ML19350B776
| ML19350B776 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/19/1981 |
| From: | Neely D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML19350B767 | List: |
| References | |
| NUDOCS 8103230678 | |
| Download: ML19350B776 (100) | |
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l t llh STAFF 3/19/81 i-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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Metropolitan Edison Company, et. al.
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Docket No. 50-289
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(Three Mile Island, Unit 1)
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TESTIMONY OF DONALD R. NEELY REGARDING BOARD QUESTIONS OF HEALTH PHYSICS PROGRAM i
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Q.1 Please state your name and position with the NRC.
A.1 My name is Donald R. Neely.
I am an Inspection Specialist in the Performance Appraisal Section, Division of Program Development and Appraisal, IE.
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Q.2 Have you prepared a st,acemt.'t of professional qualifi;ations?
A.2 Yes. A copy is attached to this testiciory.
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Q.3 What is the purpose of your testimony?
A.3 The purpose of this testimony is to respond to a question raised by the Board regarding the status of the significant evaluation findings identified on pages 20-24 of Appendix 8 to the Staff's THI-1 Restart evaluation report, Supplement No. 1.
(Tr. 13,428-29) The referenced significant evaluation findings are taken from the health physics appraisal report (IR 50-289/80-22) sent to the Licensee on November 26, 1980, which documents the results of the special evaluation performed on July 28 through August 8, 1980 of the health physics program at TMI Unit 1.
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4 Q.4 What is the status of the Staff's evaluation of the THI-1 health physics program?
A.4 We have conducted further discussions with the Licensee since the issuance of the November 26, 1980 report. On December 17, 1980, staff members-from General Public Utilities / Metropolitan Edison Company and staff tambers of Region I, Office of Inspection and Enforcement met to continue discussions of the Licensee's responses to the report.
As a result of these discussions, the Licensee has made certain commitments and clarifica-tions regarding its health physics program.
The Staff's evaluation of these commitmonts is contained in the attached report entitled " Evaluation of Metropolitan Edison's Response to the Items of Noncompliance and Significant Weaknesses Identified During the Special Health Physics Evaluation - IE Inspection No. 50-289/80-22."
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Q.5 What are your conclusions regarding the health physics program for TMI-1?
A.5 Based on our evaluation of the Metropolitan Edison Company responses to our health physics report of Novemoer 26, 1980, we conclude that their corrective actions and commitments in response to the items of noncompli-ance and the significant findings identified in that report satisfactorily resolve those items. Assuming that the Metropolitan Edison Company will j
fully and prcperly implement its commitments regarding its health physics program, we conclude that the program will be adequate and will be in compliance with applicable regulatory requirements.
NRC Office of Inspec-tion and Enforcement will verify the implementation of the ccmmitments prior to restart of TMI-1.
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s Professional Oualifications DONALD R. NEELY SCHOOLS /
Management Oversight and Risk Tree; U.S. Department of Energy, 2/80; TRAINING:
Systems analysis technique for detecting management oversights and assigning relative degrees of risk.
Health Physics in Radiation Accidents; Oak Ridge Associated Universities; 2/79.
Pressurized Water Reactor Fundamentals; U.S. Nuclear Regulatory Commission; 11/77.
Boiling Water Reactor / Pressurized Water Reactor Rad Waste Fundamentals; U.S. Nuclear Regulatory Commission; 8/77.
Boiling Water Reactor Fundamentals; U.S. Nuclear Regulatory Commission; 3/77.
Health Physics - State of the Art; Delaware Valley Society for Radiation Safety; 5/78.
. Respiratory Protection Programs and the Occupational Safety and-Health Administration; Los Alamos Sci ntific Laboratory, University of California; 12/76.
American Board of Health Physics Certification Preparation and Refresher Course; Delaware Valley Society for Radiation Safety; 1976/1977.
i Radiation Safety Technician Certification Course (Applied Radiation Protection); General Electric Co., Vallecitos Nuclear Center (VNC); 1965.
Boiling Water Reactcr In-Service Inspection; General Electric -
Co., VNC; 1971.
l Non Destructive Testing; General Electric, VNC; 1971.
Boiling Water Reactor Fuel Insocction and Reconstitution; General Electric Co., VNC; 19/2.
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Donald R. Neely 2
EXPERIENCE:
September 1980 - Present Inspection Specialist, Performance Appraisal Section, Division of Program Development and Appraisal IE Headquarters U.S. Nuclear Regulatory Commission Bethesda, Maryland Responsibilities include assisting in the development of performance appraisal methodology and procedures; conducting performance appraisal inspections at nuclear facilities; and performing major investigations and special inspections directed by Headquarters - Inspection and Enforcement.
Presently, on temporary assignment to Region I, Office of Inspection and Enforcement, as a Team Leader for the Health Physics Appraisal Program.
November 1975 - September 1980 Senior Radiation Specialist U.S. Nuclear Regulatory Commission King of Prussia, PA 19406 Responsible for inspecting radiation protection and radioactive waste management programs at nuclear power reactors, test and research reactors and fuel facilities during testing, start-up, maintenance, refueling and normal operation.
Assigned as a Team Leader for ongoing special Health Physics Appraisal Program.
Served as Team Leader for the radiological inspection team during the initial response to the accident at Three Mile Island on March 28, 1979 and as Shift Leader directing other NRC health physics inspectors during the subsequent eight weeks of the accident.
Lead Health Physicist for the NRC TMI Recovery Operations Office from May through October 1979. Appointed by the Director of Nuclear Reactor Regulation to serve on the special panel chartered to review the radiation protection program at Three Mile Island Unit 2.
Co-author of NUREG-0640, "Three Mile Island, Unit 2, Radiation Protection Program." Served as Team Leader for the special health physics evaluation of Unit 1 of the Three Mile Island Nuclear Station conducted during July-August, 1980 as part of the TMI-1 Restart evaluation. Assigned responsibility for updating certain of the order items contained in the supplement to NUREG-0680, "TMI-1 Restart Evaluation,"
and providing testimony for the TMI-1 Restart Hearings.
May 1974 - November 1975 Specialist and Supervisor, Nuclear l
Plant Services, Division of Chem-Nuclear Systems Fremont, CA Supervised health physics technicians during refueling and maintenance outages at nuclear power reactors.
Served as an instructor of health physics technicians, plant operators, maintenance personnel and balance of plant staff at commercial nuclear power reactors during pre-operational, start-up and refueling phases.
Provided consultation for the development of radiation protection programs for use at nuclear power reactors.
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EXPERIENCE (Continued) 1962 - 1974 Specialist, General Electric Co.,
i Vallicitos Nuclear Center Pleasanton, CA Provided radiation protection services for more than ten reactor facilities and analytical laboratories containing highly radioactive materials (hot cells) in all phases of their operation.
Supervised he.alth physics technicians who provided support to clients during maintenance and refueling outages.
Performed reactor fuel inspections and reconstitution, reactor instrumentation removal, nondestructive testing and waste disposal.
Participated in the cask loading operations, radioactive waste handling, underwater operations, decontam-ination, shipping of radioactive materials, personnel monitoring, area monitoring, environmental sampling, gamma scanning, whole body counting, outage planning and the development of radiation protection procedures.
Activities involved field service in nuclear facilities in the United States as well as Japan and Switzerland.
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THREE MILE ISLAND NUCLEAR STATION UNIT 1 Evaluation of Metropolitan Edison's Response to the Items of Noncompliance and Significant 'deaknesses Identified During the Special Health Physics Evaluation - IE Inspection No. 50-289/80-22.
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TABLE OF CONTENTS Page I. Chronology of Health Physics Evaluation and Responses.............
1 II. Noncompliance Identification, Correction and Evaluation...........
7 Generic Program Improvements Undetaken by Metropolitan Edison.....................................................
7 Items of Noncompliance, Corrective Actions and NRC Evaluations........................................
11 A.
Certain Respiratory Protection Procedures Were Not Maintained and Implemented.........................
11 B.
Respiratory Protection Program Was Not Being Audited............................................
13 C.
Quality Assurance Criteria for Shipping Packages for Radioactive Material - Requirements Were Not Met............................................
