IR 05000269/1976010
| ML19322B850 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 10/26/1976 |
| From: | Epps T, Kowalczuk A, Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322B843 | List: |
| References | |
| 50-269-76-10, 50-270-76-10, 50-287-76-10, NUDOCS 7912050826 | |
| Download: ML19322B850 (30) | |
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p0 C'%g UNITED STATES
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230 PEACHTREE STREET, N.W. SUITE 818
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IE Inspection Report Nos. 50-269/76-10, 50-270/76-10 and SU-287/76-10 Licensee:
Duke Power Company Power Building 422 South Church Street Charlotte, North Carolina 28201 Facility Name:
Oconee Units 1, 2 and 3 Docket Nos.:
50-269, 50-270 and 50-287 License Nos.:
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Category:
C, C and C Location:
Seneca, South Carolina Type of Inspection:
Routine, Unannounced Dates of Inspection:
March 31 - April 2, 1976 August 30 - September 10, and September 14-17, 1976
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Dates of Previous Inspection:
August 17-19, 1976 Principal Inspector:
T. N. Epps, Reactor Inspector
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Reactor Projects Section No. 2. -
Reactor Operations and Nuclear Support Branch Accompanying Inspectors:
J. W. Hufham, Radiation Specialist Environmental Protection and Special Project Section Fuel Facility and Materials Safety Branch A. L. Cunningham, Environmental Specialist Environment 91 Protection and Special Projects Section Fuel Facility and Materials Safety Branch A. D. Kowalczuk, Radiation Specialist
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Radiation Support Section Fuel Facility and Materials Safety Branch
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IE Rpt. Nos. 50-269/76-10, 50-270/76-10 q
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/d-M ~ / b Principal Inspector:
./ u T. N. Epps, Respo'r Inspector Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Supp rt Branch Reviewed byi
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[(R.C. Lewis, Chief Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch
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IE Rpt. Nos. 50-269/76-10, 50-270/76-10
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and 50-287/76-10-3-
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SUMMARY OF FINDINGS
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I.
Enforcement Items
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Infraction 1.
Contrary to Technical Specification 4.16 a 0.97 millicurie radiation source designated ONS #60 was not leak tested prior
to use when identified as being larger than 100 microcuries of i
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beta activity during 1976.
(Details II, paragraph 2)
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2.
Contrary to Appendix B Technical Specification,1.2.B, pH
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limits assigned for all water discharged from the plant site "ere exceeded on February 12, 1976 and March 16, 1976.
Although identified and reported by the licensee, the corrective actions taken to prevent recurrence were inadequate.
(Details III, paragraph 3).
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Licensee Action on Previously Identified Enforcement Matters I
The four infractions identified in IE Inspection Report Nos. 50-269/76-2, 50-270/76-2 and 50-287/76-2 are considered closed after verification of corrective actions.
(Details II, paragraphs 2, 3,
4 and 5)
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III.
New Unresolved Items
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None
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IV.
Status of Previously Reported Unresolved Items A.
73-12/1 Calibration of Effluent Monitors
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Comparisons between monitor response and activity in fluids have been made.
Additional comparisons are
needed.
This iten remains open.
74-3/3 Training of Unlicensed Utility (health physics)
Operators
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A training checklist with skill level verification has been initiated.
This item is closed.
(Details II,
, paragraph 8)
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IE Rpt. Nos. 50-269/76-10, 50-270/76-10 sj and 50-287/76-10-4-
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76-2/1 Process and Effluent Monitor Calibrations and Functional Checks
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Procedures have not been properly revised.
This item remains open.
(Details II, paragraph 9)
B.
Other outstanding unresolved items were not reviewed during this inspection.
V.
Other Significant Findings Deviations Sampling of Interim Waste Building Ventilation Air Daily samples were not analyzed for iodine or particulate radio-activity as stated in a Duke Power Company letter dated July 9, 1976, to Region II.
VI.
Management Interviews Meetings were held on September 3 and 10, 1976, by A. Kowale:uk with J. E. Smith and members of the Oconee staff to discuss the health physics related items in this report.
A meeting was held on September 8, 1976, by J. W.,Hufham with'
R. M. Koehler and other members of the Oconee staff to discuss results of the emergency planning inspection in Details IV of this report.
A meeting was held on September 3, 1976, by A. L. Cunningham with J. W. Hampton to discuss inspection findings given in Details III of this report.
A meeting was later held with M. Tuckman - Lead Licensing Engineer on October 15, 1976.
The scope of the inspection and the item of noncompliance listed in this sucnary were discussed (Detail.; III, paragraphs 1 and 3).
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A meeting was held on September 17, 1976, by T. N. Epps with J. E. Smith and members of the Oconee staff to discuss results of the operations inspection in Details I of this report.
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IE Rpt. Nos. 50-269/76-10
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T.N.Epps,ReaftfrInspector Date Reactor Projecev Section No. 2 Reactor Operations and Nuclear Support Branch Dates of Inspection:
September 14-17, 1976 Reviewed by:
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R. C. Lewis, Chief Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch i
1.
Individuals Contacted Duke Power Company (DPC)
i Oconee Personnel J. E. Smith - Manager, Oconee Nuclear Station J. W. Hampton - Manager, Administrative Services L. E. Schmid - Superintendent of Operations 0. S. Bradham - Superintendent of Maintenance R. M. Koehler - Superintendent of Technical Services
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R. T. Bond - Perfor=ance Engineer
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W. R. Campbell - Reactor Engineer W. M. Harris - Operating Engineer Other Operations Personnel 2.
