IR 05000269/1972011

Insp Rept 50-269/72-11 on 721206,12-14,16 & 18.No Noncompliance Noted.Major Areas Inspected:Licensee Action on Previously Identified Enforcement Matters,Training, Security,Hot Functional Tests & Review of Maint Procedures

ML19322A871
Person / Time
Site:	Oconee
Issue date:	02/12/1973
From:	Jape F, Murphy C, Warnick R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19322A864	List: IR 05000269/1972011 ML19322A863 ML19322A868
References
50-269-72-11, NUDOCS 7911270629
Download: ML19322A871 (35)

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UNITED STATES

!'d No ATOMIC ENERGY COMMISSION l

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RO Inspection Report No. 50-269/72-11 Licensee: Duke Power Company Power Building 422 South Church Street Charlotte, North Carolina 28201 Facility Name: Oconee Unit 1 Docket No.:

50-269 License No.:

CPPR-33

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Location: Oconee County, South Carolina Type of License: B&W, PWR, 2452 MW(t)

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Type of Inspection: Special, Announced - December 6, 16 and 18, 1972 Routine, Unannounced - December 12-14 and 20-21, 1972 i

Dates of Inspection: December 6, 12-14, 16, 18, and 20-21, 1972 Dates of Previous Inspection: November'14-17, 1972 Principal Inspector:

R. F. Warnick, Reactor Inspector Facilities Test and Startup Branch Accompanying Inspectors:

F. Jape, Reactor Inspector Facilities Test and Startup Branch C. M. Campbell, Radiation Specialist

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Radiological and Environmental Protection Branch

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Other Accompanying Personnel:

M. S. Kidd, Reactor Inspector Yacilities Test and Startup Branch

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A. F. Gibson, Radiation Specialist Rad ologica,1 and Environmental Protection Branch Principal Inspector:. [ [

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>/ h f/2 73 R. F. Warnick,/deact'? Irispector D4te'

Facilities Test an Startup Branch Reviewed by:

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C. E. Murphy,0 ccing f, Facilities Test and Startup Dat e'

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SUMMARY OF FINDINGS I.

Enforcement Action None

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Licensee Action on Previously Identified Enforcement Matters i

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A.

Violations

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The following items are closed:

1.

Criterion V - Failure to Implement Approved Procedures for Control of Nonconforming Items (See Letter to DPC dated October 26, 1972, Item 1.b.)

Procedure Q-1 has been revised to eliminate the conflict of instructions which previously existed between procedures Q-1 and R-2.

The inspector reviewed the draft copy which was being circulated for approval. This item is closed.

(See Details I, paragraph 2.)

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2.

Criterion VII - Installation of Cable Withcut Documentary Evidence That Cable Met Procurement Soecification (See Letter to DPC dated October 26, 1972, Item 2.)

An electrical QC audit revealed that only one reel of r

cable out of 659 reels had not been properly released for installation and this one item has since been corrected.

When QC documentation-is not available at the site, it is obtained by telecopier prior to installation. This item is closed.

(See Details I, paragraph 3.)

3.

Criterion VI - Failure to Follow Administrative Procedures

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for Preoperational Testing (See Letter to DPC dated October 26, 1972, Item 3.c.)

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The changes made to TP 202/7, "HPI Operational Test,"

were reexamined and found to be within the definition as stated in the " Guide for Conducting the Oconee Pre-

. operational Test Program." However, the definition for

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major and minor changes as given in the " Operational Quality Assurance Manual" will be reviewed further.

This item is closed.

(See Details II, paragraph 15.)

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Criterion VI - Failure to Document Changes to Test

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Procedures (See Letter to DPC dated October 26, 1972, I

Item 3.d.)

Instructions regarding proper documentation of test

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changes have been issued to the licensee's personnel who have responsibility for the performance of tests.

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This item is c.losed.

(See Details II, paragraph 10.)

5.

Criterion XIV - Failure to Establish Measures to Indicate the Status of Cable (See Letter to DPC dated October 26, 1972, Item 4.)

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Procedure S-2 was revised to specify the documentation to be turned over to operations at the time systems and

QA documentation are transferred from construction to

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operations. All Unit 1 cable has been identified. This item is closed.

(See Detai'.s I, paragraph 4.)

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Criterion XI - Failure to Document Test Results (See Letter to DPC dated October 26, 1972, Item 9.)

A memorandum was issued on November 24, 1972, emphasizing

the need to document test results. This item is closed.

(See Details II, paragraph 9.)

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• The following items remain open:

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7.

Welding Program Deficiencies (See Letter to DPC dated

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March 8, 1972, Item 5.)

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-DPC stated that their final report on welding deficiencies and improvements in their welding program should be available after December 25 for AEC inspection.

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Safety Items

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New Unresolved Items i

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-72-11/1 FSAR Training Commitment Vs. Actual Training Received-

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The training actually received by certain members of the Oconee Nuclear Station Unit 1 staff differs from the training commitment stated in Oconee's Final Safety Analysis Report (FSAR), paragraph 12.2.1, " Initial

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Operating Staff Training Program." DPC will revise the FSAR to agree with training actually received.

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(See Details I, paragraph 5.)

72-11/2 Evaluation of Sample Delivery Line Losses

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f An adequate evaluation of sample delivery line losses,

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in the sampling lines from the unit vent and the reactor

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l building to their respective process monitors, has not l

been completed.

(See Details III, paragraph 20.b.)

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72-11/3 Evaluation of the Efficiency of the Halogen Collection Media An in-place determination of the efficiency of the halogen

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collection media in the unit vent and reactor building process

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monitors has not been completed.

(See Details III, paragraph 20.c.)

72-11/4 Iodine condensation Losses in an outside Sample Delirerv Line Measures to minimize and determine iodine cordensation losses in an outside sample delivery line have not been done.

(See

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Details III, paragraph 20.d.)

72-11/5 Representative Sampling of Liquid Waste During Discharge The provisions for sampling liquid effluent discharges

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from the radwaste system do not assure representative samples.

(See Details III, paragraph 21.)

• 72-11/6 Unit 1 Security Plan The Unit 1 security requirements have not been identified.

(See Details I, paragraph 6.)

IV.

Status of Previously Reported Unresolved Items

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A.

Reactor Internals Inspection An inspection of the re:ctor internals following completion of the preoperational tests will be performed as described in TP-200/22. This item is closed.

(See Details II, para-graph 7.)

B.

Field Testing of Steam Generator

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Field testing of the steam generator to confirm results of

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prototype tests will be run as described la TP-800/22. This item is closed.

(See Details II, paragraph 5.)

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C.

Reactor Internals Vibration Testing

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A reactor internals vibration test will be run during hot functional testing as described in TP-200/34 and TP-200/36.

This item is closed.

(See Details II, paragraph 8.)

D.

Vibration Testing of Raactor Coolant Piping

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A procedure has been prepared by DPC and reviewed by Region II.

Comments have been resolved. This item is closed. (See Details I, paragraph 7.)

E.

Reactor Coolant Flow in Excess of FSAR Value The rc ctor internals have been modified and flow tests have beu; repeated during hot functional testing. Flow tests will also be repeated after the initial core is loaded. This item is closed.

(See Details I, paragraph 8.)

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F.