15 D.
No PORC Reviewed and Unit Superintendent Approved Whole Body Counter and Laboratory Counting Equipment Procedures Jere in Use...................
17 E.
Licensee Had Not Determined if Appropriate Extremity Monitoring Device Were Being Supplied...........................................
19 III. Significant Weakness Identification, Correction and Evaluation....
21 I-Description of General Public Utilities / Metropolitan Edison Management Documents.........................................
21 Significant Weaknesses, Corrective Actions and NRC Evaluations..................................................
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Organization, Rsponsibilities, Staffing and Management 0versight...............................
24 B.
Exposure Contro1...................................
39 C.
Radioactive Waste Management.......................
55 D.
Emergency Plan Implementation......................
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i SPECIAL HEALTH PHYSICS EVALUATICN OF THREE MILE ISLAND NUCLEAR STATION, UNIT 1 I.
Chronology of Health Physics Evaluation and Resconses A.
Details of the evaluation are described in IE Inspection Report No.
50-289/80-22, enclosed with a letter from the Director, Region I, Of fice of Inspection and Enforcement, NRC to Metropolitan Edison Company, dated November 26, 1980. That letter stated, in part:
"The NRC nas identified a need for licensees to strengthen the health physics programs at nuclear power plants and has undertaken a significant effort to assure that action is taken in tnis regard.
As a first step in this effort, the Office of Inspection and Enforcement is conducting special team appvisals of the health physics programs, at all operating power reactor sites, which include the health physics ascects of radioactive waste management and onsite emergency preparedness. The cbjectives of these appraisals are to evalute the overall adequacy and effectiveness of the total health physics program at each site and to identify areas of weakness that need to be strengthened.
During the period of July 23 - August 8,1980, the NRC conducted a special evaluation of the health physics program at Unit 1 of the Three Mile Island (TMI) Nuclear Station.
The major portion of this evaluation was conducted using the same appraisal techniques and acceptance criteria for the same areas as are being used in the conduct of the special team appraisals at operating power reactors throughout the country. Two adcitional areas were included in the TMI evaluation which are not addressed in the special team appraisals at operating power reactors.
The two additional areas reviewed were:
- 1) your actions to correct items of nonccepliance brought to your attention as a result of the investigation into March 28, 1979 accident, the findings of which were documented in NUREG 0600, " Investigation into the March 28, 1979 Three Mile Island Accident By the Office of Inspection and Enforcement"; and, 2) verification of your implementation of reccamendations contained in NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Ters Recommendations". Because of these differences, the term
" evaluation" is used to distinguish it frca the special team appraisals conducted at operating reactors..."
" Based on the findings, the Evaluation Team reached the overall conclusion that the Unit I aspects of the health physics program are adequate to support the present level of activities, but there are a number of significant weaknesses which must be corrected to provide reasonable assurance that the program will be ade';uate during cperation and major outages.
The significant weaknesses included the following:
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There was a lack of effective management oversight in assuring that the radiological controls, training and radioactive waste organizations were clearly defined, that personnel were properly selected, qualified and assigned responsibilities for staffing these organizations, and that assigr.ed responsibilities were being carried out.
2.
The exposure control program contained discrepancies between Unit 1 and Unit 2 indirect bioassay procedures, exhibited inadequacies in several calibration procedures, lacked action levels for issuance of special monitoring devices, exhibited shortcomings in the maintenance of respiratory protection equipment and had an established quality assurance program which failed to include all monitoring devices and contractor-supplied bioassay services.
3.
The solid radwaste shipping program lacked key elements for ensuring the proper use of shipping containers and implementation of the attendant QA requirements.
4.
There were incomplete and conflicting actions in relation to resolution of NUREG-0578 items.
Within the portion of the evaluation related to implementation of the Unit 1 draft proposed NUREG 0654 Emergency Plan, the Evaluation Team concluded that significant weaknesses included the following:
1.
The lack of clear assignment of individuals to the functional areas of emergency activity; 2.
Failure to have a clearly defined program for training individuals who may be assigned emergency duties; 3.
Procedures which implement the emergency plan were incomplete, overly general, and exhibited omissions of key elements; and 4.
There were facility and equipment shortcomings in relation to the Emergency Operations Facility, Environmental Assessment Center, and Reactor Building evacuation alarm.
Subsequent to the exit interview on August 8, 1980, various meetings were held with you and members of your staff to discuss the preliminary findings of the health physics evaluation.
During these meetings, additional information and preliminary responses were provided by Metropolitan Edison Company in reply to the preliminary findings identified by the Health Physics Evaluation Team.
The additional information and preliminary responses provided were reviewed and considered by the evaluation team in ccmpleting their overall evaluation of the Three Mile
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Island Unit I health physics program. We recognize that, as a result of these discussions, action to resolve the significant weaknesses has been initiated and, in many cases, may have been completed by this time.
Our verification of your corrective action will await your formal response to the request in the following paragraph.
After receiving your response, all information supplied will be reviewed for its implementation during subsequent inspections.
The significant weaknesses identified must be resolved prior to restart of Unit 1. Items identified as significant weaknesses which must be resolved were selected in a manner consistent with that used in selecting significant weaknesses which must be corrected at operating power reactors where special team appraisals have been conducted.
It is requested that you carefully review the 57 items identified as necessitating resolution prior to restart for consideration of effecting improvements in_the % alth physics and emergency planning programs. We recognize that an explicit regulatory requirement pertaining to each significant weakness identified in Appendix A may not currently exist.
However, to determine whether adequate protection will be provided for the health and safety of workers and the public, you are requested to submit a written statement within twenty (20) days of your receipt of this letter, describing your corrective action for each item requiring resolution prior to restart including:
(1) steps which have been taken; (2) steps which will be taken; and (3) a schedule for completion of action.
This request is made pursuant to Section 50.54(f) of Part 50, Title 10, Code of Federal Regulations.
We note that a number of the significant weaknesses identified are also applicable to Unit 2 because many of the findings for Unit 1 are based on the direct support which elements of the Unit 2 radiological controls and radwaste organizations provide to Unit 1.
This matter will be the subject of separate correspon-dence with respect to Unit 2.
During this evaluation, it was also found that certain of your activities did not appear to have been conducted in full compliance with NRC requirements, as set forth in the Notice of Violation enclosed herewith as Appendix A.
The items of noncompliance in Appendix A have been categorized into the levels of severity as described in our Criteria for Enforcement Action dated December 13, 1974.
Section 2.201 of Part 2, Title 10, Code of Federal Regulations, requires you to submit to this office, within twenty (20) days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further items of nancompliance; and (3) the date when full compliance will be achieved."
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B.
In a letter to the Director, Region I, Office of Inspection and Enforcement, NRC, dated December 11, 1980, Metropolitan Edison stated:
" Confirming discussions between Mr. V. Stello (NRC I&E) and Mr.
R. C. Arnold (Met-Ed), our response to the recent Health Physics Evaluation Report will not be submitted by the end of the 20-day period as requested in the forwarding letter for this report.
To ensure complete and expeditious resolution of the issues raised in the report we will meet with IE staff at your Region I Office on December 17, 1980 to discuss our proposed responses.
Following these discussions, it is our expectation that a new due date for the written response will be established.
We do expect to respond to the Notice of Violation of the subject letter on December 16, 1980 as requested."
C.
In a letter to the Director, Region I, Office of Inspection and Enforcement, NRC, dated December 16, 1980, " Health Physics Evaluation,"
Metropolitan Edison stated, in part:
"Your letter of November 26, 1980, forwarded the Three Mile Island Health Physics Evaluation Report from Region I and included a Notice of Violation which set forth five items of noncompliance.
Attached to this letter is a description of our actions to address those items of noncompliance. As discussed with Inspection and Enforcement management, our response to the items set forth in the evaluation as requiring corrective action prior to restart will be submitted at a later date.
While the NRC's Health Physics Evaluation concluded that the Unit 1 aspects of the health physics program are adequate to support the present level of activities, it identified significant weaknesses that must be corrected to provide reasonable assurance that the program will be adequate during operation and major outages..."
