higher priority. !
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STAFF RESPONSES TO THE SEQUOYAH ACCIDENT'l.ESCONS LEARNED' GROUP RECOMMENDATIONS t I iSECTION: '2.1. RECOMMENDATION #1- (Ref: 1) Pressure-sensing instrumentation should be connected to UFs cyliffders and cold
- t. raps any time heat is applied to them. Heat should not be applied to UF,. ,
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' cylinders or cold traps unless-there is verification that'a vent' ath is open-
. - to the. associated pressure-sensing instrumentation. The pressIr sensing
-Instrumentation should provide both alarm and. visual display. functions.
F 95scussion: The licensing, staff agree that this.. recommendation should be implesanted,'and
', will take the . actions necessary to incorporate this recommendation-in our J
, license requiremsats.;
Pressure-sensing instruments were not present'when the overfilled UFe cylinder
. .wes heated ~at Sequoyah-Fuels on January 4. Had this type of instrumentation' Lt. heen present and monitored, the overpressure condition could have been
[___ recognized and heating-terminated before pressures reachedithe rupture peint. 4 for the' cylinder. 13 . Apprnch:- -
- The licensing, staff has required Sequoyah Fuels Corporation to provide pressbre instrumentation for cylinders being heated in steam chests and -to make a
- p* commitment to have such equipment operational .before heating a cylinder. '-
.i Tastrumentation-of this type 'is already present on' the cold traps, i
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- The ' staff will survey other licensees using similar processes:and provide
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. recommendations and requirements as necessary. 'I
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'The appropriate regulatory documents will be revised to incorporate this
, requirement. .i
'M Schedule: 4 l Requirements' to be in piece for Sequoyah Fuels Corporation at the time of j restart completion: 8/29/86. , A combination inspection and survey of other ! licensees will:be completed by 3/31/87.' Following this, appropriate changes
'im' license requirements will be initiated by 6/1/87. Appropriate revisions to the regulatory framework (e.g. , rulemaking, guidance documents, inspection i modules, etc.) are projected for completion by 12/31/88. !
) . - Resource Reauirementsi : Restart Review
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ri 4: Other projects delayed indefinitely during' review for Sequcyth. 43acklogL
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74., JSTAFF RESPONSES 70 THE SEQUOYAH' ACCIDENT LESSONS LEARNED GROUP REC 0 EMENDATIONS [' ag .. SECTIONI 2l .1' . REcomENDATIM s2 (Ref: 2) V Provisions should be made for overpressure relief or automaticNat termina- ' 1 l x U Qtion upon 'overpressurization any time heat is applied to UF, cy1DGrs or
. celd traps. . ,,
Discussion: o ,- The licensing staff agree with this recommendat. ion ~as-an automatic. safeguard .j agal'nst overpressure consequences and will take the actions necessary to - 1 incorporate'this recommendation in our license requirements;: 1 l Many licensees alrea@ provide such sy' stems.,for UF. heating, and such a system i was part of the design submitted by Sequoyah Fuels for.the new depleted UF. to l UF4 conversl6n facility. Sequoyah Fuels,has indicated that overpressure relief. I and automatic hiat'ternitiation.will be provided as part of modifications te the :d
# conversion plant made since the January 4,1986 accident . . .
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, -Approach: -)
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- -E i The licensing staff has required.Sequoyah Fuels Corporation to provide such interlocks as part of the equipment modifications made prior to restart. This 1 requirement willibe made part of the license and inspected against during the "
restart inspection.. 1-
,The staff will survey other licensees using similar processes and will provide recommendations and requirements as appropriate.
The appropriate regulatory documents will be revised to-incorporate this
. requirement.
Schedule: ' s Y
# Requirements to be in place.for Sequoyah Fuels Corporation at' the time of -
restart completion: 8/29/86. A combination inspection and survey of other ' licensees will be completed by 3/31/87. ~ Following this,' appropriate changes in license requirements _will be initiated by 6/1/87. AppropH ate revisions to l i the regulatory framework (e.g. , rulemaking, guidance documents, inspection' modules, etc.) are projected for completion by 12/31/88.
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'. SECTION:' 2;1.4 RECO MENDATION #3
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' Theiuse of a'utocla'ves for heating UFe cylinders:should be'evaludgstin terms of providing aa additio,nal margin of, safety.
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Thel licensing staff agrees with this> recommendation. . { s The' staff have
'and.autoclavest.not'evoluated the relative merits of atmospheric' steam chests:
for heating UF. cylinders,; but believes such a 4 comparison to1be
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, " Members of WSS staff visited DOE's gaseous diffusion plant at Paducah, Kentucky,
- to evaluate their UF, handling procedures including their use'~of autoclaves.'
e_ 'Most-of the autoclaves at Paducah are low pressure units that would not have a-i . m* . - p .
. contained the. cylinder that' ruptured at.Sequoyah. '
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.The staff is requesting that'Alli_ed Chemical evaluate the use of autoclaves .vs. .- !
atmospheric steam chests and provide the ~ staff,their justification for choosing-one .over the other. Sequoyah Fuels is currently performing this evaluation. . A-siellar evaluation will-be requested .of other licensees handling UFe that do L. C not presently use autoclaves. These licensees include: General ~ Electric, . Wilmington,' N.C. ; Exxon Nuclear, Richland,' Wash.; Com'oustion Engineering, Hematite..MO. ; and Nuclear Fuel Services, Erwin.4 Tenn. Westinghouse Electric,
- Columbia l S.C. uses autoclaves.- Following the licensing. staff's assessment of the evaluations received from the licensees, it will issue a report of its findings as to whether autoclaves provide.a.n additional margin of safety.
Revisions to the appropriate regulatory' documents.will be considered at that 4 n_ . time. l: jchedule: , Send letter Response Evaluate Response
- Allied 07/31/86 10/18/86 01/18/87 other licensees 09/01/86 1/31/87 04/30/87 !
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1 w k I 2 4 SECTIONi 2.2. : RECOMMENDATION #1' (Ref: 4)
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At 1 east two separate means should be utilized for determining t4Lauantity 'of 4 ' UFs loaded. into cylinders or cold: tra;is before applying heat to them. "Real- '
. time" quantification ' methods are preferred, such as load cells; techanical a scales, or. flow integration. Alarms should be associated with thi quantiff' cation 1 4 asethods. -
Discussion: * - j' '
.The licensing ' taff agree with this recommendation and will take the actions-s 3
-T necessary to incorporate this recommendation'in our-license requirements. .
s . i Staff were working,with licensees to' upgrade capabilities in this' area prior'to - the Sequnyah Fuels accident. Allied Chemical:has'provided three methods for the independent determination 'of the quantity of. UFa loaded inte ~ cylinders.
'These are: flow totalizers Land two separate independent scales. . As a part of >
," the restart modifications, Sequoyah Fuels Corporation installed. duplicate.c
* . Independent _ load cells 'at the cylinder filling station.. Scales provide alar,m capability and automatic' termination of filling when total weight is reached.
~; " Aseroacht -
The licen' sing staff will require that' independent methods'of measurement be in
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.D" place and operational as part of. its review of Sequoyah Fuels Corporation '
request for restart. The staf.f will also survey other licensees using similar processes and provide recommendations and requirements as necessary. The - appropriate regulatory documents will be revised to incorporate this.-
, requirement. '
Schedule:
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l Requirements to be in place for Sequoyah Fuels _ Corporation at the time of' . i m- ' . restart completion: 8/29/86. A combination inspection and survey of sother
. 4 licensees will be completed by 3/31/87. Following this, appropriate changes [ ]
in license requirements will be initiated by 6/1/87. Appropriate: revisions to the regulatory framework (e.g. , rolemaking, guidance documents, inspection modules', etc.) are projected for completion by 12/31/88. L . , d j l l y e l l , 5 4
STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDA'TION SECTION: 2.2. RECOMMENDATION #2,_ (Ref: 5) Licenseesshouldberequiredto'establishmaximumfilllimitsfo(cylindersand
, cold traps bm ed on suitable standards. ,
-Discussion; The licensing staff agree with the recommendation and will take the actions necessary to incorporate this recommendation in our license requirements.
' Maximum fill limits for cylinders have been developed.and implemented as part ,
r of the voluntary compliance with ANSI standards. ~ Criteria may be found in i
" ORO-651. . Sequoyah Fuels Corporation and Allied Chemical have voluntarily established such limits on the basis of ANSI fill limits for cylinders for shipment. 'The Department.o? Transportation has undertaken rulemaking to irx:orporate these limits into its regulations for transport'.of. cylinders- . The i staff initiated contact with DOT shortly after the January 4 accident.
,, Approach:
r- The, licensing staff as part'of-' license reviews, will determine that licensees
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' have established limits as part of the procedures which are required by license.
The staff will request' that the Regions inspect for the presence'of these limits during ~routice inspection of facilities. r, ..
." The staff will survey other licensees using similar processes and provide recommendations and requirements as necessary. , The appropriate regulatory documents will be revised to incorporate this requirement.
~ S, chedule:
Review of Sequoyah' Fuels Corporation:i 8/29/86 Review of Allied Chemical: . Complete ' I Survey of other licensees: 10/31/86 P Revise regulatory framewerk: 12/31/88 , ,
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SECTION: 2.3. RECOMMENDATION #1 (Ref: 6b t 'N
- Movement of' filled,- heated .UFs cylinders should be minimized. The use of , '
combination filling, weighing, heating, and sampling stations should be , evaluated for the Sequoyah facility.' -
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'Diseussion: '
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The licensing staff agree with this recommendation and will take the actions- '
- necessary to incorporate this recommendation in our license requirements.
The staff were investigating th'e movement o' f heated UFe cylinders with'
' licensees prior to the January 4, 1986; incident. Requirements were placed on the licenses of both Allied Chemical and Sequoyah FuelsLto investigate the Lhandling of cy,linders. In , response, Allied has now modified all stations to allow' filling, weighing, heating, and sampling at one location without movement.
l Sequoyah Fuels has modified its stations to provide s'ampling without heating.
- - - Approach:
" License Condition No.'11 for Sequoyah Fuels Corporation required an evaluation
, , . of' liquid UF cylinder filling,and handling. Staff will review anti act upon the informat on submitted as part of restart.
I'" 'TO staff will survey other licensees using similar processes' an'd provide recommendations :and requirements as necessary. The appropriate regulatory documents'will b4r revised to incorporate this requirement. Schedule: Requirements to be in place for Sequoyah Fuels Corporation at the time of restart. completion: 8/29/86. A combination inspection and survey of other H; licensees will be completed by 3/31/87. . Following this, appropriate changes y in. license requirements will be initiated .by 6/1/87. Appropriate revisions i the regulatory framework (e.g. . rulemaking, guidance documents. inspection , t,o ,
, modules,' etc.) are. projected for completion by 12/31/88.
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o. STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP _ RECOMMENDATIONS SECTION: 2.3. RECOMMENDATION #2 (Ref: _7)
-e A requirement, generally analogous to 10 CFR 50.'59 should be estaMished reqUlring that certain NMSS. licensed facilities perform engineering evaluations of proposed design changes to ensure that overall siftty
, margins would not be compromised by the, proposed changes. ,
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., Discussion: , i The 'staf f- agrees with this recommendation. '
-i n . Approach: .
The Office of Nuclear' Reg'ulatory Research has been requested to prepare.a rule .; change to Parts 30, 40,' and 70 to include wording similar-to Part 50.59. t , _ . . . Schedule. ,
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STAFFRESPONSESTOTHESEQUOYAHACCIDEkTLESSONSLEARNEDGROUPRECOMMEb , SECTION: 2.4. ' RECOMMENDATION #1 (Ref: 8) Overfilled UFs cylindersior filled cylinders which are found'to bt Aefective should be evacuated without increasing cylinder internal pressure above
, atmospheric and preferably without application of heat. ,e.
Disciassion: . The licensirig staff agree with this recommendation and will take the actions ' necessary to incorporate this recommendation'in our license requirements. ,
;i Allied Chemical and Sequoyah Fuels Corporation have committed to not heating i
. overfilled cylinders. These licensees are currently investigating methods for removal'of UFs from cylindersi including the feasibility of installirig improved vacuum systems. While heating should be minimized or avoided, however, it
" remains a demonstrated method of UFs removal which is considered satisfactory
- when the liquid contents of the cylinder are less than cylinder capacity and ,
1 appropriate pressure sensing and venting equipment are installed and operational. 7 Approach: - The licensing staff will. require as part of the Sequoyah. restart authorization, that heat not be applied to overfilled _ cylindars. The staff will survey other t ; licensees using siellar processes and' provide recommendations and requirements 1
, T~. " as necessary. The appropriate regulatory documents will be revise'd to incorporate this requirement.
, Schedule 1 l
Requirements to be in place for Sequoyah Fuels Corporation at the time of restart completion: 8/29/86. A combination inspection and survey of other , l
. licensees will be completed by 3/31/87. Following this, appropriate changes ,
, c. in license requirements will be initiated by 6/1/87. Appropriate revisions to !
the regulatory frameWo'rk (e.g. , rulemaking, guidance documents, inspection _ f l modules, etc.) are projected for completion by' 12/31/88. l 8 i i L t I
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' ';", , . ?The. frequency of. hydrostatic testing of UF6 cylinders specified 11 ANSI.- J m N14.1-1982 should be reevaluated to resolve the differences in tseatment of 'l Jespty and filled cylinders.,. +
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l Staff' agrees with this recommendation. To address the evident prob 1'em wit . the ANSI standard,' staff have commented on DOT's proposed ammendment_ to' thel
/r . Hazardous Materials Regulations fer transporting Uranium Hexafluoride (Docket '
No. IW-166V; Notice No. 86-2).- This response, dated June-16, 198S' highlights ; + NRC's concern over.the " exemption" of the ANSI 5 year testing. standard given ' to filled. cylinders and. suggests that this issue,be, reevaluated for the final amendment package.- , i e.
' Approach' .
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. ' Staff does not 'bslieve any . specific actions related to this recommendation !
j are required for the Sequoyah restart. - i
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The DOT /NRC Memoranda,of Understanding (44 FR 38690, pubitsbed 7/2/79)' gives l DOT responsibility for' development of safety standards for design and_ j performance of LSA material packages. Staff will recunsider,any further acti.ons
't- ' (sith DOT coordination) after publication of DOT's above r'eferenced amendment 'l
- package.
