IR 05000327/1997015

Insp Repts 50-327/97-15 & 50-328/97-15 on 970922-29.No Violations Noted.Major Areas Inspected:Emergency Preparedness

ML20198N452
Person / Time
Site:	Sequoyah
Issue date:	10/23/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198N450	List: IR 05000327/1997015 ML20198N446
References
50-327-97-15, 50-328-97-15, NUDOCS 9711040298
Download: ML20198N452 (13)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos: 50-327, 50--328 License Nos: DPR-77. DPR-79 Report No: 50-327/97-15, 50-328/9/-15 Licensee: Tennessee Valley Authority (TVA)

Facility: Sequoyah Nuclear Plant Units 1 & 2 Location: Sequoyah Access Road Hamilton County, TN 37379 Dates: September 22-29, 1997

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Inspector: G. Salyers. Emergency Preparedness Specialist Approved by: K. Barr, Chief. Plant Support Branch Division of Reactor Safety ENCLOSURE 9711040298 971023 PDR ADOCK 05000327 G PDR

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EXECUTIVE SUMMARY

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Sequoyah Nuclear Plant NRC Inspection Report Nos: 50-327/97-15 and 50-328/97-15 This routine. announced inspection was conducted in the area of Emergency Preparedness by an Emergency Preparedness Specialis o Emergency response facilities and equipment were satisfactorily

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maintained (Section P2.1).

, o The effectiveness of EPIP 17. Appendix 1. OSC inventory audit had decreased (Section P2.1)-

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-o In testing emergency response equipment, the licensee was limiting

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their focus to the systems overall performance and not including an evaluation of the system at the component level (Section P2.1).

o The Public Notification siren system was satisfactorily tested and maintained (Section P2.2).

o Sirens 45 and 76 had lengthy histories of consecutive unsatisfactory bi-weekly silent test without corrective maintenance (Section P2.2).

o The Emergency Action Levels (EALs) were well organized cr formatted and could be easily used. The EALs appeared to be technically correct and closely followed the industry guidance (Section P3.1).

o Three major errors were identified in the development, review, and approval of Emergency Plan Implementing Procedure -14. Radiological-Control Response. Revision 8 and represents a program weakness (Section P3.1).

o The delay in decla' ring a Notification Of Unusual Event during the October 5, 1996 transformer explosion was considered a weakness in the plant's emergency prepareuness performance. The delay was an indication of weakness in the area of emergency preparedness training for operators, and another example of lack of attention to detail on the part of Emergency Preparedness for not taking corrective action (Section P3.1).

o TRN-30. Radiological Emergency Preparedness Training. the licensee's controlling document for training did not clearly establish training requirement Emergency Response Organization lesson plans were adequate. (Section P5.1).

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-o -Emergency Response Organization exams were not challenging. There was 3 little difference between the different-Emergency Response Organization position exams.(Section P5.1),

o The drill commitments in Section 14. Orills and Exercises of the !

Emergency Plan were met. Completeness of drill documentation had I improved since the last inspection. (Section PS.2)

o Emergency Preparedness continued to receive management support (Section P6.1)

o -The Emergency Preparedness audit was organized and objective and satisfied the requirements in 10 CFR 50.54(t) (Section P7.1)

o The licensee was adequately tracking and resolving drill comments.

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Although documentation had improved since the last inspection, continued attention is warranted. (3ection P7.2)

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Reoort Details l

PLANT SUPPCi_ J P2 Status of EP Facilities, Equipment, and Resources P Insoection Scone i

a. This area was inspected to determine whether the licensee's Emergency ;

Response Facilities (ERFs) and equipment. were adequately maintained in accordance witn the Emergency Plan. Requirements applicable to this area are found in 10 CFR 50.47(b)(8) and (9).10 CFR 50.54(q).

