IR 05000269/1977024

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IE Insp Repts 50-269/77-24,50-270/77-24 & 50-287/77-24 on 771011-19.Noncompliance Noted:Failure to Perform Monthly Insp of self-contained Breathing Apparatus & Emergency Survey Instruments
ML19329A482
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 11/28/1977
From: Jenkins G, Perratti D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19329A471 List:
References
50-269-77-24, 50-287-77-24, NUDOCS 8001031053
Download: ML19329A482 (16)


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>* # 8 89 UNITED STATES

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NUCLEAR HEGULA TORY COMMISSION r%.*

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Report Nos.:

50-269/77-24, 50-270/77-24 and 50-287/77-24 i

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Docket Nos.:

50-269,' 50-270 and 50-287 f

License Nos.:

DPR-38, DPR-47 and DPR-55 i

l Licensee:

Duke Feuer Company l

P. O. Box 2178

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422 South Church Street

Charlotte, North Carolina 28242 J

Facility Name; Oconee Units 1, 2 and 3 i

Inspection at:

Oconee Nuclear Station, Seneca, South Carolina

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and Of fice of Inspection and Enforcement, Region II Atlanta, Georgia l

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j Inspection conducted: October 11-19, 1977 u

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Inspector:

D. J.

er tti Reviewed by:

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NM 77 G. R. Je= ins, Acting Chief Date Environmental and Special Projects Section Fuel Facility and Materials Safety Branch

_ Inspection Summary l

inspection on October 11-19; 1977 Qeport Nos. 50-269/77-2_4,, 50-270/77-2_4_,

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and 50-287/77-24)

Areas Inspec_ted_: A routine unannounced inspection was perforned on October 11-19, 1977 to determine the adequacy and effectiveness of the licensee's emergency organization, emergency facilities, equipment and procedures,' emergency tests and drills, main control room environmenta'

I system, fire brigade organization, means for determining a radioactive release and emergency training. The inspection involved 33 inspector-

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hours en site by one inspector. A routine unannounced inspection was performed on October 17, 1977, from the IE Region II Office to determine that the licensee had maintained contact with offsite support agencies and had continued to coordinate emergency planning activities with the agencies.-

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Results: Of the ten areas inspected, no items of noncompliance were

'l found in nine areas; two apparent itons of noncompliance (infraction -

self-centained breathing apparatus had not been inspected conthly -

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C; RII Rpt. Nos. - 50-269/77-24,

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50-270/77-24 and 50-287/77-24-2-

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77-24-03; deficiency - emergency survey instruments had not been battery checked monthly (7 7-24-04)) were identified in one area; five deviations

i were identified in four areas.

(77-24-01; 77-24-02; 77-24-05; 77-24-08; 77-24-09)

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RII Rpt. Nos. 50-269/77-24, S0-270/77-24 and 50-287/77-24 I-l i

DETAILS I Prepared by:

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

tob r 11-19, 1977 ((

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O Reviewed by:_

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G. R. Je. Ins, Acting Chief Date Enviro ntal and Special Projects Section Fuel Facility and ?!aterials Safety Branch 1.

Persons Contacted a.

Licensee Personnel J. E. Smith, Station Manager

  • R. M. Koehler, Technical Services Superintendent
  • R. T. Bond, Technical Services Engineer

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  • R. C. Adams, Instrument and Electrical Superintendent P. Deal, Assistant Health Physic st

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C. Yongue, Station Health Physicist.

R. Knoerr, Instrument and Electrical Associate Engineer G. Itin, Safety Engineer

  • R. Nickols, Training Supervisor J. Herring, Unit 3 Shift Supervisor M. Major, Environmental Lab Group, !!cGuire Nuclear Station b.

Offsi_te Personnel Co_ntacted By_ Telephone _

C. D. Stone, Sheriff, Pickens County L. Collins, Administrative Assistant, Oconce County Sheriff's Office B. Black, Jr., Director, Oconce County Civil Defense H. G. Shealy, Director, South Carolina State Soard of Health, Division of Radiological Health, Columbia, South Carolina Dr. Pruitt, Oconee !!emorial Hospital Dr. Carpenter, !!enorial Clinic H. Hudson, Administrator, Oconce ?!ecorial Hospital

  • Denotes those attending the exit interview.