At this ' time, staff doe's not foresee' any aedions *which -should be taken to l improve the regulatory framework with relation to this recommendation. ' ' a Schedule: J
,_, DOT Notice of Proposed Rulemaking 4/11/86 ,
NRC comment substttal 6/16/86 .- DOT acknowledgment of receipt of.coseents - 6/19/86
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, Comments cutoff date 7/01/86 i Next DOT action Fall 86 l Resource Requirements:
I None Impacts of Reprogramming Resource: '
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STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP REcom ENDATIONS i
'SECTIOH: 2.5. RE_C0%FNDATION#1 (Ref: 10)
Instrumentation for detecting UFe releases should be utilized in. Areas of < potential airborne UFs relaases and in conjunction with steam heating to detect UFs released to' the steam conde; late. = eL. . , Discussion: The' licensing staff agree,'and will take the actions necessary to incorporate I this recommendation in our Itcense requirements. Allied Chemicai and Sequoyah Fuels have invest'igated the detection i capabilities and reliability of UFs detectors. UFs detection in condensate is a design feature provided by Sequoyah Fuels in the proposed' depleted UFs to
, UF4 conversion facility.
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UFe in air rapidly hydrolyzes to 00 F2 resulting in a dense white vapor. Visual W detection is possible for very small quantities of material. However, automdtic j detection capabilities are important to prevent reliance upon human observation )
, and to detect' problems in unattended areas. '
l The licensing staff. ano Regl' on IV have otiserved.during inspection, that Sequoyah Fuels has. installed UFe, HF, and F detectors. 4
.E' Aiproach:
j The staff will request that licensees provide information on detection capabilities , I and will provide recommendations and requirements as necessary based upon' e review. The appropriate regulatory documents will be revised'to incorporate this requirement, i ! o.- I Schedule 2 ,f j Requirements to be in place for Sequoyah Fuels Corporation at tha time of I
, 'testart i completion: 8/29/86. A combination inspection and survey of othe'r
]
licensees will be completed by 3/31/87. Following this, appropriate changes
- in license requirements will be ~1nitiated by 6/1/87. Appropriate revi.sions to i
-the regulatory framework (e.g.i rulemaking, guidance documents, inspection modules, etc.) are proje:ted for co6pletion by 12/31/88.
1 Resource Requirements 2 3
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J , STAFF RESPONSES:TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP REC 0 m ENDATIONS
~
SECTION: 17.5 RECOMMENDATION #26 (Ref: 11) The instrumentation for detecting UF6 releases should provide alarm and/or , iautomatic protection functions (for example; containment, emergency ventilation, or effluent cleanup), e ' Discussion: The* licensing staff agrees, and will take the actions necessary to incorporate - this recommendation in our license requirements. " Automatic detectinn and alarm capabilities are necessary to provide,early warning of squipment problems aid health hazards without dependence'on human observation. ' j h ach: ,
, e ,
~
Tha staff will, as part of actions taken for f.he previous recommendation ' (Ref:-10)' determine that protection functior.s are available with'UF, detectio*n
- system. Recommendations and requirements will be provided as necessary. The
-" appropriate regulatory documents wili> be reviseo to incorporate this > -
, requirement. '
)
Schedule:
~
t" ' , ' Requirements. to be in place for'Sequoyah Fuels Corporation at the time of , , restart completion: 8/29/86. A combination inspection and survey of other < licensees will be completed by_3/31/87. Following'this, appropriate changes ,
' in license requirements will be initiated by 6/1/87. Appropriate revisions to ;
the regalatory framework (e.g. , rulemaking, guidance documents, inspection
. ' -' modules, etc.) are projected for completion by 12/31/88.'
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STAFF RESPONSES-TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP REC 0tHENDATIONS 1 SECTION: 3.1.'_1 RECOMMENDATION 11 (Re'f: 12) ' 1 The individuals responsible for development, maintenance, updat45 and imple-mentation,of the contingency plan should be clearly identified at-both 'the corporate and site levels. , Discussion: J It has been tho, licensing staff's policy to have as part of the license : an identification of responsible positions within the management of the licensee. ' In the revised contingency p1'an for Sequoyah Fuels the Emergency Coordinator , , t of the Sequoyah Facility is . responsible for the development and implementation of the plan und implementing procedures. The Contingency Preparedness Coordinator periodically reviews and' updates the plan and~ implementing s procedures. The Sequoyah Facility Manager, has final authority. for onsite 1 response matters and the General Manager,' Sequoyah Fuels Operations, for }
... corporate response matters. ,
]
~
7 This rscommendatfon' applies to all fuel cycle and matertal licensees who have r.., a radiological contingency plan. l
' l
_ Approach: i I
- w. The staff will consider this and any additional recommendations made in this '- i
.P' area as part of the ongoing emergency preparedness rulemaking, for fuel cycle.
and.other radioactive material, licensees. Other regulatory documents will be
, revised.as appropriate, following issuance of the final rule. l Schedule:
l 1 The tsview for the Sequoyah Fuels restart will be completed by 8/29/86. l O- .' The final rule is scheduled to 60 issued in taid-1987. . e , . - e ; The update of the radiological contingency plan's for the' other licensees will I be performed in accordance with the schedule provided in the final rule.. l Appropriate revisions to the regulatory framework are projected for completion by 12/31/88. o D 13
UMN , STAFF RESPONSES.TO,THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS SECTION: 3. I'.1. RECOMMENDATION #2 (Ref: 13) '- Audits of contingency plan implementation sho01d be conducted by,. individuals not having direct implementation responsibility, and the audits shpyld include > evaluation of the' appropriateness of the ' plan, procedures, facilfties, equipment , l (including location of facilities and equipment), training andspatriodic exercises l- in the spectrum,of accidents or emergencies possible at the facility. Discussion: The revised Sequoyah contingency plan is subject to quari.erly audits directed L by the Director, Regulatory Compliance of the Environmental and Health l Management Division, Kerr-McGee Corporation. The Sequoyah Facility is audited to evaluate and verify adherence to the contingency plan and implementing procedure s. <
. _~ 'This recommendation. applies to all fuel cycle and mai.orial licensees who'have a radiological contingency plan.
lw Approach: *
~
The staff will consider this and any additional recommendations made in this area as part of the ongoing emergency preparedness rulemaking for' fuel cycle and other radioactive material licensees. Other regulatory documents will be
. rsyised as appropriate, following issuance of the final rule. '
p .- Schedule: , , 1
~
The' final rule is scheduled to be issued in mid-1987. The update of other !' licensee contingency plans will be performed in accordance withithe schedule l previded in the final rule. Resource Requirements: r, >
;. 1/2 man year s
_ l Impacts of Reproarammina Resource: , . , None l 3 ( b I
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I 1 ' 7 SECTION: - 3.1.2. RECOMMENDATION #1 (Ref: 14) nD 1* AIsys ematicitrain'ing program should be established to famil_1,ari S all plant' personnel with the general contents.of the contingency plan anet repriate + < m
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response' actions.M Specific training should 'be 'provided ,to< indiv vals (toth ' ' a site and corporate) who might be' assigned specific response fun *c ns'andt N responsibilities. ' s ' Discussion:' +
- 4. -
i The current Sequoyah facility. training program is designed to train,all facility 1 l
. personnel, members of the onsite contingency response organization, 'andi ,
corporate personnel., with, radiation and chemical safety? plant' operations, and the contingency plan emergency procedures-and implementing procedures. The ' extent of contingency plan. training is dependent upon,the job' function a'nd ~ i,, emergency response responsibilities ,
;-; , +
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+
This recommendation applies 1to all fuel' cycle and matefial Llicensees.that have-a 'radioingidal contingency plan. , . ;
.( Approach:: _ ,
~~ '
The staff will consider this and any additional recommendations made in this- 'i
. area as part of the ongoing emergency. preparedness rulemaking for fuel cycle
; g_- 'and other radioactive naterial licensees. Other riegulatory documents will be-revised as appropriate, following issuance of the final rule.
' Schedule:
. . i 1 ;
.. The final- rule is scheduled to be issued in mid-1987. '
.d
> The updat!e of other licensee contingency plans will be performed-in accordance '
.. with the ' schedule provided in the final rule.- ~
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--1/2 man year '
Impacts of Reprogramming Resource:' f
'None' s 1 .
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' SECTION: 3.'1. 2. RECOMMENDA. TION #2 (Ref: '15) , ,
r ( i .g, l0ffsite organizations who cight be requested to support an emergency response
,, should be invited to-attend training specific to the response expected. ,
i
, . , , c v Discussion: 3 .q ** L . -
I JThe staff' generally agree with this recommendation. Emergency exerciser may -'- 1 m include di ntt' participation by those offsite organizations that would respond '
. to the site to help mitigate' the accident, i.e. , police and fire, and'the- ' .,;
, exercise should test communications with other offsite emergency organizations.- >
1~ These other eganizations would be expected to implement generic emergency q plans during.on incident, n 6 S'equcyah Fuels Corporation has as part of the revision of'its Contingency Plan-briefed and provided training to' local officials, the media, and potential -
-; flocal response groups ruch as police, civil defense offices, the county health -
. departments, and cooperating hospitals. .,
This recommendation applies to all fuel cycle and material licensees that have ' c N a radiological 1 Contingency plan.
~
g ,,. j
- Approach:
T~ ,. The licensing staff will ensure that appropriate cooperative training is provIded
- as'part of its review of the revised Contingency- '
Plan for.Sequoyoh Fuels which j was submitted on May 27, 1986. The staff will cor. sider this and any additional recommendations made in this +
," , area as part of the ongoing emergency preparedness rulemaking for fuel' cycle. a and other radioactive material licensees. Other regulatory documents will be' revised as ' appropriate, following issuance of the final rule. '
a_' Schedule: e
~
r ? . Implementation of this recommendation for Sequoyah Fuels will be included in the restart decision; 8/29/86. The final rule is scheduled to be issued in mid-1987. j l j L The update of other licensee contingency plans will be performed'i'n accordance j with the schedule provided in the final rule. i 1 ls 4 s h>, l 'e. . l l 16 I i
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' STAFF RESPONSES TO' THE. SEQUOYkH' ACCIDENT LESSONS LEARNED G x +
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'SECTION: ' 3. i. 3. RECOMMENDATION #1
' l 3
(Ref: $6)
^ '-
- Drills and exercises, involving substantial. Staff- response to a' spectrum of ,
simulated emergency ' situations should be conducted periodically. .Jhe ' simulated - I eventi should be-based on prepared scenarios to demonstrate .spectfic objectives, 3
'and they should be observed and critiqued by qualified personnel L .Any deficie:-- '
cies observed should be evaluated and responsibility for corrective action: assigned and followed. .,
.s '
- i w ,, Disc' ussion: , a
, l i . .
. +
Sequoyah Fuels will conduct periodic drills and exercises to test, develop,'
.rnd maintain skills in emergency contingency response. Exercises-will be. '
* " formal detailed scenarios, using observation and control personnel.: <
Post-exercise critiques will be conducted, deficiencies identified, and remedial action responsibility assigned.
~ ~ ~ '~ oThis recommendation applies to all fudi cycle and materials . licensees that hhve
a radiological contingency plan. '
/
a j i
,-- ; ., . Approach: 1 2 . ..
The. staff will consider this and any additional recommendations' made in'this d
,; area. as part of the ongoing emergency preparedness rulemaking for_ fuel cycle
-Y and other radioactive material licensees. Other regulatory documents will bel
- revised as appropriate, following issuance'of the final' rule.,
. Schedule:
, Ttie final hule is scheduled to be issued in mid-1987.
The update of other licensee contingency plans ' will be performed in accordance- ' with the schedule provided in'the final rule. i- , . D- -
\
5- Resource Requirements: [
+
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1/2 man. year,
' 1 Impacts of Reprogrammir;u Resource: ,
)
None
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7 STAFF RESPONSES TO THE SEQUOYAH ACCIDENTL LESSONS LEARNED GROUP RECOP94EleATIONS - r
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'SECTION: i3 .1.3.W RECOMMENDATION #2 (Ref: 17) a ,
+ ,.
Drills and exercises should periodically include the offsite organizations ' which might be called upon for support (local police, civil defensa, health' departments, etc.), as well as corporate personnel (see Section 3.3). ,
~
' = t.- '
0,iscussion:
- The$taffgenerallyagreewiththisrecommendation. Emergency exercises may *
. include direct participation by those offsite organizations that would respond.
.to the site to help mitigate the accident, i.e. , police 'and fire, Land the exer-cise should consider testing communications with other offsite emergency '
)
organizations. These other organizations would be expected to implement m generic emergency plans during an incident. Requiring a licensee to' include
. ._of.fsite organizations in drills and eftercises must be evaluated very thoroughly,
, ,because this may necessitate FEMA involvement and a licensee hostage situation .1 gQ 1say develop.
- ~ "! This recommendation appl.ies to all fuel cycle and material license,es that have 7 radiological cor.tingency plans. .> ' '~ ~
' .The revised Sequoyah Fuels contingetacy plan requires a simulated . emergency
. exercise for onsite personnel annually, and every five years an exercise will-include offsite response groups (local . authorities and corporate personnel).
' C" ' A J proach:
The staff will consider lthis and any additional recommendations mad'e in this
' area as part of'the ongoing emergency preparedness rulemaking for fuel cycle and other radioactive material licensees. Other regulatory documents 'will be revised as appropriate, following issuance of the final rule.
Schedule: - , The final' rule is scheduled to be issued in mid-1987. _ f j 1
- The update of other licensee contingency plans will be performed in accordance !
with the schedule provided in the final rule. t
.- Resource Requirements.
, 1/2 man year {
J
, 0.1 FTE in'IE to coordinate rulemaking. ,
i s / Impacts of Reprogramming' Resource;_ '
, i i
None F '
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-# 3 _,i-i e STAFF RESPONSES'TO THE SEQUOYAH ACCIDENT. LESSON 3 LEARNED GROUP RECOMMENDATIONS'
' 1
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W' ' . Lc7 .SECTION: 3'1.4. " RECOMMENDATION #1 (Ref: '18) , a' nf s
. ConsiderrequiringadesignatedEmergencyl0perationsCenter-(E007cn'siteand' l: 4 an alternate EOC either off site or in another onsite location.whTch is unlikely-L.
,to be. impacted by-the, incident. The'EOC.and alternate.EOC'shoult coptain
+ !
adequate-communications capability and accommodations to provide for coordina- . a' tion'of the onsite emergency response. activities and notifications and coordif
; , ' nation with offsite supporting; organizations. 'The E0C or alternate EOC-shouldE .
4 be accessible'24 hours;a. day.
. Discussion:- "
y, . m . Sequoyah Fuels has designated an .onsite. Emergency Operatior.s ' Center which . contains communications and accommodations for direction.'and controllof the , on' site emergency response effort. An'offsite Emergency Operations. Center has-i been acquired to support an onsite emergency response activ?ty. . Both' centers ,
,; are capable of providing notifications and coordination with offsite supporting - g organizations and.are accessible 24 hours a day.- *~ ' '
2o ., , This recommendation applies to $11 fuel cycle and materials licensees thati - '!