Plant Operations This part of the inspection involved review of operating records on
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all three units.ncluding control room and shift supervisor's log books, from August 1.through September 15, 1976, control room log sheets, recent work requests, incident reports, out of normal log books and discussions with bperations personnel. A plant tour was also conducted.
The purpose of the operations inspection was to review several activities to verify compliance with sections 3.0 i
and 6.4 of the Technical Specifications and licensee administrative controls.
a.
Records Review Following are the more significant items covered by this review.
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IE Rpt. Nos. 50-269/76-10
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50-270/76-10 and 50-187/76-10 I-2
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(1) On September 15, 1976, the heat tracing a: arm light was on in the Unit 1 control room.
A work request had been
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written to investigate the problem but the' work request
was classed as non-safety-related.
The inspector stated that licensee personnel tend to use the licensee's document defining " safety-related structures, systems and components" without question, and this may be incorrect, since some heat tracing, on safety-related systems, is safety-J related.
This is related to an outstanding ouresolved item concerning the definition of " safety-related."
(2)
The inspector reviewed records of primary coolant activity related to failed fuel.
Licensee data showed Unit 1 to j,
have about 0.06% failed fuel; Unit 2 about 0.3% failed I
fuel; and Unit 3 less than 0.01% failed fuel.
The data indicated no increasing trend.
The design criteria take into account as much as 1.0% failed fuel.
(3)
An entry in the Unit 2 shift supervisor's logbook on
August 2, 1976, showed that the estimated critical boron concentration (ECB) was in error in a nonconservative direction by about 91 ppm, which resulted in the reactor being critical below the predicted value (during unit startup) and the reactor was shutdown.
The duty perform-ance engineer was called in to assist,in recalculation of ECB.
There was nothing in the logbook concerning how this problem was zesolved.
Inspection revealed that the situation was corrected before startup was resumed.
The inspector stated that logbook entries should be completed by stating how problems are resolved.
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(4) An entry in the Unit 2 shift supervisor's log indicated that on August 3, 1976, a snubber on the "A" steam line
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in the reactor building had leaked out all of its oil.
This snubber was replaced with a spare the same. day.
The licensee stat,ed that several spare snubbers are now at the site along with snubber testing equipment.
b.
Plant Tour The inspector conducted a plant tour that included the turbine building, portions of the auxiliary building.and all three control rooms.
No significant comments resulted from this tour.
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IE Rpt. Nos. 50-269/76-10
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50-270/76-10 and 50-287/76-10 I-3 3.
Reportable Occurrences The following reportable occurrences were reviewed during this inspection.
a.
50-269/76-11 Contrary to Technical Specification 3.5.2.1 tb-licensee's reactivity balance procedure did not consider the most reactive rod withdrawn.
The corrective action stated in the licensee's report was verified to have been implemented and there were no further questions.
This nonconpliance was identified and corrected by the licensee.
b.
50-269/76-7 This item involved reactor coolant flow measurement errors not being included in the flux flow trip setpoint.
The corrective actions stated in the licensee's report were verified to have been inplemented and there were no further questions.
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c.
50-270/76-6
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Contrary to Technical Specification 3.6.1-2 manual containment
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isolation valves were open during heatup on July 6, 1976.
This was identified and corrected by the licensee.
d.
50-270/76-5
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Contrary to Technical Specification 3.12.3 the auxiliary hoist was operated over the open vessel without appropriate procedures on May 20, 1976.
This was identified and corrected by the licensee.
The inspector confirmed that the licensee has plans to place cautica signs in the Unit 3 reactor building to prevent a sinilar occurrence during the Unit 3 refueling outage.
e.
50-270/76-7 On July 6, 1976, the Unit 2 chennel B RPS pressure transmitter failed to function and prevented the channel from tripping.
The transmitter was calibrated on May 2, 1976, and on May 13,
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IE Rpt. Nos. 50-269/76-10, 50-270/76-10 and 50-287/76-10 I-4
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1976, the isolation valve for the transmitter was repacked by
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maintenance mechanics.
The incident occurred because the isolation valve for the transmitter was left closed.
The inspector stated that maintenance mechanics should be cautioned
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against operating any valves in the plant unless allowed by station directive 3.1.4.
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50-270/76-8
Contrary to Technical Specification 3.3.6.d, the Unit 2 2A reactor building cooling unit and 2A reactor building spray
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train were out of service simultaneously on July 23 1976.
j The licensee's corrective action was to implement a preventive maintenance program on motor control center breakers.
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The licensee also committed to have all 600 volt ES load
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center protective device settings reviewe by January 1, 1976,
to determine if settings are too low.
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This incident involved a steam generator tube leak that was repaired by tube plugging.
The inspector had no further
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Contrary to Technical Specification 3.5.2.5.d'the Unit 3 power level cutoff was exceeded momentarily on July 13, 1976.
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j This was identified and corrected by the licensee.
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DETAILS II Prepared by:Alexarfder D. Kowalczuk,' Rad tion'
'Dat4 Specialist Radiation Support Section Fuel Facility and Materials Safety Branch Dates of Inspection:
August 30 - September 3 and eptember 7 - 10, 1976 Reviewed by:
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A. F. Gibson, Section Chief Date Radiation Support Section Fuel Facility and Materials Safety Branch 1.
Individuals Contacted J. E. Smith - Manager, Oconee Nuclear Station R. M. Koehle: - Superintendent of Technical Services L. E. Schmid - Superintendent of Operations
C. T. Yongue - Health Physics Supervisor
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R. T. Bond - Technical Services Engineer R. Knoerr - Assistant Plant Engineer
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W. P. Deal - Assistant Health Physics Supervisor
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D. L. Davidson - Assistant Health Physics Supervisor-R. D. Nichols - Training Coordinator R. P. Todd - Assistant Test Engineer 2.
