IR 05000261/1978018

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IE Inspec Rept 50-261/78-18 on 780807-11 During Which 1 Item of Noncompliance Was Noted:Plant Access Emergency Kit Had Survey Instrument W/Batteries Left in & Had the Wrong Number of Respirators
ML14175A998
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 10/11/1978
From: Hufham J, Perrotti D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14175A993 List:
References
50-261-78-18, NUDOCS 7812070075
Download: ML14175A998 (18)


Text

REGq, UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N ATLANTA, GEORGIA 30303 Report No.:

50-261/78-18 Docket No.:

50-261 License No.:

DPR-23 Licensee:

Carolina Power and Light Company 336 Fayetteville Street Raleigh, North Carolina 27602 Facility Name:

H. B. Robinson Steam Electric Plant Inspection at:

H. B. Robinson 2, Hartsville, South Carolina Inspection conducted:

August 7-11, 1978 Inspector: D. J. Perr tti Reviewed by:

J. W. Hufha,

bief 4ate E4 ronmenta a d Special Projects Section Fde Facility -a Materials Safety Branch Inspection Summary Inspection on August 7-11, 1978 (Report No. 50-261/78-18)

Areas Inspected:

A routine, unannounced inspection was performed on August 7-11, 1978 to determine the adequacy and effectiveness of the licensee's emergency organization, including coordination with offsite support agencies, emergency facilities, equipment and procedures, means for determining a release, emergency training, fire brigade organization and training, tests and drills, and review of licensee action on previous inspection finding The inspection involved 32 inspector-hours onsite by one NRC inspecto Results:

Of the nine areas inspected, there were no items of noncomplianc One apparent deviation was identified in one are (Paragraph 5b.)

78120700 15

RII Report No. 50-261/78-18 I1 DETAILS I Prepared by:___*_

D. J. Perrotti, Radiation Specialist Date Environmental and Special Projects Section Fuel Facility and Materials Safety Branch Dates of Inspection:

A gust 7-11, 1978 Reviewed by:.

-a

,

/2

.W. ufham ief Date Eironmental d Special Projects Section F 1 Facility d Materials Safety Branch Persons Contacted H. B. Robinson Personnel

  • C. W. Crawford, Acting Plant Manager
  • W. Traylor, Administrative Supervisor
  • D. S. Crocker, Environmental and Radiation Control Supervisor 8* Eaddy, Radiation Control and Test Foreman
  • S. Zimmerman, Engineering Supervisor
  • J. Curley, Nuclear Engineer
  • W. Garrison, Quality Assurance Supervisor F. Lowry, Training Coordinator K. Dripps, Document Control Technician J. Sawyer, Engineering Technician Other Carolina Power and Light Employees B. McFeaters, Raleigh Siting Unit G. Forest, Raleigh Siting Unit Other Individuals Contacted F. J. DeMarco, III, Administrator, Byerly Hospital Several other H. B. Robinson employees were interviewed during the inspectio *Denotes those present at the exit intervie.

Licensee Action on Previous Inspection Findings Noncompliance (Open) Deficiency (50-261/77-7): Maintenance and inventory of Emergency kit The licensee has not adhered strictly to Pro-

RII Report No. 50-261/78-18 1-2 dure HP-30, as committed by the licensee's response, dated December 22, 1977, to IE Report No. 50-261/77-This item remains open (Paragraph 5.b.).

(Closed) Deficiency (50-261/77-7): Hydrostatic test of portable fire extinguishers. All portable fire extinguishers requiring hydrostatic testing have been tested. This item is close (paragraph 11.c.)

(Closed) Infraction (50-261/77-7): Initial fire fighting training for members of the Fire Brigad As of October 27, 1977, members of the Fire Brigade had completed the formal training program as specified by the Fire Protection Manual. This item is close (Paragraph ll.b.)

(Closed) Deviation (50-261/77-7): Review and updating of the Emergency Pla The Emergency Plan has been updated by the license (Paragraph 9.a.) Unresolved Items (Closed) Unresolved Item (50-261/77-7): Emergency facility at Byerly Hospita The emergency facility was reviewed and appears to satisfy the requirements of 10 CFR 50, Appendix E, Section TV, paragraph G., and Section 1.F.2 of the Emergency Pla (Para graph 4.b.)

(Open) Unresolved Item (50-261/77-7): Emergency Implementing Procedures. The Emergency Plan and Procedures are under review with regard to Reg. Guide 1.10 This matter remains ope (Paragraph 9.c.).