~ 4>
have a' radiological contingency plan. Approach: <
, . i
~
u Y. ' The staff,will consider' this and any additional recommendations made in this
~
+ ' area as p' art of- the' ongoing emergency preparedness ,rulemaking for fuel cycle and other radioactive ~ material licenseer. Other regulatory documents.will be irevised 'as appropriate, following issuance of the final rule.
- -Schedule: u a-
. The fihal rulai is ' scheduled to,be issued'in mid-198I. ;
s =_ . i.
'" The 'updai.e of other licensee contingency plans'will be performed in accordanc,e with the schedule provided in the final rule.
( , Resource' Requirements: i
; 1/2 man year <
Impacts of Reprogramming Resource: , , i None , ' i i
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. STAFF RESPONSES TO THE-SEQU0YAH ACCIDENT: LESSONS LEARNED GROUP 1. RE 4
LSECTION: 3.1.4. RECOMMENDATION #2 , (Ref: 19 I
- e L ,' ' * .;
Locations' of emergency equipment and kits should be reviewed by thMIRC and ,
licensees:so that in the event of an emergency in a given facili or. ina' accessibility of, a large portion of the facility, access t6 location',", ate- ,. i emergency. equipment and facilities, including emergency ~decontaminationifaci- ; litics,+ can be assured. Equipment caches should be,in multiple locations.. 7 , 1
- Discussion: *
- 3 y
... ' The staff will consider this recommendation' in prepar' ing $ Regulatory Guidel 1 1
which will provide guidance on ways acceptable to the staff for compliance with' R the requirements established by regulation. '
. Sequoyah Fuels has provided emergency. equipcaent in additional locations, .
including an off-site location, as part of an upgrade in their respous's _ .. capability. , i This recommendation applies to'all fuel cycle and materials licensees that
- . .lhave a. radiological contingency' plan. !
Approach: 1 t After the Commission issues a draft emergency preparedness reg'lation for fuef Y. . u l cycle and materials licenses, the staff will begin development- of a Regulatory ', Guide which will provide details on how a licensee,can comply with the regula-tion. The suitability of equipment and locations,will be reviewed and inspected ; by the licensing staff and Region IV as part of the Sequoyah restart review and contingency plan review.- , . ,
' Schedule: -1 a-' A draft Regulatory Guidit will be published in FYfE The agreement of 'the ' '
(
~
, s r-Sequoyah Fuels Contingency Plan with this recommendation will'be determined-as part of the restart decision, 8/29/86. The update of other licensees contin- <
gency plans will be performed in accordance with the schedule provided in,the q final rule.
.j Resource Requirements: , !
1/2 man year ' Impacts of Reprogramming Resource: ' 1 None i i 1; _ i 20 1
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STAFF RESPONSES TO THE SEQUOYAH ACCIDENT' LESSONS LEARN, ED GROUP RECOMMENDATIONS i i 4
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SECTION: 3.1.4. . RECOMMENDATION #3, " (Ref: 20) Consideration should be given to providing strategically placed *nir capsula escape units". to allow workers' to escape from portions nf a facil4ty in.which there exists a potential moments. '- for exposure to toxic fumes for more ,tg a few 1 0
-g ' Discussions- , ,
,g The staff agree with this recommendation'n.' 6 The fatality. on January 4,1986 resulted from prolonged exposure to UFe,.0022 F '
.and HF fumes'during escape without respiratory protection. Had appropriate-respiratory protection been available, the consequences could have been mitigated. ,Sequoyah Fuels has voluntarily installed self-contained air supply. i a escape units since the January 4 accident.
*, f /' i-
_ _ . . Approacht i
. i E
The licensing staff will request that licensees. investigate current pract' ice
- r. within their facilities and provide for NRC review,.an analyses of each plant's '
.- safety. The staff will provide appropriate recommendations and requirements based upon review of the licensees submittals. Consideration will be given at i that time to revising..the regulatory requirements.. -
,. : ichedule: ,
The licensing, staff's review for the Sequoyah Fuels restart will'eb complated s
. -c by 8/29/86. - The review of other licensees' ~submittals will be completed by
, 3/31/87. '
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.,1 SECTION:- 3.1.4 REC 0fmENDATION #4 [Ref: 21) e- ,
o The facility comm'Jnications system should include.a radio systee. compatible.with l local, police orlother offsite responder communications: systems. 'In addition, y i 'the. licensee.should' attempt to identify beforehand to local an6 State police, insofar as practical, offsite individuals who would be called on for support.. ]
'in the event of an emergency at the . site. Radio communications'with police e 4- i officials ~during an emergency can resolve specific issues. ' l + . ,
a 1 Discussion: , , l The staff will consider,this recommendation ,in preparing a Regulatory Guide , d which will provide guidance on ways acceptable to.the staff to' demonstrate-
'l compliance with the requirements established by regulation. , ,.
L -; Sequoyah Fuels Corporation has provided for radio communications with local f i
,2, _ police units as part of its revised Contingency Plan.. :0ffsite organizations.
have'been identified, briefed .aM provided training by .SFC. 4 . This recommendation applies 'to' all fuel cycle and matSrials licensees,that :
~
l'
-i have a radiological contingency. plan.
r 31 o s l Approach: ' l D 'Ahter the Commission issues a draft emergency preparedness regulation'for fuel
+
cycle and materials licenses the staff will-begin development of a Regulatory
- Guide which will provide details on how a licensee can comply viith the
. regulation. ,
Schedule: - q A draft of a Regulatory Guide will be published during FY87. The agreement of l al '_
~
the Sequoyah Fuels Contingency plan with this recommendation will'be considered as ,part of the restart decision,. 8/29/86. . . The update of other licensee"s contingency plans will be performed in accordance , with the , schedule provided in the' final, rule. < .
~ Resource Requirements: '
;1/2' man year . <
Impacts of Reprogramming Resource: None
-a
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i e F: 22
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4 , , STAFF! RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP, RECOMMENDATIONS A , 1 3.2.1. S_LCJION: RECOMMENDATION #1' (Ref: 22)
' e The events describe'd in the'. radiological contingency. plan required of certain NMSSlicensons.shouldbereviewed-todevelop-aconsistentanalgstsand.
classification of events. The resulting classification should bS-used in NRG decision criteria to. initiate transition of the NRC from a Normal Moo' e to higher response modes.
,. , .. 4 :e 4 Discussion:-
- l c, ; The Sequoyah Fuels l revised contingency plan provides for classification of events-1 ant for a graded onsite.and offsite response to the events. Classification of
' ' events.was one requirement of.the 1981' Order requiring the preparation of '
Radiological' Contingency Plans by certain NMSS licensees. > 5 This recommendation applies to all, fuel cycle a'nd materials licensees that.
;_,, , have,.e radiological contingency plan.- . .
Approach: a '
~
l The staff will consider this and any additional recommendations made in this , , area as part of the ongoing emergency preparedness rulemaking for fuel cycle and'other radioactive material: licensees. Other regulatcry documents will be
- g. revised as} appropriate; following issuance of the final rulo., . . -
Schedule: ", ' 4 The final rule is scheduled to be issued 1 tn mid-1987. The update of other. <
~ licensee con'tingency plans will be performed in accordance with the schedule provided in the final rule., ,
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Resource Requirements: . - z_ ( 1/2 man year. '
- i Impacts of Reprogramming Resource:
. o .. ;
None. s y ,
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I i 23 1 1
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3 N J~ ~ DRAFT 1 STAF/ RESPONSES .TO THE SEQUOYAH ACCIDENT LESSONS' LEARNED GROUP RECOMMEN !
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'SECTION: 3.2.1 REC 0 MEN 0ATION32 -(Ref: 23)
+
l f. Training and guidance should be provided to Headquarters Operatifns Officers- ! and. Emergency Officers relative to the han'dling 'of nonreactor eyelits. The NRC Regions,should develop additional training and awareness of nor)rgctor events
, and suitable response modes, and should assure that radiological c,ontingency plans' and other facility information.are readily available. ;
- Discussion: , ,
, '+
The staff agree with this recommendation,
- a. :. ..
The basic Headquarters Operations Officers and Emergency Officers procedures were reviewed and were found to adequately cover radiological events at fuel
~
cycle fccilities; however, events involving chemical hazards were not clearly addressed. The Headquarters Operations officer's (H00) and emergency Officer's
'(EG) procedures have been revised to assure assessment of chemical as well as radiological ~halards of reported events.- '
1 Training of H00s:and EOs to assure adequate assessments of'nonreactor events. T-must include. event classification and those aspects of nonreactor accidents that can threaten public health and safety. The training can be provided to
~
response personnel by IE; but; training material must be developed by NMSS.
't- ~ Apiproach: ,
IE has requested that MSS develop trair4ng materials on fuel cycle event ; classification and public safety aspects. IE will assure that all personnel responsible for initial assessment of'rstported events receive the training.
' Schedule: .
, - HMSS provides training material March 1987 e
- Training Complete June 1987 .-
4 Resource Requirements: t' Less than 1 month of lii staff time , 4 NHSS unknown Impacts of Reprogramming Resource: 4 None. j
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, STAFF RESPONSES TO-THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS
.t + -
,t-l SECTION:~ 3.2.1 RECOM4EN0ATION #3 (Ref: ' 24F ]
Periodic NMSS training exercises .should include events at fixed' Yites ~" artti' *.14+ : % . *
~ ' '
involve the NRC Operations Center and regional personnel. e w t, W. 9,v. Discur,si,p_n; n ~ -' y2 tThe staff agree with this recommendation. i IE has been working with HMSS.over the past year to develop and train an W , ,. organization for fuel cycle response. These capabilit'ies were first exercised' f - for a simulated transportation event and subsequently for a fuel cycle' facility. j i h ' at Lynchburg,uVa. An exercise that; simulates a' response to another fixed fuel
. cycle facility will be conducted. ~
_; , _ Approach: t
.C
. A working group composed of NMSS, IE and the regions will be forasd to develop
- . , a fixed fuel cycle facility exercise scenario. This scenario will be used.to o .. .. .
_ conduct a fixed fuel , cycle exerciseLin 1986. Schedule: Conduct fixed fuel cycle exercise before January 1987.' . l L .t
- _
h- Resource Requirements: IE .3 FTE ' ' NMSS .5 FTE Impacts of Reprogramming Resource: c_. None.
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'SECTION: 23.2.2.1 RECOMMENDATION #1 ('Ref: 25) >
e If call-in of regional staff is anticipated or sustainiajosunun4 cat.igns.are ! expected, early use of the Regional; Incident Resportse Center'she'uld IPs - l W considered to staff facilitate preliminary evaluation tification pot ~of the event.aneq# j of the regional (if a fan-out notification'is, .used)., - 1 *s Discussion:
.Use of the Regional. Incident Response Center and/or Headquarters Center communi-Leations for situations requiring multiple phone lines is~ routine as'was demon-strated during the Sequoyah event. No action is required to implement this .g recommendation.
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, i SWF RESPONSES 70 THE SEQUOYAM ACCIDENTM5jdM '. EARNED GROUP RECOMMENDATIONS t ,.
I l SECTION: - 32.2.2 RECOMMENDATION Q , TRe f: - 26) e . il When there.is significant raedia irl646st leistgy during or following an event, ' ' 1 regularly scheduled press briefings coordisaid kith licensee, NRC and state.
. responders should be considered / The -ourrtat, 'axperience indicateti the value of ithe " unified voice'!.' approach fcr updating the'Jst"attis of an event. Tkk result i was the muct reduced impact from separate'inquicies to response team members.. J Discussion: .
The Office of Public Affd' irs agrees that~ regularly scheduled joint' press brief- { ings.are a desirable goal, yhere feasible. FEMA would normally aluJ partici- i r pate. In any emergency, wt intend to coordinate with 'the licensee, the State i and FEMA. However,- in a fast-moving situation, there may come_ a time when we '1 have to move quickly in~ the public affairs area and the logistics do not
.- permit full coordination.
~ ~ '~ ResourceRecuir ments: *
- j
' The 0ffice of Public Affairs is not staffed to mount a nation-wide effort in " , , emergency planning for. fuel facilities similar to the one for power plants, in terms of assessing emergency plans and participating in drills.. A large-scale effort in this direction would require additional staff. j E ', '
9 )
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27
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i< v' . J STAFF RESPONSES TO THE.SEQUOYAH. ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS , SECTION: ' 3.2.2.2 RECOMMENDATION'N #2 (,te f: 27) NRCshouldhe.e.,aredto.initiatetheinstallationofadditic$a(telephone s i lines early. In hn' event. all facilities with limited installed comnui5fcations capability. -; . .e,,
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~
Discussion?. , . ~* ff .. . . y In the event of an emergency, NRC has ready access to the AT&T Federal Systems group for prospt installation of additional phone lines. Also. Boise Idaho i Fire. Cache has a portable satellite communications systein which would be dis- )
' patched upon NRC request. -In. addition, there are other Federal.. agencies.that i NRC may call upon for use of their portable telecommunication capabilities.
Further, IE and Telecommunications are looking at an overall communications upgrade that will specifically~ address transpor^,ation events and events at . l
'- facilities' that are not equipped with an Emergency tHotification System (EN5). l No additional action is required. i
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@ $q'1 LSTAFF RESPONSES TO THE SEQUOYAH ' ACCIDENT. LESSONS LEARNED GROUPJRECOMPtENDATIONS. ' O
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. w. > > C.S7 EC., TION: '3.1:1D~~ RECOMMENDATION #2 (Ref: 13)' 'O> ".
t1 i s , . a-f~huditsofcontingencyplan'implementationshouldbe.conductedbyMndividubis1.. f4 ' '
' ~'
inot!' hading direct. implementation' responsibility, andithe audits shapid. include? ' i
;1 Devaluation of the' appropriateness of the plan, procedures, facilk.ies, equipmentr' 'j
"; '(including ~ 1ocation of facilities and equipment),~ training and9estiodic exercises- i e
y, in the spectrum'.of-accidents, or emergencies' possible at the: facility.
. o.
o l01Acussion: w .