Sections IV.E and VI of Appendix E to 10 CFR Part 50, and the

, licensee's Emergency Pla b. Observations a,nd Findinos The inspectors toured the Technical Support Center (TSC) and Operational Support Center (OSC) and tested telephones, fax machines, and Emergency Response Facility Information System monitors and Computer The inspectors reviewed documentation of tests and audits completed as required for 0-PI-REM-244-001.0. " Periodic Testing Of Emergency Response Facility Communications Equipment " Revision 0, from September 1996 through September 1997. The licensee provided the

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inspectors a bar chart titled " Equipment Failures Surveillance Identified" that displayed the number of equipment which tested satisfactory and the total number of equipment tested in 0-PI-REM-244 001.0. The bar chart indicated a " good" reliability or performance for the equipment tested. When the inspectors asked the licensee for specifics on which equipment components had failed, the licensee stated that specific equipment failures were not readily available, but the information could be retrieved from document control's microfiche. In ensuing discussions with the inspector, the licensee stated that they did not track or trend specifi ?quipment failures identified in surveillances. This indicated to che inspector that tne licensee was limiting their focus to the overall performance of the system and not including an evaluation of the

, system performance at the component leve The inspectors audited several controlled volumes of the Emergency Plan Implementing Procedures (EPIPs) in the ERFs for being maintained up to date. All of the EPIPs audited were up-to-dat The inspectors uced EPIP 17. Emergency Equipment and Supplie Revision 13. to audit the inventories of three emergency cabinets and the emergency lockers in the TSC and OSC. The equipment tested by the inspectors operated satisfactorily and the emergency lockers inventories were complet _

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The inspectors reviewed documentation of completed Appendices (inventory forms) of EPIP 17. from September 1996 through September 1997. _ Although the inspectors found the documentation complete, the inspectors noted examples of lack of attention to details in the inventory forms:

oEPIP 17. Appendix H. TSC. had the licensee verify " SETS" of System Operations Manuals. System Operating Instructions. Annunciator Response Manuals, and Periodic Instructions, that were on the shelves, but neither the Appendix indicated nor the licensee knew how many books were supposed to be in a " SET".

oEPIP 17. Appendix I. OSC. had changed the audit of two Electrical and four Mechanical Emergency Tool Kits from a detailed list of required tools in each bag to simply. "6 Tool Kits and various tools". The licensee stated that the Appendix I was changed as a result of a Quality Assurance audit finding resulting from tool bags not meeting their, inventory requirement " Assorted" was used to specify type and quantity of office and i desktop supplies required in the OSC and TS No significant changes to the facilities were observed by the inspector c. Conclusion The inspectors concluded that the licensee maintained the facilities l and equipment at a satisfactory level of operational readines Equipment performed satisfactorily, Audits of equipment and supplies were completed at the required frequencie The effectiveness of EPIP 17. Appendix 1. OSC inventory audit had decrease In testing of emergency response equipment, the licensee was limiting their focus to the systems overall performance and not including an evaluation of the system at the component leve P2.2 Public Alertino System Insoection Scoce (82701)

This area was inspected to review the licensee's method of notifying the public in the event of an emergency, and the Public Alerting Syste.n test frequency and test data. Requirements applicable to this area are found in 10 CFR 50.47(b)(C). Sections IV.D of Appendix E to 10 CFR Part 50. and the licensee's Emergency Pla _ _ -

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3 Observatj,ons and Findinas The licensee maintained 108 sirens within the Emergency Preparedness Zone for their public alert and notification system. The inspc_ ors reviewed documentation from September 1996, through September 1997, for quarterly preventative maintenance on the sirens, bi-weekly silent test, monthly sounding and an annual sounding of the siren The inspector's review determined that the sirens had been maintained and te.sted at the required frequencies. The 1996 Sequoyah Nuclear Plant siren availability report summary indicated a siren availability of 97.9 percent compared to the Federal Emergency Management Agency's acceptance criterion of 90 percen While reviewing the documentation the inspectors noted that siren number 45 had not satisfactorily completed the bi-weekly silent test since October 1996, and siren number 76 had not satisfactorily completed the test since July 16, 1947. The licensee determined that no work request had been written on either siren. The licensee was only reviewing the system availability factor and was not trending which sirens tested unsatisfactoril c, Conclusion The inspectors concluded that the siren system was being satisfactorily tested and maintained. However, sirens 45 and 76 had lengthy histories of consecutive unsatisfactory b?-weekly silent

