ML20153C472

Insp Repts 50-327/88-33 & 50-328/88-33 on 880711-15. Violation Noted.Major Areas Inspected:Emergency Preparedness,Including Review of Listed Progammatic Elements

ML20153C472
Person / Time
Site:	Sequoyah
Issue date:	08/22/1988
From:	Decker T, Kreh J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20153C444	List: ML20153C441 ML20153C463 ML20153C472
References
50-327-88-33, 50-328-88-33, NUDOCS 8809010156
Download: ML20153C472 (7)

See also: IR 05000327/1988033

Text

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                                                101 MARIETTA STREE T. N.W.
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         Report Nos.:         50-327/88-33 and 50-328/88-33
         Licens:e: Tennessee Valley Authority
                         6N38 A Lookout Place
                         1101 Market Street
                         Chattanooga, TN 37402-2801
         Docket Nos.:         50-327 and 50-328                      License Nos.:                                                                                                                        OPR-77 and DPR-79
         Facility Name:         Sequoyah Nuclear Plant
         inspection Condu'ted: July 11-15, 1988
         Inspector:              4HU-         ,   k tLt        -                                                                                                                                                  .b b db
                                                                                                                                                                                                                  Date Signed
                        J.(.jKreb                            ,
         Approved by: e            ?n a           d ok                                                                                                                                                            8-/6'f6
                                                                                                                                                                                                                  Date Signed
                          T. R. Decker, Section Chief
                          'livision of Radiation Safety and Safeguards
                                                         SUMMARY
         Scope:      This routine, unannounced inspection was conducted in the area of

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         emergency prepcrodness, and included review of the following progranvr.atic
         elemente.:       (1) emer
         cocrunications,          (3) gency detection and classification, (2) notifications andshift s
         assessment.
         Results: One violation was identified:                    failure on February 8, 1988, to
         adequately implement procedure IP-1, "Emergency Plan Classification Logic" (see
         Paragraph 2 below for details). No deviations were identified. The findings
         of this inspection indicated that the licensee was adequately prepared to
         respond to an emergency at the Sequoyah Nuclear Plant,                                                                                                                 it was noted however,
          that there was no general oversight system in place to assure all required
          training was completed (see Paragraph 5 below for details).
    8809010106 000822              7
      DR      ADOCK 0500

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                                                                                        REPORT DETAILS
                                                   1.     Persons Contacted
                                                          Licensee Employees
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                                                          T. Adkins, Program Manager (Corporate)
                                                          D. Amos, Chemical Engineer
                                                         J. Chenkus, Jr., Program Administrator (Corporate)
                                                          S. ?,hilders, Shift Operations Supervisor
                                                        *M.     Cooper, Compliance Licensing Supervisor
                                                          D. George, Operations Duty Specialist (Corporate)
                                                          T. Gullette, Lead Duty Officer (Corporate)
                                                        *R. Kitts, Chief Emergency Preparedness Branch (Corporate)                                                           ,
                                                          B. Lake, Supervisor, Licensing Training Section
                                                        *B. Marks, Supervisor Emergency Preparedness Branch (Corporate)
                                                        *T. Noble, Project Engineer, Emergency Preparedness
                                                        *D. Onnsby, Licensing Engineer
                                                        *J. Patrick, Operations Superintendent
                                                          J. Polehn, Health Physicist (Corporate)
                                                        *E. Sliger, Manager of Projects                                                                                      -
                                                        *S. Smith, Plant Manager
                                                          G. Stirling, Shift Technical Advisor
                                                         W. Vanosdale, Shift Operations Supervisor
                                                          D. Wall, ',dpervisor, Exercise Development and Emergency Facilities
                                                              (Corporate)
                                                        *T. Youngblood, Emergency Preparedness Program Manager
                                                          Other licensee employees contacted during this inspection included
                                                          operators, technicians, and administrative personnel.                                                              l
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                                                          NRC Resident inspector
                                                        * P. Ha nnon
                                                        * Attended exit interview                                                                                            '
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                                                   2.     Emergency Detection And Classification (82201)                                                                     1
                                                          Pursuant to 10 CFR 50.47(b)(4); 10 CFR Part 50, Appendix E. Sections IV.B
                                                          and IV.C; and Appendix B to the licensee's Radiological Emergency Plan,
                                                          this program area was inspected to detennine whether the licensee used and
                                                          understood a standard energency classification and action level scheme,                                            ,
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                                                          The inspector reviewed the licensee's implementing procedure IP-1,                                                 !
                                                          entitled ' Emergency Plan Classification Logic." The event classificatiens                                         '
                                                          in the procedure were consistent with those required by regulation and the
                                                          Radiolegical Emergency Plan (REP). The classification procedure did not
                                                          appear to contain impediments or errors which could lead to incorrect or
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         untimely classification.        Selected emergency action levels (EALs)