Surveys - Source Leak Tests
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a)
On September 8, 1976 the inspector reviewed the Source Leak Test and Periodic Inventory Log.
A note in the above log indicated that a radioactive materials source designated ONS No. 60 was discovered to be 0.97 mci when it was forserly thought to be 0.97 uC1. No leak test results w:re available and a management representative indicated the source is used daily for instrument checks.
Failure to leak test the source was in noncompliance with Technical Specification 4.16.
Leak tests taken on September 8, 1976 at the inspector's request were acceptable.
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IE Rpt. Nos. 50-269/76-10, j
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The inspector noted that sources designated ONS No. 101, 103-106, and 108 were identified as inaccessible due to unit operations and that leak test results were not recorded.
Management representatives were advised that leak tests re-quired by Technical Specification 4.16 must be made at the first opportunity when unit operations permit access to the sources.
c)
The Health Physics Source Handling Procedure, HP/0/B/1005/01 with changes 1 and 2 was reviewed by the inspector.
3.
Liquid Waste Monitor Response
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Procedures HP/0/3/1000/60/F and HP/0/B/1000/60/G were reviewed by the inspector.
Periodic correlation of monitor response to analyzed radioactivity concentrations is specified.and acceptance criteria are established.
4.
Liquid Waste Monitor Setpoint Operability criteria for effluent radiation monitors have been established in enclosure 13.5 to PT/0/A/230/1 titled, Radiation
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Monitor Check.
Records of liquid waste releases76-700, 76-702, and 76-741 through 76-743 were reviewed by the inspector to confirm that redundant samples were being collected and analyzed and that redundant valve lineup checks were being made prior-to each release.
5.
Radiation Surveys The inspector observed that RIA-53 which monitors air exhausted a.
from the Interim Waste Bldg. vent, formerly designated RIA-52,
was operating on August 31, 1976.
Records indicated that a station modification designated NSM No. ON-0583 to add a low flow alarm indication for RIA-53 in the Unit-3 control rocm had been initiated.
Management representatives stated that the modification is expected to be completed by September 24, 1976.
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.Results of the Interin Radwaste Building Exhauster Flow Test, PT/0/B/170/OS for August 18, 1976, indicated a discharge flow of 13,886 cfm.
The test is scheduled for periodic performance to measure the ventilation discharge rate.
Records of daily operability checks on RIA-53 for May through August 1976 were revtewed by the inspector. Monitor readings ranged between 20 and 100 cpm.
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c.
Sampling of Interim Waste Building Ventilation Air Management representatives stated that weekly particulate and iodine samples were being taken from the Interim Radwaste Building vent.
This is a deviation from a commitment set forth in a Duke Power Company letter dated July 9, 1976 to
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Region II, USNRC, to take and analyze daily samples from the vent.
The inspector reviewed the August 1976 sample analysis j
results.
Management representatives agreed to provide a written revision to the previous sampling and analysis commitment.
d.
The inspector ascertained that a thin charcoal impregnated filter was used for vent sampling with a flowrate of 7 cfm.
This sampling arrangement provides a very short sample residence ttne in the charcoal adsorber.
Licensee repre-sentatives provided test documentation indicating about a 90%
collection efficiency for this arrangement.
A correction factor had not been applied to iodine effluent release data to account for the above collection efficiency.
Management representatives agreed to correct previous effluent data and to apply an efficiency of collection factor to all future,
effluent data.
The amcunt of additional radioactivity to be accounted for by this correction will be small relative to total plant releases and will not cause release limits to be exceeded.
A discussion with management representatives confirmed that c.
the method currently used for computing maximum liquid waste release concentrations conforms to 10 CFR 20, Appendix B.
6.
Environmental Monitoring Sample Analysis Sensitivities Four milk samples frog station 015 collected July 9, 1976 were a.
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analyzed for Iodine-131 with a sensitivity of less than 0.5 p C1/1.
b.
Raw water samples from stations 004.1C and 006.1C collected in March 1976 and May 1976 were analyzed for I-131 with a sensitivity of less than 1.5 pCi/1.
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Water sampics from stations 004.1C and 006.1C collected in May 1976 and June 1976 were analyzed for gross alpha and gross
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beta radioactivity to a sensitivity of 0.5 pCi/1 and 1.0 pC1/1
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The sensitivity of the analyses appear to conform to the licensee's commitments.
7.
Calibration of Effluent Monitors (Unresolved Iten 50-269/76-12/1)
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a.
Comparisions between expected monitor readings and laboratory analyses were reviewed by the inspector for the following monitors:
RIA-33 RIA 32 RIA 34 RIA 44 RIA 37 RIA 45 RIA 38
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The comparison data demonstrated the need for additional work to insure that monitor readings can be interpreted accurately.
The licensee is continuing work on this problem.
b.
An offline monitor was being used experimentally in lieu of
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RIA 33 and 34 for liquid waste discharge monitoring.
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decontamination procedure which consistently lowers the monitor background to less than 1000 cpm has been used successfully.
The ncw monitor has significantly better
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sensitivity than the previous monitors due to improved geometry.
Plant personnel have determined that if the monitor
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background is maintained below 15 to 20 thousand counts per minute then alarm settings corresponding to 10 CFR 20 concentration levels can Le set for effective isolation of the liquid discharge as required by Technical Specifications.
8.