, tests without corrective maintenance.

g P3 EP Procedures and Documentation P Emeraency Plan implementina Procedures insoection Score (82701)

The inspectors reviewed the licensee's changes to the EPIPs to evaluate whether changes to the EPIPs were in agreement with 2nd implemented the Emergency Plan. Requirements applicable to this area are found in 10 CFR 50.47(b)(16). 10 CFR 50.54(q), Appendix E to 10 CFR Part 50, and the licensee's Emergency Pla b. Observations and Findinas The inspectors reviewed EPIP 14. Radiological Control Response, I Revision 8, effective date of September 19. 1997. The ability of onshift personnel to perform an offsite dose assessment in the event of a radiological emergency was identified as an issue in Inspection Report 50-327.328/96-04. The inspectors specifically focused on EPIP 14 Appendix E. " Methodology For Projecting Total Effective Dose

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Equivalent (TEDE)". Appendix E provided the user two methods of deriving " Plant Total Gaseous Rad Release"; a computer method and a manual method. If the computer was not available. then the manual method was to be used. It was the licensee's expectation that both methods should give the user the same result. On September 21, 1997, a review of EPIP 14 revealed that, if both methods were performed, the computer method was approximately 20 percent iceer than the manual method. A detailed review of Appendix E revealed two major errors in the procedure:

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l oThe computer method used the dispersion factor (X/0) value from Tl 30 Revision 3. The manual method used the dispersion factor (X/0)

value from Tl 30 Revision oln the manual method. the final calculation of step 4.a. incorrectly applied a multiplier of X1 The licensee could not identify why the errors were not found in the development or review proces The inspectors reviewed EPIP.1. Emergency Plan Classification Matri Revision 23. effective date of July 11. 199 EPIP 1 was the licensee's Emergency Action levels (EALs) based upon NUMARC methodology. The inspectors compared the instrumentation ranges and nomenclature identified in the EALs to the instrumentation in the control room. No inconsistencies were identifie The inspectors reviewed the licensee's event declarations to verify that events were properly classified and notifications were made in a timely manne On October 5,1996, the licensee made a Notification Of Unusual Event (NOUE) emergency declaration when a Potential Transformer in the 500 KV switchyard exploded. The inspectors' review noted the control room had indications and reports of a transformer explosion at 1:13 The fire alarms were secured at 1:37 p.m. and by 1:39 p.m. all control room annunciators were returned to normal. The NOUE (EAL

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4.2. Unplanned explosion within the protected area resulting in visible damage to any permanent structure gr equipment) was not declared until 2:12 p.m. The time line indicated that the NOUE was not declared until 59 minutes after the event was initiated and 33 minutes after the control room was returned to normal. EPIP Emergency Plan Classification Matrix. Revision 20 which was in effect at the time of the event states in the definitions of an Even " Implicit in this definition is the need for timely assessment within 15 minutes." NRC Emergency Preparedness Position Number 2. Timeliness Of Classification Of Emergency Conditions, dated August 1.1995, states the NRC's expectation on timely declaration as: "The staff

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position is that a 15 minute goal is a reasonable period of time for assessing and classifying an emergency once indications are available to control room operators that an EAL has been exceeded." This NRC position was made available to all utilities. A review of Sequoyah's documentation of the event indicated that neither managemen training, operations, nor emergency preparedness had identified the delayed or late declaration as a concern requiring corrective actio '

The inspectors viewod this late declaration as a weakness in the plant's emergency response performance, Conclusion

