IR 05000289/1997008

Insp Rept 50-289/97-08 on 970728-0906.No Violations Noted. Major Areas Inspected:Operations,Engineering,Maintenance & Plant Support & Results of Announced Insp in Area of Emergency Preparedness

ML20217J366
Person / Time
Site:	Three Mile Island
Issue date:	10/09/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20217J362	List: IR 05000289/1997008 ML20217J357
References
50-289-97-08, 50-289-97-8, NUDOCS 9710210050
Download: ML20217J366 (25)

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U. S. NUCLEAR REGULATORY COMMISSION REGION 1 Docket N '

License N DPR 50 i

l Report N l Licensee: GPU Nuclear Corporation Facility: Three Mile Island Station, Unit 1

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Location: P.O. Box 480 Middletown, PA 17057 Dates: July 28,1997 September 6,1997 Inspectors: Wayne L. Schmidt, Senior Resident inspector Samuel L. Hansell, Resident Inspector Lois M. James, Reactor Engineer William A. Maier, Emergency Preparedness Specialist Edward B. King, Physical Security inspector Approved by: Peter W. Eselgroth, Chief Reactor Projects Branch No. 7 9710210050 971009 PDR- ADOCK 05000289 0 PDR m

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EXECUTIVE SUMMARY 1hree Mile island Nuclear Power Station Report No. 50-289/07 08 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a six week period of resident inspection; in addition, it includes the results of one announced Regional inspection in the area of emergency preparednes Overall GPU Nuclear (GPU) operated Three Mile Island Unit 1 (TMI 1) safely over the perio Pjont Operations Operators responded well to two equipment failures that caused minor plant power / pressure transients including: a failed integrated control system (ICS) module which, caused a feedwater transient; and a partial closure of makeup (MU) valve MU V 3, which caused a reactor pressure increase (Section 01.1).

Operators effectively implemented approved written procedures for infrequently performed fuel reactivity control, control rod movement, and Tave reductions, at end of core lif (Section 01.2)

The inspectors noted strengths in control room operator equipment manipulations and supervisor command and control and management oversight, during the unit shutdown for the 12th refueling outage (12R) (Section 01.2).

MaintenanGA GPU conducted the observed maintenance and surveillance task well. Post shutdown sutvaillance testing was properly scheduled for the appropriate plant condition The shift sepervisor provided excellent self-checking feedback to the instrurnent and control technicians during a reactor protection system surveillance (Section M1.1).

The GPU staff demonstrated excellent performance during the core flood (CF) system check valve testing, including excellent coordination between the control room and the reactor building (RB) personnel, GPU conducted on-line main steam relief valve testing, in accordance with ASME Code requirements. Personnel demonstrated proficiency in resetting lift setpoints. The procedure clearly addressed, verified, and documented proper valve release nut installation and associated cotter pin material which had caused stuck open relief valvea at other Babcock and Wilcox (B&W) sites. (Section M3.1),

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Engineerina Overall, the engineering department provided good support for the safe operation of TMI The engineering department provided operations with clear procedures for roactivity control management during end of core life operations. (Section 01.2).

The system engineer provided excellent coordination of the main steam safety valve lift test in the plant. In additlun, the Engineering Director provided senior management oversight for part of the test (Section M3.1).

The system engineer and inservice test enaineer provided good direction and oversight when needed during CF testing. (Soction M1.1).

GPU Nuclear responded promptly and very eftsetively in their review. analysis, and corrective actions for the SSAS power suppl *< logic design deficiency. Engineering i performed wellin developing and analyzing a change to the emergency operating procedures to ensure the ability to throttle DHR and BS pump flows, after a DBA LOCA, to maintain adequate NPSH. The Operations department properly followed the TS and reported the condition to the NRC. The LER described the issue in detail and appropriately addressed the root cause and associated corrective actions. NRC enforcement discretion was exercised, and no violation issued, in recognition of licensee self identification and correction through voluntary initiatives of an old design issue. (Section E8.1).

Plant Suonort Radiation Protection:

The radiological control monitoring and oversight of the fuel trunsfer system cable drive modification was very good. GPU Implemented good controls over a diver performing modification activities in the spent fuel pool (SFP). Lessons learned.from previous industry problems with such activities were properly factored into the work. (Section R1.1)

Emeraency Preoaredness:

GPU effectively implemented the emergency preparedness (EP) program, including maintenance of an operational technical support center and emergency operation facility

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that wert, maintained operationally ready. The inspector noted improvement in management support of activities and programs. Emergency plan and procedure changes met NRC requirements. The EP training program administration and qualification maintenance were also improved. External audits of the EP program implementation were well defined, but the EP Department has not yet implemented a self assessment program (Sections P5,6,7 and 8.2).

