IR 05000289/1989002

Forwards Safety Insp Repts 50-289/89-02 & 50-320/89-01 on 890123-26.No Violations Noted

ML20236C293
Person / Time
Site:	Crane
Issue date:	03/14/1989
From:	Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Roche M GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8903220063
Download: ML20236C293 (2)

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MAR 141989 Docket Nos. 50-289 License Nos. OPR-50 50-320 DPR-73 GPU Nuclear Corporation ATTN: Mr. M. B. Roche Director of TMI-2 P. O. Box 480 Middletown, Pennsylvania 17057 Gentlemen:

Subject: Combined Inspection Report Nos. 50-289/89-02 and 50-320/89-01 This refers to the routine, announced, safety inspection conducted by Mr. C.

Amato of this office on January 23-26, 1989 at the Three Mile Island Nuclear Generating Station, Londonderry Township, Pennsylvania, and to discussion of our findings by Mr. Amato with you and your staff at the conclusion of the inspection.

The areas examined during this inspection are described in the NRC Region I Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examination of procedures and records and interviews with personnel by the inspector.

Within the scope of this inspection, no violations were identified.

No reply to this letter is required.

Your cooperation with us in this matter is appreciated.

Sincerely, C:gned Signed cy.

k: aid R. Ochmy Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards

Enclosure:

NRC Region I Combined Inspection Report Nos. 50-289/89-02 and 50-320/89-01

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0FFICIAL RECORD COPY CIR TMI 89-02/01 - 0021.0.0 03/09/89 8903220063 890314

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GPU Nuclear Corporation

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REGION I==

Report Nos.

50-289/89-02 50-320/89-01 Docket Nos.

50-289 50-320 License Nos.

OPR-50 Priority --

Category'C OPR-73 Priority --

Category C

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Licensee:

GPU Nuclear Corporation P. O. Bax 480 Middletown, Pennsylvania 17057-0191 Facility Name: Three Mile Island Nuclear Generating Station

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Inspection at: Harrisburg, Londonderry Township and Susquehanna Township, Pennsylvania Inspection Conducted: January 23-26, 1989-Inspectors:

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C. G. Amato, Em'ergency Preparedness Specialist, date'

Emergency Preparedness Section, FRSSB, DRSS Approved By:

b de ggy W. J. Lar/#rus, Chief Emer jency Preparedness date /

Section, TRSSB, DRSS Inspection Summary::

Inspection on January 23-26, 1989 (Inspection Report Nos. 50-289/89-02 and 50-320/89-01)

Areas Inspected:

Routine, announced, safety. inspection of the Itcensee's'-

emergency preparedness program conducted on January 23-26, 1989.

Results: No violations, deviations or unresolved items were identified.

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DETAILS 1.0 Persons Contacted The following GPU Nuclear Corporation personnel were contacted.

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• J.' Byrne, Licensing Manager, TMI-2

• J. Colitz, Plant Engineering Director, THI-1

• D. Ethridge, Radiation Engineering Section Manager, THI-l'

J. Grisewood, Lead Offsite Emergency Planner, EP Department G. Giangi, Manager, Emergency Preparedness Department, GPUNC

• D. Hassler, Licensing Engineer, TMI-1 J. Hildebrand, Vice President and Director, Radiation and

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Environmental Controls Division

• H. Hukill, Director and Vice President THI-1 C. Incorvatti, TMI Quality Assurance Audit Manager A. Knoche, Sr. Emergency Planner, TMI Emergency Planing Section

• D. Laudermilch, Support Training Manager -

• S. Mervine, Protection Training Supervisor

• S. Peleschak, Nuclear Engineer, Bureau of Radiation Protection, Dept.

of Environmental Protection, Commonwealth of Penna.

M. Roche, Director and Vice President TMI-2

• E. Schrull, Licensing Engineer THI-2

• G. Simmonetti, TMI Emergency Planning Section Manager

• J. Stacey, TMI Security Section Manager, Security Department

• H. Wilson, Plant Material Assessment Coordinator

• Denotes licensee personnel who attended the exit meeting.

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The Inspectors also observed the actions of, and interviewed other i

licensee personnel.

2.0 Licensee Action On Previously Identified Items j

I The following items were identified during previous inspections. Based j

upon observations, review of procedures and discussions with licensee personnel by the inspector, the following inspector follow up items and

the Notice of Violation (NOV) have been resolved.

(CLOSED) (50-289/87-14-02 and 50-320/87-06-02) (NOV) Parsippany Technical Function Center (PTFC) procedures were not submitted to' the NRC as required by 10 CFR 50.4(b) and Section V of Appendix E to 10 CFR 50. The l

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licensee made the required submittals and reclassified the PTFC as a Support Center.

