IR 05000395/1982003

IE Emergency Preparedness Appraisal Rept 50-395/82-03 on 820111-15.No Noncompliance Noted.Major Areas Inspected: Emergency Preparedness Program

ML20050A789
Person / Time
Site:	Summer
Issue date:	03/02/1982
From:	Andrews D, Cline W, Huffman G, Jenkins G, Marston R, Roemmich R NRC Office of Inspection & Enforcement (IE Region II)
To:	South Carolina Electric & Gas Co
Shared Package
ML20050A782	List: IR 05000395/1982003 ML20050A781 ML20050A785
References
50-395-82-03, NUDOCS 8204020272
Download: ML20050A789 (31)

Text

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UNITED STATES

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NUCLEAR REGULATORY COiViMISSIOM

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REGION 11

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ie: -: Nc. 50-395 52-03 Soutn Carolina Electric and Gas Company 1:ensee:

P. O. Box 764 Columoia. SC 29215 racility Name:

V. C. Summer Nuclear Station OccKet No. 50-395 License No. CP:R-94 Inspection at ne Summer site near Jenkinsville, SC

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W. E. Cline Date Signec Accomoanying ?erse.n E. E.,ickey, J. Simones

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G.R.J Ws, Section Cnief, EPOS Division 0' ate Signec SUM. VARY

Inspection on January 11-15, 1982 Areas :ns ected

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This special announcea inspection involvec 390 inscec::r-hours en site in performance of an Emergency Preparedness Aopraisal.

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Results In :ne areas inspected, no violations or dev'a icns oe-e icentif'ec.

• praisal deficiencies.ere identified in the folicwing areas:

Emergency Facilities and Equipment, carag-ach 4.1.1.6 and 4.1.1.7 ; area arc P-ocess Racia.icn Yonitors,

aragraoh 4.2.1.2; Emergency Notification, paragraoh 5.4.1; anc, Eme ;ency

mplementing -ocecurss, caragrapn 5.4.3.3 anc 5.4.6.

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8204020272 820331 PDR ADOCK 05000395 G

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TABLE OF CONTENTS

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acministration

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.:mergency.rgant :a:1on

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2. '. Onsite Organi:ation i

2.2 Augmer a-ion Organi:ation t

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-:me gency -act tiles anc : uloment

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mergency.aci,ities

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t Assessment Facilities

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4.1.1.1 Control Room

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iecnnical dupoor: Center (iSe)

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4.1.1.3 Coerations Support Center (OSC)

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mergency woerations -acility (,r)

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4.1.1.5 Post-Accicent Coolan Sampling and Analysis

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,ost m.ccicent containment Air Samo..iing anc

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Analysis 4.1.1.7 Dost-Accident Gaseous and Particulate Effluent

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Sampling and Analysis

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4.1.1.3 Post-Accicent Liquic Ef fluent Sampling

anc Analysis 4.1.1.9 Offsite Lacoratory Facilities t

4 1.2 Orotective Facilities

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Med,i ca. 'Reassemoly Areas.

Assemoly,

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.reatment rac111 :es

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4,.,.c, 4.1.2.3 Decontamination.:acilities

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exoancec duccort -act,it es

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4.1.4 News ~ enter a.2 Emergency E:ui: ment

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4.2.1 Assessmen E:v' ment

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a.:.1.1 Emergency <i s anc Por:acie Instrumentation a.2.1.2 Area arc :*ocess Raciation Monitors a.:.1.3 Nor-Raciation Process Monitors a.2.1.4 Meteorologicai Instrumentation a.2.2 Drotective Ecuipmen:

2.2.2.1 Reso4-atory Orcsection a.2.2.2 Drotective Clo:ning a.2.3 Ocemunications a.2.4 Damace Control /Cor-ective Action..

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meserve :mergency suco ies anc :culement

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.o 4.2.6 Transoortation 5.3 Drotecures 5.1 Gene *al Content anc :orma:

5.2 Emergency. Alaem anc Abnormal Cccurrence 3*ccecures 5.3 Implementing Instructions 5.a Imolementing Deccecures 5.a.1 Notifications 5.a.2 Assessment Actions 5.a.2.1 Of f site Raciological Surveys 4'

5.4.2.2 Onsite (Out-of-Diant) Radiological Surveys 5.4.2.3 In-Dian: Raciological Surveys 5.a.2.4 Drimary Cociant Sampiing 5.a.2.5 Primary Cociant Sample Analysis 5.4.2.5 Post-Accicent Containment Air Samoling 5.a.2.7 Containment Air Samole Analysis 5.d.2.8 Stack Ef fluent Sampling 5.a.2.9 Stack Ef fluent Samole Analysis 5.a.2.10 Liouid Effluent Sampling

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5.a.2.11 Liquic Effluent Sample Analysis 5.4.2.12 Rad 4ological Environnental Monitoring Program (REMP)

5.a.3 Drotective Actions e

5.a.3.1 Raciation 3rotec; ion During Emergencies 5.a.3.2 Evacuation of Owner Controlled Areas 5.a.3.3 Dersonnel accountability

5.4.3.4 Personnel Von'toring and Cecontamination

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5.4.3.5 Onsite irst Aic/ Search and Rescue

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5.a.a security During Emergencies 5.a.5 ecair.' Corrective Actions 5.4.5

ecovery

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5.a.7 Ouolic-:q'ormation-l 5.5 Su o'ementary P ocecures

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Coordination with Of # site Gr0uod

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Of * site Agencies

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INTROCUCTION l

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ne ourcose of :nis special acoraisal was to cerform a :omc*enensive evaluation

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This acoraisal. incluce: an O' tae licensee's eme*gency precarecness program.

anc effectiveness of areas for wnicn explicit eva'uation of :ne aceouacy reg. atory recuirements may no: Ourrently exist.

The acoraisal effort was

ciae::ec towaras evaluating the 'icensee's cacacility anc cerformance ratner than l

tre ' centi #i:3 f on of soe:ific items of noncomoiiance, Tne acoraisai scoce anc fincings were summari:ec on January ;5, 1932, with those i

persons indicatec in :ne attacnment to tnis report.

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~ is area was reviewec curing tne acoraisal on June S-17.1931 (OIE Report No.

50-395 SI-12).

No deficiencLes or imorovement items were icentifiec and the r

1. '.c'ngs incicatec that this area was complete anc acecuate.

No further nsce;; ion was concuctec in this area.

3.0 Ere gency Organi:ation

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nsite Organi:ation Tne onsite eme gency organi:ation was reviewee curing the acoraisal in June 1961.

anc :ne crocecu-es for staffing tne functional positions in tne organization nac net ceen com:1eted.

(OIE Recort No. 50-395/SI-12).

At this time a licensee a procecure was being cevelopec wnicn woulc cesignate epresentative stated tnat

'ncivicuals cy position or title wno woulc fill tne functional cositions witnin In acdition, a method was to De cevelocec for shift

ne eme gency organi:ation.

staffing anicn aoulc insure tnat the onsnif t organi:ation woulc ce aware Of their inciv cual emergency team responsibilities. Revisions to tne Emergency Plan anc i

ne onsnift emergency

.mplementing Procecure EPP-Clc were reviewec to verify tnat

individuals onsnift have oeen assignec Organi:ation nac ::een soecifiec anc that functiona. -esconsicilities in the emergency organication.

The emergency organi:ation nas ::een icentified and specific onshif t assignments have been mace.

Items 50-395,31-12-01 and 50-395/S1-12-02 are closec.

a ; entec Emergency Organi:ation 2.2 u

A ce'ic ency icentified in tnis area curing ne aceraisal of June S-17,19S1 (GIE i

Report Nc.

50-395/51-12,) concerning tne clarification of autnority anc esconsibi'ity for octh tne Offsite Emergency Coorcinator anc the Emergency l

Oirector, -as reviewed to verify tnat corrective actions hac ceen taken to

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l esolve tne Or0 gram deficiency.

The struc.ure of :ne augmented emergency organization was altered and an

organ;:ational cosition was added to provide overall management control of tne representative.

emergency orgar.1:ation, to be filled by a senior SCE&G management Tne new position is cesignated the Emergency Control Officer and is no-mally fillec Dy the Vice D-esident, Grouc Executive, Nuclear Operations.

Appropriate

t al ternates have :een cesignated.

and duties of the Section 5.3.1 of the Emergency Plan cescribes the authority Emergency Control Officer wno has overall nanage.ent control of *.he emergency m

resocnse organization.

00m and and control functions among the Emergency

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Control Officer have Director, Of f site Emergency Coordinator and the Emergency

sen clarifiec.

This area The deficiency previously identifiec in tnis area has been :cr-ectec.

a: pears to be a: equate. Item 50-395/31-12-03 is Closec.

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3.0 Emergency Dlan ~ raining Retraining 3..

