ML15224A525
| ML15224A525 | |
| Person / Time | |
|---|---|
| Site: | Oconee |
| Issue date: | 12/24/1981 |
| From: | Jenkins G, Kevern T, Marston R, Mcfarland C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15224A526 | List: |
| References | |
| 50-269-81-13, 50-270-81-13, 50-287-81-13, NUDOCS 8206070645 | |
| Download: ML15224A525 (44) | |
See also: IR 05000269/1981013
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION 1l
101 MARIETTA ST., N.W., SUITE 3100
ATLANTA, GEORGIA 30303
Report No. 50-269/81-13
50-270/81-13
50-287/81-13
Licensee: Duke Power Company
P.O. Box 2178
Charlotte, NC
28242
Facility Name: Oconee Nuclear Station
Docket Nos.
50-269, 270, and 287
License Nos.
DPR-38, 47, and 55
Appraisal at the Oconee site near Seneca, SC.
Inspectors:
T. A. Kevern (Team Leader)
Date Signed
R. R. Marston
Date
igned
C. R. McFarland
Date Signed
Accompanying Personnel:
Clark, E. E. Hickey, J. Fairobent, B. Pickett
Approved by:
. R.
kins, Section Chief, EPOS Division
Date Signed
Summary
Inspection on August 24 - September 3, 1981
Areas Inspected
This special announced appraisal involved 445 inspector hours on site in the
performance of an Emergency Preparedness Appraisal.
Results
In the areas inspected, no violations or deviations were identified. Significant
appraisal deficiencies were identified in one area:
Post-Accident sampling
capability (Section 5.4.2.4).
E306 07 0 64 5 08520100259
PDR ADOCK 050026
Q820670645
pDR
TABLE OF CONTENTS
INTRODUCTION
DETAILS
1.0 Administration
2.0
Emergency Organization
2.1
Onsite Organization
2.2 Augmentation of On-Site Emergency Organization
3.0 Training/Retraining
3.1
Program Established
3.2
Program Implementation
4.0
Emergency Facilities and Equipment
4.1
Emergency Facilities
4.1.1 Assessment Facilities
4.1.1.1 Control Room
4.1.1.2 Technical Support Center (TSC)
4.1.1.3 Operations Support Center (OSC)
4.1.1.4 Emergency Operations Facility (EOF)
4.1.1.5 Post-Accident Coolant Sampling and Analysis
4.1.1.6 Post-Accident Containment Air Sampling and Analysis
4.1.1.7 Post-Accident Gas and Particulate Effluent
Sampling and Analysis
4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis
4.1.1.9 Offsite Laboratory Facilities
4.1.2 Protective Facilities
4.1.2.1 Assembly/Reassembly Areas
4.1.2.2 Medical Treatment Facilities
4.1.2.3 Decontamination Facilities
4.1.3 Expanded Support Facilities
4.1.4 News Center
4.2
Emergency Equipment
0
TABLE OF CONTENTS (Continued)
4.2.1 Assessment Equipment
4.2.1.1 Emergency Kits and Emergency Survey
Instrumentation
4.2.1.2 Area and Process Radiation Monitors
4.2.1..3
Non-Radiation Process Monitors
4.2.1.4 Meteorological Instrumentation
4.2.2 Protective Equipment
4.2.2.1 Respiratory Protection
4.2.2.2 Protective Clothing
4.2.3 Emergency Communications Equipment
4.2.4 Damage Control/Corrective Action and Maintenance
Equipment and Supplies
4.2.5 Reserve Emergency Supplies and Equipment
4.2.6 Transportation
5.0
Procedures
5.1 General Content and Format
5.2
Emergency, Alarm and Abnormal Occurence Procedures
5.3
Implementing Instructions
5.4
Implementing Procedures
5.4.1 Notifications
5.4.2 Assessment Actions
5.4.2.1 Offsite Radiological Surveys
5.4.2.2 Onsite (Out-of-Plant) Radiological
Surveys
5.4.2.3 In-plant Radiological Surveys
5.4.2.4 Primary Coolant Sampling
5.4.2.5 Primary Coolant Sample Analysis
5.4.2.6 Containment Air Sampling
5.4.2.7 Containment Air Sample Analysis
5.4.2.8 Stack Effluent Sampling
5.4.2.9 Stack Effluent Sample Analysis
5.4.2.10 Liquid Effluent Sampling
5.4.2.11 Liquid Effluent Sample Analysis
5.4.2.12 Radiological and Environmental Monitoring
Program (REMP)
5.4.3 Protective Action
5.4.3.1 Radiation Protection During Emergencies
5.4.3.2 Evacuation of Owner Controlled Areas
TABLE OF CONTENTS (Continued)
5.4.3.3 Personnel Accountability
5.4.3.4 Personnel Monitoring and Decontamination
5.4.3.5 Onsite First Aid/Search and Rescue
5.4.4 Security During Emergencies
5.4.5 Repair/Corrective Actions
5.4.6 Recovery
5.4.7 Public Information
5.5 Supplementary Procedures
5.5..1 Inventory, Operational Check and Calibration of
Emergency Equipment, Facilities, and Supplies
5.5.2 Drills and Exercises
5.5.3 Review, Revision and Distribution
5.5.4 Audit of Emergency Preparedness
6.0 Coordination with Offsite Groups
6.1 Offsite Agencies
6.2 General Public
6.3
News Media
7.0 Drills, Exercises and Walk-Throughs
7.1
Program Implementation
7.2 Walk-Through Observation
8.0
Persons Contacted
8.1
Licensee Personnel
8.2 Other Organizations
8.3 NRC
0II
INTRODUCTION
The purpose of this special appraisal was to perform a comprehensive evaluation
of the licensee's emergency preparedness program. This appraisal included an
evaluation of the adequacy and effectiveness of areas for which explicit regu
latory requirements may not currently exist. The appraisal effort was directed
towards evaluating the licensee's capability and performance rather than the
identification of specific items of noncompliance.
The appraisal scope and findings were summarized on September 3, 1981, with those
persons indicated in Section 8.0 of this report.
DETAILS
1.0 Administration (Responsibility, Authority, Coordination, Qualification
Criteria)
The responsibility for emergency planning associated with the Duke Power Company
nuclear stations has been formally assigned to the Emergency Response Coordi
nator. This individual reports directly to,
and is a staff assistant of the
manager,
Nuclear Production Division.
The
Emergency
Response Coordinator's
responsibilities include corporate emergency plans and procedures, interrela
tionships with Federal
and State agencies,
coordination of each station's
emergency planning,
and assuring that exercises and drills are conducted and
documented.
The responsibility for emergency planning at the Oconee Nuclear Station has been
formally assigned to the Emergency Preparedness Coordinator, who reports to the
Station Manager via the Licensing and Projects Engineer and the Superintendent of
Technical Services. The Emergency Preparedness Coordinator's responsibilities
include the station emergency plan and implementing procedures, interrelation
ships with local offsite agencies and organizations, coordination of exercises
and drills, and coordination of emergency preparedness training for both station
personnel and offsite support agencies/organizations. These responsibilities are
delineated in the Emergency Preparedness Coordinator's specific position
description.
The aspects of emergency planning are the primary duties and
responsibilities of this individual.
The auditor noted that station management
and staff personnel are familiar with the identity and duties and responsi
bilities of the Emergency Preparedness Coordinator. The auditor noted that the
Emergency
Preparedness Coordinator does not report directly to the Station
Manager, but that the Emergency Preparedness Coordinator does interface directly
with the Station Manager in the performance of her duties and responsibilities
and does have the full support of the Station Manager.
Discussions with licensee representatives indicated that adequate coordination
and cooperation exist between the corporate staff and station staff in the area
of emergency planning and that emergency planning receives adequate visibility
and management support at both the corporate and station levels.
Discussions
with individuals of various offsite agencies/organization
indicated that
adequate coordination exists with these groups (See Section 6.0).
Both the Emergency Response Coordinator and the Emergency Preparedness Coordi
nator have been formally selected and designated to provide expertise in various
disciplines that the licensee considers important in emergency planning.
The
auditor noted that a specific position description existed for the Emergency
Preparedness Coordinator and a draft position description for the Emergency
Response Coordinator.
The existing position
description
identified
the
responsibilities of the position and the criteria for selection.
2
Discussions with the Emergency Response Coordinator and the Emergency Prepared
ness Coordinator indicated that the individuals possessed an understanding of
the principles involved in developing plans and procedures and had experience in
emergency planning. Discussions with licensee management indicated that these
individuals were selected for their positions according to specific criteria
established by management and that professional training is planned for these
individuals.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
2.0 Emergency Organization
2.1 Onsite Organization
Both an initial onshift and an augmented emergency response organization have
been established and are discussed in Section 5.2 of the station emergency plan.
Table 5.0-1 of the plan identifies, by position or area of expertise, the onshift
and augmented personnel responsible for the major functional areas of emergency
response. Station Directive 2.9.2, Emergency Response Organization and Training,
describes the augmented emergency response organization, identifies organiza
tional divisions and the respective responsibilities for functional areas of
.
emergency response, and identifies supervisory individuals, by title, and their
respective responsibilities. The management structure for the functional areas
of emergency response is well-defined.
In an emergency situation, the shift supervisor assumes the duties of Emergency
Coordinator until the arrival of the Station Manager or a designated alternate.
The Emergency Coordinator has the authority and responsibility to initiate any
emergency actions within the provisions of the station emergency plan, including
protective action recommendations to authorities responsible for coordinating
offsite protective actions. A line of succession for the Emergency Coordinator
position and other management positions in the emergency organization has been
developed. The emergency organization is quite similar to the normal station
organization, i.e.
individuals are assigned emergency response responsibilities
commensurate with their normal areas of responsibility.
Station Directive 2.9.2 clearly defines the onsite emergency response organi
zation. Discussions with licensee representatives indicated that all aspects of
the emergency response organization are understood.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
2.2 Augmentation of Onsite Emergency Organization
SThe station emergency organization is augmented by personnel from the corporate
staff located in Charlotte, NC.
These personnel form the Crisis Management Center
(Emergency Operations Facility). This organization is briefly described in the
3
station emergency plan and is fully detailed in the Crisis Management Plan
(corporate emergency plan) and associated implementing procedures.
The Crisis
Management Plan
identifies the
positions, functional descriptions,
and
individuals by name which make
up this organization.
The organization has
capability in all areas applicable to an emergency.
The functions to be per
formed by the indivduals in this organization are similar to the respective
funtions performed by these individuals in the normal licensee organization.
The
Crisis Management organization is directed by the Recovery Manager (Manager,
Nuclear Production Division), who has the overall authority for the management of
and recovery from the emergency. The licensee has provisions for continuous
operation of this organization for a protracted period.
