IR 05000289/1986016

Insp Rept 50-289/86-16 on 860922-23 & 1015-17.No Violation Noted.Major Areas Inspected:Emergency Preparedness Program Including Recent Changes,Knowledge & Performance of Duties & Licensee Audits

ML20215D605
Person / Time
Site:	Three Mile Island
Issue date:	12/11/1986
From:	Amato C, Craig Gordon, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20215D568	List: IR 05000289/1986016 ML20215D566
References
50-289-86-16, NUDOCS 8612160417
Download: ML20215D605 (11)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /86-16 Docket. N License No. DPR-50 Priority --

Category C Licensee: GPU Nuclear Corporation k P. O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mile Island - Unit 1 Inspection At: Middletown and Harrisburg, Pennsylvania

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Inspection Conducted: Septe,mber 22 - 23 and October 15 - 17, 1986 Inspectors: . FA . / l>- /o C' Z . don, E ,

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'W &'hahrusyCKe/, Emergency date P wedness SectYon Inspection Summary: Two part inspection conducted on September 22 - 23 and October 15 - 17, 1986 (Report No. 50-289/86-16).

Areas Inspected: Routine, announced followup inspection of the emergency preparedness program including recent changes, knowledge and performance of duties, and licensee audit Results: No violations were identified. The changes raade by consolidating the TMI-1, TMI-2, and Oyster Creek Emergency Plans into the GPU Nuclear Corporation Corporate Emergency Plan were in accordance with 10 CFR 50.54(q), i.e., the overall effectiveness of the plans have not been decreased. The plans, as changel, continue to meet the standards of 10 CFR 50.47(b).

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DETAILS 1. Persons Contacted R. Danrehy, Manager, Environmental Laboratory D. Hassler, Licensing Section P. Kovach, Corporate Emergency Planner G. Giangi, Manager, Emergency Preparedness, GPU Nuclear H. Hukill, Vice-President GPUN, and Director TMI-1 G. Simonetti, Emergency Preparedness Coordinator, TMI N. Brown, Emergency Preparedness R. Eherts, Emergency Preparedness C. Incorvati, QA Audits

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0. Shalikashvili, Manager, Plant Training TMI 2. Licensee Actions on Previously Identified Items (Closed) 50-289/85-23-01: The increase in the amount of activities taking ' place in the Control Roora and lack of security has the potential for excessive overcrowding during the initial stages of the emergenc The inspectors reviewed the memorandum dated February 11, 1986 from J. J. Bevelaqua, Emergency Preparedness Manager, to Unit 1 Emergency Directors and determined that it adequately reinforced a previous security directive which gives an Emergency Director the authority to assign site protection personnel to the Control Room to prevent overcrowdin (Closed) 50-289/85-23-04: The air sample taken in the area of the Containment Atmosphere Post Accident Sampling System was not repre-sentative of the actual breathing air spac The inspectors reviewed an internal memorandum dated January 9, 1986 from D. E. Tuttle, Radiological Field Operations Manager to J. J. Bevelaqua, Emergency Preparedness Manager stressing the importance of using proper methods for obtaining worker breathing zone air samples. A copy of the memo was provided to those tech-nicians who are expected to wear personal air sampling devices, (Closed) 50-289/85-23-05: The boat used for environmental monitoring is not initially equipped with essential safety items such as ade-quate lighting, a reliable generator, and life preserver The inspectors reviewed a memo dated January 29, 1986 from G. Barker, Environmental Controls to J. J. Bevelaqua, Emergency Preparedness Manager and determined that adequate safety items will be available when neede .. _ - _ _ _ _ _ _ _ _