Verification that the Stack Sampling Probe is Isokinetic ('

Verification that stack sampling probe is isokinetic was-available. This item is closed.

(See Details III, para-

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graph 18.)

G.

Low Level Solid Waste Handling P_r_ocedure A procedure for compactor operation, co.11ectica, and storage of low level solid waste has been completed. This item is closed.

(See Details III, paragraphs 6 and 7.)

H.

Health Physics Training Records A system for maintaining and updating records of health physics training has been implemented. This item is closed.

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(See Details III, paragraph 9.)

I.

Completion of Change Rooms Installation of shelves and lockers in change rooms has been completed and clothing is readily available. This item is closed.

(See Details III, paragraph 11.)

J.

Installation of Personnel Monitoring Count Rate Meters Installation of the mounting rackIs for the count rate meters has been completed and the meters are operacional and readily

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available for distribution to monitoring points. This item is closed.

(See Details III, paragraph 13.)

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Calibration of Area Monitors

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Calibration of the area monitors has been completed. This

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item is closed.

(See Details III,. paragraph 12.)

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Operation of a Continuous Water Sampler in the Keowee Tailrace i

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The operation of a continuous water sampler in the Keowee i

tailrace during liquid effluent discharge from the radwaste

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system is no longer required. This item is closed.

(See

Details III, paragraph 19.) '

The fallowing items remain open:

M.

Axial Power Imbalance RO is waiting to receive a copy of procedure TP-800/24 for review to verify by startup test that the reactor protection

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system responds to axial power imbalances in a manner designed

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to prevent the axial design peaking factors from being exceeded.

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Verification of Core Bypass Flow

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RO is waiting for a test to be identified and a procedure to

be written to verify core bypass flow.

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Reactor Coolant Pump Flow Tests

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Test procedures TP-200/12, " Reactor Coolant Pump Flow Test," and TP-200/13 " Reactor Coolant Flow Coastdown Test," have been revi ewed. The pump coastdown curve which is part of TP-200/13 acceptance criteria differs from the FSAR coastdown curve.

(See

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Details II, paragraph 6.)

P.

Thin Ualled Valves The results of L_J's ultrasonic measurement of wall thicknesses '

of valves within the reactor coolant system pressure boundary should be available for RO review during January 1973.

Q.

Loop Backflow

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RO is waiting for a procedure to verify loop' backflow analysis by tests on reactor coolant loops.

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R.

Flowmeter Error Analysis and Tests

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RO is awaiting informatica and action from DPC concerning this item.

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'l RO Report No. 50-269/72-11-7-

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Operational Quality Assurance Manual I

I DPC's " Administrative Policy Manual for Operational Quality Assurance of Nuclear Stations" has been issued, reviewed by RO,

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and RO comments discussed with DPC. (See Details I, paragraph 9.)

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Calibration of Liquid Flow Meter on Waste Discharge Line i

The calibration of the 0-50 gpm flow meter on the liquid d

waste discharge line has not yet been completed. This item is open.

(See Details III,' paragraph 3.)

U.

Incomplete Status of Gaseous Effluent Monitors

i Of the five monitors that were not fully operative at the i

end of the last health physics inspection (August 1972), three are still not completed. This item is open.

(See Details III, paragraph 4.)

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V.

Verifica: ion of In-Plant Air Flows The question of air flow from waste handling areas to clean areas (*

still exists. This item is open.

(See Details III, paragraph 5.)

W.

Installation of Solid Waste Compactor Installation of the solid waste compactor has been completed but exhaust blower motor is not installed. This item is open.

(See Details III, paragraph 6.)

X.

Spent Resin Transfer Procedure A procedure for spent resin transfers to a truck mounted essk has not been completed. This item is open.

(See Details III, paragraph 8.)

Y.

Calibration of Beckman Beta-Mate II

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The Beckman Beta-Mate II liquid scintillation detector, in the counting room, has not been calibrated. This item is open.- (See Details III, paragraph 10.)

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Z.

Calibration of Process Monitors At the completion of the previous health physics inspection (August 1972), seven process monit.:rs were not ccepletely_

-calibrated. Four monitors are not yet ready for operation.

This item is cpen.

(See Details III, paragraph 14.)

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R0 Report No. 50-269/72-11-8-

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AA. Completion of Decontaminr31on Facilities i

Decontamination facilities were not complete. This item is open.

(See Details III, paragraph 15.)

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i BB. Verification of Hood Air Flows Hood air flows have not yet been shown to be satisfactory.

l This item is open.

(See Details III, paragraph 16.)

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CC. Filter Test of Hydrocen Purg'e System

The air filter test of the hydrogen purge system has not been completed. This item is open.

(See Details III, i

paragraph 17.)

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V.

Design Changes

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None

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Unusual Occurrences,

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VII.

Other Significant Findings i

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VIII.

Management Inte rview

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A management interview was held on December 14, 1972, with Construction management <.nd Quality Control personnel, Beam, Freeze, and Aycock, in

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which the status of previously identified enforcement matters, as des-cribed in the Simmary of Findings. was discussed.

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At the conclusion of the inspection, a Management Interview was held on December 14, 1972, with the following DPC representatives presenti P. H. Barton - Manager, Technical and Nuclear Services

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J. E. Smith - Plant Superintendent K. S. Canady - Nuclear Engineer

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D. C. Holt - Assistant Nuclear Test Engineer R. M. Koehler - Technical Support Engineer j

M. D. McIntosh - Operating Engineer

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L. E. Summerlin - Staff Engineer

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The following items were discussed:

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Previousiv Identified Enforcement Matters

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RG' Report No. 50-269/72-11-9-l The status of previously identified enforcement matters, as described in the Summary of Findings, was discussed.

B.

Previously Reported Unresolved Items The status of previously reported unresolved items, as described in the Summary of Findings, was discussed.

C.

Training The inspector stated that he had reviewed DPC's initial operating staff training program as described in the FSAR and found that the training actually received by certain staff members did not meet the commitments specified in the FSAR. DPC representatives stated their intention to amend the FSAR to reflect training actually received.

(See Details I, paragraph 5.)

D.

Security The inspector stated that he had reviewed the security plan for the Oconee Nuclear Station. In a subsequent tele-phone conversation with the plant superintendent, the inspec-tor stated that the lack of definition of the present require-

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ments for Unit 1 security will be referred to Headquarters.

(See Details I, paragraph 6.)

E.

Hot Functional Tests The inspector stated that he had witnessed portions of tests 200/12, " Reactor Coolant Fump Flow Test," 200/34, " Reactor.

Vessel and Internals Flow Induced Vibration Test," and 330/3A

" Control Rod Drive Trip Test," and that no deficiencies in test conduct were observed.

The inspector stated that the control and instrument engineer had agreed to revise test procedure 330/3A to require the slowest and fastest control rods to be drop time tested an additional 25 times after the initial core is loaded. The plant superintendent indicated his concurrence.

F.

Review of Test Procedures The inspector stated that he had reviewed 22 out of 137 test procedures and the results of these tests. Com=ents on three of the tests were discussed and resolved with the licensee's management.

(See Details II, paragraph 2.)

G.