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The inspectors concluded that the EALs were very well organized and could be easily used. The EALs appeared to be technically correct and closely followed the industry guidance. The EALs were considered a strengt The errors in development, review. and approval of the en shift dose assessment procedure was a weakness and another example cf lack of attention to detail.

l The delay in declaring a NOUE during the October 5.1996 transformer explosion was a weakness in the plant's emergency preparedness respons P5 Staff Training end Qualification in EP

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P Trainino of Emeraency Resoonse Personnel Insoection Score (82701)

The inspectors reviewed the Emergency Response Training Program to evaluate emergency response personnel initial training and annual retraining. Requirements applicable to this area are contained in 10 CFR 50.47(b)(2) and (15).Section IV.F of Appendix E to 10 CFR Part 50 and the licensee's Emergency Pla o. Observations and findinas The status of the classroom training program was reviewed by selecting positions in the Emergency Response Organization (ERO) and reviewing the training reccrds of personnel qualified to fill the positions. No discrepancies were found by the inspectors. The licensee continued to maintain classroom training of the ERO in accordance with Section 15 of the Emergency Plan and EPIP 1 Radiological Emergency Preparedness Training and Drill . _ _ _ _ _ -

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6-TRN 30. Radiological-Emergency Preparedness Training described

~Sequoyah's Emergency Preparedness training program. Appendix B to TRN-30 was a matrix which related ERO positions to required. training:

. courses. -The inspectors noted that TRN-30 had been revised in response to Inspe_ction Report 50-327; 328/96-04. The inspectors found TRN-30 to be basic as a program document-and lacked specific as to training requirements and responsibilitie During the initial review, neither the inspectors nor the licensee' manager _ responsible for the program could use the appendix matrices to identify the !

-_ required training for key positions within the Emergency Response !

Organization (ER0). The_ emergency preparedness-staff member >

-responsible for implementing the program explained the training matrices to the inspector .

The inspectors--reviewed three lesson plans and their associated exams je -identified in the matrix, _ The inspectors' review determined that the ( lesson plans were adequate but the exams were not challenging. Th exams. contained poor distractors and often key words in the question were self revealing in the correct answer. Some examples from the Site Emergency Director Exam - EPT201.000 were:

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Procedure that contains checklists used to terminate the emergency <

status of SON:

Answer:

SON EPIP-16. Termination and Recovery Procedure Question 12:

- Which of:the following: notifications. represent the primary method used to notify plant personnel to report for assembly and accountability?

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Assembly Alarm The inspectors concluded most questions on the exam would not-challenge a Site Emergency Director's-knowledg Conclusion

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-TRN-30. Radiological Emergency Preparedness Training, the licensee's controlling document for training did not clearb establish training requirement ERO lesson plans were adequate, but the exams were not challenging. There were-minor differences iri questions between the different ERO position exam .

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-7 P Emeroency Plannino Drills Insoection Scooe(82701) l The inspectors reviewed the licensee's drill documentation to evaluate whether they were conducting the types and number of drills identified in Section 14. Drills and Exercises, of the licensee's Emergency Pla Requirements applicable to this area are contained in 10 CFR 50.47(b)(14) Section IV.F(1) of Appendix E to 10 CFR Part 50, Observations and Findinas The inspector reviewed 1996 6nd 1997 documentation of Sequoyah's quarterly TSC/0SC Staffing Drill with each of the four Teams: PASS Drills; a Graded Exercise which contained dose assessment and radiological control drills; and Medical Drills with Erlanger Hospital and North Park Hospital.

The inspectors verif1EJ that the licensee had conducted the required l drills in accordance with Section 14. " Drills and Exercises ' of l their Plan in 1996 and 199 Documentation of drills

scenarios, critiques and comments, had improved since the last inspectio Conclusion The licensee satisfied the drill commitments in Section 14. Drills and Exercises of their Emergency Pla Drill documentation had improved since the last inspectio P EP Organization and Administration P Management or Oraanizational Chanaes Insoection Scooe (82701)

This area was inspected to determine if any changes had occurred in the licensee's management or personnel which would effect the efficiency or performance of the Emergency Preparedness Organizatio Requirements applicable to this area are found in 10 CFR 50.47(b)(1)

and (16).Section IV.A of Appendix E to 10 CFR Part 50.