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The inspector closed one previously identified violation. Another violation was documented as withdrawn by NRC letter dated Geptember 26,1997, based on review of licensee information. (Sections P8.4 and P8.5). (CLOSED VIO 97 04 03; WITHDRAWN VIO 97-04 04)

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TABLE OF CONTENTS PAGE N EX ECUTIVE S U M M ARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Il TABLE O F CO N T E NT S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v l. Operations ....... ....... .................................... 1 01 Conduct d Operations (71707) ............................. 1 01.1 General Comtnents ................................. 1 01.2 Plant Shutdown for the 12R Refueling Outage . . . . . . . . . . . . . . 1 II. Maintenance .................................................. 2 M1 Conduct of Maintenance (62707, 61726) . . . . . . . . . . . . . . . . . . . . . . 2

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M1.1 General Comments ................................. 2 M3 Maintenance Procedures and Documentation . . . . . . . . . . . . . . . . . . . . 4 M3.1 Maintenance Surveillance Test Procedures . . . . . . . . . . . . . . . . . 4

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l E1 Co.1 duct of Engineering (37 551) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 E8 Miscellaneous Engineering issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 E8.1 (Cloned) LER 50 2 8 9/9 7-00 9-00 . . . . . . . . . . . . . . . . . . . . . . . . 6 IV. Plant Suppert ................................................. 7 R4 Staff Knowledge and Performance in RP&C . . . . . . . . . . . . . . . . . . . . 7 P2 Status of EP Facilities, Equipment and Resources . . . . . . . . . . . . . . . . . 8 P3 EP Procedures and Documentation ........................... 9 j P5 Staff Training and Qualification in EP , . . . . . . . . . . . . . . . . . . . . . . . . 10 P6 EP Organization and Administration . . . . . . . . . . . . . . . . . . . . . . . . . . 11 P7 Quality Assurance (OA) in EP Activities . . . . . . . . . . . . . . . . . . . . . . . 12 P Independent Reviews by Nuclear Safety Assessment (NSA) ... 12

..... ............................................. 13 P8 Miscellaneous EP Issue s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . - 13 P8,1 (UPDATE) VIO 97 04 01: Lack of Computer Code Documentation and Procedures for Dose Assessment . . . . . . . . 13 P8.3 (UPDATE) IFl 97 04 02: Additional Guidance Necessary for Steam Generator Leakrate Calculation Tool . . . . . . . . . . . . . . . 15 P8.4 (CLOSED) VIO 97 04 03: Personnel on ERO Duty Roster Who Were Not Qualified ................................ 15 P8,5 (WITHDRAWN) VIO 97 04-04: EP Audit Program inadequate to Correct Deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 M a nag eme nt Mee ting s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 X1 Exit M ee ting Summ a ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 PARTIAL LIST OF PERSONS CONTACTED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 ITEMS OPENED, CLOSED, AND DISCUSSED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 LIST O F ACRONYMS U S ED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 v

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Report Detallt Summary of Plant Statut GPU Nuclear operated the unit safely throughout the period, maintaining essentlJlly 100%

power. Prior to the shutdown on September 5,1997, for the 12R refuel outage, the plant reactor power dropped to 98% due to fuel burn up, at the end of the operating cycle, l. Operations 01 Conduct of Operations (71707)'

01.1 General Comments Using inspection Procedure 71707, " Plant Operations," the inspectors conducted frequent reviews of ongoing plant operations. Operators performed in a professional and safety conscious manner, responding well to two equipment failures that caused minor plant power / pressure transients including: a failed integrated control system (ICS) module, which caused a feedwater transient, on August 19; and a partial closure of makeup (MU) valve MU V 3, which caused a reactor pressure increase due to reduced normal primary letdown flow, on August 21. Following the ICS module failure operators stabilized plant power and directed that the instrument and controls department (l&C) troubleshoot and conduct repairs as needed. When operators noticed that MU V 3 was closing they properly directed that the valve be manually positioned open to restore the normalletdown flowpat The manual positioning of the valve made it inoperable as an automatically closing containment isolation valve and the operators properly entered the required Technical Specification (TS) limiting condition of operation (LCO).

01.2 Plant Shutdown for the 12R Refuelina Outaae The inspectors found that plant operators conducted and management supported an orderly unit shutdown for the 12 refueling outage (12R) on September 5. Plant management augmented the normal control room staff to include additional reactor operators (ROs) at the feed, turbine, and ICS stations, to allow efficient monitoring of parameters during the reduction in power. The inspector observed that the operators performed very wellin reporting trends and controlling their specific parameters. Plant operators used good communmations techniques and senior reactor operators (SROs) (shift management) conducted good briefings as the unit entered different phases of the shutdown and prior to survoillance testing. Plant management conducted a very good pre shutdown meeting and control room briefing. Further, the presence of plant management in the control room during the shutdown provided excellent support and coaching to the operator ' Topical headings such as 01, M8, etc., are used in accordance with the NRC standardized reactor inspection report outline. Individual reports are not expected to address all outline topic .

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In addition, prior to the 12R shutdown the engineering department properly evaluated and provided instructions for reactivity controls. Approved written procedures provided detailed direction to the plant operators for the infrequent reactivity control manipulations. The plant operators properly executed these procedures. In particular, the operator cautiously adjusted the reactor coolant system average temperature (Tave) reductions and axial power shaping control rod (APSR) withdrawal without any impact on plant operation. The shift and plant rnanagement provided focus on these infrequent manipulations at the daily management meetings to ensure plant personnel awareness.

l II. Maintenanga M1 Conduct of Maintenance (62707,61726)

M1.1 General Commtata lDsoection Scooe The inspectors observed all or portions of the following maintenance and surveillance work activities:

o Job Order No. 137103, "'B' Decay Heat Removal Pump Cyclone Separator Clean and inspect."

e Job Order No. 139804, " Install Open and Close Torque Switch Bypass

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Modification."

e Job Order No. 133745, " Fuel Transfer System Cable Drive Modification."

e Surveillance Procedure 130311.3, " Main Steam Safety Valves."