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Review of Maintenance Procedures The inspector stated that he had reviewed nine maintenance

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RO' Report'No.- 50-269/72-11-10-l (~'[

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l procedures out of twenty-four. Comments were discussed and i

resolved with the licensee's management.

(See Details II,

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paragraph 3.)

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Review of Operating Procedures The inspector stated that he had reviewed' 8 out of 88 operating procedures. Comments were discussed and resolved with the licensee's management.

(See Details II, paragraph 4.)

I.

Evaluation of Losses in Samole Delivery Lines

Management was informed that it appears that they have no

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evaluation nor verification of sample delivery line losses for two gaseous sample delivery lines. Management stated that a staff evaluation of this had been done and provided the inspector with a copy. Management further stated that this had been previously discussed in detail with Licensing

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l and they believed that no further action was required. The inspector agreed to review the report and follow up cn this

item.

(See Details III, paragraphs 20.a. and b.)

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Verification of Efficiency of Halogen Collection Media Management was informed that it appears that they have not

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verified, nor have any plans to verify, the efficiency of

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the halogen collection media in their process monitors.

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Management stated that this had been previously discussed

in detail with Licensing and their plan to frequently change the collection media was an adequate alternative to actually i

verifying efficiencies. The inspector agreed.co follow up j

on this item.

(See Details III, paragraph 20.c.)

K.

Iodine Condensation Losses in Sample Deliverv Line j

Management was informed that it appears that no measures

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are being taken to minimize, nor verify, iodine condensation

losses in the sample delivery line running down the outside of the stack. Management agreed to look into this situation.

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(See Details III, paragraph 20.d.)

L.

Representative Sampling of Liould Effluent During Discharge Management was informed that their program for sampling liquid waste did not provide for obtaining representative

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samples. Management agreed to look into this and come up

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with a proposal.

(See Details III, paragraph 21.)

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.-/ A c DETAILS I.

Prepared by:.

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j R. F. Warnick, Date'

l Reactor Inspector

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Facilities Test and

Startup Branch Dates of Inspection: Dec. 6, 12-14, and 16, 197.

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Reviewed by:

CC

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C. E. Murphy / /

Date*'

j Acting Chief

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i Facilities Test and l

Startup Branch

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Individuals Contacted

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Duke Power Company (DPC)

December 6, 1972 i

l W. O. Parker - Assistant Manager, Steam Production Department l

K. S. Canady - Nuclear Engineer

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i D. C. Holt - Assistant Nuclear Test Engineer f

I J. O. Barbour - Staff Quality Assurance Engineer

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M. L. Birch - Assistant Health Physicist T. E. Holland - Junior Engineer l

December 12-14 and 16, 1972

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. J. E. Smith - Plant Superint.ende*nt P. H. Barton - Manager, Technical and Nuclear Services

S. E. Nabow - Project Engineer K. S. Canady - Nuclear Engineer D. C. Holt - Assistant Nuclear Test Engineer M. D. McIntosh - Operating Engineer

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R. M. Koehler - Technical Support Engineer-G. W. Cage - Assistant Operating Engineer

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L. E. Summerlin - Staff Engineer R. L. Wilson - Performance Engineer G. M. Thra11 kill - Staff Engineer C.

L.. Thames - Health Physics Supervisor 0. S. Dradham - Instrument and Control Engineer D. G. Beam - Project Manager, Construction D.'L. Freeze - Principal Field Engineer C. B. Aycock - Senior Field Engineer Four Duty Supervisors Three Shift Supervisors (or Assistant Shift Supervisors)

Two Test Coordinators Two Instrument Technicians One Control Room Operator

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Contractor Organizations I

i Babcock and Wilcox Company (B&W)

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D. E. Thoren - Principal Engineer

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2.

Failyre to Implement Approved Procedures for Control of _bNnconforming

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Q3,71 cal Items 1/

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The inspector reviewed a draft copy of the recently revised procedure Q-1, " Control of Nonconforming Items." This procedure is now compatible

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with procedure R-2.

Procedure R-2 allows each inspection procedure to include methods of g

correcting and documenting nonconformities which are observed during

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inspections. When a method is not specified in an inspection procedure, procedure R-2 requires that form Q-lA be used to document the nonconformity.

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A problem of conflicting instructions had existed because the old procedure Q-1 required those items which did not conform with QA

procedures, field installation procedures, specifications, codes, or design drawings to be documented and reported on the Q-1A form,

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" Nonconforming Item Report Sheet."

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This previously identified item of noncompliance is now closed.

3.

Insta11attin of Cable Without Documen'tary Evidence That Cable Met Procurement Specificationl/

The inspector was informed that all QC field engineers were instructed

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during a regular staff =eeting that whenever cable'QC documentation is not available onsite, it is to be obtained by telecopier from DPC's Design Engineering office in Charlotte, North Carolina, prior to using the cable.

DPC's electrical QC conducted an audit on Auge t 22, 1972, to deter-

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mine the percent of reels of safeguards cables, with jackets other than black, that were onsite available for use without having written approval onsite by DPC's Engineering Department to use these reels. This audit revealed that only one reel out of 659 reels had not been properly re-leased for installation and that one has since been corrected. The inspec-

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tor reviewed the audit and there are no further questions.

This previously identified item of noncompliance is now close,d.

1/ See RO Inspection Report No. 50-269/72-8 Section II, paragraph 10.

2/ See RO Inspection Report' No. 50-269/72-8,Section II, paragraph 15.

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4.

Failure to Establish Measures.to Indictee tLL..atusofCable/

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Procedure S-2 (not S-1 as indicated by a typographical error in RO Report Nos. 50-269/72-8, 50-270/72-7, and 50-287/72-5) was

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revised on November 6, 1972, to specify the documentation that

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is required to be turned over to Operations at the time systems and QA documentation are transferred from Construction to Operations.

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As reported in the previous inspection,1/ the identification of cable at Unit 1 was not always known when systems and the QA documenta-l tion were transferred. The inspecto'r was informed that all cable for Unit 1 has since been identified.

This previously identified item of noncompliance is now closed.

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' Training The inspector reviewed DPC's initial operating staff training program as described in paragraph 12.2.1 of the FSAR and compared the training actually received with the training commitments specified in paragraph 12.2.1.

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The inspector found that certain control operators, assistant control

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k operators, utility operators, and instrument and control technicians were not assigned to the training programs as stated oc page 12-7 of the FSAR. This was discussed in the management interview. DPC representatives stated their intentipn to amend the FSAR to reflect training actually received.

The assistant superintendent, operating engineer, technical support engineer, assistant operating engineers, shift supervisors, health physics supervisor, instrument and control enginee*, and the chemist received the training stated on page 12-7 of the FSAR.

The inspector reviewed the documentation of the training received by one shift supervisor, one assistant shift supervisor, and one assistant operating engineer. There.was no documentation of the shift supervisor's'

home study program. The aLJistant shift superv'.sor received six weeks training at H. B. Robinson nuclear plant rather than at the Saxton plant.

All.other traf ning commitments for these three 1.nd4 tiduals were documented.