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In a letter to Metropolitan Edison dated December 31, 1980, the Director, Region I, Office of Inspection and Enforcement, NRC, l
stated:
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Subject:
Combined Management Meeting (50-289/80-32; 50-320/80-21)
This refers to the management meeting held at the NRC Region I Office, King of Prussia, Pennsylvania on December 17, 1980 which related to activities authorized by NRC License No.
DPR-50. The attendees of this meeting are listed in the enclosed meeting report and included J. G. Herbein, myself and members of our respective staffs.
The meeting was held at your request to discuss those proposed corrective actions already taken or planned to be taken for those items identified in the Three Mile Island (TMI) Unit 1 Health Physics Evaluation (Report No. 50-289/80-22) as significant weaknesses requiring improvement prior to Unit I restart.
5 It is our opinion that this meeting was beneficial and served to provide us with an understanding of the scope of your proposed actions and you with an understanding of our acceptance criteria.
The items identified in Report No. 50-289/80-22 as requiring improvement prior to Unit I restart and an understanding of your proposed corrective actions presented during the meeting are contained as an attachment to this letter.
Your proposed corrective actions, if implemented as described, would meet our acceptance criteria.
As a result of our discussions at the December 17, 1980 meeting, it is our understanding that you will provide this office your written response including your proposed corrective actions to Report No. 50-289/80-22 no later than January 30, 1981.
If your understanding of the above is different from ours please notify this office within 5 days of your receipt of this letter."
E.
In a letter to the Director, Region I, Office of Inspection and Enforcement, NRC, dated December 30, 1980, Metropolitan Edison stated, in part:
"In meetings with members of your staff on December 17 and 18, 1980 in King of Prussia, it was determined that early submittal of our response to the first thirteen (13) items set forth in the evaluation as requiring corrective action prior to Restart, would facilitate preparation of testimony for the Three Mile Island Unit 1 Restart Hearing.
The remaining items will be responded to at a later date.
Our response to the first thirteen (13) items required prior to Restart is attached..."
F.
In a letter to the Director, Region I, Office of Inspection and Enforcement, NRC, dated February,1980 (LTL 024), Metropolitan Edison stated:
"At the Combined Management Meeting held at the NRC Region I Office, King of Prussia, Pennsylvania on December 17, 1980, I
Metropolitan Edison Company agreed to provide written response, by January 30, 1981, for those items which require corrective action prior to Unit 1 Restart. As a result of that same meeting, Metropolitan Edison Company provided early submittal of responses to the first thirteen (13) items which pertained to management effectiveness.
Attached please find responses to the remaining forty-four (44) items requiring resolution prior to Unit 1 Restart.
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6 We believe the responses enclosed are consistent with the discussons held on December 17 and should resolve each item as identified by the NRC.
Some of the items provide additional details or explanations which may assist you in evaluating the responses."
G.
In a letter to the Director, Region I, Office of Inspection and Enforcement, NRC, dated February 13, 1981, " Combined Management Meeting (50-289/80-32; 50-320/80-21)", Metropolitan Edison stated:
"This letter is being submitted to clarify our position on the meeting siammary provided in your letter of December 31, 1981.
The following comments are given:
Item 22-20 is distinctly different from those minutes taken and discussed by members of the Met-Ed/GPU staff.
We did not commit to develop and utilize a conservative neutron flux to dose conversion factors at this time as stated in your 12/31/80 letter.
Item 22-19 NRC minutes do not indicate as do the Met-Ed/GPU minutes that the current badge system was determined to be acceptable for TMI-1."
H.
In a letter to the Director, Region I, Office of Inspection and Enforcement, NRC, dated February 27, 1981, " Health Physics Evaluation,"
Metropolitan Edison stated, in part:
"in telephone conversations with members of your staff, we were advised that supplemental information was desired to the responses given in my December 16 and 30, 1980 and February 2, 1981 letters.
This additional information is necessary to close those items identified in your November 26, 1980 letter as requiring resolution prior to restart.
The supplemental responses which are enclosed have been reviewed and agreed to by members of our respective staffs..."
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7 II.
Noncompliance Identification, Correction and Evaluations This section contains the NRC evaluations of the corrective actions taken by Metropolitan Edison in response to the items of noncompliance identifed during the Health Physics Evaluation.
In addition, this section contains information regarding other actions taken by Metropolitan Edison over the last year and was submitted along with this their responses to the j' ems of noncompliance.
GENERIC PROGRAM IMPROVEMENTS UNDERTAKEN BY METROPOLITAN EDISON In a letter to the Director, Region I, Office of Inspection and Enforcement, NRC, dated December 16, 1980, " Health Physics Evaluation," Metropolitan Edison stated, in part:
"...In view of the extensive scope of the inspection, the number of individual specific items flagged by the report as needing corrective action, the highlighting of the concern about management effectiveness in implementing the health physics program, and our request for additional opportunity to discuss our response to those items, we consider it appropriate to provide at this time a sumrary of the actions which have been undertaken by management over the last year to improve our Radiologica' Controls program. We believe that many of the items set forth in the evaluation report reflect that our planned upgrading is not yet complete.
Although prior to the accident our program was characterized by inspection personnel as about average for Region I, extensive efforts to build from that program base during the first six months after the accident to correct problems occurring during past accident activities and those identified during the various investigations into the accident were not successful.
This fact was evidenced by the many meetings and letters between the NRC and the Company and the appointment by the Director, NRR in September,1979 of a Special Panel on TMI Unit 2 Radiation Protection Program.
The Company recognized the ineffectiveness of its efforts and undertook in October, 1979 to completely revamp and reorient the resources being applied to our radiological controls program. A program plan was developed, and provided to the NRC to:
Increase the technical and management strength of the organization.
Increase the organizational stature and independence of the radiological control organization.
Upgrade the program procedures.
8 Formally state for the total organization the importance of the radiological control program and each radiation worker's responsi-bility for proper program implementation.
Upgrade and expand the training programs for radiological control technicians and workers.
Provide adequate formal definition of the organization and the responsibilities of the individual elements and positions within the organization.
This program had the involvement and support of management throughout the organization includir.g the president of General Public Utilities.
Major progress has ben made in carrying out this program including the following which affect the Unit 1 program:
Reorganization of the Radiological Control organization which began in November 1979, culminated in the placing of both Unit 1 and Unit 2 Radiological Control Departments under a single division head in the GPU Nuclear Group on July 1,1980, when staff additions become available to fill out the organization.
GPU/ Met-Ed issued a detailed Radiation Protection Plan in January 1980 committing management and all personnel to high standards of performance in radiological control.
The radiological control management was strengthened by the addition of experienced professionals.
Functions not essential to the Radiological Control Department were transferred to other groups.
The staff responsible for radiological control in Unit 1 was increased to five times its previous size.
Support activities such as instrument calibration and dosimetry now have separate organizations with resources dedicated to those tasks. Approximately 46 full time individuals in these two organizations alone perform functions previously done on a part-time basis.
Approximately one hundred radiological control procedures were rewritten to make it easier for workers to follow procedures exactly as written.
Results of efforts to reduce radiation exposure are already apparent since exposures for 1980 have be; one-third less than forecast.
9 Major radioactive work including steam generator inspection has been performed in 1980 with minimal radiological problems.
The Auxiliary Building area in Unit 1 controlled because of contamination has been reduced by 80%.
Training for radiological control personnel and those who perform radioactive work has been extensively upgraded.
Radiological Control Technicians have been carrying out their assigned responsibility to stop radiological work that is not performed properly.
Radiological audits and inspections have been upgraded, including assignment of an individual full time, to identify weaknesses before they become significant problems.
Unit 1 radioactive waste generation rate has been reduced by 50%.
Subsequent to the Unit 2 accident a Radioactive Waste Shipping group was formed within the Unit 2 Site Operations organization.
This dedicated group is responsible for shipping radioactive waste for both units whereas this function was previously handled on a part-time basis.
The Radioactive Waste Organization has been upgrading the radioactive waste program at TMI.
This upgrading includes procedure review, definition of responsibilities, radioactive waste reduction, and quality assurance measures such as checklists and audits.
