IR 05000312/1989023
| ML20012B600 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 02/27/1990 |
| From: | Wong H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20012B598 | List: |
| References | |
| 50-312-89-23, NUDOCS 9003150389 | |
| Download: ML20012B600 (9) | |
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i U. S. NUCLEAR REGULATORY COMMISSION
REGION V
Report No:
50-312/89-23
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Docket No:
50-312
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License No: DPR-54
Licensee:
Rancho Seco Nuclear Generating Station
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Sacramento Municipal Utility District 14440 Twin Cities Road Herald, California 95638-9799 l
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Facility Name:
Rancho Seco Unit 1 l
Inspection at:
Herald, California (RanchoSe:oSfte)
w Inspection conducted:
Decetaber 9,1989, through Jenaary 24,1WO.
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A. J. D'Angelo, Senior Resident Inspector l
Inspectors:
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C. J. Myers, Resident Insnector n
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P. H. Qualls, Resident Inspecter
Approved By:
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91. Wong, ChTef f'
Date Signed
.ReacterProjectsSectionII
_ Summary:
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Inspection between December 9,1989 and January 24, 1990 (Report 50-312/89-23)
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Areas Inspected:
This routine inspection by the Resident Inspectors involved
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the areas of operational safety verification, health physics and security observations, engineered safety features system walkdown, maintenance, surveillanceandtesting,oceduresquality assurance and followup items.
During this inspection, Inspection rr 71707, 71710, 61726, 62703, 41400,~30702, and 30703 were used.
Results:
Of the areas inspected,-no violations of NRC requirements were identified.
A weakness was identified in the level of management approval used to defer the containment isolation valve leak rate testing requirements specified by
Technical Specifications and 10 CFR Part 50, Appendix J.
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Significant Safety Matters:
l No significant safety matters were identified.
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9003150389 900227
PDR ADOCK 05000312 b
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DETAILS
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1.
Persons Contacted
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D. Keuter Assistant General Manager (AGM), Nuclear
- J. Shetler, Deputy AGM l
S. Crunk, Manager, Nuclear Licensing P. Bender, Manager, Quality and Safety l
B. Gibson, Manager, Support Services
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P. Lydon, Manager, Nuclear Plant
D. Brock, Manager Nuclear Maintenance W. Peabody, Manager, Technical Services
l D. Yows, Manager Environmental Monitoring & Emergency Preparedness J. Clark, Nuclear Chemistry L. Houghtby, Manager, Nuclear Security M. Bua, Nuclear Radiation Protection J. Delezenski, Supervisor, Regulatory Coordination, Licensing
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Other licensee employees contacted included technicians, opcretors.
mechanics, security, and oi'ffc? personnel.
- Attenced the Exit Meettag on Jan% ry 26, 1990.
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Operational Statua cf Pancho Seco The plaat started this inspection period having just completed on
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L recember 8,1989, the inovement of all fue? dssemblies frc'n the reactor vessel to the spent fuel pool. t.dditional licensee activities during L
this period consisteri of draining the fuel transfer t. anal, rep'f acing the
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reactor vessel head, and orcgressir.g tc Mace systet.is not necessary to i
support operation in the defueled conditioi in a loag-term layup status.
At the conclusion of the period, cooling for the spent fuel pool was being provided by the spent fuel pool cooling system with a train of the
' decay heat removal system (including an emergency diesel generator)
available as a backup means of spent fuel pool cooling.
Investigations continued to attempt to resolve a small leak through the liner of the spent fuel pool.
parent improper valve alignment on the spent On January 26.-1990, fuel pool cooling systeman ap(SFC) led to an approximately two-foot level l
decrease in the spent fuel pool, from thirty-eight feet to thirty-six feet of water. There remained approximately twenty-three feet of borated water over the spent fuel which provided shielding to limit the dose rate on the surface of the pool after the level decrease to 1 mrem /hr, as l
measured by the licensee.
The-spent fuel pool level change had occurred after the close of this report period and will be addressed in the next inspection report.
50-312/90-03.
The licensee had also met with the NRC in NRC Headquarters on January 19, 1990, and on January 24, 1990, at the Rancho Seco facility, to discuss the status of the licensee's plans in the areas of emergency planning, training, and security. The licensee's plans discussed were of a general nature, but were structured to outline the licensing actions the licensee believes are needed for eventual decommissioning of the facility.
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Throughout this period the inspectors monitcred plant staffing levels.
l The total site staffing at the date of plant shutdown, June 6,1989, to the end of this period decreased from approximately 1500 to 655. The
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current staffing total is projected to decrease approximately 8 percent
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in July 1990. This staffing level appears adequate based on the defueled condition of the facility.