D-ogram Estaoiisnment i

I Ine insoector's review and evaluation of :ne training anc retraining programs involved:

discussions with licensee reoresentatives; review of crocecures, review of lessons plans, anc examination of -ecorcs relatec to General Employee

Training and Soeciali:ec Training Programs.

reviewed incluce One most recent revision of EDP-OIS issued on C-:ce:ures Among otner things tnis procecure prescrices tne tyces of training 12.1/ 5 '..

l Otner crocecures recuirec for on-site and offsite emergency resconse eersonne.

reviewec :nat cave cearing on emergency resconse. raining inciuce AP-3101 General

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Emoloyee Training, Rev 3 anc AP-110S Visitor and Contractor Training, Rev. O.

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sho ec :nat as of Decemoer 31, 1931 tne licensee hac 20 records Licensee Dlan Procecures tnat prescrioec certain speciali:ec emergency -esconse Eme*gency func-ions.

Following tne review of :ne procecures EPP-018. AD-1101 and AP-1108, l

tne nscector nac no comments *eievant to their tecnnical content.

ine insoector revienec selectec licensee lesson plans related to e~ergency

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response function training for general employees anc emergency resconse wor (ers.

Tne lesson plans reviewed accearea ccmciete in tnat tney containe stated performance ocjectives, inclucec site soecific inf ormation wnere acclicacie, outlinec major topics to be discussed, and referencec applicable procecures.

Training records examinec included Qualification Recore Carcs, Waiver of Otner Tne inscector noted nat these Training Recuests, anc individual training files.

records were being maintainec in accordance with applicable procecures.

position existed within tne General Emoloyee Training i

It was notec :nat a vacant Seogram as a esult of a recent reorgani ation. Licensee representatives stated tnat recruitment ef forts were underway to fill tne position.

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The five items icentified as pending c moletion in section 3.1 of NRC Re: ort 50-395/31-12 eere reviewed.

As a result of implementation of cractices anc procedures delineated in procecures EPP-01S Rev. O, AP-1101 Rev. 3, anc AP-110S Rev. O these 'ive items are now considered comolete.

Dased on :ne above findings this area of the licensees crogram acoears to be i

adecuate.

Items 50-395,51-12-04, 50-395/S1-12-05, 50-395/31-12-06, 50-395/SI-II-07, anc 50-395/S1-12-08 are closed.

3.2 D-opram :molementation

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examination of selected licensee training records, The in<,pector veri fied by of licensee procedures, anc by discussion witn licensee personnel that

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review emergent.y response training had been provided to aoprocriate on-site and offsi e

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t agency emergency resoonse personnel.

Licensee procedures orovide for retraining / refresher training.

A review of training records indicated that tne p*ogram is ceing implemented in acc edance witn estaolishec Orocedures.

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Item 50-395/31-12-09 is closed.

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• 4s 00r*.icn of *ne licensee orogram accears *o se aceouate, newever, :ne

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following snovic ce consicerec f or 'morovemen.:

Estaolisn cualification c-iteria for incivicuais selec ec to concuc emergency resconse training (50-395/S2-03-01).

a.0 Emergency Facilities anc Ecuipment 4.1 Emergency Facilities g ssessment Facilities A

4.1.1 4.1.1.1 @# Control Room No.

This area was reviewed curing tne appraisal on June S-17,19S1 (OIE Recor:

50-395/31-12).

No ceficiencies or improvement items were icentifiec anc :ne f1ncings incicatec that inis area was complete anc acetuate.

No furtne*

inspection oas concutted in this area.

4.1.1.2 Tecnnical Support Center Tnis area was reviewec curing the acoraisal on June S-17, 1991 (OIE Recor: No.

50-395/51-12).

No deficiencies or improvement items were i entifiec anc :ne fincings incicatec tnat this area was complete anc acecua.e.

No fur:rer inspection was concucted in this area.

4.1.1.3 Operations Support Center inis area was reviewed during the acoraisal on June S-17,1981 (0IE Reper: No.

50-395/51-12).

No ceficiencies or improvement items oere icentin e: anc.ne findings incicatec that this area was complete anc aceauate.

No furtner insce : ion was concucted in this area.

4.1.1.4 Emergency Coerations Facility This area was reviewed during the aporaisal on June S-17, 1981 (OIE Report No.

50-395/S1-12).

No deficiencies or imorovement items were icentifiec and :ne fincings indicated that tnis area was :cmplete and aceauate.

No furtner inspect;on was concucted in this area.

4.1.1.5 Post Accident Coolant Sampling anc Analysis i.

The post aC:icent Coolant sampling and analysis system was evaluateC agains: 10 CFR 50.47(b)(B), 10 CFR 50 Appencix E, Paragraon IV.B., se'e::ed cr':eria in NUREG-0654,Section II.I and NUREG-0737,Section II.S.3 and tne attachments to

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The location of the post-accicent sampling area on Eleva. ion 412 is accessible curing accident conditions and is monitored for high levels of racia-ion.

7he design and shielcing of the sampling areas and sample l'nes are such.nat

radiation doses received by the user shculd not ce excessive.

he sarple col'.ection, cilution and analysis is fully aute a:ed ith ;rovision for manual sampling. Act:matic or manual cilution of samples eliminates :ne neec for remcte

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nancling ecuipment anc snielcing.

Ine samoling and analysis systems are cesignec Basec on :ne aoove

• o y eld f4M srec analytica' cata in approximately one nour.

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.# ncings, tnis portion of :ne licensee program acoears to ce aceouate.

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50-395<51-12-10 is closec.

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4.1.1.6 Post-Accicent Containment Air Samoling anc Analysis

Tne cost-accicent containment air samoling anc analysis systems was evaluated

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against 10 CFR 50.57(b)(8), 10 CFR 50 Appendix E, Paragraon IV.B., selectec l

criteria of NUREG-0654,Section II.I anc NUREG-0737 Section II.3.3 and the

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Attacnments to : I.F.1.

Tne post accicent containment air sampling anc analysis system is cesignec witn a

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The backup station cacv.uo coerating station, botn stations are on Elevation 463.

is orovicec in case the primary station is in a higner radiation field. Both coerating areas anc :ne sampling stations are monitored and will ce accessible uncer a worst case accicent, altnougn it may be necessary to traverse scme rela.ively nign raciation fielos enroute. The procecures recuire the use of a nanc held monitor and tne system is designed for the rapid removal of samples, assuring that eersonnel exoosures are ALARA.

Automatic cilution of samoles

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eliminatec tne neec for remote nandling eauipment and snielcing. Tne samoling anc analysis systems are designed to yield finished analytical results in aporoximately one hour. However, since tne ecuipment has not Deen released for use, a walk-tnrougn was not performed.

The acceptacility of tnis area of the licensee's program could not ce determinec because tne sampling equipment has not been released anc this area will be

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reviewed curing a subsecuent inspection.

Since the containment air samoling and analysis is not functionally available for use, item 50-395/31-12-11 is

consicerec a ceficiency in :ne emergency preparecness program.

4.1.1.7 Post-Accident Gas and Particulate Ef fluent Sampling

f This area was reviewed during the appraisal of June 1981.

The results of that i

review were recorted in 01E Inspection Report No. 50-395/S1-12. The fincings of

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the report indicate that this area of the licensee's program could not be i

appraised at inat time (50-395/81-12-12). The f acilities anc equi;; ment available for post-accicent gas and particulate effluent samoling and analysis were evaluated against 10 CFR 50.47(b)(S),10 CFR 50, Appendix E, Paragraph IV E, anc

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selected criteria in NUREG-0654,Section II.I.

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At this time, all systems used for cost-accident gas and particulate samoling are i

installed anc functional, however, the systems, including monitors, are still in preccerationai testing and have not been turnec over to cperations.

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The locations of all the post-accicent sampling points should be accessible

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accicent conditions.

Personnel collecting the samples will folicw l

during HPP-310, Sampiing of Radioactive Gases and Licuids, for ottaining the samples.

.l EPP-003, In-Plant Radiological Surveying, provices guidance in ne area of

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radiological safety while taking the samples in an emergency.

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concit ons, there are

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If the counting room is not accessible during accident

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j provisions to use an alternate facility which is alreacy estaclisnec or to move l

analytical equipment to ano.her location if neces sary.

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L Easec on tne a::ve #incings, tne following ceficiency was icentifiec:

Tne testing and calioration of e:uipment usec for cost-ac:icent gas anc carticulate ef fluent sampling was not complete.

Item 50-395/S1-12-12 is

ansicerec a program ceficiency.

4.1.1.3 Post-Accicent Liouic Effluent Samoling and Analysis inis area oas *eviewe: curing tne acoraisal of June 1981. The results of that review we e recorted in DIE Insoection Report No. 50-395/81-12. The fincings of tnis area of tne licensee's orogram coulc not be

nat recort incicate that acoraisec at tne time (50-395/S1-12-13). The facilities and eouipment available r

for cost-ac icent liouic effluent samoling anc analysis were evaluatec against 10 CFR 50.47(b)(5),10 CFR 50, Apoendix E. Paragraon I.V.E. and selectec criteria in l

NUREG-0654, Se: tion II. I.

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Dost-accicent liquic effluent samples are to te taken from ne same sample coints t

and in tre same manner as normal liouic samples. The samples are to Oe taken in accorcance witn HPD-310 Sampiing of Radioactive Gases anc Liouids and HPD-308, Sample Analysis.