, specified in IP-1 were reviewed. The reviewed EAls appeared to be ,

         consistent with the initiating events specified in Appendix 1 of                                              ;

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         HUREG-0654 and the REP. The inspector noted that many of tha EAls were
         based on parameters obtainable from Control Room instrumentation.
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         The inspector verified that the licensee's procedures included criteria                                        ;
         for initiatton of notifications to offsite agencies and for development of                                    ,

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         protective hetion recommendations. The notification procedures required                                       3
         that offsite notifications (via the licensee's Operations Duty Specialist

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         in Chattanooga) be made promptly after declaration of an emergency,                                           i

, The inspector discussed with licensee representatives the coordination of J

         EAls with State and local officic15. A letter dated July 5, 1988, from                                        I
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         the Tennessee Emergency Manageroent Agency confirmed that the State had                                       ;

i reviewed and concurred in the EALs for the Sequoyah facility.

j The responsibility and authority for classification of emergency events j and initiation of emergency action were prescribed in licensee procedures

i        and in the REP. Interviews with selected key members of the licensee's                                        .
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         emergency organization revealed that chese personnel understood their                                         i
         responsibilities and authorities in relation to accident classification.                                      [

]j notification, and protective action recomendations. [ f j l Waik-thrcugli evaluations involving accident classification problems were 1

         conducted with two Shif t Operations Supervisors.                                          All personnel
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         interviewed promptly and properly classified the hypothetical accident                                        i

3 situations presenteri to them, and appeared to be familiar with appropriate j classification procedures, i

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!        The inspector reviewed licensee records, including Control Room journals,                                     I
         pertaining to all emergency declarations at Sequoyah since January 1,
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         1988.    The following is a listing of those events which resulted in
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         implementation of the REP (each was classi."ied as a Notification of                                          i
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         Unusual Event):

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         Date                               Description of Event                                                       !
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02/08/88 Seismic alarm received on annunciator panel 1-xA-55-15B [

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         02/09/88          Identified reactor coolant system (RCS) leakage exceeding
 )                         10 gpm                                                                                      j
         02/29/63         Unidentified RCS leakage exceeding 1 gpm
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         04/02/88         ShutdewninitiateduponexpirationofLCO[ limiting                                               '
                          conditionforoperation]timelimit

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)        04/03/88         Pressurizer valve in safety-related system failed to close                                   I
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         04/06/88         Unidentified RCS P.akage exceeding 1 gpm                                                     !
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                 The Shift Operations Supervisor's log for February 8, 1988 disclosed that                    :
                  the alam indicating "SEISMOLOGICAL RECORDING INITIATED" (1-XA-55-15B,                       .'
                 window 22) was received at 12:09 p.m., but a Notification of Unusual Event
                  (NOVE) was not declared until 1:13 p.m. Receipt of the referenced alarm
                 was specifically listed in procedure IP-1 (Revision 12 dated Octoter 5,
                  1987) as an EAL associated with a NOUE classification. General direction
                 was provided in Section 3.0 of IP-1, including the following:                                ;
                               "If there is any reason to doubt whether a given condition has
                               actually occurred, the shift enginear or the Site Emergency Diretor
                               will proceed with the required notification without waiting for
                               formal confirmation.                If followup investigations show that a
                               suspected condition has not occurred, is less severe, or more severe           l
                               then originally suspected, the classification will b: cancelled.               l
                               downgraded, or upgraded as required. "                                         l

. Instead of imediately declaring the NOVE in accordance with the quoted 4

                  instruction, licensee personnel consumed 64 minutes investigating and                       r

, discussing the validity of the alarm, according to the Control Room log.  :

