IR 05000289/1999006

Insp Rept 50-289/99-06 on 990608-11.No Violations Noted. Major Areas Inspected:Licensee Emergency Preparedness Plan

ML20209D865
Person / Time
Site:	Three Mile Island
Issue date:	07/08/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20209D849	List: IR 05000289/1999006 ML20209D845
References
50-289-99-06, 50-289-99-6, NUDOCS 9907140059
Download: ML20209D865 (9)

Text

.fL ,

-j -

. U. S. NUCLEAR REGULATORY COMMISSION t

REGION I Docket No: 50-289 License No: DPR-50 l

Report No: 50-289/99-06 Licensee: GPU Nuclear Corporation Facility: Three Mile Island Nuclear Station I

' Dates: June 8 - 11,1999 Inspectors: D. Silk, Senior Emergency Preparedness Gpecialist W. Maier, Emergency Preparedness Specialist N. McNamara, Ernergency Preparedness Specialist W. Schmidt, Senior Resident inspector, TMI Nuclear Station C. Smith, Resider't inspector, TMI Nuclear Station N. Perry, Project Engineer, Branch 7, Division of Reactor Projects Approved by: Richard J. Conte, Chief Human Performante and Emergency Preparedness Branch Division of Reactor Safety 9907140059 990708 PDR ADOCK 05000289 G pm

EXECUTIVE SUMMARY Three Mile Island Nuclear Station )

Full-Patticipation Emergency Preparedness Exercise Evaluation  !

June 8 - 11,1999 l Inspection Report 50-289/99-06 l l

Overalllicensee performance during this exercise was very good as the Emergene Response Organization (ERO) demonstrated that it could implement the emergency plan. The emergency j response facilities were stayed and activated in a timely manner. Good command a nd control !

were demonstrated by all of the facility leads. There were good communications ob served l within and enong the facilities. Event classifications were accurate and timely. Offs te notifications were all made wl thin the 15 minute requirement. News releases and pn'ss I briefings were accurate and timel )

Facilities were well equipped and capable of supporting ERO activities. The licensee dentified ,

'

f that the Technical Support Cen!er (TSC) size was a challenge in meeting the comfort 1eeds of !

responder '

There was very good assessment of plant conditions. Mitigation strategies were quick /

developed and implemented. The licensee addressed current simulated problems well while anticipating potential plant degradation issues, classification upgrades, and protective a tion recommendations. Dose projection and dose assessment activities were well coordinat ad between the Emergency Control Cecnter (ECC) and Emergency Operations Facility (EOl ).

During the critique, the licensee methodically reviewed the exercise objectives for each f. cility and identified issues in addition to the ones identified by the inspectors. Positive and neptive l items were noted. Overall, the critique was thorough and appropriately self-critical and wi s I assessed as very goo l l-ii-

_.- l

!

Beport Details P3 EP Procedures and Documentation .

!

a. Insoection Scope (82701) .

l The inspectors reviewed changes the licensee had made to the emergency plan and its associated implementing procedures since the last EP inspection. They performed this l review in the NRC regional office. Specifically, they reviewed revision 15 to the GPUN nuclear emergency plan and revision 0 of the TMI emergency plan. They also reviewed revisions and temporary changes made to the emergency plan implementing procedures during the period September 29,1998 through April 16,199 j b. Observations and Findinas Based on the licensee's determination that the changes made to the emergency plans and implementing procedures during the period September 29,1998 through April 16, 1999, do not decrease the effectiveness of the onsite emergency plan and that the plan, as changed, continues to met >he requirements of 10 CFR Part 50.47 (b) and ~

Appendix E to 10 CFR Part 50, no prior NRC approval of those changes is required. The inspectors noted that revision 0 of the TMI emergency plan was simply a rewrite of the GPUN nuclear emergency plan with all references to GPUN and the other nuclear site operated by GPUN removed. This revised plan was developed in support of the planned j transfer of ownership of the TMI site. The inspectors determined that this change, as j well as the other changes made to the onsite emergency plan and implementing  !

procedures which they reviewed, were made in accordance with NRC regulations. The !

inspectors did not review revision 5 of the licensee's emergency classification and basis l procedure since that change was approved by a licensing action made by the NRC's Office of Nuclear Reactor Regulatio c. Conclusions The inspectors determined that the changes made to the onsite emergency plan and its implementing procedures from September 29,1998 through April 16,1999, which they reviewed were made in accordance with NRC regulation P4 Staff Knowledge and Performance a. Exercise Evaluation Scope i