.o Surveillance Procedure 1300 31, "lST of Nuclear Service River Water Pumps and Valves."

o Surveillance Procedure 1300 3T, " Pressure tro'ation Test of Core Flood Valves CF V4A/B, CF-V5A/B and DH V22A/B."

e Refueling Procedure 15051, " Fuel and Control Component Shuffle."

e - Surveillance Procedure 1303 4.1 A, "RPS Channel 'A' Test." Observations and Findinas Technicians and operators performed surveillance tests properly and the tests demonstrated the ability of the associated eystems to perform their design safety functions. The initial refuelinterval surveillances were scheduled and olanned te be performed at the proper plant condition ._ . _ _ _ _ _ . __ __

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The shift supervisor (SS) provided excellent self checking feedback to the instrument and control (l&C) technicians during the 'A' reactor protection system (RPS) test. The l&C techalcians used proper communications and repeat backs for each action step. On a few occasions the SS noticed that the I&C technicians did not always apply the " touch the tag" self checking principal. The SS appropriately coached the techniclans on management's expectations and the technicians applied the " touch the tag" check throughout the remainder of the RPS test.

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Operators performed and engineering supported Surveillance Procedure 1300 3T,

" Pressure Isolation Test of Core Flood Valves CF V4A/B, CF V5A/B and DH-l V22A/B." The Inspectors observed:

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Excellent test coordination between the control room and the reactor building, l

e - The establishment of proper plant conditions during the plant cooldown, l * A clearly written test procedure that contained critical tasks in the correct sequence, o Good system engineer and inservice test (IST) engineer oversight and direction in the RB, and e A shift supervisor (SS) providing excellent self checking feedback (touch the tag) to the instrument and control technicians during testing, Conclusions The TMI staff performed surveillance testing and maintenance activities wel Testing demonstrated the abi!ity of systems to function properly. The initial refueling surveillance was properly scheduled and conducted as plant conditions warrante M3 Maintenance Procedures and Documentation M3.1 Maintenance Surveillance Test Procedures Insoection Scoco The inspectors observed portions of surveillance procedure 130311.3, " Main Steam Safety Valves," from the Intermediate Building, Observations and Findinas The licensee properly conducted the safety valve testing and lift settings using appropriate ASME code devices. The inspectors observed:

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e The main steam system engineer coordinated the safety valve test locally at the safety valves, in addition, the Engineering Director observed part of the test in the plan e The test procedure included the acceptable and required lift tolerances, allowed set pressure adjustments, time between valve openings, number of test required per valve, and amblent temperature criteria, o Engineering properly performed a temporary change notice to update the

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procedure with the new inservice test (IST) requirements contained in the 1987 edition of the ASME Code. The maintenance personnel were experienced and had performed the test numerous times in the past. An example was noted for the safety valves that required adjustment to meet the 1% lift set point. The technicians were experienced and were able to adjust the lift setpoint to within 1% accuracy for the three valves found set outside the procedure criteria, Conclusigna GPU effectively conducted on line main steam relief valve testing. Engineering was involved and the test procedure was well written to meet ASME code requirement Personnel well demonstrated proficiency in resetting lif t set point The procedure clearly addressed, verified, and documented proper valve release nut installation and associated cotter pin material which had caused stuck open relief valves at other Babcock and Wilcox (B&W) site Ill. Enaineerina E1 Conduct of Engineering (37551)

E8 Miscelleneous Engineering lesues E8.1 1 Closed) LER 50 289/97 009-00: Engineering Analysis of the Loss of 'A' Train DC Power with a Loss of Offsite Power and a Loss of Coolant Acciden insoection Scoos Background The inspectors reviewed GPU actions to address a report from Parsons Power group (formerly Gilbert Commonwealth) and Framatome concerning the potential loss of

'A' Train DC electrical power Engineered Safeguards Actuation Systems (ESAS)

design deficiency at Crystal River 3 nuclear power plant. Parsons Power designed the ESAS for both Crystal River 3 and TMI 1. The design problem had a potential to prevent the ability to throttle the decay heat removal (DHR) and building spray (BS)

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pumps to ensure adequate net positive suction head (NPSH) would be maintained for a postulated loss of coolant accident (LOCA) with a failure of the 'A' DC electrical power supply and a concurrent loss of offsite power (LOOP).