The NOUE was finally declared af ter the seismic alarm was determined to  !

                 have been spurious; this action was also not in accordance with the
                 requirements of IP-1.                       Failure to irrplement procedure IP-1 in a timely j
                 manner during the referenced event was identified as a violation of                          :
                 Technical Specification 6.8.1.e.                                                             ;
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! Violation (327,328/88-33-01): Failure on February 8, 1988, to Adequately i

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                  Implement Pror.edure IP-1, "Emergency Plan Classification Logic."

i l l One violation and no deviations were identified. j

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j 3. Notifications and Comunications (82203)  ;

                 Pursuant to 10 CFR 50.47(b)(5) and (6); 10 CFR Part 50, Appendix E,                          !
!                Section IV.D; and Sections 5 and 6 of the REP, this area was inspected to                    l

) determine whether the licensee was maintaining a capability for notifying  ; J and communicating with its own personnel, offsite supporting igencies and l c authorities, and the populace of the 10-mile emergency planning zone (EPZ)  ! 3

                  in the event of an emergency.                                                               ;

j The inspector determined by review of applicable procedures ano by I

                 discussion with licensee representatives that adequate procedural means                      ;
                 existed for alerting, notifying, and activating emergency response                           !
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personnel. The procedures specified when to notify and activate the

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                 onsite emergency organization, corporate support organization, and offsite

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                 The management control program for the Alert and Notification S"stem was

! reviewed. According to licensee documentatien and discussions with

licensee representatives, the system consisted of 35 fixed sirens and

! numerous mobile sirens. Maintenance of the system was provided by the i

                 licensee. The inspector reviewed tiren test records for the period

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        October 1987 to June 1988.     The records showed that a silent test was
        conducted biweekly, a growl test quarterly, and a full-cycle test monthly.
        The testing regime exceeded that specified in appendix 3 to NUREG-0654.
        The licensee had completed installation of 72 new sirens intended to                               '
        eliminate the need for mobile-siren routes in the 5- to 10-mile annulus.
        Full-scale preoperational testing of these Jnits started in June 1988.                             ;
        Communications equipment in the Control Room, Technical Support Center
        (TSC), and Central Emergency Control Center (CECC) was inspected.
        Provisions existed for prompt communications among emergency response
        organizations, to emergency re!.ponse personnel, and to the public. The
        installed communications systems at the emergency response facilities
        listed above were consistent with system descriptions in the REP and its
        implementing procedures.                                                                           ;
        The inspector reviewed licensee records for the period March-June 1988,
        which indicated that comsnunications tests were conducted at the required
        frequencies. Licensee records aico revealed that corrective action was
        taken on problems identified during communications tests.
        No violations or deviations were identified.
 4.     Shift Staffing and Augmentation (82205)
        Pursuant to 10CFR50.47(b)(2) and Section IV of Appendix E to
        10 CFR Part 50, this area was inspected to determine whether shif t
        staffing for emergencies was adequate both in numbers and in functional                            l
        capability, and whether administrative and physical means were available
        and naintained to augment the emergency crganization in a timely manner.
        Shift staffing levels and functional capabilities of all shif ts were
        reviewed and found to be consistent with the guidance of Table B-1 of
        NUREG-0654      The licensee used an Autenated Paging System (APS) for
        expediting the notification of the plant emergency response organitation.                          !
        The APS was a computerized, menu-driven system which activated radio
        pagers via one transmitter ensite and several offsite.                             Weekly,
        unannounced tests of the APS were conducted, with variance in the day of
        the week (excluding Sunday) and the time of day (between 5:30 a.m. and
        10:30 p.m.). The APS, activated by the Shif t Operations Supervisor's
        clerk, appeared to be effective in meeting Table B-1 goals.
        The inspector discursed staff augmentation times with licensee                                     ,
        representatives, who provided documentation of a study done in
        October 1987, to confirm that Table B-1 augmentation times could he ret.
        The inspector reviewed records of the weekly APS tests, the results of                             !
        which provided a continuing demenstration that staff augnentatior times                            t
        would be generally consistent with Table B-1 guidance in the event uf an
        antual activation of the emergency response organization.
        No violations or deviations were identified.
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   5.     Knowledge and Perfccmance of Duties (Training) (82206)
          Pursuant to 10 CFR 50.47(b)(15) and Section IV.F of Appendix E to
          10 CFR Part 50, this area was inspected to determine whether emergency
          response personnel understood their emergency response roles and could
          perfccm their assigned functions.
          The inspector reviewed documentation of the emergency response training
          program, including training precedures and selected lesson plans, and
          interviewed members of the instructional staff. Based on these reviews
          and interviews, the incpector determined that the licensee had established
          a femal emergency training program.
          The Emergency Preparedness Program Manager was directly responsible for
          providing required specialized initial training and annual retraining to
          Site Emergency Director designees and personnel assigned to staff the
          Technical Cupport Center ar.d the Operations Support Center (training
          modules 1.'2, 2.1, and 2.2, respectively) .      Use of a personal computer
          system was recently implemented to track the training of those personnel.
          The call lists contained in procedures IP-6 and IP-7 were updated
          quarterly against the computerized training roster. The inspector
          concluded that adequate management oversight existed with respect to the
          training of the TSC and OSC staff. Training of all other nonlicensed
          plant personnel with assigned roles in the emergency response organization
          was the responsibility of the various work groups to which those
          individuals belonged. The result of this arrangement was that licensee
          management did not exercise oversight to assure that all personnel with
          derignated emergency response functions received the required training.
          This matter was discussed with licensee representstives during the course
          Of the inspection and in the exit interview as well. The licensee had
          previously recognized that tracking of required training was not being
          accomplished satisfactorily and was in the process of considering
          alternatives for improvement in this area.
          The inspector conducted walk-through Ovaluaticns with selected key members