Based upon discussions with licensee representatives and observation of an
emergency exercise, it appears that timely augmentation of the onsite organi
zation can be accomplished and that the Crisis Management organization would
provide support in the requested areas. The auditor reviewed the corporate and
station emergency plans and discussed the roles of and interfaces between the
onsite and Crisis Management organizations with licensee management.
It was
noted that the authority, responsibility and interfaces of these organizations
are clearly defined and understood.
Additional assistance in coping with emergencies would be provided by the NSSS
vendor and INPO. Support by local agencies/organizations for services such as
medical,
ambulance,
firefighting and law enforcement has been arranged and
letters of agreement are included in the station emergency plan.
A review of the
emergency plan and discussions with licensee representatives and representatives
of the agencies/organizations indicated that interfaces between the licensee and
these support groups are established and understood.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
3.0
Emergency Plan Training/Retraining
3.1 Program Established
The status of the emergency plan training and retraining program was reviewed and
discussed with licensee representatives, including the EP Coordinator and the
Training and Safety Coordinator, who are primarily responsible for emergency
organization training onsite. In general,
the training requirements for the
emergency response organization are contained in the Oconee Emergency Plan,
Section 8.1.1 and written to support Station Directive (SD)
3.8.5
Emergency
Procedures and SD 2.9.2 Emergency Response Organization and Training.
These
documents provide for initial specialized and annual refresher training for those
individuals who may be assigned to the onsite emergency organization.
In
addition, all permanent employees at the station are provided emergency plan
O
training on an annual basis. Offsite, non-licensee groups, for which letters of
agreement exist for support during an emergency,
have been provided emergency
plan training which included a site orientation, access procedures, radiological
protective measures
and coordination of support activities with licensee
representatives.
0
0
4
Initial training for all designated emergency organization personnel and for
non-essential personnel has been completed by licensee training personnel and the
Emergency Preparedness Coordinator.
The Administrative Policy Manual
Section 2.5 provides basic requirements for
training operations personnel.
The Nuclear Station Training Plan dated June 3,
1974 has provided the requirements for training for the routine programs; this
plan is currently being upgraded.
The implementing procedures for the emergency planning work has recently been
upgraded and Station Directive 2.9.2 Emergency Response Organization and Training
provides for the training and annual retraining of all identified participants
and the documentation of the training. The onsite station personnel include the
fire brigade members who would be required to fight all onsite fires.
The
offsite, local fire department personnel have been trained to fight fires under
radiological conditions inside the owner controlled area that is outside the
protected area. Training is also provided for the medical support agencies, the
law enforcement agencies and the local government officials. SD 2.9.2 provides
for training objectives, format, frequency and the outline of the training to be
provided for the various participants for the emergency response program.
The
training documentation does not provide for qualification and requalification of
instructors.
This need has also been recognized by the routine operations
inspection program of the NRC
(and
by an audit by INPO in May 1981)
and a
corrective action program is being developed by the licensee.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
3.2 Program Implementation
The emergency preparedness training programs as provided by the EP, the IPs and
SDs 2.9.2 and 3.8.5 were reviewed for implementation.
The general training
program is in place and functioning for both the onsite and offsite participants.
A sampling of current onsite EP training appears to be adequate; however,
the
mechanism to ensure retraining of all personnel for EP responsibilities is not
yet in place.
The site training program does not include the personnel assigned to Crisis
Management Center (CMC).
The CMC staff are included in the training program for
the corporate headquarters.
The offsite radiological monitoring teams
are
directed by the CMC
once the CMC is activated. The Offsite Radiological Coor
dinator (ORC) would move from the TSC to the CMC when the CMC is activated and
assumes control of this function.
The ORC has participated in two drills with
the CMS.
Based on the above findings this area of the licensee's program appears to be
.
acceptable; however, the following item should be considered for improvement:
Ensure retraining for EP participants (50-269,
270, 287/81-13-01).
5
4.0 Emergency Facilities and Equipment
4.1
Emergency Facilities
4.1.1 Assessment Facilities
4.1.1.1 Control Room (CR)
The control rooms are located on the fifth floor of the Auxiliary Building; Units
1 and 2 share a common CR and the Unit 3 CR is separate. Each CR has a complete
set of emergency plans and procedures, station directives, technical specifica
tions and appropriate drawings as specified in the Plan.
Common readouts are
readily available for appropriate area and process radiation monitors,
non-radiological monitors and meterorological parameters.
Communication pro
visions between the units and to other facilities are available as described in
the Plan, i.e., separate phones to the NRC and to the NRC Health Physics network,
microwave communications to corporate facilities in Charlotte, NC.
and other Duke
Nuclear facilities, the
Oconee plant system,
the telecopier
system,
the
commercial Southern Bell
system
and three radio base stations as further
described in Section 4.2.3 of this report.
Procedures relative to the initial determination of emergency actions,
the
emergency action levels (EAL),
the protective action guides (PAG),
response
actions and evacuation of station personnel are included in the plan.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.1.1.2 Technical Suport Center (TSC)
The TSCs are adjacent to each of the two CRs on elevation 822 of the Auxiliary
Building providing ready access between the personnel in the TSC and the CR.
Working space in the TSC for assigned personnel
is available.
Data displays,
records and communications are accessible. Radiation shielding and ventilation
system considerations are comparable to the CR. Telephones are available to be
switched to serve the needs of the TSC upon activation of the TSC as described in
the Plan.
The
upon activation for an emergency will be staffed,
in
accordance with the Emergency Plan, to provide engineering design and technical
review capabilities as well as plant operating performance evaluations. In the
event that the Plan is activated during off-duty hours, personnel to staff the
are called in by normal
telephone communications.
Reference materials,
including the Technical Specifications, Operating Procedures, FSAR, drawings and
schematics, Plant Status Boards, a Dose Projection Status Board area Maps, county
and State REPs, and supplies are stored in the TSC. Additional drawings are to
be stored in the emergency cabinets when the cabinet space can be rearranged.
The emergency Plan and procedures will be brought to the TSC by the Emergency
. Preparedness Coordinator upon activation of the TSC. Radio communication between
the TSC
and the field monitoring
teams
is
available.
(This
function is
transferred to the CMC/EOF when the CMC is activated.)
6
Based on the above findings, this area of the licensee' s.program appears to be
acceptable.
4.1.1.3 Operations Support Center (OSC)
The OSCs are adjacent to each of the two CRs on elevation 822 of the Auxiliary
Building as stated in the Plan.
The OSCs are large enough to accommodate more
than the number of persons assigned to the OSC (including the space for assem
bling HP and special teams.). Primary and backup voice communication systems are
provided between the OSCs,
TSCs,
and CRs.
Radiation shielding and ventilation
system considerations are comparable to the CRs. The two OSCs are available to
be the backup locations in the event the primary facility becomes uninhabitable.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.1.1.4 Emergency Operations Facility (EOF)
The nearsite Crisis Management Center (CMC) is located offsite, but adjacent to
the station at the Oconee Training Center as described in the Plan.
All
emergency and recovery activities are to be directed from this center with
emphasis on coordinating all offsite activities when an emergency is classified
as a Site or General
Emergency.
The County Emergency Operations Centers in
Walhalla,
SC and Pickens,
SC (or the Oconee County Law Enforcement Center in
Walhalla,
SC) will be available as an alternate EOF(s).
The CMC provides adequate
space for the assigned personnel.
The CMC
is equipped with emergency radio
logical equipment as stated in the Plan and in procedure HP/O/B/1009/01 Emergency
Equipment Operation/Inventory Check. The communications equipment is available
as stated in the Plan and is able to be switched over to meet the needs of the
Plan, including the needs for NRC,
ENS,
and HPN extensions.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.1.1.5 Post-Accident Coolant Sampling and Analysis
The auditor interviewed the Station Chemist, Nuclear Chemistry Specialists (NCS),
and Nuclear Chemistry Technicians (NCT), concerning postaccident reactor coolant
sampling.
The licensee has performed a design and operational review of post
accident reactor coolant sampling.
Duke Power Company
has designed and is
currently installing, in Unit 1, a remote sampling hood that will allow a post
accident reactor coolant sample to be taken that appears to be in accordance with
NUREG-0737 guidelines and is "as low as reasonably achievable" (ALARA).
The Unit
2 and 3 sampling systems will be installed during subsequent outages.
Until the installation of the sample hoods are completed,
ONS plans to utilize
the existing sampling points and sampling equipment.
At this time,
a post
accident primary coolant sample could be taken, but with the postulated high
activity level of the coolant running through the sample lines, the technicians
7
taking the sample would be exposed to very high levels of radiation. This would
result in a high man-rem exposure for taking the sample.
It appears that the
licensee has not taken steps to determine what radiation fields the technicians
would be passing through and standing in while taking the sample. According to
the procedure for post-accident (liquid) sampling, calculations of postulated
dose rates of various volumes of reactor sample have been
made as well as
estimated times to perform required tasks. At the time of an accident it will be
determined how many technicians will be required to take a post-accident reactor
coolant sample. No modifications of the present system have been made.
According to the licensee, the reactor coolant sampling lines are shielded as,
much as possible; however, even during normal operations, the sample lines which
run along some hallways cause high background.
It is possible that during and
accident the sample rooms and nearby hallways will be inaccessible.
A pres
surized sample can only be taken if there is reactor coolant letdown.
A lead pig
has been designed and constructed to be used in transporting the sample.
Special
handling tools are being considered for handling the highly radioactive sample.
The sampling area is monitored by a permanently installed alarming detector and
Health Physics will be involved in the preplanning of taking a post-accident
sample. With the exception of boron analysis, no special equipment or procedures
have been developed for analyzing the coolant samples.
In addition, there are no
accident procedures for diluting the primary coolant sample.
If
the sample can be taken,
sample measurement and analysis can be performed
within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following item should be considered for improvement:
Provide for taking a postaccident reactor sample under accident conditions.
Provide special sampling equipment,
including remote tongs and install
shielding as appropriate at the primary coolant sample point to facilitate
the sampling of reactor coolant during an emergency while maintaining
radiation exposures as low
as
reasonably
achievable
(50-269, 270,
287/81-13-02).
4.1.1.6 Post-Accident Containment Air Sampling and Analysis
The auditor discussed postaccident containment air sampling and analysis with the
Health Physics Support Function Coordinator and other members of the health
physics organization.
The post-accident reactor air sampling equipment
is
located in the Purge Equipment Room and is the same equipment and location as the
normal plant operation sampling system for containment air.
The containment air sampling system has no special shielding or other modifi
cations for accident situations.
In addition,
sample location may not be
accessible during an emergency due to high radiation fields.
8
Discussion with licensee representatives indicated that shielded containers were
available for use in transporting the sample.
Some remote handling tools are
available for use in transporting the sample;
however,
if
more tools were
necessary for the specific accident situation, a tool would be made at the time
of the accident.
The health physics personnel indicated that portable radiation monitoring would
include use of an Eberline PIC-6A instrument and air samples would also be taken.