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8 Observation and Findinas The organization and management of the emergency preparedness program were reviewed and discussed with licensee representative Since the last inspection, several site managers were new in the their l positions. None of the changes in staffing directly offected the operation of the emergency response organization. An additional staff member was recently 1ssigned to the Emergency Response Organizatio Onclusion Emergency Preparedness continues to receive management suppor P7 Quality Assurance in EP Activities P Reauired 10 CFR 50.54(t) Audit of Emeraency Preoaredness Proaram The inspectors reviewed this area to assess the quality of the

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required audit and evaluate whether the audit met the requirements of 10 CFR 50.54(t) and the licensee *s Emergency Pla Observations and Findinas

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l Aadit SSA9703 was'a combined audit for Browns Ferry. Sequoyah. Watts Bar Nuclear Plants, and Corporate Offices in Chattanooga and Knoxville conducted between June 16 and August 1. 1997. The audit team consisted of a Lead Auditor and eleven team members from the TVA nuclear sites. TVA corporate, and a member from another utility. For Sequoyah, the audit identified two Level D (minor) implementation weaknesses:

oA change in the Emergency Plan was not incorporated into the Emergency Plan Implementing Procedures, oAn incorrect home phone number was identified in the Operations Support Center Call Lis The inspector noted that the weaknesses had been corrected Conclusion The inspectors' review of the Emergency Preparedness audit determined the audit to be organized and objective and satisfied the requirements in 10 CFR 50.54(t).

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P Licensee's CorrecQ/e Action Prooram For Drill Comments and Issues Insoection Scone (82701)

This area was reviewed to evaluate the licensee's corrective actions i to comments and issues identified in their drills. Requirements applicable to this area are contained in 10 CFR 50.47(b)(14). Observations and Findinas Inspection Report 50-327.328/96-04 identified a weakness in documenting corrective actions in response to drill comment The inspector reviewed findings from the licensee's drill critiques and compared these findings to the licensee's tracking system Tracking And Reporting of Open Items (TROI), and Activities Management Oversight System (AMOS). AMOS was a local PC based tracking system used by the Emergency Preparedness groups. From the tracking lists, the inspector selected two items that had been

closed, and reviewed documentation of their closure and resolutio i Although the licensee's documentation for tracking and resolution of drili comments had improved considerably since inspection report 50-327.328/96-04 the quality of the documentation could be improve Conclusion The inspectors concluded that the licensee was adequately tracking and resolving drill comments. Although documentation had improved since the last inspection documentation could still be improve Manaaement Meetina Exit The inspection scope and results were summarized in a exit interview on September 26. 1997. The inspectors described the areas assessed and discussed the inspection results in detail. No proorietary information w6s reviewed during this inspection, none is contained in this repor _

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PARTIAL LIST OF PERSONS CONTACTED Licensee

• H. Bajestani, Vice President. Site

• P. Baron. General Manger Nuclear Assurance '

• L. Bryant. Outage Manager

• C.-Burton, Engineering and Site Support Manager

• N. Catron. Manager, Emergency Preparedness

• R. Driscoll, Site Training Manager

• M. Fecht, Nuclear Assurance Manager

• T, F11ppo. Site Services Manager

• J. Herron, Plant Manager

• R. Kitts. Manager. Emergency Preparedness, Chattandoga

• T. Nahay, Emergency Preparedness

• R. Norton, Site Quality Manger (acting)

• R Proffitt, Nuclear Engineer

• P. Salas, Manager, Site Licensing

• J. Smith, Site Licensing Supervisor

• R. Summy. Assistant Plant Manager

• H. Williamson. Emergency Preparedness INSPEC110N PROCEDURE USED 82701: Operational Status of the Emergency Preparedness Program i

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