2.

License _e Action on Pre _vi_ous inspectton Findinn

No IIconsee actions on previously identified inspection findings were

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revic'.eed during this inspection.

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R1I Rpt. Nos. 50-269/77-24,

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50-270/77-24 and 50-287/77-24 I-2

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3.

Unresolved Items Unresolved items are matters about which more information is

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required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.

Two unresolved items disclosed

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during the inspection are discussed in paragraphs 11 (77-2t-06) and l

13 (77-24-07) of this report.

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4.

Coordination _k*ith Offsite_ Support _ Agencies i

a.

Section III of Station Directive 3.8.5, Oconee Nuclear Station Emergency Procedure, specifies certain offsite groups available for emergencies. Section 12.3.3(e) of the Final Safety Analysis

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Report (PSAR) commits to annually contacting offsite agencies to verify telephone numbers.

Section 12.3.3(c) defines the established outside emergency services and section 12.3.8 commits to simulated drills involving offsite agencies.

b.

The inspector discussed with a licensee representative letters of agreement, and the coordination and maintenance of contact

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with the offsite support groups defined in the Emergency

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Procedure and PSAR. The inspector verified by a rebiew of records that letters of agreement had been maintained for the offsite support groups required by the Emergency Procedure.

The licensee representative stated that during each quarterly emergency drill two of the agencies are contacted to verify correctness of telephone numbers. The inspector reviewed records of drills which indicated that some of the agencies had not been contacted since December 1975 and that Oconee Memorial Hospital, medical consultants at Menorial Clinic and the ambulance service had not been contacted for over two years. The inspector also discussed the participation by offsite agencies in the emergency drills and was informed by the licensee representative, that the only full scale drill involving offsite support agencies took place in June,1975 when the Pickens County Civil Defense Office initiated an emergency drill involving a spill on Highway 183.

The inspector verified by discussion with the licensee representative and by a review of the drill critiques that, since the June 1975 drill, there has been no participation by any offsite support group in the quarterly emergency drills.

Telephone contacts vers made'by the inspector on October 17, 1977, with principal offsite support agencies to confirm tele-

_ phone numbers and that concunications between the licensee and the support agencies had been maintained. The results of the

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of fsite agency contacts are included in the following paragraphs.

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R11 Rpt. Nos. 50-269/77-24, 50-270/77-24 and 50-287/77-24 I-3

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(1)

Oconee County Sheriff's Office - the Administrative

Assistant stated that their copy of the Emergency Procedures

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was dated August 1976, that she thought the sheriff was satisfied with the agreement letter and that she could not remember the last time the Ifeensee had contacted the sheriff. A review of drill critiques indicated that the l

last contact with the Oconee County Sheriff's Offi-e was on December 19, 1975.

(2)

Pickens County Sheriff - C. D. Stone, Pickens County

Sheriff, stated that he was satisfied with the letter of

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agreenent between his office and the licensee.

The sheriff stated that he was certain he had received a copy of the Oconee Emergency Procedure but at the present he

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was unable to find it.

The sheriff was not sure of the i

latest contact with the licensee. A review of drill critiques indicated the last contact was during December 1975.

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t (3) Oconee County Civil Defense - B. Black, Jr., Oconce County Civil Defense Director, stated that he was satisfied

with the agreement letter, that he had been contacted by

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the licensee about two weeks ago and that his' of fice had a copy of the Oconee Emergency Procedure, dated February 18,

1975.

(4)

South Carolina State Board of Health - H. G. Shealy, Director, Division of Radiological Health, stated that he was satisfied with the agreement letter, that the licensee contacted him periodically, and that his of fice had a copy of the Oconee Emergency Procedure dated October 14, 1976.

(5)

Oconee Memorial Hospital - Dr. Pruitt, Medical Consultant for the licensee, and H. Uudson, Hospital Administrator, were contacted.

Dr. Pruitt stated that his last contact with the licensee was over one year ago, and that he was satisfied with the agreement letter, but that he would like more contact.

Mr. Hudson stated that he thought the hospital had a copy of the Oconce Emergency Procedure, but he would have to check with the Emergency Room nurse in order to locate it.