During this inspection, the inspectors observed and evaluated the licensee's biennial full- !

carticipation exercise in the emergency control center (ECC), the technical support 1 tenter (TSC), the operations support center (OSC), the emergency operations facility (EOF) and joint information center (JIC). The inspectors assessed emergency response organization's (ERO) recognition of abnormal plant conditions, classification of emergency conditions, notification of offsite agencies, development of protective action recommendations (PARS), commarsi and control, communications, utilization of repair and field monitoring teams, and the overallimplementation of the emergency plan. In addition, the inspectors observed the post-exercise critique to evaluate the licensee's self-assessment of the exercis E j l

-2- J Emeraency Response Facility Observations and Critigyg EQQ

' The ERO staffed the ECC in a timely manner. The shift supervisor emergency director (SSED) correctly classified the Alert, and the notification of offsite agencies of this event was accurate and within the required 15 minutes. The SSED exhibited excellent l command and control in directing the actions of the operations crew. Tumover to the j emergency director (ED) was adequate and completed quickl i The ED also exhibited excellent command and controlin the ECC Communications

~within the ECC, especially between the ED and the operations coordinator, were very good. Additionally, communications between the ECC and the TSC, OSC, and EOF were very clear. Briefings by the ED were informative and very timely with respect to J

events. The ED ensured that all notifications of offsite agendes were accurate anc 1 within the required 15 minutes. Detection and classification of the Site Area Emergency i (SAE) and General Emergency (GE) events were accurate. The ED and the operations coordinator also did good contingency planning, tying the TSC into the proces T d

- The TSC was activated very quickly, within 25 minutes of the Alert declaration and within F minutes of the announcement of the Alert declaration over the plant public address

. sy;: tem. . The facility was activated with a minimum staff of five and satisfactorily pe formed at this staffing level for a half hour before additional responders were admitted. This was done in order to demonstrate the adequacy of the minimum staffing levels. The minimum responders were able to set up the facility's communications links with the other emergency response facilities, generate plant process computer printouts i and trend this information on the status boards, and perform routine engineering functions such as the calculation of reactor coolant system leak rate l The TSC was able to accommodate its full complement of emergency responders, but it was uncomfortable for those responders. There were, at times, up to 16 responders in the facility, and there were not enough chairs for all of these people. The temperature and humidity of the room were adversely affected by the personnel loading, and several responders waited outside the facility proper, entering when summone i for a support task. Toward the end of the exercise, the room's environment produced fatigue tnat affected efficiency of the responders, but not adversely enough that the facility was unable to perform its required functions. The TSC size was a challenge in meeting

' comfort needs of msponders. This issue was also identified by the licensee during the critiqu Facility command and control were very good in the TSC. The TSC coordinator gave frequent briefings to the entire facility where he elaborated on TSC task priorities. He practiced three-way communications and enforced its use among his subordinates. He directed facility responders' atter.tlon to the plant public address system when important exercise information was being transmitted. He established priorities early as plant

. .

- .

.

.. .. . . . . . . .

.. .. .

.

.

-3-

events occurred and plant conditions changed. He re-directed staff efforts as the priorities changed. He was assisted by the TSC advisor in performing these command and control task The TSC performed its support functions of engineering assessment adequatel Engineers there quickly determined a level of fuel damage when mechanical damage had occurred to the core. They performed a primary-to-secondary leak rate calculation early in the scenario when condenser conditions supported the ability to do so. The TSC also supported the ECC's and the ED's needs by development of mitigation procedures for removing power to a stuck open reactor building isolation valve and for establishing a fluid seal on the once-through steam generator tube lea QgLQ The activation of the OSC was timely and staffing was sufficient to carry out assigned functions. The OSC was activated within 15 minutes of the Alert declaration. The initial manning was provided by the on-shift personnel and then turned over to the emergency responders. Manning was in accordance with TMI Emergency Plan Implementing Procedure EPIP-TMl .29, OSC Operation Command and control within the OSC were good. The OSC Coordinator effect;vely discharged his duties and responsibilities. Frequent briefings were held to inform OSC personnel of changing plant conditions and priorities. Congestion and noise were held to a minimum by providing pre-designated staging arcas within the OSC for operations, maintenance, and radiological personnel waiting for assignment. Personnel assigned to perform tasks were properly briefed on the work to be performed including the expected radiological conditions. Workers were debriefed on completion of their assigned task The status board was maintained up-to-date to track teams as they were sent into the plant. The inspectors identified some minor procedural (EPIP-TMI .29) adherence