• According to an assistant operating engineer with responsibilities for training,'two control operators did not complete the' Westinghouse 3eactor

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- Operator Training, three assistant control operators did not participate in the home study course nor the full-time cL..sroom instruction in Charlotte (although they did participate in the classroom inIstruction at

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the reactor site). Of the two utility operators e= ployed prior to January 1, 1970, one did not. participate in the nome study course nor the B&W training cours.e at the Lynchburg Pool React:

The FSAR does

not specify training for the utility operators hire'

ter January 1, 1970.

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1/ See RO Inspection Report No. 50-269/72-8,Section II, paragraph 1.

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50-269/72-11 I-4

., 'R0 Repert No.

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DPC has 28 utility operators hired after January 1, 1970, that have nuclear navy experience. Seven non-Navy utility operators hired after e

January 1,1970, have completed full-time classroom instruction at the

reactor site, the B&W training course at the Lynchburg Pool Reactor,

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and Oconee plant design training course at the reactor site.

i The inspector was informed that 23 recently hired instrument and control technicians have not received the B&W Oconee Plant Design

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Training specified in the FSAR.

6.

Security

The inspector read the Oconee Nuclear' Station security plan. The plan has been submitted to Licensing for review. A DPC representative informed the inspector that it was DPC's understanding that the

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security plan had to be submitted to Licensing (but not approved) prior to receiving a license for Unit 1 and that the plan had to be approved by Licensing prior to receiving a license for Unit 2.

He stated that the plan has not been implemented. The inspector did rot comment

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on the adequacy of the plan since it is being reviewed by Licensing.

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The lack of definition of a temporary security plan for Unit 1 will

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be referred to Headquarters for resolution.

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Vibration Testing of Engineered Safeguards Piping Syste g i

The inspector reviewed a draft copy of the miscellaneous test proposed to check the vibration of various piping systems. According

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to the procedure, portions of the following systems will be monitored for vibration:

a.

Low pressure injection including core flood, decay heat removal,

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and li-inch supply to pressurizer, j

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b.

High pressure injection, c.

Spent fuel cooling,

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d.

Low pressure service water, I

e.

Component cooling, f.

Steam generator flush and drains through the first isolation j

valve off the steam generator, g.

Reactor coolant system loop piping through the first isolation

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valves off the reactor coolant system,

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h.

Reactor building spray, and

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i. Reactor coolant pressurizer spray and surge.

Based on the inspector's comments, DPC agreed to give the test procedure

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a number, and also agreed to correct the units of the ordinate (Y axis)

on the acceptance criteria graph.

This previously unresolved item is now closed.

8.

ReactorCoolantFlowl/

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Test procedure TP-200/5B, " Reactor Coolant Loop Flow Data Test,"

indicated the measured cold flow differed from the expected flow stated in the FSAR. Since this concern was first discussed, exten-sive modifications have been completed on the reactor internals.

Because of the modifications, reactor coolant flow tests as de-scribed in TP-200/12, " Reactor Coolant Pump Flow Test," will be rerun before and after initial core loading. The results will be reviewed as part of the normal inspection effort to review the hot functional test results.

This previously identified unresolved item is closed.

9.

Administrative Poliev Manual for Operational Ouality Assurance of (

Nuclear Stations The inspector received a draft copy of DI2's Administrutive Policy Manual for Operational Quality Assurance of Nuclear Stations. This was reviewed and comments prepared by RC:II were discussed with Parker, Holt, Holland, Birch, Barbour, and Canady on December 6, 1972, in the DPC office at Charlotte, North Carolina.

On December 15, 1972, DPC issued approved copies of the manual. All of RO's co==ents have not been incorporated into the approved manual.

RO's position is that prior to reco= mending that DPC receive a license to load the initial core into Oconee 1, the remaining RO:II coccents must be satisfactorily resolved, the administrative procedures approved, and the program implemented. Copies of the manual (with the resolved

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concerns at least temporarily noted) must be available to reactor and quality assurance personnel."

RO:II's comments and DPC's position are as follows:

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a.

Connent: The definitions of " abnormal occurrence" and " unusual event" as stated in the manual differ from definitions stated in the Technical Specifications (TS). To avoid confusion, the defini-tions should be in agreement (manual paragraphs 1.2.2.1 and 1.2.2.35).

Response: DPC will consider changing the Oconee 1 TS.

1/ See. R0 Inspection Report No. 50-269/72-7,Section II, 'aragraph 10.

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b.

Comment: The independence of the Steam Production Department

quality assurance engineer is not evident. Paragraph 1.4.2.3.3 (of the draft copy) states that he "is responsible to the Assistant Vice President, Steam Production for matters pertaining to operational quality assurance." Figure 1.4-2 shows him under the manager, opera-

, tion and maintenance.

• Response: DPC indicated that he is responsible to the Assistant Vice President for matters pertaining to operational quality assurance but that he reperts to the Manager, Operation and Maintenance for pay and other administrative reasons.

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c.

Comment: Figure 1.4-3 (of the draft copy) does not show the

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station QA personnel. It is our understanding that at least i

one quality engineer reports to the staff engineer for pay and other administrative reasons but is responsible to the plant superintendent for m.itters pertaining to quality assurance.

The manuai does not discuss statica QA personnel, their duties, nor their responsibilities.

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Response: This is shown in the latest revision to Figure 1.4-3.

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It will be revised to show a dotted line from station QA personnel to the plant superintendent.

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Station QA personnel duties and responsibilities will be added.

d.

Comment : In paragraph 1.5.3, the allowed revisions do not include improvements in control of quality.

Response: DPC did not mean to exclude revisions of this type.

DPC will review and put it in.

e.

Com=ent: In paragraph 2.1.5.5, refetence is made to " periodically" verify that the various working files and index of the drawings are valid and accurate. The frequency needs to be specified.

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Response: DPC will specify the frequency.

f.

Comment: Records need to be maintained of modifications (design changes) and also of all evaluations to determine if "unreviewed

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safety questions" exist (manual sect. ion 2.2).

Response: This will be covered under the " Station Modificatiens" section.

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g.

Comment: Each station needs a list of measuring and test equipment

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complete with calibration requirements, calibration frequencies,

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calibration procedure, storage requirements, and manufacturer's recommendations (manual paragraphs 2.3.3.2 and 2.2.3.3).

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Response: Such information will be available at each station.

h.

Co= cent: Paragraph 2.4.1 states that section 2.4, " Control of Materials, Parts, and Components," "shall be applicable to those l

items for which quality assurance certification is required."

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DPC needs to identify those items for which quality assurance

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certification is required to ensure consistancy of application l

and effort in the spare parts program.

I Response: This will be done for each station and will be available at the station.

1.

Comment: The details of the training, retraining, and replace-

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ment training programs need to be available at the station.

l Response: The training programs will be available at the station.

I j. Comment: The frequency of audits to be conducted by the Steam

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Production Department quality assurance engineer is not sufficient.

The frequency in the draft copy was at least quarterly. This has been' changed to semiannual (manual paragraph 2.6.2.3).

Response: DPC intends to do more than the mininum amount of at?.its.

Until the first refueling, audits will be conducted at least qu. rterly.

k.

Comment: The word "should" denoces a recommendation while the word "shall" denotes a requirement according to DPC definitions. The paragraphs that key on the word "should" are not inspectable. In the draft copy of the manual paragraphs 3.1.3, 3.1.4, 3.1.6, 3.2.1.5, 3.2.1.6, 3.2.2.6, 3.3.2.9, and 3.3.3.9, many "shoulds" are used where "shalls" need to be used.