Training of Unlicensed Utility Operators (Unresolved Item 50-269/74-3/3)
Intrastation letter dated, June 9,1976, subject: Waste Systems Training OS 272.00 signed by the Superintendent of Operations, establishes a listing of training items to be signed off by #he i
trainee's supervision when competency has been established.
Training recc.Js reviewed by the inspector indicated that about 19
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regular and 6 temporary employees have completed the training
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50-27C/76-10 and 50-287/76-10 II-5 items.
The Superintendent of Operations assured the inspector that plant policy does not allow untrained personnel to operate equipment or systems without supervision.
The established program appears satisfactory.
9.
Process and Effluent Monitor Calibrations and Functional Checks (50-269/76-2/1)
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a.
The inspector reviewed calibration records dated August 25, 1975 and August 14, 1976 for RIA-53.
Records appeared satis-factory.
b.
Setpoints for radiation monitors as given in PT/0/A/230/01 were compared to setpoints given in Enclosure 3 to OP/162/A/
1104/07 (Liquid Waste Release Form), IP/0/A/360/13 for RIA-42, IP/0/A/360/3C for RIA-49 and IP/0/A/360/18 for RIA-53.
Setpoints in the various procedures still conflict (see Unresolved Item 76-2/1) and if set as specified could result in radioactive material releases in excess of permitted concentrations and
quantities.
Management representatives agreed to provide a
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written response to Region II, USNRC, stating the date by t
which procedure changes needed to resolve this item will be completed.
Iodine monitor functional checks still do not'us'e the Ba-133 c.
i check source response from the annuti calibration to establish the acceptability of responses duri:4 insequent checks (see l
Unresolved Item 76-2/l). Management representatives agreed to respond to Region II, USNRC, stating the date by which procedure changes needed to resolve this item will be completed.
10.
Familiarity of Plant Personnel with Radiation Monitors The inspector reviewed Oconee Nuclear Station Directive 3.8.6 titled Radiation Monitor Responsibilities.
Records indicated that the material in the above document had been reviewed with the operating shifts.
Radiation monitor alarm logs for July and August
1376 were reviewed.
Commitments related to the above items appear
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Qualifications - Radiation Protection Organization a.
The inspector reviewed changes and additions to the radiation protection organization and verified that qualification statements in paragraph 2.5.3.3.2 of the Administrative Policy Manual appeared to have been met.
b.
Position descriptions for "Labman" and "Labtech" which had been changed to include the duty of acting as a leadman during
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shift work were provided by the H.P. Supervisor for review by
the inspector (This change was responsive to the comment in OIE Report 50-269, 50-270, 50-287/75-4, Details II, paragraph 2).
12.
Licensee Audits The inspector reviewed records of internal audit 76-53 and an intrastation letter dated August 25, 1976 specifying corrective actions.
Procedural requirements in paragraph 2.6.5 of the Administrative Policy Manual appear to have been satisfied.
13.
Training
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Based on a review of several personnel training records, the scope of training, new personnel training, refresher courses and training documentation are consistent with Section 1,K of th'e System Health Physics Manual and paragraph 2.5.6 of the Administrative Policy Manual.
14.
Radiation Protection Procedures Changes to procedures HP/0/B/1005/01, HP/0/3/1005/02, a.
HP/0/B/1005/06 and HP/0/3/1005/07/A appear consistent with the System Health Physics Manual, b.
Observation of equipment, discussions with management repre-sentatives and review *of draft procedures appeared to confirm
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that refueling canniements in FSAR paragraphs 9.4.2.4, 9.9.2.3 and 9.4.2.4 and FSAR Table 11-9 sc e being met.
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15.
Advanced Planning and Preparation for Refueling l
Management representatives stated that about 20 extra health physics personnel will be available during Unit 3 refueling and maintenance.
Recent experience on refueling and maintenance of Units 1 and 2 has
provided training for Unit 3 activities.
Management representatives stated that supplies and equipment to cope with the outage activites have been anticipated.
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16.
Instruments and Equipment TLDs are used for personnel monitoring.
These dosimeters are a.
read by a contractor.
Li F dosimeters are used for establishing neutron dose.
All personnel badges issued contain the neutron dosimeter, but only those issued to health physics personnel are evaluated routinely.
Neutron surveys are made using rem-meter type portable survey instruments.
TLDs are evaluated quarterly,
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b.
Pocket dosimetars are used to provide immediate indication of radiation exposure.
The inspector reviewed calibration records of about 200 dosimeters and verified that about 75 to 100 dosimeters issued in the 3rd quarter were calibrated within l
the previous 3 months as required by HP/0/B/1004/17 titled.
Procedure for Dosimeter Leak and Calibration Check.
The inspector commented that a scheduled recalibration of the condenser R-meter used to check dosimeter responses (see procedure HP/0/B/100/14) would seem appropriate.
17.
Exposure Control a.
Management representatives stated that to their knowledge no minors have been occupationally exposed and that no personnel overexposures have occurred in 1976, b.
The inspector reviewed procedures EP/0/B/1000/01, HP/0/B/1000/02, l
HP/0/B/1000/02C, and HP/0/B/1000/03 related to personnel
dosemetry issue and exposure control.
Records of contractor and visitor personnel dostmetry issued and the exposure records pursuant to NRC forms 4 and 5 appeared satisfactory for the first and second quarters of 1976.
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Posting, labeling and Control of Contamination a.
The inspector observed that NRC Form 3 and a notice of the
availability of 10 CFR 19 and 20 and other license related l
documents were posted.
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b.
During a plant tour the inspector observed that radiation areas, and high radiation areas were posted and secured as
required by 10 CFR 20.
Radiation levels were verified by
licensee measurements made during the tour.
The inspector toured the Unit-3 spent fuel pool area, observed
c.