While plant equipment and personnel staffing levels have significantly decreased from the operational capabilities 9 1ch existed prior to the
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shutdown, it appears that plant personnel are able to support plant
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operations in the defueled condition in all functional areas. The
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current management effort is directed toward long-tem layup and the licensee's goal is to have the plant in a caretaker mode by the end of the third quarter of 1990, t
3.
Operational Safety Verification (41400. 71707)
The inspectors reviewed control room operations which included access control, staffing, observation of system alignments, procedural
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adherence, and log keeping. Discussions with the shift supervisers and i
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operators indicated an understanding by these personnel of the rer. sons
for annunciator indications, abnomal plant conditions end maintenance work in progress. The inspectars also verified, by observation of Sc1ve end switch position indications, that plant systems were properly alignao as required by technical specifications for the defueled condition of the
plant.
Control room staffing remained at that reqdired by the Tecnnical
Specification (TS) requireraent of one Senior Licensed Operator (SRO) and two Lice n ed Operators (RO). The licensee has proposed, in a letter dated December 28, 1989, that one SR0 and one R0 (not consistent with Technical Specification requirements while in cold shutdown) is an adequate manning level. That staffing level and position is consistent with 10 CFR Part 50 requirements and will be further reviewed by the NRC and is Inspector Followup Item (50-312/89-23-01).
Fire brigade personnel levels were being manned at the required level of five trained persons onsite. On-shift Technical Advisor (OTA) staffing in the control room has been removed and the personnel have been assigned to other duties and departments onsite. The TS do not require OTA watch standing for the cold shutdown conditions.
The operttions staff has decreased significantly to the point that power operation of the facility would strain their current capabilities. The present plant staff is adequate to support the defueled condition of the plant. No plans exist to train new operators.
A licensee submittal dated December 4,1989, described the licensee's interpretation of the Technical Specifications presently applicable in the defueled condition. The submittal essentially states that the applicable specifications are the current Technical Specifications.
Section 3.9, which establishes the operational parameters for the spent fuel pool system.
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The licensee submitted on January 30, 1990, a description of their plans for layup of systems. This submittal categorized systems into four classes:
operable, available, prudent to operate, and layup. The
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licensee has also established administrative controls over other plant l
systems which the licensee considers prudent to maintain in a functional
status. These controls encompass administrative action time limits for
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the outage of selected equipment. The "A" train side of plant equipment i
for emergency power of the Decay Heat Removal System (DHR) and the DHR
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system itself, with an associated heat sink, are being maintained in an
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available state. The surveillance intervals for these systems have been increased to a quarterly frequency based on the licensee's engineering review, rather than the previous monthly schedule provided for in
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Technical Specifications, i
The licensee's current actions regarding the "A" DHR system and auxiliary systems appear to maintain the systems functional to perfcrm their intended function as a backup system to the normally operating spent fuel
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pool cooling system. This issue is also under review by NRR for adequecy.
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The licensee hn continued toward the development of icyup plens wh1ch
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incorpcrate not only the acf.ual layup conditions, but also maintenance and su+veilknces necess6ry to support long-term layup conditions. This area is further Discussed in Paragraph 5 of this inspection report.
implementation of the layup plans have begun with the control rod drive,
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main condeasste-feeowater, nuclear instrumentation and reactor coolant
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System 3 beginning the layup process at the close of the inspection reriod.
System layup plans develop?d for the Reactor Coolaut Systeu (RCS) and
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Feedwater/ Condensate System (FW) were reviewed by the inspector.
Initial
inspector discussions involved the licensee's plar, for dry layup of the
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f RCS using nitrogen gas. The concern arose over the use of nitrogen gas in the RCS in that while the RCS may be relatively leak-tight with regard to liquids, the RCS may not be leak-tight when containing nitrogen gas.
This could result in some gas leakage out of the RCS, potentially accumulating in the lower levels of the auxiliary building and causing a personnel harard. The licensee stated that they shared the same concerns and had' decided to implement wet layup of the RCS. Progress towards achieving layup of both the RCS and FW systems have been proceeding, with completion expected by May 1990, and June 1990, respectively.
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Tours of the auxiliary, reactor, and turbine buildings including exterior areas, were made to assess equipment and plant conditions. Also, the tours were made to assess the effectiveness of radiological controls.
The inspectors 4,lso observed plant housekeeping and cleanliness, looked for potential fire and safety harards, and observed security and
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safeguards practices.
During this inspection period isolated housekeeping discrepancies were identified by the inspector which were promptly resolved by the licensee.
The general state of housekeeping was considered acceptable.
During work activities, it appeared that the health physics managers were conducting plant tours and monitoring work in progress. They appeared aware of significant work which occurred during this period.