Response: The use of "shall" rather than "should" will be

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considered.

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1.

Comment: Paragraph 3.1.5 needs to make it clear that response procedures need to be prepared for all alarms. In addition to training, the book of alarm responses needs to be available in the control room for reference.

Response: Response procedures will be prepared for all Unit 1 alarms and they will be available in the control room.

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Comment: Paragraph 3.4.1 states that the requirements of section

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3.4 shall be applicable to modifications of safety-related structures,

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systems and components. These need to be identified for consistent i

application by DPC personnel.

Response: This will be done for each station.

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Comment: Do station modifications spoken of in section 3.4

require engineering approval?

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Response: This section has been rewritten.

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Additional comment: The new section 3.4 only requires approval

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by the Station Review Committee and the plant superintendent when the modification does not involve an unreviewed safety question or change the TS.

Changes to the design need to receive the same reviews and approvals as the original design.

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Comment: Paragraph 3.5.5.2.1 defines Class A, Class B, and Class C cleanliness. How will station and QA personnel know the cleanliness requirement for each system?

Response: This has been provided for each station.

p.

Comment: Paragraph 4.1.1 states, "The requirements of these

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instructions shall be applicable only to those materials,

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parts and components requiring quality assurance documentation."

The reouired materials, parts, and components need to be identified.

Responsc: A list will be provid'ed for each station.

q.

Comment:

In paragraph 4.3.2.2.6, a major change is defined as

"a change to a test procedure which affects the intent of the applicable approved procedure..." This d?.finition is sub-ject to interpretation because of the word " intent." Minor i

changes need to be limited to typographical, editorial, or ob-f vious mistakes. All other changes should be major changes.

As an alternate, a system to permit temporary changes as dis-

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cussed in ANS 3.2, and which provides for formal reviews and-approvals, may be used.

Response: This will be considered.

r.

Comment: Test results need to be reduced to meaningful and

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understandable form. This is not covered in the document.

Response: This will be included in the =anual.

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s.

Comment: Have the requirements of Criterion XVI, " Corrective Action," of Appenc'ix 3 to 10 CFR 50 been cowred in the manual?

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RQ Report'No. 50-269/72-11 I-9 Response: This will be checked to see the requirements are adequately covered.

10. Conduct of operations During the hot functional testing of Oconee Unit 1, the inspector observed the conduct of reactor operations on December 12 on the

12-8 shift and on the 4-12 shift, on December 14 on the 8-4 shift, and on December 16 on the 4-12 shift. The inspector witnessed parts of the following tests:

TP-200/12, Reactor Coolant Pump Flow Test TP-200/34,. Reactor Vessel and Internals Flow Induced Vibration Test TP-200/36, Loose Parts Monitoring System Functional Test TP-330/3A, control Rod Drive Trip Test TP-600/18, Reactor Protection System Functional Test The inspector verified that test prerequisites had been completed and signed off and that the test procedures were being followed.

No deficiencies in test conduct were noted.

• 11. Control Rod Drive Test To Determine Rod Drop Times The inspector determined during discussions with the instru=ent and control engineer concerning TP-330/3A, " Control Rod Drive Rod Drop Time Test," that after initial core loading, DPC was not planning to drop the fastest and slowest rods an additional 25 times. They were ::-

planning to drop the slowest and fastest rods during hot functional l

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tests when only five rods are installed.

j The discussion resulted in DPC agreeing that all rods will be dropped and time tested after the initial core is loaded, and that the slowest i

and fastest will be repeated an additional 25 times. Following subse-quent fuel reloads, the fastest and slowest rods will be retested fewer than 25 times.

This was discussed in the management interview. DFC manage =ent agreed -

to the testing following the initial fuel loading.

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RO Report No. 50-269/72-11 II-1 (~

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DETAILS II Prepared By:

AGYt

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F. Jape, Reactor Date

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Inspector, Facilities Test and Startup

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Branch

{

Dates of Inspection: Deccmber 12-14, 1972 December 18, 1972

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December 20-21, 1972

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Reviewed by:

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C. E. Murphy, Acting Date Chief, Facilities Test

and Startup Branch i

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1.

Individuals contacted Duke Power Company (DPC)

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J. E. Smith - Plant Superintendent

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M. D. McIntosh - OpeJacing Engineer R. M. Koehler - Technical Support Engineer L. E. Summerlin - Staff Engineer

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K. S. Canady - NucleaJ Engineer D. C. Holt - Assistant Nuclear Test Engineer

E. D. Brown - Maintenance Supervisor T. McConnell - Engineer J. Neal - Shift Supervisor

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R. O. Frink - Test Coordinator

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N. Rutherford - Duty Supervisor 2.

Review of Test Procedures The following 22 test procedures were reviewed and the test results evaluated by the inspector. Questions on two of the procedures were discussed and resolved with the' licensee's representative. The

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inspector had no questions or comments on the other 20 test procedures or test results.

TP 200 1D Emergency HP Injection Flew Instrument Pre-Operational Calibration TP 203 1B Borated Water Storage Tank Temperature Instrument Calibration TP 203 1C Flow to RV from LP Pumps Flow Instrument Calibration TP 203 1D LP _ Injection Temperature Instrument Calibration f

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TP 202 10 Heat-up of LDST for RCS Hydrolysis TP 203 2 Borated Water Storage Tank Leak and Functional Test TP 203 3.

LP Injection Siphon Electric Test TP 204 1B RB Spray System Plow Instrument Calib' ration TP 204 1A RB Spray System Press Instrument Calibration TP 204 3 RB Spray System Pumps and Valves Electric Test TP 301 3D N 14 Intermediate Range Calibration TP 305 5A RB Hi Press Trip Channel A TP 210 1D CA Boric Acid Pump Discharge Press Instrument

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Calibration I

TP 210 1C CA Boric Acid Tank Level Instrument Calibration i'

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TP 230 11 Keowee Hydro Tailrace Minimum Flow Test

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.+e, TP 233 2 LW Miscellaneous Waste Transfer Pump Discharge Press Instrument Calibration TP 233 1 LW Miscellaneous Waste Holdup Tank Level Instrument a

Calibration TP 233 11 LW High Activity Waste Tank Level Instrument Calibration

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TP 234'4 GWD Waste Pilter Delta P Instrument Calibration

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i TP 270 1C Main Steam Header Pressure TP 270 1S Turbine Bypass Valves Instrument Calibration

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TP 270 IT MS Supply to Auxiliary Steam Header

l The first question raised by the inspector had to do with_TP 301 3D.

In this procedure, one of the final steps was-to verify that all of the reactor protective channels were untripped. The space provided

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for checkoff of this item was marked "not applicable." A licensee's representative explained that this procedure is to be converted to a periodic test and when used again, the step in question becomes Jimportant but that during the initial test, this step haa no signifi -

i cance.. The inspector agreeded with.this answer and had no further

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questions.

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The second question had to do with TP 23011. One of the licensee's auditors had noted that the test method used was not in agreement with the method described in the FSAR. The licensee's representative

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stated that the FSAR has been revised and that the test method used was as described in the FSAR. The inspector had no further questions.

3.