(Closed) Unresolved Item (50-261/77-7) Security Building Monitor alarm point. The monitor and procedure are available as specified by the Emergency Pla (Paragraph 6.b.)

(Open) Unresolved Item (50-261/77-7):

First aid and medical supplies in Unit I First Aid Room. The medical consultant has not furnished the licensee with a recommended list of first aid and medical supplie This matter remains ope (Paragraph 7.a.) Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non compliance, or deviation Four unresolved items disclosed during the inspection are discussed in paragraphs 6.d., 5.d., 8.a. and 1l.b. of this repor RII Report No. 50-261/78-18 1-3 Coordination With Offsite Support Agencies Appendix E to 10 CFR 50, Section IV.D specifies that the emergency plans shall contain procedures for notifying, and agreements reached with local, state, and federal officials and agencies for early warning of the public. Appendix E also specifies arrange ments for the services of a physician and other medical personnel qualified to handle radiation emergencies; arrangements for transportation to, and treatment of injured or contaminated individuals at treatment facilities outside the site boundar Section I.B.6 of the Emergency Plan, paragraph b. states that all outside agencies which might become involved in an emergency situation have been contacted, that each agency has agreed to participate in these planned actions in the event of an incident, that each agency has been briefed on these plans and their related duties, that copies of the plans shall be made available to each agency and that periodic reviews shall be held with these outside agencies as require The inspector discussed the coordination with offsite support agencies and renewal of written agreements with a licensee repre sentative. The inspector was informed that the licensee had maintained contact with offsite support groups through meetings and telephone call The inspector verified, by review, that the licensee had obtained new agreement letters with the following agencie (1) South Carolina Department of Health and Environmental Control (2) Darlington County Civil Defense (3) Department of Energy, Savannah River Operations Office (4) Dr. Nickels, Jr., Medical Consultant (5) Byerly Hospital (6) Hartsville Rescue Squad (7) Hartsville Civil Defense The inspector also reviewed a memo of a meeting held by the licensee on September 27, 1977, with representatives of eight offsite support agencies to discuss the agencies' involvement in H. B. Robinson's emergency planning effor To complete the veri fication of coordination with offsite agencies the inspector contacted agency representatives identified in paragraph The following are the results of these contact RII Report No. 50-261/78-18 1-4 Byerly Hospital:

On August 7, 1978, the inspector met with the Byerly Hospital Administrator. The inspector explained that the hospital emergency facility and training for nurses was defined as an unresolved item during the last emergency planning inspection (IE Report No. 50-261/77-7).

The hospital administrator informed the inspector that the facility for treating contaminated injured patients had been improved, that members of the emergency nursing staff had received emergency training through films and lectures, and that the licensee had maintained contact with the hospita The inspector verified, by review, that the emergency facilities had been improved and that medical emergency equipment would be available for treating a contaminated injured patien There were no items of noncompliance or deviation.

Facilities, Equipment and Procedures Changes in Facilities, Equipment and Procedures The inspector reviewed changes to the facilities, equipment and the emergency plan and procedures up to and including Revision 7.14 dated January 16, 1978. The changes did not alter the initial requirements of the emergency plan and did not constitute an unreviewed safety question nor a change in the Technical Specifi cation Emergency Kits (1) Appendix E to 10 CFR 50, Section IV.F. specifies that the emergency plan include provisions for emergency first aid and personal decontamination facilities, including equipment at the site for personnel monitoring and decontaminatio Section I.F. of the Emergency Plan specifies the location and general contents of four emergency kits:

Unit 2 Control Room, Plant Access, CP&L office in Hartsville, and Byerly Hospital.Section III, subsection 3.2 of Health Physics Procedure HP-30, Emergency Kit Inventory, specifies the items to be placed in each kit, the frequency of calibrating survey instruments, the method of reporting discrepancies and replacing missing items, the proper storage of air bottles, and the posting of inventory result (2) During a previous inspection the inspector identified discre pancies concerning the maintenance and inventory of the Control Room and Plant Access emergency kits as an item of noncompliance (JE Report No. 50-261/77-7).