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3. Changes to the Emergency Preparedness Program Two significant changes to the Emergency Preparedness Program have occurred since the previous inspectio First, a consolidation of the GPU Site Emergency Plan was conducted by the Corporate Emergency Preparedness group. A review of the new CPU Nuclear Corporation's Corporate Emergency Plan is provided in Section Secondly, a new Emergency Preparedness Coordinator assumed duties in June 1986 and is responsible for carrying out the major functions of the progra . Review of the GPU Nuclear Corporation Corporate Emergency Plan On March 11, 1986 the GPU Nuclear Corporation's Emergency Plan was sub-mitted to the NRC by the licensee which consolidated the TMI-1, TMI-2 and Oyster Creek Plans. The purpose of the consolidation was to identify generic information at each site and compile it into one document. Basic changes found in the new Plan are elimination of extraneous or repetitive information, and reference of certain documents such as evacuation time estimates, prompt notification system description, and letters of agree-men The inspectors reviewed the new Plan against the requirements of 10 CFR 50.47, 10 CFR 50, Appendix E, and criteria of NUREG-0654. Special effort was given to Emergency Action Levels (EAL's), changes in the emer-gency response organization, and new information affecting coordination with offsite group Based upon the review, the following is a list of changes and deficient areas of the new Plan requiring attention by the licensee. These comments were reviewed and discussed with the licensee's corporate emergency planning staff. The review does not include comments on EAL's since the revised EAL's for Oyster Creek were not completed at the time of the inspection. These items are collectively identified as follow-up item 50-289/86-16-0 Licensee action regarding these items will be reviewed in a subsequent inspectio Organization-Section . Figure 19 - The on-shift emergency organization chart for the combined plan (Figure 19) has a position entitled " Site Protection Sergeant / Corporal" who reports to the ED. The TMI-1 and TMI-2 plans did not have this position on their organizational chart (Figure 12A). Assignment of Security Personnel should be consistent with the information provided in Table 13, page E13- . Section 5.2.2.1,p. 38 - One non-delegable duty was added to the ED and ESD responsibilities in the combined plan - serve as principal " point of contact" for receiving NRC advice and directives. It is unclear if such advice or directives would include any technical (engineering, health physics)

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l 3. Section 5.2.2.1, p. 37-41 - The combined plan deleted the statement in the separate plans which gave the ESD authority to overrule the ED's decision regarding event classificatio It is not clear who has the authority to make emergency classi-fication . Section 5.2.2.1 (A), p. 38-39 - Revision 5 of the TMI-1 plan and Revision 1 of the TMI-2 plan stated that the ED maintains the responsibility for approving and directing official notification to offsite agencies throughout the emergency. The combined plan requires that this responsibility be transferred to the ESD when ,

he arrives in the EOF and declares himself ready to assume the role. Although this change appears adequate, the benefit of having the functions of emergency classification and directing official notifications to offsite authorities performed by two individuals is unclea . Section 5.2.3 (13), p. 53-54 - The Environmental Assessment Coordinator (EAC) responsibilities listed in the combined plan do not include deploying and directing offsite radiological survey teams and communicating with Pennsylvania on dose pro-jection/ assessment matters as indicated in Revision 9 of the Oyster Creek pla . Figure 23, " Interrelationship of Emergency Response Organiza-tions" charts. The U.S. Department of Energy and the Environ-mental Protection Agency report to the State of Pennsylvania Emergency Management Agency in the conbined plan (Figure 23)

while they were shown reporting to the Pennsylvania D. Bureau of Radiological Protection (Figure 20) in the TMI-1 and TMI-2 plans. Also, in New Jersey, dose assessment is performed in the Oyster Creek EOF but neither this function nor the licensee personnel in the EOF who communicate with State dose assessment personnel are identified in the new Pla . The following organizational changes appear adequate, however training of personnel in new emergency assignments and reporting chains will be reviewed during a subsequent inspectio '

Section 12 (Figures 20 and 21) - The combined plan added an Emergency Director (ED) Assistant position to the " Initial Response Emergency Organization" and an Emergency Support Director (ESD) Assistant position to the " Emergency Support Organization". The ED Assistant has the ECC communications Coordinator, Emergency Assembly Area Coordinator, Security Coordinator, and Public Information Representative report-ing to him and not the ED as in the previous plan Similarly, the ESD Assistant provides direction to the Emergency Preparedness Representative, Public Information Representative, and EOF Communications Coordinato . .

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Section 5.2.3 (3), p. 49 - The combined plan defines the position entitled " Group Leader - Radiological and Environ-mental Controls" (R&EC). The R&EC reports to the ESD and has the Radiological Assessment Coordinator (RAC) and Environmental Assessment Coordinator (EAC) reporting to him. The previous plans for TMI-1, TMI-2, and Oyster Creek has the RAC and EAC reporting directly to the ES *