' deficiencies conceming the set-up and use of intemal OSC communications equipmen This was identified by the licensee at the critiqu The OSC effectively carried out its support functions. Radio communications were maintained between the OSC and teams sent into the field. For teams assigned to perform tasks covered by plant procedures, procedure adherence was maintaine Emergency maintenance was conducted with the approval of the ECC and was coordinated with the TS EQF The EOF was staffed and activated in a timely manner, although there were some minor communication problems initially caused by Commonwealth of Pennsylvania personnel arriving at the EOF sooner than ERO members. The Commonwealth personnel had quickly staffed and established communication links; and, in the early phase of operation at the EOF, they had information sooner than the emergency support director (ESD). As more EOF staff arrived, this issue dissipated. This issue was identified by the licensee

, during the post-exercise debrief and is being evaluate '

,

l

~

There was good control and leadership demonstrated by the ESD. Frequent briefings were conducted. The EOF noise level was maintained at a minimallevel. The ESD effectively solicited input from his lead The use of the computer generated plant status information provided good and timely information. Plant / emergency status boards were kept up to date, with proper supervisor review. Communications between the engineering, dose assessment and public relations personnel were very good. Technical support personnel questioned plant data and demonstrated the ability to think of contingency plans and to comment on plans being developed at the TSC. The emergency action levels were continually referenced during the exercis L I

The EOF staff developed the appropriate PAR for the GE and relayed it in a timely l

fashion to Commonwealth emergency officials. After the initial PAR, the EOF staff j frequently reviewed the PAR applicability for possible upgrade. Throughout the entire j exercise, there were good interactions between the EOF staff and the Commonwealth representatives as discussions were frequent and informativ ; Dose Assessment b. Dose Assessment at the ECC The group radiological controls supervisor arrived at the ECC and was expedient in establishing communications, retrieving procedures and placing the dose assessment process into operation. Once the radiological assessment coordinator (RAC) arrived, he received a good turnover and maintained good command and control throughout the exercise. The RAC interacted with the ED on numerous occasions, kept him informed of any changing radiological conditions and continuously verified the plant radiation monitor parameters in the dose assessment model corresponded with the simulator panel. Once a release was imminent, the RAC dispatched a site team to radiologically monitor the site

]1 boundary and continuously reassessed their positions with respect to the direction of the plume. The RAC and the dose assessment staff kept in contact with the Bureau of ;

Radiation Protection (BRP) representatives from the Commonwealth providing ]

radiological updates, as well as, plant information while the BRP waited for the EOF to l be activate j Once the EOF was activated, the RAC at the ECC maintained control of onsite activities (radiological) and conferred with the radiological environmental coordinator (REC) at the l EOF who coordinated and monitored the effsite activities. Throughout the exercise, the ECC's dose assessment team continued to perform "what if" calculations and served as a verification check on the dose assessment data that was generated by the team at the EO b.5.2 Dose Assessment at the EOF The radiological environmental support team was very knowledgeable, continuously ran dose assessment calculations and performed "what if" calculations. During the SAE, the REC was pro-active in evaluating the plant conditions and making recommendations to the ESD regarding PARS. At the time of the GE, the PAR was accurate and the

! .

5-

notification to the Commonwealth met the time requirements. Excellent teamwork was 1 observed between the RAC, ECC and the technical support group for acquiring changing plant conditions, questioning erroneous information and re-evaluating the PAR for upgrad The data generated by the licensee's dose assessment model compared well to the i calculations performed by the BRP and the ECC. Very good interactions were observed i between the REC and the Commonwealth representatives, particularly, during the ESD briefings for answering question Field monitoring teams were properly dispatched and moved accordingly with changing radiological conditions. They were able to locate the center of the plume and were later moved to verify there were no dose consequences beyond the 10 mile emergency planning zone, b.6 dlQ The JIC was activated in a timely manner. Press releases were prompt and accurat Mock press meeting were conducted by the licensee, in conjunction with the Commonwealth, in an orderly and coordinated manner. Uimplified drawings and maps were used to communicate information to the press. The press players asked ,

challenging questions to the spokespersons in a realistic manner. The licensee provided accurate or clarifying information and researched information during breaks for questions that they did not have an immediate arswe b.7 Licensee Exercise Critiaue immediately following the exercise, the licensee began its critique process with players, q as well as controllers, providing debriefs. Players and controllers were mostly candid discussing both positive and negative comments regarding player and equipment l