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The inspector's review of Radiation Work Permits (RWP) revealed that the RWPs did include: job description, raciation levels, contamination, airborne radioactivity (if expected), respiratory equipment, protective clothing, dosimetry, special equipment RWP expiration, health physics (HP) coverage,andsignatures. The RWP radiation and contamination surveys were kept current.
The inspectors observed that personnel in the controlled areas were wearing the proper dosimetry and personnel exiting the controlled areas
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were using the monitors properly.
Labeling of containers appeared l
appropriate.
It appears that employees understand RWP requirements.
The inspectors walked down portions of the protected and vital area boundaries to ensure that they were intact and that security personnel were properly posted where kncwn deficiencies existed. The inspectors also observed protected area access control, personnel screening, badge
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issuing, general employee training, and maintenance on &ccess control equipment. Access control wts observed. Personnel entering with packages were properly searched and access esntrol w3s in accordance with licensee procedures. The inspector 4 observed no obstructions in the
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isolation tone which could conceal e person or interfere with the i
detection / assessment system. Protected area illuminatitt appeared
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adequate.
A major revision to the Security Plan (Revision 17) was 5sbmitted en
December 28, 1989, for NRC revier based ct, the facility's defueled condition. Thit, revisinn propusts tc redur.e the number of vital areas tc reflect the defueled canottion, therefure leading tr, reduced security
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personnel and maintenance support den.ane,.
For example, ccrtain
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emergency diesel generator rooms would nu longer be vital oreas.
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Security training continues.
In sumary, operations staffing appears adequate for the defueled condition at the plant. Plant equipment is being maintained in a graded approach dependent on its classification as an operable, available, prudent to operate, or layup system. Only systems required to be
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operable by Technical Specifications are being maintained in the manner similar to that which was previously performed while the plant was operating.
No violations or deviations were identified.
4.
ESF System Walkdown (71710)
During the inspection period the inspectors walked down the spent fuel pool cooling system, vital electrical switchgear rooms and emergency diesel generators.
The inspectors concluded that:
All observed hangers and supports were properly made up and aligned.
- Housekeeping was adequate, except some minor discrepancies which
were promptly corrected by the licensee.
No excessive packing leakage was observed on valves.
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Major system components were properly labeled, lubricated and i
cooled. No excessive leakage was apparent, j
Instrumentation appeared to be properly installed.
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No out of calibration gauges were identified.
Flow path components appeared to be in the correct position.
Required support systems were available.
- Proper breaker and switch positions were verified.
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No violations or deviations were identified.
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5.
Maintenance and Surveillance Observation (61726. 62702. 62703)
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Technical Specification (TS) required surveillance tests were observed and reviewed to ascertain that they were conducted in accoroance with
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7echnical Specification requirements.
Maintenance 6cti"ities for the systems and components were observed and
cev bwed to escartain that they were conducted in accoraance with
approved procedurcs, regulatory guides, industr,u t. odes or standards, end
the Technical Specifications.
Tne following items were considered during this review: testing 'as in
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accordteco with adequate procedures; test instruraentation was calibrated; limiting eonditions for operation were met; removal and restoration of
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the affected components were accomplished; test results conformed with TS and procedure requirements and were reviewed by personnel other than the individual directing the test; the reactor operator, techniciar,or engineer performing the test recorded the data and the data was in agreement with observations made by the inspector, and that any deficiencies identified during the testing were properly reviewed and
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resolved by appropriate management personnel. The activities reviewed i
included layup and testing of RCS components, control rod drive mechanisms, feedwater/ condensate components, and the main steam system.
The licensee has significantly reduced the scope of their maintenance program and the size of their maintenance staff. The total maintenance staff has decreased from about 70 to 45. The licensee's present maintenance activities can be summarized as follows:
L Maintenance on equipment required by Technical Specifications to be
operable in the present defueled condition.
Maintenance on equipment that is not presently required to be
operable, but that the licensee has concluded is prudent to maintain
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in service or in a ready-to-operate condition.
Maintenance being performed to prevent the degradation of equipment
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no longer in service.
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As an example of equipment not required by the Technical Specifications which is being maintained, the licensee interprets the Technical i
Specifications to not require the Emergency Diesel Generators to be operable when in the defueled condition. However, the licensee has elected to maintain one diesel generator. Electrical components not i
needed in the defueled condition are energired, but are not being
calibrated and, for many components, unnecessary actuation or initiation
features have been disabled.
For example, control room alarms and
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annunciators which would be expected in the defueled condition have been evaluated by the licensee and disabled to minimite the amount of
constantly lit alarms.
j At the end of the inspection period, the inspector was notified by the licensee that surveillance testing on some containment isolation valves had not been completed within the 24-month frequency specified by 10 CFR
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Part 50, Appendix J.