(CLOSED)(25-00-24) Inspection of emergency plans for power reactors.

These plans have been inspected.

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(CLOSED) (50-289/87-14-04 and 87-06-04) The EP-Security-Operations interface. requires specification. Coordination meetings and security drills are held which include the on shift operations personnel.

(CLOSED) (50-289/87-14-01 and 87-06-01) Parsippany Technical Function Division (PTFO) personnel who staff the PTFC receive ' emergency pre-paredness (EP) training, but this training may not be sufficient in all areas, such as accident management training. PTFC staff are lectured by representatives from eich GPUNC site and attend lectures during which relevant industry events are discussed.

(CLOSED) (50-289/87-14-03 and 50-320/87-06-03)' The primary emergency communications systems failed-for three hours on May 9,1987. To reduce further the probability of'another occurrence, the-_ licensee is installing a phone line to the Commonwealth Police Headquarters.- Auto-ring phone circuits have been modified so simultaneous. notification can be given to '

the Commonwealth and the risk Counties. The Pennsylvania Emergency Management Agency's communication system redundancy and diversity have'

been ' improved.

3.0 'The Emergency Preparedness Program (EPP) Organization

'I To determine if the licensee has developed, maintains and implements an emergency preparedness program (EPP) required by 10 CFR-50.47(t) which meets the standards of 10 CFR 50.47(b) and Section IV.of Appendix E _to 10 CFR 50, organizational structure was studied," personnel were interviewed, and EPP activities were-identified.

3.1 The EPP was transferred to the Radiological and Environmental Controls (R&EC) Division during_1988. The present Divisional Director-Vice President was appointed during October 1988. He devotes about 20% of his time to EPP activities and regularly briefs the GPUNC President about these matters. The President is a qualified Alternate Emergency Director for THI.

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3.2 A R&EC Emergency Preparedness Department is responsible for the GPUNC EPP. There are two Department sections-one for each GPUNC '

site. A manager and three emergency planners staff the Department office. Two of the planners are senior planners responsible for off site emergency planing. The TMI EPP section complement includes a manager and five professionals'with backgrounds in nuclear engineering,' operations and health physics. The TMI EPP Section manager maintains ongoing' liaison with the TMI Directors.

3.3 Technical Support Center (TSC) staff and staff training have been expanded. A senior reactor operator and five support engineers have been added to the TSC staff. TSC Coordinators have observed exercises at other facilities. Training is now given in

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Abnormal / Transient Operating Guides'and use of material in a TSC Calculations Guide.

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Based on the above findings, this portion-of the licensee's emergency plan is acceptable.

4.0 Emergency Preparedness Training (EPT)

To decide if emergency preparedness training is-in compliance with 10 CFR 50.47(b)(15) and Section IV.F of Appendix E to 10 CFR 50, EPT activities, training records, lesson plans, Emergency Response Organization (ERO)

qualification roster, and the trafning matrix were studied, and Training Section staff interviewed.

4.1 The TMI Section of GPUNC's Training and Education Department (TED)

is responsible for EPT.

ERO positions and EPT.are correlated; the correlation is listed in GPUNC Emergency Plan Table 23.

EPT reflects job task analysis and is performance based.

Various training modalities are ust' including classroom instruction and'

drills.

Classroom attendanta is checked and numerical grades are assigned.

Expanded EPT is non bcing given as noted in Section 3.3 above.

4.2 An EPT QA audit team recommended three actions; all training and qualification status information should be included in a single summary report; a report listing the status of-on shift personnel I

. status should also be developed; and, drill attendance tracking should be improved to ensure key ERO personnel shall participate regularly to maintain proficiency. =Ttese audit findings are presently being evaluated by GPU management.

4.3 The ERO is divided into three groups:

1) on shift; 2) initial

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and 3) support. Training matrices have been developed for each group.

Lessons plans are current-and attendance is tracked. About 280 TMI staff are currently qualified for both units. At least three personnel are qualified for each ERO position.

Security officers are emergency preparedness trained; a lesson plan has been developed for this training.

4.4 Licensed operators receive six hours of EPT including class-ification, notification, and Protective Action Recommendation

development.

Simulator training is not provided except for drills and exercises which will be run from the simulator. The Protective Action Logic diagram (Fig. 24 of the EP) has not' been included in the operator EP lesson plan; it will be inserted into the 1989 revision. Shift Technical Advisers are not emergency

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preparedness trained.