' The? revised Sequoyah continger.cy plan is subject to quarterly audits' directed .
z 'by the_-Director, Regulatory Compliance of the' Environmental. and Health: , K . Management Division, Kerr-McGee Corporation. .:The,Sequoyah Facility.is audited - 1 6
. to evaluate 1and verify ' adherence to the contingency plan'and implementing - .l procedures. ,
- i... i
. .[ ,
< This recosaendation applies to cil fuel cycle and material lidnsees who have ,
_ _ . . .. Datradiological contingency plan
-1 Jf .' ; Approachi /
7 5 -
~
~." The staff will' censider
'T . area as part of ~ the ongothis ing emergency ~and any additionalrulemaking preparedness recommendations for fuel cycle- made in thisl and other radioactive. material licensees. ? 0theer regulatory documents will Ae1
_. . revised as appropriate following-issuance of the final rule. y . Scheduler The' final rulelis; scheduled to be issued in mid-1987. The update of.other
- llcensee contingency plans will be performed in accordance with the schedule
- provided 'in the final = rule.
M ource Requirements: . E . 3 1/2 man yebr. .
. J' Issacts of Reprogramming Resource:
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LSTAFF2 RESPONSES TO THE SEQUOYAH ' ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS
/
3 .1. 2'. (Ref: -14) JSECTION: LREcc mENDATION #1 r i A sy'stematic' training program'should ;be established. to 'familf arifs all' plant-lpersormel with thel general contents of'the contingency' plan and) opriate. , irasponse ' actions.- Specific" training should be provided to indivi uals (both! isite and corporate) who' might be ' assigned specific response funi: ns'and ; responsibilities. Discussion: , . !
-{
' The current Sequoyah facility training program is' designed to. train a11 Lfacility .
parsonnel, . members of- the onsite contingency response orgar,ization, and
. corporate. personnel with radiation and chemical . safety 4 plant. operations and -
~
!the contingency plari emergency procedures and implementing procedures. The extent of contingency: plan training,is dependent upon tha job function'and ;
Lemergency- response responsibilities. L .o _This- recommendation applies to all fuel cycle and material licensees that' have a . radiol ogical : conti ngency ' p1 an.
~
- Approach:"
~
The' staff will consider this and' any additional recommendations made in'this area 'as part of the' ongoing emergency preparedness rulemaking 'for fuel cycle < > d and other radioactive material licensees. 'Other regulatory documents will be-
' ravised'as appropriate, followingfissuance 'ofL the final rule.
Schedule: The final rule h scheduled to be issued in mid-1987. The update of other licensee contingency' plans-wil1 be performed in accordance- ; with.the schedule provided in the final rule.
' Resource Requirements: - .7
.q 1/2 man year' 4
)
Impacts of Reprogramming Resource: 4
'None l
4
. 1 F
15 1
- l 1
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- 24 . STAFF RESPONSES TO THE.SEQUOYAH ACCIDENT LESSONS. LEARNED GROUPeRECOMMENDATIONS
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( . SECTION: 3.1.3. :RECOP94ENDATION #1 (Ref: 16)
.w e Drills -and exercises. involv.ing substantial staff response to a' spectrum-of -
simulated' emergency situations should be conducttd periodically. Jhe simulated events should be-based'on prepared scenarios to demonstrate spectfic_ objectives, ? and they.should be observed and critiqued by qualified personnelt.- Any deficien- . cies observed should be evaluated and responsibility for corrective action "
. assigned and followed.
Discussion: ,
+
Sequoyah Fuels wi,11 conduct periodic drills and exercises;to test,' develop, I N and maintain skills in emergency contingency response. Exercises will be-formal detailed scenarios, using observation #and control personnel. Post-exercise critiques will be conducted, deficiencies identified, innd remedial action responsibility assigned. a This recommendation applies to all fuel' cycle and materials licensees that hgve ~ ~~",, ca . a radiological contingency plan. , Approach: - 1 e 1 The staff will consider this and any additional recommendations made in this area as part of the ongoing emergency preparedness rulemaking for fuel cycle-and other radioactive material licensees. Other regulatory documents will be' E revised as appropriate, following issuance of the final' rule. Schedule: : (
} The final rule'is scheduled to be issued in mid-1987.
The update of other licensee, contingency plans will be performed in accw dance with the' schedule provided in the final rule. . m -
~
r Resource Requirements: . [ 1/2 man year Impacts of Reprogramming Resource: None 8 e O i' r ' { l 17
LSTAFF RESPONSES TO.THE:SEQUOYAH ACCIDENT: LESSONS LEARNED GROUP RECOMME50AT j
,;, ~
\
5ECTION: 3.1.3; RECO>t4ENDATION #2 (Ref: 17) _ , T
. Drills and exercises should periodically include the offsite, organizations. '!
which might be. called upon for_ support-(local . police, civi.1 defensa.: health;
~
departments, etc.), as well asicorporate personnel.(see Section 3.3).. . W
+ i
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Discussion: a ' ' y ,
< ~
The staff generally agree;with.this reccamendation. Emergency exercises may . , include direct participation by those offsite organizations that would respond. -) to .the site to help mitigate the ' accident, i.e., police and fire', and the exer - q cise should consider testing communi. cations with'other offsite emergency organizations.--These other organizations would be expected to. implement' sgeneric emergency plans during.an incident. Requiring a ifcensee to include , j of.fsite organizations in drills end exercises must be evaluated very thoroughly, ! because'this'may necessitate' FEMA involvement and a licensee hostage situation q _, may develop. .
~"
.This recommendation applies to all fuel cycle and material licensees't' hat have radiological contingency plans.
'f ~ .
~"
~' The revised Sequoyah, Fuels contingency plan requires a simulated emergency.
; exercise for onsite personnel annually, and every five years an exercise;will >
' include offsite response groups (local authorities and corporate personnel). '
W
- Approach:
The staff will consider this and any additioac1 recommendations made in this
- area as part of the ongoing emergency preparedness rulemaking for. fuel cycle and other radioactive material licensees. Other regulatory' documents will be' !
--t revised as appropriate, following issuance of the final rule.
x Schedule: , D- - p . The final ~ rule is scheduled to be issued in mid-1987. . / The t;pdate of other licensee contingency plans will be performed in accordance with the ' schedule provided in the final rule. Resource' Requirements:
,. 1/2 man year C 0.1 FTE in IE to coordinate rulemaking.
Impacts of Reprogramming' Resource: ', Mone- " - l
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SECTION: 3.;1.'4; . RECOMMENDATION #1- (Ref: ~18) - 1 1 Consider requiring a- designated Emergency Operations Center (E00 on . site arid - 3 s ,, an alternate.EOC either off site or in another onsite location h is unlikely .j to be impacted by the incident. The EOC and alternate .E0C shou 1(contain i
* ' adequate" communications capability and accommodations to provide for coordina-Ttion ofothe onsite emergency response activities and' notifications and coordi-
. ; nation with offsite? supporting organizations. : The. EOC or alternate EOC should '
be accessible'24 hours a day. a-Discussion: ) Sequoyah Fuels has. designated an onsite Emergency Operations Center which : contains communications and. accommodations for direction and control of the i r' 'onsite emergency response effort. An offsite Emergency Operations Center has j t heen acquired :to support an onsite' emergency response activity. Both centers .j are capable.~of providing notifications and coordination with offsite supporting'
- - - - .l 7 organizations and are accessible 24 hours a day.- ~*~
,3 a l j
_. This recommendation applies -to all fuel cycle and. materials licensees that -- i (;. -," have'a-radiological contingency plan. ~ Approach: ,,
~
't . - .The staff will consider this.andbany. additional recommendations made in this area as part of the ongoing emergency preparedness rulemaking for fuel-cycle j and other radioactive' material' licensees. Other regulatory documents will be j revised as appropriate, following issuance.of the final rule.
.., Schedule:
The final rule is scheduled to be issued in mid-1987. ' o l o .
?
.- The update of other -licensee contingency plans will be ' performed in accordance; y 8 with the schedule provided in the final, rule. ,
Resource Requirements: ' 3 1/2 man year Impacts of Reprogramming Resource: None P 1 1 1 l 19 1
'1
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' ~
'. 'STAFFIRESPONSEST0lTHE.SEQUOYAHACCIDENr"LESSONSLEARNEDGROUPRECOMMENDATIONS
,ay lf 5 i. c %. SECTION: 3. L 4.~ REC 06HENDATION #2 (Ref: 19) I ., 1 L' .~. Locations of ' emergency equipmen't' and ktts should be reviewed by the-NRC and i
- l. . licensees.so that in the event of an emergency i.n regiven fac111tf location, 1
- or inaccessibility.of a large portion of ethe facility, access t5 Edequata emergency. equipment and facilities, including emergency. decontamination fact- q 11 ties, can be. assured.. Equipment. caches should be in multiple locations. 1 i
I ' Discussion: r - . . j 5 'The' staff will consider this recommendation in preparing a Regulatory Guide I which will provide guidance on ways acceptable to the staff for-compliance with j the requirements' established by regulation. , Sequoyah Fuels has provided emergency equipment in additional locations, , j
. ,. Including an off-site location, as part of an upgrade in their response =
s__... capability. . ,j This recommendation applies to all fuel cycle and materials licensees that '" L .~ .' 'hawe a radiological contingency' plan. . y o- Approach- * { After the Commission issues a draft emergency preparedness regulation for fuel- l
+Q . .- cycle and materials licenses, the staff will begin development of a Regulatory l Guide which will provide details on how a licensee can comply with the regula-tion. The suitability of equipment and locations will be reviewed and inspected !
. by the licensing staff and Region IV as part of the Sequoyah restart review and ,
contingency ' plan , review. Schedule: ' 4
, ,- 1 0- A draft Regulatory Guide will be . published in FY87. The agreement of the ..
1 1- Sequoyah Fuels Contingency Plan with this reconnendation will be determined as i part of tho' restart decision, '8/29/86. The update of other licensees contin-~ gency plans will be performed in accordance with the schedule provided in the final rule. ( Resource Requirements: 1/2 man year Impacts of Reprogramming Resource: ,
.a i 3r. l i
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20
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"" y STAFF RESPONSES T0 THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECO MENDATIONS: ,,
5 SECTION: 3.1.4. REC 0 MEN 0ATION #3 (Ref: ~20) Consideration should be given to providing strategically placed *hir capsule : escape units" to' allow. workers to escape from portions of a faci 14ty in which-thereexistsapotentialforexposuretotoxicfumesformorethg*afew moments.. - Discussf on: , , i The' staff agree with this recommendation. ,
' The fatality on January 4,1986 resulted from prolonged exposure'to 'UFi, UO22 F and HF fumes during escape without respiratory protection. . Had appropriate respiratory protection been available, the consequences could have been mitigated. Sequoyah Fuels has voluntarily installed self-contained air supply ,
, escape units since the January 4 accident. , ,
. , _ , _ . . . Approach. , . The licensing staff will req'uest that l'icensees investigate current practice j c' . within their facilities and provide for>NRC review,' an analyses of each planDs
-- safety. The staff will provide appropriate reccamendations and requirements .
based upon review of the licensees submittals. Consideration will-be given at that time to revising the regulatory requirements. _ Schedule: The licensing staff's review for the Sequoyah Fuels restart will be completed by 8/29/86. The review of other licensecs' submittals will be completed by 3/31/87, m ,
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.7 STAFF; RESPONSES TO'THE-SEQUOYAH' ACCIDENT LESSONS: LEARNED GROUP REC 0mEE ATIONSL -I pMo f.
+ '
a 1 4 y, ' ' iSECTIONi'3.1L4 RECOMMENDATION'M ~ (Ref: 21 [
! . ,e ; 1 The' facility? communications! system'should includeia radio. system s.capatible 'with L,' local police'orLother offsite responder communications systems. ?In addition, ..
@ the licenseelshould attemptLto. identify, beforehand to.. local' and, State 2polica,-
- insofar.as practical, offsite individuals who, would 'be called on for support ' < '
in the event' of an emergency at the site. Radio communications with police 3 officials during an emergency can' resolve, specific issues.?.
. , j
+ .. Discussion: . i ' '
^- , Thefstaff will consider this recommendation,in preparing a Regulatory Guide ] j
.which will; provide guidance on ways; acceptable to the' staff to demonstrate 4 compliance.with the requirements estabilshed by regulktion. '
.n , ,
q Sequoyah Fuels Corporriion has provided for radio communications with it.c'al , 1 _ ... police.unitt, as part of.its revis~ed Contingency Plan. Offsite organizations. J have been, identified, briefed, and provided training by SFC. j
.y . .; This recommendation applies to all fuel cycle and materials. licensees that , j
' haveL a: radiological. contingency plan.
1 j
- Approach:: '
Y After;the Commission issues a draft emergency. preparedness regulation "for fuel: ., ! cycle :and materials licenses the . staff will begin development of a Regulatory j Guide which will provide' details on how a ifcensee can comply with the-c regulation. - Schedule: , ALdraft of a Regulatory Guide will> be published during FY87. The agreement of , l e- the LSequoyah. Fuels Contingency plan with this recommendation will be considered 1
~
r as' part ot' the restart decision, 8/29/86. '
. 4 a The update of other licensee's contingency plans will be performed in accordance ;
.with the schedule provided'in the final rule. '
Resource Requirements: ' 1/2' man year , Impacts of Reprogramming Resource:
~
None v -- i l 22
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*~ > ,JSECTION: 3.21
.=
- RECOMMENDATION #1- (Ref: 22) * ,,,
~
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!The eventibescribed in th'e radiological contingency plan frequired 4,f certain-
}
l L
* 'fetSS licensees should.be ' reviewed to develop'a consistent' analysis an'd- d
. classification of ' events. The resulting classification should"bS-used in NRC ,
j decision criteria. to initiate transition of the NRC from a Normal Mode.to higher response modes. > q l 4 i o
~' '
Discussion: ' l The Sequoyah Fuels revised contingency plan provides for classification of events and for a graded onsite and offsite response to the events. Classification of l events was one requirement ofJ the 198I. Order requiring the preparation of 1
- w. Radiological Contingency Plans by certain NMSS licensees. j 1This recommendation applies,.to alli fuel cycle and materials, licensees that' .
. have a radiological contingency plan. e .
~
Approach: , The staff will consider' this and any additional recommendations made in this'
- area as' part of the . ongoing' emergency: preparedness rulemaking 'for fuel cycle ,
and'other radioactive material licensees. Other regulatory' documents will be. " g.. revised as. appropriate, following. issuance of the final rule. " -
' Schedule: o c ,
+ a. ,
4 ' The firial rule is' scheduled to be issued in mid-1987. The u'pdate of otheri ;
~ ' '
licensee contingency plans will <be performed in accordance with the schedule 1 provided in the fira1 rule. ' i Resource Requirements: -
' O-i 1/2 man year. '
- [ '
g , Impacts of Reprogrgylna Resource: 1 Hone. I- , l j l
'3 C'_
i 4 23 5
"h + .,
. STAFFRESPONSESTOTNE.SEQUOYAH'.ACCIDENTLESSONSLEARNEDGROUPRECOMENDATIONS
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.SECTION: ' 3. 2.1 - REC 0 MEN 0ATION #2 (Ref: 23)- ,
3/- Training an'd guidance shoul'd be provided to Headquarters Operatifas bfficers' and Emergency:0fficers' relative:to the handling of nonreactor evelfts. The NRC Regions ~ should develop. additional training 'and awareness of;nogryctor events, Mi: > and suitable response modes, and should assure-that radiological contingency , a
?