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(6) Memorial Clinic - Dr. Carpenter, Medical Consultant, stated that he was satisfied with the letter of agreement and that he has recently been in touch with L. Lewis, the

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Duke Power System Health Physicist, with regards to

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attending the medical training course conducted by Oak

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Ridge Associated University.

Dr. Carpenter stated that he does not remember receiving any Oconee Emergency

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(7) The inspector attempted to contact the Pickens County Civil Defense Director through the Pickens County Sherit:

Office and by calling his home phone number but was unable to reach him, i

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c.

The failure to annually contact the offsite support groups i

defined in Section 12.3.3(c) of the FSAR is identified as a deviation from the commitment of Section 12.3.3. (e) of the FSAR (77-24-01).

The failure of the Ifeensee to conduct simulated emergency drills avolving offsite agencies is

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identified as a deviation from the commitment of Section 12.3.8 l

of the FSAR (77-24-02).

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5.

Changes in Facilities, Equipment and Procedures

The inspector reviewed changes to the facilities, equipment and the Emergency Procedure including the latest revision dated * June 23, 1977.

The changes did not alter the initial requirements of the Energency Procedure and did not constitute an unreviewed safety question, nor a change in the Technical Specifications.

6.

Equipment Available For Handling Emergencies a.

Technical Specification 6.4.1 states that the station shall be operated and maintained in accordance with approved procedures, and that writ ten procedures with appropriate check-of f lists and instructions shall be provided, in part, for Emergency j

Procedures involving potential or actual release of radioactivity

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and Radiation Control procedures.

Section III.A.4 of the Energency Procedure specifies certain equipment to be available for handling emergencies.

Technical Specifications, Table

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4.1-1 requires a monthly battery check and annual calibration of emergency survey instruments. HP Procedure HP/0/B/1009/04,

" Scott Air Paks II and III, Self Contained 3reathing Apparatus",

I states that all Scott Air Paks shall be thoroughly inspected

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once per month and the inspection Information be placed on a tag on the case. Technical Specification 6.7.1.a.2(d) requires written procedures to assure proper selection, supervision, and training of personnel, fitting and testing of respirators, issuance, cleaning, inspection repair and storage of respiratory protective equipment.

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O RII Rpt. Nos. 50-269/77-24,

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50-270/77-24 and 50-287/77-24 I-5

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b.

The inspector discussed with a licensee representative, the

equipment required by the Faergency P ocedure to b'e available

for handling emergencies and verified by observation that all

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the equipment required to be on site and located in the control rooms, Visitor's Center, energency boat and HP office work area was available and ready for use, with two exceptions.

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October 12, 1977, the inspector, accompanied by a licensee representative, toured the respiratory equipmen; storage ares

near the Unit 2 work area and was unable to find any Self

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Contained Breathing Apparatus (SCBA's) that were available and

ready for use in handling an emergency.

The licensee represen-tative stated that the serviceable SCBA's that would normally

be stored at the work area had been used for work involving

Unit 2 shutdown. This matter was discussed at the exit interview.

j On October 12, 1977, the inspector observed that the emergency i

survey instruments, HP-69-2 in Unit 3 control room and HP 69-1 I

in Units 1 and 2 control rc9a had apparently last received a

monthly battery check on March 24, 1977 and May 4, 1977 respec-

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t iv ely. At the exit interview a licensee representative stated that the survey instruments would be battery checked

~y right away and would be routinely checked each month. The inspector also observed that the inspection tags o*n two SCBA's in Unit 1 and 2 control room, two SCBA's in Unit 3 control room and one SCBA in the administrative building first aid room, indicated the five SCBA's had not been inspected each month as required by HP Procedure HP/0/B/1009/04.

At the exit interview a licensee representative stated that all the SCBA's would be inspected monthly. W e inspector reviewed HP respira-tory procedures HP/0/B/1009/04 through 1009/07 and verified that procedures for the respiratory protection program had been written and maintained in accordance with Technical Specifications.

c.

W e inspector identified the failure of the licensee to conduct monthly inspections on the SCBA's in Unit 1 and 2 control room, Unit 3 control room and the first aid room as noncompliance with HP Procedure HP/0/B/1009/04 and Technical Specification 6.4.1 (77-24-03). The inspector identified the failure of the licensee to conduct monthly battery checks on the emergency survey instruments as noncompliance with Technical Specification Tabic 4.1-1 (77-24-04).