The licensee's response, dated December 22, 1977, stated that the appro priate personnel have been instructed in checking the emer-

RII Report No. 50-261/78-18 1-5 gency kits to strictly adhere to HP-30 in maintaining the inventory list. Through discussions with licensee represen tatives and observations of the contents of the emergency kits at Byerly Hospital on August 7, 1978, and the Plant Access and control room on August 8, 1978, the inspector verified that the kits were being maintained and inventoried as specified by HP-30, with the following exceptions. At the Plant Access kit there were two portable survey instru ments with batteries left in, and quantities of half-face and full-face respirators did not agree with the approved inventory list. The inspector was informed that two of the half-face respirators had recently been replaced with full face respirators in order to provide better protection for the user. The inspector stated that changes to emergency kits and equipment lists should be made in accordance with established plant administrative procedure (3) This matter was identified by the inspector as a deviation from the licensee's commitment to strictly adhere to HP-30 when inventorying the emergency kits as stated in licensee's response to IE Report No. 50-261/77-7 (261/78-18-01). Respiratory Equipment (1) Section 6.12 of the Technical Specifications requires written procedures for maintenance, inspection and storage of respira tor Section III of Health Physics Procedure HP-30, Emergency Kit Inventory, paragraph 3.2.10 requires a monthly inspection for condition and operability of the Scott Air Paks in all emergency kit station (2) The inspector observed the Scott Air Paks in the Emergency Kit location and verified that the equipment, including spare air tanks, was available as required by HP-30. The inspector verified, by review of HP-5, Daily Health Physics Report, that the Scott Air Paks had been inspected during June and July of 197 (3) There were no items of noncompliance or deviation Main Control Room Isolation System (1) Table 4.1-3 of the Technical Specifications requires a functional test of the ventilation fans every refueling shutdown. Periodic test procedure, CPL-PT-12.2, Radiation Monitoring Systems (biweekly), paragraph 3.1.6.4 requires a check to assure that the control room ventilation isolates from outside air and transfers to filters upon alarm of R-1, control room radiation monito RH Report No. 50-261/78-18 1-6 (2) The inspector reviewed periodic test procedure PT-24.0, Fan and Associated Charcoal and Absolute Filters (Refueling Interval), which verified a functional test was performed on March 20, 197 The inspector also reviewed PT-12.2 for the period January to July, 1978, which verified the biweekly system isolation test had been performed satisfactoril The inspector discussed with a licensee representative the procedural change which would provide for manual activation of the control room isolation in the event of an alarm from one of the airborne effluent monitor The inspector was informed that a change to Section I.E.2 of the Emergency Plan Evacuation Alarms, specifies switching the control room ventilation system to the emergency recirculation position upon initiation of the plant-site evacuation alarm. The inspector commented that this instruction would be more effective in Section IL.C of the Emergency Plan under the procedure for initiation of a site emergency. The inspector advised the licensee representative that more time would be required to evaluate this change to the Emergency Pla (3) The matter regarding the procedural change for manual isola tion of the control room was defined by the inspector as an unresolved item (261/78-18-02). Emergency Lighting During a previous emergency planning inspection a licensee manage ment representative agreed to investigate the possibility of incorporating a test of the emergency lights into periodic test procedure PT-23.2. During this inspection, the inspector discussed this matter with a licensee representative. The inspector was informed that PT-23.2 had been reviewed. However, it was not feasible to incorporate the testing of the emergency lights into the procedure. The inspector was also informed that lighting is provided by three different systems:

(1) the regular AC system which receives routine maintenance; (2) emergency AC lighting in all areas of the plant which receive power from the emergency diesel generators; and (3) the emergency DC lights which are provided in vital areas of the plant. The licensee representative explained that with the primary lighting system and two back-up emergency systems, it was extremely unlikely that lighting would be lost to vital areas of the plant. The inspector had no further comment Emergency Communications (1) Section l.F. of the Emergency Plan, paragraph 9, states that various communications will be available for us Paragraph

RII Report No. 50-261/78-18 1-7 9.e states that 2-way radios are tested weekly. Section of the Emergency Plan states that the site evacuation alarm shall be tested weekly over the PA system at 9:00 a.m. each Friday and that the containment vessel alarm will be tested bi-weekl (2) The inspector reviewed the shift foreman's log, for the period May 5-July 14, 1978, which verified that the site evacuation and fire alarm test had been performed satisfac torily. The inspector reviewed H. B. Robinson Unit 2 Auxiliary Operator Weekly Check List, for the period August 1977 to August 1978, which verified the 2-way radios and the contain ment alarm had been tested satisfactoril (3) There were no items of noncompliance or deviation.