Appropriate protective clothing, dosimetry and respiratory equipment will be worn
when samples are taken.
The post-accident containment air samples will be taken back to the count room for
analysis.
If the count room is uninhabitable or the background is too high,
instrumentation will be moved to a location in the administration building. If
movement of the necessary equipment is not possible, the samples will be counted
in the Emergency Count Room which is being constructed in the Visitors Center.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following item should be considered for improvement:
Provisions should be made such that a containment air sample can be taken
under accident conditions.
Shielding and/or modifications should be made
such that radiation doses received by the personnel taking the samples are
ALARA (50-269, 270, 287/81-13-03).
4.1.1.7 Post-Accident Gas and Particulate Effluent Sampling and Analysis
The auditor discussed post-accident gas and particulate effluent sampling and
analysis with the Health Physics Support Functions Coordinator and other members
of the health physics organization.
Comments and conclusions made in Section
4.1.1.6 Post-Accident Containment Air Sampling and Analysis also apply to this
section (50-269, 270, 287/81-13-04).
4.1.1.8 Post-Accident Liquid Effluent Sampling and Analysis
The auditors discussed liquid effluent sampling with the Health Physics Support
Functions Coordinator, with respect to potential high activity in plant liquid
systems that must be sampled prior to transfer of the liquid or release to the
environment. No special modification or procedures have been prepared for post
accident liquid effluent sampling. The procedure used for taking liquid effluent
samples is HP/0/B/1000/60/C, Procedure for Sampling and Release Requirements for
CTT,
CMT, and LHST.
The location of the liquid effluent sampling area appears to be accessible under
accident conditions. The primary sample analysis facility might not be accessi
ble under some accident conditions; however,
an Emergency Count Room is being
.
constructed in the basement of the Visitors Center and will be utilized during an
emergency.
9
No special precautions are taken to reduce radiation exposure during accident
conditions.
There are no special equipment, tools or shielded transport containers identified
as being used during an accident.
Based on the above findings, the licensee's program appears to be acceptable;
however, the following item should be considered for improvement:
Special equipment,
tools and
shielded transport containers
should be
identified and health physics support in exposure -control
should be
addressed (50-269,
270, 287/81-13-05).
4.1.1.9 Offsite Laboratory Facilities
Offsite laboratory support is provided by the Environmental Laboratory located
near the McGuire Nuclear Station.
Driving time from Oconee to McGuire is
approximately 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. Instruments are routinely calibrated and maintained for
use in the environmental program and would be readily available for immediate use
during an emergency. The licensee is in the process of establishing a backup
laboratory facility at the Oconee Visitors Center. Equipment has been purchased
for installation into this backup facility. Additionally, contingency plans have
been developed by Health Physics for the removal of analysis and calibration
equipment from the site in an emergency.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
The program will be significantly improved upon completion of the
backup laboratory at the Visitors Center.
4.1.2 Protective Facilities
4.1.2.1 Assembly/Reassembly Areas
Upon hearing the Site Assembly Alarm, all personnel,
except those working in
Radiation Control Areas,
assemble with their supervisors at their designated
assembly locations and wait for additional instructions.
Persons working in
Radiation Control Areas in protective clothing leave their work areas and go to
the change room and contact the appropriate persons for personnel accountability
reporting. Judgement is used concerning the advisability of changing clothes and
reporting to normal assembly areas.
The assembly locations are used exclusively for accountability. If radiological
conditions exist that warrant the evacuation of the site,
the Emergency
Coordinator will direct personnel to be relocated offsite to one of two possible
alternate assembly areas as per procedure AP/O/A/1000/10, Emergency Evacuation of
Station Personnel, and Station Directive 2.9.1, Station Assembly and Evacuation.
.
One offsite assembly area is established at Keeowee School, to the west of the
site, and the second is proposed to be at Daniel High School, to the southeast.
10
These areas are large enough to handle the number of persons expected from the
site and will be provided with emergency kits for decontamination purposes. The
offsite assembly areas will be used for decontamination and for releasing site
personnel.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following items should be considered for improvement:
Provide assurance that both offsite assembly areas will be available and
accessible (i.e. that keys are provided, etc.) (50-269,
270, 287/81-13-06).
Provide the emergency kits at the offsite assembly areas (50-269,
270,
287/81-13-07).
4.1.2.2 Medical Treatment Facilities
Section 7.5 of the Emergency Plan describes the medical treatment area.
The
First Aid Room described by the Emergency Plan as being located in the Admini
stration Building, is now in the trailer area across the access road.
A nurse is
on duty at this facility during normal
day shift duty hours.
The room is
equipped with a treatment table and other medical equipment and supplies.
During
back shifts and on weekends, first aid is provided by trained station personnel
using station first aid kits.
A second First Aid Room is located in the Radiation Control Area near the Unit 2
Health Physics operations area and is
used for treatment of injuries where
radioactive contamination may be present. A contamination survey instrument is
available in the room. Shower and sink facilities are available for decontamina
tion.
Since the room is
unlocked and is
normally unoccupied,
the medical
supplies are locked in a cabinet.
Two stretchers are located in the room in
addition to a backboard and a scoop type stretcher.
The auditor noted that
stretchers and first aid kits were available at various locations in the plant.
Station Directive 5.1.3 provides procedures to be followed in case of personal
injury.
A bioassay facility is used to determine if personnel have inhaled or ingested
radioactive materials, or if such materials have been absorbed through the skin
or entered wounds. A body-burden analyzer and a thyroid-burden analyzer are
located in the Administration Building and liquid scintillation counting
facilities for tritium analysis are available in the Health Physics Counting
Room.
Emergency dosimetry is provided by Health Physics.
Potassium Iodide supplies are
stocked by Health Physics and issued in accordance with procedure HP/0/B/1009/12.
Based on the above findings, this area of the licensee's program appears to be
.
acceptable.
11
4.1.2.3 Decontamination Facilities
Section 6.5.2 of the Emergency Plan describes the decontamination facilities
available on site.
Station Directive 2.9.1, Station Assembly and Evacuation
Procedures, provides a limited procedure for decontamination of personnel and
vehicles during evacuation.
A draft procedure HP/O/A/1009/23,
Procedure For
Emergency Decontamination Of Personnel And Vehicles On Site And From Offsite
Remote Assembly Area, provides more detailed procedures for decontamination of
personnel and vehicles during evacuation from the plant and at the offsite
assembly areas. An agreement is in effect for the use of Keowee High School as
an assembly and decontamination point. The auditor noted that a storage cabinet
has been ordered for the decontamination supplies to be stored at the high
school, but the decontamination kits are not yet in place. A written agreement
has not yet been received for the use of the other offsite assembly and
decontamination point, Daniel High School.
Station Directive 3.8.18 provides
guidelines
for personnel
decontamination.
HP Procedure Guide No.11-11,
Decontamination, is provided
in the Emergency Kits maintained
by the HP
organization at the Station and the Visitors Center.
Routine decontamination can be performed at the Hot Change Rooms and at the First
Aid Room in the Radiation Control Area.
.
The auditor was advised by a licensee representative that, in the event of an
evacuation, personnel would normally be decontaminated at the Security Exit area.
A prepositioned decontamination kit is not in this area, however, since all the
supplies are available from the Supply Room which is accessible 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day.
A list of required materials for decontamination has not been established. The
auditor believes that a list of materials for decontamination should be made to
ensure that adequate supplies are drawn when needed.
When decontamination is required, solid waste will be placed in cans or bags.
Health Physics has determined that any liquid waste which is not contained will
be diluted to within regulatory limits.
Based on-the above findings, this area of the licensee's program appears to be
acceptable; however, the following items should be considered for improvement:
Secure written agreement for use of Daniel High School (or other facility
East of Station)
as
offsite decontamination location (50-269, 270,
287/81-13-08).
Stock decontamination kits at the offsite decontamination locations (50-269,
270, 287/81-13-09).
Establish a list of supplies to be drawn from the station Supply Room in the
event onsite decontamination is required during evacuation (50-269,
270,
.
287/81-13-10).
12
4.1.3 Expanded Support Facilities
Offices are provided for NSSS, Babcock & Wilcox Co.
(B&W),
representatives in the
Technical Support Center (TSC). A telephone is assigned to B&W in the TSC.
A
dedicated line to the B&W home office has been installed.
Normal
telephone
service is provided to the B&W onsite offices for the B&W staff assigned to
ONS.
The auditor noted that the licensee is the A/E for the Oconee station.
During emergencies,
additional assistance can be obtained from the INPO,
as
stated in the INPO Resources Manual.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.1.4 News Center
Provisions have been made for a primary news center at the nearsite Visitors
Center and
an alternate
news center at the Jervey Field House,
Clemson
University. The auditors reviewed the primary news center facility and discussed
news facilities and equipment/provisions with licensee representatives.
The
primary news center provisions include:
Telephone service, electric supply to carry added load, copying equipment,
PA system, audio-visual equipment, and security such as media lodging and
crowd control.
Accommodations for the expected number of media representatives.
Based on the above findings, this area of the licensees program appears to be
acceptable.
4.2
Emergency Equipment
4.2.1 Assessment Equipment
4.2.1.1
Emergency Kits and Emergency Survey Instrumentation
Emergency kits and Emergency Survey Instrumentation are discussed briefly in
Section 7.3.2 and 7.3.3 of the Emergency
Plan.
Prepositioned supplies and
equipment are located at specified points for use in emergencies.
The Environmental Organization maintains emergency kits and supplies in the
Environmental
Lab in accordance with Procedure CP/O/B/4003/01.
The auditor
examined the storage area and inventoried the items stored outside the cases. A
case was selected at random from the six and was inventoried. Inventories were
conducted in accordance with Enclosure 5.3 of the Procedure.
All items listed
were contained in the case and were operable.
Instruments were found to have
current calibrations.
13
The instruments, sampling systems,
and operational procedures were reviewed to
ensure the capability of measuring the required minimum detectable activities.
The SAM-2 instrument with RD-22 detector is used to determine iodine concentra
tions and the E-120 with HP-210 G-M detector is used to measure dose rates.
The Health Physics Organization uses normal plant Health Physics instruments and
equipment for emergency in-plant surveys. An emergency kit for in-plant surveys
is maintained in the Visitors Center.
The kit is inventoried and checked in
accordance with Procedure HP/O/B/1009/08. A complete inventory was conducted in
accordance with Enclosure 5.2 of the Procedure. All items listed were found to
be on hand. All instruments were in current calibration and operable.
The
equipment and operational procedure were determined to be adequate to ensure the
capability of measuring the required minimum detectable activities.
The Health Physics Organization also maintains emergency kits in the Control Room
areas for each TSC,
an emergency kit in the Visitors Center for CMC use and an
emergency kit at the Oconee Memorial Hospital which contain protective and
decontamination supplies.