4.5 The Parsippany Technical Functions Center (PTFC) staff was trained in the details of the revised Corporate Emergency Plan, PTFC operation, and updated as to significant nuclear industry safety related events.

Based on the above findings, this portion of the licensee's emergency preparedness / training program is acceptable.

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5.0 Audit / Review An independent audit / review 1s required at least-every twelve months by 10 CFR 50.54(t) including determination for adequacy of the' licensee State / local government-interface a'nd availability of_the results.of this study'to State / local goverament(s).

To ascertain if these requirements are met, the Quality Assurance ~ evaluation report for the TMI EPP was.

reviewed and correspondence checked.

5.1 The TMI Site Audit Section undertook the required audit-from June to September 1988 using GPUNC's Quality Assurance Procedures. The audit' encompassed.eight EPP activities.

Results'of the EPP audit were satisfactory.

Interface adequacy was evaluated. Auditors contacted the. Pennsylvania Emergency Management Agency. Copies of;

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the report was sent to this' Agency.

Based on the above findings, this. portion of the licensee's emergency preparedness / audit program is acceptable.

6.0 Plans and Procedures Plans and Procedures were reviewed to determine if they meet the requirements of 10 CFR 50.47(b)(16) and'50.54(q), and Section IV G of Appendix E to 10 CFR 50.

6.1 The current status of TMI-2 required revisions to the GPUNC Emergency Plan (EP) and TMI emergency classification. procedures.:

Two classification procedures are in effect, one for Unit I and!the other for Unit 2.

A basis document for the Unit 2 Emergency Action Level (EAL) classifications was developed.

These EALs were correlated with the examples given in Appendix 1.of NUREG-0654, Rev. 1.

Safety Analysis and Safety Evaluation Reports-were consulted. Eighteen TMI-2 initiating conditions were-identified for the^ four EAL classes

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including two for a General Emergency and six' for a Site' Area

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Emergency. A TMI-2 Emergency Plan Implementing Procedure.(EPIP) for classification has been developed, reviewed and approved by the Itcensee.

6.2 The GPUNC EP was revised and submitted to NRC for review. GPUNC responded to NRC concerns and the EP was reissued as~ Revision 1.

The'EP required changes to the TMI-1 EPIP for Protective Action Recommendation (PAR) development.

Changes were made so'the EP and EPIP agree with respect to PAR development.. A PAR Logic Diagram was developed for Unit 2 and incorporated into the EPIP for Emergency q

Direction as Enclosure 3.

This diagram is consistent with Figure 24 of the EP.

6.3 EPs and EPIPs in each Emergency Response Facility were surveyed to find out if the current and correct PAR logic diagram was inserted.

Results indicated current EPs and EPIPs were in place and contained the current PAR logic diagram.

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6.4 Section 2.2.2 of the EP identifies related Plans.and Procedures and-(

their coordination with the EPIPs.

These plans and procedures I

include, for example, the Site Security Plan, Emergency Operation-Procedures (EOPs) and the Emergency Public Information Plan. E0Ps contain'

referrals to EAL classification procedures. A sampling check

indicated the other procedures,-as appropriate, were available.

j Based on the above findings, this portion of the ficensee's emergency

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preparedness program is acceptable.

7.0 Emergency Response Facilities Emergency Response Facilities (ERFs) are designed to meet the j

requirements of 10 CFR 50.47(b)(8) and (b)(9),Section IV of Appendix E -

i to 10 CFR 50, Supplement 1 to NUREG-0737 and Regulatory Guide 1.97.

j Equipment, status boards, communications systems, plans, procedures and l

access control provisions were checked.for the Emergency Command Center (ECC), the Emergency Operations Facility (E0F), the Technical Support

j Center (TSC) and the Operations Support Center (OSC).

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7.1 The TMI-1 ECC is located within the the Control Room area.

It is equipped with meteorological, radiological and plant system parameter l

readouts. Plant and off site communication systems were in place

and functional.

The ECC and the Radiological Assessment Center

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(RAC) which is located within the ECC were maintained in a state of

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readiness. Health Physics Network phones in the RAC worked. TMI-2 i

ECC and RAC are maintained in a state of readiness.

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7.2 The TMI-1 TSC and OSC are located within the Control Building.

Status boards, maps, wall boards, plans, procedures and equipment are maintained in a state of readiness. Plant and meteorological variables specified in Regulatory Guide 1.97, and plant records, drawings etc. are also available. Thirteen communication systems link the TSC with other ERFs and off site entities. A TSC and OSC are not required for TMI-2.