In accition EPP-003, In-Plant Radiological Surveying, orovices c.uicance in the area of radiological safety curing samole collection.

Ali equi: ment used for effluent sampling anc analysis was in place anc coerational.

Based on the a:ove findings, this cortion of the licensee's program appears to be acceptacle. Item 50-395/81-12-13 is closec.

cacilities d.1.1.9 Offsite Laboratory This area was -eviewed curing the acoraisal on June S-17,1981 (OIE Report No.

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50-395/31-12).

No ceficiencies or improvement items were identifiec anc :ne findinos indicated that this area was complete and adeouate.

No furtner

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inspeciion was concucted in this area.

4.1.2 Protective Facilities 4.1.2.1 As se-bly,' Reassembly Areas This area oas -eviewed with respect to the requirements of 10 CFR 50.a7(b)(10),

and specific : 'teria in NUREG-0564, Section J.

The (initial) On-site assembly areas are designatec for on-site individuals as:

normal oork areas for permanently assignec people; the Planning /Scheculing Rocm

1. or Chanps/ SCI support people, and the QA/ Security Building for visitors and i

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non permanently assigned pecole. The cesignatec emergency persennel will report to their emergency station, i.e.,

Tech Support Center, Emergency GP's Area, r

Health ?hysics Lab., etc. Onsite assembly is addressed in EPP-008.

Evacuation and offsite assembly are accressed in EPP-012. Two of f site assembly areas are des'gnated.

The Emergency Director /Shif t Supervisor will cetermine is to be usec depending On meteOrol0gical concitions. Drovisions are made which for a senior su:ervisor to establish control of the area, anc for ;ualifiec

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ce-sonnel to ce cisoa cnec to tne of# site assemoiy area for personnel monitoring r

anc cetontamination.

Ectn offsite areas nave sufficient space to ac:ommocate :ne eersonnel and nave toile. facilities.

Basec on tne acove #4ncings, tnis area of tne licensee's crogram accears to be acecuate. Item 50-395,51-12-14 is closec.

4.1.2.1 Meci:al Treatment Facilities This area was reviewed during tne acoraisal on June 5-17. 1981 (OIE Recor: No.

50-395/31-12).

No ceficiencies or imorovemen; items were icentifiec and tne fincings in icatec nat tnis area was comclete anc acecuate.

No further inspection oas concuctec in tnis area.

4.'. 2.3 Cecontamination The onsite ce:ontanination facility is locatec in :ne vicinity of the cnange room, onsite mecical f acility, and the HF lab.

asice for oersonnel friskinc, a I"e cecontamination. area nas a small area set

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larger room w':n :nree sinks ano anotner large room witn several cecontamination snowers.

Decontamination suoplies, sucn as cecontamination foam, cete gent, soap, and wices, are available in a cacinet near tne sinks.

Decontamination procedures will not be maintained in :ne decontamination area, cue to its proximity to tne HP lab.

Survey instruments are not yet available in the decontamination area for frisking.

Discosaole replacement clotning is available in :ne cabinet in the cecontamination area.

Licuic waste will crain to :ne Racwaste Area in tne Auxiliary Builcing.

Solid waste will be out into :ags q

anc crums to te croviced.

Provisions are made for survey and decontamination at assemly/reassemoly areas.

for monitoring Off site Holding Area Emergency Kits have supolies anc ecub.nent anc cecontamination, and are availacle at tne security exit f rom the Protected Area. at tne EOF anc at the reassemoly area at the Nor:n ene of Monticello reservoir.

Item 50-395/31-12-15 is closed, based on the acecuacy of supplies anc ecui; ment now in place.

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Based On the above 'indinos. this cortion of the if censee's procram a;cears to be

acecua:e; newever, tne lack of frisking instru ents in :ne decontamination area t

kits will be trackec under and the uncalibratec instruments in :ne eme gency

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Secti on 4. 2.1.1.

4.1.3 Exoanceo Succor Facilities This area was reviewed during the a;craisal on June 6-17,1901 (OIE Recort No.

t 50-395/81-12).

No deficiencies or improvement i ems ere icentif'ea anc the findings indicated that this area aas c omo '. e t e and acecuate.

No further inspec:f on oas conductec in :nis area.

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.a c.1.a News Cente-In's area was reviewe curing tne acoraisal on June 3-17. 1931 (OIE Report No.

50-395.31-12).

No ceficiencies or improvement items were icentifie: anc tne fincings incicated tnat tnis area was complete anc aceouate.

No furtner inspection was concuctec in :nis area.

4.2 Emergency Ecuioment 4.2.1 Assessment Ecuipment

4.2.1.1 Emergency Kits and Emergency Survey Instruments imoiementing crocecure EPP-019. " Emergency Ecuioment Cnecklist", cefines tne

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Accendix E

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location anc content of emergency kits anc other emergency sucolies.

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o' :ne Emergency Plan lists ecuiement and sucolies, out it was not current in

nat eculoment specifiec Dy ne E?D cic not mat:n tne e uipment snown in :nis portion of tne clan.

P ocecure EPP-019 anc :ne most recent Emergency Kit inventories aere -evienec.

ne kits oere inventeriec, tne calibration status of tne incluced instruments l

we-e cneckec, anc the emergency kits aere dis assec witn licencaa r

i recresentat ves.

i i

anc sucolies aere located as specified in tne D-ececure with

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The kits, ecuioment, tne exception of tne EOF kits oni.n are to be storec in :ne hP lao until tne EOF

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Kits anc ecuioment are locatec so as to De reacily available is eacy for use.

• to tne teams recuirec to use tnem.

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The emergency kit contents were invent 0riec acainst the Attacnments to inventory per formed by licensee pe-sonnel.

The inventor'es anc the most recent were founc to De complete witn the exception of one cneck source missing from the l

CSC (it anc one from tne TSC kit. The TLDs and extremity TLD holcers soecifiec i

were not founc in :ne TSC kit, out were replaced oy simulatec TLDs. The licensee statec that a purcnase order was available for the TLDs and that they coulc ce

sent from the vencor in Columbia upon recuest.

The procecure also specified I

Operational check and calibration frecuencies for the instruments and air j

With tne exception of the VAMP Monitor used in the OSc,

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samolers in the kits.

Calibraticn none of the instruments, dosimeters or air samplers were calibrated.

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procecures were available for the survey instruments and dosimeters anc One is being oritten for air samplers.

Ion chamber anc G-M instruments are octh avaacle for in-plant anc of# site monitor teams.

Specialiced instrumentation is also available fcr the in-clant

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teams.

i The e;uipment and crocedures used for octh in plant and envi-Onmental surveys i

ensures the capability to detect and measure airborne iocine anc particulates to r

the -ecuired minimum activities.

i cuel wanci'ne

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Since erer;cncy kits are new 'nstalled in the Auxiliary and Euildings, item 50-395/S1-12-16 is closec.

Since the emergency kits now have acequate sets of procecures,

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i 50-395/ S1-12-15 i s cic sed.

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St e:e ;-ocecure E:0-019 now i ncluces requirements for instrument operacility

necss, item 50-395,31-12-21 is closec.

5 nce extremity dosimetry is now provicec for in tne TSC Emergency Kit. item 50-395/31-12-22 is closec.

Ease: on the above fincings, this cortion of tne licensee's program accears to be

ne following items wnien were icentifiec in Inspection Report ace:aate; nowever,

' c. 50-395c 31-12, snould ce :ensicered for improvement:

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This TLDs need to De provided for the TSC., EOF anc Offsite Emergency Kits.

ciscrecancy was icentifiec on the crevious inspection anc is ceing tracKec in tne kits anc a copy of as 50-395/ 31-12-17. Hign range cosimeters are now Drecau-ions Limitation anc Se points is now in :ne TSC.

Survey ins ruments, cosimeters and air samplers in :ne emergency kits nee to ce calibra:ec as specifiec in the HPD Series Orocecures (50-395e51-12-IS).

Rew ew anc revise as necessary, Appencix 3 of :ne Emergency Plan to ensure

na:

ne list of emergency ecuipment anc suopiies is current (50-395/51-12-20).

4.2.1.2 Area and Drocess Radiation Mgnitors This area was reviewec curing the acoraisal of June 1981. The results of inat rev ew oere -ecorted in OIE Inspection Recort No. 50-395/SI-12.

The f'ncings, as sta:ec in :na: report, were tna :nis area of the licensee's program appearec to de at:ep;acie cending completion of four items. Comoiete installation, testing anc calioration of

ne area and process radiation monitoring system (50-395/S1-12-23) was found to be unaccomplisnec.

The nign range reactor building area monitor (RMG-13) has not ceen installec.

Tne main steam 'ine monitor ( RMA-la)

monitors (RMG-19A, B anc C), :ne reactor cuilcing ourge exnaus and :ne hign range main clant vent monitor (RMA-13) nave been instal'ec, calibrated anc are functional, however, these monitors are still being creop tested anc are not operational.