The kits are maintained, inventoried, and checked in
accordance with Procedure HP/O/B/1009/01.
The kit maintained in the Visitors
Center was inventoried and determined to be complete. Instruments were operable
and in current calibration.
Kit contents were determined to be adequate for
- their intended use.
It was determined that the Environmental and Health Physics Organizations have
procedures for the calibration of all emergency instruments and air samplers.
All instruments and air samplers examined were noted to have current calibrations
and inventories and checks were observed to be current.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.2.1.2 Area and Process Radiation Monitors
Area and Process Radiation Monitors are described in the Emergency Plan, Section
4.5.1. All area and process radiation monitor readouts specified in Accident
Assessment Procedures are available in the Control Rooms with the exception of
RIA-18 (located in the Visitors Center)
and 1RIA54 and 3RIA54 (which monitor
Turbine Bay sumps and are located in the Turbine Building). The readout points
are expected to be accessible under accident conditions.
The sensors are shielded where required to minimize the effects of background
radiation. Source checks are performed on a quarterly basis and the monitors are
calibrated annually across their respective ranges using an electronic pulser.
The HP organization conducts an annual correlation of the instrument readings by
evaluating process samples in accordance with Procedure HP/O/B/1000/60F.
The three Reactor Building Entrance Area Monitors go off scale above 30 R/hr.
These readings are used for initial source term calculation for potential
releases and do not have adequate range to cover the more significant releases.
14
Coverage of higher releases is currently provided by the use of portable
instruments and new high-range monitors are planned to be installed during
scheduled outages.
Readouts are provided so that each Control
Room has accessibility to those
readouts applicable to its unit and important readouts of the other two units.
A sample of check and calibration procedures were reviewed for the systems.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.2.1.3 Non-Radiation Process Monitors
The non-radiation process monitors described in the Emergency Plan as being
necessary for emergency detection, classification and assessment, such as reactor
coolant system pressure .and temperature, liquid levels, containment pressure and
temperature,
flow rates, fire detection equipment and meteorology instrumenta
tion, had readouts located in the combined Unit 1 Unit 2 control room and were
operable. The seismic monitor had annunciators in the Control
Room with the
monitor equipment located in the Reactor Buildings and the Auxiliary Building.
Assessment of a safe shutdown event (0.1g)
can be confirmed by a standard
operating procedure. Assessments of events greater than 0.5 must be performed
offsite by Kinemetrics, the equipment manufacturer.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.2.1.4 Meteorological Instrumentation
The plant is located in an area of complex topography,
and local airflow char
acteristics are difficult to describe. Two meteorological towers are used to
provide information on local atmospheric transport and diffusion conditions.
The
primary tower is located on a hill 20-30 m in height,
about 275 m west
north-west of the reactor complex. Meteorological sensors are mounted along the
west edge of the tower. Wind speed and wind direction sensors are about 1 m
above the upper-most tower girder.
Temperature sensors at 10 m and 45 m, used to
determine vertical temperature gradient as an indicator of atmospheric stability,
are mounted on booms about 1.5 m from the western vertical support of the tower
and oriented downwards towards the surface. The tower is surrounded by trees of
about 15-20 m in height. A secondary tower is located along the Keowee River
below the dam, east of the reactor complex. The base elevation of this tower is
about 60 m below the base elevation of the primary tower and about 40 m below the
grade of the reactor complex. Wind speed and wind direction are measured at the
10 m elevation of this tower.
.
Measurements from the primary meteorological tower provide the basic parameters
(i.e., wind speed, wind direction,
and atmospheric stability).
Meteorological
data from the primary tower were used as bases for the staff evaluation of
15
atmospheric dispersion conditions during the Operating License review. Because
of concern about interference from the tall trees, wind speeds from the 46 m
level were reduced to 80% of the measured speeds for the staff's evaluation.
Actual measured speeds,
with no reduction,
are used by the licensee in the
implementing procedures of the emergency plan. The licensee should document the
representativeness of measurements made on the primary tower, considering general
airflow characteristics, airflow at the reactor complex, interference by trees
surrounding the tower,
and possible interference
by the tower structure.
Measurements from the river tower are used in the emergency plan to better
characterize plume transport during nocturnal gravity airflow conditions. Strip
charts on standard recorders are used to display the following meteorological
data in the control rooms: wind speed and wind direction from the 45 m level of
the primary tower; temperature difference between the 10 m and 45 m levels of
the primary tower; and, wind speed and wind direction from the 10 m level of the
river tower. Because of the location of the displays of meteorological data
behind the main control room instrument panels for the reactor, the licensee
considers the displays to be accessible to both the control
room and the
Calibration of the meteorological measurements system is performed quarterly by
personnel from the licensee's offices in Charlotte,
N.C.
Maintenance
and
emergency replacement of sensors and recorders is also performed by personnel
from the Charlotte office. Repair of a damaged component is normally accom
plished within 24-to 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of notification. The licensee is considering using
onsite personnel for maintenance of the system at some future date.
Routine
operability checks and replacement of strip charts are performed weekly by onsite
staff. Control room operators check the strip charts daily as an operability
check of the system. The weekly strip charts are sent to the Charlotte office
where a meteorologist performs a check of the reasonableness of the information.
The calibration and maintenance
procedures and operability checks appear
adequate; however, the written procedures for calibration and maintenance should
be reviewed by the staff.
Also, the licensee should provide historical data
recovery and a history of major instrument malfunctions,
including cause and
corrective action.
The licensee is planning to install the NOAA weather wire to receive information
about severe weather in the area. The licensee has proposed to obtain offsite
meteorological data from the National Weather Service Station at Greenville
Spartanburg airport, located about 60 miles from the plant.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following items should be considered for improvement:
Justify that the offsite source of meteorological data is considered repre
sentative of the Oconee site (50-269,
270, 287/81-13-11).
Justify the use of unmodified wind speed and wind direction data from the 46
meter level of the primary tower, considering regional airflow character
istics, the location of the tower on a hill overlooking the reactor complex,
16
interference of airflow by tall trees surrounding the tower,
and possible
interference of airflow caused by the massiveness of the tower structure
(50-269, 270, 287/81-13-12).
Installation of a system to make severe weather information available to
control room operators (50-269, 270, 287/81-13-13)
4.2.2 Protective Equipment
4.2.2.1 Respiratory Protection
The licensee has Scott Air Paks located in various places throughout the plant
including the Unit 1, 2, and 3 control rooms, the Unit 1, 2, and 3 Fire Brigade
Storage Rooms, the Nurse's office, the Waste Management Facility and the Station
Respiratory Facility. Respiratory Equipment is not available in the OSC or TSC
but could be accessed from the station Respiratory Facility if
needed in.these
locations. There are a total of 31 Scott Air Paks on site with 26 reserved for
emergency use.
There are approximately 60 spare bottles with better than 20
minute capability. There is capability for refilling the bottles onsite and a
decontamination facility is available to clean and decontaminate the equipment.
This equipment is useable in high airborne areas.
O Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.2.2.2 Protective Clothing
The auditor observed that protective clothing reserved for emergency use is
stored in Warehouse #6.
Over 400 pairs of cotton coveralls and over 500 pairs of
disposable coveralls are kept in the store room.
The coveralls stored in the
change rooms would be used before accessing the emergency store of clothing.
The
protective clothing maintained appears to be adequate for initial and continuing
response to an accident.
The stores of protective clothing would likely be
accessible under emergency conditions.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.2.3 Emergency Communications Equipment
The Emergency Communications Systems are described in the Emergency Plan, Section
7.2.
Communications Systems and Operations are further described in Procedures
CP/O/B/4003/03,
Radio
Operations
Maintenances
and
Communications,
and
PT/O/B/2000/04, Procedure for Quarterly Inspection of Emergency Equipment and
Supplies in the Technical Support Center
During an emergency, internal station communications are accomplished through
commercial telephone, station telephone, public address system, and a station and
security radio network.
17
External station communication is accomplished through Commercial telephone, the
Duke Power microwave system,
two way radios, and dedicated NRC lines (HPN
and
ENS). The communications are available in the Control Room TSC areas and in the
Crisis Management Center (CMC).
TSC Telephones are kept in the TSC emergency cabinet and plugged into terminals
which are pulled down from above ceiling panels in the TSC.
The same system is
used in the CMC.
The ceiling panels are not marked to show which ones provide
access to the telephone terminals; this could result in delay in locating the
terminals.
The telephone system in the TSC is set up to assign the individuals manning the
TSC the same plant extension numbers that they are assigned in their offices for
routine use.
Procedure PT/O/B/2000/04, Enclosure 13.2, provides the procedure
for switching the telephone lines from the office telephone to the TSC. However,
the procedure does not assign responsibility for making the switch.
Mechanical Maintenance uses the Mechanical Maintenance Shop for an OSC during an
emergency. There are two plant telephones available in the shop, and there are
five telephones available in the adjacent supervisors'
offices.
The OSC for
Units 1 and 2 is located in the kitchen area adjacent to the Unit 2 Control Room.
There is one plant telephone in this area.
The Unit 3 OSC consists of a room with one plant telephone adjacent to the
Control Room. Plant Engineers will operate from their offices near the Control
Room, but these offices are not radiologically protected. If the offices become
uninhabitable or more OSC space is needed, the Unit 1 and 2 OSC will be used.
Information on plant emergency alarms is presented in the inital employee HP,
Emergency, and Security Training and Retraining. The four plant alarms are (1)
Area Radiation Monitor, (2) Reactor Building Evacuation, (3) Site Assembly, and
(4) Site Evacuation. Notification of a fire is provided over the Public Address
System.
The operation of emergency communications is checked during drills and exercises
and some problems have been discovered.
A check of the records of drills on
March 25,
1980 and June 10,
1980 showed problems with the PA System.
A drill
conducted on September 28, 1980 revealed Paging System Problems and Fire Brigade
Communications Problems. An Exercise on February 27, 1981 showed blind spots in
the Auxiliary Building in the Radio System used by the Fire Brigade. A drill on
June 30, 1981 showed Radio System problems and VAX system problems.
Procedure PT/0/B/2000/04, Section 12.1.1 requires an operational check of TSC
Telephone
Communications
System
equipment each quarter.
The Procedure was
approved on August 20, 1981,
so the program has not yet been implemented.
In addition to the multiple communications systems available in the Control
Room/TSC areas and in the Crisis Management Center, a backup system is available
in case of failure of any one communications link between two points.
18
If plant power fails, there are power lines coming into the plant from two other
power generating stations.
It
is
planned to have diesel generator power
available by late 1983.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following items should be considered for improvement:
Communications problems discovered during drills and exercises should be
evaluated and resolved (50-269,
270, 287/81-13-14).
Ceiling panels in the TSC and CMC should be marked to show the location of
emergency telephone plugs (50-269,
270, 287/81-13-15).