7.3 Plans and Procedures, equipment and communication systems in the OSC were in place and functional including the Health Physics Network phones.

7.4 The EOF is a non-dedicated facility located 12 miles from the site. Adequate space is provided for all functions. The EOF is maintained in a state of readiness. Twelve communication systems tie the EOF to other ERFs and off site emergency response centers. Health Physics Network phones were operative. A l

Certificate of Occupancy hrs been been issued for the leased building housing the EOF. The Environmental Assessment Center

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located within the EOF is also maintained in a state of readiness.

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7.5 The-licensee plans to evaluate their~ERFs using I&E Inspection Procedure 82412 (ERF Appraisal);

Based'on the above findings, this portion of the-licensee's emergency,

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plan is acceptable.

8.0 Emergency Action Levels '(EAls)-

To determine if. the EALs meet the standard of 10 CFR 50.47(b)(4), the-requirements of Section IV B'of Appendix E to:10 CFR-50, the guidance of:

NRC Office of Inspection and Enforcement Information Notice No. 28 of i

1983 (I&E IN 83-28),'and Planning Standard D and Appendix 1 to NUREG-0654,:-

l Rev. 1, EAls were reviewed and discussed with EPP personnel.

8.1 Revision 5 of TMI-2 procedure for " Classification of Emergency Conditions" was compared with the standard, = requirements and guidance.

Classification is based on. events, symptoms, breached barriers and projected doses. Guidance of I&E IN

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83-28 is applied..EAls were sent'to the Commonwealth of-

Pennsylvania government (see Sec; 9.1 below).

t Based on the above findings, this portion of the licensee's emergency plan is acceptable.

9.0 Protective Action Recommendations (PARS)

The standard and requirements for PARS are given in 10 CFR 50.47(b)(10)

and Section IV B of Appendix E to 10 CFR 50. ' Applicable guidance is found in I&E IN 83-28.

To determine if the-standard and requirements are met and PARS are consistent with federal guidance, PARS were reviewed,-

and discussed with licensee's staff.

9.1 PARS are based on Figure 24 of the GPUNC EP (see Sec. 6.0 above).

EAls and PARS were sent to the Bureau of Radiation Protection (BRP),

Department of Environmental Protection, Commonwealth of Pennsylvania and discussed with the BRP: site representative. The BRP staff replied there was no objection to GPUNC using this logic diagram.

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Based on the above findings, this portion of the licensee's emergency plan is acceptable.

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.30.0 Notification and Communications Communications systems were checked to ascertain. if the requirements of 10 CFR 50.47(b)(5) and (b)(6), Sections IV D.1 and IV E.9 of Appendix E

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to 10 CFR 50, and I&E IN 86-97 were met.

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1 10.1 Fifteen communication systems are available.

These systems are independent, redundant and diverse.

Operability was checked on a sampling basis and found to.be satisfactory.

10.2 A number of steps have been taken te_ improve communication:

reliability with off site organizations. _The licensee has arranged for the installation of a phone'line to Commonwealth Police Headquarters bypassing the Middletown exchange. -PEMA will be able l

to'use the Commonwealth Police microwave system and will be given radios (named PEMARS) by the licensee.

PEMARS will be installed in each risk County Emergency Operations Center. The PEMA Duty Officer.

has been given a cellular phone.

i 10.3 Partial tests of call in system effectiveness for the initial and support emergency response teams indicated responses from 70% to 100%. The average'was 89%.

Based on the above findings, this portion of the licensee's emergency preparedness plan is satisfactory.

11.0 public Information A Public Information Department staff member was interviewed and printed material distributed to the public reviewed to determine if the requirements of 10 CFR 50.47(b)(7) and Section IV D.2 of Appendix E to 10 l

CFR 50 are met.

11.1 The public is advised as to emergency procedures by mailed i

brochures, phone book inserts and newsletters. Ninety six thousand brochures were sent in the fall before the annual exercise to the residents living within the ten mile Emergency Planning Zone (EPZ).

Leaflets are not used for transients; brochures are sent to hotels, motels, camp sites and major employers, A brochure summary has been placed within the blue pages of the Bell and Donne 11ey directories for all communities within the EPZ.

The brochure is reviewed

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annually.

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11.2 Two quarterly newsletters are mailed; one goes to residents within the EPZ and the other to 600 off site, governmental emergency workers.

One issue of the resident newsletter summarizes the

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emergency brochure contents.

11.3 The Joint Information Center (J1C) is located in downtown Harrisburg.

Space is provided for 200 reporters; 15 phone lines are available for their use. Dedicated rooms are provided for the NRC, FEMA and

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PEMA. Access control will be established by GPUNC Security Officers. Briefing material, diagrams and maps.are available.