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that area monitors were installed and that the change room facilities specified in FSAR prargarph 11.2.3 were in usable condition.
d.
During the plant tour the inspector had several smears taken and analyzed to verify the effectiveness of the contamination control program.
Results were satisfactory.
An equipment
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decontamination area was observed and the methods used for contamination control appeared adequate.
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19.
Notifications and Reports A management representative stated that report,s required by 10 a.
CFR 20.408 are funished to all visitors or temporary personnel who have entered the plant during a given calendar quarter.
b.
The inspector reviewed copies of data reported to the commission under 10 CFR 20.407(b) for calendar year 1975.
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DETAILS III Prepared by:
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A. C.'Cun'ningham ) nvironn' ental
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Scientist, E #1ronmental and Special Project Section Fuel Facility and Materials Safety Branch Date of Inspection:
September 3, 1976 Reviewed by: [ I. k4 # M
/0[J/[7/
R.'L. Bangart, Cpief
'Date Environmental ahd Special Projects Section Fuel Facility and Materials Safety Branch 1.
Scope Inspection was limited to the following items, viz. :
(1) review of corrective actions implementation in response to reported occurrences involving exenrsions above chemical discharge limits for solid detergents and pH assigned by Appendix B Technical Specifications 1.2.A and 1.2.B respectively; (2) review and audit of bulk chemical inventory records for the period January 1, 1976 through August 31, 1976.
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2.
Individuals Contacted J. W. Hampton - Assistant Station Manager R. M. Koehler - Superintendent, Technicsl Service D. C. Smith - Plant Chemist M. Taekman - Lead Licensing Engineer 3.
pH Discharge Limits i
Appendix B Technical Specification 1.2.B requires that all water
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discharged from the plant site have pH within the range 6.0 to 8.5.
The specification also requires daily monitoring and record-ing of pH of the wastewater collection basins and effluent from the plant site. During the first quarter of 1976, the licensee i
I reported two occurrences of pH excursions above the assigned limits.
These occurrences - their respective corrective actions, and the inspection findings are discussed below.
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'IE Rpt. Nos. 50-269/76-10, 50-270/76-10
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a.
Settling Basin Overflow
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i In accordance with the reporting requirements defined by i
Appendix B Technical Specification 1.2 (Chemical Discharge Limits), the licensee reported that at 0830 on February 12, 1976, a water sample of the yard drains indicated a pH of 9.2.
Investigation revealed that during drainage of Unit No. 1 steam generators to the lower settling basin, the discharge valve of the basin was shut.
This condition resulted in overflowing the spillway and discharge from the site via the yard drainage system.
The drainage was subsequently diverted to the upper settling basin and the inlet valve to lower basin was closed.
In the written report dated February 19, 1976, the licensee listed the following corrective actions to prevent recurrence:
(1) the settling basins would be operated
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such that the weir (discharge) valve would remain open and pH of the basin contents controlled such that effluent from the site would remain within the 6.0-8.5 range; (2) inline pH monitoring of the yard drains and outlet of the lower settling basin would be installed to provide remote readout capability in the water treatment room.
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Caustic Day Tank Overfill
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In accordance with the reporting requirements defined by Appendix B Technical Specification 1.2 (Chemical' Discharge l
Limits), the licensee reported that at 1040 on March 16, 1976, a routine sample of yard drains indicated a pH reading i
of 8.7.
Subsequent samples indicated a maximum value of 8.8.
Investigation revealed that the occurrence involved regeneration of make-up demineralizer
"A" on March 15, 1976, utilizing caustic solution from the caustic day tank. This tank was charged from the caustic storage tank through a manually operated valve located in the line between the two tanks.
It was stated that failure to promptly close the valve permitted the caustic day tank to overfill and drain into the sump; however, the elasped time during which caustic solution was enterin'g the yard drain was not given. After identification of the release the liquid was then pumped into the lower settling basin and was subsequently released.
According to the licensee's written report, the discharge valve from the lower cattling basin was closed and the basin contents were diluted and sampled periodically until pH indications were within required limits.
Yard drains were
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and 50-287/76-10 III-3 also monitored and reported to be within specifications by 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> on March 17, 1976.
The licensee reported that the following corrective actions to prevent recurrence were implemented:
(1) pH of settling basins and yard drains would be recorded every 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />; (2) pH of basins and yard drains would be recorded prior to and following completion of damin-eralizer regeneration; (3) any abnormal pH changes attending regeneration would be reported to the duty chemist who would take appropriate actions.
c.
Inspection Findings The above corrective actions were reviewed in detail.
Inspec-tion findings were later discussed with licensee representatives
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on October 15, 1976.
The written report for the February 12 occurrence stated that the revised operating procedure for the initial corrective action listed would be instituted by March 18, 1976.
Although inspection and later discussions with licensee representatives revealed that the procedure was instituted on March 4, 1976, the inspector considerud the corrective action inadequate.
The subject corrective action neither described nor required implementation of a more effective pH monitoring program to assure that water
leaving the plant site would be maintained within spc:ified
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limits.
In further discussions with licensee representatives, it was revealed that the commitment to insta,11-inline pH~
monitoring of yard drains and the outlet of the site waste-water collection basin with remote readout capability in the water treatment room would not be implemented until early 1977.
The inspector informed licennee representatives that the occurrences of February 12, 1976 and March 16, 1976 - involving pH excursions outside the limits assigned in Appendix B Technical Specification 1.2.B constituted an item of non-compliance. The inspector further stated that although the licensee identified and appropriately reported the subject occurrences, the corrective actions taken in each case to prevent recurrence were inadequate.