Figure 19 - The on-shift emergency organization chart for the TMI-1 and TMI-2 plans (Figure 12A) has the Chemistry Coordinator reporting directly to the ED while the combined plan (Figure 19) has the Chemistry Coordinator reporting to the OSC Coordinato B. Emergency Measures Section . Section 6.2, p. 66 - The combined plan provides a discussion on how Oyster Creek parent and risk counties are notified but does not discuss it for TMI. This information is found in Figure 25 and differs from Oyster Creek, in that the parent county is notified at TMI regardless of emergency clas . Section 6.5.1.1, p. 77-79 - The combined plan does not specifically identify the locations of emergency assembly areas and remote assembly areas as were previously defined in the separate TMI-1, TMI-2, and Oyster Creek plan C. Section 7.0 - Emergency Response Facilities and Equipment Section 7.0, p. 91 - The combined plan did not provide descrip-tions of the post-accident sampling systems. (Revision 9 of the Oyster Creek plan did contain a description of the post-accident sampling system.) Section 7.7.a, p. 122 - The combined plan does not discuss first aid facilities defined in Revision 5 of the TMI-1 pla Specifically, the first aid facility at the 305' elevation in the east hallway of the Service Building, and the extensive medical aid facility located below the Control Room in the Radiological Control Laboratory, appear to have been eliminate . Section 7.5.1.B(g), p. 110 - The status of the Oyster Creek high range containment radiation monitor (as required by NUREG-0737, II.F.1.(3)) should be identifie . Table 18 - The new plan describes the OSC for TMI-1 as being located on the 305' el. of the control tower within the control room ventilation system boundar Revision 5 of the TMI-1 plan describes the OSC as being located on the 306' el. of the

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Control Building within the Auxiliary Building ventilation with the capability to be placed in a recirculation mode with a charcoal filter system. This difference should be resolve . Similarly, the combined plan describes the TMI-2 OSC on the 305' el, of the Control Building while Revision 1 nf the TMI-2 plan has the OSC on the 305' el. of the Service Building. This difference should also be resolve D. Maintenance Emergency Preparedness - Section . Section 8.1.1 (3), p. 126 - Revision 5 of the TMI-1 plan and Revision 1 of the TMI-2 plan both have a provision for annually inviting the State Police to participate in a training progra It is not clear if the State Police will continue to be invited to attend site training and orientation session . Section 8.1.2, p. 127 - Revision 5 of the TMI-1 plan and Revision 1 of the TMI-2 plan stated that the Operations and Maintenance Director had to approve dates for quarterly drills and annual exercises. The combined plan did not contain this provision. Approval of drills and exercises should receive authorization by an individual of upper level managemen . Section 8.1.2, p. 127 - Revision 5 of the TMI-1 plan and Revision 1 of the TMI-2 plan had provisions for an annual

" repair and damage control drill". Although the combined plan does not include this provision, in-plant repair and corrective actions should be demonstrated during annual exercise E. Recovery - Section . Section 9.0, p. 132 - Revision 9 of the Oyster Creek plan had an additional guideline which must be met prior to entering the recovery phase. The guideline was to hold discussions with the New Jersey Office of Emergency Management and the NRC and reach agreement on terminating the emergency and entering recove ry. This guideline was deleted from the combined pla The basis for this change is not clea F. Identification of Non-substantive Changes Glossary Definitions of TSC and EOF do not appear in the new Pla Some definitions of specific emergency positions were deleted in the new Pla _____________

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7 Scope The combined plan does not include 10 CFR 50, Appendix E as a reference used for the development of the emergency pla Section 2.1.3.b, p. 14 - In the combined plan the Dover Township population number on p. 14 (61,287) was not consistent with the number on Table 2, p. E2-1 (64,455).

3. Organization p. 32 - The combined plan does not delineate the responsi-bilities of the Deputy Director TMI-2 (shown in Figure 15). p. 33 - The Deputy Director for Oyster Creek is not included in the OCNGS Division Organizational Chart (Figure 16). p. E13-1 (Table 13) - The last shift position on the page should be the ECC Communications Coordinator with the ECC Communicator under this functio p. 50 - The combined plan and the TMI-1 and TMI-2 plans indicate that the Public Information Representative

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shall report to the Control Room prior to E0F activation to gather information. Revision 9 of the Oyster Creek plan doesn't have this provision. It is not clear if a new procedure is to be provided for the Oyster Cree p. 56 - The combined Plan does not indicate that the Director of Technical Functions Division will provide liaison to the NRC during long-term recovery. This duty was designated in Revision 9 of the Oyster Creek Pla This individual should be identifie p. 53 - It is unclear if the functions of the Radiological ( Controls Support Coordinator defined in the combined plan

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and the Personnel Monitoring Coordinator and Radiological Controls Manpower Support Coordinator in the TMI-2 plans

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l p. 46 - The combined plan states that Radiological Engineer-l ing Support located in the ECC shall assist the Radio-

! logical Assessment Coordinator in performing dose projec-l tion calculations. The previous plans refer to this

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position as the " Radiological Analysis Support Engineer" (RASE). It is not clear as to where the RASE for Oyster l Creek will be located.