7.

First Aid and Decontamination Facilities a.

Sections III A.3. and III A.4 of the Emergency Procedure specifies certain first aid and decontamination equipment to

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be available. Code of Federal Regulations, 49 CFR Part 173.134 requires a hydrostatic test be performed every five years on oxygen cylinders.

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RII Rpt. Nos. 50-269/77-24, 50-270/77-24 and 50-287/77-24 I-6

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f b.

The inspector discussed with a licensee representa,tive and

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and decontamination of personnel was available as specified by

the Emergency Procedure, with one exception. During the

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inspection of equipment in the auxiliary building first aid room, the inspector observed that the resuscitator kit contained one broken face-cup and that two oxygen bottles were overdue for the five-year hydrostatic test (bottles stamped 10-66).

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This matter was discussed with the site safety engineer who I

stated that there were three face-cups in the kit, one child and two adult, and that he thought the oxygen bottles had been switched the last time they were turned in for recharging. At i

the exit interview a licensee representative acknowledged that the oxygen bottles were overdue for hydrostatic tests.

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inspector asked about the inventory and replenishing of the

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first aid supplies in the first aid room and the first aid

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kits throughout the plant.

The licensee representative stated

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that although the kits are not on a formal inventory schedule,

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they are checked routinely and shortages are corrected on the I

,,s spot from supplies drawn out of the stock room.

The inspector

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verified that the first aid room and the first aid kits in the chemistry lab and instrument and electrical of fice' contained a full complement of required first aid supplies.

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The inspector identified the failure of the licensee to conduct c.

hydrostatic testing of the resuscitator cxygen bottles at the required five-year intervals as a deviation from generally acceptable practices in the industry (77-24-05).

8.

Main Control Room Ventilation System Technical Specification 4.12.1 requires a system test, quarterly, a.

for flew at each unit outlet, pressure drop across the filter bank and operational test of the fan motors for one hour, b.

The inspector reviewed surveillance records that verified the system tests were performed satisfactorily on a quarterly basis for Units 1 and 2 control room and Unit 3 control room during 1977.

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The requirement for the main co' trol rooms ventilation system c.

tests appeared to be satisfied.

9.

Congunications

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Section II.D. of the Emergency Procedure specifies various a.

a types of communications be available for emergency reporting,

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RII Rpt. Nos. 50-269/77-24, 50-270/77-24 and 50-287/77-24 I-7 i

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varning and aid summoning.

Enclosure 13.2 of periodic test procedure PT 600-1, Ir.3:rument Surveillance Periodic Checks,

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requires a weekly test of the site evacuation alarm.

b.

The inspector discussed with a Itcensee representative and verified by. observation in Units 1 and 2 control room, Unit 3 control room, and the emergency boat that the types of communi-cations required by the Emergency Procedure were operable and available for use.

The inspector reviewed PT 600-1, Instrument Surveillance Periodic Checks, for the period September 1, 1977 to October 13, 1977 and verified that the site evacuation alarm had been tested weekly.

e.

The requirement for the various types of communications to be available for emergency purposes appeared to be satisfied.

10.

Emergency Lighting Section 8.2.4 of the FGAR describes the emergency lighting a.

system to be available.

Periodic test procedure PT 610-9,

'^4 Emergency Lighting, requires a test of the emergency lighting system once per quarter.

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b.

The inspector reviewed surveillance records for the period January - September 1977, which verified that the emergency lights for all three units had been tested as required.

The requirement for the emergency lighting system appeared to c.

be satisfied.

11.

Vroefss and Area Monitoring j atems_

a.

Section III.4. of the Emergency Procedure specifies that process and area monitors be available with area monitors alarming both in the control room and locally. Tab'le 4.1-1 of-the Technical Specifications requires a quarterly calibration of the radiation monitoring systems, b.

The inspector discussed with a licensee representative the process and area monitors that would be utilized to determine the magnitude of the radioactivity released in the event of an emergency.

The inspector observed the following monitor j

indicator / recorders in the control rooms and verified they were available and operable with one exception, the waste

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liquid monitor.

