IR 05000289/1981012
| ML19352A910 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/27/1981 |
| From: | Bores R, Chestnut S, Donaldson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19352A907 | List: |
| References | |
| 50-289-81-12, NUDOCS 8106020317 | |
| Download: ML19352A910 (31) | |
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U.S. NUCLEAR REGULATORY COMMISSION t-0FFICE OF INSPECTION AND ENFORCEMENT
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Region I Report No. 50-289/81-12 Docket No. 50-289 Category C
License No.DPR-50 Priority
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Licensee:
Metropolitan Edison Company P.O. Box 480 Middletown, Pennsylvania 17057 Facility Name:
Three Mile' Island Nuclear Station, Unit 1 Inspection at:
Middeltown, Pennsylvania Inspection conducted: May 4-7,1981 Inspactors:
(lit. b 4tfib 27h/
D. Donaldson, R 'diation Specialist, RI (ate tignec AAR WA shgh/
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S. Chesnut, Emergency Planning Analyist, HQ dd:e s4gnec u
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date signed A,' proved by:
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, Ph.D. Acting Chief, Emergency
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Pr ;aredness Section Inspection Summ ry:
Inspection on May 4-7, 1981 (Report No. 50-289/81-12)
Areas Inspected: Special, announced inspection to followup 30 significant emergency preparedness items from a prior evaluation performed on July 28-August 8, 1980 (Report No. 50-289/80-22).
The inspection involved 60 inspector-hours onsite by one regionally based inspector and a headquarters representative from the Division of Emergency Preparedness.
Resul ts : Of the 30 items reviewed, 26 have been resolved and 4 remain open.
Of the 4 remaining items, the licensee's actions underway were consistent with formal comitments to the NRC and the dates for final resolution has not passed.
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i Region I Form 12 (Rev. April 77)
.8106020 3l0
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DETAILS
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Individuals Contacted a.
Principal Licensee Individuals
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Toole, Manager, TMI-1
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Giangi, Supervisor, Emergency Preparedness R.
Regin, Emergency Preparedness Manager
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Smyth, Licensing Group R. -Dubiel, Radiological Engineer R.
Zechman, Supervisor, Training
- Denotes those also present at the exit interview.
b.
Non-licensee Personnel M.
Reilly, Pennsylvania Bureau of Radiological Health S. -Cohen, Pennsylvania Bureau of Radiological Health 2.
General During the period July 28-August 8, 1980, the NRC conducted a special evaluation of the health physics and emergency preparedness programs at Unit-1 of the Three Mile Island Nuclear Station.
The results of this evaluation were cocumented in Office of Inspection and Enforcement Inspection Re;:rt 50-239/S0-22 and transmitted to the licensee by a letter frem the NRC Regional Office dated November 26, 1980.
Appendix
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B to the referenced letter forwarded 30 significant findings in relation to the licensee's proposed NUREG-0654 eme gency preparedness program. In a letter to the NRC dated February, 1981, (LIL 024), the licensee' provided a written response to the aformentioned 30 emergency preparedness items.
The purpose of this inspection was to review the licensee's progress toward resolution of these items.
Subsequent paragraphs detail this status.
3.
Licensee Action on Emeroency Preparedness Items from Health Physics Evaluation 50-239/80-22 a.
(Closed)
Assignment of individuals by position or title, to the functional areas of emergency activity described in the Emergency Plan and Emergency Plan Implementing Procedures, with such assignments detailed, further, by
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i name, in the Emergency Plan Implementing Procedures /EOSR (289/80-22-56).
. LICENSEE Attachment I to the revised Administrative RESPONSE:
Procedure 1014, " Administration of the
.-TMI-I 0' site and Offsite Emergency Duty Rosters," identifies personnel by po-sition title or functional qualifications who are considered to be qualified to serve in specific emergency response positions in the functional areas of emergency activity described in the Emergency Plan. Selection and assignment of individuals will be accomplished by comparing individual qualifications with the position specifications being developed for each emergency response position identified in AP 1014.
Individual assignments, by name, are reviewed and posted periodically in the onsite emer-gency duty rosters.
AP 1014 is PORC approved and was im-plemented on January 2, 1981.
Develop-ment of position specifications will be completed by August 21, 1981.
NRC The inspector reviewed administrative EVALUATION:
Procedure 1014 dated January 7, 1981,
" Administration of the TMI-1 Onsite and Offsite Emergency Duty Roster."
This procedure described the method for assigning individuals to the functional areas described in the Emergency Plan.
Personnel are assigned by name to the Eme sency Duty Shift Roster (EDSR) based on satisfying position titles / expertise requirements of Attachment 1 to AP 1014 A comparison of Attachment I and the Emergency Plan indicated that snecific position title </ expertise were provided i
for all emergency functions with the exception of Radiolot :al Moni*cring Team Members. Based on discussions with the licensee, the inspector noted that
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the licensee intended to assign only Health Physics Technicians and Auxiliary Operators as Radiation Monitoring Team Members.
During the inspection, the licensee initiated a procedure Change
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Request.(PCR) to change Attachment 1 to
'AP 1014 to indicate that Health P..ysics Technicians ard Auxiliary Operators would be assigned to the EDSR to perform Radiation Monitoring Team duties.
The irspector also reviewed several com-pleted position descriptions which would-be used to augment the selection of per-sonnsl to the EDSR.
Approximately two-thirds of the-position descriptions had been completed. Those which had not been completed were primarily those of support staff personnel.
Based on the licensee's actions, the inspector determined that adequate measures had been implemented to assure that individuals would be assigned to the functional areas of emergency activity as described in the licensee's Emergency Plan. The use of position descriptions, when completed, will further supplement individual assignment to the EDSR.