Review of Maintenance Procedures j

j The following nine maintenance procedures, which represent approxi-

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mately 25% of the maintenance procedures, were reviewed by the

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inspector:

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MP 1400 1 - RC Pumps MP 1400 2 - Pressurizer Relief Valve Removal and Replacement MP 1400 SB - CRDM Motor Tube Removal and Installation Procedure

HP 1400 SC - cRDM Motor Tube Stator Removal and Installation Procedure

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MP 1400 SD - CRDM Motor Tube PI Removal and Installation Procedure MP 1400 SE - CRDM Motor Head Screw Removal and Installation Procedure i

MP 1400 8 - Reactor Internal Vent Valve Removal and Replacement MP 1400 09 - Incore Monitor Piping Repair MP 1400 10 - HP Injection and Purification Filter Replacement The inspector had no questions on the individual maintenance proce-

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dures but questions and comments that applied to all maintenance procedures were discussed with the licensee's representatives.

Resolution of these questions and comments was as follows:

a.' Post-Maintenance Checkout Inspector's Com=ent The procedures do not include a post-maintenance checkout before returning equipment to service.

Licensee's Response

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An administrative procedure will be prepared to require and

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describe a post-maintenance checkout.

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b.

Test Equipment Control Inspector's Comment The individual procedures state that tools and equipment used for maintenance are to be in good working condition. How

~ will the handling of test equipment such as *.orque wrenchs,

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pressure gauges, dial indicators, etc., be covered?

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Licensee's Response An administrative procedure will be prepared to cover care and treatment of test equipment.

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c.

Maintenance Records Inspector's Comment

In the FSAR, it is stated that, records of preventive maintenance and repair to all major equipment will be maintained. Will the individual, completed maintenance procedures be retained as a record > or will the records be generated by some other

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means?

Licensee's Response

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An administrative procedure will be prepared to provide instruc-tions regarding the form and filing system for maintenance records.

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d.

Replacement Parts

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Inspector's Comment What controls are to be used to insure replacement parts have

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the proper QA documentation?

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Licensee's Response l

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An administrative procedure will be prepared covering the con-

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trol of replacement parts for the station's safety-related structures.

i Vendor Manuals Referred to Within a Maintenance Procedure e.

Inspector's Ccement

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What reviews are planned'for revisions of vendor manuals in maintenance procedures?

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Licensee's Response

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-These documents are received and reviewed by the Design Engineering Department. Each =anual is identified by a number following its review and prior to issuance to the stat, ion i

superintendent.

4.

Review of Operating Procedures

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The following seven operating procedures were reviewed by the

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RO Report No. 50-269/72-11 II-5 7-

inspector:

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OP 1102 15 - Fill and Drain Fuel Transfer Canal OP 1103 02 - Filling and Venting RC System OP 1103 04 - Soluble Poison Concentration Control OP 1103 05 - Pressurizer Operation OP 1103 06 - RC Pump Operation OP 1104 01 - Core Flooding System

.

OP 1104 02 - EP Injection System Operation Procedure

The following comments were discussed and resolved with the licensee's representative.

a.

Inspector's Comment When using a procedure, are the steps to be performed in any particular sequence, and if so, how or where is this require-ment conveyed to the user?

Licensee's Response In sore procedures, the sequence is important and in others, it is not.so important. This is usually obvious from the nature of the procedure. An administrative procedure will be prepared on this subject.

b.

Inspector's comment

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In seme operating procedures, r limit is given that is identical to the Technical Specification and in others, the limits are more conservative than Technical Specifications. How'will an overrun of limits be handled to ensure an overrun of a Technical Specifi-i cation is reperced as required by Technical Specifications 6.37 Licensee's Response An administrative procedure will be prepared to give detailed

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instructions on required action when a limit is exceeded.

c.

Inspector's Comment In OP 1103 06, " Reactor Ccolant Pump," there are four conditions given for stopping a pump. Will operator action be taken to

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adjust reactor pcwer level before a pump is stopped or will the integrated control system be expected to adjust power?

Licensee's Response i

A note will be added to OP 1103 06 giving instruction on actions to be taken by the operator before stopping a reactor coolant pump.

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.e 5.

Field Test of Steam Generator 1B A test of steam generator 1B will be conducted as described in TP

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800/22, " Thermal Measurements for 13 OTSG Fluids."

The copy of this procedure that was reviewed by the inspector did not contain acceptance criteria. This was discussed with the licensee's representative and the licensee indicated that an appro-priate. statement for acceptance criteria will be added to the test procedure.

This previously identified unresolved item is now closed.

6.

Reactor Coolant Pump Flow Tests The licensee provided test procedures TP 200/12, "RC Pump Flow Test,"

and TP 200/13, "RC Flow Coastdown Test," in response to the previously identified unresolved items regarding the reactor coolant pump flow tests. These procedures were reviewed by the inspector.

The inspector commented that both procedures called for jumpers to be installed to bypass an interlock and that control and subsequent c-removal of the jumpers was not included in the test.

The licensee's

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representative stated that the procedures would be revised to include a reference to the jumper and bypass procedure. With this change, the question is considered resolved.

The inspector commented that the ficw coastdown acceptance curve chown in Figure 1 in the test procedure did not agree with the

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coastdown curve presented in Figure 14-16 in the FSAR. The licensee's representative stated that these curves would be reviewed and corrected before the test is completed. The inspector stated that until the licensee corrects the discrepancy, this unresolved item will remain open.

7.

Reactor Internals Inspection following Hot Functional Testing

_

The licensee has provided TP 200/22, " Reactor vessel Internals Inspection," which prescribes the extent of the inspection of the reactor internals following hot functional. testing. This test procedure was reviewed by the inspector, and the following

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comments were discussed and resolved with the licensee's representative.

la. Inspector's Cec =ent

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.In the Limitations and Precautions section of the procedure, a reference to Class A Cleanliness" is made. Where.is Class A

Cleanliness defined?

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Licensee'o Response This reference will be deleted frca the procedure and in its place, a descriptive statement for cleanliness will be added.

b.

Inspector s Comment The acceptance criterion does not provide a means for deter-mining if the results of the internals inspection is acceptable or not.

Licensee's Response The criterion will be restated to permit an evaluation.

c.

Inspector's Comment The 96 bolts which attach the thermal shield to the flow distributor and the 20 support pads en top of the thermal shield are not included in the list of items to be inspected.

Licensee's Response

These items will be added to the inspection list.

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This previously identified unresolved item is now considered closed.

8.

Internals Vibration Test i

The licensee has provided-TP 200/34, "RV and Internal Flow Induced Vibration Test," and TP 300/36, " Loose Parts Monitoring System Func-tional Test and Field Adjustment," which prescribes the monitoring program to be run during hot functional testing. These procedures were reviewed by the inspector. There are no questions or comments en these two tests.

This previously reported unresolved item is now closed.

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9.

Failure to Document Test Results This matter was initially discussed in RO Inspection Report No. 50-269/

72-8,Section V, paragraph 4, and a reply was received from the f

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i licensee on November 24, 1972.

A memorandum was issued on November 24, 1972, to emphasize the need for documentation of test results. The memorandum ~as distributed to

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personnel who have responsibility for performing tests.