We bel'ieve our corrective action progam as identified in the radio-logical control management plans has been bicad based and responsive to the scope of the identified problems. We are dedicated to completing that program as scheduled and are confident it will result in a health physics capabilid/ sufficient to fully support normal operation, major outages, off normal conditions and the decontamination of Unit 2.
Further, we expect that our overall efforts to improve the TMI radiological program, including an expansion of the application of our Quality Assurance Program in conducting surveillance and audits of radiological work activities will substantially reduce the likeli-hood of further items of noncompliance.
Upgrading of our emergency plan also has been the subject of extensive efforts. ' Starting with the draft guidelines made available in September.1979, the draft NUREG 0654 distributed in January 1980 and publication of the final rule (10 CFR Appendix E) in November 1980 we have been working continuously and conscientiously with NRC to develop an acceptable Emergency Plan, the additional response capabil-ities and the implementing procedures. Our understanding is that we were the first utility to be authorized to implement a Plan consistent with the requirements of draft NUREG 0654. We have made even further improvements to reflect comments on that version of the Plan and to comply with the final rule on Emergency Planning.
1 10 We have expanded the staffing and improved the management capability for this area of activity also. We now have a corporate department head reporting at the vice president level dedicated to emergency preparedness. The professional qualification and personal capabil-ities of the individual assigned to this position have been endorsed, based upon prior association, by personnel of the Pennsylvania Emergency Management Agency.
We will be completing our detailed procedures and implementing our new emergency program on the schedule established by NRC. We antici-pate this effort will satisfy the concerns raised in the related portions of the evaluation report."
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11 ITEMS OF NONCOMPLIANCE, CORRECTIVE ACTIONS AND NRC EVALUATION A.
Certain Respiratory Protection Procedures Were Not Maintained and Implemented Apparent Item of Noncomolian g
Reference:
NRC letter to Metropo;itan Edison dated November 26, 1980.
Contrary to 10 CFR 20.103(c) and Regulatory Guide 8.15:
(1) As of August 1,1980, allowance was made for the use of respir-atory protective equipment, but written procedures for perform-ing periodic maintenance on self-contained breathing apparatus (SCBA) units and air-line respirator regulators were not approved and implemented.
This lack of approved, detailed programmatic guidance contributed directly to a) the unavailability of records documenting periodic maintenance reportedly being performed and b) the licensee's failure to recognize the neces-sity of performing periodic calibration / maintenance of airline respirator pressure regulators.
(2) As of August 1,1980, allowance was made for the use of respir-atory protective equipment but, procedures for filling the SCBA air bottles, using either the Eagle or Mako breathing air compressors did not exist. Operating procedures / instructions are necessary to assure: a) the safety of personnel operating high pressure air compressors, and b) performance of proper, periodic maintenance of the equipment to ensure continued capability of supplying high quality breathing air.
First Statement in Reply to Notice of Violation I
Reference:
Metropolitan Edison letter to NRC dated December 16, 1980.
A(1) Prior to the evaluation, GPU/ Met-Ed had identified inadequacies in the existing respiratory protection procedures and had procedure revisions in process.
These procedures were revised to include periodic maintenance on self-contained breathing apparatus units and air line respirator regulators and were issued as follows:
8-12-80 Inspection, Maintenance and Repair of Respiratory Equipment - RCP 4053, Revision 0.
8-28-80 Respiratory Protection Program - RCP 4051, Revision 1.
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The results of the GPU/ Met-Ed bioassay r,rogram, both whole body counting and specimen bioassays, have demonstrated that the Respiratory Protection Program has been operationally effective.
Full compliance has been achieved.
A(2) Operating Procedures for the Eagle and Make breathing air compressor for filling SCBA bottles are currently in preparation I
and will be approved for implementation by January 31, 1981.
Preventative Maintenance procedures for both compressors existed prior to the Health Physics Evaluation (PM-M-121 4/80 for Mako and PM-M-1.'.1 through 114 4/79 for the Eagle compressor).
Manufacturers operating instructio.ns for the Eagle compressor and Instructions for Recharging Breathing Air Systems are both in use for filling SCBA bottles, however, they have not been formally approveJ.
This is a correction to the Met-Ed letter responding to informal items to Region I dated October 31, 1980 file number TLL 566.
Full compliance will be achieved January 31, 1961.
Initial Evaluation of Licensee Resoonse The response states that certain actions are being taken which could correct this problem such as revisions to certain procedures, however, corrective steps which have been taken to prevent further items of noncompliance were not addressed.
Additional Statement in Reply to Notice of Violation
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
In addition to the procedure revisions noted in our earlier response to Items Al and A2, increased emphasis on procedure compliance, other. improved procedures, additional assigned personnel resources and personnel reinstruction in the corporate policy of verbatim compliance function as a system to prevent recurrence of this item.
Licensee will ensure that the management policy on use of and verbatim compliance with procedures is included as part of the General Employee Training (GET) and annual retraining programs.
Final NRC Evaluation of Licensee Responses Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
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13 B.
Respiratory Protection Program Was Not Being Audited Apparent Item of Noncompliance
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Contrary to Technical Specification 6.11, 10 CFR 20 requirements and Rai;ological Controls Procedure No. 1616.2, based on discussions with the individual responsible for overseeing the respiratory protection program in Unit 1 (Supervisor, Radiological Engineering' it was determined that as of the time of the NRC Health Physics Evaluation, Procedure No. 1616.2 had not been implemented in that, the program was not being audited as required and no other mechanism was ongoing to provide timely management overview to evaluate the full effectiveness of the respiratory program.
First Statement in Reply to Notice of Violation
Reference:
Metropolitan Edison letter to NRC dated December 16, 1980.
As stated to the NRC inspector during the evaluation, this deficiency in conducti1g the audits required by the TMI Unit 1 procedure had been identified by the licer.see prior to the inspection.
The required audits are now being conducted monthly.
Full compliance has been achieved.
Initial Evaluation of Licensee Response The response states that full compliance has been achieved and that required audits are being performed, however, corrective s ups which have been taken to prevent further items of noncompliance were not addressed.
Additional Statement in Reply to Notice of Violation
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
The licensee's letter stated, in part:
"In addition,... increased emphasis on procedure compliance, other improved procedures, additional assigned personnel resources and personnel reinstruction in the corporate policy of verbatim compliance function as a system to prevent recurrence of this item.
Licensee will ensure that the management policy on use of and verbatim compliance with procedures is included as part of the GET and annual retraining programs."
14 2
Final NRC Evaluation of Licensee Responses
.I Metropolitan Edison's responses concerning corrective actions are 4
acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior i
to TMI-l restart.
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15 C.
Quality Assurance Criteria for Shipoino Packaces for Radioactive Material - Recuirements were Not Met Aco& rent Item of Noncomoliance
Reference:
NRC letter to Metropolitan Edison dated November 25, 1980.
Contrary to 10 CFR 71.51 and 10 CFR 71, Appendix E, Criteria 10 and 12:
(1) On June 5 and 30, 1980, two radioactive waste shipments (Nos.
80-49 and 80-56) were delivered to a carrier for transport without mandatory QA inspection hold points being witnessed.
The QA hold points were intended to assure compliance with package Certificates of Complianca and package lid closure.
(2) As of the time of the NRC Health Physics Evaluation, no measures were established to assure that torque wrenches, used to torque package lids to shipping casks, r.n activity affecting quality, were properly controlled, caliba ted and adjusted.
The licensee's contractor loading and package closir.g procedure for shipment of licensed material provided lid torque limits and tolerance values.
Statement in Reply to Notice of Violation
Reference:
Metropolitan Edison letter to NRC dated December 16, 1980.
C(1) A review of a.1 Type B shipment record since late 1979 was conducted by Quality Assurance personnel. Administrative errors were found including the deviation from the requirements to sign off the Rad Waste procedure.