Based on the above findings, this item is closed, b.
(Closed)
Development of an approved procedure governing the ad-ministrative aspects of the EDSR and the selection criteria to be applied in assigning individuals to positions in the onsite emergency organizations if the EDSR approacn is to be continued (289/80-22-57).
LICENSEE As noted in Item 56 above, AP 1014, im-RESPONSE:
ple.mented on January 2, 1981, establishes procedures governing the administrative aspects of the emergency duty rosters, including preparation, review and main-tenance. AP 1014 also identified func-tional qualifications'or expertise which constitute part of the selection criteria to be applied in assigning individuals to duty positions.
When completed, the position specifications for each emergency response position identified in AP 1014 will be usec as additional selection criteria and will form the basis of individual assicnment to the onsite emergency response organization.
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Development of position specifications will be completed by August 21, 1981.
NRC The inspector reviewed Administrative EVALUATION:
Procedure 1014, dated January 7,1981,
" Administration of the TMI-1 Onsite and Offsite Emergency Duty Roster." As de-scribed in the evaluation of Item 22-56 the inspector noted that this procedure contained adequate position titles / expert-ise for the emergency functional areas described in the Emergency Plan with the exception of Radiation Monitoring Team members. A PCR was initiated while the inspector was on site to indicate that Health Physics Technicians and Auxiliary Operations would be assigned as Rad-iation Monitoring Team members. With this change in place, an adequate procedure exists for assigning personnel to the onsite emergency organization.
The in-spector reviewed the current Emergency Duty Shift Rosters and noted that Attach-ment l'to AP 1014, Position' Titles / Expertise, was being used in selecting individuals for assignment to the EDSR.
The position descriptions (also discussed in response to Item 22-56) for emergency response positions augment the selection pro-cess for members of the onsite emergency organization.
Based on the submittal of a PCR clari-fying the assignment of individuals by position or title to the Radiation Mon-itoring Teams, the inspector determined that adequate measures had been implemented to assure that qualified individuals would be assigned to the functionci areas of emergency activity according to an approved selection criteria.
The use of position descriptions will further enhance assignment of individuals to the onsite EDSR.
This item is, therefore, closed.
c.
(Closed)
Assignment of individuals / contractors to the functional areas of offsite support by position or title, with such assignments detailed further, by name, in the Emergency Plan Implementing Procedures /EDSR (289/80-22-58).
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i LICENSEE AP 1014 identifies personnel by position RESPONSE:
title or expertise who are considered to be qualified to serve in specific offsite emergency response positions.
Selection and assignment of individuals by name, will be accomplished by com-paring individual qualifications with the position-title or expertise.
Upon completion, position specifications, currently under development for each emergency response position identified in AP 1014, will provide additional criteria upon which to base assignment to the offsite emergency response organization.
Position specifications will be completed by August 21, 1981.
NRC The inspectors reviewed the licensee's EVALUATION:
emergency organization ano found tnat individuals assigned to the TMI-1 emer-gency organization would be site or corporate personnel and that no contractor personnel were assigned.
All emergency functions described in the Emergency Plan were included in AP 1014.
Since the functional areas of the licen-see's Emergency Plan are assigned in accordance with AP 1014, this item is closed.
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(Closed)
Development of an approved procedure governing the ad-r.inistrative aspects of the offsite EDSR and the selection criteria to be applied in assigning 4-lviduals to po-sitions in the offsite emergency organization (2S9/80-22-59).
l LICENSEE AP 1014 governs the administrative i
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aspects of the development, approval, distribution, and maintenance of the offsite emergency duty roster.
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conjunction with the position spec-ifications now being developed, AP 1014 provides selection criteria for the assignment of personnel to the offsite er.ergency response organization.
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Position specifications will be com-
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pleted by August'21, 1981.
NRC The inspector reviewed AP 1014-dated EVALUATION:
January 7, 1981 " Administration of the TMI-1 Onsite and Offsite Emergency Duty-Roster." This procedure described the method for assigning individuals to the TMI-I Offsite Emergency Organization.
Personnel are currently' assigned to the Offsite EDSR based on satisfying the position title / expertise required for the respective positions by Attachment-1 to AP 1014.
These provisions are discussed for offsite personnel in the evaluation of Item 22-56.
Additionally, the in-spector reviewed completed position descriptions which will be used as additional telection criteria and form the basis of individual assignments to the emergency organization.
The inspector determined that the licensee had implemented an approved procedure governing assignment of personnel to the Offsite EDSR.
Additionally, the use of position descriptions will enhance the selection of personnel to tne EDSR.
This item is therefore closed.
e.
(Closed)
Description of the interfaces between the elements of onsite and offsite emergency organizations with such interfaces reflected in the EPIPs (289/80-22-60).
LICENSEE Table 8 of Revision 3 to the TMI-1 Emer-RESPONSE:
gency Plan implemented on January 2, 1981, incorporate expanded definitions of the specific responsibilities and interfaces between functional elements for emergency response personnel. Specific l
responsibilities are also reflected in revision to the applicable Emergency Plan Implementing Procedures.
i NRC The inspector reviewed Table 8,
EVALUATIONL Revision 3 to the licensee's Emergency l
Plan and noted that it provided the
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expanded description of spec-ific responsibilities and inter-faces and reporting chains for the various members of the licensee's
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onsite and offsite emergency organizations.
Additionally, the inspector reviewed
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a training lesson plan, " Basic In-doctrination for Essential Personnel,"
which included responsibilities and interfaces of portions of the emergency organization.