The ESAS is a two train, three channel system with separate bypass switches for all three channels. The 'A' and 'C' channels are powered from the 'A' train electrical power supplies and the 'B' channel is powered from the 'B' electrical power supply, in order to bypass an ESAS actuation signal to permit throttling DHR and BS pumps, two of the three ESAS channels must have power to the bypass logic. For the postulated LOCA coincident with a LOOP and failure of the 'A' DC power supply, the 'B' bypass logic would remain functional but would not allow the ESAS actuation signal to be bypassed in the absence of the minimum required two channels. The ability to bypass ESAS to regain control of ES equipment would be required post LOCA to prevent potential air entralnment in the DHR and BS pumps when taking suction on the Reactor Building sum The inspectoro reviewed emergency procedure EP 1202 9A, " Loss of 'A' DC DistribJtion System," temporary change notice (TCN), associated engineering safety evaluation and engineering evaluation request (EER) related to the ability to bypass the engineered safeguards actuation system signal to throttle the DHR and reactor BS pumps. The review included the DHR and BS Technical Specifications (TSs),

operations training handout, and NRC reporting requirements.

t b. , Observations and Findings Resolution GPU Nuclear personnel reviewed the Crystal River report immediately and determined that the design deficiency also applied at TMI 1. The engineering department recognized that if the assumed single failure v;are a loss of 'A' DC power, the ability to bypass the ESAS actuation signal and throttle DHR and BS pumps in response to a large break LOCA may not be accomplished in a manner consistent with the safety analysis and existing plant procedures. Due to the lack of written procedure guidance to bypass the ESAS signal, plant management declared the 'B' DHR and BS systems inoperabl Plant operators entered the proper Technical Specification limiting condition of operation (LCO) for the inoperable systems. TS sections 3.3.1.1.c., " injection Systems," and 3.3.1.3.a., " Reactor Building Spray System," required a plant shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> if the problem was not corrected. Emergency procedure EP 1202 9A, " Loss of 'A' DC Distribution System," was revised to include written guidance for plant operators to cross tie the 'A' ESAS bypass logic power supply from the 'B' channel to provide the ability to throttle the DHR and BS pumps. The EP 1202 9A temporary change notice (TCN) was completed in approximately hours and included a detailed engineering safety evaluation and engineering evaluation request (EER) that supported the ability to bypass the engineered safeguards actuation systern signal to throttle the low pressure injection and reactor building spray pumps. Engineering properly verified that the 'B' emergency diesel

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generator (EDG) loading criteria would not be exceeded due to the additional channel 'A' electricalloads. The installation of a relay and test switch in the ESAS to allow bypassing the B channel without the loss of DC power was planned for implementation during the current refuel cutage. The extended period without

operability of the DHR and PS system is a violation of 10 CFR Appendix B, Criteria Ill, Design Control. The violation was identified by the licensee as a result of a voluntary initiative, corrective actions were prompt and comprehensive, the violation was not likely to be identified by routine licensee efforts such as normal surveillance or quality assurance activities and the violation is not reasonably linked

! to current performance. As a result, this apparent violation of NRC requirements will not be cited in accordance with Section Vll.B.3 of the NRC Enforcement Polle (NCV 50 289/97-08 01).

The TMI root cause evaluation was thorough and determined that the problem was attributed to the oversight of the plant's designers to recognize the need and ability to bypass the 'B' ESAS logic on a loss of offsite power and a loss of the 'A' DC electrical power supply. Also, engineering ana'yzed the effect of the loss of offsite power with the redundant 'B' train DC power supp!y and determined that ths A&C channels would retain the ability to bypass an ESAS signal, in addition, the effects of the loss of offsite power and loss of a train of DC electrical power were evaluated for the reactor protection system (RPS), the Heat Sink Protection System (HSPS). No design deficiencies were note Each operations shift crew was given a copy of the revised emergency procedure prior to assuming their duties. The operators were instructed how to restoie power to the ESAS bypass logic to regain control of the 'B' train equipment. In addition to the short term corrective actions, the engineering department will review the

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possibility of a modification to allow the bypass of the ESAS actuation without the need for additional operator action The licensee event report (LER) provided a detailed description and assessment of the event. The root cause analysis and associated corrective actions were comprehensive. The LER is close c. Conclusions GPU Nuclear responded promptly and effectively in their review, analysis, and ;

corrective actions for the ESAS logic power supply design deficiency. Engineering performed wellin developing and analyzing a change to the emergency operating procedures to ensure the ability to throttle DHR and BS pump flows, after a DBA LOCA, to maintain adequate NPSH The Operations department properly followed the TS and reported the condition to the NRC. The LER described the issue in detail and appropriately addressed the root cause and assoc!ated corrective actions. In recognition of licensee self identification and corrective action initiatives, this violation will not be cited, i

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R4 Stafi Knowledge and Performance in RP&C

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The radiological control monitoring and oversight of the fuel transfer system cable drive

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modification was very good. Radiological Control supervision provided a detailed pre job brief to the divers, supervisors, rad con techs, and other support personnel prior to the first spent fuel pool (SFP) dive. The pre job brief included the recent Calvert Cliffs diving problems and highlighted the root cause and related problems. TMl applied the lessons

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learned and verified that the TMl program controls would prevent the problems noted at Calvert Cliffs. The div" cnntrols and safety were followed throughout the fuel transfer wor In addition, the foreign material exclusion (FME) controls contained in administrative ,

procedure AP 1030, " Control of Access to System / Component Openings," were followed i for the SFP work activitie P2 Status of EP Facilities, Equipment and Resources insoection Scope (82701)

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The inspectors toured the onsite Technical Support Center (TSC) and the offsite Emergency Operations Facility (EOF), checking the readiness of both facilities. They i

also reviewed the contents of three sealed emergency equipment lockers, the .

operability of the telephone circuits and the availability of computer displays in the two facilities. They reviewed selected inventory sheets and communication surveillances for the last twelve months and interviewed licensee EP staff who l oversee the maintenance of EP facilities, equipment and resources. They also reviewed two licensee corrective action plan reports that described the late

performance of two facility inventories and the results of an inventory audit containing several discrepancies, l Observations and Findinas i

The TSC and EOF contained all the major equipment specified in the facility

, inventories. Licensee staff demonstrated the availability of the plant process monitor and the primary plant computer in the TSC. The three sealed equipment lockers observed contained the necessary items. Some minor discrepancies were noted in the two f acilities including:

An "information only" book of piping and instrumentation drawings was present at i the TSC that was five years out of date. There were also current, controlled copies of the drawings in the TSC file cabinets, such that responders would have access to the up to-date drawings. The out of date drawings were removed from the TSC prior to the end of the inspection.