The witnessing and holdpoint i
verification of shipments 80-49 and 80-56 were performed by QA l
surveillance personnel. This is documented in QA Surveillance Reports 80-77 and 80-95. To improve administrative controls and provide better documentation the Radioactive Waste procedur will be revised by 1/31/81 to include a requirement for hold point signature by QA personnel. QA and Radioactive Waste personnel will be re-indoctrinated by 2/1/81 in these requirements.
Full compliance has been achieved and further improvements will be complete 2/1/81.
C(2) 1.
The governing procedure in effect at the time of the evaluation to control torque wrenches was TMI Station Administrative Procedure AP 1022 " Control of Measuring and Test Equipment", dated Novemcer 13, 1978.
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Operating Procedure 2104-4.13, with attachments for the closure of shipping cask lid bolts, requires the torquing of bolts to specified values.
3.
The QA Surveillance checklist requires verification that the cask lid closure is correct.
A review of past QA Surveillance checklists indicated that al' cask lid closure were witnessed by QA in accordance with their checklist and in some specific instances the surveillance persornel indicated the torque wrench number.
4.
Since specific shipment numbers or dates were not cited by the NRC in their description of the apparent infraction further verification could not be performed.
To improve administrative control and provide better documentation the operating procedure OP 2104-4.13 will be revised to require listing the torque wrench number and calibration due date.
Full compliance has been achieved and further improvements will be complete by issuing a revised procedure by 1/31/81.
Evaluation of Licensee Response Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
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17 0.
No PORC Reviewed and Unit Suoerintendent Acoroved Whole Body Counter and Laboratory Counting Equioment Procecures Were In use Apoarent Item of Noncompliance
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Contrary to Technical Specification 6.8.1 and Appendix "A" of Regulatory Guide 1.33, November 1972, as of July 28, 1980 no Unit Superintendent approved or PORC reviewed procedures were being used fcr operation, 4
calibration and Quality Assurance of the whole body counter, a device used for personnel monitoring, or for the Unit 2 contractor laboratory counting equipment. The contractor counting equipment was being used to analyze samples of effluents being released from Unit 1.
First Statement in Reply to Notice of Violation
Reference:
Metropolitan Edison letter to NRC dated December 16, 1980.
GPU/ Met-Ed disagrees with the NRC Evaluation team's interpretation that contractor procedurcs must be reviewed and approved by the PORC and Unit Superintendent respectively.
GPU/ Met-Ed maintain that in the case of contractor services the contractor should be required by contract to have a contractor-approved quality assurance program satisfactory to the licensee for the type of services covered by the contract. When such an approved program requires written procedures for the work, licensee auditing of the program is the verification that the contractor procedures are being followed and that they are in accordance with the contractor's quality assurance program.
The whole body counting contractor, Radiation Management Corporation and the two chemistry contractors, B&W and SAI, have such contracts and quality assurance programs satisfactory to the owner. Audits of the onsite radiochemistry work by SAI and B&W were completed in April 1980 and September 1980.
Audit of RMC is in progress.
B&W and SAI have worked to their own procedures. These procedures are being approved by GPU/ Met-Ed since GPU/ Met-Ed intends to accomplish this work in the future. & spiked sampTe program has existed with the two contractors and GPU/ Met-Ed since after the TMI-2 accident.
Results have been documented;.but the program wasn't documented-until GPU/ Met-Ed prepared a formal Quality Control Program for Radiochemistry Instrumentation (Procedure 1982).
This procedure provides for daily background counting and calibration also, a
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18 The SAI and B&W procedures will be transformed to GPU/ Met-Ed procedures i
by January 31, 1981; which requires PORC review and Superintendent approval.
Initial Evaluation of Licensee Response The licensee's response did rot adequately address corrective actions with regard to operation, calibration or quality assurance of the whole body counter.
The license's response did not provide any new information that wasn't already documented in the details of Evaluation Report 80-22, therefore, the licensee's response is unsatisfactory.
Additional Statement in Reply to Notice of Violation
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
The Whole Body Counting equipment must be operated by a certified individual.
This requirement is specified in the Whole Body Counter operating specification.
Individuals a m certified by RMC upon completion of the Whole Body Counter Training Program wnich is established by a Training Outline.
The Whole Body Counting equipment is operated in accordance with RMC written procedures.
These items (Operating Specifications, Training Outline and Procedures) are a part of the Wohle Body Counting Manual which has been approved by GPU Radiological Controls.
The QA Program which verifies the adequacy of the Whole Body Counter service is specified in RCP 4239.-
Included in these requirements, among other items, are daily source checks and quarterly calibration checks with a phantom containing radioactive sources. These checks are reviewed by trained and experienced personnel in the Radiological Controls Organization.
Be RCP will be revised by May 30, 1981 to specify performance standa rds and review requirement by the Radiological Health organization.
l The Manager, Radiological Health, with assistance from the Manager, I
Radiological Technical Support, is responsible for verifying compliance with the above procedures and for ensuring that the Whole Body Count l
Program is maintained consistent with applicable Reoulatory Guides and Standards. The Quality Assurance Department a'.;o monitors and audits performance in this area as a part of their regular audit j
program.
Final NRC Evaluation of Licensee-Resoonses Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to THI-1 restart.
12 E.
Licensee Had Not Determined if Approcriate Extremity Monitorinq Device Were Being Supplied Apparent Item of Noncomoliance
Reference:
NRC letter to Metiopolitan Edison dated November 26, 1980.
Contrary to 10 CFR 20.201(b), 10 CFR 20.201(a), and 10 CFR 20.202(a),
as of July 2f.,1980, the licensee had not determined if appropriate extremity monitoring devices wore being provided to individuals.
The devices provided were TLC ring badges that were supplied, processed and quality controlled entirely by the vendor.
The licensee had not performed any evaluation of the adequacy of the device or the processing capabilities of the vendor to determine if the device and the vendor's processing were acceptable and capable of evaluating personnel extremity exposure due to the presence of radioactive materials.
The licensee routinely issues the devices to personnel who may sustain extremity exposure.
5tatement in Reply of Violation
Reference:
Metropolitan Edison letter to NRC dated December 16, 1980.
"10 CFR 20.201 Surveys" requires evaluations of radiation hazards; such evaluations are conducted using portable radiation monitoring equipment.
"10 CFR 20.202 Personnel Monitoring" requires each licensee to supply appropriate personnel monitoring equipment.
The vendor, Harshaw, Inc., is a nationally utilized supplier of this same TLD personnel monitoring device for reactor work.
The appropriateness of the single chip TLD and processing capability were verified by GPU/ Met-Ed subsequent to the NRC Evalution.
Evaluation of Licensee Response
Reference:
Telephone discussions on February 26, 1981 between members of ths NRC Region I staff and Metropolitan Edi~ son staff members.
Metropolitan Edison denied this as an item of noncompliance. However, licensee represento.ives stated during the telephone discussions (referenced above) that while they did not agree this was an item of.
noncompliance they had instituted procedures on their own initiative which would provide quality control measures over procurement and processing of personnel monitoring devices received frcm contracted suppliers in the future.
20 The NRC staff position was that the item stated was an item of noncompliance.
Therefore, notwithstanding the licensee's denial of the item of noncompliance, which remains as cited, and subject to reinspection, the NRC staff finds that acceptable resolution of the issue has occurred.
Satisfactory implemente. tion of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-l restart.
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21 III. Significant Weakness Identification, Correction and Evaluation This section contains the NRC evaluations of the corrective actions taken by Matropolitan Edison in response to the siinificant weaknesses identified as a result of the Health Physics Evaluation.
DESCRIPTION OF GENERAL PUBLIC UTILITIES /METROPLITAN EDISON MANAGEMENT DOCUMENTS In a letter to the Director, Region I, Office of Inspecton and Enforcement, NRC, dated December 30, 1980, Metropolitan Edison stated, in part:
"In analyzing the thirteen (13) management effectiveness items and our response, it will be helpful to review briefly the content of seven (7)
GPU/ Met-Ed management documents and why these documents were only partially available during the evaluation.
More than a year ago, GPU/ Met-Ed recognized that a significant restruc-turing of the Radiological Control Program at TMI Unit 1 and 2 was necessary.
Timely implementation of this upgrading effort required placing emphasis on performance related items and a lessor priority on documentation.