The inspector also reviewed the Emergency Plan Implementing Procedures and found that they reflected the emergency functional titles and responsibilities consistent with those described in the TMI-1 Emergency Plan.
Based on the above findings, implementation of the licensee's response is considered adequate to close this item.
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(Closed)
Development of formal, approved lesson plans containing
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student performance objectives and a means to measure performance again:t those objectives for each functional area of emergency activity (289/80-22-61).
LICENSEE Administrative Procedures (AP 1052) and RESPONSE:
Section 6.5, TMI Training Department Ad-ministrative Manual will delineate training requirements for personnel involved in emergency response activities uy functional area.
The TMI Instruction Manual provides guidance for the development of formal lesson plans which include student performance objectives and the means to measure performance against those objectives.
Section 7, TMI Training Department Administrative Manual will reflect those requirements.
The TMI Training Department Adminsitrative Manual is scheduled to be published by February 28, 1981.
A formal Emergency Plan Training Program is being developed which will be consistent with all of the above.
Completion of program development and commencement of the first iteration of the new training program is scheduled for April 1, 1981.
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NRC Tha inspector reviewed Administrative EVALUATION:
Procedure 1052, dated December 15, 1980,
". Three Mile Island Unit.1, Emergency Planning Training," and the Training Department Manual and noted that.the content was consistent with the licensee's response.
The licensee had completed a major revision of the entire emergency planning training program resulting in substantial improvement of th.e training program.
The inspector reviewed the implementation of these procedures and found that lesson plans are being written in.accordance with the training program procedures for those training sessions conducted since initiation of the new training program
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in April, 1981. Performance of students was measured through quizzes and periodic drills, as specified in AP 1052 and the TMI-1 Training Manual.
' Bas *ed on the.above findiass, the inspector determined that the licenste had it-plemented the actions outlined in the response and therefore, tais item is closed.
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(Closed)
In the procedure which governs the conduct of the emer-gency plan training program (EPIP 1004.24) specification of:
(289/80-22-62)
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The means by which training will be documented.
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The designation of instructors and their qualification.
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The manner in which members of the emergency organization will be trained in changes to procedures, facilities or equipment which occur in the period between scheduled training session.
LICENSEE The above noted items are specified in RESPONSE:
the following' relevant documentation.
AP 1052 and Section 6.5 of the TMI Training Department Administrativt Manual provide that the TMI Training Department will document all training and will prepare and main'.ain required records and reports.
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Section 5, TMI Training Department Ad-ministrative Manual, scheduled for' pub-lication by February 28, 1981, will establish qualifications and selection criteria for instructor personnel.
This manual, includes selection criteria for those instructors who will conduct emergency plan related instruction.
AP 1052 and Section 6, TMI Training Department Administrative Manual, provide that Emergency Plan Training is cyclic in nature.
Further, Section 6 provides that the program shall be maintained to reflect the following:
... Changes in Regulatory Requirements.
... Changes in Applicable Codes, Standards and guides.
.. Experiences at the facility.
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... Audit results.
. Critiques (r appropriate).
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Changes will be tracked and managed con-sist
.ith in place management controls.
NRC The inspector reviewed Administrative EVALUATION:
Procedures 1052, "TMI-1 Emergency Planning Training" dated December 15, 1980 and noted that there were provisions for training documentation and designation of instructors consistent with the description in the licensee's response.
Additionally, the inspector selected samples of training courses which had been conducted and found that the training documentation was being maintained.
With regard to trcining on changes to procedures, facilities, or equipment, the inspecter noted during the review of AP 1052 and Section 6 of the Training Department Manual that the program
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provided for annual updating of the emergency planning training program.
The procedures did not, however, provide for training on changes in procedures or equipment for the period between annual training cycles.
This was discussed with the licensee who indicated that AP 1055, Draft B " Maintaining Emergency Preparedness" provides a mechanism to identify and track necessary supple-mentary training or changes to the emergency planning training program. The inspector reviewed AP-1055 and found this to be an acceptable method to im-plement additional training or changes to the training program.
Based on the above findings, this item is considered closed.
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(Closed)
Coordination of the content of training for offsite support groups with the offsite support groups to whom the training will be provided (289/80-22-63).
LICENSEE Administrative Procedures (AP 1052) pro-RESPONSE:
vide that the content of all emergency response training provided specifically for offsite emergency support organizations will be coordinated with target audience representatives prior to presentation.
NRC The inspector reviewed procedure AP EVALUATION:
1052, Revision 0, dated December 15, 1980.
Section 3.1.1 and Enclosure 1 of the procedure specified that training programs would be offered for the following offsite groups on an annual basis:
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Pennsylvania Emergency Management Agency;
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Dauphin County Emergency Management Agency;
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York County Emergency Management Agency;
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Lancaster County Emergency Manage-
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Pennsylvania Burecu cf Radiation.
Protection; Pennsylvania State Police;
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Middletown Police Department;
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Dauphin County Fire and Ambulance;
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York County Fire and Ambulance;
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Lancaster County Fire and Ambulance;
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Cumberland County. Fire and Ambulance;
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Hershey Medical Center; and
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The above groups will be invited to participate in the licensee's General Emergency Plan Training Course and various specialized courses listed in the procedure.
The inspector noted that AP 1052 provided for forwarding the General Emergency Planning Training lesson plans to offsite response organizations, but there were no provisions for coordinating the content of the specfalized training.
This was discussed with the licensee who indicated that a Permanent Change Request (PCR) to add a requirement to Section 3.25 which would indicate that the content of both the introductory general training as well as specialized training j
would be coordinated with these groucs.