All other process anc area monitors nac been testec.

In accition. RYA-13 was found to be -eading 100 mR/hr.

Licensee personnel statec the reacing may be cue to the low temoe-atures anc ice whicn had formed on

na:

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ne ce:ector :acinet.

Three of the four items (50-395/51-12-24, 50-395/31-12-25 and an item also ciscussec in Section 3.2) were founc to be ::mpleted.

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Based on the atove 'indings, the following ceficiency was icentif'ed:

Installation, testing and calibration of ne high range conta'rment l

radiation moniter was not ::=cleted.

Item 50-395/S1-12-23 is consicered a i th -espect to the reactor builcing moni:ce arc :ne program ceficiency o

c:mpletion of pre-operational test ng anc turn-over of the area anc orc:ess i

raciation monitoring system.

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i Nor-Eaciat on D*0:ess V0nt0*s i

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.I.2.1.3-is area was rev'ewee cur'n; :ne acoraisai of June 1981. Tne results of tna:

ie-ere recortec in CIE Insce:: ion Recor: No. 50-395/51-12.

Tne fincing es (5C-395,31-12-26) as stated in :nat report was ina

ne licensee's program a::earec to se accepta0ie cencing completion of the installation of the seismic arnunicators in the control room.

During this acoraisal all instruments and-eaccuts we-e founc to e installec anc functional.

Basec on :ne acove fincings. :his area of the licensee's program appears to be a::e :acle. I em 50-395 31-12-26 i s closed.

c.2.1.c Veteorolcoical Instrumentation review of is area was evalua:ec by insoection of instrumentation anc eoui: ment.

ninsoecilon anc calicration recorcs, tne Instrument Control Procecure, and

4 scussion wi:n ensee eersonnel.

Tne casic carameters recuirec ey.he Emergency Plan and Drocecures (winc speed,

.inc cire: icn, incication of atmosone*ic stacility (ceita T)) were providec by meteorological instruments located on :ne primary onsite tower.

All tne tre in the instrumentation at ne crimary site anc recording anc incicating ecuioment Centroi Room ere aceracie anc caitoratec.

In :ne event na tne primary system is incoeracle, meteorological varia0les at Site 2, across :ne reservoir, are used as input to the cose assessment crocecure.

The Site 2 information is not transmittec to :ne pian; but someone has to be ciscatenec to the Site to reac and transmit the information to the plant.

A 'icensee re -esentative statec :nat a cackup system will Oe erec.ec Onsite witn automatic transmission of cata. Yeteorological data can be enterec manually c*

automatically in:0 :ne cose assessment computer sys:em.

i At least nree daily ocerational cnecks are cone oer week Of :ne crimary system.

I Siweekly calibration checks and monthly functional tests are done, anc a full calibration i s cone every six months.

P-Ocecure EPP-002 makes provisions for meteorological information for followuo notification messages from the plant to offsite authorities.

Procecure EPD-005 Orovides for :::aining t a c k.uo meteorological data for dose assessment anc

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protec.ive ac.'cn cecision making if the primary system becomes inoperacle.

o from :ne Onsite The backuo data will come from the Site 2 instrumentation (later, Dackup system) or tne National Weather Service.

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This area was reviewed during the appraisal of June 1981 anc reocrtec in Office

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of Inpsection and Enforcement Inspection Report No. 50-395/5;-12.

The following items from tha: report are :lesed:

em 50-395/S1-12-27 is closed since the atmospheric stability incicator is avai'able at tne interi.m backup system at Site 2.

Item 50-395/31-12-2S is ciesec since the eteorological ca.a has n:w been integrated int the raciological assessment procedures.

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ATTACHMENT 70 OIE REPORT NO. 50-395/52-C3 P

sons Contactec s

Licensee Personnel

'W. A. Williams. Jr., General Manager Nuclear Oceration SCE&3

'O. 5. Eracham, Station Manager

'J. B. Conneliy, Deputy Plant Manager

'K. Woocward, Supervisor of Coerations

'o. V. Fant, Director, Station 0.C.

'R. C. Mayew. Licensing Engineer (Gilbert)

'H. C. Fields, Tecnnical Support Engineer

'B. G. Croley, Assistant Manager Tecnnical Succort

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'K. E. Beale, Emergency Planning Coordinator

'L. A. Blue, Director of Healtn Physics

'W. F. Bacon, Director of Cnemistry

'F. J. Leach, Director of Site Engineering

'H. J. Sef cA. Security Sucervisor

• L. F. Stor*, Assi stant Manager Goerations

'H. I. Donnelly, ISEG Engineer

'5. R. Hunt, QA

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' A. R. Koon, Tecnnical Service Cooroinator l

• S. J. Smith, Assistant Manager Maintenance Service

• V. R. Albert, Assistant Manager - Support Services

• C. M. Counts, Director of Health Physics

'G. A. DiCorts, HP Suoervisor

'R. H. Brockmeier, Consulting Engineer QC

_NRC

• J. Skolds, Senior Resident Inspector

• 0. Matnews, Section Leader DEP, IE:HQ n

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Easec on :ne aoove 'inc ngs, :nis cortion of tne licensee's program acoears to ce aceouate.

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4.2.2 P-otective Ecuicment 4.2.2.1 Resciratory Protection Th's area was reviewed curing :ne acoraisal of June 3-17, 1981 (OIE Report No.

50-395,S1-12).

No ceficiencies or improvement items were icentifiec anc the fincings ind1cated tnat tnis area was complete anc aceouate.

No furtner inscec. ten was concuctec in :nis area.

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4.2.2.2 Drotective Clotninc f

This area was reviewec curing :ne appraisal on June 5-17.1951 (OIE Report No.

,

50-395/SI-12).

No deficiencies or improvement items were icentifiec anc tne fincings incica.ec na: :nis area was comoiete anc aceouate.

No furtner

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inspection was concuctec in this area.

4.2.3 Eme-cency Communication Ecuionen:

The evaluation of tnis program area involvec d4scussions witn licensee representatives, review of recent crocecures; and a pnysical inspection of f acilities anc eouipment.

The inspector reviewed tne procecure EPP-002, Verification of Communications Rev 0, cated Septemoer 11, 1981. and approved on January 8,1982.

Ope-acility, This crocecure prescribes recuirements for cer'ocic testinc and cocumentation of testing of emergency communications eouipment.

The ;:rocecure also accressed recuirements for verification of teleonone numoers listed in tne notification list in EPP-002 on a cuarterly basis. This matter was previously icentifiec as an Ocen item in the previous acoraisai (OIE Report No. 50-395/51-12).

In view of the 'incings notec acove, tnis matter is consicered closed.

The inspector ciscussed the installation of ne NRC HPN system with licensee One HPN dedicated telephone bad been installed at :ne time of representatives.

the acoraisal; nowever, the HPN system had not been installed in tne TSC or EOF as soeci fiec in NUREG-0696. This matter will be folicoed pending ins.a11ation of

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tne HPN at all required locations.

• The inspecto-Observec ::mmunications equipment in ne c:r. trol rocm anc TSC. Tne inspector ciscussec use and operation of communications system with plant operations personnel.

The inscector had no : mments concerning ::mmunications sys.em usage as a result of the interviews.

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Items 50-395/S1-12-29 and 50-395/51-12-30 are c'esec.

4.2.4 Damage Control / Corrective Action

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This area was eviewed during the appraisai :n June E-17,1981 (01E Report No.

50-395/31-12).

No deficiencies or 'morevement items were icentified and the fincings i noic ated that this area,as ccmo'ete and acequate.

No furtner

nducted 'n this area.

c inspect cn

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• a.2.5 Reseeve Emercency Sucolies and Eouiomen Inis area was reviewec curing tne acoraisal on June 5-17, 1931 (OIE Repor: No.

5C-395/S1-12).

No deficiencies or improvement items were icentified anc tne incings incicatec that this area was complete anc aceouate.

No further

'nspection was concucted in tnis area.

4.2.5 Transoortation This area was reviewed curing the appraisal on June 5-17,19S1 (OIE Report No.

50-395/E1-12).

No ceficiencies or improvement items we~e icentified and the

1. incings incicatec that tnis area was complete anc acecuate.

No furtner inspection was concuctec in :nis area.

5.0 D*ocedures 5.1 General Content and Forma of Imolementinc procecures This area was reviewec during the acoraisal of June 1981. Tne resuits of tha:

review were recortec in Office of Inspection anc Enforcement Inscection Recor l

No. 50-395/31-12.

The fincings, as stated in nat report, were, "Except for

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nose specific comments as noted in the following sections, the revised content anc are acce:tacle procecures were consicerec adequate as to form and pending tne final review, accroval, and issuance of the 'molementing procecures."

The necessary implementing procecures nave been approvec anc issuec.

Basec on a review of tne procedures, this area of the licensee's program appears

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Item 50-395/SI-12-31 is closec.

to De acecuate.

l 5.2 Emergency. Alarm and Abnormal Occurrence D-ocecures

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This area was -eviewed during tne appraisal of June, 1931. Tne #incings of that the auditor was review, as statec in OIE Report No. 50-395/SI-12, indicatec :na:

unable to find an establisnec link between EOP anc the Emergency Plan and imolementing crocecures.