Means For Determining a Release Appendix E to 10 CFR 50, paragraph IV.C requires means for determining the magnitude of release of radioactive material, and criteria for determining when protective measures should be considered within and outside the site boundar Process and Area Radiation Monitors (1)Section I.F. of the Emergency Plan states that readout of all process and area monitoring equipment shall be displayed in the control room. Table 4.1-1, Item 19 of the Technical Specifications requires a monthly test and calibration at each refueling for the process and area radiation monitor (2) The inspector reviewed surveillance records PT-12.2, Radia tion Monitoring Systems, for the period January-July, 1978, which verified the operability, auto functions, including control room isolation by R-1, and alarms of the monitors listed belo R-1 Control Room Area Monitor R-14 Plant Vent R-15 Condenser Air Ejector Gas Monitor R-17 Component Cooling Water System R-18 Liquid Waste System Effluent R-19 Steam Generator Blowdown Calibration of the area and process monitoring systems was verified by an inspector during a previous inspection (1E Report No. 50-261/77-21).

RH Report No. 50-261/78-18 1-8 (3) There were no items of noncompliance or deviation Security Building Evacuation Alarm (1)Section I.E.5 of the emergency plan requires that a monitor be located in the security building with a setpoint of I R/hr that requires evacuation of the security building upon an alar (2) During a previous inspection (IE Report No. 50-261/77-7), an inspector observed that the security building monitor had a range that could be adjusted, thereby moving the alarm set-point from the specified I R/h In addition the inspector noted that security procedures corresponding to the appro priate protective action for the alarm were not availabl During this inspection, the inspector observed that the monitor was available in the security building and the range selector switch was modified to prevent switching from the preset alarm point of 1 R/h To complete the verification of the security building monitor, the inspector reviewed Security Procedure S-18, which furnishes instructions to the guards for evacuation of the building upon alarm of the monito (3) There were no items of noncompliance or deviation Seismic Instrumentation (1) Periodic test procedures CPL-PT-28.1 and 28.2 require a monthly function test and a semi-annual calibration, respec tively, of the seismic monitor (2) The inspector reviewed surveillance records CP&L-PT-28.1 for the period January to July 1978, which verified the monthly operational test was completed satisfactoril The inspector also reviewed surveillance records CPL-PT-28.2, which verified the seismic monitors had been calibrated on December 9, 1977 and May 17-18, 197 (3)

There were no items of noncompliance or deviation Meteorological Instrumentation (1) Section H.1 of the Emergency Plan states that the Unit 2 computer will provide hourly data for ambient temperature, upper and lower wind direction, upper and lower wind speed

.

RII Report No. 50-261/78-18 1-9 and Pasquill Stability facto Section H.1 also describes Unit 1 Wind Speed and Direction Chart as the back-up method in the event Unit 2 computer is not workin (2) The inspector discussed with licensee representatives and observed the meteorological instrumentation for Units 1 and 2 in the control room on August 8, 197 The inspector reviewed surveillance records which verified that semi-annual calibrations had been completed satisfactorily for Unit 2 meteorological system on September 26-29, 1977 and April 18-20, 197 The inspector verified, by observation, that the Unit 2 computer printout was available as specified by the Emergency Plan. However, the Unit 1 wind direction monitor indicated a value of wind direction very different from the Unit 2 monitor. Through discussions with licensee represen tatives at the CP&L Siting Unit in Raleigh, North Carolina, and the plant site, the inspector determined that the Unit I meteorological system was not calibrated or functionally tested. The inspector expressed concern about using the Unit 1 system wind direction in the the event that Unit 2 computer was shut dow (3) The inspector defined the Unit 1 meteorological system as an unresolved matter, and informed licensee management representa tives that Unit I meteorological data should not be used to assess offsite ground level concentrations in the event of an emergenc (261/78-18-03) Meteorological Overlays and Decisional Aids (1) Section H. of the Emergency Plan requires that meteorological overlays, an aerial map of the plant site, Volume 15 "Curve Book," and graphs be available to determine offsite ground level concentrations of radioactivit (2) The inspector verified, by observation, that the meteoro logical overlays and other decisional aids were available in the control room as specified by the Emergency Pla (3) There were no items of noncompliance or deviation.