The inspector contacted representatives of the Pennsylvania Bureau of Radiation Protection and verifed that the licensee
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had, in fact, contacted this agency to
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coordinate training content.
Based on the.above findings, this item is closed.
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(0 pen).
Completion of at least "one training iteration" in accordance with the training program (289/80-22-64).
LICENSEE-
-The current training program objective RESPONSE:
is to complete development of a formalized training program, consistent with approved
. procedures, to commence the first cycle of that program by April 1,1981 and to complete at least one cycle of that
_ program prior to restart.
In the interim, onsite training continues, to include GET, basic health physics, emergency plan orientation and familiarization training / training drills.
NRC The inspector reviewed the emergency EVALUATION:
planning training program described in AP 1052 and found that the training program had been developed and that training con-sistent with this program commenced in April, 1981. As of the date of this in-spection, emergency planning indoctrination training for essential and non-essenital personnel had been completed and specialized training for specific skills and functions had commenced.
In addition, several drills had been conducted to instruct and evaluate personnel assigned emergency functions. A training matrix had been developed to ensure that specialized emergency function training will be conducted.
As one co plete training iteration has not been conducted, this item remains open and will be reviewed during a subsequent inspection.
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(Closed)
Development of selection and qualification criteria for emergency planning instructors (289/80-22-65).
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LICENSEE Section 5, TMI Training Department Ad-RESPONSE:
ministrative Manual, currently under
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development and scheduled for publication by February 28, 1981, will provide specific selection and qualification criteria for those instructors who will conduct emergency plan related training.
In addition, the site emergency prep.reeness staff'will assist in the development and presentation of the training program.
NRC The inspector reviewed Section 5 of the EVALUATION:
TMI-Training Department Administrative Manual dated April 24, 1981 and noted that the content was consistent with the licensee's response.
Included as a part of the manual was a position description, listing the education, experience, training, and duties of an Instructor, Emergency Plan / EPIP.
The inspector determined that the licensee had implemented the actions in the response and this item is, therefore, closed.
k.
(Closed)
Evaluate and, as necessary, upgrade communications be-tween the EAC, EOFs, and Control Room for the purpose of transmitting and receiving environmental monitoring informai.on and direction (289/80-22-67).
d LICENSEE The dedicated telephone communications RESPONSE:
systems, required for communication be-tween the EAC, EOF-and Control Room, and appropriate redundant systems, were in place and operationally tested during the August 26, 1980 emergency exercise.
These include dedicated lines connecting the Control EOF, EOF-EACC and Control Room EACC; radio communications linking the EACC-EOF Control Room; and common-
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user telephone circuits.
There are
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provisions for periodic checks of the
functional operability of these systems.
NRC ine inspector verified that the comm-EVALUATION:
unicacions system between the EAC, EOF
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and Control Room were in' place and.
operational as stated in the licensee's response.
This item is closed.
1.
(0 pen)
Determine the audibility of the reactor building evacuation alarm throughout the reactor building (289/80-22-63).
LICENSEE The reactor building evacuation alarm RESPONSE:
system will be modified to improve audibility. This modification (LM #29)
supplements the present warning system avith warning lights, additional sneakers and expanded intercom terminals to ensure the evacuation message is audible throughout site.
The majority of the required material has been received.
Modification will be completed prior to restart.
In addition, the site alert system is being modified by the addition of three electronic siren systems which will provide an additional public address system capability site-wide.
Completion of this modification is scheduled for July 1, 1981.
NRC Modifications to the reactor ouilding EVALUATION:
evacuations alarm system have not yet been completed and are still scheduled for completior, in July 1981.
As such, this item remains open.
m.
(Closed)
Coordination of EOF emergency work-space allocation with the NRC Region I Office (289/80-22-69).
LICENSEE Based on recent completion of a project RESPONSE:
to renovate / upgrade the TMI Observation Center for its primary purpose as a Visitors Center, reorganization and work space re-allocation are in progress.
Upon completion of the basic internal layout of the interim EOF at the TMI Observation Center, specific work space allocation and relocation of NRC telephones will be accomplished.
This effort is scheduled for completion by April 1, 1981, i
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When the guidance in NUREG 0696 is finalized, selection, design and construction of a permanent EOF will be accomplished.
Specific work space allocation and communications requirements will be coordinated with the NRC Region I during that process.
NRC The inspector toured the licensee's EOF EVALUATION:
and noted that the NRC ENS and HPN had been relocated to a work area measuring about
20 feet by-12 feet.
This area was de-signated as the eraergency work-space for the NRC.
Discussion with the NRC Region I Emergency Preparedness Coordinator verified that the installation of the ENS and HPN, as well as work space requirements, had been coordinated with the NRC.
This item is clostd.
n.
(Closed)
Interface emergency, abnormal ano alarm condition pro-cedures with the-Emergency Plan Implementing Instructions (procedures 1004.1 through 1004.4) to ensure prompt de-tection and classification of emergencies and to resolve aprarent conflicting course of action for radiation protection and chemistry personnel (289/80-22-71).
LICENSEE Emergency and abnormal procedures have RESPONSE:
been review:d to determine which require specific interface with Emergency Plan Im-plementing Procedures 1004.1 through 1004.4 to assure appropriate emergency response. That review has been completed and procedures have been identified for further review and revision.
The revision process is ongoing and procedures are being cross referenced to assure prompt detection and classification of emergencies and to resolve apparent response conflicts.
The shift supervisor is required to consult the emergency and abnormal procedures which provide specific reference and interface to the EPIP's.
Therefore, review action for alarm procedures is not appropriate in this context.
The
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revision process will be completed prior to restart.