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(1) Waste Disposal Liquid (High)

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Control Room Gas, Units 1 and 2, Unit 3 (4)

Unit Vent Particulates, Units 1, 2 and 3 i

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Unit vent Iodine, Units 1, 2 and 3

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Unit Vent Cas (High), Units 1, 2 and 3 (7) Visiter's Center Area Monitor

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Control Room Area Monitors, Units 1 and 2 Unit 3 i

A licensee representative explained that the liquid waste monitor (high) was in the process of being replaced with a new raonitor, but that the new equipment had not been calibrated and was not operable as yet.

The inspector reviewed surveillance

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j records, for the period April 1976 to October 1977, which

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Waste Liquid monitor, had been operationally tested, calibrated

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and alarm points tested on a monthly frequency.

c.

The requirement for process and area monitor instrumentation to be available in the control rooms appeared to be satisfied, with the exception of the Waste Disposal Liquid (High) monitor.

This matter was identified by the inspector as an unresolved item pending the installation, calibration and testing of the new Waste Liquid monitoring system (77-24-06).

12.

Meteorological Instrumentation a.

Section III.A.4 of the Energency Procedure specifies that

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microwave tower meteorological instruments and local area maps be available. Section 12.3.6 of the FSAR specifies that wind speed, wind direction and differential temperature meteorological data is available in the control room.

b.

The inspector discussed with a licensee representative the meteorological instrumentation in the control room. The inspector observed the meteorological instrumentation in Units 1 and 2 control room and verified that the cionitors for

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wind speed, utad direction and dif ferential were available and operating. The inspector was informed that testing and cali-

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bration of the entire meteorological instrucentation system

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was performed by the Environmental Laboratory group located at l

McGuire site. The inspector contacted a licensee Tepresenta-l tive at the Environmental Lab and was told that although there

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j is no calibration frequency established for the meteorological

instrumentation, the Environmental Lab performs a calibration l

at least every six months.

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The inspe-tor reviewed surveillance records that verified the

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meteorological instrumentation had been calibrated at least every six months by the System Environmental Lab group.

c.

The requirement for meteorological instrumentation in the control room appeared to be satisfied.

13.

Seismic Instrumentation a.

Section 5.6.2.2 of the FSAR specifies certain seismic instru-mentation be available.

Technical Specification 6.4.1.f requires a written procedure for a station survey following an earthquake.

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b.

The inspector discussed with a licensee representp,tive the j

seismic instrumentation in Unit I containment, auxiliary building and control room.

The licensee representative informed

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the inspector that the strong motion recorder was receved from service and was presently being replaced with a new system, Kine =etrics SMA-3, which was observed by the inspector.

The inspector was also informed that a technical representative would be on site in about two vecks to troubleshoot some problems that were being encountered.

The inspector observed i

the seismic trigger annunciator point in Units 1 and 2 and Unit 3 control rooms and reviewed emergency procedure EP/0/A/1800/9,

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Earthquake, which would be impicmented following a seir nie n

trigger alarm or visual observation of an earthquake.

c.

The inspector identified the requirement for siesmic instru-

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mentation as an unresolved item pending the installation, and satisfactory calibration and test operation of the new SMA-3 strong motion recorder (77-24-07).

The requirement for a written procedure for a station survey folleving an earthquake appeared to be satisfied.

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14.

Training

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First Aid Training C

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Section 11.E. of the Emergency Procedure specifies that

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station emergencies will be handled by personnel on site

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and onshift, and that station personnel have received fire and first aid training and are considered qualified in these areas.

Section III.A.3.a. specifies that personnel have completed first aid training and h>1d American Red

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i Cross Standard or Advanced First Aid Certificates.

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I (2) The inspector discussed with the plant safety engineer

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the first aid training of shift personnel.

The licensee

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representative stated that all employees receive as a

miniumum a first aid indoctrination and that shift personnel receive American Red Cross Standard training which is renewed every three years.

The inspector reviewed training records for operations, health physics, and chemistry personnel and verified that first aid trained personnel were available on each shift.

(3) The requirement for shift personnel to be first aid trained appeared to be satisfied.

b.

Emergency Procedure Training (1)

Station directive 2.5.1, paragraph 1.c. requires initial training in the Emergency Procedure for all employees.

Technical Specification 6.1.1.5 specifies that retraining will be conducted in accordance with Section 5.5 of ANSI 18.1-1971.