Medical and Decontamination Facilities Appendix E to 10 CFR 50, Section IV.F. specifies that the emergency plan include provisions for emergency first aid and personal decontamination facilities, including equipment at the site for personnel monitoring and decontamination, and facilities and medical supplies for first aid treatmen Section I.F. of the

RII Report No. 50-261/78-18 1-10 Emergency Plan, paragraph 6, specifies that sufficient first aid and medical supplies are maintained in Unit 2 first aid room to treat all injuries which do not require hospitalization.Section I.F., paragraph I specifies that the plant facilities and services include a personnel change and decontamination roo During the last emergency planning inspection (IE Report N /77-7), a licensee representative stated that a new list of required first aid and medical supplies would be obtained from the licensee's medical consultan On August 8, 1978, the inspector discussed the first aid and decontamination facilities with a licensee representative. The inspector was informed that a temporary first aid and decontamination station had been set up due to construction of new facilities in the auxiliary buildin The inspector verified that the temporary facility had been established. However, the medical supplies and equipment being maintained were the same as those observed during the last inspec tio The inspector was informed that the list of recommended supplies and equipment had not been furnished, as yet, by the medical consultan The requirement for the personnel decontamination facility appeared to be satisfied. The inspector informed licensee management representatives that the matter concerning the first aid and medical supplies would remain an unresolved ite (261/78-18-04) Emergency Plan Training Appendix E to 10 CFR 50, paragraph IV.H. requires that the emergency plan contain provisions for training of employees of the licensee who are assigned specific authority and responsibility in the event of an emergency, and other persons whose assistance may be needed in the event of a radiation emergenc General Employee Training (1)

Section I.B.6 of the Emergency Plan requires each individual at the H. B. Robinson plant to become familiar with the emergency procedures, and with his individual duties so that planned action may be carried out in the event of an emergency situation. Training instruction, T1-300, General Employee Training, specifies an annual formal lecture on Emergency Plans for all plant personne (2) The inspector discussed the annual refresher training with licensee representatives from the training departmen The inspector was informed that the training for 1978 had not been completed as yet. A tentative schedule had been set for training to begin again in Septembe RII Report No. 50-261/78-18 I-11 (3) The inspector defined the annual refresher training for general employee Emergency Plan as an unresolved ite (261/78-18-07) Operator Training (1) During a discussion of operator training with a licensee representative from the training section, it was pointed out that the requalification program requires licensed operations personnel to review emergency plans and procedures on a quarterly basi Section 4.1.6 of the Administrative Instruc tions allows the quarterly review to be waived during refueling shutdowns (1-3 months).

(2) The inspector verified, by review of records for seven operating personnel, that quarterly reviews of the emergency plan and procedures had been completed by operations personnel during the 4th quarter of 1977 and the 2nd quarter of 197 The inspector was informed that the plant was shutdown for refueling during the 1st quarter 197 (3) There were no items of noncompliance or deviation Emergency Coordinator The inspector discussed with a licensee representative from the training section, training received by the personnel who may succeed to the position of Emergency Coordinator as described in Section I.C.1 of the Emergency Plan (Operating Supervisor, Plant Manager and any supervisor acting in the capacity of the Operating Supervisor. Additionally Section I.C.6 specifies that the Maintenance Supervisor may act in the capacity of the Plant Manager or Operating Supervisor).

The inspector verified that the Operating Supervisor and Maintenance Supervisor, as well as Shift Foremen, are licensed operators, and, as such, complete a review of the Emergency Plan and Procedures each quarter. The inspector was informed that the Plant Manager, as chairman of the Plant Nuclear Safety Committee (PNSC), reviews the entire Emergency Plan and Procedures on an annual basi The inspector verified, by review of the minutes of PNSC meeting number 408, that all members of the PNSC, including the Plant Manager reviewed the Emergency Plan and Procedures on December 27, 1977. The inspector had no further comment Emergency Monitoring Teams (Includes First Aid Trained Personnel)

(1) Section l.C.11 of the Emergency Plan, paragraph a. specifies that the monitoring team shall consist of members of the Radiation Control and Test Group (RC&T) and of other plant personnel who have received training and are qualified in Health Physics and First Ai Training Instruction TI-100, Retraining and Replacement Training for Non-jicfped Per-