-Eplans and other facility information are readily available.
Discussion: . The' staff agree with this recommendation. ' The- ba' sic Headquarters.0perations Officers and Emergency Officers procedures ' were reviewed'and were found to adequately cover radiological events at fuel l cy'le c facilities; however,. events involving chemical hazards were not clearly F > ;
- ~'
addressed. 'The Headquarters Operations Officer's (H00) and emergency Officer's
+ -(EO), procedures 'have been revised to assure assessment,of chemical as well 'as. >
radiological hazards of reported events. .
~ . '
' Training of H00s and EOs to assure adequate assessments' of nonreactor events - "
must include event' classification and those aspects of nonreactor accidents !
~
. that' can threaten' public health and. safety. The training can be provided to l response' personnel by;IE; but,' training. material'eust be developed by NMSS. . 1
" 's-- -- - @, roach: .;
3,
- IE has requested that NMSS develop training materials on, fuel cycle event
- classification and public safety aspects.. IE will assure that all personnel responsibl+ for initial assessment of reported events receive the' training.
' ~
? : Schedule: ~ + <
g NMSS provides training material
~
March 1987 ! Training, Complete , June 1987 -
.c . i, Resource Requirements:
Less than 1 month of IE staff time NMSS unknown i Impacts of Reprogramming Resource: i* ' None. M 6
-[ .
l 24 > l
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5 STAFFRESPONSESTOTHE'SEQUOYAHACCIDENTLESSONS'LEARHEDGRbuP' RECOMMENDA
+ '
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3.2d
' SECTION: RECOMMENDATION M3 (Ref: ' 24) ,
s4 . heriodic NHSS: training exer'eises shoulti include ehents at fixed,5jtes anY .$,,4 g. "; ) involve the NRC Operations Center and regional personnel. 1, . ' . i
= r. 5 Nw3
,c Discussion: ..-
,i
- . . o ,
The staff agree with this recommendation, a
-l '
t . g IE has been' working with HMSS.over the past year to develop and train an * ' *- - organization for fuel cycle response.- These capabilities were first exercised " s for a simulated transportation event and' subsequently for.a fuel cycle facility +
'" 1 at Lynchburg, Va. An exercise that simulates a response to.another fixed fuel-cycle facility will be conducted.
' '+ ,
_, . ,. ' A.Parcach;_ 7 , 7 A working group composed of.NMSS,' IE and the regions will be formed to develop I b, a fixed fuel cycle facility exercise scenario.. This scenario will be used to conduct a fixed fuel cycle exercise in 1986.
,;, - I Schedule: '
i
. , Conduct fixed fuel cycle exercise before Januarp 1987. I t" .
, Resource Requirements:
1 IE .3 FTE . .
. - HMSS .5 FTE
' Impacts of Reprogramming Resource: j e 'None. .
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' STAFFRESPONSESTOTHESEQU0iANACCI0ENTLESSONSLEARNEDGROUPRECONNENDATION
-* 4
, , f SECTION: 3.2.2.1 RECOMMENDATION iil i (Ref: 25)- '
. e ,
If call-in of regional staff is anticipated or sustatnnojommunicatiqns,are , expected,. early use of the Regional Incident Rssponse Center sho^uld, tre - a considered to facilitate preliminary evaluation of ,the event. ant! Notification of the regional . staff (if a f a'n-out notification is..fot used) ,- ',l ?
,- i
. Di;scusston: j e , c ,
j Use of the Regional" Incident Response Center and/or Headquarters Center comuni-l cations for situations requiring multiple phone lines is routine as was demon-- strated during the Sequoyah event. No action is required to implement this recommendations.
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cr a, t ' STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP. RECOMMENDATIONS s e . ' - . E
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^ SECTION: v 3. 2.~ 2. 2 RECOMMENDATION #1 '
(Ref: 26) u , q
- 3. ,,
L When there is significant mediaris.Q~ est lo.cally, during or following.an' event, regularly scheduled press briefings coordinated vith licensee, NRC'and state h ' respondersishould be considered...The w rrtat experience indicatei the value of , s the " unified voice'.' approach far updating the] status 'of an ' event. The result was, the much reduced impact from separate ~inquici.es to respon'se team members.
' 4 ..
T '
,. Discussion:4 ,
TheOf fice 'of Public Affairs -agrees that regularly scheduled joint press brief- ~' ings are.a desirable gor.1, where feasible. FEMA would normally also partici-J,. pate. In any. emergency, we intend to coordinate with the licensee, the State '~
.and FEMA." However, in a fast-moving situation, there may come a, time when we y have to move quickly in'the public affairs area and the logistics do not,
_, ' permit full coordinaticis. I' ~ '~ Resource' Requirements: '
, ,i t
~ The .0ffice of Public Affairs is not staffed to mount a nation-wide effort'in - -
I _'" emergency.. planning for fuel' facilities similar to the 'one for power plants, in i terms of assessing emergency plans 'and participating in drills. .A large-scale <- effort in this direction would require additional staff. .
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~
i SECTION: - 3.2.2.'2 RECOMMENDATION #2 _ (Ref: 27) ,_ y NRC should ie ... s [telephone lines earlfinTn' hared eventto. initiate thewith-limited aOFacilities int;tallationins' of.alled additionA t communications l capability.~ ' '
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mp
. . M 'O Y Dis'cussion? , . * ./ . o
- v. . .. .
'In the event cf an emergency, NRC'has ready access to.the AT&T. Federal Systems l, .
group for prompt insta11ation 'of ' additional phone lines. Also, Boise Idaho
., Fire Cache has a portable satellite communications system which would be dis-
. . patched upon NRC request. In. addition, there are other Federal' agencies that NRC may call:upon for use of their portable telecommunication capabilitf as.
, , Further, IE and Titlecommunications are looking.'a', an overall communications >
upgrade that will specifically address transportation events and events at '
' facilities that'are not' equipped with an Emergency' Notification System (ENS).
No additional. action.is. required. , .-. i
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. STAFF' RESPONSES'T0;THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP' REC 0 EMENDATIONS
'% . :: a *'m J . A . g{
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- SeCTION: 3. 7. 2. 2 RECOMMENDATION #3 (Ref: 28) -
" ii.tputC should haveipredetermined criteria'for acceptable onsite-akoffsite i 2 ~N scohtamihation levels,' preferably based on-projected dose ronwitmeipts or '
q health imp' acts.. Such criteria should be< readily available andqcributed' G-I'sd thati ad-hoc ' acceptability criteria need not be. generated under crisis .
, tonditians. ,
Discussion:
.One issue here is the use of Protective Action GuDies (PAG's)Lissu6d by EPA and.
others.1Because of the wide variety-of radionuclides, chemical and physical-
, . ~!
forms,' and exposure pathways,:it is not feasible -to set predetermined: radio- !
.nuclide quantity limits. This must be done on a case-by-case basis using the-ap'propriate dose related PAG. The ~ staff will review existing PAG's to ensure '
l
~-
that- a complete set is_ available for, use in emergencies. These guides' generally i apply to the'shor.t term protective actions while the situation is being+ .,
- - - -stabilized.1 -
~~a- For. the long tein,' NMSS, 'in concert with EPA, developed criteria for acceptable. , g concentrations for uranium ~and _ thorium in soil, based on dose commitments. !
These were provided to the; team responding to the accident. We have also l
' developed criteria'for other radionuclides, using the same dose commitments? ,
-~ Acceptable ^1evels for surface contamination on equipment and buildings tus also !
't -+ + bfen developed for most radionuclides. Both sets of criteria have beer, putclfshed i
,as Branch Technical Positions and are used during decommissioning of fuel cycle i facilities. They are: *-
4 .
- 'i 1. " Disposal or On-Site fStorage of. Thorium or Uranium Waster from Past .
_ ?> Operations,": October,) 19G1. ' Option 1 provides acceptable concentra- 'q tions of uranium and thorium ,in,the environment: 0 , i i
, , f U-235- 30 pCf/gm . Natural U*ariium - 10 'pCf /gm ,
7n s U-238 35 pC1/gm Natural Thorian 10 pCi/gm '
- 2. " Guidelines for the Decontamination of Facilities and Equipment
#. )
Prior to the Release for Unrestricted Use, or Termination of
.Licensas for the Use of Source, Byproduct, or Special Nuclear Material," July, 1982. {
, These criteria treat radiological risk alone. For chemics 1 nt . Ards or special ,
chemical forms which influence pathways to radiological risi, tne possibilities ! are so many and varied that they must be considered on a case by case basis ] using the basic criteria listed above as a starting point. . . . l'"' o Schedule: i r- l s , The PAG review will be completed and appropriate guidance will Serprovided to a11' fuel facility licensees and the Regional Offices by 12/31/86.' i l ! 29 '
^
j , v _a u i
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- v. 7 o, , ,
h .n [STAFFRESPONSESjTOTHESEQUOYAHACCIDENT.LESSONSLEARNEDGROUPREcomENDATIONS-p' , k '
+
. a 9 3.2.2.2 " .
'SECTION: ' RECOMMENDATION #4' (Ref: '29)' V
; f
!The.NRC-teaq responding,to; contamination events y
# individuals'tusponsible'for coordinating sample,s'hould collection andinclude af indfifdual orl d(ta" analysis.-
c (For a response to ;a reactor _ event, 'an Environmental Team Leadypould normally? e F be. dispatched with the initial Site Team.), The person assignac Cle~ sample and . o dataicoordination function'should be retained in that position sufficiently long to' assure skaipling,' analyses'and~ data handling consistency.' If personne1'
.: ui L ,
assignments'are changed, -sufficient turnover time must be -allowed to ' assure.
. smooth tracsition. JSpecific training,
- exercises and drills .should be conducted !
in sample collection and: data handlin,g. The sample data-sh'ould be entered into- ,e a computerized data base as early as possible 7or ready analyses and sorting by 4 all parties with need for the data. '
,s ..
Di~scussion: L , L- . . . .
-DOE h'as an agency mandate to' provide radiological assistance'to offsite author-q
- .----..- -ities'in order to protect the publ.ic health and safety in a radiological /emep-l' o
gency.. It' carries this 'out through. the Radiological Assistence Progrant '(RAP)
" , and the' Aerial Measurements Systems .(AMS). . It should be recognized that in .
any incident where .there is a real or potential thrwat of a significant radio- ;! logical-release, NRC, the State 'and/or the licensee may and should call' upon . - 1 DOE to provide radiological; assistance. Under the Federal Radiological Emer - gency. Response Plan-(FRERP)~ DOE has the responsibility, during the emergency; y~ -D phase of..a radiological incident, to coordinate the offsite radiological moni- 3
..toring, assessment and' evaluation and*to provide their assessments to the cog- ,
, . nizant. Federal' Agency and the affacted State (s). NRC cannot and should'not ,_
duplicate these existing and extensive capabilities. However,.a member of the. . NRC site. tema'should be responsible to assure that-any NRC monitoring activ-' '
" ities are coordinated with DOE when they. arrive and assume responsibility.for i interfacing with DOE by' being the primary contact with.the DOE RAP teams -or the .
FRMAC. '
"~ Approach: .
e .; q 3 The NRC' regions and the NRC Headquarters response teams will be reminded to l call on DOE for radiological assistance for any event where there is a real or potentially signific. int radiological release to the environment. , Schedule: ' Regions will receive guidance by October 1,1986. <
. I e
F i
. g' A c' _ ,
f I h 30 I y .
. v' e STAFF RESPONSES TO, THE' SEQUOYAH ACCIDENT LESS0his LEAkNED GROUP ' RECOMME
, c 1 n
+
(
- y '
)
- SECTION: '3. 2. 2. 2 RECO MENDATION #5 (Ref: 30), J
. TheneedforestablishingstandardizedsamplingandsampleprepaEation !
procedures and the means.of.intercomparing laboratory results shoIild be fj recognized and met early.in any event involving multiple.organi,z gions. 1
. i Discussion: )
, 1 As noted in response to Section 3.2.2.2, Recommendation' #4 (REF:' 29), in any event of any possible consequence 00E will be called upon to. coordinate the offsite moxitoring activities which includes the establishment of standardized sampling, sample preparation, and calibration ~ procedures. DOE is prepared to < >
i carryout this task and has the staff,' facilities, procedures, and organization
~ d-to, implement these activities. Therefore, no 9ction 1-s required to inplement- i recommendations. l A
1 mNe* i F O w if y ,
?
- I6
(
. . . rl , .
I i n r 1 3 I R.- F . l a + ' O
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h ,j e' ' iSTAFF' RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS l. EARNED GROUP RECO i g , . ,. -t (SECTION: 3.3.1 -RECOMMENDATION #1 (Ref: -31)- o }
-In the event an emergencyLinvolving an impact on public healthJnd safety,
~f il otherl federal agencias' may'nced to respond on 'a timely t' asis with personnel, ;
' equipment,. oriprocedures for obtaining pertinent information. ?4hes.e egencies 4 - i should be notified of an event as early as;possible:(see Section 3.2).7,-
g Discussion: ' i .. i
- Since the Sequoyah fuels accident, the Operational' Response' Procedures between ';
# NRC, DOE,. EPA, and HHS'has been revised to include USDA as a fulF participant :
'iu' these procedures. , These procedures have been reviewed and thra staff believes f
- that. current thresholds .for notifying thess agencies are adequate. However, we ,
have written to each of these agencies and. requested their comments as to the adequacy of'the notificationithresholds. i 6 have also conferred with.HHS'(FDA) _~ and EPA (ORP) to reconfire previous arrangements that each of these.-primary agency contacts has accepted the responsibility lto make further contacts within their agencies, i.e. , in HHS, FDA will' notify .COC and NIOSH and in EPA, ORP
- e will inform CERCLA staff. In accordance with NUREG-0981, FEMA continues' to
{
. notify o,ther Federal agencies of any incident where NRC goes into Standby Mode.
, 1
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' STAFF RESkONSES.TO THE SEQUOYAH ACCIDENT LESSONS LEARNED ,
l' GROU
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LSECTIONi ' 3.3i2.1' ' REC 0mlNDATION #1 ; (Ref: 32) , M ' f Personnel oft local agencies' that might be called upon to respond h. emergencies - should be,given training (see Section 3.1.2, Training).- o
=t. ,
.._: Discussion:
. iy .