NRC Tha inspector reviewed 41 emergency and EVALUATION:
abnormal procedures and noted that they had been reviewed and revised to interface with EPIPs 1004.1 through EPIP 1004.4.
This review also revealed that conflicting courses of action for radiation protection and chemistry personnel had been resolved.
This item is closed.
o.
(Closed)
Development of procedural guidelines for the conduct of in plant radiological surveys (radiation, air and contamination) to support-the accident assessment and in plant radiation protection schemes (289/80-22-74).
LICENSEE The following Emergency Plan Implementing RESPONSE:
Procedures have been developed to provide procedural guidelines for the conduct of in plant radiological surveys to support accident assessment and in plant radiation protection programs during emergencies.
1.
EPIP 1004.9 -
In-Plant Radiological Controls During Emergencies 2.
EPIP 1004.31 - Airborne Radioactivity Sampling and Analysis 3.
EPIP 1004.15 - Post Accident In-Plant Sampling The above EPIP's have been PORC approved and were implemented with Revision 3 to the TMI-1 Emergency Plan on January 2, 1981.
NRC The inspector reviewed the following EVALUATION:
procedures to verify that they provided procedural guidelines for the conduct of in plant radiological surveys (radiation, air and contamination) as stated in the licensee's response:
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EPIP 1004'.9, Revision 0, December
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.15, 198C, "In-Plant Radiological Controls During Emergencies";
EPIP 1004.31, Revision 0, December
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15, 1980, " Airborne Radioactivity Sampling and Analysis";
EPIP 1004.15, Revision 0, December
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15, 1980, " Post Accident In-Plant Sampling ".
The inspector noted that within the three EPIPs referenced in the licensee's response (1004.9, 1004.31, and 1004.15),
only one (1004.31) had clear provisions for conducting' surveys in plant during emergencies. These provisions were made by reference to Radiation Control Procedures (RCP) 1605, 1606, 1607, and 1616.4 in EPIP 1004.31.
The inspector requested copies of the aforelisted RCPs and noted that RCP 1606 had been rescinded, with its content included in RCP 1605 and in a new procedure, 1605.1.
In addition, the reference to procedure 1616.4, which was purported to describe the methods for handling' air samples, was erroneous.
Pro'.edure 1616.4 was a Unit 2 procedure related to the maintenance of respiratory protection devices.
The inspector reviewed the following procedures to verify that they specified the procedural guidelines for radiation, air and contamination surveys:
RCP IC05, Revision 9, April 15,
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1981 " Portable Air Sacoling for
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Particulates and Iodine";
RCP 1605.1, Revision 2, February
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20, 1981, " Analysis of Portable Air Samples for Particulates and Iodine"; and RCP 1607, Revision 3, July 23,
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1980, " Sampling of Radioactive Gas".
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This review indicated that, within the.
scope of procedures referenced in the licensee's response, methods had only been specified for airborne radioiodine, particulate and radioactive gas sampling.
While EPIP 1004.9, step 4.7.3, Radiation Surveys, stated that " radiation levels must be determined while performing other duties...with all information documented for use as guidance by others requiring access," the procedure failed to reference or contain the methods for performing the surveys.
The inspector reviewed the following procedures which related to the "other duties" stated in step 4.7.3 of procedure 1004.9 and noted that they too failed to describe or reference the survey methods to implement the step:
EPIP 1004.15,
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EPIP 1004.16,
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EPIP 1004.18,
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EPIP 1004.21, and
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EPIP 1004.31.
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The inspector held discussions with licensee personnel to review the findings.
As a result of these discussions, the licensee initiated a Procedure Change Request wherein procedure-1004.9 was revised to include references to RCPs 1602, 1605 and 1609 relative to contamination and general area radiation surveys in-plant.
Based upon the procedure revision, the licensee has specified the methods and equipment for in plant radiation, air and contamination surveys. This item is closed, p.
(Closed)
Development of procedures for sampling and analyzing containment air under accident conditions (289/80-22-75).
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LICENSEE EPIP 1004.31, entitled " Airborne Radio-RESPONSE:
activity Sampling and Analysis", has been revised to include procedurer for sampling and analyzing containment air under accident conditions. A new containment air sample station, (Task #LM-24B), is currently being evaluated by Engineering.
The tentative date for material delivery i
is 3/1/81.
Implementation date for the system is tentatively set for 8/1/81.
Procedures will be established to reflect its operation when completed.
NRC The inspector reviewed EPIP 1004.31, Re-EVALUATION:
vision 0, December 15, 1981, " Airborne Radioactivity Sampling and Analysis",
and noted that it had not been revised to include proceaures for sampling and analyzing containment air under accident conditions as stated in the licensee's response.
Further review indicated that a procedure change request dated March 26', 1981 had been submitted and approved by the Plant Operations Review Committee.
The change refers the user to RCP 1631, " Sampling
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of Waste Gas Decay Tanks and Reactor Building".
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The inspector reviewed Procedure RCP 1631 and determined that the methods and procedures for containment sampling and analysis under accident conditions were clearly specified.
In discussing the sample station with licensee personnel, the inspector determined that the "new containment air sample station" discussed in the licensee's response referred to improvements to the existing station which met interim NUREG-0578 requirements.
This item is closed.
q.
-(Closed)
Review of Procedure 1004.15 against actual post-accident sampling system design upon completion of the NUREG 0578 evaluation currently in progress (289/80-22-76).
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LICENSEE Upon completion of the NUREG 0578 eval-RESPONSE:
uation, Procedure 1004.15 will be reviewed against actual post-accident sampling system design.
Completion will be prior to restart.
