IR 05000327/1988033

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)

Text

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NUCLE AR REGULATORY COMMISSION REGION il 101 MARIETTA STREE T. '. .f ATL ANT A, GEORGIA 30323 5'

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...*   ggg 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

, emergency prepcrodness, and included review of the following progranvr.atic elemente.: (1) emer cocrunications, (3) gency detection and classification, (2) notifications andshift s assessmen 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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I REPORT DETAILS 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

   * 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 personne l t

NRC Resident inspector

   * P. Ha nnon
   * Attended exit interview       '

l Emergency Detection And Classification (82201) 1 Pursuant to 10 CFR 50.47(b)(4); 10 CFR Part 50, Appendix E. Sections I 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, , i 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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.l untimely classificatio 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  ; j ' - HUREG-0654 and the REP. The inspector noted that many of tha EAls were based on parameters obtainable from Control Room instrumentatio ' The inspector verified that the licensee's procedures included criteria  ; for initiatton of notifications to offsite agencies and for development of ,

protective hetion recommendations. The notification procedures required 3 that offsite notifications (via the licensee's Operations Duty Specialist , 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 classificatio [ ]j notification, and protective action recomendation [ f j l Waik-thrcugli evaluations involving accident classification problems were

conducted with two Shif t Operations Supervisor All personnel l 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 t

! The inspector reviewed licensee records, including Control Room journals,   I pertaining to all emergency declarations at Sequoyah since January 1,
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198 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): j  ! 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 .

) 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  ! l i l l l l l I

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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 confirmatio 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: cancelle l downgraded, or upgraded as required. "   l

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

instruction, licensee personnel consumed 64 minutes investigating and r , discussing the validity of the alarm, according to the Control Room lo :

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- 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. ;

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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 identifie j t j 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)  !

in the event of an emergenc ; 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  ! t

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

onsite emergency organization, corporate support organization, and offsite 1 agencies.

- The management control program for the Alert and Notification S"stem was ! reviewe 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 ! l l ! w- - . - . _ _ . . _ - _ - . - - _ - - - _ - . _ - - _ - - -

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October 1987 to June 198 The records showed that a silent test was conducted biweekly, a growl test quarterly, and a full-cycle test monthl The testing regime exceeded that specified in appendix 3 to NUREG-065 The licensee had completed installation of 72 new sirens intended to ' eliminate the need for mobile-siren routes in the 5- to 10-mile annulu Full-scale preoperational testing of these Jnits started in June 198 ; Communications equipment in the Control Room, Technical Support Center (TSC), and Central Emergency Control Center (CECC) was inspecte 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 procedure ; 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 test No violations or deviations were identifie . 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 manne 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 organitatio ! The APS was a computerized, menu-driven system which activated radio pagers via one transmitter ensite and several offsit 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 goal 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 re 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 organizatio No violations or deviations were identifie __-

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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 function 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 progra 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 personne 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 trainin 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 are 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-makin No violations or @viations were identifie . 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 releas l l

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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 CEC ; i 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 activitie The inspector requested and observed a dose assessment walk-through by an individual designated as responsible for dose projection at the CECC during an emergenc The individual demonstrated the ability to make such calculations using a computerized system, and was able to produce acceptable results within 10 minute No violations or deviations were identifie . 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 verificatio . 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 belo 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. }}