+-
- c. c ., ,
d The revised .Sequoyah' Contingency Plan calls. for local offsite respon'se agencies, , __ .; i' including police, departments,ihighway patrol, and health department personnel -l
.o to be instructed in the areas of the plan which affect their. ability to resp'ond ll lto an, emergency when needed. ,
i Note '.that offsite agencies should not be required to be trained, they should be: i invited to the. training. . This recommendation applies'to all-fuelicycle'and-materials licensees thatthave a' radiological ' contingency plan.
.v. -
- 41 ,
Approach: i The'staffwiliconsiderthis'andlanhadditionalrecommendationsmade-inthis
~
- . . area as part.of the ongoing emergency preparedness, rulemaking for fuel cycle-
_ 7 and other radioactive. material . licensees. Other regulatory documents will be
- revised.as appropriate. .following issuance of the final' rule. -
i
, q Schedule: ' '
t- ~ i
~
The' final rule 'is1 scheduled to be ' issued in mid-1987. The_ update of other - licensee' contingency plans will be performed in'_accordance'with the schedule
; provided in _the final rule. . ,
. , -1 1 Resource Requjresents:
1/2' man' year. - - c: i --' _'
. t s.
'T Impacts of Reprogramming Resource: ' ' _ [' I
. None. ,
a, ,
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i y k a h p I g' F
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n 33
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- SYAFFRESPONSESTOTHESEQOOYAHACCIDENTLESSONSLEARNEDGROUP-REC 0l+1 l," ^ , ,
J , 3 15ECTION0 3.2.2.2 S RECOMMENDATION #2 (Ref: 33)
/<
NRC should consider routine uso .of e 'ihot line" (a rumor control'line) in , y a- response to nonreactor events. (State and local emergency plans 'far. reactor ,
., o sites presently require " hot' 11ne" (rumor control) provisions),, , - J Discussion: .
Experienced Public-Affairs officers in Headquarters and the Regions currently ' perfois the function of rumor control, A Public Affairs Officer is also dis-patched to the site in the event of an emergency. All are available,to answer i
- telephone inquiries from. members of the public and press. ,
a ; i j
- t Approach- ' 4
' +
It is important that the Office of Public Affairs be provided with the latest technical data at all' times in order to fulfi.ll this function. .
+
Resource Requir,ements: '
-o
~
r- If the , level of public and press interest is extreme'fy high (as during the Three Mile-island, event), OPA may need to supplement its staff and install additional telephone lines during the event. ; p .
, )
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F s' - 6 3 ( _ i s a 34
_ _ _ - _ _ _ _ _ - _ _ _ _ _ _ . - - . . . .=_- - o n 3
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~
J .- ..g LSTAFF' RESPONSES TO THE:SEQUOYAH. ACCIDENT LESSONS. LEARNED GROUP RECOMMENDATIONS t , >
-* r. , ~
., ,, .. i . .
4 SECT 10Ni 3.3.3.' ' RECOMMENDATION'#1 . (Raif: 34)' ' ( l + Hospital staff who might reasonably be expected to deal uith iiijrries frosa - 4 ! E a major accident thould be trained-to deal with all aspects 'of the~
. . injuries. Radiological plans.and and their'use=in drills are des'irable C . (See Section 3.1.2, Trainingj. '
' s
'" ,2-~
. Discussion: ,
,. 3 The Sequoyah Fuels revised contingency plan has included medical $upport- .
. .. personnel in their training program. Hospital staff who might be expected to o, A
treat' workers who are contaminated and/or have cheefcal injuries will' receive. l training to deal with'such : injuries.resulting from an accident. .., o Nate that the hospital s'taff 'should'not' be required to be' t' rained, they shduld ~ A-he invited to be trained. This recommendation applies to all fuel cycle and
, ' . materials licensees that.have'a radiological contingency plan. ' -
j Approach: [ l
. ._ The staff will consider this and 'any additional recommendations made in this ~
.. area as part of the ongoing emergency preparedness rulemaking for fuel cycle !
and other radioactive material licensees. Other regulatory documents will be- , revised as appropriate, following issuance of the final rule. "
+ <
n. [ Schedule: , The final rule is scheduled to be issued in mid-1987. The' update'of'other-
.
- licensee contingency plans will be performed in accordance with the schedule
'j provided in the final' rule.
itesource Requirements: 4 a- - 1/2 man year. , !
+
n n . ;
' Impacts of Reprogramming Resource:
i u ..
, None. ,, ,
n . ,
.. i f
!l ' ,
* ' . r 3 7' ,
t. D 35 4' ,
9 3 *^ r '
; M STAFF RESPONSES TO THE'SEQUOYAH ACCIDENT LESSONS. LEARNED GROUP REC 0W4ENDATION j
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Q. ! n , J ' '4 . SECTION: 3.3.4. 3 . 'c RECOMMENDATION'#1 - (Ref: 35)- j
- Radiological cientingency pinnning should' include site' cuntrol plans tand- .
methods for implementing site access control.. Local lav enforcement groups- g
- that might'be: called on'in an emergency should be trained (see e ,
. : Section 3. L 2). ' '*
'" t- i.
g . Discussion: o d y, .
, j i The staff will consider this recommendation in preparing a Regulatory Guide which will provide guidance on ways acceptable.to the . staff for compliance with the req'uirements established by regulation. '
,c
.- + ,
e E- The Sequoyah contingency plan includes an' Administration and Security Coordinator-
- 1
- who is responsible for maintaining facility security and access control during t and after an emergency. Local police departments can be called upon for security,
. .c : access, and traffic control assistance and will be trained in the areas of the
,_ plan which affect their ability'to respond to an emergency. , i e .
~
+ "
This recommendation applies to all fue.1 cycle and materials. licensees, that s y ,, have radiologfeti contingency plans. . a -
~
Approach: t ,,3 + D ,. . After the' Coinnission . issues a proposed emergency planning regulation for fuel. ~
. cycle and materials licensees ~ the staff will begin development of a Regulatory. ,
' Guide which will provide details on how a licensee can comply with the regulation.
~
.c
" ~
Schedule: , 1
.c
, Lj A. draft Regulatory Guide will be published in FY 87. :l s )
ar_- The update of other licensees contingency plans will be performed in accordance J'
- , with the schedule provided in the final rule. '
e , .
. Resource Requirements:,, ,
1/2 man year. ' Impacts of Reprogramming Resource: Ikine.
.y r-
'(
36 4 ,
. 1
- . H':
- STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GR0tiP RECOMMENDATIONS' ,;
, . s SECTION: 4.1 RECOMMEND \ TION #1 (Ref: 36)
An opinion should be prepased for publication in 10 CFR 8 that precisely
,. defines' the scope of NRC regulatory authority with respect to nonradiological hazards in. industrial chemical ar}d other plants operating undenr%C.. license.
The opinion should address the nonradiological hazards.of the. licensed .
. materials and the reaction ot' those materials with process and other chemicals present at the plant.
' Diseussion:
The LLG Report indicates a prob?em regarding the scope of agency jurisdiction e over chemical hazards that' needs to be authoritatively resolved. The recone mendation suggests a reasonable vay of doing so. OGC ha.s an attorney reviewing a-the legislativeLhistory of the Atamic Energy Act and related , legislation, as _~ well as reviewing relevant cases, and intends to prepare a legal memorandum on
~ ~ ~-
the subject. '
-. Approach: '
~
~ "
~ .The approach is to prepare a thorougt, legal analysis of the scope of NRC i authority vis-a-vis hazardous chemical effects of licensed materials and related activities.
4
'r_' Schedule: ,
~
The present schedule calls for completici of the legal memorandum by September 1, , 1986. Resource Requirements: i o Resources are within current budget. No new resouces are needed. , L "e"
- l a
+ t p 3
l I , F
. a !
r_ ! i 37 , l
_, l'
~
STAFF RESPONSES.TO 'THE SEQUOYAH' ACCIDE, NT; LESSONS i. EARNED GROUP. REC 0fetEN0ATIO '
, q SECTION: : 4.1 REC 0 MEN 0ATION 12 (Ref: 37) '
i
'A' Memorandum of Understanding-(M00)'should be concluded with thmbrtment of i Labor covering the'0SHA-NRC-interface. The.MOU.should 1.ncorporatlF1he conclu-a e
isions of the. opinion developed under; recommendation -1, w and shog1('l descr.ibe in 1 detail-the scope'of hazards subject to Atomic Energy Act regulat on. 'Under the
'M00, occupational hazards that are then not, precisely the regulatory responsi- ' ?g bility of NRC would be'under; OSHA regulatory jurisdiction <. 'I Discussion:,
The'NRC thru IE will negotiate with OSHA, Department of Labor an interface: 'l
'MOV to facilitate coordination and cooperation concerning employee health and
- safety. in'NRC-: licensed facilit-les. This MOU will: detail the scope of each -
- cacency..as uto the hazards regulated within these facilities.
Approach: : l _, . .) l
'1 MRC will , approach this MOU by scheduling meetings between NRC and OSHA personnel e
'~W to scope the regulatory authority'for each agency.and develop a mutuelly accept- i able expressions of.that. authority. A guide will also.be developed which can, '
he changed as: personnel and regulations change and which will. incorporate.the provisions of the' current, unsigned guidelines. J : ' l y;, 1 , t 7- , Schedule: ,
>' ~
1, j' On' June 24, 1986 the firsttIE/ OSHA meeting was held.- Other meetings will be !
~ held as needed. The MOU will be finalized after the legal opinion from.Section H 4.1, ' Recommendation #1, '(REF: 36) has been developed and published. I
, . . . - r kesource' Requirements! 1 IE: 150. staff hours /writeup and, negotiation ~ ' ' i
}~
Impacts of Reprocrammino Resource: ' ' 1 Mone at present. 1
. )
e s [ . 6 L l 4r_ , 1 1 4 38 t .
.. - ,n.
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' STAFF'RESPONSESTOTHESEQUOIL4ACCIDENTLESSONSLEARNEDGROUPRECOMMENDATIONS t kk 6 4',', 5 * / r SECTION: 4.2 RECOMEQ,JIO_N_#1 ' . (Ref: 38)
NRC licensees should be YeMnted through an IE Information- Notici of their obligation to report releases above reportable quantity limits to-4.he National
- Response Center and the potential of a criminal penalty under CElfCLA for ,
failure to do so. * ' - t Discussion: Although enforcement of the requirement to report to the National' Response . Center is not the responsibility of the NRC,.it is an important safety require- l ment and necessary to activate the nonradiological response to a chemical
.c release. '
Approach: ' IE will. issue.an information notice that reminds licensees of the NRC require- 4 . _ ... ment to report releases of radioactive materials in accordance with . ; 10 CFR 20.403. The information notice will also state that under CERCLA, ' releases above specified limits must be reported to the National Response Center, j
- r. , . ,
- Schedule:
Issue IE Information Notice in September 1986. Resource Requirements: Minimal. 9 E
. 4 1
{ r D u. l 39 % _ _________m._.__-----..---- -- "
'[
9, q T > a'
.i
,w ST,AFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS 4
, ( '
l i lO<l{ MSECTION: 5.2 REC 0mENDATION #1- (Ref: - 39) '
.+
]
The criteria of? draf t NRC Manual Chapter 0513 should be reexamined. relative to clarification of the use of an IIT versus the:use of an AZT following events involving offsite consequences or mult1 agency response. c= L . q Discussion: i
\
The Appendix of NRC Manual Chapter 0513, NRC Incident Investigation Program - ' defines .a significant operational event-(SOE) as "[a]ny radiological,- safeguards, orlother safety-related operational event'at 'an NRC licensed, facility'which by its consequences, poses an. actual or potential hazard to' public' health and safety, property, or the environment." (Esphasis added) The appendix- further states that IIT's perform the single NRC investigation ~of .; significant operational' events, and defines several characteristics that may _ be present in an SOE. These characteristics include: '
- 1. [a] significant radiological release....
- i 3.- [a]ppears to involve a major. deficiency in design, construction,3'or"
, operation having potential generic safety implications.
1
- 4. (a]n event that lead to a site emergency.
D
- 8. [a]n event that is sufficiently... unique.~..to warrant an independent investigation or an event which warrants an investigation...to best serve the 'needs and interest of the Commission. ]
AE00 believes that an incident having the characteristics of the Sequoyah event could be judged to be an SOE for several reasons: 1 Roads were closed around the plants for some time. - This action e., taken by the licensee implies the event had either an actual or
;. potential hazard to public health,and safety, and a such, met the ,
r definition of an SOE. . NUREG-1140, A Regulatory Analysis on Emergen y Preparedness for. Fuel d
. Cycle and Other Radioactive Material Licensees, contains a theoretical analysis of'a UFe release approximately equal to that of the Sequoyah event. The analysis demonstrates.that possible permanent kidney I damage could occur under adverse weather conditions'and plausible l transient kidney damage could occur under typical conditions. (The l damage results form chemical toxicity of uranium, a radioactive '
" , material.) - These calculations imply that the amount'of material released at Sequoyah represented "a major radiological release," a H r-possible characteristic of an SOE. '~~~
.g l' --
Both American UFs conversionfacilitiesheatlargeUFa'[yllndersin [ steam chest. - The Sequoyah cylinder rupture might have represented 3 40 N
1
--f f, - I 4
, 1 h
[G' iSTAFF ..RESPONSEg 4TO THE SEQUOYAH ACCIDENT' LESSONS LEARNED GROUP, NEC0KGNDATIONS
' f' i
i- '
't '
}{
( . a . . q . . an event having generic. safety. implications, a pos'sible-e characteristic of an SOE.- 'd
'i t- -
The' licensee in their Radiological Contingency Plan.us the reporting # s ' ". characteristics.of 10 CFR-10.403,' Notification.of'Irttitents,'to ' i U define the. categories 1of events. The rupture of a Ufa cylinder was. M m given as an example;of a " General Emergency," a-higher livel of. ',' esent than a." Site: Emergency." .'Although the licensee did not 1 declare the: event.to be either a general or site emergency,z NRC . L ' personnel could us.e the emergency plan ~to assess the.licenste's-h perception'the.the event's significance. - 'The licensee'sS Radiological Contingency Plan implies the event represented at least. " 1
- a site emergency.