Complete operational checks of emergency communications as required by
Procedure PT/O/B/2000/04, Section 12.1.1 (50-269,
270, 287/81-13-16).
Posters should be installed in the plant describing the plant emergency
signals and required actions.
This information is provided in annual
training, but emergency signals may be confused without occasional reminders
(50-269, 270, 287/81-13-17).
4.2.4 Damage Control/Corrective Action and Maintance Equipment and Supplies
The Emergency Plan provides for personnel
and material for damage control,
corrective action and maintenance. Existing administrative and work procedures
are to be followed, but expedited, during an emergency. Functional positions in
the emergency organization are identified with the responsibility for providing
supplies of spare parts, equipment and supplies. Existing maintenance equipment
and supplies were reviewed and are considered adequate.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
4.2.5 Reserve Emergency Supplies and Equipment
Supplies of reserve equipment are available from the onsite warehouse facilities.
The inventory is maintained with a maximum and minimum range noted for each
category. A computerized inventory system is in effect to monitor inventories of
all components at Oconee and within the Duke Power system, including Catawba and
McGuire Nuclear Stations. All inventoried items within the Duke Power system use
a uniform identification code so that identical components at different stations
will have the same I.D. number and can be located quickly. The inventories are
routinely audited and supplies of emergency equipment are rotated annually.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
0
19
4.2.6 Transportation
No vehicles are exclusively set aside for supporting emergency program needs.
Company vehicles are made available to the Field Monitoring Coordinator in the
event of an emergency.
Seven (7) vehicles are identified in the procedures to
equip six (6) field monitoring teams, and numerous other vehicles are available
onsite.
Keys for the vehicles can be obtained from security or from the Field
Monitoring Coordinator. Several of the vehicles are equipped with four-wheel
drive
and several
can
be
equipped with dc-ac power inverters if
needed.
Ambulances,
if
needed,
are provided by the Oconee Memorial Hospital.
A heli
copter can be provided from Inland Airways (Greenville,
SC),
during daylight
hours and adequate flying weather, within three hours.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.0 Emergency Implementing Procedures
5.1 General Content and Format
The auditors reviewed the recently revised procedures which implement the Oconee
Emergency Plan with respect to their content and format and discussed the pro
cedures with licensee representatives. Overall these procedures were found to be
adequate regarding the assigned responsibility for each area, prerequisites and
conditions modifying specified actions, references to related procedures and
guidelines for specific actions to be taken relative to the emergency action
levels and accident classification. Except for those specific comments noted in
the following sections, the procedures are considered adequate as to form and
content.
The procedures utilized to implement the Emergency Plan are not specifically
identified/titled as implementing procedures.
Rather, special administrative,
chemistry, health physics, calibration, and test procedures and special station
directives have been developed which collectively implement the Emergency Plan.
However,
in reviewing the procedures the auditors noted that titles of various
procedures which implement the Emergency Plan do not clearly identify the
contents of the procedure.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however the following item should be considered for improvement:
Title procedures such that the scope and content are clearly identified
(50-269, 270, 287/81-13-18).
5.2
Emergency, Alarm and Abnormal Occurrence Procedures
.
The station emergency operating procedures were reviewed and the areas of
abnormal and emergency operations were discussed with licensee representatives.
20
Emergency procedures have been developed for emergency and abnormal conditions
which define the steps the station operators are to take in order to mitigate or
respond to the emergency situation.
Additional procedures have been developed
which implement the
Emergency
Plan.
(See
Section 5.1).
Specifically the
AP/O/A/1000 series of procedures provide for the emergency detection (i.e., EAL
recognition) and classification of the emergency situation. The administrative
organization and the training program establish that, in the event of an
emergency,
plant operators and supervisors utilize emergency
procedures in
operation of the plant and the Shift Supervisor utilizes the AP/0/A/1000 series
procedures in accomplishing the station response to the emergency. There are no
cross-references between the emergency procedures and APs; however, the auditors
determined that the station's training program for Shift Supervisors and plant
operators adequately identifies the .scope, applicability and responsibility for
use of the two categories of procedures.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.3 Implementing Instructions
The Emergency Plan implementing procedures include a procedure for each class of
.
emergency specified in the emergency plan (AP/0/A/1000/02-05). These procedures
identify the various Emergency Action Levels (EALs)
associated with each class of
emergency and specify the actions to be considered or implemented for each
emergency class. The procedures are written for use by the Emergency Coordinator
(initially the Shift Supervisor) and orchestrate the implementation of addi
tional , more specific procedures which have been developed to implement the
Station Directive 2.9.2 identifies the emergency response
organization and clearly defines the scope of authority and responsibility vested
in the Emergency Coordinator as well as the duties and responsibilities of other
members of the emergency response organization.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.4 Implementing Procedures
5.4.1 Notifications
The auditor reviewed applicable sections of the Emergency Plan and implementing
procedures: AP/0/A/1000/01,
Initial Determination of Emergency Action
(Event
Index),
AP/0/A/1000/02 Emergency Action Level
(EAL)
Unusual
Event,
AP/0/A/
1000/03,
Emergency Action Level (EAL)
Alert, AP/0/A/1000/04,
Emergency Action
Level (EAL)
Site Area Emergency,
AP/0/A/1000/05,
Emergency Action Level
(EAL)
General Emergency,
AP/0/A/1000/06, Initiating Protective Action Guides for the
. General Public in the Emergency Planning Zone,
SD 2.9.2,
Emergency
Response
Organization and Training,
PT/0/B/2000/04,
Quaterly Inspection of Emergency
Equipment and Supplies in the Technical Support Center.
21
For each class of emergency there is
a specified list of individuals and
agencies/organizations to notify and the sequence for notification to alert,
mobilize, or augment the onsite emergency organization and supporting agencies/
organizations. Immediate notifications are the responsibility of the Emergency
Coordinator and are incdrporated in the "immediate
action steps"
of AP/0/A/
1000/02, 03, 04, 05, and 06.
Equipment to be used for notification is specified
and includes ring-down,
onsite and
commercial
telephone systems.
Alarms,
announcements,
and pre-formated messages (included in AP/0/A/1000/02,
03, 04,
and 05) are used for initial notifications. Telephone numbers for the required
notifications are contained in an enclosure to PT/O/B/2000/04.
Authentication of
the initial notifications to State and Local agencies is accomplished by the
respective agency.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.4.2 Assessment Actions
The assessment program is described in the Emergency Plan, Section 6.2.
If an
accident or emergency occurs at the station, the station emergency organization
.
continuously monitors changing station parameters which may affect the emergency
classification and the decisions implementing specific emergency measures.
In
addition, surveys may be required.
The station and area parameters may be monitored by:
surveillance of control
room instrumentation,
in-station radiological surveys, site and site-boundary
surveys, and Environs survey.
Initial evaluation of the accident emergency is done in accordance with procedure
AP/0/A/1000/01, Initial Determination of Emergency Action Level.
This procedure
provides for initial classification of the event and reference to other proce
dures in the AP/0/A/1000 series which provide instructions for controlling the
accident/
emergency and information for escalation or de-escalation of the
classification and response.
Procedures AP/0/A/1000/02 through AP/O/A/1000/05 specify that if the possibility
of an offsite dose exists and a qualified Health Physics Supervisor is not avail
able,
an offsite dose calculation will be done in accordance with Station
Directive 3.8.5, Offsite Dose Calculation.
Station Directive 3.8.5 provides a
four-hour dose projection using a Reactor Building Area Monitor reading or, if
the Area Monitor is off scale, a portable instrument reading taken near a fixed
spot at the Reactor Building Wall.
The instrument readings are used to classify
the release to the Reactor Building Atmosphere as a Design Basis Accident, a Gap
Activity Release, or a release of no offsite significance. Monitor readings and
meteorological data are then used to select and correct the appropriate Time
Distance Dose Curves. Applicable protective action recommendations are then made
to the offsite authorities.
Accident assumptions used in Station Directive 3.8.5
are specified in Attachment 8 of the directive.
22
The Field (Environmental)
Monitoring group within the emergency organization
locates the offsite plume centerline, directly samples and measures airborne
iodine concentrations and takes other measurements and samples as determined
necessary by the Field Monitoring Coordinator. This information is passed on to
the Dose Assessment Coordinator. Field Monitoring is conducted in accordance
with the CP/0/B/4004 Series Procedures.
In-plant airborne iodine cencentrations are determined in accordance with
Procedure HP/0/B/1009/09.
An air sample is drawn through a Silver Zeolite
cartidge which is then counted with an E-120 instrument with an HP-210 G-M probe.
Procedure HP/O/B/1009/11 provides for manual or computer calculation of downwind
whole body and thyroid doses for a release from a unit vent. Inputs required are
sample analysis of vent gas (Monitor readings as backup),
meteorological data,
gamma average energy (Mev/disintegration),
vent discharge flow rate (CFM),
and
time since reactor trip. Environmental samples are recommended to verify the
dose calculations.
Procedure HP/O/B/1009/10 is
used to calculate iodine and noble gas activity
releases using the Main Steam Line Process Monitor readings.
. Procedure HP/O/B/1009/15 describes methods for collecting samples or taking
radiation measurements for estimating noble gas and iodine release rates.
Protective Action Guides and initiation procedures are specified in Station
Directive 3.8.5 and AP/O/A/1000/66.
Trends may be followed by feeding Area or Process Monitor outputs to Trend
Recorders.
Specific reference to update of assessment is
made in Station
Directive 3.8.5 and in the AP/0/A/1000 series procedures.
The auditor reviewed the accessibility of offsite data and use of meteorological
data *in plant emergency procedures describing radiological assessment actions.
The procedures reviewed were HP/O/B/1009/13,
Procedure for Implementation and
Verification for Availability of a Back-up Source of Meteorological Data,
and
Station Directive 3.8.5.
The National Weather Service station at Greenville-Spartanburg airport, located
about 60 miles east of Oconee,
is identified as the source of back-up data.
Information requested of the back-up source includes air temperature and sky
conditions, which are not used in the procedures for offsite dose projections.
However,
information about weather conditions (e.g.,
rain or snow) which may
affect dose projections should be requested
from the back-up
source
of
meteorological data.
The procedure of Station Directive 3.8.5 is designed for use as an initial 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />
projection, incorporating real-time meteorological data for the first hour and
"1worst case" for the next 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> into time-distance dose curves. The procedure
requires the operator to obtain back-up data if onsite data are not available.
23
If an NWS station is used as the back-up, wind direction information may be only
available in 100 increments. Section B.3 is an attempt to incorporate knowledge
of complex local airflow characteristics into dose projections.
Because these
'complex conditions are most likely to occur from 4 p.m. to 10 a.m., operators on
the backshift will have to be most familiar with rapid identification of the
proper conditions through the contingencies outlined in this procedure.
Although
these complex airflow patterns are important considerations at Oconee,
the
procedure for identifying the proper time-distance-dose curves and attachments
appears confusing and cumbersome.
