ML15224A525

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IE Emergency Preparedness Appraisal Repts 50-269/81-13, 50-270/81-13 & 50-287/81-13 on 810824-0903.No Noncompliance Noted.Significant Appraisal Deficiencies Identified in post-accident Sampling Capability
ML15224A525
Person / Time
Site: Oconee  Duke Energy icon.png
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

TSC

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

TSC

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

Technical Support Center.

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

Emergency Plan.

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

-

STA

W. H. Caudill

-

STA

  • 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.