]
The'Sequoyahievent was unique, and resulted in; evacuation of the-plant; major responses by licensee management and NRC' Region _IV ~~' personnel; and local and national media attention. .- The event , could have warranted'an-independent investigation based on its & uniqueness 'or' the needs and -intere.st of the Commission, a . , ! ' u. . . . characteristic of an'SOE. - L'~ q AE00 believes: that the. subject manual' chapter, currer.tly under final review, i meets ~the intent.of the recommendation. 1 TU The use of.an IIT'rather than an AIT follows from the significance of the W' event. The appendix to the chapter contains at least five measures by which d j the significance of the Sequoyah event could be judged. We' note specifically f -that-v' = > -- 1
-With regard to offsite consequences, events having offsite ;
consequences'may be judged to be'significant operating events based ' on the definition of an SOE, or~ characteristics.1,!3, 4, or 8 given. a_
=
.above. d
,l ..
4 With regard to events irwolving multi-agency response, we view such 1
. response as following from the significance of the event. As such, l we do not believe that it should be defined as a' separate- I characteristic of an SOE. We also note that characteristic 4 or 8 above could capture an event involving multi-agency response as one that uhould be evaluated as an SOE to serve the needs and interests of tha Commission. ,
AE00 believes that the Manual. Chapter does not require revision, and, had the Chapter been available at the time of the Sequoyah event. it could have been used to determine whether or not in IIT was more appropriate than an AIT investigation. We have, however, reexamined the IIT procedures and added i additionalexamplesofeventswarrantingconsiderationofIIT'sjugingtheLLG report and recommendation. 1 t 1 41 m
m w , 4 o e' , f ; ,,
; - ~- - ~T 7 l , ; p. 5 y
.a e . . . .
e . i LSTAFF RESPONSES!TO THE SEQUOYAH ACCIDENT- LESSONS LEARNED CROUP RECOMMENDATIONS u .
~
. . y- .f ;
l '
- SECTION: =6' RECOMMENDATION #1 (Ref: 40)
I' - <, GThe Federal Radiological Nonitoring and Assessment-Plan 1FMAP):shguld be- a utilized to collect and assess' data relative:to the heaRh effects of an 'j Lincident. .: Current.NRC response. plans-provide for interfacing n wdttLFRMAP and
;q<
f for providing direction'to FRMAP agencies, therefore a separate healthieffects-
* / task force may not be necessary. , If a task force is> formed, .however, it 'should - 5
, ibe" set.up-to utilize FRMAP generatedidata and assessments without,ispectingLon S
' the response:to the incident.
i -
]
j
- 4. Discussions '
m W' As lnoted in the response to Recommendation No.'L4,- Section 3.'2.2.2. (Ref: 29) DOE will be called upon early'in La response to an event to provide extensive 1
.offsitelmonitoring assistance.- En ~a significant event, 30E will' establish a I
' Faderal: Radiological Monitoring and Assessment Centor (FMhC) which will >
J coordinate fall monitoring activities including those of the State and'11censee. <
'~; lIn' addition, one key' aspect of,the FRMAC activities ig an assessment group * ]
S composed of representatives of 'allJ the Federal; technical agencies, the State (s)
*" iand the licensee to assess the field data. Whether a health effects group will :l
- be part of this.FRMAC assessment team or a separate health effects' group.is
~ .
established at a.different location,Lthe FAMAC generated data and assessments. ! should ~be the basis foritheir work.. ThisLpolicy will reiterated to all NRC
~
j region. and Headquarters response teams. t
. I
- 7. - ;
' Approach:
NRC regions 'and Headquarters response personnel,will be reminded to ' call'on DOE-for radiological assistance for any event where there'is a real or potentially- g significant radiological release to the environment.. ' 1
' Schedule:.
r
\
Region will receive guidance by October 1,1986. , [ ] l
)
i 1 W
- a
$C _
9 42 l l _li___ _ _
1 I e y-f ,
. STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDAT I
)) i i 6' c
. SECTION: RECO MENDATION #2- (Pef: 41) .!
Data'should be entered into a computerized data base as early in the. event las-possible and the data base should be made~available to the appropriate federal j 1
. and state agencies to enable them to more easily assist in.the evaluation of' j
. health ef fects.- - >
. Discussion:
Environmental monitoring data, analysis would be part of the DOE response as - . f discussed in Section 6, . Recommendation #1 (REF: 40). Therefore, no action is l required if this recommendation concerns environmental data. Other types of :( data would need to be'considere:i on a case?by-case basis. .. ) l1 a 4 % gr . 8 e 4, I { d 1 L. . . . 1 r . V I l l
.. 1
- ]
-. I
?r_ j l
l 43 !
-----___-___--_a
L' . . MI STAFF RESPONSESITO THE SEQUOYAH ACCIDENT. LESSONS LEARNED GROUP.RECOMEN0ATIONS. I SECTION: 6. REC 0mENDATION #3 (Ref: 42)' ; i Recognizing ttie need to issue the report of .the assessment of: the short-term health effects promptly, a schedule _should be established within that. report to ensure.the assessment and followup of the longer range effects. The_latter should be' included in a supplemental. report. -= EL Discussion: The licensing staff generally' agree with this recommendation. When the~ Health Effects Reports were issued, arrangements were made :for the
. licensee to perfom followup testing of the environment (soil and vegetation) and. personnel. A' supplemental; report was not anticipated, but could be issued if the followup' testing so: indicates.- _.
Schedule:
' ~.
-* " .Sequoyah Fuels, with NAC. oversight, completed taking the followup' environmental 1
. samples in May. . These results should be available by September. -As recommended !
~' by the Health Effects report, personnel sampling will continue for at least t two. year period.
. 7. - -
I
-V . :.
O i 44 J l
r" ' U51615 s , STAFT RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECO M NOATIONS'
~
3,. 1 j j t{ SECTION: 6. REC 0mENDATION #4- (Ref: 43) u 1 3 ':s 1
' Additional consideration'should be' given to the intended audience for the .
reports. Because of the potential impact on plant employees.and 5e~arby '
.: 't residents,' the report.(or at least. the Executive Summary) shouldtbe . '
l b. written in language understandable. to the general- population. Sufficient copies of.the report should be made available in the local area to enable !
' interested persons'to obtain them.
.)
Discussion: - o i
'We understand and appreciate the comment.
~
It is difficult' to produce a consensus-report, written by techincal people,.which is necessary to make 1 technical decisions on 'a very short time frame, and make it readily understand- ' able to the general population. ;The first order ofLimportance is to state the j
~'
1 technical facts' accurately in a way which professionals understand them and can take action'. Reports aimed at the public tend to be less precise. However, if
- such:a task comes up. in the future, consideration will .be.given. to such options. !
as hiring.a technical editor from the outset to develop a version'for public-
,. consumption. '
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TS AFF RESPONSES TO THE-SEQUOYAH ACCIDENT LESSONS LEARNED GROUP, RECOMMENDATIONS
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.. SECTIONi 7 RECOMMENDATION #1 (Ref: 44 -
A formal system should be developed within the'0ffice for Analys W and Evalua-tion of Operational Data (AE00) for obtaining, evaluating and disseminating
. 'information.and reports concerning incidents involving NRC lidinled activities L. ,
, and for. DOE and foreign. facilities.' This also would permit'AE00 to establish a l
[ more complete database of information for use in NRC-licensing and inspection
. programs, and in the develoriment of requirements for training and operational ~
procedures.
- l. , ,
! ;0iscussion: JAE00 already has.a system in place to receive reports of. events submitted ' by NRC, licensees. ..These reports are normally entered-into the Reactor Information Distribution System (RIDS) by the region; depending on the category l: '. assigned to.the event in the RIDS, NMSS and:IE receive copies. ' Reports from ! ___ Agreement State' licensees are received from State Programs. ~The.LLG Report .
~~~
points'outithe: fact that events _at DOE and foreign facilities may be of " r interest.:'AE00' agrees that non-licensee events atLD0E and foreign 1 fuel' cycle , ; _% Land large' material. processing plants may provide valuable operational data - x - applicable to NRC licensees ~and the regulatory process. i Approach: 'D ~
. AdOD wi11. review and revise, as necessary, its system for obtaining and
' disseminating information.from reports concerning certain 00E and foreign !
facilities, and NRC licensees. This review will consist of the following
. actions: 7
'l
~
(a),' Contact DOE to arrange to have NRC receive, reports of events at their fuel- cycle and material processing facilities. 4 m- ~ (b) Contact International Programs to discuss >how best to meet T our need to receive, on a timely basis, reports of events at - e foreign fuel cycle and material processing plants. (c) Review the Radiological Contingency Plans. submitted under the NRC Orders (1980) to determine what events licensee's themselves + track.
,(d) Contact Inspection and Enforcement to' discuss how best to obtain information on events that certain nonreactor licensees themselves track. ,
Nhentheaboveactionshavebeenundertaken,AE00willdevelopanh00 procedure covering domestic and foreign event reports at fuel cycie and large materialprocessingplantstoassurecollection,analysisandfee)backofthe events. 46 3 _?--_____-____.______-_-
- - - - ~ - ~ ~ ~ ~ ' ~ ~ ~ ~ ~ ~ - ~
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1' g -^ f 1 iSTAFF RESPONSES 1TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDA i
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'S'chedule: >
~
, . , . ,, .. . ?' J -
e - m Sin' ce items (a)T (b), 'and-(d),:may require actions by other\ organizations 1for completion,' AE00' can provide completion dates only for our' portion of these'e r
.1 " { -
etforts.. ' ** L . ' u.
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(a).'. Contact DOE . . . 7/15/86
~ .Begin Receipt la'nd Screening ;0 pen
- of DOE Data (b) Contact OIP. .
7/15/86 ' ,
'i
Enhanced Receipt and' Screening 'Open of Foreign Data
.y ;
..(c), Review Radiological 8/15/86 ,- >' '4 97 ; Contingency Plans "F" "4-L(d) Contact IE. :8/29/86- o i
' Enhanced Receipt of Domestic s .. . ; 7. ... :0ata ~
- s, Release'AE00 Procedure. 10/30/86 j
. - Resource Requirements:.
> y ~" '~ Item
~
a , 16 hr E .- b 24 hr t c 160-.hr d- 24 hr m: - AE00 Procedure- 160 hr T ~
. /
Ongoing 160 hr/yr 1 l3-I, I I
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. LSTAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS-n SECTION: 7 RECO>NENDATION #2 (Ref: 45)
'e.
The requirements and. guidance for reporting potentially sign 91'ca4L tVen1;s ' ate - ~ fuel facilities and at certain other materials licensees should be revieiledito ensure that all potentially significant events' are reported to NRLj .% p , i ' n ' 4 - Discussion: ~
- - -* * + -
)
-The reporting requirements for' nonreactor' licensees are embodied in a number-of sections of 10 CFR Parts 20, 30-35, 40, 50 (reprocessing plants), 70-73, and i 150, or in license conditions. . Generally, reporting requirements for incidents !
are limited.to those in 10 CFR 20.403, some of which are duplicated in other sections of the regulations. By'and large,,the reporting requirements have fairly high thresholds, and~ represent requirements to report. events that have 1 occurred (or are threatening to occur) and that have. had some impact.- Precursor .
., events per 'se may.not' fall into existing reporting requirements. l 3 . ,.
-~~ .
' At this time', there is not'an existing database to demonstrate whetherfdifferent s
o' reporting requirements-would result in reports of significant precursor events.
~ '
v - Approach:
.l Changes in reporting requirements can only be effected through changes in regulations and as such, represent long time line items. Before a commitment.
T" to. change regulations can be.made, authority to undertake rulemaking must be l I
'obtained from the EDO.
l s* Using information generated in-response to Section 7 Recommendation 1. AE00 will develop, in conjunction with NMSS, IE, and RES: a definition of those ! nonreactor licensees for which revised reporting requirements might be appro-priate; a preliminary set of revised reporting requirements; and either a draft ., J of.the letter to the EDO~ requesting authorization to initiate rulemaking, or an m. analysis of why changed requirements are not needed.
~ '
RES will undertake submission of the request to the EDO, and follow on. All efforts on this task are long-term. il Schedule: Start work September 1,1986 Provide draft letter to RES January 31, 1987 l P e k N' V-48
STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP . RECOMMENDATIONS Resources Requirements: AE00 .560h I
$ I: '
NMSS - (80 hela '". T ; ci IE (80 hr)/ - * '
- RES 'l24 hr) ,* ./ ,,
Note: No resources budgeted for rulemaking. i O
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I-49
5 l , p , 1 STAFF RESPONSES TO.THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS' L 7
'SECTION: 8.1. RECOMMENDATION #1 (Ref: 46)
A Standard Review Plan .dd -review'.of, fuel facility license appiifations '. including those for UFe 'c'onversiorf, f'acilities, should be establisJi'ed, implemented and maintained? Licensing guidance should also mosef efini-tively identify those ar'ste of anJappli't. ant's operations which require the development and implementation o> pPocedures and formalized training. This guidance should be in sufficient detail to permit the applicant to' develop an acceptable program. Discussion: ' The staff agrees with this recommendation, and has an ongoing effort to develop standard review plans (SRP's) for all fuel cycle licensing activities. However, c6nsidering the upgrading that is taking place on the only two UFe plants r through the license reanalysis process, the SRP and guides in this area are l- considered L lower priority. H. . Approach: l .
~ .
The recommendations contained in the Lessons Learned Group Report and appropriate recommendations from the group currently evaluating the licensing and inspection of materials licenser will be considered in the development of'
.y. SR.o's and the revision of Standard Format and Content Guides (SFC). .~ Schedule:
Complete draft SRP's for safety reviews: 01/01/88 Complete draft SRP's for Environmental reviews: 01/01/88
. Revise SFC Guides 03/01/88 Complete Final SRP's 05/01/88 l
9 S l' . 50
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4 . p -STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS.LEARMED GROUP RECOMMENDATIONS 1
.SECTION: 8.1'. RECOMEN0ATION E2 ~(Ref: 47) j l
-116.4 *should ensure'that l license reviewers have sufficient;techn'iial capability j to'~mdre' bfoadly ev'aluate,the' indirect effects of process:equipmenC facilities < , )
and peaced% res on radiological safety.1 . Such Lassurance can be 4bgined by ' l
!# 'increising tRe training and qualifications't. 'ndividual reviewers, contracting j
- for' outstde.1xpertise, or increasing the use s other IRC personnel with the necessary. expertise.: ,
.h . Discussion: #
. We agree.with this' recommendation,. and believe that our existing staff and
- contractors have sufficient and varied expert'ise and operational . knowledge of.- j major. fuel facilities to conduct such reviews. In recent years, however, since 1
!al1Joff the fuel cycle facility. licensing has 'been done for the renewal of.