These performance items having been to a great extent accomplished, the GPU/ Met-Ed priority has now been placed on form and format items.
This next phase of upgrading will include the development of or improvements in the documents listed below by the schedule indicated.
The schedule is based on the present Commission Order, the ASLB Hearings, and our schedule for criticality which is September 21, 1981.
1.
GPU Nuclear Organization Plan January 31, 1981 2.
Personnel Charts January 31, 1981 3.
Department Organization Plans a)
THI-1 Radiological Controls February 28, 1931 b)
THI-2 Radiological Controls February 28, 1981 c)
Corporate Radiological Controls February 28, 1981 4.
Program Responsibilities Document (Radwaste) February 28, 1981 5.
Position Descriptions August 21, 1981 6.
Training Administration Manual February 28, 1981 7.
Position Specifications August 21, 1981 l
Items 5 and 7, Position Descriptions and Specifications encompass the entire GPU Nuclear Group, however, priority will be given to those in the Radiological Control Area covered by the evaluation.
The GPU Nuclear Organization Plan will include a description of each division's mission, responsibilities and organization structure to the Section Head level.
The Personnel Charts will list each member of the GPU Nuclear Group and cefine his/her reporting relationship.
22 The Department Organization Plans were developed prior to the evaluation as Project Organization Responsibility Documents and defined the responsi-bilities of members within the Unit 1 and Unit 2 Radiological Control Organization.
They will be revised as Department Organization Plans and include additional definition of the interfacing of the Unit 1 Radiological Control Department and those eienents of the Unit 2 Radiological Control Department which support Unit 1.
The Program Responsibility Document has been under development for some months in the Radwaste area.
This document oeffnes the interfaces and responsibilities of the several departments involvd with the production, handling, analysis and shipment of Radwaste.
Position descriptions are being revised to reflect the current GPU/ Met-Ed organization. These descriptions will describe the following for each supervisory and management position associated with Three Mile Island:
I Accountability Objective Il Dimension III Nature and Scope IV Principle Accountabilities The Training Department's Administrative Manual is in preparation and includes the following sections:
- 1. 0 Introduction 2.0 Nuclear Assurance Organization Description 3.0 Training Department Policy 4.0 Functional Objectives 5.0 Training Department Organization 6.0 Training Programs 7.0 Training Department Procedures The first five sections have been prepared in draft form for approval and implementation by February 1,1981.
Sections 6 and 7 currently contain programs and procedures in either approved or draft form.
The General Employee Training, Radwaste Administration and Unit 1 Radiological Controls Technician programs have all been approved by the cognizant Managers of Radiological Controls and by the Manager of Training.
All programs and procedures for the Training Department will be addressed in the Manual as they are developed and approved.
The programs listed below are currently being conducted and formal documen-tation being developed by the Training Department:
Licensed Operators (R0 and SRO)
Non-Licensed Operstors Maintenance Chemistry Security Force Members Emergency Response Team Memcers
23 Fire Brigade Members Shift Technical Advisors Supervisory Personnel (Supervisury Skills and Decision Analysis)
Instructors Position specifications are being developed which contain a description of:
Position Function Minimum Education / Experience / License and Certification Required Additional Education / Experience / License and Certification Desired Minimum Training Required Additional Training Desired An example was reviewed in the December 17, 1980 meeting.
We hope this information will be helpful in providing a background for analysis of our responses to the first thirteen (13) items in the evaluation report.
We also believe this letter provides an adequate response to the first significant weakness in Health Physics Program set forth on page 2 of your letter of November 26, 1980 concerning effective management oversight of Radiological Controls, Training and Radioactive Waste Organiza-tion."
NOTE:
Those significant findings dis issed in the following paragraphs marked with an
- also relate to Unit 2 and must be acted.upon prior to restart of THI-Unit 1 (
Reference:
Letter from NRC dated December 31,1980).
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24 SIGNIFICANT WEAKNESSES. CORRECTIVE ACTIONS AND EVALUATIONS A.
Organization, Responsibilities, Staffing and Management Oversight Significant Finding No. 50-289/80-22-01
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Definition of the interfaces of the Unit 1 Radiological Controls Department and radwaste operations functions with those elements of Unit 2 which support Unit 1.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
A GPU Nuclear Organization Plan will be develcped which will present all positions down to and including the Section Head Level.
Also to be developed is a Department Plan Organization, Program Responsibility Document and a Personnel Chart.
The interfaces will be defined in these documents.
A technical specification change request is to be submitted which defines the new organization.
Statement in Reply to Significant Aporaisal Finding
Reference:
Metropolitan Edison lett-r to NRC dated December 30, 1980.
The following GPU/ Met-Ed management documents will be developed in response to this item:
GPU Nuclear Greco Organization Plan Personnel Charts Department Organization Plans (Radiological Controls)
Program Organization Responsibility Document for Radwaste Position Specifications Position Descriptions Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactrry implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1' restart.
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Significant Finding No. 50-289/80-22-02 l
Reference:
NRC letter to Metropolitan Edison dated 1
November 26, 1930.
Definition of the Unit 1 Training Department organizational structure down to and including the instructor level.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The training Department Organization will be presanted in the documents to be developed to satisfy Item 80-22-01.
Statement in Reply to Significant eporaisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
The following GPU/ Met-Ed management documents will be developed in response to this item:
GPU Nuclear Group Organization Plan Department Organization Plans (Radiological Controls)
Personnel Chart Training Department Administrative Manual Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropofitan Edison's responses concerning corrective actions are l
acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
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Significant Finding No. 50-289/80-22-04
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Definition of the Unit 2 Radiological Controls Department organizational structure down to and including the non-supervisory level and reflecting organizational interfaces with the Unit 1 radiological controls program.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Thi's department organization will be presented in the documents to be developed to satisfy Item 80-22-01.
Procedure 4010 will also address this topic and will be revised as necessary to reflect current organization which is to be defined for Item 80-22-01.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
The following GPU/ Met-Ed management documents will be developed in 1
response to this item:
GPU Nuclesr Group Organization Plan Department Organization Plans (Radiological Controls)
Personoci Charts Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified oy the Office of Inspection and Enforcement prior i
to TMI-1 restart.
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i 27 Significant Finding No. 50-289/80-22-05
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Definition of the Unit 2 radioactive waste organizational structure down to and including the non-supervisory level and reflecting organizational interfaces with the Unit 1 program.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This department organization will be presented in the documents to be developed to satisfy Item 80-22-01.
Statement in Reply to Significant Acpraisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, ~ '80.
The following GPU, Met-Ed management documents will be developed in response to this item:
GPU Nuclear Group Organization Plan Personnel Charts Program Organization Responsibility Document for Ra1 waste by 2/28/81.
Department Organization Plans (Radiological Controls)
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
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Significant Finding No. 50-289/80-22-C6
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
1 Development of job descripticos for positions in the THI-1 Radiological Controls Department.
Licensee Planned Action
Reference:
NRC letter to Metropolit,, Edison dated December 30, 1980.
Position descriptions to be called Position Specifications will be i
developed which will identify position, states who position re: orts to, minimum education and experience needed, any licenses needed, additional desired education, mini =um training and any additional training needed.
Statement in Recly to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated Decemoer 31, 1980.
The following GPU/ Met-Ed management documents will be developed in response to this item:
GPU Nuclear Group Organization Plan Personnel Charts Program Organization Responsibility Occumcnt for Radwaste Position Descriptions Position Specifications In addition, revised job descriptions are being negotiated for technician positions.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated Decencer 30, 1980.
(2) NRC letter to Metropolitan Ecison dated December 31, 1980.
Metropo'.itan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-l restart.
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29 Significant Finding No. 50-289/80-22-08
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Definition of the responsibilities and functions to be performed by the corporate element of the Radiological Controls Department.
Licensee Planned Actions
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This will be defined in the Department Organization Plan, and the Corporate Organization Plan.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
The following GPU/ Met-Ed management documents will be developed in response to this item:
GPU Nuclear Group Organization Plan Department Organization Plan (Corporate Radiological Controls)
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to Ni'C dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning correctite actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
30 Sicnificant Ficcinc No. 50-239/50-22-10
Reference:
NRC letter to Metropolitan Eciscn catec November 25, 1980.