While Technical Specifications do not require containment integrity to be demonstrated while in the defueled condition
of the plant, the testing frequency specified in Appenoix J does not i
account for outages which may occur at the end of tie testing frequency.
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The inspectors identified that an engineer, with his innediate
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supervisor's approval, evaluated the serve 111arce requirement with regard to containment integrity regulNments of Techniral Soecifiatio'is and
concluded that it was acceptable to not perform the leak rate tost;ng gecified by the surveillances. Since the engineer was in charge of the computer tracting system for thtse survei tancts, he and his superviser
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l vere the only ones who reviewed the cancellation of the rurveillances.
The inspector's co:c:trn was that the cancellation of surveillance testing
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was not being reviewed at a sufficient managment level to usure en adequate review of the implications of the decision. The licensee had
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previously submitted, on October 20. 1989, an exemption request from the requirements of Appendix J, but this request had not yet been acted on by
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the NRC. This issue will be further reviewed by the,NRC and is Inspector FollowupItem(50-312/89-23-02).
An additional concern was expressed by the inspector in the licensee's evaluation of requirements which are not plant mode dependent, whether the review carefully considered the literal requirement and not only its
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l implication to plant safety. Such examples include 10 CFR 50.49 (Environmental Qualification) and T.S.3.2.2., for low temperature overpressure protection. The licensee had stated that a review was in process at the close of the inspection period to identify other l
requirements which are not mode dependent and do not have technical merit i
to be performed in the current plant mode.
In summary, normal maintenance activities continue at their previous level for those sytems needed for the defueled condition of the plant; however, the full maintenance program is no longer applied to many systems which are no longer needed, nor could the present maintenance staff support full program implementation. The licensee is taking actions to prevent physical degradetion of systems no longer in service, however the licensee does not intend to maintain that equipment in a ready-to-operate condition. Greater management attention needs to be placed on the decision-making process to assure that evaluations to defer or delete previous requirements are reviewed by the proper levels of management.
No violations or deviations were identified.
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{ngineeringStatus The inspector has periodically reviewed the status of the licensee's i
engineering organization. The licensee no longer appears to have
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sufficient engineering staff to operate the plant at power and the st6ff remaining are primarily focused on the completion of plans for the long
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tenn layup of systems. These efforts appear to be adequate. The
inspector reviewed the layup plans associated with the RCS and feedwater
systems and had discussions with the vendor and reviewed vendor manuals
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l to assure that layup plans included any pertinent vendor information.
l The present engineering staffing stands at approximately 50, down from 91 at the time of plant shutdown.
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Training Program Statul
The 11cersee's training program has been significantly reduced in scope;
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For'ever, the program appears appropriate for the defueled condition at the plant. No new operator training is being conducted. Requalification trtining is being ctaducted focusing on the defueled condition at the-i
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plant. Training applicable to an operating facility is being deferred
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i until the end of the training cycle with the expectation of obtaining program relief from the NRC prior to that time. The licensee infomed the NRC in a letter dated January 1,195,0 of its intention to withdraw from JNPD. Relief t1auests from the requirementd of Part 55 for a high fidelity simulatnr and training have been r9baitted. Technical staff
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training has been eliminated.
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0A procram Status
The overall safety assessment and QA oversight capabilities have been
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reduced to the point that would not support normal power operations; however, current capabilities are adequate for the defueled condition at the facility. The scope of the OA and OC program is focused on the defueled condition at the facility. Theplantoversightcommittees(PRC
- onsite and MSRC - offsite) continue to meet at regular intervals with membership changes made due to the reduction in plant personnel. These committees continue to be maintained with fully qualified personnel.
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Fitness For Duty. Initial Training Inspection (TI 2515/104)
The inspectors attended licensee " fitness for duty" training for employees and escorts, and for supervisors. This training was required for the licensee to comply with new federal regulations in this area.
The training for employees and escorts addressed:
Licensee policy and procedures
Personal and public health and safety hazards of drug abuse
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The effect of over-the-counter and prescription drugs
The roll of the Medical Review Officer
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Employee assistance programs
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Techniques for recogniting drugs and indications of abuse
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Techniques for recognizing aberrant behavior
Procedures for reporting problems
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Consequences of lack of compliance to policy
Additional training provided to supervisors included:
f Their roles in program implementation
The roles of personnel, medical and employee assistance program
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Techniques for recogniring indications of drug use
Procedures for initiating appropriate corrective action
No viohtions or deviations were identified.
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10. Exit Meeting (30/03)
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The irispector met with licensee representatives (noted in persgraph 1) at various times during the report period and formally on January 26, 1990.
The scope and findings of the inspection activities described in this, report were sumarized at the meeting. Licensee representatives acknowledged the inspector's findings at that time.
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