ML20214J199

Rev 0 to TVA Employee Concerns Special Program Rept SWEC-SQN-15, Sequoyah Nuclear Plant Radiological Emergency Plan

ML20214J199
Person / Time
Site:	Sequoyah
Issue date:	11/13/1986
From:	Birchell R, Knightly J, Stewart D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
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References
SWEC-SQN-15, SWEC-SQN-15-R, SWEC-SQN-15-R00, NUDOCS 8612010199
Download: ML20214J199 (7)

Text

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TVA EMPLOYEE CONCERNS REPORT NUMBER: SWEC-SQN-15 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 0 TITLE: Sequoyah Nuclear Plant Radiological Emergency Plan REASON FOR REVISION: N/A SWEC

SUMMARY

STATEMENT: The items in this report were identified by the Nuclear Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed and were closed by the NRC.

PREPARATION PREPARED BY:

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SIGNATURE DATE CONCURRENCES CEG-H: LD lt/4/f6 SRP: mh ll*l2.'8 SIGNATURE DATE G SIGNATURE

• DATE APPROVED BY' YN 11 ll'l3O AllA ECSP MANAGER DATE MANAGER OF/N0 CLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files.

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TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT ENPLOYEE CONCERNS TASK GROUP OTHER SITES CEG Element

Title:

SQN Radiological Emergency Plan SWEC Concerns: A02850506006-001

-002 A02841206001-001

-002 Source Documents: NRC Inspection Report 50-327/85-13, 50-328/85-13 and NRC letter dated November 28, 1984 Emergency Plan Deficiencies Report Number: SWEC-SQN-15 Evaluator: ,(. 3aA/, /8!d !fb R. C. Birchell Dat6 Reviewed By: klA4 '

/0[3[(0 J. J. Knightly Date Approved By: emu A.G.Debbag[

/0 [7!fli, Date' 1398T

9 Report SWEC-SQN-15 I. Introduction During an unannounced Nuclear Regulatory Commission (NRC) inspection in the area of emergency preparedness (March 25 through March 29, 1985),

the NRC inspector identified and reported (reference 1) two violations. In addition, NRC issued a letter (reference 2), dated November 28, 1984, identifying two concerns with the Sequoyah Nuclear

' Plant (SQN) emergency plan. These are addressed as issues in the Stone

& Webster Engineering Corporation (SWEC) systematic analysis, as follows: -

1. A02850506006-001 (Violation 50-327,328/85-13-02) Failure to Provide t Emergency Response Training to Shift Engineers.

2. A02850506006-002 (Violation 50-327, 328/85-13-01) Silent Tests of Sirens not Conducted on Two Week Internals.

j 3. A02841206001-001 Failure to Neet Planning Criteria In NUREG-0654.

4. A02841206001-002 Notification by Commercial Broadcasts Per t NUREG-0654.

Information on the background, corrective actions taken, verification methodology, verification analysis, completion status, and pertinent references for these four issues are included in this report.

II. Verification of SWRC Issues A. Background The NRC inspector identitled the following violations:

1. 50-127. 328/85-13-02

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10 CFR 50.54(q) requires that nuclear power reactor licensees j follow and maintain in effect emergency plans which meet the i

requirements of Appendia E to 10 CFR Part 50 and the planning

] standards of 50.47(b). 10 CFR 50.47(b)(15) requires that those 1

' who may be called on to assist in an emergency be provided radiological emergency response training. Section 4.1.1 of the Sequoyah Nuclear Plant (SQN) Radiological Emergency Plan (REP) i states, in part, that it is the responsibility of the Site i Emergency Director to initially make recommendations for protective actions to State and local agencies if necessary.

Section 4.1 of the plan states that the Shift Engineer on duty may be designated the Site Emergency Director and acts for him until relieved.

Contrary to the above, Shift Engineers' performance during walk-through interviews indicated that training was inadequate in the area of protective action decisionmaking.

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Specifically, the Shift Engineers were not capable of consistently determining when and what type of protective action recommendations were appropriate to protect health and safety of the public.

2. 50-327, 328/85-13-01 SQN Technical Specifications, paragraph 6.8.1.e specifies, in part, " Written procedures shall be established, implemented and maintained covering the activities referenced below: . . .e.

Site Radiological Emergency Plan implementation." The SQN Radiological Emergency Plan, Section 7.1.12.2 " Fixed Sirens "

states, in part, "the stren system is activated on a monthly basis by Tennessee Emergency Management Agency (TEMA) as a regularly scheduled test. A silent test is conducted every two weeks to test the radio link to the sirens. The silent test advances a counter on each steen if the radio link is complete. TVA employees read the counters on a monthly basis." Contrary to the above, the silent test had not been run every two weeks for approximately seven months but had been included in the monthly test for the ensulas period.