References to implementing procedures have now been included in ECP's where appropriate.

Dased on tne above findings, this area of the licensee's program accears t0 be aceauate, anc item 50-395/31-12-32 is closed.

i 5.3 Imole enting* Instructions

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This area was reviewed during the appraisal of June 1931.

At that time

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instructions to the on-cuty shif t, and the IED, were ace througn a Stancing

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Orce-Sook.

The licensee now has appropriate eme*gency procecures. EAL's, and

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ECP's, approved and in place.

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Based on the above findings, this area of the 'icensee's program accears to be

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adequate, and ' tem 50-395/S1-12-33 is closec.

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5.4 Imolemer:ing Procedures

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5.4.1 Notifications

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ne instector ciscussec :ne emergency notification system witn licensee a

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eoresentative anc reviewec relevant procedures.

Licensee procecures related to

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n::i #ications are containec in EPP-001, Activation anc Imolementation of Plan, Rev. O, catec May 20, 1981.

Tne insoector notec :nat this Emergency o-Ocecure nac ceen accrovec oy the plant manager anc reviewec oy tne olant safety res ew ::mmittee on Novemoer 30, 1981. The crocecure was issuec on Decemoer 1, 1951.

During ne walk-tnrougn onase of :ne aporaisal, selected licensee

e-senne' cemonstrated knowlecge of anc worKaoility of tne notification system by

-o:eriy following notification reouirements prescrioed in procecure EPP-001 anc EDD-002.

-ne notica:' on program was reviewed curing :ne appraisal of June 1981 (NRC Recor: No. 50-395/51-12). The fac; na crocecures were not approvec at the time o' :ne acoraisal was consicerec an coen item.

In view of the acove fincings,

nis ma :er is :icsec.

Tne Dualic Natification System (PNS) was completec anc an integratec test of the system oas : ncuctec on January 30, 1982. The system test was reviewed by tne NRC Sent:r Res cent Inspec or at tne site.

Some of the sirens failec to 0:erate crocerly curing ne test of the system and utility management was informec :nat ceficiencies in tne DNS system must be corrected prior to operation above SS-atec power (50-395. 82-03-02).

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5.a.2 Assessment Action The inspector reviewed licensee procedures relevant to dose projections and dicusse: projection methodologies with licensee representatives.

The inspector notec that EDD-005, Of f site Dose Calculations, had seen revisec and had seen

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given formal a:oroval on January S. 1982. The insoector also reviewed EPP-004, i

Out of D'an Surveying. The inspector was toic by licensee representatives nat-evisions were uncerway to revise EPP-004 to incluce provision for fixec anc spreacaole contamination monitoring.

The " Quick Dose Projection" method was discussed with licensee ersonnel.

Licensee representatives indicated that they had withdrawn the " Quick Dose Drojection" method from their procedures. Based on a review of EPD-005 and an evaluation of licensee representatives ability to use the procecure, this area a:: ears ac:ectable.

Consecuently, item No. 50-395/S1-12-34 of the June 1981 apprai sal i s closed.

The inspector ciscussed open item 50-395/S1-12-35 of the June 1981 a era 4 sai oith licensee re:resentatives.

Licensee :ersonnel demonstrated to the inspector inrougn application of procecures EPP-004 and EPP-005 that licensee technical

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ersonnel hac the capability to evaluate surface contamination leveis, deposition

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1. cm a gaseous plume, and to cetermine dose to a receptor submersec in a gaseous

lume. This matter is considerec closed.

A previous item (50-395/81-12-36) concerning the radiciodine to roble gas ratio usec in :ne initial offsite dose projection Orc:ecure was reviewed and c4scussed licensee representatives.

The -atio used by SCE&G during the #ull scale with exercise in April 1981 was 'nc:nsistent with :"e -atto usec by :ne 5:a:e of Sc;:n Carolina Ce:artment of Realth and Envi ormental Control (OHEC).

This inconsistency resulted in significantly ci##eren; iccine dcse projecticns by

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SCE&G anc CHEC anc mace protective action cecisions difficult.

Since sna exercise SCE&G reoresenta: ves me with OHEC anc resolvec :ne dif#erences ex* sting in :ne -esoective cose projection crotecures SCE&G agreec to use

ne EDA recommencec emoirical raciciocine to nocle gas ratio :s coes DHEC in initial cose projections until actual measured data cecomes available.

This matte-i s closed.

5.4.2 I Offsite Raciolooical Surveys reviewed tne two crocecures used by the licensee for offsite The inspector radiological surveys and discussec :ne emergency offsite monitoring program with licensee reoresentatives. Tne crocecures are EPP-004, wnicn cirects raciological surveys outsice One piant in

.ne event of an emergency, and EPo-007, wnich crovices guicance for tne surveying of the environmental monitoring stations curing an emergency.

Two environmental monitoring kits are storec in the Security Annex Bui'cing anc two are currently storec in :ne Health Physics Lab anc will be stored in the EOF wnen that facility is completec. Tne instruments in :ne kits are not cur-ently calibra:ec anc :ne TLDs are not available in :ne kits. These discrecancies are trackec under Section 4.2.1.1.

In Maos are provicec witn envircr.menta' monitoring coints oio::ec for surveys.

EPP-004 tracking tne plume, the teams may te cirectec to :nese or c:ner points.

provides instructions for samoling anc analyzing for iocine anc carticulate concentrations in air. Samole results are proviced to :ne State.nrougn :ne EOF.

Acecuate instruments anc ecuioment are provided in the kits for the teams to l

perform their function.

Tne procecures and forms ma(e orovision for recorcing l

all -ecuirec information. Environmental samples and cartricces are laceled for I

later icentification.

The crotecures co not ma(e provision's for ciscosal of j

survey sneets.

Since the lack of calibratec instruments and TLDs in the Environmental Monitoring is tracked under Section 4.2.1.1 and the kits are crocerly sealec, item Kits 50-395/S1-12-37 is closed.

Easec on the above findings, this portion of the licensee's program a;; ears to De aceouate; newever, the following items should be considered for imorovement:

0-ovisions snould be mace for a central location for the collection of survey records.

Thi< item oas originally icentifiec in CIE hoor: No.

50-395/SI-12 (50-395 SI-12-38).

A backup means of communication shoulo be icentifiec in Orocecure E3P-004

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(50-295/S2-03-03).

5.4.2.2 Onsite (out-of-clan:) Raciolooical Surveys Onsite (out-of-pl ant) radiological surveys oill be :erformec.ith :ne same.

identified in Section 5.4. 2.1 of this report (i.e.,

EPD-004 anc crocedures EPP-007). Cnsite Heal:n Ohysics Tecnnic'ans will make :ne ini-ial rad'oi:gical

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surveys wi nin one mile of ne olant.

Upon :neir arrival a. the site, tne Env--enmenta!

ao Teams take ove-performing tne effsite monitoring. inclucinc surveys witnin tne site ocuncaries.

Base on the above fincings, nis portion of the licensee's program acoears to be acecuate; however the items icentified in Section 5.4.2.1 sncuid oe consicered for improvement.

5.4.2.3 In-clant Radioiccical Surveys The insoector reviewed EPP-003, ne procedure soecifies the metnocs anc ecuioment usec wnen making inolant surveys curing an emergency.

The procecure inciuces a survey recorc wnicn provices for recercing the recuirec usec, iccation of anc results of surveys as well as information or ecuipment other certinent information.

Collectec samoles anc smears are lateled and sent to tne :cunting rocm for analysis.

If excessive background is cresent in the counting -ocm, sa: Dies will ce sent to tne Environmental Lab for analysis.

Survey resu' s aill :e -elayec.o ne TSC via racio. Backuo : mmunications are also ciscussec.

HPP-303 also provices raciation protection anc respiratory crete: tion ;uicance.

Based on tne acove findings, this area of tne licensee's procram actears to oe acecuate.

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5.a.2.4-

.)

5.4.2.5 Dost-Ac:icent D-imary Cociant Samoline anc Analysis The post-accicent primary coolant samoling pro:ecures were reviewec anc evaluatec curing aalk.nrougns. Tne crocecures aere evaluated against tne recuirements of 10CFR50, apoendix E. Paragraph IV.S.. NUREG-0654,Section II. I. and NUREG-0737,Section II.S.3.

The coolant sampling system is totally automated and designec to provice cotn sample anc analysis sitnin 45 minutes.

In tne event of failure of the automated system, a grab samole can be obtained and analy:ed by normal raciccnemical orocedures yielding tne results in less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. The samoling crocedures are covered by Chemistry Operating :-ocedure CHP-903 ahich a;: ears to be scecuate except that tne cneck list is still under develcoment.

Since this samoling system will be used on a caily basis, tne licensee plans to iaminate the procedures in CHP-903 so that one operator can provice directions to a second operator wnile making notes with a grease pencil of comcletec steos.

.