The March 16, 1976 occurrence was evidence that the earlier corrective actions were not adequate.
In a brief discussion concerning more effective corrective actions for preventing recurrence of pH excursions, a licensee representative stated that an audible announciator was considered in the initial design of the inline pH monitoring system discussed in paragraph 3.a.
It was further stated that use of an announciator, actuated at an assigned critical pH within the required limits would serve to
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l preclude further pH excursions by allowing ample time to implement any required adjustments necessary to maintain water leaving the plant site within the prescribed pH limits.
4.
Chemical W.istes Appendix B Technical Specification 1.2. A limits the annual usage of solid laundry detergents to 4,760 pounds.
On June 2, 1976 the licensee noted that total usage of solid laundry detergent through May 1976, was 5,625 pounds. This finding was reported to NRC Region II in accordance with the reporting requirements defined by Appendix B Technical Specification 1.2 (Chemical Discharge Limits).
Excessive usage was attributed to the following factors:
(1) completion of a station modification in February, 1976, which allowed improved segregation of laundry wastes and
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ot'.te capability for processing of all laundry; (2) the increased number of outages, both scheduled and unscheduled, during 1976, which led to unusually high manpower requirements.
In view of increased manpower requirements and the resultant increased pro-j ected quantity of laundry processing, the assigned limit of 4,760 pounds had been shown by the licensee to be too conservative for present and future operations.
On this basis, licensee cor-rective action entailed a review of current chem 2. cal discharge limits and a proposed revision of such limits to reficct more realistic values.
The review and appropriate Technical Specifi-cations revision request was scheduled for submittal to NRC by September 1, 1976.
Inspection revealed that the proposed revision was submitted to the NRC Office of Nuclear Reactor Regulation in a letter dated September 1, 1976.
Inspection of the bulk chemical inventory for the period January 1,1976 through August, 1976 I
revealed no additional occurrences concerning chemical discharge l
wastes at the time of inspection.
There were no further questions concerning this item.
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c~s IE Rpt. Nos. 50-269/76-10, 50-270/76-10 and 50-287/76-10 IV-1
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DETAILS IV Prepared by:'\\. <A
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Radiation Specialist iDate ~
W. Hut' ham,'l and Special Projects Section J
ironmental E
F 1 Facility and Materials Safety Branch Dates of Inspection:
March 31-April 2, 1976 September 7-8, 1976 Reviewed by:
[ /.
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R. L. Bangart, pfief
'Dade Environmental and Special Projects Section Fuel Facility and Materials Safety Branch 1.
Scope of Inspection
An energency planning inspection to determine the adequacy and effectiveness of the Oconee Nuclear Station emergency organization relative to the emergency agreements with agencies that would assist the plant in an emergency, emergency facilities and equip-ment, means for determining a radioactive release, medical facilitf.3, and emergency training.
The inspection consisted of a review of records and documents, interviews with plant and offsite personnel, and observations and inspections of installed equipment.
The
inspection was initially begun on March 31, 1976 - April 2, 1976, but was interrupted due to another work priority until September 1976.
The inspection was completed on September 7-8, 1976.
2.
Individuals Contacted i
a.
Duke Power Company - Oconee Nuclear Station J. E. Smith - Station Manager L. E. Schmidt - Superintendent of Stations Operations i -
R. M. Koehler - Superintendent of Technical Services T. S. Barr - Performance Engineer
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R. T. Bond - Techn,1 cal Services Engineer R. D. Nichols - Training Supervisor R. T. Bugert - Operator Training Coordinator
'7 W. G. Itin - Industrial Safety Training Coordinator C. T. Young - Health Physics Supervisor b.
Seneca Memorial Hospital B. Moyle - Assistant Hospital Administrator
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Individuals Contacted By Telephone H. Shealy - Director, Division of Radiological Health - State of i
South Carolina B. Black - Pickens County Civil Defense Director J. Wood - Oconee County Civil Defence Director C. Webb - U. S. Energy Research and Development Administration -
Savannah River Operations Office 3.
Coordination of the Oconee Nuclear Station Emergency Plan With Offsite Support Agencies Appendix E, to 10 CFR 50, Section IV, paragraph A, requires that means of notification in the event of an emergency be established for contacting appropriate state and federal agencies with the responsibilities for coping with emergencies.
The Oconee Nuclear
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Station FSAR in Section 12.3.3(c) required that outside emergdhey services be available for an emergency at the Oconee plant.
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To confirm that agreements had been established with these agencies, the inspector discussed the offsite arrangements with the Health Physics Superintendent and Plant Superintendent.
The inspector was informed that emergency agreements had been established with support agencies ad that the agreements had been maintained.
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was also informed that communication checks were performed fre-i j
quently with these agencies.
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I To verify that the agreements were current, the inspector reviewed the following agreement letters between the Duke Power Corporation and the following agencies:
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a.
State of South Carolina - State Board of Health (Memorandum i
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dated October 27, 1972)
b.
State of South Carolina - Department of Health, Division of
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Radiological Health (Letter dated June 27, 1975)
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State of South Carolina - Highway Patrol (Letter dated August 4, 1975)
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Oconee County - Civil Defense Agency (Letter dated August 4, 1975)
e.
Oconee County - Sheriff (Letter dated August 4, 1975)
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Oconee County - School District (Letter dated August 8, 1975)
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Pickens County - Civil Defense Agency (Letter dated July 8, 1976)
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Pickens County - Sheriff (Letter dated August 4, 1975)
The inspector also reviewed a plant memorandum dated July 17, 1975, that listed the outside agencies that were visited by plant personnel during 1975 and others that were contacted by mail.