(2) The inspector reviewed records for station personnel for 1976 and 1977 and verified that Emergency Procedure training and retraining had been conducted as required.

(3) The requirement for initial and refresher training in the Emergency Procedure was apparently satisfied.

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.c.

Op,erator Training

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(1) Oconee Nuclear Station License Requalification Program

requires IIconsed operators to complete annual requali-i

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fication which includes a review of the Emergency Proco-i

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RII Rpt. Nos. 50-269/77-24, 50-270/77-24 and 50-287/77-24 I-11

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(2) The inspector reviewed training records for the opera-l tions group which verified that annual Emergen'cy Proce-dure training had been completed.

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(3) The requirement for operators to receive annual Emergency Procedure training was apparently satisfied.

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d.

_ Station Manager Training

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Section II.C of the Emergency Procedure specifies that all

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emergency situations will be handled by the Shif t Supervisor until relieved by the Station Manager.

The inspector discussed the training of the Station Manager with the Training Supervisor,

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who informed the inspector that the Station Fbnager was not licensed and as such received the same Emergency Procedure training as a general employee.

The inspector commented as to the adequacy of this training to prepare the Station Manager to relieve the Shift Supervisor during an emergency.

The inspector was informed that the Station Manager reviews the Emergency Procedure and approves changes as required by Technical Specifications. This matter was also discussed at the exit interview and the inspector informed licensee mana6ement that this matter would be forwarded to Licenstag for a*ction.

Training o_f_Offsit_e Support Groups e.

(1)

Section III.B.I.a of the Emergency Procedure specifies that selected individuals of the Oconee County Rural Fire System will be given radiological training on an annual basis.

Section 12.3.8 of the FSAR commits to training and retraining of nurses, hospital attendants and ambulance drivers in the care and handling of possible contaminated patients.

(2)

The inspector discussed with a licensee representative the training of offsite medical personnel.

The licensee representative stated that the Health Physics Dcpartment condtets training sessions for fire department personnel and medical personnel. The inspector reviewed records that verified twenty-six members. of the Keovee Fire Department received radiological training on September 13, 1976 and forty-two medical personnel from Oconce Memorial

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Hospital nurses and emergency staf f recetved radiation protective procedure training on April 13,1977.

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The requirement for training of medical personnel in the handling and care of possible contaminated patients and

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s-for' orientation of fire fighting personnel appeared to be satisfied.

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RII Rpt. Nos. 50-269/77-24, S0-270/77-24 and 50-287/77-24 I-12 15.

Fire Brigade _ Organization and Training

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Section II.E. of the Doergency Procedure specifies that personnel a.

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will be available on site and onshift to handle station emer-gencies and that station personnel have received first aid and fire training and are considered qualified in these areas.

Station Directive SD 5.3.1, " Fire Brigade Organization and Training", defines the Fire Brigade organization and specifies i

mimimum training requirements for new members, and that all i

permanently assigned Fire Brigade personnel and security guards should complete the requalification training program once every two years.

Section 6.2 of SD 5.3.1 specifies that

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at least one fire drill per year vill be held unannounced.

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b.

The inspector discussed with licensee representatives the training and organization of the Fire Brigade.

The inspector reviewed SD 5.3.1 which outlines an initial 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> minimum fire training course, based on the NFPA industrial fire training manual, for new mernbers and a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> refresher course for

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requalification every two years. 'Ihe inspector reviewed training records that verified fire training had been conducted

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as required by SD 5.3.1.

The inspector was inform *ed that fire drills are conducted on a monthly basis.

The inspector reviewed the drill critiques for the period January to September 1977 which verified fire drills had been conducted each month.

c.

The requirement for the Fire Brigade organization and training appeared to be satisfied.

16.

Distribution of the Emergency Procedure a.

Section 12.3.8 of the FSAR commits to distribution of the Emergency Procedure to all participating outside services.

Section 12.3.3(c) defines the established outside services.

b.

The inspector discussed with a ifcensee representative the distribution of the Emergency Procedure to onsite and of fsite individuals / agencies.