Develecsent and isolesentatica cf staffing plans to ensure tnat tne res ensibilities ar.d functions assigned to the corporate ele:ent of the Raciological Centrols Cepartzent can be ;erfersed.
Licensee Planned Acticn
Reference:
NRC letter to Metrecolitan Ecisen catec Cecencer 31, 1950.
This will be defined in the Corporate Organizaticn Plan, the Ce:artment Organi:ation Plan anc tte Personnel Chart.
Statesent in Recly to Significant Accraisal Fincinc
Reference:
Metrecolitan Edisen letter to hRC cated Ceceecer 30, 1980.
The fo11cwing GPU/ Met-Ed zanagement cccusents -ill te develeped in response to this iten:
GPU Nuclear Grcup Organi:ation Plan
' Personnel Charts Department Organization Plan (Corscrate Radiological Centrols)
Evaluatien of Licensee Ressense
References:
(1) Metropolitan Edison letter to NRC dated Decencer 30, 1930.
(2) NRC letter to Metropolitan Ecisen cated Decencer 31, 1980.
Metrepolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective seasures will be verified by the Office of Inscection and Enforcement prior to TMI-1 restart.
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31 Significant Finding No. 50-289/80-22-11
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Review of the adequacy of the implementation of the management and managerial functions in relation to the radiological controls program at the TMI site by an independent review group, outside the GPU system, having expertise in the review and analysis of management principles and practices.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
An audit will be performed to prepare for licensing hearings. Will address organization, communications and training.
Statement in Reply to Significant Aporaisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
The Three Mile Island Nuclear Station Unit 1 Radiation Protection Plan commits, in Article 3, to:
" Periodically, the services of an outside consultant will be retained to provide evaluation and guidance on ways to improve the TMI-1 Radiological Controls Program." The evaluation and guidance on ways to improve the program will include review and analysis of management principles and practices as they apply to the Radiological Controls Program.
The evaluation is being conducted by Basic Energy Technology Associates, Inc. as part of a general review and analysis of the appliction of management principles and practices throughout the GPU Nuclear Group.
The results of this evaluation will be available by 2/28/81.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of thes corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
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Significant Finding No. 50-289/80-22-13
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of selection criteria for all positions in the Unit I radwaste organization which include formal education, experience and training factors.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The selection criteria will be presented in Position Specification.
The Position Specification will contain the elements discussed in licensee planned action for Item No. 80-22-06.
Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
Position Specifications will be developed in response to this item.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
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33 Significant Finding No. 50-289/80-22-14
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Development of selection criteria for all positions in the Unit 2 radwaste organization which include formal education, experience and training factors.
Licensee planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The selection criteria will be contained in the Position Specifica-tion.
The specification will contain the elements discussed in
-licensee planned action for Item No. 80-22-06.
Positions down to technical level will be addressed.
Statement in Reoly to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
Position. Specifications will be developed in response to this item.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to THI-1 Restart.
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- i 34 Significant Finding No. 50-289/80-22-15
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
i Development and implementation of selection criteria for staff positions in the corporate element of the Radiological Controls t
Department.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The selection criteria will be presanted in Position Specification.
(See Item No. 80-22-06.)
Statement in Reply to Significant Aporaisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
Position Specifications will be developed in response to this item.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC date'l December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
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o 35 Significant Finding No. 50-289/80-22-16
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Development and implementation of approved training and replacement training programs for Unit 1 general employees, radiological controls, radwaste and training personnel.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The training and replacement training will be presented and discussed
'in the Training Department Manual and Procedure 1690 series.
First Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
The Training Department's Administrative Manual will be developed in response to this item.
Initial Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
The response did not address when actual implementation of the training programs would be initiated.
Additional Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
The Training Department Administrative Manual describes programs already in place in the areas of Radiological Controls, General Employee, Rad Waste Training and the Instructor Development Program.
Therefore, formal implementation for those areas is the date of issue.
36 Final NRC Evaluation of Licensee Responses i
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures i
will be verified by the Office of Inspec'.Sn and Enforcement prior to TMI-1 restart.
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37 Significant Finding No. 50-289/80-22-17 Reference nkC letter to Metropolitan Edison dated November 26, 1980.
Development and implementation of retraining and replacement training programs for Unit 2 radiological controls and radwaste personnel.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Documentation will be contained in the Training Department Manual.
Programs will be developed for ALARA engineers, dosimetry engineers, dose assessment personnel-and Radiological Control Instrumentation Technicians.
Final Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated December 30, 1980.
1.
The Training Department's Administrative Manual will be developed in response to this item.
2.
The Unit 2 Radiological Controls Training Procedures will be issued by 2/28/81.
Initial Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated December 30, 1980.
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
ihe response did not address the implementation of the retraining and replacement training programs.
Additional Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
The TMI-2 Radiological Controls Section of the Corporate Radiological Controls Trainfog Manual was approved on February 27, 1981.
This section of the manual is effective on issue.
An early response refers to this manual section as a procedure.
Training for Unit 2 Rad Waste personnel is covered by the Training Department's Administrative Manual.
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38 Final NRC Evaluation of Licensee Resconses Metropolitan Edison's responses concerning corrective actions e.re acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
39 8.
Exposure Control Significant Finding No. 50-289/80-22-19
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Resolution of the effect of high energy (approximately 2.2 MeV endpoint) beta radiation on the TLD gamma exposure results.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The licensee will submit details as to the nature, extent and control of this effect at Unit 1.
First Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024)
The effect of high energy (i.e. 2.2 MeV endpoint) beta radiation on the TLD gamma exposure results is limited to the effect of strontium activity in Unit 2 and is not a factor on TLD exposures in Unit 1 under normal operating conditions.
The effect of high energy radiation on the TLD gamma results is a consideration in some areas of Unit 2.
During the past 15 months the company has expended extensive research resources to obtain an approved beta monitoring capability.
Since there was no commercial system readily available which was considered acceptable for use without some modification, three systems, a Harshaw system, a Pana-sonic system and an INEL system have been researched.
None of these systems as presented by the manufacturer are acceptable as is for TMI use. Two of the systems are not on the market (readily available i
for short term order) and one of the systems is still in the develop-l ment stage.
GPU/ Met-Ed has been working closely with one of these companies in particular and has had on site representatives of the other two companies. Any of the three systems will ultimately l
require additional technical and management efforts by GPU/ Met-Ed to j
ensure that the system procurred for use is adequate for our purpose.
l The recommmendation to improve the TMI beta monitoring system cculd caly be achieved with an extensive research and investigative effort on the part of the company and with the cooperation of the vendors.
Due to our efforts and the efforts of the cugnizant vendors a final l
decision on one of the three systems which will improve the beta l
monitoring capabilities at TMI has been made.
It is expected that l
l l
40 the procurement and installation, calibration, computer software, preparation and comt' uter tie-in will require several months.
Since the high energy beta radiation is not a factor in TLD exposures in Unit 1 under normal operating conditions the implementation of this new system is not considered a prerequiste to startup of Unit 1.
Initial Evaluation of Licent e Resoonse
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024)
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
The response did not state how the licensee prepared t0 control individual exposures to the high energy beta radiation (i.e., Unit 1 personnel entering Unit 2 controlled areas) and what method would be established and implemented to identify and assess the potential doses received 5v these individuals as a result of their entries into the areas.
Additional Statement in Reply to Sicnificant Accraisal Findino
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
With noted exceptions, the beta correction factors used for TMI Stations are based on a natural uranium correction factor.
Compared with a Strontium-90 beta correction factor this is a " conservative" or higher factor; therefore, if used in a beta radiation field composed of mixed isotopes, some of which were Strontium-90, use of this factor would yield a slightly higher exposure indication. This correction factor is determined by technical personnel and then programmed into the computer for automatic beta interpretation and requires no manipulations or calculations on the part of the TLD equipment operator.
Likewise, some Strontium-90 activity in a beta field will yield slightly higher exposure indications on the gamma component.