When the automated system is Operating, it is only necessary 0 -e: Orc the

.

results registered. W en a grab sample is taken, eacn analysis is covered uncer separate procecure with its own cata sheet.

The results f-Om either the

!

aaut: mated or grab sample aoproach are recorded on a form attacned to Chemistry-ecedure CHP-614 Quality control, including laceline re:ui-ements #:- samoles, is inciuced in Chemistry 3-::ecure CHP-503.

To be ::mplete, CHP-6'.4, CHP-608, tne procecures #or eacn racic:nemical aralysis, anc the eaitn ;nysics

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o-ecautions fo* nancling nign level and contaminatec samoles snoulc ce referenced

'c H?-903.

-ov'sions for tne automatec cilution of samoles eliminates tne neec for nandling nign level samples with rare exceptions; howeve, in tne event tnat tne analysis

'acoratory becomes a nign radiation area, a cortable, snielcea GeLi system is

.

available.

Also, a cac(up environmental lacoratory is available less tnan 4 m1'es f-om tne site.

Cnemistry Procecure CHP-614 lists the normal distribution of analytical results uncer routine operations.

(Section 6.4.1).

Chemistry Ocerating procecure CHP-903, wnicn covers cotn normal and post-accicent concitions. -ecuires tne immeciate :nanneling of analytical results to tne TSC anc tne Shif t sucervisor after an ac:icent.

The laceratory is cesigned anc aceauate ecuioment is availacie for tne retention of post-accident samples.

Basec on the acove findings, this area of the licensee's orogram accears to ce at:e:taoie; newever tne following snould De consicerec for imorovement:

P-ovice an ope-ator : neck list for tne p*0cecures in CHD-903 anc crovice training for ali personnel wno may be reauired to use tne sampiing system.

Item 50-395/31-12-39 will remain open.

Reference all procedures associated witn sampling, analysis anc :ne health anysics precautions necessary in sampling and analysis under post ac:icent concitions. Item 50-395/81-12-40 will remain open.

5.4.2.6-5.4.2.7 Containment Air Samoline and Analysis The pos.-ac:icent containment air sampling procecures were reviewed; however, a-alk-througn was not performec cecause the eouioment hac not oeen -eleasec for use. The procedures were evaluatec against tne recuirements of 10C R50, Accencix E Paragraph IV.B., NUREG-0654,Section II.I anc NUREG-0737,Section II.B.3.

The containment air sampling system is fully automated witn a monitor to determine the -elative radiation level for the purpose of selectinc accrocriate sample cilution. There are two operating stations allowing selection, according to area radiation levels, under cost-accident conditions.

The licensee has agreec to sce:ify the location of the samole system and the two operating stations in the acclicable Health Physics Procecure HPP-920.

Dilution of tne samples makes it unnecessary to maintain special hancling eouipment, transportation equipment, or analytical cata sheets for hign level samples.

Ho ever, in the event that a nigh level samole is cbtained

.

inadvertently, handling, transcorting and counting epui;. ment are available.

Also, sampling procedure HPP-920 recuires that personnel :arry a nand-held monitor which they are to use for their protection oy evaluating their exposures during the sampling process.

P-ocedure HPP-920 does not address the sampling media, samole 'atel'ng, a-alysis,

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ntamination ::ntrol or incluce.ne analytical -esults sheets, al' of nhicn are

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r. ainec in ::ne-cccuments.

Tne licensee nas agree: to incluce these e:ui ements cy -eference.

re samoling syste-and analyttcal procecures are designec to provice the

~

mpietec analytical -esults in less tnen one nour from tne samoling time.

In tre event tna: :ne anarytical i acoratory cecomes a hign -aciation area, a 00-taole GeLi system witn snielcing is availacie anc a cackuo environmental

'a: oratory is locate: less than a miles from tne site.

Since tre system is not comolete anc training in this area nac not been conductec a -al(-:n cugn couic not ce cerformed. Items 50-395/SI-12-41 anc 50-395/81-12-42,

ncerning sam:iing and analysis of containment atmoschere, are considerec a ce'iciency in ne emergency crecarecness crogram.

5.2.2.8 Dost-Accicent Stack Effluent Samoling inis area oas eviewec curing the appraisal of June 1981.

The results of tne review ee e -ep;rtec in OIE Inspection Report No. 50-395/SI-12.

Tne fincing in was :nat at tne time. -he licensee's program could not ce acoraised.

ne -eccr The -eac 0* building curge exnaust monitor (RMA-14) anc the nign range main plan; vent meritor (;MA *.3) are used for post-accicent stack effluent sampling.

Sotn of :nese mani crs reac out i n mR/hr in :ne controi room and at a location close to tne monitors.

Tne monitors have no sample points and tnerefore are not s ecifically accressec in the samole procecure HPP-510.

Samoles of gaseous ef fluents f rc= otner monitors (RM-Al thru 12) are accressec in HPP-510.

This crocedure identifies tne step Dy step metnod for sampling at the sample point.

Sampling coints and locations for post-accicent samples are the same as normal

'

coeration anc a-e icentifiec in :ne procedures.

Samples are to be lateled anc collection start anc stoo times recorded.

Accorcing to a

licensee-eoresentative, curing accicent conditions, samples are to De taken in accordance with EPP-003.

This procedure provices guicance in :ne area of radiological safety wnile taking samoles in :ne event of an emergency.

The procecure coes not specifically accress the methods used for taking tne samples. Ine above metionec procedures dic not reference one another; however during an emergency both cro:ecures would De utilized.

This cru on of the licensee's program appears to De acecuate; nowever, the following should ce consicered for improvement:

Reference sneu:0ece made in HPP-SIO to EPD-003 and vice versa.

Item 50-395/51-12-13 ill remain Open as an improvement item.

5.a.2.9 os -Accicent Stack Effluen: Samoling Analysis

.

This area was revieaed during the appraisal of June 1951. The results of that review were reported in OIE Inspection Report No. EC-395/51-12.

Tne 'incings 'n the report was that at the time, the licensee's program could not be acoraisec (50-395/cl-12-44)

Dest-ac:':ent gaseous effluent samoling analysis is performed 'n accordance oi:n 6 0-505, Sam la Analysis.

The procecure orovices guicance for sacole precarat'en and sam:le analysis for normal and acc' dent sample : nditions. The procecure

.

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acceesses limits anc crecautions for racioactive samoies; nowevee, it coes not accress octen.ially nign racica :ive samoles anc measures o De usec for analy:ing sucn sampies. Samoles are lacelec anc recorcs are (eo: for all samples analy:ec.

Basec on :ne above findings. this area of *ne licensee's orogram accears to be a::ectacle; however tne following snould De consicerec for improvemen*:

Accress measures *o be usec wnen analy:4ng cotentially hign racicactive samples. Item 50-395/SI-12-aa will remain coen.

5.a.2.10 Liou4d Effluent Samoling inis area was reviewed during :ne acoraisal of June 1981.

The results of tna:

review were recortec in OIE Inspe : ion Recor: No. 50-395/SI-12.

Tne fincings in tne recort statec that the licensee's crogram could not De aporaisec (50-395/31-12-45).

ost-ac:icen licuia effluent samoles are ta(en in accorcance witn HPD-S10, Sampiing of Racioactive 3ases and Licuics anc EPP-003, In :lan-Radiological

!

Surveying. HPP-510 crovices step-by-steo instru:: ions for taking licuid ef fluent samples.

Sampling points and locations for cost-accicent samoles are tne same as d

in normal operation and are identifiec in :ne procecures.

Samoles are to be laceled anc collection start and 5.00 times recorced. According to a licensee representative, during accident concitions. samoies are to be taken in accorcance with EPP-003.

This procedure provices guidance in :ne area of radiological safety while taking samoles in the event of an emergency. The crocedure coes not specifically accress the methocs used for taming the samoles.

The above mentioned procecures co not reference one anoiner; newever, curing an emergency both procecures would ce utilized.

Based on the aoove findings, this portion of the licensee's program accears to be

acecuate; newever

.ne following shouic ce consicerec for improvement.

'

Reference should be mace in HPP-310 to EPP-003 and vice versa.

Item 50-395/SI-12-45 will remain open, j

5.4.2.11 Liouid Ef fluent Samoling Analysis This area was reviewec curing the acoraisal of June 1981.

The results of that review were re:orted in 0IE Inspection Report No. 50-395/SI-12.

The fincing in the report stated that at the time, the licensee's program coulc no: De aopraised (50-395/31-12-26).

.

Post-accident liquic effluent analysis is performed in ac:creance to HPD-308, Sample Analysis.

The procedure provides guidance for samole preparation and sample analysis for normal and acci:ent sample condi-ions.

Dost-acticent licuid effluent sample analysis will be carried out in the same manner as normal sample analysis.

The procedure acdresses limits and precautions for racioactive samples. Samples are laDeled anc -ecords are kept of all samples analy:ed.

Based on.he above findiags, :nis area of the 14:ensee's :rogram accears to be acceptable.

I.em 50-395/S1-12-46 i s closed.