In addition to the above corrective action, the licensee's repre-

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sentative has stated that an audit team will be conducting checks

'during the actual performance of tests.

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This matter is closed.

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10. Failure to Document Changes to a Test Procedure This matter was initially discussed in R0 Inspection Report No. 50-269/

72-8,Section V, paragraph 4, and a reply was received from the licensee on November 24, 1972.

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Instructions have been issued to emphasize adherence to the " Guide for Conducting the Preopera 13nal Test Program." The instruction emphasized that any change to a test procedure must be properly documented.

This matter is closed, 11. Regulatory Operations Bullecin 72-2, " Simultaneous Actuation cf a Safety Injection Signal on Ecth Units of a Dual Unit Facility" A review of the electrical distribution system at the Oconee Nuclear Station was completed. A separate inverter supplies power to each of the three redundant engineered safeguards logic channels. Admini-strative control permits only one of the power supplies to be removed from service at a time for maintenance or testing. The inspector was advised by 'the licensee that with this arrangement, only one channel of the ES protection system could be actuated by loss of a.c. power or maintenance activities.

The inspector has no further questions on this item.

.

12. Plant Security The-inspector visited the plant at about 2045 hours0.0237 days <br />0.568 hours <br />0.00338 weeks <br />7.781225e-4 months <br /> on December 20, 1972, to observe the conduct of precperational tests. The shift supervisor on duty challenged the inspector and would not allow him entry to the plant until he was able to identify himself. A repre-sentative of the licensee, who recognized tne inspector identified

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him to the shift supervisor.

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13. Witnessing of Tests Portions of the following preoperacional tests were witnessed:

TP 270/33 - Main Steam Relief Valve Test TP 230/5 - Soluble Poison Control Test TP 200/34 - RV and Internal Flow-Induced Vibration Test TP 200/36 - Loose Parts Monitoring System Functional Test and Field Adj ustment No deficiencies or unusual events were observe.

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14. Review of Preoperational Tests The review of preoperational test procedures and evaluation of test results, to date, is summarized below:

Category I

II III Test Procedure Reviewed 83%

31%

3%

Evaluated Test Results 50%

39%

3%

Audits of Categories I, II, and III test results verify that the licensee is reviewing and evaluating all preoperational test results.

15. Failure to Follow Administrative Procedures for Preoperational Testinr, The changes made to IP 202/7, "HPI Operational Test," were discussed with the licensee's represencative and it was concluded that the intent of the test was not changed; and the changes were made in'accordance with the definition given in the " Guide for Conducting the Oconee Preoperational Test Program." This guide is being incorporated into the Operational Quality Assurance Manual. Regulatory Operations'

comments on the definition of major and minor changes are included in the review and discussion of the QA manual currently underway.

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DETAILS III Prepared by:

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/~ 27-77 C. M. Campbell, Date

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Radiation Specialist,

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Radiological and Environmental Protection Branch Dates of Inspection: December 12-14, 1972

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Reviewed by: / (/ [/

edy!/.7. ?- 7 7 g/. T. Sutherlan?d, '

Date Acting Chief, Radiologi-cal and Environmental Protection Branch 1.

Individuals Contacted (All Duke Power Company)

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M. D. McIntosh - Operating Engineer

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R. M. Koehler ' Technical Support Engineer C. L. Thames - Health Physics Supervisor O. S. Bradham - Instrument and Controls Engineer

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C. T. Ycngue - Health Physics Technician 2.

Organizational Changes None 3.

Comoletion of calibration of licuid flow meter on rad waste discharge

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line

Discussion with licensee representatives indicated th'at this has not yet been completed and is pending completion of LPSW (low pressure service water) system. Licensee representative stated that the system hopefully will be completed ne.xt week (December 18-22, 1972)

and then the flow meter calibration could be completed in a couple of days.

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4.

Completion of work on gaseous effluent monitors Five gaseous effluent monitors were not fully operational during last health physics inspection. Current status of there units is as'follows:

a.

Unit Vent Particulate (RIA-43)

Calibration now completed.

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Spent Fuel Building Gas (RIA-41)

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Licensee representative stated have had additional problems with pump failures. The licensee is currently revising the discharge lines in an attempt to get the desired pressure drop. A licensee representative stated completion should be fairly soon as piping revisions are in process.

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c.

Unit Vent Iodine (RIA-44)

Calibration was not complete. A licensee representative l37 l33 rather than Cs source stated that they had received a Ba fror. the vendor and are in process of exchanging for correct source. He further stated that calibration would be completed upon receipt of correct source from

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vendor.

d.

Reactor Building Particulates (RIA-47)

Calibration is still not complete. A licensee representative stated they are having flow problems with this unit.

e.

Reactor Building Iodine (RIA-48)

Calibration of this unit is now complete.

5.

Ve'rification of in-plant air flows

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Verification of in-plant air flows has not yet 'been completed.

A licensee representative stated that modifications to the existing ventilation _ systems are in process and when'these are completed verification of air ficws will be performed and documented. He further stated that plans will be made to per-

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form air flow testing on a periodic basis.

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6.

Solid waste comuactor

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Solid waste compactor and exhaust have been installed. The exhaust blower motor needs to be reinstalled. An operating procedure for the compactor has been written and includes compactor operation as well as collection and storage of low level solid waste. Upon completion of repairs the blower motor will be installed.

7.. Solid waste packaging procedures

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There will be two procedures dealing with packacing of solid waste.' One is the procedure referenced in paragraph 6 above and the other will be a " Shipment of Radioactive Materials" procedure which a licensee representative stated is still in the process of being completed..

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8.

Spent Resin Transfer Procedure

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A detailed procedure for the transfer of spent resin to a truck mounted cask is not completed. A licensee representative stated this will be part of a shipment of radioactive materials procedure that is currently in draft status.

9.

Health Physics Training Records

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Licensee representatives stated that a system of maintaining and

. updating training records has been implemented and responsibility for this has been assigned to an individual (designatad the Training Supervisor) in the Operations Department. F.ach time a training course is completed a list of attendees who completed the course 'a compiled and provided to the Training Supe 3 visor. A licenset cepresentative provided a typical coepleted sheet to the inspector for review. The inspector questioned tle retriev-abxlity of an individual's current training history and was assured that-this could be done. The inspector stated that we would look at some individual training histories on a subsequent inspection.

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10. Beckman Beta-Mate II

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I Calibration of the Beckman Beta-Mate II Jiquid scintillation'detec-tor, in the counting room, has not yet been completed. A licensee representative informed the inspector that the holdup was caused by delay in obtaining a transformer from Beckman. Vendor promised delivery date is December 18, 1972..

11. Completion of change rooms i

Installation of shelves in the pool area change room has been completed. Lockers have been provided for the roo= designated as the hot machine shop change room. The inspector also observed

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that protective clothing was readily available from the main change

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A licensee representative explained that his plan was not to room.

actually supply the two change rooms until construction traffic had

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diminished or there was a need for clothing in these areas. Clothing is supplied where needed, such as access areas to the fuel storage pool, and readily'available for use as needed. Personnel in the hot machine shop will normally use the main change room. The hot machine

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shop " change room" will serve as an auxilliary change room as deemed necessary by health physics.