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4. fmergency Measures p. 68 - The combined plan indicates that notification must be made to the Parent County for all emergency classes. This is in conflict with Section 6.2, second paragraph which states for Oyster Creek that the parent County (Ocean Lounty) need only be notitied directly for a General Emergency while New Jersey notifies Ocean County for other emergency classe p. 79 - Section 6.5.1.1 indicates that a search will be done of all buildings and other areas in the Owner Control-led area to ensure that all persons have assembled or evacuated the site. This " simultaneous search" appears to be unnecessary since the accountability / search and rescue procedures would be implemented to locate missing individual p. 73 - The combined plan does not include (1) time v distance dose plots for a TID-14844 accident and (2) time vs. exposure rate plots for the dome monitor (these were contained in Revision 5 of TMI-1 plan).

5. Facilities and Equipment p. 99 - The combined plan identifies dedicated communica-tion lines between Babcock and Wilcox and the TMI-1 Shift Supervisor's office, TMI-I & TMI-2 TSC, RTSC, and PTF The previous TMI plans only described the dedicated line between Babcock and Wilcox and the PTFC. It is not clear that these phone lines are new, are operable, and routinely teste Tables 2A and 2B p. E21A-1 and E21B-1 - The combined plan has added (21A) and deleted (218) several atmospheric radia-tion monitors, area radiation monitors, and liquid radia-tion monitors. The overall impact of equipment changes will be determined during a subsequent inspectio p. 113 - The combined plan indicates that TMI meteorolo-gical data can be remotely interrogated by the NRC and the State of Pennsylvania. This information was not found in the previous TMI plans. It is not clear if specific arrangements for this capability have been made with Pennsylvania and the NRC and if the same capability has been provided to New Jerse p. 115 - The combined plan has a description of TMI and Oyster Creek real-time field monitoring stations. However, it is not clear as to the locations where data from these stations are provide .

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9 p. 118 - The combined plan has provisions for obtaining back-up meteorological information from Weather Services International (WSI). This agreement should be formalized, E18-1 - The combired plan lists a new location for the Oyster Creek TSC (Site Emergency Building). Revision 9 of the Oyster Creek plan has the TSC located in Building . Knowledge and Performance of Duties The inspectors reviewed the licensee's training program, including lesson plans, drills, and training record Emergency training course content, tests, and employee feedback were discussed with the Training Support Coordinator and training instructor Employee records were reviewed to verify that initial training and retraining were provided. Records were also reviewed for individuals who have dem- astrated their ability to function in emergency drills and exercises. Based upon classroom training provided and results of examinations, the inspectors determined that 254 emergency response organization personnel are adequately trained to pro-vide one primary and two alternates in each emergency positio On-site training is performed by the 55 person staff of the Plant Training Group. The group gives General Employee Training (GET), operator train-

> ing, on-the-job-training, and required professional trainin Institute of Nuclear Power Operations (INPO) Certification has been obtained by five (5) training department representatives. Off-site training is provided by two consultants (RMC and EM, Inc). Training is updated monthly and retraining is performed annually. Exams, including essay questions and walk-throughs are also given to site personnel. Passing grade for exams is 70%. The site Emergency Preparedness manager reviews and approves lesson plans. Lesson Plans are not yet based on job task analysis, but training staff stated this is expected in the near future. The simulator is also expected to be used for Emergency Preparedness training. The Communications Division, which includes Public Information and Affairs, trains mass media personnel and disseminates public emergency informatio . Independent Reviews / Audits The Emergency Preparedness program is reviewed annually by the Quality Assurance Department per QAP 1000 ADM - 1291.01. This has been performed for five (5) successive years. Reports are plant life-time records and are submitted to the President of GPUN within 60 day Findings and recommendations must be resolved by the Emergency Preparedness staf If concerns cannot be resolved at this level, corporate officers will resolve them. Technical Specification requirement 6.5.3 covers audits and the QA Program is carried out in accordance with Appendix B to 10 CFR 50, Reg. Guide 1.146, and ANSI-45. Government interfaces are checked, drills observed and a report is sent to state and local government agencies regarding interface adequac ._ - _

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j Summary On September 23 and October 24, 1986, the inspectors summarized the scope and findings of the inspection with the Licensee Management and Emergency Preparedness Management. At no time during this inspection was written material provided to the licensee by the inspector !

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GPU Nuclear Corporation 2 cc w/ enc 1:

R. J. Toole, Operations and Maintenance Director, TMI-1 C. W. Smyth, Manager, TMI-1 Licensing R. J. McGoey, Manager, PWR Licensing E. . L. Blake, Jr. . . Esquire TMI-1 Hearing Service List Public Document Room (PDR)

Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC)

FEMA Region III NRC Resident Inspector Commonwealth of Pennsylvania 1