'

performance. At the formal licensee critique on June 11,1999, the licensee methodically reviewed the exercise objectives for each facility. The licensee identified issues in addition to the ones identified by the inspectors. Overall, the critique was thorough and self-critica c. Overall Exercise Conclusions Overall licensee performance during this exercise was very good as the ERO ,

demonstrated that it could implement the emergency plan. The emergency response 4 facilities were staffed and activated in a timely manner. Good command and control were demonstrated by all of the facility leads. There were good communications observed within and between the facilities. Event classifications were accurate and timely. Offsite notifications were all made well within the 15 minute requirement. News releases and press briefings were accurate and timel ]

l

'

Facilities were well equipped and capable of supporting ERO activities. The licensee identified that the TSC size was a challenge in meeting the comfort needs of responder ,

.

-6 There was very good assessment of plant conditions. Mitigation strategies were quickly developed and implemented. The licensee addressed current simulated problems well while anticipating potential plant degradation issues, classification upgrades, and protective action recommendations. Dose projection and dose assessment activities were well coordinated between the ECC and EO During the critique, the licensee methodically reviewed the exercise objectives for each facility and identified issues in addition to the ones identified by the inspectors. Positive and negative items were noted. Overall, the critique was thorough and appropriately i self-critical and was assessed as very goo P8 Miscellaneous EP issues l

P Scenario Preparation and Exercise Control An in-office review of the exercise objectives and scenario was conducted by the inspectors prior to the exercise. It was determined that the scenario was adequate to support the demonstration of the stated objectives and satisfactorily exercised a significant portion of the emergency response capabilitie During the exercise, controllers mostly performed well and drillsmanship was goo .

However, in two minor instances, OSC controller input was unrealistic. There was !

minimal impact upon the exercise and these instances were identified by the licensee during their critiqu P8.2 LClosed) Insoector FolEw-uo item 50-289/98-07-01: Exercise Weakness - Failure to notify offsite aaencies within 15 minutes This open item concerned instances when notifications were made late during an emergency drill. The licensee determined the cause for the late notifications was inadequate training and practice of ERO communicators in performing the offsite notification task. Contributing to this was a large number of individuals qualified to perform the offsite communicator's task; therefore, many individuals did not have an opportunity to practice the required skills during drills. Additionally, the procedures for performing the notifications were changed frequently during 1997, anci a complete revision was completed in 199 Corrective actions taken included: the pool of communicetors was reduced by removing individuals from the list who would not normally be comn unicators, such as shift technical advisors and senior reactor operators; the prccedures for performing notifications have been controlled to limit the number of changes; and, when changes are made, training is conducted regarding the char.ges; and additional training was conducted for the appropriate individuals regarding how to efficiently perform the notifications, and the importance of completing the notifications within 15 minutes. The inspector reviewed the completed corrective actions and discussed them with licensee personnel. Additionally, the inspectors observed that during the exercise, conducted on June 8,1999, all notifications were completed efficiently, in less than 10 minutes each time. Management oversight and sensitivity to completion of the notifications quickly and

~

accurately was apparent during the process. The inspectors concluded that actions taken have adequately addressed the concern with making timely notification '

i i

, .

-7-V. Manaaement Meetinas X1- Exit Meeting The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 11,1999. The licensee acknowledged the inspectors'

finding !

l l

j l

.

.

INSPECTION PROCEDURES USED l 82301: Evaluation of Exercises for Power Reactors 82302: Review of Exercise Objectives and Scenarios for Power Reactors ITEMS OPENED, CLOSED, AND DISCUSSED Opened None Closed IFl 50-289/98-07-01: Exercise Weakness - Failure to notify offsite agencies within 15 minutes Discussed None LIST OF ACRONYMS USED BRP Bureau of Radiation Protection ECC Emergency Control Center ED Emergency Director EOF Emergency Operations Facility ERO Emergency Response Organization ESD Emergency Support Director GE General Emergency GPUN GPU Nuclear Corporation JIC Joint Information Center NRC Nuclear Regulatory Commission OSC Operations Support Center PAR Protective Action Recommendation RAC Radiological Assessment Coordinator REC Radiological Environmental Coordinator SAE Site Area Emergency SSED Shift Supervisor Emergency Director TMI Three Mile Island TSC Technical Support Center