j of the emergency organization. During these walk-throughs, individuals i were given various hypothetical sets of emergency conditions and data and l asked to talk through the response they would make if such an emergency

          actually existed. The individuals demonstrated f amiliarity with emergency
          procedures and equipment, and no problems were obsersed in the areas of
          emergency detection and classification, dose calculation, and protective
           action decision-making.
          No violations or @viations were identified.
   6.     Dose Calculation and Assessment (82?07)
           Pursuant to 10 CFR 50.47(b)(9), this area was inspected to determine
          whether there was an adequate method for assessing the consequences of an
           actual or potential radiological release.
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             The inspector reviewed TI-30, a procedure for manually calculating release           ,
             rates in the event the plant computer was not available. The calculated
             release rate, along with any actual measurements in the environs, would
             be und to detennine the emergency classification in accordance with the
             EALs in IP-1. Dose projections would be performed at the CECC.                       ;
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             The inspector discussed the dose projection models used by the licensee
             and the State of Tennessee. The models used by the State and licensee
             were different under certain conditions. According to a licensee
             representative, the reasons for the differences, as well as their impact,
             were understood and taken into account during assessment activities.
             The inspector requested and observed a dose assessment walk-through by an
             individual designated as responsible for dose projection at the CECC
             during an emergency.     The individual demonstrated the ability to make such
             calculations using a computerized system, and was able to produce
             acceptable results within 10 minutes.
             No violations or deviations were identified.
      7.     Action On Previous Inspection Findings (92702)
             (OPEh) Violation 327,328/88-18 01:         Failure to Provide Annual REP
             Retraining to a Member of the Emergency Response Organization. In the
             licensee's rasponse of May 13, 1938, 4 the Notice of Violation, the root
             cause of the violation was identified is "a failure to verify that all
             designated emergency respense personnel receive the required training."
             As indicated in Faragrapn 5 above, the corrective steps taken by the
             licensee were not sufficiently comprehensive to provide for such
             verification.
      8.     Exit Interview
             The inspection scope and results were sumarized on July 15, 1988, with
             those persons indicated in Paragraph 1. The inspcetor described the areas
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             inspected and discussed in detail the inspection results listed below.
             Licensee representatives expressed coments dissenting from this finding,
             while indicating that they intended to analyze it further. Although
             proprietary information was reviewed during this inspection, none is
             contained in this report,
             item Number                            Description and peference
             327,328/88-23-01                       Violation:   Failure on February 8,
                                                    1988, to make an emergency declaration
                                                    in a timely manner (Paragraph 2).
             Licensee management was informed that a previous violation, discussed in
             Paragraph 7, would remain open because the corrective action to date did
             not fully address the root cause of the problem.

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