The NBC letter dated November 28, 1984, identified the following two concerns:

3. Revision 9 - The review of changes to the REP submitted as revision 9 Indicated that Procedure P-7, " Emergency Equipment and Supplies," has been deleted. This procedure provided for the periodic inspection and maintenance of emergency equipment and supplies. Failure to provide for this is inconsistent with l the specific planning criteria in section II.H.10 of 1

NUREG-0654, which states that each organization shall make provisions to inspect Inventory, and operationally check emergency equipment / instruments at least once each calender l quarter and after each use.

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) 4. Revision 11. Section 7.1.12. " Prompt Notification Systems " was added to the Plan. This addendum was found to meet the criteria for acceptance in revision 1 of NUREG-0654,

!' appendix 3 section B and 10 CFR 50.47(b)(5)(7), except that notification by commercial broadensts and the contents of the message were not addressed, although the plan states that the tone-elect radlos are placed in institutions. Failure to i provide for this is inconsistent with the specific planning criterla in section II.E.7 of NUERG-0654, which states, in part, that "Each organization shall provide written messages i

intended for the public. . . the role of the licensee is to l provide supporting information for the messages."

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r B. Corrective Action Taken

1. A02850506006-001 (Violation 327, 328/85-13-02) Failure to l Provide Emergency Response Training to Shift Engineers

, In response to this violation (reference 3) SQN revised Implementing Procedure (IP)-5, " General Emergency" (reference 4) to ensure consistency with federal guidance for protective action decisionmaking, and a letter was sent to the Shift Engineers and Assistant Shift Engineers describing the changes. The procedure changes for IP-5 were also be*ng reviewed during scheduled licensed operator requalification training.

2. A02850506006-002 (Violation 50-327. 328/85-13-01). Slient Tests of Sirens Not Conducted on Two Week Internals SQN provided NRC the following corrective actions in response

] (Keference 3) to this violation:

! TVA and TEMA resumed the original frequency for performing the s11ont test on May 15, 1985.

No additional deviations from the stren test schedule will be

initiated unless such changes are reflected in the REP.

Individuals responsible for making changes to the REP have been reinstructed on established guidelines for making changes on the REP.

, A letter from TVA to TEMA dated April 22, 1985 documents the decision to resume the two-week silent test frequency.

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3. A02841206001-001 Failure To Neet Planning Criteria In NUREG-0654 This concern deals with revision 9 of the REP. SQN is currently implementing revision 26 to the REP. In addition,

{ four NRC inspections (references 3,5,6, and 7) have been

! performed at SQN in the area of emergency preparedness since I

the issuance of the NRC letter and no violations or deviations were identified in this specific area. No additional concerns on planning criteria for NUREG-0654 compliance have been identified by the NRC on later REP revisions.

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4. A02841206001-002, Notification By Commercial Broadcasts Per NUREG-0654 This concern deals with revision 11 of the REP. As stated

' previously, SQN is implementing revision 26 to the REP and four inspections (references 3, 5, 6 and 7) hsve been performed in l this area with no violations or deviations identified.

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7-C. Verification Methodology The SWEC concerns identified for Employee Concerns Task Group (ECTG) verification were stated as follows:

RIMS ISSUE RIMS ITEM A02850506006 Failure to provide emergency RIMS-001 response training to shift engineers.

A02850506006 Silent test of strens not RIMS-002 conducted on two week intervals RIMS ISSUE RINS ITEM A02841206001 Failure to meet planning RIMS-001 criteria in NUREG-0654 A02841206001 Notification by commercial RIMS-002 broadcasts per NUREG-0654 BCTG reviewed the SQN Compliance Licensing files for internal and external correspondence related to this issue, the applicable procedure, and the NRC status and tracking system for the issues.

This review of the pertinent documentation formed the basis for this verification activity.

D. Verification Analysis The ICTG review indicated that the two violations and two concerns were adequately resolved. The corrective actions for violations 50-327, 328/85-13-01 and 50-327, 327/85-13-02 were found acceptable to the NRC. Violation 50-327, 328/85-13-01 was closed in NRC report 85-41 (reference 6) and violation 50-327, 328/85-13-02 was closed in NRC report 86-03 (reference 7).

E. Completion Status - Based on SQN corrective action, compliance with requirements, and NRC closure of the items, no further actions on these items is required. These SWEC concerns are closed.

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III. References

1. NRC Inspection Report Number 50-327, 328/85-13 dated May 3, 1985, Roger D. Walker to H. G. Parris

2. NRC letter, " Emergency Plan Deficiencies - Sequoyah Nuclear Plant,"

dated November 28, 1984, John A. 01shinski to H. G. Parris

3. Response to NRC Inspection Report Number 50-327, 328/85-13, dated June 3, 1985, J. A. Domer to Dr. J. Nelson Grace

4. SQN RRP Implementing Procedure (IP)-5, " General Emergency"

5. NRC Inspection Report Number 50-327, 328/85-07, dated February 27, 1985, Daild M. Vercelli to H. G. Parris

6. NRC Inspection Report Number 50-327, 328/85-41, dated December 19, 1985, David M. Vercelli to H. G. Parris

7. NRC Inspection Report Number 50-327, 328/86-03, dated February 3, 1986, David M. Vercelli to S. A. White i

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