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Two telephones, the operations line and the technical function line, in the EOF had no dial tone and would not function. The EP staff member accompanying the

'a inspectors immediately initiated action to repair the circuits. The licensee EP staff later learned that these circuits were undergoing troubleshooting to investigate a previously reported problen There were three operatcr aids at the EOF that hed no approval signatures or control numbers. Two of these gave instrut ons for certain operation of the primary plant computer and the other gave lutructions for manual operation of the EOF emergeracy diesel generator. The inspectors discussed the presence of these items with the EP Manager, who stated an intention to investigate the implementation of a system of trccking operator aids used in emergency  :

preparedness facilities and activitie The inventories performed in the past year were performed monthly and after use, ,

The licensee inventoried sealed equipment cabinets quarterly, provided the seal was intact. The EP staff member overseeing the inventory performance knew the status of most oi the recently completed inventories. The 'icenace identified two recent t problems associated with sealed emergency equipment lockers. These problems were documented on conective action program (CAP) forms. One problem involved two sealed equipment lockers that were not inventoried during the second calendar quarter of 1997 and the other involved multiple shortages of items ideatified during an EP audit of all the !ockers *he week pricr to the inspection. This EP audit also identified extra unused ;amper seals located in tnree lockers Unauthorized use of these tamper seals could allow a person to remove contents from the locker, apply a tamper seal, and prevent detection of the loss until the next quarterly inventor Nuclear Safety Arrssment personnel later issued a Quality Deficiency Report (ODR) to document these problems for evaluation and resolution, c. Conclusions The inspectors consiered the TSC and EOF to be operationally ready. They concluded that th9 deficiencies noted in those facilities did not significantly detract from the readiness of those facilities. They concluded that the EP staff was exercising adequate oversight of the emergency facilities and equipment. The inspectors considered the locket inventory discrepancies to be worthy of attention by the licensee but not so severe as to affect the level of onsite emergency preparedness. They concluded that the licensee was taking adequate action to document and investigste the proble ;

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P3 EP Procedures and Documentation a. Insoection Scoce (82701)

The inspectors also reviewed, at the NRC Regional office, Temporary Change Number 197-0083 which the licensee made to Emergency Plan implementing Procedure EPIP TMI .03, Emergency Notifications and Call Outs. They also reviewed Revision 6 to document 6610-PLN 4200.02, TMI Emergency Dose Calculation Manual (EDCM).

b. Observations and Findinos I The temporary change made to procedure EPIP TMI .03 and Revision 6 to the EDCM contained the appropriate approva; signatures. Neither change decreased the effectiveness of the approved corporate emergency plan, c. Conclusions The inspectors concluded that the temporary change made to procadure EPIP-TMI-

.03 and Revision 6 to the EDCM were made in cccordance with the licensee's document control practices. The inspectors further concluded that these changes met the requirements of 10 CFR 50.54(q) and thet prior NRC review and approel of the changes was not require P5 Staff Training and Qualification in EP a. insoectior. Scoce (82701)

The inspectors reviewed the training records of 25 persons in the on-shift, initial response and emergency support organizations to dete mine if the licensee was conducting EP training in accordance with the requirements of the emergency pla They also reviewed selected EP training lesson plans and tests to evaluate the content of the training given to emergency responders and the effectiveness of the testing. Finally, the inspectors interviewed training department personnel responsible for the administration of EP training to determine how emergency responder qualifications are tracked and to discuss the changes made to the EP training program since the March,1"97 exercise,

' Observations and Findinos All of the individual training records reviewed showed that training for those s

individuals had been accomplished according to emergency plan requirements. The lesson plans addressed the duties and responsibilities of the specific emergency '

response positions. Test questions were based on information contained in the lesson plan M' w.e m

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The EP training program had undergono several changes that applied lessons learned from the March,1997, exercise For example, training was conducted with emergency decision makers to provide guidelines for validation of conflicting information. Also, additional training conveyed expectations regarding the conduct of emergency activitie1, including praper communication technique Emergency responder :lualifications are maintained by attendance at EP continuing training and they are 7acked by several systems. An Emergency Preparedness Tracking System (EP" S) was initiated by the EP Department to track the qualification status of all but on-shift responders. Individual responders can also determine their own qualifications by accessing this system. The EP training coordinator checks this system for upcoming qualification lapses frequently during the period of EP requalification training (January through July). EP staff members also check this system for potential lapses of emergency response organization member GPUN has also implemented, since February,1996, a second system for tracking qualifications. This system is called the Quals Coming Due Notification System (OCDNS). The QCDNS system is an automatic system for notifying work group managers and training qualification administrators of impending lapses of qualifications of personnel in their work groups. The system generates reports it the baginning of each month that flag irdividuals whose qualifications are coming due in the near future. Individuals are notified by the work group administraturs to schedule training for requalification. As a backup, coordinators for the different I emergency response organizations check before the end of each month to ansure l that individuals flagged for requalification have received the required training. Since the implementation of this system, the licensee has had good succes: in preventing qualifications of on-duty personnel from lapsing (see Section P8.3). Conclusions