NRC The inspector noted that the licensee's EVALUATION:
interim post accident sampling system as described in Amendment 23 to the Restart Report was in place.
The licensee had completed preliminary planning for im-provements to the system.
These improvements were ' scheduled to begin the week cf May 11, 1981. The inspector noted that the Procedure 1004.15 had been reviewed against the design of the existing system as stated in the licensee's response and had been tested during several drills.
This item is, therefore, closed.
r.
(Closed)
Description of the metheas and equipment to be used for environmental radiation and contamination surveys at onsite locations to include:
(289/80-22-77)
1.
Specification of pre-determined survey points or routes; 2.
Description of ultimate disposition of original data sheets; 3.
Specification of the central collection point for samples; 4.
Description of primary and backup communications provisions; and 5.
Specification of the means of team transportation.
LICENSEE Emergency Plan Implementing Procedure RESPONSE:
EPIP 1004.10 identifies pre-determined survey sites, provides for team trans-portation, describes team communications capabilities and procedures, and provides instructions concerning the ultimate disposition of survey sheets.
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EPIP 1004.31 specifies procedures to be followed in collecting samples and the
central collection point for all samples.
NRC The inspector reviewed Procedure 1004.10, EVALUATION:
Revision 0, dated December 15, 1980,
"Onsite Radiological Monitoring", and noted that the four items had been specified for air radiation surveys however, there were no provisions for contamination or radiation surveys (S,
.T) either contained in or referenced in Procedure 1004.10.
While Procedure 1004.10 referenced Procedure EP 1004.31, Revision 0, dated December 15, 1980, this procedure did not describe provisions for conducting radiation or contamination surveys.
The inspector discussed these findings with licensee management who initiated a
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Permanent Change Request to EPIP 1004.10, dated May 5, 1981, which included the procedure to be followed for onsite environmental radiation and contamination surveys.
Based on the above findings, this item is closed.
s.
(Closed)
Description of the methods and equipment to be used for offsite environmental radiation and contamination surveys to include:
(289/80-22-78)
1.
Specification of pre-determined survey points or routes; 2.
Specification of the collection point for samples; 3.
Description of back-up communications methods; 4.
Description of the means to be employed by the teams to obtain transportation.
LICENSEE Emergency Plan Implementing Procedure RESPONSE:
EPIP 1004.11 identifies pre-determined survey sites, provides for team trans-
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portation, describes team communications capabilities and procedures and provides instructions concerning the ultimate disposition of survey sheets.
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EPIP 1004.31 specifies procedures to be followed in collecting samples and the central collection point for all samples.
Procedures are in place fo-operation of all equipment associated with the offsite environmental surveys.
NRC The inspector reviewed Procedure 1004.11, EVALUATION:
Revision 0, dated December 15, 1980, "Off-site Radiological Monitoring", and noted that the procedure did not contain provisions for backup communications or collection points for samples once the EACC assumed control of the offsite monitoring effort. In addition, the procedures failed to specify the met. hods and equipment for radiation and contamination
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surveys. While Procedure 1004.-11, Step 4.8 directed the team to perform " dose rate surveys...in accordance with Radioactivity Samoling and Analysis,
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Procedure 1004.31", this procedure
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failed to describe or reference'the equipment to be used.
The inspector held discussions with licensee management who initiated PCRs
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to Procedures 1004.11 and 1004.31 to include the procedure to be followed in
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performing offsite environmental radiation and contamination surveys.
Based on the above findings, this item is closed.
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(Closed)
Development of approved procedure describing the detailed actions to be taken to implement the emergency Rad-iological Environmental Monitoring Program (REMP3 (289/80-22-79).
LICENSEE The TMI REMP consists of an extensive, RESPONSE:
monitoring program which is functional on a continuing basis during normal operations and an emergency REMP which is guided procedurally by Emergency Plan Implementing Procedure 1004.12.
In the event of an emergency, EPIP 1004.12 pro-vides for the implementation of increased environmental monitoring in direct re-sponse to a declared emergency.
This procedure provides guidance on the
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dispatch of a mobile environmental assessment laboratory and other mobile monitoring teams, identifies TLD locations and provides guidance on the type environmental samples to be collected, where and in what quantities.
An additional procedure, now under development by the Environmental Assessment Coordinator will specify the procedures to be followed to determine the number and type of samples to be collected based on the nature of the emergency.
This procedure will be implemented prior to restart.
NRC The inspector reviewed Procedure 1004.12, EVALUATION:
Revision 0, dated December 15, 1980,
" Environmental Monitoring", and noted that the content was cons! stent with the licensee's response.
In addition, the licensee had developed a procedure for use by the Environmental Assessment Coordinator in determining the procedures to be followed in implementing the emergency REMP (ECP 1606, Revison 0, dated December 9, 1980, " Emergency
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Radiological Env'ronmental Monitoring Program").
The inspector determined that the licensee had implemented the actions outlined in their response.
This item is, therefore, closed.
L u.
(Closed)
Dev91opment of provisions for comparing the results of projected dose calculations with action levels and Pro-tective Action Guides of the Commonwealth of Pennsylvania as a basis for recommending the implementation of protective actions in behalf of the general population.
(289/80-22-80)
LICENSEE Emergency Plan Implementing Procedures RESPONSE:
(EPIP) 2004.2 throuch ;^04.4 (Alert, Site Emergency and General Emergency) and
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EPIP 1004.7 (Offsite Dose Projections)
implement provisions for comparing the
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results of projected dose calculations with action levels and protective action guides of the Commonwealth of Pennsylv.nia.
This comparison serves as the basis for
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recommending the implementation of protective actions in behalf of the
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general population.