12. Calibration of area radiation monitors Calibration of the area radiation monitors (RIA's 1-17) has.been completed. The inspector reviewed the calibration documentation for these seventeen units.

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RO Report No. 50-269/72-11 III-4 es 1,3. Installation of count rate meters Installation of the mounting racks for all 21 count rate meters has been completed. A licensee repreeentative stated that all the units are calibrated, operational and ready for installation and all units will be set in place when traffic decreases in these areas. One unit is in place and operating continuously.

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14. Calibration of process monitors At the time of the previous (August 1972) health physics inspection seven process monitors had not been completely calibrated. The cali-bration of t'aree of these units has been completed (RIA-16, 17, 43). A licensee representative stated that completion of the calibration of process monitors RIA 31 and 35 is pending completion of the LPSW system. The calibration of process monitors RIA 44 and 47 was not completed.

(See Details III, paragraph 4.c. and 4.d.).

15. Status of Decontamination Facilities Work continues on completion of the decontamination facilities.

The drain to the ultrasonic unit has been installed. Installation of the hood and associated exhaust duct has been completed but hook-up of the duct to room ventilation duct has not been completed.

Plans are to complete this installation as soon as possible.

16. Verification of air flow in laboratory hoods Verification of air flows in the hoods in the health physics and-radiochemistry laboratory has not been done. Modification of the ventilation system to these hoods is in process. A licensee repre-sentative informed the inspector that the verification and documenta-tion of the air ficws would be performed upon satisfactory completion of the work on the ventilation system.

17. Filter testing of reactor building and hydrogen purge systems

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The filter testing of the Reactor Building purge system was completed on October 4, 1972. The filter testing of the hydrogen. purge system has not been performed. Licensee is planning to conduct this test.

18. Verification that stack sampling probe is isokinetic Discussions with licensee representatives and review of vendor drawing indicated that the stack (unit vent) sampling probe was designed to be isokinetic and was specifically designed for the existing piping and anticipated flows at its present location.

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s 19. Adequate flow from Keowee tailrace continuous wafer sampler

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During the previous health physics inspection (August 1972) it was observed that the licensee was having problems maintaining an adequate flow from the continuous water sampler in the Keowee tailrace. Plans were to change out a valve to correct this situation. Revisions to the Technical Specifications have since deleted the requirement for obtaining a continuous water sample

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from the Keowee tailrace during discharge of liquid effluents.

During discussions with licensee representatives the inspector was informed that in view of no longer having this requirement the continuous water sampling system was being modified. The submersible pump was being replaced with a pump counted on the existing platform below the bridge. A licensee representative told the inspector that the use they now foresee for the system is to obtain periodic samples to fullfill some requirement in the non-radiological environmental monitoring program. Since a con-tinuous water sampler is no longer required and the need and function of this sampler is uncertain this item was removed from the outstanding items list (OIL).

20. Minimization and calibration of sample loss in delivery lines:

a.

Sharp angle bends in sample delivery lines Licensee has removed sharp angle bands from the sample delivery line from the stack (unit -vent) to process monitors (RIA-43, 44, 45, 46). The licensee has not removed these bends from the sample delivery 'line from the reactor building to process monitors RIA-47, 48 and 49.

A licensee represent'a-tive informed the inspector that a Station Problem Report, dated December 14, 1972, had been submitted to their Engineering Department requesting evaluation and correction of this problem.

b.

Evaluation of losses in sample delivery lines Discussions with licensee personnel indicated to the inspector

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that no evaluation nor verification of the losses in the two sample delivery lines, referenced in paragraph a. above, had been done. Further discussions with management representatives revealed that a staff evaluation of the potential iodine plate out problem in the unit vent monitor sample line had been done.

The evaluation does not discuss the topics of particulate losses nor any losses in the delivery line from the reactor building to its process monitors. In further discussions manage =ent represen-tatives indicated that this topic had been reviewed by Licensing and their approach found adequate. Based on previous licensing

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reviews and the staff evaluation management's position is that

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they do not believe any additional action is required. A licensee

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representative stated that they have no way to obtain samples from the stack end of that delivery line for comparison with samples

obtained at process monitors but could obtain samples from the

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reactor building for comparison with samples obtained from those

process monitors.

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c.

Verification of efficiency of halogen collection media

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Discussions with licensee representatives showed that they presently have no verification of the collection efficiency

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of the halogen collection media in the process monitors looking

at samples drawn from the stack (unit vent) and the reactor

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building. A licensee representative stated they are planning to use the manufacturer's efficiencies and frequent changing (weekly) of the collection media as a means to assure their i

efficiencies are not dropping below the manufacturers values rather than actually determining the efficiencies. Manage-ment representative further stated that this approach was previously discussed in detail with Licensing personnel and found to be acceptable. Management's position is that no additional action is necessary.

i d.

Iodine condensation losses in samole delivery line Discussion with licensee representatives indicated that no measures have been taken to minimize iodine condensation losses in the outside sample delivery line running from the stack'(unit vent) to its respective process monitor. The sample delivery line is about 93 feet long aad for much of that run is essentially a vertical run of pipe. A licensee representative also stated that there is no drain in this line. The inspector pointed out the possibility of condensate flow to the detector. Management agreed to *.ake a look into this situation.

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21. Representative sampling of liquid effluent during liquid waste discharge

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The inspector pointed out that it does not appear that the licensee

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will be' obtaining representative samples of liquid' effluent during liquid waste discharges. Liquid waste can be discharged to the Keowee tailrace from either the Low Activity Waste Tanks (LAWT)

or the Condensate Test Tanks (CTT). Discussions with licensee-representatives, review of drawings, and licensee procedures revealed the follow ng information:

a.- Low Activity Waste Tanks

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There are two LAWT's. One tank common to units 1 and 2 and one for unit 3.

Floor drains are piped directly to the LAWT according to licensee drawings (these drains could not be located on the FSAR drawing of the system). There is no isolation valve between these drains and the LAWT. Licensee liquid waste disposal operating procedures do not prohibit the use of these drains during effluent discharge from the LAWT into the Keowee tailrace. Further, these operating proce-dures do not require the isolation valves between the LAWT and the laundry cr between the LAWT and drain header D-1 to be closed during discharge. The operating procedure requires a sample to be collected and analyzed prior to discharge to determine the concentration of radioactivity to be discharged. The procedure does not require sampling during discharge.

b.

Condensate Test Tank A similar condition exists for discharge of the condensate test tanks. The discharge procedure does not require sampling during discharge and does not require the' tanks to be isolated frem the Reactor Coolant Bleed Evaporator Distillate Coolers.

c.

Discharges to Keowee tailrace Discharges to the tailrace will be monitored by process monitors (RIA-33 and 34); however, these instruments do not appear to be..

sensitive enough to measure the low concentrations expected to be discharged. A licensee representative stated the sensitivity of these units to be about 2 x 10-7 uCi/ml and anticipated effluent levels to be in the 10-8 uCi/ml range.

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I d.

Summary The inspector stated that without the capability to isolate the

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LAWT prior to and during discharge it is not valid to assume that the composition of the effluent doesn't vary during the discharge period. Management representatives acknowledged that

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the LAWT could not be isolated prior to or during discharge.

A management representative agreed that this situation should be looked at and stated they would come up with a proposal.

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