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5.4.2.12 Raciciocical Envi-onmentai Moni:nrino Prcoram

'nis area was reviewec curing tne acoraisai on June S-17 1981 (OIE Recor No.

50-395/S1-12).

No ceficiencies or improvement items were icentifie anc :ne

'incings indicatec that tnis area was complete anc acecuate.

No furtner inscection was conducted in this area.

5.4.3 Protective Actions

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5.4.3.1 Radiation Protection During Emergencies Radiation protection curing emergenc'es was evaluatec against tne recuirements of

'

10C:R50.47(o)(11). and selec:ec criteria in NUREG-0654,Section II.K.

Inis area was reviewee curing tne acoraisal of June 1981.

The resul s of :nat-eview were recor:ed in OIE Inspection Recor: No. 50-395/S1-12 anc incicatec four fincings.

Procecure HPD-505 ahich ceals with ne Control anc Issuance of Personnel Dosimetry has oeen completec. reviewec anc accroved oy ne licensee, Item 50-395/31-12-47 is closec.

!

The Health Chysics Manual wnicn ceals with provisions for scecial centrois to be imolemented for emergency concitions is still in Draft Form.

Item 50-395/51-12-45 remains open as an improvement item.

,

The licensee has ourchasec additional self-contained breathing cevices in sufficient cuantity such that when comoinec witn tne adcitional air tanks on hand tne heal:n pnysics cersonnel woulc nave acecuate creatning e:uipment to -escond to any emergency. Decontamination facilities have also oeen exoanced along oi n accing acditional nealth anysics cersonnel. Item 50-395/S1-12-49 is closed.

)

]

P*ocedures cescribing now anc by whom all health physics functions will be i

performed along with the prioriti:ing of those functions during emergency situations nave not yet been ceveloped.

In accition, the Health Physics Manual, wnich will also refer to tnese requirements, is still in draft form.

Item 50-395/SI-12-50 remains open.

5.4.3.2 Evacuation of Owner Controlled Area t

i This area was reveewec curing the acoraisal of June 1981.

The findings of. hat i

review, as stated in 0IE Recort No. 5C-395/S1-12, found that the crocedure aere adecuate pending final review, aporoval, and issuance of tne imolementing

procedures (50-395/81-12-31).

Imolementing Procedures E??-001, 308, 012, have

.

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been approved and issued.

This a-ea of the licensees program accears to be acequate.

Item 50-395/51-12-31

!

is closed.

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5.4.3.3 Dersonnel Accountability i

!

This area was rev iewed during the a:praisal of June 1981.

The "ndings of.nat

!

eview, as stated in OIE Reccet No. 50-395/51-12, f ounc. hat the peccedures cic

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not orovice for continuous accountacility after ne initial accountability nas oeen complete:.

Security furtner indicatec tnat an aux'liary Access Portal is to me installec at tne :onstruction ac:ess gate. anc :nat accitional comouter facilities are to be instailec to complete the computer controlled accountability system.

It acoears tnat a signal comoatability problem exists between existing care reacers anc tne crocosec system. Until nis problem is resolvec tne cacge count is accomolisnec manually.

Discussion with Security personnel incicated that continuous accountability of emergency personnel remaining onsite after an evacuation is accomolishee manually oy tne emergency suoervisor of eacn component of tne emergency resconse organi:ation.

Items 50-395/SI-12-51 and 50-395/S1-09-09 will remain coen as a orogram ceficiency cending satisfactory imolementation of a mecnanism for positive accountability of all individuals on site within 30 minutes, anc :ne accountacility capacility has been demonstrated.

5.4.3.a Personnel Monitorino anc Decontamination Procecures APD-708 EPP-010, anc HPP-405 were reviewec and tne program was discussec witn licensee representatives.

APP-703 requires monitoring of all individuals exiting :cntaminated areas, anc

,

EPP-010 establishes requirements for personnel and vehicle monitoring at the assemoly and reassemoly areas.

EPD-010, Attacnment I, provices for recording all recuirec information.

Contamination levels that recuire decontamination are speci f'ed i n EDP-010.

Initial personnel monitoring will take olace upon exiting contaminated areas anc near the inolant cecontamination area.

Initial decontamination may De cone at the Cecontamination f acility as specified by HPP-405.

Further monitoring and cecontamination can also be done at the Security Annex, tne EOF anc :ne reassembly areas.

!

Since procedures are now available for personnel contamination monitcring curing

'

a site evacuation, item 50-395/SI-12-52 is closed.

Based on the aoove findings, this portion of the licensee's program aopears to be l

ace:uate.

5.4.3.5 Onsite First-Aic Rescue

.

The methods for receiving, recovering, transoorting and hancling injured persons C9, On-Si e Vedical, who may also be contaminatec are specified primarily in E?D-:

t and also in EPP-010 and EPP-011.

The lead medically trainec person makes the recommendation to the Emergency Director for offsite mecical assistance.

A Healtn Physics representative will accompany the injured oerscn to the hosoital j

if tne injured oerson is contaminated. Some supplies and e:uic.ent are l istec in

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tre r0cecu e ;0 De tasen in :ne amoulance.

A kit is provicec for use in tne ar uiance. cut 's not ciscussec in :ne procecure.

Raciation protection guicance is provicec for the team in Procecure EPD-010.

Basec On the acove findings, this portion of tne licensee's orogram accears to be aceouate; nowever :ne following item snould De consicered for improvement:

E00-009 snoulc ce changec to incluce taking tne :irst Aid Room Amouiance Raciation Emergency Kit i n tne amouiance wnen tne patient is transpor:ec to ne noscital (50-395/S2-03-Oc)

5.a.4 Security Ourine Emercencies This area was eviewec curing the aporaisal of June 1951. The findings of that review, as stated in OIE Report No. 50-395/31-12. found that this area accearec aceauate ;ending fina' review, approvai. anc issuance of implementing procecures anc :ne staticr security procecures.

Tne i mp 'tementing rocecures nave been accrovec and issuec.

Tne security

-ocecures nave Deen accrovec (except SPP 114, wnicn was in the final stage of acor: val) anc oil' oe implementec witn the security plan on scnecule for fuel cac.

Basec on the aceve 'incings, tnis area of :ne 'icensees program appears to De

.

acecuate anc 50-395,31-12-53 i s closed.

5.4.5 Reca'

'Co-ective Ac:fons Recair'cor-ec 've actions we-e revienec for the criteria of NUREG-Oc54 Section II.K.

Inis area -es -eviewed curing tne appraisal of June, 1981.

Tne results of inat evieo ae-e -e:orted in CIE Inspection Recort No. 50-395/81-12.

Procecure EPD-020 provices the guicelines for re entry into the plant areas to effect eoair'::rrective actions witn regarc to establishing exoosure I'mits anc cose projecticas of such teams.

Eased on the a:ove findings, tnis portion of the liceasee's program accears to be

acecuate.

5.a.6 Rec 0very RecSe y :-Oce:ures were reviewed for the repuirements of 10CFR50.17(b)(13),

.

ICC.:R5C appendix E, Paragraph IV.H, and the criteria of NUREG-0654 Section II.M.

This area was -eviewed during the appraisal of June,1931. The results of that review oere reportec in OIE Insoecticn Report No 50-395/51-12. The fincings, as stated in that report, were acceotaole pending the final':stion and implementation of tne c:rcorate e ergency plan and -ec:very prccedu-es.

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5e:: on 5.a of Oroce:ure EDo-017 ceais wi n recove y coerations anc organization nas ceen eviewec anc accroved oy licensee management. This cortion of tne ani t censee's crogram accears to be aceouate; nowever, tne corocrate emergency management pian is still in craft form Item 50-395/51-12-54 is consicered a ceficiency in :ne emergency orepare: ness program.

5.4.7 public Informat.on This area was reviewee curing the appraisal on June 5-17, 1981 (OIE Report NO.

50-395/51-12).

No ceficiencies or improvement items were icentified anc the fincings indicated that this area was complete anc aceouate.

No furtner

,

inspection was :oncutted in tnis area.

'

5.5 Sucolementary Procedures 5.5.1 Inventory. Coerational Chec( anc Calioration of Eme-cency Ecuiomer.t.

ac' ities and Sucoiles Ine insce: or -eviewec Procecure EPD-019 and inventories, 'ns ectec eme gency kits anc ecuipment and discussed emergency facilities and ecui ment witn licensee representatives.

The procecure crovices a specific inventory of ecuicment reserved for emergencies

anc specifies :ne location of the eouipment.

Inventory, operational cnec( and Portable calicration frecuencies are specified in :ne ;rocecure anc attacnments.

communications equipment to be used by the emergency teams is not incluced in thi s crocecure.

Basec on the a:ove findings, tnis portion of :ne licensee's program accears to De aceouate; newever ne following item snoulc te consi:erec for incrovement:

Communications eouipment to be usec by tne emergency teams snoulc ce includec in EPP-019 (50-395/S2-03-05).

5.5.2 Drit's anc Exercises The licensee's program for drills and exercises was -eviewec w th respect to the i

recuirements to 10C FR50. 47( b)( 14), 10CFR50, Appencix E. Paragraon IV.F. and criteria in NUREG-0654,Section II.N.