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The inspectors concluded that the training administration program had improved and met all emergency plan requirements. They further conciuded that the qualification tracking systems in use were being effectiv3ly impicmente P6 EP Organization and Administration Insoection Scoce (82701)

The inspectors interviewed eight managars to determine the level of management involvement and support for EP activities. They also interviewed officials of three of the five risk counties surrounding the plant and reviewed records of training given to offsite response personnel to determina the level of support given by the licensee to the offsite organizations. They discussed the stn .~ure of the site and corporate

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EP organizations with the EP manager and the Director of Radiation Health and

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11 ' Observations and Findinos The licensee had reported inadequate management oversight and attention to EP as the root cause of the unsatisfactory exercise performance in March,1997. All of the senior managers interviewed recognized this inadequacy and were aware of a need for improvement in this area. The Site Director stated several actions he either had committed to perform or was investigating in order to accomplish this. Other managers stated their expectations for their own and their subordinates' support of EP activities. These intentions on the part of the managers interviewed indicated a-desire by the licensee management to increase their support of the EP progra All of the interviewed officials of the risk counties were pleased with the attention given by the licensee to their needs. They cited the efforts of the offsite emergency planner at GPUN to provide quality training. They also cited the licensee's recent upgrade of the offsite siren notification systeni by providing diagnostic feedback

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circuitry. One official noted that tSe licer.see was working with them to improve

the timeliness of offsite notification of emergency conditions. All of the officials interviewed felt the licensee was responsive to their county's emergency preparedness need The staffing level of the EP department has recently been reduced by one individua Currently there are three onsite plannern, one offsite planner and one corporate planner to share the departrnent's workload. The inspectors discussed this fact with the EP Manager and the Manager of Radiological Engineering. The EP manager did not see this loss as having an impact on his department's ability to accomplish its work load since the workload of the lost individual has been transferred to the Radiological Engineering Department. The Manager of Radiological Engineering did not see the increased workload for his department as a significant increase since an additional person from another company location is expected to assist in performing the work of the former onsite emergency planne The inspectors learned from the corporate Director of Radiation Health and Safety that he had recently been assigned as the Radiation Protection Manager at the Oyster Creek plant. This assignment is in addition to his corporate oversight responsibilities for radiation protection and emergency preparedness at both site This additional responsibility has reduced the amount of his time available for corporate oversight. The effects of the burden of this additional responsibility on his corporate oversight effectiveness have not been shown since the additional assignment was made in the month immediately preceding this inspectio Conclusions The inspectors concluded, baea on the interviews with the licensee's management,

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the managers' knowledge of the causes of the performance problems associated with the March,1997 exercise and the orally stated expectations for the improvement of EP performance and oversight, that the support for the EP program by the site management has improved noticeably. They further concluded, based on the interviews with the risk county officials and the review ci offsite responder

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training records, that the licensee was providing good support to the offsite agencies on the county level. They also concluded that the loss of the fourth onsite emergency planner will not adversely impact the effectiveness of the EP department

. since that individual's workload has also been transferred. Finally, they concluded that the effects of the corporate Director of Radiation Health and Safety's additional duties on ble performance as corporato oversight of the EP program at TMl will need to be evaluated furthe P7 Quality Assurance (QA) in EP Activities -

P Indeoendent Reviews by Nuclear Safety Assessment (NSA) Insoection Scoo.e (82701)

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The inspectors interviewed the managers and two auditors in the Nuclear Safety Assessment Department. This interview was primarily to inspect corrective actions for previously identified Notices of Violation, but the information presented in the -

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past year. They also reviewed GPUN Audit Report S-TMI 96-08, dated September 13,1996, which detailed the annual review of the EP program for 1996,

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They also reviewed the audit plan for the recently completed, but not yet documented, audit report S-TMI 97-07 for the 1997 annual revie Observations snd Findinas The audit report for the 1996 annual review was written to summarize both the results of the audit team's activities and the NSA findings that were recently identified outside of the audit. The audit team leader was selected because he had

' no emergency response duties and was completely independent of the EP progra <

The audit evaluated all of the items required by 10 CFR 50.54(q), including offelte interface, drills, and procedures '-

The audit plan for the 1997 review also included all the items required by 10 CFR 50.54(q) and was a very comprehensive plan, evaluating 86 attributes of all aspects of the licensee's EP program. The 1997 review had a different audit team leader than the previous review who was also independent of the emergency response program at the sit : '

Conclusions-The inspectors concluded that the NSA audit activities met all the requirements of 10 CFR Part 50.54(t) and wore sn effective tool for the licensee's self evaluation of the EP program. They felt the licensee's effort to select audit team leaders who