RH Report No. 50-261/78-18 1-12 sonnel, specifies annual retraining for RC&T personnel by review of Emergency Plans and Procedure (2) The inspector reviewed training records which verified twenty-nine personnel from RC&T received refresher training in the Emergency Plan and Procedures on December 30, 197 The inspector verified that there was at least one first aid trained person on each shift by reviewing approximately one-third of the first aid training records for RC&T personne (3) There were no items of noncompliance or deviation Offsite Agency Personnel Training (1)Section I.B.6.b. of the Emergency Plan specifies that each outside agency has been briefed on these plans and their related specific duties, and that periodic reviews are held as require (2) The inspector verified, by discussion with a licensee represen tative and review of a memo of a drill critique, that the principal offsite agencies met and discussed emergency planning with licensee representatives on September 27, 1977, and attended a drill critique at the H. B. Robinson site on December 14, 197 The inspector was also furnished a list of twenty-two nurses from Byerly Hospital who attended a film and lecture on handling of radiation patients during the period October 12-17, 197 (3) There were no items of noncompliance or deviation.

Review, Updating and Distribution of Emergency Plans and Procedures Appendix E to 10 CFR 50, paragraph IV.E requires provisions for main taining, up-to-date, the organization for coping with emergencies, the procedures for use in emergencies, and the lists of persons with special qualifications for coping with emergencie Review and Updating of Emergency Plan and Procedures by the Plant Nuclear Safety Committee (PNSC)

(1) Section 6.5.1.7.1 of the Technical Specifications requires a review of the Emergency Plan and implementing procedures by the PNS Section 1.B.7 of the Emergency Plan states that the complete plans and procedures shall be formallv reviewed annually by the plant manager and by the PNSC; and shall be updated as require RH Report No. 50-261/78-18 1-13 (2) During a previous emergency planning inspection, the inspector defined updating of the Emergency Plan as a deviation from the requirements of the Emergency Plan. During this inspection, the inspector reviewed the Emergency Plan, up to and including Revision 7.14, dated January 16, 197 This review verified that the licensee has updated the plan. The inspector also verified, by review of the minutes of PNSC meeting number 408, that all members of PNSC reviewed the Emergency Plan and Procedures on December 27, 197 (3) There were no items of noncompliance or deviation Audit of Emergency Plan by Offsite QA Group (1) Section 6.5.3 of the Technical Specifications requires an audit to be conducted every two years by an independent offsite QA grou (2) The inspector reviewed records that verified audit QAA/20-16 of the Emergency Plan and Procedures had been conducted by CP&L Corporate Quality Assurance during the period July 10-14, 197 (3) There were no items of noncompliance or deviation Emergency Implementing Procedures (1)Section II of the Emergency Plan includes certain procedures that would be implemented during an emergenc (2) During a previous inspection (IE Report No. 50-261/77-7), an inspector discussed with a licensee representative emergency procedures that were probably available onsite in other documents and that would also be considered as emergency implementing procedures, specifically, security and account ability procedure During this inspection, an inspector reviewed the H. Robinson Emergency Plan, which includes Section 11, Emergency Procedures, with respect to the recommendations of Re Guide 1.101,

"Emergency Planning for Nuclear Power Plants."

The inspector noted that the Emergency plan did not contain procedures for accountability, reentry and recovery, plant security and documentation and record However, after discussion with a licensee representative and review of pro-

RII Report No. 50-261/78-18 1-14 cedures at the security building and Health Physics office, it was verified that procedures for site and local evacua tions, reentry, accountability and security were availabl The inspector was informed by a licensee representative that the Emergency Plan and procedures are undergoing a review process and will be revised with regards to Reg. Guide 1.10 (3) The inspector informed licensee management representatives that this matter would remain an unresolved item until the review and revision of the Emergency Plans and Procedures are completed by the licensee, and review of the remaining emergency procedures by the inspecto (261/78-18-05) Distribution of Emergency Plan and Procedures and Changes to the Emergency Plan to Onsite and Offsite Groups The inspector discussed with a document control technician, the method used to insure proper distribution of the Emergency Plan and changes to the Emergency Plan to onsite and offsite group The document control technician explained that a method of signed receipts insured all parties were receiving copies of the plan and changes to the plan. Following the discussion the inspector reviewed Document Control Index Book No. 5 which verified that changes to the Emergency Plan and Procedures, up to and including Revision 7.16, have been sent to all appropriate onsite and offsite group.