Drocedure EPD-019 is a licensee accroved crocecure arc was available for review at :ne time of the appraisal. The licensee has con ucted an exercise anc several crills which were reviewed along with their eesce::ive scenarios anc i

criticues in ac:orcance with EPP-018.

Dis:ussions were he'

eith tne station

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emergency coordinator as well as n'i t h the energency lann'ng 00crdirator in

'

reference to the exercise, drills, critic;es, and manage ent :cmmitments to resolve any resulting 14 censee icentifiec items, ealth Physics drills are : nduc.ed on a semi-annual basis. Vedical res nse and u-adio'ogical onitoring drills are conducted annually.

C:mmunication crills are

!

concuc ed :uar erly anile fire br'gade : rills are c:rcuc;ec :nce ea:n : car:er # 0r j

each shif t.

f an actual event occurs, tne -es:cnse to that even: 's no:

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consicerec a crill even nougn tne response is criticuec. Tne news mecia are not usually involvec as players in plant crills out were incorocrated in :ne plant exe-cise anc tne cril' of April 14, 1981 wnen :ne EOF was activatec. Drills an; exercises are discussed furtner in Section 7.1 of this recort.

Basec on the above fincings, this portion of the licensee's program apoears to be acecute. Item 50-395/51-12-55 is closec.

5.5.3 Review. Rev'sion anc Distribution of Emergency Plan anc Procecures inis area was reviewed during tne appraisai on June S-17,1981 (OIE Report No.

50-395/SI-12).

No ceficiencies or improvement items were icentified anc the Ancings incicatec tnat this area was complete and acecuate.

No further inscection was concucted in this area.

5.5.a Aucits of Emergency Precarecness Tne eview of tne audit program for emergency crecarecness consisted of a review of ne latest revision of :ne Ouclity Assurance Plan, review of auci recorcs, anc discussions with licensee anc contractor personnel.

In carticular. tne inspector reviewed Section 3.7 entitled "Incecencent Aucits" of ne SCE&G Operational Quality Assurance Plan, Rev. S. catec Decemoer 31, 1951, This section of :ne plan indicated tnat audits of the emergency pian requirements anc related implementing procecures would oe conducted at least once every twelve montns.

Tne inspector reviewed the results of audit No. II-50-81 conducted by the licensee on :ne emergency precarecness program.

The audit was concucted on Decemoer 1-2, 1981.

Proolems identified oy the licensee auditor representatives relatec to communication eauipment repairs at the ECC anc cocumentation control procecures. Tne inspector cic not see written indication of acknowiecgement of audit findings by the af fected group; however, licensee -epresentatives having resconsibility in the emergency preparecness area stated they were aware of tne findings and that corrective action were being taken to resolve the proclem.

Based on the above findings, this area of the 'icensees program accears to te acceptable. Item 50-395/31-12-56 is closec.

6.0 Cocedication witn Offsite agencies 6.1 Offsite Agencies This area was -eviewed during the aporaisal on June 3-17, 1981 (OIE Recor No.

50-395/31-12).

No deficienc'es or improvement items were 'centifiec anc the

-

findings indicatec that this area nas ccmp'ete and acecuate.

No further inspection was c:ncucted in this area.

6.2 General Public This area was reviewed during the Aoorai sal of June '_981.

he results of that review indicated that provisions for cisem'nating emergency infor ation to

,

transients who :ay be present witnin the 10 mile E?Z oere not complete.

The licensee has completed in'stallation of signs at ecreation areas witnin the EPZ

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2d actions to ce taken in :ne event of an emergency at tne exclaining emergency Information crocnures nave oeen cistrioutec to motels in tne general plant.

7ne-e are no motels or otner transient facilities other inan cay use a-ea.

rec-eation areas, witnin :ne 10 mile EPZ.

!

Sasec on the aoove findings, item 50-395/S1-12-57 is closec.

'

6.3 News Mecia This area was reviewed curing tne appraisal on June 8-17, 1981 (OIE Report No.

50-395/SI-12).

No deficiencies or imorovement items were icentifiec and

'incings incicatec that this area was complete anc acecuate.

No further insoection was concucted in this area.

7.0 Drills. Exercises anc Walk-Throuchs 7.1 program Imolementation The 'icensee's imolementation of c-ills anc exercises was reviewed with respect

'

10C.R50. Apoencix E paragrapn IV F.

anc

te -eauirements of 10CFR50. 47(b)( 14),

Criteria in NUREG-0654,Section II N.

This area was reviewec during tne Aporaisal of June 1981.

The results of that were recortec in OIE Inspection Report 50-395/S1-12.

The fincings, as review statec in nat recort, were that this area of the licensee's program hac not been formally imolemented because the procedures were still in craf t form.

The licensee has concuctec a series of crills (3/31/S1; 4/14/S1; ?/2S/S1) to evaluate and improve the resoonse capabilities of Health Physics anc tne Fire Brigace along witn medical anc security response in preparation for the eme gency exercise.

A full-scale exercise was conducted on May 1, 1931 (IE Report No. 50-395/51-09).

Suosecuent Health Physics crills have been conductec Tne information cata and learning exoeriences obtainec from tne by the licensee, exercises and drills were incorporated into the Emergency Precaredness Program.

The exercise and suosequent drills recuirec by the recently establisnec Emergency Plan anc Procecures have been conducted in accordance with procedures found in EPP-015.

The licensee's experiences pertaining to the drills and exercise were reviewec and discussed with the Station Emergency Coorcinator.

Criticues of ne exercise anc drills nave :een written by the licensee with corrective actions and followuo activities being taken on licensee icentified items.

Ocmplete anc total esolution of tnese items appears to have management attention.

Sased on the above findings, this portion of the licensee's orogram a;; ears to be

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acecuate. Item 50-395/81-12-53 's closed.

7.2 Walk-Through Cbservations This area was reviewed during the Aopraisal of June 1981. The esuits of that f

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review eere reported in DIE Insoection Report No. 50-395/31-12.

~he 'incings, as stated in that report, were inat the overall acceptability of the area Of l

walk-through coservations could not be determinec at that time since many p ant

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systems were in:cmolete. ecuicment was not in operation anc procecures were not imolemente:. Wais ~nrougn ooservations were concucted in the ceiow listec areas anc oe-e consice ee aceouate. Item 50-395/S1-12-59 is closec.

Emercency Detection. Classification and Noti #ications a.

Walk-througns were conductec in tne area of Emergency Detection.

Classification anc Notifications.

Tne incivicuals interviewee were SCE&G Controi Room Coerators, Ocerator Foremen and Shift Supervisors.

These eersonnel accear to have a gooc uncerstanding of the implementing procedures (EDo-001; E?P-002: EPP-005) anc were coserved and talkec walKec through

neir actions af ter ceing given a set of simulated ac:icent parameters.

Inn s area accearec to be acecuate.

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Dose Assessmen:

Ine aucitors concuctec interviews with operations shift personnel in the of offsite cose calculations.

The incividuals were familiar with area E-C05, o#f site cose calculations and coulc cuic(iy and efficiently perform l

ne manual cose calculation. This area accears to De aceouate.

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Dost Acc' cent Samoline and Analysis

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a The.'alk inrough in the post accident coolant samoling and analysis system demonstrated that ne automatec equipment and facilities are cacable of provicing coth sample and analyses within one nour, and tnat th.: tnrce hour criteria can be met for grab samples.

The Chemical Scecialist uno oe-formed the tasx possesses a comprehensive knowiecge of tne system anc adecuate skills; newever, the licensee indicatec that no other individuals nave completed the training anc this function will normally be performec cy two coerowcrs.

Training was being conducted in this area ~at the time of :ne aporaisal and will be completed for all chemistry cersonnei involvec in post acticent coolant samoling by Feoruary 22. 1982.

Training in :nis area is discussec in paragraph 5.4.2.4 c.

Offsite Environmental Samolina and Analysis Six Health Ohysics Specialist were tested on their ability to use Procedure EP -00c to determine airborne radiciodine anc carticulate concentrations onen given tne samole net count rate anc the total air flow

nrough :ne ai r sampier. The problems we-e to be solved by using the graons attacnec to :ne procecure, then by calculetion using cata provided'in the procedure.

There were some proolems in using the grachs and a few significant errors were made in the calculations.

The individuals making

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the errors were able to recognize those errors and correct them.

In addition, the Health Physics personnel at the TSC or EOF shoulc be atle to recogni:e significant monitoring errors and orovide assistance to the monitoring teams.

Based on the aoove fincings, this portion of,he licensee's program accears to be adecuate; hcwever tne following item snould be considered for improvement:

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use of

"eal n Dhysics Scec'alists should te giver. more training in

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- ra:ns anc a formula crevicec in :ne a-ocecure for :aiculatinc. aircorne rac3ciocine anc particulate :encentra:icns in :ne event ne: count rates and air sameie-total flows are off :ne main scale c'

ne graons (50-395,82-03-06).

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