The technical bases for the contingencies
outlined in Section B.3, including time periods and stability criteria (i.e, what
stability classes are represented and what diffusion rates have been used in the
time-distance-dose curves?) need to be presented in a document separate from the
implementing procedure. Section B.9 requires reassessment every hour or 22.50
wind shift. Wind direction is a very unsteady parameter, and use of a change of
only 22.50 as a criterion for reassessment could require numerous updates,
depending on the averaging time used to determine wind direction.
If an NWS
station such as Greenville-Spartanburg is used as a source of information, wind
direction will likely be provided in 100 increments, which is not consistent with
the 22.50 criterion for reassessment.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following should be considered for improvement:
Procedure HP/0/1/B/1009/13 should be changed to include weather conditions
as part of the information required from the National Weather Service;
alternating communications checks among shifts, and include the time of the
checks in Enclosure 5.1; and record concurrent onsite meteorological data
with offsite data in Enclosure 5.1
(50-269,
270, 287/81-13-19).
Station Directive 3.8.5 should be changed to include incorporation of the
use of 15-minute averaged meteorological data into the procedure; clarifi
cation of the procedure for the case when primary or river tower data is not
available; and clarification of the 22.5 degree criterion for wind shifts to
determine need for assessment. Wind direction is an unsteady parameter and
numerous reassessments could be required depending on the averaging time for
meteorological data (50-269,
270, 287/81-13-20).
5.4.2.1 Offsite Radiological Surveys
The facilities and equipment for offsite radiological monitoring are described in
the Emergency Plan,
Section 7.3.3.
The methods and equipment used to perform
emergency offsite radiological surveys are specified in Procedure CP/0/B/4003/01.
The Procedure describes the team assignments and procedures,
and includes a
description of the responsibilities of the Field Monitoring Coordinator (FMC)
and
Field Monitoring Supervisor. The FMC initially locates in the TSC, reporting to
the Station Health Physicist, then reports to the Offsite Radiological
Co
ordinator once the CMC is established.
The FMC determines .the plume direction
and sectors to be monitored using Procedure CP/0/B/4003/02, the Determination Of
Plume Direction And Sectors To Be Monitored Following A Large Unplanned Release
24
of Gaseous Radioactivity. Radiation protection clothing and equipment (including
Potassium Iodide) is provided in the team kits.
Radiation protection guidance is
provided in Sections 3.4 and 3.5 of the Procedure. Transportation is specified
in Sections 4.2 and 4.4.3.4 of the Procedure, and Sections 4.3 and 4.3.1 specify
primary and backup communications.
Teams A, B, and C will normally be dispatched by motor vehicle and monitor the
designated sectors at distances of 1, 3, and 5 miles, attempting to locate the
plume centerline and determine 1-131 activity. Team D is normally a backup team;
Team E normally monitors plume activity on Lake Keowee; and Team F monitors the
plume from the air when conditions permit.
Maps are provided with the monitoring kits to enable the teams to locate the
designated monitoring points. The Procedure (CP/O/B/4003/01) and its Enclosures
provide detailed instructions for taking and recording required survey data.
The Field Teams provide sample results to the FMC or Superviser in accordance
with Section 4.4.4.2 of the Procedure. The results are then passed to the Dose
Assessment Coordinator in accordance with Section 4.4.2.4.
Samples are returned to the Environmental Lab or CMC as directed by the FMC. No
provision is made for the Monitoring Teams to turn in the data sheets for the
surveys.
Based on the above findings, this area of the Licensee's program appears to be
acceptable; however, the following item should be considered for improvement:
The Procedure should include a provision for disposition of the Monitoring
Teams'
data sheets (50-269,
270, 287/81-13-21).
5.4.2.2 Onsite (out-of-plant) Radiological Surveys
The out-of-plant radiological surveys are performed by the in-plant teams within
the protected area (security area) fence. The remainder of the exclusion area is
surveyed by the
Environmental
Monitoring
Teams using their procedures and
equipment.
The in-plant radiological survey program evaluation is presented in Section
5.4.2.3 of this report. The offsite radiological survey program evaluation is
presented in Section 5.4.2.1 of this report.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the item identified in Section 5.4.2.1 should be considered
for improvement.
5.4.2.3 In-plant Radiological Surveys
.
Onsite radiological monitoring is briefly described in the Emergency Plan,
Section 7.3.2.
Emergency radiological surveys are performed in accordance with
Health Physics Emergency Procedures (1009 Series).
Health Physics Operational
e0
25
Procedures (1000 Series) for surveys and HP Operating Procedures (1002
Series)
for the use of specific instruments provide instruction for taking and recording
surveys.
Air sampling is performed and recorded in accordance with procedure HP/O/B/100/57
Air Sampling, Counting and Calculation Procedure. Smear sampling and analysis is
provided for in procedure HP/O/B/1000/56 Smear Sampling, Counting, and Calcula
tion Procedure. Other procedures in this series provide for effluent sampling.
The individual procedures provide for the disposition of samples and original
data.
The plant telephone system would be the primary communications system used by the
monitoring teams, and the radio system used as backup.
Radiation protection guidance is provided in the Health Physics Guidelines,
specifically, Radiation Exposure Guidelines For Personnel
Who Are Performing
Assessment Actions During An Emergency.
Based on the above findings, this area of the Licensee's program appears to be
acceptable.
5.4.2.4 Post-Accident Primary Coolant Sampling
The licensee has established a procedure CP/O/A/2002/04A, Post-Accident Sampling
(Liquid) for obtaining a post-accident primary coolant sample.
Review of this
procedure included discussions with the Station Chemist and other Chemistry
personnel.
Section 2.4 of the procedure states that by determining the exposure rate of the
coolant sample, allowable stay times can be calculated, however, there is no
calculation which takes into account the radiation fields in which the chemistry
technicians would be working. Radiation protection is discussed in the proce
dure, but portable monitoring instruments and high range dosimetry to be used are
not specified. The procedure does not identify special equipment or techniques
to be used when transferring the coolant sample container from the hood to the
shielded transport container in order to reduce the extremity exposure to the
technician handling the sample. The procedure does not state where the shielded
transport container is kept and how to move it
from the storage area to the
sampling point. The procedure does not provide a check list for the operation of
the emergency sampling equipment. The procedure does not designate the primary
counting facility nor the alternate facility in the event of high background in
the primary counting area.
The labeling and storage of the high activity samples
are not addressed.
The procedure does not include a data sheet for recording
high activity sample results, nor the disposition of data.
Based on the above findings, the following deficiencies must be corrected to
achieve an acceptable program:
Upgrade procedures as follows (50-269,
270, 287/81-13-22):
26
Revise the procedure to provide more explicit guidance and health
physics support in exposure assessment.
Provide for the use of specialized dosimetry and discuss portable
monitoring to be used.
Provide specialized equipment and/or techniques for transferring the
sample to and from the lead pig.
Provide a procedure to relate post accident sample results to EALs.
5.4.2.5 Primary Coolant Sample Analysis
Discussions with the Station Chemist and a Nuclear Chemist Technician indicated
that with the exception of boron analysis,
no special procedures had been
developed for the analysis of a postaccident coolant sample. Normal procedures
used for analyzing primary coolant samples would be utilized in case of an
emergency. These procedures do not address handling of a highly radioactive
sample nor do they take into account calibration of counting equipment for high
level samples. Dilution of the sample is also not addressed.
Licensee repre
sentatives stated that the normal analysis procedures would be appropriately
modified by the technical support staff in the event of a specific accident.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following items should be considered for improvement:
Develop procedures which contain methods for analyzing high level primary
coolant samples in accordance with NUREG-0737 guidelines.
The procedures
should discuss provisions for calibrating equipment, diluting the sample,
protection of laboratory personnel and storage of the sample when analysis
is complete (50-269,
270, 287/81-13-23).
5.4.2.6 Containment Air Sampling
5.4.2.7 Containment Air Sample Analysis
5.4.2.8 Stack Effluent Sampling
5.4.2.9 Stack Effluent Sample Analysis
The licensee has established a procedure, Procedure for Quantifying High Level
Gaseous Radioactivity Releases During Accident Conditions,
HP/0/B/1009/15 for
taking and evaluating containment air and effluent gas activity under accident
conditions. Individual exposures are to be kept below 3 Rem whole body dose
and/or 18 3/4 Rem extremity dose per quarter.
The procedure addresses use of
. protective clothing, respiratory equipment,
survey instruments and high range
dosimetry. However, the procedure does not address the use of special tools and
equipment which.would be used to limit exposure.
27
Data sheets to be used while taking the samples are not available in the proce
dure. Transporting the sample is addressed but the location of the shielded
container to be used is not identified.
Isotopic analysis of the samples are addressed in the procedure;
however,
specific methods
and instrumentation to be used for the analysis are not
identified. In addition, it
is not clear who will be performing the analysis.
Calibration of instruments for counting high level samples is not addressed in
the procedure nor is counting the samples in a high background area.
The
procedure does not discuss radiation protection of the personnel working with the
high level samples. Contamination control is not addressed and analytical data
sheets are not available in the procedure. Storage of the sample is mentioned in
the procedure but a location for such storage is not identified. The results of
the analysis and the intrepretation of data are not discussed.
Based on the above findings, this area of the licensee's program is considered
acceptable; however, the following items should be considered for improvement:
Upgrade the procedures as follows (50-269,
270, 287/81-13-24):
Special tools and equipment to be used while taking samples should be
addressed.
Data sheets for taking and analyzing the sample should be included in
the procedure.
Methods and instrumentation to be used in the isotopic analysis should
be addressed in the procedure.
Calibration of equipment for use with high level samples should be
addressed.
Radiation Protection and contamination control in the counting facility
should be discussed in the procedure.
The procedure must relate post-accident sample results to EALs.
5.4.2.10 Liquid Effluent Sampling
5.4.2.11 Liquid Effluent Sample Analysis
The auditor reviewed the licensee's procedure for liquid effluent sampling and
analysis, Procedure for Sampling and Release Requirements for CTT, CMT and LHST,
HP/0/B/1000/60/C.
This procedure is used during normal operations and does not
address sampling and analysis under emergency conditions. Limiting radiation
exposure to sampling personnel
and verification of the habitability of the
sampling area is not addressed. Special equipment or tools to be used during an
accident are not identified.
28
There are no analytical procedures for high level liquid effluent samples.
Calibration of counting equipment for high level
samples is not addressed.
Radiological protection of laboratory personnel and contamination control are not
discussed in the procedure.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following should be considered for improvement:
Upgrade the procedures as follows (50-269,
270, 287/81-13-25):
The procedure should be revised to include provisions for sampling and
analysis of high level liquid effluents.
Means for limiting radiation exposure and contamination control should
be addressed.
Special tools or equipment that might be used for taking or analyzing a
high level sample should be identified.