The inspector reviewed the procedures for notifying the offsite agencies and emphasized the importance of keeping the telephone numbers in the procedures current.
Telephone contacts were made by the inspector to the following support agencies,
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a.
U. S. ERDA - Savannah River Operations Office b.
Oconee County Civil Defense c.
Pickens County Civil Defense d.
State of South Carolina - Department of Health, Division of Radiological Health
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The inspector verified through the telephone conversations
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that the utility had maintained communications with the.two civil defense agencies and the U. S. ERDA office.
The two civil defense agencies indicated that the plant had also involved them in emergency exercises.
The representative for the State of South Carolina informed the inspector that the Memorandum of Understanding between Duke Power Company was still in effect and that the plant had made the effort to maintain good communications between the state and the site.
However, the state representative expressed a desire for the
plant to involve the state in additional emergency exercises
sponsored by the utility.
The requirements for coordination with offsite agencies appeared to be satisfied.
4.
Means For Determining The Magnitude of A Release of Radioactive Materials a.
Procedures for Determining A Release i
Appendix E to 10 CFR Part 50, Section IV, Paragraph C, re quires that means be established for determining the magnitude
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of the release of radioactive materials and the criteria for determining the need for notification and participation of local, state, and federal agencies.
Section 6.4.l(d) of the Oconee Nuclear Station Technical Specifications requires that emergency procedures involving the potential or actual release of radioactivity be established.
Section 12.3.6.1 of the FSAR required that protective action be established for the emergency situation be taken promptly.
To verify that these procedures were available, the inspector discussed the requirements with the Superintendent of Operations and the Health Physics Supervisor.
The inspector also reviewed the procedures included as Appendix A to the Oconee Emergency i
Plan.
The inspector verified by direct observation that the procedures were maintained in the control room and that the meteorological information necessary for the procedures was available.
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The requirements for procedures to determine the magnitude of a radioactive release appeared to be adequately satisfied.
S.
Medical Facilities a.
Onsite Medical Facilities
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i Appendix E,10 CFR, Part 50,Section IV, paragraph F, requires that emergency first aid facilities be available.
Section i
12.3.3(d) of the FSAR required that provisions be established for the treatment of a medical and radiation injury (onsite).
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To verify that this facility was established the inspector inspected the first aid facility in the administrative build-ing as well as the first aid room in the restricted area.
Both facilities appeared to be adequately supplied.
After inspecting both facilities the onsite medical facilities appeared to satisfy,the requirements.
b.
Offsite Medical Arran2ements
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l Appendix E to 10 CFR Part 50, Section IV, paragraph E, requires I
that arrangements for the services of a physician and other medical personnel qualified to handle radiation emergencies, arrangements for transportation of injured or contaminated individuals, and arrangements for treatment of injured per-sonnel be established.
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(1) Arrangements For The Treatment of Injured Personnel
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To verify the arrangements for an offsite medical faci-lity, the inspector met on September 7, 1976, with the
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Assistant Hospital Administration of the Seneca Memorial Hospital.
The inspector discussed the arrangements that had been established at the facility and inspected the facility.
The rooms appeared satisfactorily equipped and supplied.
The inspector was informed by the Assistant d
Hospital Administrator that th.2 hospital personnel had received training from the plant personnel and the plant had involved the hospital in the emergency drills sponsored by the utility.
Records of the training and drill partici-pation were maintained by the hospital.
Letters of agreements between the hospital and the plant were also reviewed by the inspector.
(2)
Emergency Medical Transportation To verify that arrangements had been made for medical transportatien, the inspector discussed the ambulance agreements with the Assistant Hospital Administrator.
The represcatative informed the inspector that a company vehicle would normally transport an injured / contaminated individual to the facility; however, if the company vehicle was not available or suitable, then an ambulance from the hospital would provide the service.
The inspec-tor reviewed a letter of agreement dated August 4, 1975, that verified this ambulance service.
(3)
Services of Physicians i
To verify that arrangements for physicians had been established, the inspector discussed the arrangement with the Assistant Hospital Administrator and reviewed letters of agreements dated August 4, 1975, that confirmed that services for a physician had been established.
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The requirements for the offsite medical facility, medical transportation, and physician services appeared to be adequately satisfied.
6.
Emergency Facilities Section 12.3.3, paragraph A, of the Oconee FSAR required that emergency equipment for handling a radiation, and contamination, or j
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reactor accident be available and that the equipment be located in strateg!: locations and replaced and serviced as necessary.
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(a)
Emergency Kits The inspector visually inspected the availability of the energ acy equipment in the control rooms of Units 1, 2 and 3.
The inspector also inspected the equipment in the visitors center.
All of the equipment was stored in sealed metal drums and the seals were not broken to inspect the contents of each drum. However, the inspector did review the emergency equip-ment inspection sheet.
The inspection sheets verified that the emergency kits in the Unit 1 and 2 control room and the visitors center had been inspected monthly since February 1974 and the emergency kit in the Unit 3 control room had been inspected monthly since it was placed in the designated location in October 1975.
(b)
Control Room Emergency Ventilation System Section 4.12.1 of the Oconee Nuclear Station Technical Speci-fications requires that the control room emergency ventilation system be operationally tested quarterly.
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To verify that this surveillance procedure had been performed, i
the inspector reviewed records that verified that the opera-i tional tests had been performed quarterly since July 1975.
i The inspector also reviewed procedures that verified that the
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emergency ventilation system for the Unit 3 control roca had i
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been tested quarterly since March of 1975.
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The Technical Specifications appeared to be adequately completed.