' existing licenses, less emphasis has been placed.on operational safety reviews f
< except as they relate to. nuclear. criticality or radiation' safety. .In future
. renewal reviews,l operational safety will be reemphasized. The matter of staff
- . . qualifications _ is also being examined by the Mater,ials Safety Regulation Review v'
Study Group which might also have recommendations in this area. The final
. approach will take this into account.
4 Approach: ' t" The Format and Content Guides and Standard Review Plans will be revised to
' reemphasize operational safety.
L .
- IMSS'has asked IE to consider an HMSS/IE/ Regional onsite performance assessment team review that would combine same aspects of both SALP and PAT. This tehm'
- . ' inspection would be performed in conjunction with the-license renewal review. .3 This would also be an opportune time to evaluate over all process safety. NFS 7
Erwin, Tennessee, has been chosen to. test this approach. Current plans are to
.g - conduct this assessment at NFS in early 1987. With respect to training, as
'" qualified experienced ' staff are replaced by new employees, needed specialized.- !
training will be considered on a case-by-case basis. This 1s currently being i L- ' done in the area 'of nuclear criticality,' for example. Schedule: Team Assessment of NFS: March 1987 j
- - . Evaluate Test
- June 1987 l
Final Plan: August 1987 ! ~ Revise'SFC and SRP: March 1988 (See REF: 46)
- l. ..
The review of overall process safety for the other fuel facility licensees ' < will take place at the time of license renewal. r- ! s : Resource Requirements: Ir-Unknown until after test. 51
- 4 O'.._.----.---_-..--. '2-.
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STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP,RECO MEN 0ATIONS 4 ' SECTION: 8.1. RECOMMENDATION 43 (Ref: 48)
+ , ,
The' current license format used by IMSS should be evaluated to' determine
*- *; ' , . .the:need to more clearly identifyz 3)censee commitments incorporated into n l ' ". a Itcense to ensure: recognition of all applicable commitments, sp'ecifica-tions, and requireinents. '" L - .
- f. %j c,.
?* ' + - gproach:
The staff believe the license requirements are. clear, however there might be. ' i 4 room for improvement. Currently there is an independent panel, the Materials . Safety Regulation ~ Review Study Group,' which'is reviewing the licensing and i inspection of radioactive materials. Action on this recommendation should be-
~
held in abeyance pending. completion of this evaluation. Present schedule for-a completion of this review'is September 1986. . i e
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L STAFF RESPONSES TO,THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDAT10NS l ' o i 4 y SECTION: 8.1. RECOMMENDATION ~#4 (Ref: 49) l r l NRC should review each of the recommendations in Chapter 2 of thTs report ' , l ' and determine whether specific changes should be m Me in license'ye'quirements and licensing criteria. The need for any changes should be co g nicated to applicable NRC,licens'ees and other fuel facilities. ~ Discussion: l The staff agrees with this recommendation, and is addressing each Chapter 2 L recommendation, as appropriate, for Sequoyah Fuels prior to restart, Approach: All Lessons k. earned Group (L'LG) recommendations are beind evaluated to determine to which licensees'they uply. Where changes in license requirements ara indicated for other licensees, those changes will be made. All affected
- - .. licensees.will be sent a copy of the LLG report. The letter transmitting this
- l. information will. suggest that the licensees give serious consideration to the
~
reports recommendations. Each license will be evaluated to determine if . individual recommendations are appropriate. Schedule:
-r -- Copies of LLG Report transmitted to licensees - 7/31/86 .
~
Complete review of all ifcensees - 10/31/86 ,
. Resource Requirements:
~
Un % wn. Impacts of Reprogramming Resource:
- E U1known.
f F 53
3 , .3., , ,
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4 9 , STAFF RESPONSES TO THE'SEQUOYAH ACCIDENT l.ESSONS 1. EARNED GR0lto RECOM ENDATIONS" o LSECTION: 8. 2. - RECOMMENDATION #1 (Ref: 50)- 't Consideration should be given te having the IE Emergency Preparedn(ss 3 ranch - review ra'diological contingency plans for nonreactor facilities. 1se - of: this group could make available the. expertise dev'eioped 'in reyJ ing
', reactor, plans, and c' ould enhance communications with the NRC Opera ons ' Center - {
personnel . '
, Discussion:
IE and NMSS agree with this'reconnendation and both offices will . cooperate in developing a functional statement on the role of IE and the regions in 3 reviewing contingency plans and updates based.on.the requirements of the i new rule. Interoffice resource. adjustments will be made as, appropriate. l
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UKR?l STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS SECTION: 8.2. RECOMMENDATION #2 (Refj 51) TheStandardReviewPlan(NUREG-0810)andtheStandardFormatdn/ Content , i l document (NUREG-0762) should be, reviewed to ensure that they are hfequate l or revised, if appropriate. The radiological contingency plans,fpr fuel l facility and materials licensees should then be reviewed against tht revised guidance to ensure that they meet the acceptance criteria. Approach: The staff are reviewing the contingency plans of fuel cycle and materials licensees to determine their agreement with the recommendations in NUREG-1198. Those found to not be in agreement will be requested to consider this:recom-mendation in updating their contingency plan.
, After the Commission issues a proposed emergency preparedness regulation for fuel cycle and materials licensees, the staff will start to revise NUREG-0810 .-, and NUREG-0762. .
Schedule: _
.~.
The revisions to the contingency plan SR? and SFC and the update of
, licensee contingency plans will be completed within 3 months of the effective date of the final emergency preparedness rule, which is scheduled to be issued 9
't - in mid-1987. ~
k t j e 6 n I r-l l l l 55
l'. , STAFF RESPONSES TO THE SEQUOYAH ACdIDENT l.ESSONS LEARNED GROUP REC 0tEENDATION
, e
' SECTION: 9.1 RECOMMENDATION #1 (Ref: 52)
The'inspectionprogramprocedurercontainedinIEManualChaptIrr'2600shouldbe revised to better emphasize inspection program aspects relative (;trprocedures, hardware, radio, logical and safety personnel training and and radioactive qualifications material control. that indirge{y affect
^
Discussion: Currently the fuel facility inspection program requires inspection of operator training (IE 88010) and operational safety (IE 88020). Approach: ' The two inspection procedures (88010 and 88020) will be revised to provide greater emphasis on operational safety on the plant. An examination of this L' subject under a planned temporary instruction will form the basis for these revisions. _During a 120-day period, inspections of operational safety will be
, conducted at each major fuel facility to the extent that the required topics have not yet been covered by regional inspections during the preceding six
- r. months. The results of these inspections will be helpful in determining the details of the planned inspection procedure revisions.
Schedule: ,
.g. ..
l Complete inspections under the temporary instruction: March 1987. } Issue revised inspection procedures: June 1987.
. Resource Requirements:' '
No additional resources are required. Impacts of Reprogramming Resource: ' I Resources will be diverted from the normal routine program to conduct the opera-tional safety inspections. In FY 1987 and future budget years 8.3 SY/ plant have been requested to cover increased attention to operational safety. F
~
56 i L- _ _ _ _ _ _ - - _ _ _ _ _ _ - - _ _ _ - - - - _ - - - - - - - - - - - - - - - - - - - - - - - - - - - -
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g l STAFF RESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP. RECOMMENDATIONS SECTION:- 9.1 RECO>NENDATION A2 (Ref: 53) .. , Anticipated inspection eesource expenditures allotted-by IE for %rjor fuel # facilities should be clearly identified for~each individual fagility, rather than being identified collectively, and reassessed with considerRion'of. - '
. variations.in complexity of facility operations'and associated hazards that directly or indirectly affect radiological' safety. !
Discussion: The information on resources allotted for each major fuel facility is avail-
- able and will be.provided to the regional offices. The allocation for each ~!
,'. ,. major facility was based on the complexity, size, and degree of hazard offthe a- ' operaticn and the corresponding inspection time required to carry out the NRC
, inspection program for the facility. Regional offices have'the. freedom and !
-i l responsibility under. the pertinent IE Manual Chapter (2600) to expend those '
.y,'res6urces as needed depending on t e inspection and enforcement history of a.
'y facility, the numuer of: incidents and allegations involving the facility' and other conditions that indicate the need for more, or for. lass inspection.
~ .
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.- Approach. -
k The L resource allotment for major' fuel facil: ties will be provided to each
-g -- region as an attachment to the regional resource. tables. -
i
. , i
- Schedule:
- August 1986.
~
. Resource Requirements:
NONE- '
.L
} Iepacts of Reprogramina Resource:
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4 1 d I J 1 '[ - r f i A C- , 1 i I L 57 5
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STAFP RESPONSES T0eTHE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP REC 069 TEN 0ATIONS' 5 i I SECTION:' 9.1 REC 069ENDATION -#3 (Ref: 54)
':e Efforts. should be made by regional' offices to assure continuity fAJ.he
, designation of inspectors assigned to ' inspect major fuel facilities., ,
- n_. .
Discussion: i i L IE agrees-that a fuel; facility inspector should be familiar with the processes '
- . and' license conditions for the fuel; facilities he/she inspects. Assigning an i inspector to the same plants for a reasonable number of years is an appropriate-
.way to ensure achievement of that objective. With the possible exception of- l L
Regien IV,.each region'has assigned one inspector who has had overallLresponsi- ! bility for the safety inspections .at the fuel facilities in the region for.a- !' number of years. In addition,.at the Nuclear Fuels. Services plantiin Erwin, . . Tennessee, the same resident inspector has been assigned since 1979. ' Consequently,:P _' there has been a considerable. continuity in the inspection process over the- ! years at the fuel facilities. e
,~
.l 5 , Approach:
In the revision to its fuel cycle 7nspection program, IE will state'in IE l
-Manual. Chapter 2600 that training and assignment of fuel facility inspectors' l should be of sufficient duration to ensure that inspectors are' a, appropriately , .. -fasiliar with the plant to be inspected and the associated license conditionL t" At the same time, the' program will also be revised to ensure that, for regions , *- 4 with small fuel facility programs, the inspections by the one.or two knowledge- ;
able people from the region will-be supplemented from time to time with inspection ~ staff from other regions and/or headquarters. In this way' the fuel facility inspection program will benefit from continuity of regional inspectors while also. benefiting from the possible new insights that an inspector from outside the. region will bring to the inspection of'a ;
,_ particular plant. ' + . .
i a I f I i i _a p. g e . l 1 I t 58
Di! AFT 4 .
~
STAFF RESPONSES O'THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP,RECO MENDATIONS ' s A SECTION: 9.2 RECOMMENDATION #1 (,Re f: ' 5,5) Personnel associated with the establishment and implementation of4nspection i programs for. major fael- facilities should be trained in aspects 6f the i processing and handling of licensed material that directly or 'fh84rectly affect . radiological safety and control of the material, as well as radiological contingency planning. ' l t . ,, I EMscussion: ,
. . m
- See. Section 9.2, Recommendation #2, (REF: 56), which covers generally the same-subject.
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'SECTION: 9. '2 - ' RECOMMENDATION #2 (Ref:- '56) . , , , , ,
, 1Thelinspector qualification' procedures. contained in IE Manual Chdter 1231. ' l L . Inspector Qualifications, should be amended to broaden thefrequireTqualifica-tion and forma'l training of fuel facility;inopectors to develop.cte.rall expertisej n the facility' operations. , u 1 ' Discussion: ' IE Manual' Chapter 1231 contains basic. training requirements for, fuel facility, - o -{ inspectors. . :IE had'previously considered formal training courses for. fuel- { m : facility inspectors. This training was. discussed with various contractors-who M 0 might supply the necessary instruction,- however, it could not be conducted by' *
-any of the persons contacted due,to the uniqueness of the processes of each ' #,
J
'n facility that would be inspected.. The number of' personnel that would.be j involved in such a course would be small,. making it difficul_t.to' justify the '
..' ...> t cost of. designing a course that would be. taught infrequently..
]1 ,;.. l Approach: -
p~
}
The regionalioffices will contiinu'e to train new personnel.by accompanying experienced inspectors on fuel facility inspections. IE will set up a series ]j of in house-seminars for experienced personnel and new personnel for discussion 1
' .. of:the plant processes'and associated operational safety problems. The IE . I
-t--'
.Mahual Chapter on training requirements will be reviewed and revised to take-
, advantage of any" additional training opportunities. This is an interim measure. . The Materials Safety Regulation Review Study Group is also looking
-into this matter and a final plan will be developed after their' report is received. ,
' Schedule:
- g. Base init'ial seminar on results of operational safety inspections to be requir~ed
., by an,IE temporary instruction. ' , 7 o . .
Inspections to be completed: ' Decerber 1, 1986 , 1
~
Seminar to be conducted: January 1987 ' Revision to IE '1231: January 1987 ,
' Resource Requirements:
For development and conduct of 1st. seminar: 0.2 SY R t
. 6 ,
SV ( l 60
4,4 m . i
? , STAFT RESPONSE _S TO THE'SEQUOYAH ACCIDENT LESSONS LEARNED GROUP RECOMMENDATIONS
.s I
SECTION: 9.2 RECOMMENDATION #3 (Ref: 57) r / .+ Technical publications a'nd infors& tion relevant to the' technology mincluding ' i standards'and processes employed in fuel facility. operations, should be , L , referenced 'in IE inspection program procedures to provide guidenetto '
- inspection personnel.;
Discussion: + Current fuel. facility inspection procedures contain referencer to partinent ...
. Regulatory Guides'and NUREGs.. . , ,
n a '
Approach: ,,
A list will be developed-of other references that may be useful in the conduct l _; :of the inspection' program. The inspection procedures will be revised to list these additional references. ' Schedule: >
).
~
," Implementing this recommendation has a low priority compared to other tasks the t.
staff has underway. Issuance of revised inspection.proceduros: March 1987. w.
. 7 e Resource' Requirements: ,
None above norma 1' staffing. Impacts of_ Reprogramming Resource: . tl ; None. i V ; . ; e fj t
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STAFF kESPONSES TO THE SEQUOYAH ACCIDENT LESSONS LEARNED GROUP' RECOM1 a ? .
, , .i. .{
SECTION: 9. 2 - RECOMMENDATION #4 (Ref: 58) 1 Since the current number of inspection personnel with fuel faci 1{ty expertise and experience is limited, better utilization of these personnel Tphears 3 necessary. This can be accomplished by interregional utilization of such i
., personnel, consolidation.of fuel facility inspection responsibil'Ty into fewer regions, or conduct of periodic team inspections by the region using appro-priate specialists. t Discussion: 3 I
t This recommendatico will'be taken 'under advisement. This is a matter which is. also being examined by the Materials Safety Regulation Review Study Group. , After their report is received, a review will be undertaken to determine the mo'st advantageous method to utilize the inspection expertise available for fuel i cycle facility inspections. , i . g T 4 9 . y_. . t l i
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