NRC The inspectors noted that EPIP 1004.2 EVALUATION:
(Step 4.23 and Attachment 1,Section IV), EPIP 1004.3 (Step 4.24 and Attachment 1,Section IV) and EPIP 1004.4 (Step 4.23 and Attachment 1,Section IV) had been revised to provide for
- omparison of projected dose calculatians with action levels and protective action guides.
EPIP 1004.7, Revision 1, February 10, 1981, "Offsite Dose Projections",
did not appear to have been revised.
Discussion with licensee personnel indicated that procedure 1004.7 had two implementation methods-computer and manual.
The computer program portion of the procedure had, in fact, been modified to perform the required comparisons.
The manual back-up procedure, however, had not been so modified. As a result of the discussion between the inspector and licensee management, a PCR was issued for Procedure 1004.7, Attach-ment VIII, Paragraph 3, whicn includec the performance of the projected dose versus Commonwealth of Pennsylvania PAG comparison.
Based on the above findings, this item is closed.
v.
(Closed)
Formulation of provisions for immediate notification of appropriate state or local agencies in the event assessment actions indicate an actual or potential exposure to the whole body or thyroid of persons in the plume exposure EPZ equal to or greater than the lower limits of the
EPA Protective Action Guides for the child (289/80-22-81).
LICENSEE Emergency Plan Implementing Procedure RESPONSE:
EPIP 1004.2 through 1004.4 (Alert, Site
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Emergency, Ganeral Emergency) specify actions to ba taken at the various classifications of emergency.
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Included are provisions for the prompt notification of the Bureau of Radiation Protection in the event potential exposure is equal to or greater than EPA Protective Action Guides.
NRC The inspector noted that EPIP 1004.2 EVALUATION:
(Step 4.23 and Attachment 1,Section IV), EPIP 1004.3 (Step 4.2.4 and Attachment 1,Section IV), and EPIP 1004.4 (Step 4.23 and Attachment 1,Section IV) had been revised to provide for immediate notification vf the Pennsylvania Bureau of Radiation Protection in the event potential exposure is equal to or greater than specified EPA Protective Action Guides. The inspector also discussed the change with representatives of the Pennsylvania Bureau of Radiation Protection who indicated that the notification concept was consistent with the state plan. These changes, in conjunction with those for item 289/80-22-80, adequately resolved the item.
s Based on the above findings, thisaitem is closed.
w.
(0 pen)
Inclusion of high range noble gas monitors and radio iodine effluent analyses in the assessment scheme (289/80-22-82).
LICENSEE High-range noble gas monitor readings RESPONSE:
and radiciodine effluent analyses will be included in the offsite dose projection procedure, EPIP 1004.7 (PORC approved 8/12/80) when the high range capabilities become available by January 1, 1982 as discussed in our response to NUREG 0737 of 1/23/81.
NRC The inspector held discussions with EVALUATION:
licensee personnel to determine the status of the installation of high range noble gas and radiciodine monitoring capabilities.
Licensee personnel stated that the delivery date for equipment to
satisfy the interim requirements of NUREG-
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0578 had slipped.
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Further discussion indicated that the January 1, 1982 date referenced in the licensee's response was in relation to the long-term requirements.
Thus, the licensee.will have a high-range noble gas and radiciodine monitoring capability (interim) should restart occur prior to the January 1, 1982 date.
The inspector noted that the present status and plans for the interim high range monitoring were consistent with Amendment 23 to the licensee's Restart Report and Supplement 3 to NUREG 0680.
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Since the interim high-range monitoring equipment was not available, inclusion in the assessment scheme (EPIP 1004.7)
had not been completed.
This item remains open.
x.
(0 pen)
Procedures for collecting and analy:ing absorbent media for radioiodine in gaseous effluents under accident conditions (289/80-22-83).
LICENSEE EPIP 1004.31, " Airborne Radioactivity RESPONSE:
Sampling and Analysis" (PORC approved 8/6/80), contains the procedures for collecting and analyzing absorbent media for radioiodine.
NRC The inspector reviewed EPIP 1004.31 and EVALUATION:
noted that it did not pertain to the sampling and analysis of radioiodine in gaseous effluents.
Discussion with licensee personnel indicated that the response was incorrect in that it did not address the item.
Further discussion indicated that the reply should have been similar to the response for item
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22-82. Specifically, the equipment to meet the interim high-range radiciodine monitoring was not yet available but would be installed prior to re-start.
The inspector noted that these statements were consistent with Amendment 23 to the licensee's restart report and with Supplement 3 to NUREG 0680.
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Since the interim high-range radioiodine monitoring equipment was not installed, the corresponding procedure had not been written.
This item remains open, y.
(Closed)
Development of procedures which describe the detailed actions to be implemented or considered to be implemented to ensure continuity of the radiation protection program during emergencies (289/80-22-84).
LICENSEE EPIP 1004.9, "In-Plant Radiological Con-RESPONSE:
trols During Emergencies" has been reviewed and revised to ensure continuity of the radiological protection program during emergencies.
NRC The inspector reviewed EPIP 1004.9, Re-EVALUATION:
vision 0, December 15, 1980, and compared its content with the draft EPIP 1004.9 reviewed during the previous appraisal.
The inspector noted that the actions to be taken and the responsible Individuals were more clearly defined through specific titles and references to interfacing procedures.
Based on the above findings, this item is closed.
z.
(Closed)
Provisions for monitoring individuals in the " Processing Center" or assembly areas that will result in the de-tection of the 1,000 dpm (100 cpm) action level (289/
80-22-85).