Copying and facsimile' transmission equipment is provided. The Rumor Control Center is located within the JIC.

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Based on the above findings, this portion of the licensee's emergency plan is acceptable.

12.0 Off Site Activities To determine if the standards of 10 CFR 50.47(b)(5) and (b)(12) and the requirements of Sections IV D.3 and IV F of Appendix E to 10 CFR 50 are l

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met, the lead off site emergency planner was interviewed and appropriate

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records reviewed.

1 12.1 County personnel are trained by staff of the Pennsylvania j

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Emergency Management Agency (PEMA).

The licensee offered

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I training to 36 local government units, school districts and

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personnel of decontamination stations. A single lesson plan

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has been developed for this' training. Table top exercises are also run.

Emergency medical training was given to-first aid' squad members. The licensee sends a letter certifying training completion to PEMA which, in turn, forwards a similar letter to FEMA Region III.

12.2 Preliminary 1989 siren test data indicated an availability of

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93%. While the EP does not provide for the use of tone alert radios, 189 have been distributed upon request. The problem

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rate for these is 10%.

12.3 Evacuation Time Estimates will not be updated until the 1990 census has been taken.

Letters of Agreement are current.

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12.4 The municipalities about TMI have adopted the All Hazard l

Emergency Response Plan (AHERP).

The AHERP classifies

'1 emergencies into one of two categories:

Limited Emergency (LE); and Full Emergency (FE).

The LE correlates with the Unusual Event and ALERT and the FE with the Site Area Emergency j

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and General Emergency.

Check lists are being developed for these classifications.

PEMA's and the Counties' Radiological

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Emergency Response Plans remain Annexes to Pennsylvania's l

Emergency Operations Procedures.

Based on the above findings, this portion of the licensee's emergency l

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plan is acceptable.

13.0 Security-Emergency Preparedness Interface I

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To determine if the requirements of Section II.O.59 of Appendix B to 10 CFR 73 are met, NUREG/CR-3251 was consulted and security personnel were

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interviewed.

13.1 Security Officers are radiation worker qualified, respirator trained and fitted. Additional training is given in Emergency Preparedness,

search and accountability, and activation of the call in pager and verif1 cation system.

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13.2 The Central Alarm Station and Secondary Alarm Stations'will be evacuated at Emergency Director discretion.

Personnel.will go to predetermined fall back locations. Self reading dosimeters, survey equipment and anti-contamination clothing are available in-the nearby-OSC.

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13.3 Security emergency preparedness interface meetings are held. There are provisions for Security-EP drills.

If a security event results in declaration of an EAL, security information is transmitted to the Emergency Comman Center which will provide the NRC with updates.

i Based on the above findings, this portion of the licensee's emergency plan is acceptable.

14.0 Dose Assessment The standard, requirements and guidance for dose assessment are' given in 10 CFR 50.47(b)(9), Sections IV B and IV E.2 of Appendix E to 10 CFR 50,

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Section II.f.1(2) of NUREG-0737 (Supplement 1), Regulatory Guides 1.23 j

and 1.97 and NUREG-0654, REV 1, Appendix 2.

To determine if the licensee

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is in compliance with these standards and guidance, facilities'were inspected, records were checked and personnel interviewed.

14.1 There is an on site meteorological tower and a backup tower at the Harrisburg International Airport.

The site. tower was inspected; it is situated outside of the protected and diked site areas and enclosed within a locked fence.

Backup power is provided by a second feeder from a plant bus.

Sensor and associated electronic calibration records were reviewed.

Calibration was current and done using approved procedures.

14.2 Sensor and electronic calibration records for plant vent points were checked.

Current and approved procedures were followed.

Calibration was current. Similar records for the off site pressurized ion chambers were checked and found to be in order.

14.3 The Environmental Assessment Center computer has been replaced with (

an improved computer. An elevated main steam release model has been

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developed and improvements made to the plume rise model. An Emergency Dose Calculational Manual has been developed.

Based on the above findings, this portion of the licensee's emergency plan is acceptable.

15.0 Exit Meeting

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An exit meeting was held with the licensee personnel identified in l

Section 1 of this report.. The licensee was advised no violations,

deviations or unresolved items were identified.

The inspector also

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discussed some areas for improvement.

Licensee management acknowledged these findings and indicated they would evaluate them and take appropriate corrective action regarding the items'.

identified.

At no time during the course of the inspection did the inspectors provide any written material'to the licensee.

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