Analytical procedures for highly radioactive
samples should be
developed.
5.4.2.12 Radiological and Environmental Monitoring Program
The auditor reviewed procedures CP/O/B/4003/01, 02, 03, 04 and 05 and discussed
the radiological and environmental monitoring program with licensee representa
tives. The licensee, as part of the normal environmental monitoring program, has
four continuously operating
environmental
air samplers
and twenty-six TLD
monitoring 'locations. In an emergency, field monitoring teams are equipped to
take air, water, vegetation, soil and milk samples to perform an analysis of the
Iodine-131 concentration in air and communicate this information to the TSC. The
responsibility for directing the field monitoring program is given to the Field
Monitoring Coordinator, or in his absence, the Field Monitoring Supervisor.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.4.3 Protective Action
5.4.3.1 Radiation Protection During Emergencies
Implementation
of the radiation protection program during emergencies
is
described in Sections 6.3 and 6.4 of the Emergency Plan.
Procedure AP/O/A/1000/01 provides for initial classification of an accident,
establishing an Emergency Action Level,
if
appropriate.
Procedures AP/O/A/
1000/02 through AP/O/A/1000/05 specify radiation protection actions to be taken
at each EAL depending on the nature of the accident/emergency.
If radiation or
29
contamination is involved, Health Physics is directed to evaluate the hazards and
recommend methods of controlling radiological problems. Health Physics Organiza
tion emergency responsibilities and functions are detailed in Station Directive
2.9.2.
These responsibilities and functions are implemented through Health
Physics Emergency Procedures in the HP/O/B/1009 Series and Health Physics
Operational Procedures in the HP/O/B/1000 series.
The emergency functions are
further implemented through contingency plans within the HP Guidelines.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.4.3.2 Evacuation of Owner Controlled Areas
Station Directive 2.9.1 and procedure AP/A/1000/10 provide for evacuation of
areas within the site and evacuation of the entire site at the discretion of the
Emergency Coordinator. Conditions for initiating evacuations are described in
these documents.
The licensee has established a system whereby all personnel, at the sound of the
Site Assembly Alarm,
report to their own section's assembly area.
Assembly
points for personnel onsite are identified in Station Directive 2.9.1 as well as
on the back of the individual's security badge. The supervisor of each section
accounts for all the people for which he is responsible.
Station superintendents
and senior supervisors of various organizations make accountability reports to
the Station Manager. Because of the large number of assembly locations (in
excess of 30), there is no attempt made to identify specific evacuation routes.
When alerted of a Station Assembly, the Security Shift Lieutenant is responsible
for initiating a patrol of the general areas within station boundaries to assure
that personnel are aware of the Station Assembly.
Station evacuations are
activated only after station personnel have been assembled through a Station
Assembly.
Evacuation will be
by designated preplanned routes which avoid
locations that may be affected by the emergency situation.
Evacuation routes,
assembly locations, and other pertinent information will be passed over the PA
system or by telephone.
Health Physics will survey evacuees and vehicles for
contamination at designated locations as directed by the Emergency Coordinator.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following item should be considered for improvement:
Provide for informing personnel, during a Station Assembly, of radiological
conditions which could prevent them from reaching and/or remaining at their
respective assembly areas (50-269,
270, 287/81-13-26).
5.4.3.3 Personnel Accountability
Station Directive 2.9.1 provides for the assembly of personnel onsite and their
accountability.
When personnel are called to their assembly areas by means of
- 0
30
the Station Assembly Alarm each supervisor is responsible for their accounta
bility. Superintendents and the senior supervisors of the various organizations
will make an accountability report to the Station Manager for their areas of
responsibility. Security would make an accountability report for in-plant
visitors.
Each reporting supervisor is to report location, his name, telephone
number, number of people assembled, and any missing persons. When alerted of a
Station Assembly, the Security Shift Lieutenant is responsible for initiating a
patrol of the general station areas within station boundaries to assure that
personnel
are
aware
of the Station Assembly
requirement.
The
Emergency
Coordinator (Shift Supervisor/Station
Manager)
receives the accountability
reports and directs necessary actions to account for any missing personnel.
There is no reference in the licensee's procedures or directives for search and
rescue nor is it clearly defined who will be responsible for conducting search
and rescue operations or who will comprise search teams. There are no security
procedures for a site assembly.
Drills have shown that accountability of the
onsite personnel
(in
excess of
1000 people)
can be
accomplished within
30 minutes.
Based on the above findings, this portion of the licensee's program appears to be
acceptable; however, the following item should be considered for improvement:
Provide procedures delineating responsibilities and make-up of search and
rescue teams (50-269,
270, 287/81-13-27).
5.4.3.4 Personnel Monitoring and Decontamination
The Emergency
Plan,
Section 6.5.2,
describes the available decontamination
facilities and handling of cases where both injury and contamination are present.
Station Directive 3.8.10,
Procedure For Use Of Count Rate Meters and Portal
Monitors, establishes the monitoring program for individuals leaving potentially
contaminated areas.
Key information
and instructions are posted at each
monitoring point adjacent to the monitoring instrument. The instrument used for
personnel contamination monitoring is the RM-14 with an HP-210 G-M probe. Draft
procedure HP/0/A/1009/23 provides for monitoring and decontamination onsite and
at assembly areas. Contamination levels for release from the site during an
evacuation are established and final decontamination and release is provided at
the reassembly areas in accordance with Station Directive 3.8.18,
Personnel
Decontamination.
Data recording
is
done in accordance with draft procedure HP/0/A/1009/23,
Enclosures 5.1 and 5.3 and Enclosure 5.2 of Procedure HP/0/B/1005/11.
Distribution of Individual Contamination Exposure Level forms are specified in
draft procedure HP/0/A/1009/23, and in procedure HP/0/B/1005/11.
Procedure HP/0/A/1009/23 specifies completion of the Initial Contamination Record
which is used for initial clearance during site evacuation, but no provision is
made for disposition of the form.
31
Based on the above findings, this area of the licensee's program appears to be
acceptable pending approval and implementation of draft procedure HP/O/A/1009/23
or equivalent.
5.4.3.5 Onsite First-Aid/Rescue
The onsite First-Aid/Rescue program is described in the Emergency Plan, Section
6.5.2.
Procedure AP/0/A/1000/08, Procedure for Response Actions
for Accidents/
Emergencies, addresses response actions for accidents/emergencies within station
boundaries.
Accidents/emergencies
are classified into
general
groups and
response actions and notifications are described for each.
Station Directive
5.1.3,
Personal Injury, also describes handling of injury cases including
responses and notifications, but, additionally, covers administrative require
ments. Rescues from radiation or contamination areas are covered in a Health
Physics Guideline--Guidelines for the Removal of Injured Persons from a Radiation
Hazard Area During a Site or General Emergency.
Description of the interface for using Oconee Memorial Hospital for contaminated
patients is provided in both procedure AP/O/A/1000/08 and Station Directive
5.1.3. Radiation protection guidance for the rescue team is provided in the
Health Physics Guidelines.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.4.4 Security During Emergencies
Security measures to be placed in effect during emergencies are specified in the
Station Security Procedures (SSP).
They are administed by a contract service,
Southern Security Incorporated. The following SD and SSPs were reviewed by the
inspector:
SD 2.9.1
Station Assembly and Evacuation Procedure
SSP 201
Security Badges
SSP 508
Badging Officer
SSP 518
Vital Vehicle Access Portal
SSP 611
ONS Contingency Procedure, Site Evacuation
These procedures are developed to meet the requirements of Appendix C to 10 CFR
Part 73 and complement the Radiation Emergency Plan.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.4.5 Repair/Corrective Actions
The Emergency Plan and implementing procedures recognize the potential need for
repair and corrective actions to correct or mitigate an emergency condition.
32
While specific procedures for repair/corrective actions in an emergency are not
provided, responsibilities are assigned and controls are designated to assure
adequate safety for repair/corrective action responses through the
use of
approved procedures for plant operations.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.4.6
Recovery
The auditor reviewed section 9.0 of the Emergency Plan and the Corporate Crisis
Management Plan and discussed recovery organization and operations with licensee
management. The Recovery Manager has the authority to declare that a recovery
phase is to be entered and to determine the specific organizational structure and
staffing. The plans and procedures provide for evaluation of plant conditions as
well as onsite and offsite radiological conditions prior to entering a recovery
phase. The Recovery Manager is responsible for informing response organizations
that a recovery operation is to be initiated and inform them of any changes in
the organization that may occur.
The Crisis Management
Plan describes the
transition from the emergency organization to the recovery organization and
identifies the key positions, as well as the individuals to fill
these positions,
in the recovery organization.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.4.7 Public Information
The licensee's Crisis News Center Plan-Oconee Nuclear Station was reviewed with
company information officials at Corporate headquarters in Charlotte,
North
Carolina. During this review, the following observations were made with respect
to public information procedures:
Organizations (internal
and external)
involved in news dissemination are
identified.
Location of these organizations and ways of contacting them (telephone) are
identified.
Methods for coordinating the internal dissemination of information to the
various locations and individuals have been developed.
Interim provisions exist for initial dissemination of information to news
media prior to establishment of the licensee news center.
Procedures clearly identify a utility spokesman and an alternate and specify
sources of information to be used by those spokesmen.
Provisions exist for coordination of information among the various organiza
tions and groups.
33
Procedures do not provide adequate written documentation and guidance for
rumor control. Provision for responding to public inquiries, separate from
the news media,
has been made through use of company "Retail Offices" via
computerized CRT communication.
This is not addressed in the present Crisis
News Center Plan. The Company also plans to issue special "rumor control"
telephone numbers via the media during an accident situation. This is not
specified in the current Crisis News Center Plan.
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following item should be considered for improvement:
Coordination with the news information function of other organizations,
including rumor information, should be clearly identified in in the Crisis
News Group Implementing Plan (50-269,
270, 287/81-13-28).
5.5 Supplementary Procedures
5.5.1
Inventory, Operational Check and Calibration of Emergency Equipment,
Facilities and Supplies
The auditor reviewed procedures HP/O/B/1009/01, HP/O/B/1009/08 and PT/O/B/2000/04
and discussed the inventory, operational checks and calibration of emergency
equipment, facilities and supplies with licensee representatives.
The procedures
contained specific inventories of equipment reserved for emergency use and
specified the locations of these supplies. The frequency of inventories, checks
and calibrations was specified and the responsibilities of performing such were
assigned.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.5.2 Drills and Exercises
The auditor reviewed the records available relative to the drills and exercises
conducted prior to the June 30, 1981. The scenarios for these drills related to
health ,physics,
radiological monitoring,
fire,
communication,
medical
and
security events and provided for events on back shifts. These drills and other
drills of small work groups were administred by the Station Health Physicist in
accordance with a scenerio developed in advance of the drill. A response to an
actual event is not considered to be a drill or exercise.