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P8 Miscellaneous EP losess P8.1 (UPDATE) VIO 97-04-01: Lack of Computer Code Documentation and Procedures for Dose Assessment Insoection Scoce (92904)

Inspectors issued a Notice of Violati>n (NOV) to the licensee during the May,1997 remedial exercise inspection report. The NOV described the inadequate '

documentation for the online dose assessment and quick calculation computer codes used to assess the offsite dose consequences of releases of radioactive material. The licensee documented their response to the NOV in a letter dated July 24,1997. The inspectors reviewed the licensee's response to the NOV and interviewed the Manager of Red Engineering and the RadCon and Safety Director to determine what actions had been completed and what actions remained to be complete $ Observations and Findinas This violation was cited in NRC inspection report 97 04, in which it was established that the licensee had exercised inadequate oversight of the computer codes used in the various dose assessment models employed during emergency condition The licensee has established a dose assessment oversight committee with a charter and has initiated actions to relocate the host computer for the continuous on-line

, assessment (COLA) model to a more secure location with a more reliable power i

supply. They have arranged to obtain the services of a programmer from another

{ company location for the maintenance of the syste The ;icensee has commnted to update the Emerger.cy Dose Calculation Manual (EDCM) to reflect the current conditions of the computer codes and to upgrade the manual code to be consistent with the COLA code. The licensee has also committed to provide training to the dose assessment personnel using the codes on the refinements that will be made. This action is scheduled for completion by the end of March,199 Conclusions This item will remain open until the actions described above and in the licensee's response to the NOV are complete.

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P8.2 EP Internal Assessm.ID11 a.- Insoection Scooe (82701)

The inspector for the last EP program inspection, conducted in April,1996, noted that the EP department did not have a clearly defined self assessment program for identifying potential problems and implementing timely corrective actions to prevent degradation of readiness or problem recurrence. The inspectors from the current inspection interviewed the EP Manager and the corporate Director of Radiation 1 Health and Safety to determine the level of self assessment currently performed, Observations and Findinas The inspectors noted that the EP department 'es an action item tracking list that is used to document deficiencies. - This list is analyzed periodically to determine if trends exist. There is no formal process in place for the EP department to perform a detailed self assessment of_its performance, apply corrective actions and determine the effectiveness of those actions. The EP Manager discussed this absence of a formal self-assessment program in an interview with the inspectors. He informed the inspectors that he had committed internally within the licensee's organization to develop and implement such a program, c.: Conclusions The insper . ors considered a well-developed self assessment program for the EP department to be a demonstrated need. The NRC willinspect the implementation of this program after its development is completed.

l P8.3 (UPD ATE) IFl 97-04-02: Additional Guidance Necessary for Steam Generator

- Leakrate Calculation Tool Insoection Scoce (92904j During the remedial exercise inspection in May,1997, inspectors noted that the licensee's newly developed methodology for determining primary to secondary leak rate was being used inconsistently between the TSC staff and the Radiological Assessment Coordinator (RAC), Observations and Findinas The inspector interviewed the Managers of Shift Engineering and Radiological Engineering to determine their expectations for the calculation of primary to secondary leak rate. Both managers agreed that the new calculation methodology for determining primary to secondary leak rate could be used by the RAC prior to the activation of the TSC, but that once the TSC was activated, the TSC staff would have the ultimate responsibility for the leak rate determinatio _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ - _ _ - _ - _ .

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The training on this policy had yet to be performed at the time of the current inspection. Training of RACs and radiological support personnel is currently scheduled for later this year and early next year, Conclusions The inspectors concluded that the actions to close this item would be complete upon the completion and documentation of the training of the RACs and radiological support personnel. Until the completion of that training, the item will remain ope P8.4 (CLOSED) VIO 97-04-03: Personnel on ERO Duty Roster Who Were Not Qualified Inspection Scoce (92904)

The inspectors for the May,1997 remedial exercise inspection identified this violation from their review of licensee audits of the EP program. The licensee's audits noted recurring lapses of qualifications for emergency responders who remeined on the duty roster. The inspectors for the current inspection reviewed the

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licensce's response to the Notice of Violation and performed an audit of the qualifications of a sample of 25 emergency response organization members. The

! inspectors also reviewed the licensee's current qualification tracking syste Observations and Findinas The licensee, in the response to the Notice of Violation, described the adoption, in l'uruary,1996, of the Quals Coming Due Notification System (QCDNS) (see Section PS.b). The OCDNS system was actually implemented prior to the performance of the licensee's 1996 EP review the discussed the qualification tracking problems. The inspectors discussed this point with the licensee's NSA management, who stated that the 1996 review included an historical summary of qualification tracking problems that existed and were documented during the year preceding the 1996 audi The licensee reported near perfect success using the QCDNS tracking system to prevent lapses of qualification of persons assigned to the emergency response organizations. Only two persons had exceeded their qualification periods without being removed from the emergency response roster. The total time occurring with unqualified members on the roster was 2.25 person-days in 18 months of implementation of the QCDNS syste The inspectors' review of the training records of 25 randomly selected persons showed no instances of expired qualifications among assigned members of the

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16 Codcdq:.;