The inspector reviewed a distribution log that indicated the necessary onsite personnel and five of the nine offsite support agencies would be routinely given copies of the updated Emergency Procedure. The inspector was informed that some of the other offsite support agencies /

individuals had been given a copy of the Emergency Procedure but that no attempt was made to send an updated copy to the

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agoney unless a particular change to the Emergency Pro-edure

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af fec ted the agency. At the exit interview a Ifeensee respre-i sentative stated that they would look for documentation of the

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I RII Rpt. Nos. 50-269/77

'4, 50-270/77-24 and 50-287/77-24 I-13 distribution of the Emergency Procedure.

The insp.ector commented that there was no mechanism to insure all partici-

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pating outside services were going to receive the Emergency Procedure and that telephone calls to Oconee Memorial Hospital and Dr. Carpenter at Memorial Clinic verified this, c.

The inspector identified the failure of the licensee to include all participating outside services on the Emergency Procedure distribution list, in order to insure that the outside agencies received copies of the Emergency Procedure, as a deviation from the commitment in Section 12.3.8 of the PSAR (77-24-08).

17.

Review of the Emergency Proce3ure Technical Specification 6.1.2.1.1. requires an annual review a.

of the Emergency Procedure, b.

The inspector discussed the requirement for an annual review of the Emergency Procedure with a licensee representative who informed the inspector that although formal reviews were not

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x conducted or documented, reviews were conducted and the Emergency Procedure was changed as needed.

The inspector r'eviewed the last two changes to the Emergency Procedure, dated January 27, 1977 and June 27, 1977.

This matter was discussed further at the exit interview. A licensee representative stated that the review of the Emergency Procedure would be included in a Health Physics procedure to insure that the Emergency Procedure is reviev M annually, The requirement for an annual review of the Ecergency Procedure c.

appeared to be satisfied.

18.

Audit of the Emergency Plan Technical Specification 6.1.3.4 requires an audit of the a.

Emergency Procedure to be performed, under the cognizance of the Nuclear Safety Review Board (NSRB) every two years.

b.

The inspector discussed this requirement with the chairman of the NSRB, who informed the inspector that the NSRB and this

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audit requirement were established by a change to the Technical Specifications on February 13, 1976.

The inspector was also informed that the audit requirement will be satisfied by a

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NSRB review of site QA audit of the Emergency Procedure.

The inspector reviewed the NRC's approval of the change to the Technical Specification and verified that it took effect on

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February 13, 1976.

The inspector also reviewed site QA audit

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RII Rpt. Nos. 50-269//7-24,

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50-270/77 24 and 50-287//7-24 1-14 of the Emergency Procedure which was completed on June 8,1977 and acknowledgel that the two year time interval for review by the NSRB was not over as yet.

The inspector informed the licensee representatives that this matter would be examined during a subsequent inspection.

19.

Tests and Drills Technical Specification 6.4.2 specifies that quarterly drills a.

shall be conducted on site energency procedures.

Section 12.3.3(e)

of the FSAR commits to drills to develop and maintain the

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competence of operating personnel in handling of each category of emergency situation, b.

The inspector discussed with a licensee representative and reviewed records of the quarterly drills for the period December, 1975 to October, 1977, which verified that drills had been held each quarter during this period of time.

The inspector reviewed the critiques of the drills and discussed with a licensee representative the fact that nost of the drill scenarios (

vere missing from the critiques and that the drills apparently consisted of an announcepent to evacuate, for personnel to assemble at their respective assembly stations, and for accounts-bility of personnel without any actual evacuation or emergency team response.

This was thoroughly discussed at the exit interview. A licensee representative stated that the emergency drills were being conducted in accordance with the Technical Specifications.

The inspector replied that the Technical Specification drill frequency was being met, however, the PSAR commitments were not being met.

c.

The requirenent for the drills to be held quarterly appeared

to be satisfied. The inspector identified the failure of the

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licensee to conduct drills that would develop and maintain the competence of operating personnel in handling each category of emergency situation as a deviation from the commitment of Section 12.3.8 of the FSAR (77-24-09).

20.

Epit_ Interview The inspector met with 7 tcensee management representatives (denoted in paragraph 1) at the conclusion of the inspection on October 19, 1977. The inspector summarized the purpose and scope of the inspection and findings. The 'nspector discussed with licensee management representatives the two items of noncompliance, the five deviations (

and the two unresolved items.

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