LICENSEE EPIP 1004.20, " Personnel / Vehicle Monitor-RESPONSE:
ing," has been revised to define procedures for monitoring individuals evacuating the protected area at assembly areas.
Monitoring procedures provide for detection of the 1000 dpm contamination action level. The procedure will be implemented under the direction of a Radiation Assessment Coordinator.
The Radiological Controls Coordinator will assign a team leader to each of the monitoring and decontamination teams who will in turn dispatch team members and coordinate their function.
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NRC The inspector reviewed Procedure 1004.20, EVALUATION:
Revision 0, dated December 15, 1980,
" Personnel / Vehicle Monitoring and Decontam-ination",
This procedure was noted to provide for monitoring of individuals upon evacuation of the site (which would occur for all emergencies of the site and general class).
The inspector noted that the equipment specified would provide the required degree of sensitivity.
This item is closed, a.a.
(Closed) Inclusion of data sheets in Procedure 1004.20 to record survey results (289/80-22-86).
LICENSEE Individual survey data sheets have been RESPONSE:
included as part of EPIP 1004.20.
In addition, packets of forms are stored with the monitoring equipment and are available to the monitor teams upon implementation of this procedure.
Forms are provided in sufficient numbers to accomplish initial monitoring and properly
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record survey results.
NRC The inspector reviewed EP 1004.20, Re-EVALUATION:
vision 0, December 15, 1980, " Personnel /
Vehicle Monitoring and Decontamination",
and noted that Personnel Contamination Report and Vehicle Contamination Report data sheets had been developed and included as Attachments II and III, respectively. The inspector also inspected a sampling of emergency kits and verified that packets of these forms were stored within.
Based on the above findings, this item is closed.
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(Closed) Development of specific action levels and judgement guidance for use in determining the need for evacuation of the protected area and the site for Alert, Site and General Emergencies (280,80-22-87).
LICENSEE Emergency Plan Implementing Procedure RESPONSE:
(EPIP) 1004.2 (Alert) will be revised by
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t March 1, 1981 to provide specific judgement guidance concer' (ng potential radiological conditions whien may justify a judge-mental decision to effect a partial evacuation of the site.
Conditions prevailing for Unusual Event and specified actions for Site and General Emergencies obviate the need for additional guidance concerning evacuation.
NRC Tns inspector reviewed EPIPs 1004.2 EVALUATION:
through 2004.4 and noted that.the pro-cedures content was inconsistent with the licensee's response.
EPIP 1004.2 did not provide guidance concerning potential radiological conditions which may justify a judgemental decision to effe'. a partial evacuation of the site.
The inspector also noted that EPIP 1004.3, Site Emergency, Step 4.23, stated "If site evacuation is deemed nece s sa ry,.
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action levels and judgement guidance.
EPIP 1004.4, Step 4.2 provides for
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automatic evacuation of the site in the event of a general emergency.
The inspector held discussions with licensee personnel to determine why the actions implemented appeared inconsistent with the licensee's te;ponse.
During these discussions the inspector was informed that the philosophy had been revised since submission of the original response.
It had been determined that the protected area alone would never be evacuated during an Alert (EPIP 1004.2)
A full site evacuation automatically would occur for all site and general emergency classes.
The inspector reviewed this philosophy and found it to be consistent with the guidance contained in NUREG-0654. The inspector also noted that a PCR had been issued to correct the discrep'ancy in EPIP 1004.3, Step 4.23, thereby correctly reflecting the aforediscussed philosophy.
This item is closed.
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separate procedure had been writen. As of the time of the inspection, the new procedure was still in final draft and had been submitted to the PORC for approval. The inspector reviewed the procedure Ap 1055, Draft B, " Maintaining Emergency Preparedness", and noted that
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the procedure contained the information described in the licensee's response.
Prior to the completion of the inspection, the procedure had been reviewed and approved by the PORC.
This item is closed.
4.
Exit Interview At the conclusion of the inspection, on May 7, 1981, the inspectors met with the licensee representatives denoted in paragraph 1.
Du; ing this meeting, the inspector summarized the purpose and scope of the inspection and the inspection findings.
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c.c.(Closed) Provisions for notifying the offsite medical treatment facility prior to transport of a contaminated and/or injured individual (289/80-22-89).
LICENS6E Emergency Plan Implementing Procedures RESPONSE:
(EPIP) 1004.16, " Contaminated Injuries /
Radiation Overexposure," provides for notification of the offsite medical treatment facilities and has been coordinated with the offsite medical support agencies.
NRC The inspector reviewed EPIP 1004.16, Re-EVALUATION:
vision 0, dated December 15, 1980 and noted that Step 4.73 provided for not-ification of the offsite medical treat-ment facility.
Based on the above findings, this item is closed.
d.d. (Closed) Description of the management controls to be used for assigning responsibility for corrective actions and their completion dates and to assure that assigned actions are completed in accordance with the es-tablished schedule and adequate to resolve the noted deficiency (289/80-22-91).
RESPONSE Administrative Procedure AP 1051, "Emer-gency Planning Drills", describes the current action item management system.
This system is a computer-tracked system which reflects items to be accomplished, responsible individuals / organizations and desired completion dates.
The system provides periodic status reports to insure proper supervisor / management involvement and approval of corrective actions.
In the case of AP 1051, the system is generally oriented to tracking and assuring correction of deficiencies in emergency preparedness identified-through drills and evaluations.
NRC The inspector reviewed AP 1051, Revision EVALUATION:
0, dated 12/31/80, " Emergency Planning Drills", and noted that it contained no information relative to the action item management system. Discussion with licensee personnel indicated that, since the submittal of the initial response, a
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