The comments and recommendations of the observers of these events are evaluated
at a critique meeting and documented in a summary report to management.
There is
no
management
control to assign responsibility for corrective actions and
assignment of completion dates to assure that assigned corrective actions are
completed in accordance with the established schedule and are adequate to resolve
the noted deficiencies, mistakes, or problems.
The' above drills and exercises were conducted in accordance with procedure
HP/O/B/1000/13 Procedure for Preparing and Conducting Site Assembly/Communica
tions Checks and Emergency Drills.
HB/O/B/1000/13 has been superceded by
034
PT/O/B/2000/01, Procedures for Preparing and Conducting Emergency Drills and
Exercises, approved July 14,
1981.
Offsite agencies and groups and the news
media have routinely participated in the drills and exercises at least per the
frequencies noted in NUREG-0654.
Based on the above findings, this area of the licensee's program is acceptable;
however, the following item should be considered for improvement:
Document the resolution of deficiencies/improvements identified in drills
and exercises (50-269,
270, 289/81-13-29).
5.5.3
Review, Revision, and Distribution
The auditor reviewed Section 8.2 of the Emergency Plan and procedure PT/0/B/
2000/03 and discussed the document control system for the Emergency Plan and
procedures with licensee management.
The Emergency plan and procedures are
controlled documents for distribution purposes.
Assigned copies with unique
numbers are provided to personnel indicated on an approved distribution list.
Signature verification of receipt is required.
Call lists are reviewed on a
quarterly basis.
The Emergency Plan and procedures are reviewed and indepen
dently audited on an annual basis.
The responsibility for the review and update of the Emergency Plan,
procedures
and call lists is not delineated.
Phone numbers that are on the monthly com
munications check are correct, but there are no assurances that other numbers on
the call lists are actually current and correct.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
5.5.4 Audit
The auditor reviewed Section 8.2 of the Emergency Plan and discussed the area of
audits with
licensee representatives.
The
licensee's Surveillance Section
conducts annual surveillances (audits) of the Emergency Plan and procedures.
Semi-annual surveillances are performed on emergency equipment and facilities.
This entails the examination of all documents and comparison of their contents
with the requirements of technical specifications, federal requirements, etc.
Checks are made to assure that document reviews, inventories, calibrations and
other periodic mechanisms for maintaining emergency preparedness have been
completed. The surveillance of emergency preparedness does not include regular
observation of exercises or drills of the emergency plan. Reports of significant
findings are made to the managers or supervisors responsible for correcting that
area of problems.
Reports to higher station management are made if corrective
action is not performed.
0II
35
Based on the above findings, this area of the licensee's program appears to be
acceptable; however, the following items should be considered for improvement:
Assure that responsibility for the review and distribution of the Emergency
Plan,
procedures and call lists is specifically assigned and that this
responsibility is stated in the Plan (50-269,
270, 287/81-13-30).
Provide a means for assuring that all phone numbers on the call lists are
current and correct (50-269,
270, 287/81-13-31).
6.0 Coordination with Offsite Groups
6.1 Offsite Agencies
The auditor discussed offsite agencies which would support a station emergency
with licensee representatives and reviewed the letters of agreement contained in
Appendix C of the Emergency Plan.
The written agreements have been rewritten
during the Spring of 1981.
These organizations will provide for radiological
support, medical assistance, medical transportation, fire protection, and law
enforcement support in the event of an emergency and the agreements are current.
Training has been provided for members of offsite agencies and organizations,
which includes onsite orientation
and familiarization training for those
.
individuals who may need to respond to the site. The licensee plans that offsite
groups responding to *the site will be accompanied by security officers while
inside the protected area boundary.
On September 1, 1981,
the auditor interviewed representatives of the Pickens
County Civil Preparedness Agency,
Oconee County Civil Defense Agency,
Oconee
County School District, Pickens County Sheriff's Office, Oconee County Sheriff's
Office, Oconee County Rural Fire Protection Association, and the Oconee Memorial
Hospital,
to discuss emergency response at the Oconee site.
The individuals
contacted at each of these organizations were cognizant of their role in the
event of an emergency at the Oconee site, had been provided training in their
respective roles in emergency response and were satisfied that adequate communi
cations and interface had been provided between their respective organizations
and the licensee.
The auditor reviewed documentation of training of offsite
agencies and organizations that had been accomplished and observed that adequate
overall interaction and coordination between offsite groups and the licensee were
evident in the February 1981 emergency exercise. The agreement with the Oconee
County Rural Fire Protection Association documents the previous verbal agreements
that their role would be to provide fire fighting equipment and manpower to bring
under control any fire that would occur outside the security area. The ONS fire
brigade has been trained and staffed to control fires within the security area
per ONS SD 5.3.1 Fire Brigade Organization and Training.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
36
6.2 General Public
The licensee has provided for dissemination of emergency planning information to
the public within the plume exposure pathway EPZ through the mailing of an
emergency information brochure.
The auditors reviewed the brochure and discussed
this area with licensee information officials.
In areas involving contact with the general public, the licensee:
Provides for dissemination of emergency planning information to the public
within the plume exposure EPZ,
including the transient population.
Sets forth procedures to coordinate emergency action information with State
and local agencies.
Updates and disseminates information at least annually.
Does not have adequate evacuation information in the present brochure with
regard to the use of the Alert and Notification (sirens).
This will be
rectified in a new brochure, tentatively scheduled for January 1982.
The
brochure would be more useful if
it
contained the call letters and fre
quencies of commercial,
radio and television stations in the area.
The
brochure would also be enhanced if
it
contained specific reference to the
needs of the handicapped, in addition to those needing additional trans
portation, and a telephone number for them to call.
Shelter areas are not
shown in the present brochure, nor is the college town of Clemson. This is
being corrected during preparation of the new brochure.
The present brochure does not provide a contact, either at the local civil
defense or company corporate level,
for additional
information.
The
licensee will correct this in the next brochure.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
6.3
News Media
The licensee's program for education and preparation of the news media in regard
to a nuclear emergency was reviewed and discussed at corporate headquarters and
at the site emergency news center.
In preparation for news media needs during an emergency, the licensee:
Has a program for familiarizing the news media with emergency plans, points
of contact for release of public information, space allocated for media use;
information about radiation,
normal versus accident plant operation,
and
accident sequences.
Conducts the program at least annually.
37
Has conducted the program at least once.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
7.0
Drills and Exercises
7.1
Program Implementation
The licensee conducted an exercise of site related activities on February 27,
1981.
Pickens and Oconee counties participated. The licensee is incorporating
the lessons learned from that exercise and from the various drills conducted in
1980 and 1981 into the emergency preparedness program. The inspector reviewed
documentation of the various drills required by the ONS Emergency Plan (EP) for
1980 and 1981.
Recommendations for correcting drill-identified mistakes and
problems are documented for the majority of the drills conducted; however, there
is no systematic documentation of the resolution of these recommendations
(reference par. 5.5.2).
The procedure HP/0/B/1000/13, Procedure for Preparing and Conducting Site
Assembly/Communication Checks and Emergency Drills and Exercises provides for the
various requirements of required drills and exercises, the frequency of these
events, the offsite participants for these events (i.e., county, state, NRC, and
FEMA) and documentation.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
7.2 Walk-Through Observations
The auditors conducted talk-through operations in the areas of emergency detec
tion and classification, notifications, dose calculations, and protective action
decision-making with shift operations personnel.
Walk-through operations with
licensee representatives were conducted in the areas of offsite dose calcula
tions, postaccident sampling, and offsite environmental sampling and analysis.
The personnel contacted during this part of the appraisal were found to be
knowledgeable and interested in their respective areas. They discussed and
demonstrated their areas of responsibility in a professional manner.
Several aspects of postaccident sampling and analysis were found to be in need of
improvement as discussed in Sections 4.0 and 5.0.
Based on the above findings, this area of the licensee's program appears to be
acceptable.
38
8.0 Persons Contacted
8.1
Licensee Personnel
H. B. Tucker
- Manager, Nuclear Production Division
- R. M. Glover
- Emergency Response Coordinator
- J. E. Smith
- Station Manager
W. W. Foster
- Associate Engineer
J. N. Pope
- Superintendent of Operations
J. M. Davis
- Superintendent of Maintenance
- T. B. Owen
- Superintendent of Technical Services
J. K. Clark
- Vice President, Corporate Communications
M. Cartwright
- Manager, Energy Information Services
G. B. Jones
- Shift Supervisor
F. E. Owens
- Assistant Shift Supervisor
L. L. Howell
- Assistant Shift Supervisor
0. C. Kohler
- Assistant Shift Supervisor
C. W. Fowler
-
W. H. Caudill
-
- J. T. McIntosh
- Superintendent of Administration
K. R. Clark
- Southern Security, Inc.
D. G. Austin
- Training & Safety Coordinator
D. Kelly
- Training Supervisor
P. Abercrombie
- Station Nurse
- C. T. Yongue
- Station Health Physicist
- C. L. Harlin
- Projects and Training Coordinator
J. A. Long
-
Support Functions Coordinator
D. L. Davidson
- Surveillance And Control Coordinator
S. L. Morgan
- Health Physics Supervisor
(Court Room and Environmental)
T. E. Carrol
- Health Physics Supervisor
(Respiratory Shift and Inst.)
S. E. Spear
- Health Physics Supervisor
(Radioactive Materials Control)
J. B. Dye
- Health Physics Supervisor
(Surveillance and Control)
M. Killough
- Associate Biologist
J. Sevic
- Station Biologist
W. E. Martin
- Planning & Materials Engineer
W. Ables
- Materials Supervisor (Services-WHSE)
D. Havice
-
I&E Coordinator
N. Dobey
-
I&E Supervisor
R. Knoerr
-
I&E Support Engineer
- R. P. Rogers
- Associate Reactor Engineer
D. P. Rochester
- Station Chemist
- R. T. Bond
-
Licensing and Projects Engineer
39
- T. E. Cribbe
-
Licensing Engineer
- T. C. Matthews
- Technical Specialist
- C. C. Jennings
-
Emergency Preparedness Coordinator
8.2 Other Organizations
Outside Agencies
D. Evett
- Pickens County Civil Preparedness Agency
C. Baumgarner
- Oconee County Civil Defense Agency
F. Hamilton
- Oconee County School District
S. Cobb
-
Oconee Memorial Hospital
S. Stone
- Oconee County Sheriff's Office
P. R. Steward
- Pickens County Sheriff's Office
F. Honea
- Oconee County Rural Fire Protection Association
8.3
NRC
F. Jape
- Senior Resident Inspector
- W. Orders
- Resident Inspector
D. Myers
- Resident Inspector
- G. R. Jenkins
- Section Chief EPOS Division, RII
In addition to the above persons, 2 operations personnel and 10 technicans
were contacted.
.
- Attended exit meeting.