(c)
Communication Equipment To verify that communication systems were available and operable in the control room, the inspector observed the communication equipment in the control rooms and requested that all of the systems be explained by the Superintendent of Operations.
(d)
Eadiation Monitoring Equipment (Portable)
During this inspection the inspector discussed the availa-bility of portable radiation m:nitoring equipment.
The equipment appeared to be available in the designated locations.
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Training Appendix E to 10 CFR 50, f ection IV, paragraph 4, requires that provisions be made for the training of employees of the licensee who are assigned specific authority and responsiblity in the event of an emergency and other persons whose assistance may be needed.
Section 12.3.3(e) of the Oconee FSAR required that on each shift there be trained and qualified personnel in health physics, radia-tion monitoring, first aid, and fire fighting.
To verify the emergency training at the plant, the inspector met with the following training representatives and discussed all of the emergency training:
(1)
Station Training Superintendent
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(2)
Operations Training Coordinator (3)
Industrial Safety Training Coordinator a.
Operator Training The inspector verified through discussions with the Operations Training Coordinator that operators received training in emergency procedures and the emergency plan.
The inspector was informed that through the operator requalification train-ing program all Itcensed operators would receive annual training in the emergency procedures and.would be trained in the station emergency plan during the annual special health physics training of the operators.
To verify that the opera-tors were receiving the appropriate training, the inspector reviewed the training records for a shift supervisor.
The review of records verified that the individual had reviewed
emergency procedures and changes to the procedures, Technical Specifications and changes, and the special health physics (emergency plan) training.
b.
General Employee Training To verify that general employees had received training the inspector discussed the general employee training program with the Station Training Superintendent.
The inspector and the
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training representative discussed the training record TSR-2A j
that listed the general employee training and retraining.
The inspector verified by a review of the form that general employce training included training in the emergency plan, fire protection, and first aid.
To verify the general employee training, the inspector reviewed records for the Station
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i Superintendent who would have the authority to designate the emergency coordinator.
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c.
First Aid Training
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The inspector was informed that approximately 100 plant personnel had been trained in first aid and approximately 100 individuals would be trained annually.
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d.
Health Physics Training The training of the health physics personnel was recently
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inspected during a radiation protection inspection and the specifics of this training were referenced in Details II of this report.
c.
Fire Team Training The in.spector discussed the fire training program with the Industrial Safety Training Coordinator.
The discussions included the fire team training as well as the organization of the fire brigade organization.
(1)
Fire Brigade Organization i
The inspector reviewed the Fire Brigade Organization as defined in the Station Directive 5.3.1(AS).
The inspector verified that a fire organization had been established at the plant and it was comprised primarily of shif t supervisors and operators with additional coverage from the security
guards, maintenance personnel, instrumetation, chemistry, and health physics.
i (2)
Fire Brigade Training In evaluating the training of the fire brigade, the inspector reviewed and discussed the plant fire pro-
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tection program entitled "0SHA/ Fire Protection and Prevention For Industrial Fire Brigade Members." The inspector was informed that the fire brigade training consisted of a 14-hour basic training course that included 10-11 hours in classroom instruction and 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> of practical training.
The inspector was informed that the training reference used for the classroom training was
" Introduction to Fire Protection for Business and Industry."
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The inspector questioned the retraining of the fire brigade and he was informed that this training was provided
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every 18-24 months.
The inspector was informed that approxmimately 75% of the fire brigade on each operating shift had been trained at the time of this inspection.
The representative also confirmed that no credit was given to the offsite fire department.
The only requirement for fire training in the emergency plan is that there be trained individuals on each shift in fire protection.
After discussing the fire training with training representative this requirement appeared t; be adequately satisfied; however, the inspector expressed concern that additional fire training of the fire brigade and fire protection procedures were warranted.
After discussing the operator training, the general plant employee training, the health physics training, the first aid training, and the fire protection training the requirements in the emergency plan as well as the regulations appeared to be satisfied.
8.
Reentry Procedures
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Appendix E, 10 CFR, Pcrt 50,Section IV, paragrpah 5, requires that
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criteria be developed to be used to determine reentry into the
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facility.
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i To confirm that these procedures did exist, the inspector reviewed
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the procedures in the emergency plan for the restoration of emergency situations to normal and confirmed that the procedures were maintained in the control room.
The requirement appeared to be adequately satisfied.
9.
Emergency Drills Appendix E, 10 CFR, Part'50,Section IV, paragraph I, requires that
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provisions be made for testing by periodic drills to assure that employees of the licensee are familiar with their specific duties and provisions for participation in the drills by other persons
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whose assistance may be needed in the event of a raidation emergency.
Section 6.4.2 of the Oconee Nuclear Station Technical Specifications
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requires that quarterly selected drills be held to test the effective-ness of the emergency organization.
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l To verify that these drills were performed the inspector discussed
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These individuals l
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50-270/76-10 and 50-287/76-10 IV-10 included licensee representatives as well as offsite personnel.
Also to confirm that the drills received the appropriate documenta-tion, the inspector reviewed drill records indicating that five drills were held during 1975.
After discussing the drills with the plant personnel and reviewing the drill documentation, the requirements appeared to be adequately satisfied.
10.
Oconee Nuclear Station Emergency Plan Evaluation The inspector informed the plant management that the emergency organization at the plant had been compared to Regulatory Guide 1.101, " Emergency Planning for Nuclear Power Plants," and defined the variances from the regulatory guide.
The inspector explained that the variances were not recommendations by the inspector but would be forwarded to the U. S. NRC - Inspection and Enforcement -
Headquarters.
The variances were defined and explained in the exit interview.
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