Based on the success rate of the OCDNS system and the results of their review of training records, the inspectors concluded that the licensee's tracking system was adequate to ensure the readiness of qualified members of the emergency response organization to respond to an emergency. They closed the violatio P8.5 (WITHDRAWN) VIO 97-04-04: EP Audit Program Inadequate to Correct Deficiencies Insoection Scoce (92904)

The inspectors for the May,1997 remedial exercise issued a Notice of Violation (NOV), citing the licensee's EP audit program as ineffective in characterizing and correcting the repeat deficiencies identified in those audits, particularly the 1996 annual EP audit. They cited the recurring qualification lapses as evidence of this problem. The inspectors also cited a f ailure to trend deficiencies and to properly characterize findings of adverse trends.

l l The inspectors for this inspection reviewed the licensee's response to the Notice of

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Violation and interviewed the licensee's Nuclear Safety Assessment management to gather any additional information regarding the findings which led to the NO Observations and Findinas The licensee's response to the NOV provided additional information that was unavailable to the inspectors during the May,1997 inspection. The licensee reported that the documentation of lapsed emergency responder qualifications during the 1996 audit was not based on findings discovered during the audit, but rather on audit findings that had been documented months before. The licensee also explained in its reply that it had, in fact, escalated the classification of repeat findings in the area of emergency equipment locker inventory results. The inspectors for the current inspection verified performance of this. The inspectors learned, through discussions with NSA management, that a method exists for escalation of NSA findings that are disputed by the responsible department. Finally, the inspeu. tors verified that the 1997 audit plan provided for re-examination of areas having deficiencies in the 1996 audit, thus ensuring a follow-up of the effectiveness of corrective actions for previous deficiencies, Conclusions The inspectorc concluded, based on their ruiew of the licensee's response to the NOV, their review of the 1996 EP audit report and their discussions with NSA management, that additional information that was not available to the inspector during the May,1997 inspection demonstrated that the licensee had characterized i

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- the findings of the 1996 EP audit report properly and that the characterization of findings of NSA audits of EP activities were not negotiated with the audited organization. The inspectors concluded that the NOV was based on incomplete information. The NRC retracted this violation by letter dated September 26,199 Manaaement Meetinas X1 Exit Meeting Summary At the conclusion of the reporting period, the resident inspector staff conducted an exit meeting with TMI management on September 11,1997, summarizing Unit 1 inspection activities and findings for this report period. TMl staff comments concerning the issues in this report were documented in the applicable report section. No proprietary information was identified as being included in the report.

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PARTIAL LIST OF PERSONS CONTACTED Licensee T. Gary Broughton, President GPUN l D. Etherloge, Acting Radiological Controls / Occupational Safety Director J. Grisewood, Emergency Preparedness Mar.ager D. Hosking, NSA Manager

'J. Langenbach, Vice President and Director R. Maag, Plant Maintenance Director L. Noll, Plant Operations Director M. Ross, Director, Operations and Maintenance J. Schork, Regulatory Affairs G. Skillman, Technical Functions Site Director P. Walsh, Engineering Director J. Wetmore, Manager, Regulatory Affairs

• senior licensee manager present at exit meeting on September 11,199 HEC B. Buckley, TMl Project Manager, NRR

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INSPECTION PROCEDURES USED IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving, and Preventing Problems IP 61726: Surveillance Observations IP 62707: Maintenance Observation IP 71707: Plant Operations IP 71750: Plant Support Activities IP 92901: Followup - Plant Operations IP 92902: Fc!Iowup - Maintenance IP 92903: Followup - Engineering IP 92904: Followup Plant Support l~

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l ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-289/97-08-02 (IFI), The inspectors considered a well-developed self-assessment program for the EP department to be a demonstrated need. The NRC willinspect the implementation of this program after its development is complete Closed 50-289/97-04-03 (VIO), Emergency response organization personnel qualifications," will be close (LER), Engineering Analysis of the Loss of 'A' Train DC Power with a Loss of Offsite Power and a Loss of Coolant Acciden Opened / Closed 50-289/97-08 01 (NCV), Engineering Analysis of the Loss of 'A' Train DC Power with a -

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LIST OF ACRONYMS USED AB Auoliary Building ALARA As low As Reasonably Achievable ASM American Society of Mechanical Engineers CDF Core Damage Frequency CR Control Room UFR Code of Federal Regulations DBD Design Basis Documents-ECCS Emergency Core Cooling System EPP Emergency Plan and Implementing Procedure l

ESF Engineered Safety Feature l

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HRA High Radiation Area IFl Inspection Followup ltem IPE Individual Plant Evaluation IR Inspection Report ISI Inservice Inspection IST Inservice Testing Program JO Job Orcier LCO Limiting Condition of Operation LER Licensee Event Report MNCR Material Nonconformance Report NCV Non-Cited Violation NRC Nuclear Regulatory Commission NSA- Nuclear Safety Assessment PCR Procedure Change Request PPB part per Billion PPM Part per Million PRA - Probabilistic Risk Assessment PRG Plant Review Group QV Quality Verification RCA Radiological Control Area RCS Reactor Coolant System RP Radiation Protection RWP Radiation Work Permits SALP Systematic Assessment of Licensee Performance SF Shift Foreman SRO Senior Reactor Operator S Shift Supervisor Tl- Temporary Instruction TS Technical Specification UFSAR Updated Final Safety Analysis Report ,

URI Unresolved item VIO Violation

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