Review of Licensee's Response to IE Bulletin 77-08, "Locking Systems" IE Bulletin 77-08 required the licensee, in part, to survey the facility and facility plans as to whether or not prompt emergency ingress into electrically locked safety related areas by essential personnel could be assured during loss of power, and if unimpeded emergency egress from all parts of the facility could be assured with respect to hardware and security system installations. In addition, the licensee was required to review existing emergency plans and procedures to assure that prompt emergency ingress and unimpeded emergency egress was fully and effectively addressed for any postulated occurrence. A written report was required for any facility that did not meet the requirements of action item I and 2 of the bulleti The inspector discussed the requirements of IE Bulletin 77-08 with a licensee representative. The inspector was furnished a copy of the licensee's response dated February 24, 1978, and was informed that another NRC inspector was looking into this matte The inspector had no further question RII Report No. 50-261/78-18 1-15 1 Fire Protection/Prevention Fire Brigade Organization (1) Technical Specification 6.2.2.f. requires at least five fire brigade members onsite at all times, in addition to the minimum shift crew of three personnel required for a safe orderly shutdown of the plan (2) The inspector was informed that the fire brigade consists of personnel from Operations and RC&T. The inspector verified, by discussion with licensee representatives and by review of shift schedules for Operations and RC&T personnel, for two of the four shifts, that the requirement for at least five fire brigade members onsite at all times was being me (3) There were no items of noncompliance or deviation Fire Brigade Training (1) Technical Specification 6.4.2 requires training sessions for the fire brigade to be conducted each quarter. Volume XIX of the Operating Manual, Fire Protection Manual, specifies that members of the fire brigade will receive the most indepth fire fighting trainin (2) During a previous inspection the inspector identified the training of the fire brigade as an item of noncompliance (IE Report No. 50-261/77-7).

During this inspection the inspector reviewed a certificate from the South Carolina State Firemen's Association that verified that sixty members of the H. Robinson fire brigade had received a sixteen hour fire fighting course on October 27, 197 However, from discus sions with licensee representatives, it was determined that due to personnel losses and a change in the make-up of the fire brigade, only fifty-seven percent of those trained in October 1977 were still on the fire brigade. The inspector was informed that some of those who had not yet received the sixteen hour course have had prior fire fighting experience in the military, and that all of the fire brigade members have had the quarterly training session The inspector verified, by review of training records, that all members of the fire brigade had received the quarterly training session for the period April to June 197 The inspector was also informed that the new brigade members had not received the professional training because of scheduling problems and difficulty in obtaining a certified instructor from the South Carolina State Firemen's Association. A licensee

RII Report No. 50-261/78-18 1-16 representative stated that they were looking into the possi bility of sending an employee to a firefighter instructor course in order to have a certified instructor onsite to provide the trainin This matter was discussed with licensee management representatives at the exit interview. Subsequent to the inspection, the inspector contacted the licensee by telephone on August 16, 197 A licensee management represen tative committed to having all members of the current fire brigade professionally trained by the end of this yea (3) The inspector defined the initial training of the fire brigade as an unresolved item pending the satisfactory completion of the professional fire fighters course by all members of the current fire brigade (261-78-18-06). Fire Extinguishers Hydrostatic Test (1) Periodic test procedure, CPL-PT-9.3, Annual Inspection of Fire Protection Systems, requires, in part, an inspection of portable fire extinguishers for hydrostatic tes (2) During a previous inspection, the inspector observed approxi mately fourty portable fire extinguishers that were apparently overdue for hydrostatic test and defined this matter as a deficiency. During this inspection the inspector verified, by a review of surveillance record PT-9.3, completed on March 22, 1978, that all fire extinguishers have been hydro stacically tested within the prescribed time interva (3) There were no items of noncompliance or deviation.

Emergency Drills CFR 50, Appendix E, paragraph IV.I requires provisions for testing, by periodic drills, of radiation emergency plans to assure that employees of the licensee are familiar with their specific duties, and provisions for participation in the drills by other persons who assistance may be needed in the event of a radiation emergency.Section I.B.6 of the Emergency Plan, para graph c. states that unannounced practice site evacuation exercises shall be conducted annuall Two NRC inspectors were onsite during the last evacuation drill held on December 14, 1977, (IE 50-261/77-21).

During this inspec tion the inspector reviewed a memo of the last drill which included a critique held on December 15, 1977, at the H. B. Robinson Visitor's Center. This critique was attended by representatives from offsite support agencie RH Report No. 50-261/78-18 I-17 There were no items of noncompliance or deviation.

Exit Interview The inspector met with licensee representatives (denoted in para graph 1) at the conclusion of the inspection on August 11, 197 The inspector summarized the purpose and scope of the inspections and the findings.