Since, in most areas this is a small percentage and the exposure indications are higher than actual (conservative), normally no correction is made.
In some areas of Unit 2, where significant quantities of Strontium-90 are found, dose assessments by tecnnical personnel are made on a case basis where the indicated exposure warrants.
Entry to these areas is rigidly controlled and requires completion of detailed data sheets and approval Director, Radiological Controls Unit 2.
Final NRC Evaluation of Licensee Responses Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-I restart.
41 Significant Finding No. 50-289/80-22-20
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980.
Decision as to what neutron monitoring equipment will be used at TMI for monitoring neutron exposure and implementation of that program.
If a badge device is selected, the device should be capable of responding to neutrons of energies from thermal to at least 1 MeV and should have a lower limit of detection of not greater than 30 millirems.
Special consideration of neutron threshold energies for the detector (140 kev) when major portions of neutron exposures are from energies less than 140 kev should be applied.
Licensee Planned Action Referer.ce: NRC letter to Metropolitan Edison dated December 31, 1980.
The licensee is currently conducting a review to locate a suitable device.
Until such time, the licensee will develop and utilize conservative neutron flux to dose conversion factors.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edicon letter to NRC dated February,1980 (LTL 024)
In the current shutdown condition, neutron monitoring is being performed by a dosimetry contractor, R. S. Landauer.
Landauer is a supplier of beta, gamma and neutron monitoring devices on a nationwide basis.
Under shutdown conditions the vendor neutron dosimetry device is considered adequate.
The company has made extensive contacts with vendors and with other professionals in neutron dosimetry monitoring and has been unable to locate a supplier of neutron monitoring equipment which is considered capable of meeting the criteria specified by the NRC.
Therefore, when Unit 1 becomes operational the neutron dosimetr monitoring procedures in effect for Unit 1 prior to March 28, 1979 will be used with additional confirmation of correction factors for specific plant areas should the additional correction factors be warranted.
The additional correction would, of course, be determined after startup of Unit I when dose rates can be taken. Although the technique will require the use of dose rate instrument determined correction factors to be applied to the neutron monitoring badge, it has the advantage of full time personnel monitoring while in the neutron field.
42 GPU/ Met-Ed will contir.oe to pursue investigations of neutron monitoring devices from commercial or research resources and will consider the use of any advances in neutron monitoring as new devices are available on the market and as they are considered tc meet the NRC response criteria.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
43 Significant Finding No. 50-289/80-22-22
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Establishment of action levels for the issuance and use of special case personnel monitoring devices under conditions where exposures to the extremities, skin of the whole body or lens of the eye may be limiting.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
A procedure will be established to provide for this item.
First Statement in Reply to Significant Aopraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Revision 11, (RCP) 1613 ' Radiation Work Permits' dated June 13, 1980 specifies criteria for issuance of extremity dosimetry.
Revision 13 of RCP 1613 (dated January 5, 1981) requires issuance of extremity monitoring when performing primary sampling, OTSG entries, manipulatine high intensity radiation sources, and any time the extremity exposure rate is likely to exceed specified criteria.
All TLD's now in use at TMI-1 are analyzed for beta exposure.
Initial Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
The response only addresses the use of extremity monitoring and does not reflect action levels or use of special case monitoring for situations such as exposure to the lens of the eyes or head.
Additional Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
Radiological Control Procedure 4200, "TLD Assignment, Issue and Data Handling" provides procedures for the issuance of extremity monitoring devices and special monitoring devices; however, it lacks the specificity
4 t
44 to ensure that the specific items noted in the Evaluation Report will be accomplished.
RCP 4200 will be revised to add the needed specificity as to performance standards which must be considered in making individual dosimetry decisions.
This revision will be com-pleted by May 30, 1981.
Final NRC Evaluation of Licensee Resoonses a
Metropolitan Edison's responses concerning corrective actions are i
acceptable. - Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
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o 45 Significant Finding No. 50-289/80-22-23
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development and implementation of a QA program for vendor supplied and processed extremity monitoring devices.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The licensee has established and implemented a QA program for extremity monitoring devices.
Statement in Reoly to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
The QA Program for extremity monitoring was implemented in Octobecs 1980.
The program includes a " spike" test for finger rings which
-l are processed by the vendor. The program requires a semi-annual test with acceptance criteria as defined in NUREG/CR-1063 modified by HPSSC WG-4.
A PRC to RCP 4220 has been submitted to incorporate the finger ring test requirements and is expected to be issued 5/30/81.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
46 Significant Finding No. 50-289/80-22-24
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Within the existing QA program, development and implementation of provisions for determining correction factors to be applied in the determination of gamma doses received in mixed radiation fields.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This will be addressed in conjunction with Item No. 80-22-19.
Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Gamma calibration factors are not applied to Unit 1 TLD data as implied in the findir.g.
The exposure received on the deep chip is taken as the penetrating dose.
The beta emitters expected to be encountered during normal Unit 1 operations have energies too low to penetrate to the deep chip.
Thus no gamma correction factors are required in determing the gamma dose.
Gamma calibration factors is a dose evaluation ' actor in Unit 2 in selected areas with significant high energy beta iotopts.
It is expected that this factor will be adequately corrected by the implementation of the new TLD monitoring system.
(See response to Item 22-19).
Evaluation of Licensee Resoonse
References:
(1) Metropolitan Edison letter to NRC dated
~ bruary, 1980 (LTL 024).
e (2) fdC letter to Metropolitan Edison dated I
December 31, 1980.
(3) Metropolitan Ediso.1 letter to NRC dated February 27, 1981.
The additional statement provided by the licensee to Significant Finding 22-19 provides satisfactory resolution to this finding.
Therefore, Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these cor-rective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 restart.
47 Significant Finding No. 50-289/80-22-26
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development and implementation of a bioassay procedure, common to both Units 1 and 2, which details criteria, collection methods and handling techniques for each type of indirect bicassay performed at the site in order to insure uniform coordination and implementation of the bioassay program.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Rescind conflicting procedures and establish a bioassay procedure which is controlled by Unit 2 policy.
This procedure will address "MPC-Hours".
Statement in Reoly to Significant Aporaisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
RCP 1628 (Unit 1 implemented November 19,1980) and RCP 4238 (Unit 2 implemented July 25,1980) documents the indirect bicassay requirements for Unit 1 and Unit 2.
The requirements contained by these procedures are consistent and common to both units.
These procedures currently invoke ANSI N343-1978 which provides guidelines on collection, handling and performance criteria for indirect bioassay.
To ensure clarity and specificity, the applicable guidelines from ANSI N343-1978 l
will be incorporated into the aforementioned procedures by May 30, l
1981.
l Evaluation of Licensee Response
^
(1) Metropolitan Edison letter to NRC dated
References:
[
February, 1980 (LTL 024).
l (2) NRC letter to Metropolitan Edison dated L
December 31, 1980.
1 Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of. Inspection and Enforcement prior t
l_
to THI-1 Restart.
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48 Significant Finding No. 50-289/80-22-29
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Establish Respiratory Protection Instructor selection criteria and provisions for qualifying these instructors prior to their assumption of instructor duties.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
A document is in review for Units 1 and 2 which will establish the selection and qualification criteria.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
The selection criteria and qualification standards for Respiratory Protection Instructors were provided to the NRC in August, 1980.
These criteria are to be formalized in the position specifications for this job oy August 21, 1981.
Evaluation of Licensee Response
References:
(1) Metropolitan Ediso,; letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measuras will be verified by the Office of-Inspection and Enforcement prior to TMI-1 Restart.
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49 Significant Finding No. 50-289/80-22-30
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Upgrade the existingUnit I respiratory protection training program to include the elements contained in NUREG 0041, Section 8.3.
Licensee Planned Action Reference NRC letter to Metropolitan Edison dated December 31, 1980.
This item is currently under licensee review.
A training documect is being prepared to address this item.
Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1986 (LTI 024).
Subject to the evaluation, the lesson plan for the Respiratory Protection Training Program was reviewed and revised to comply with applicble portions of Section 8.3 in NUREG 0041.
This Program, which has been reviewed and approved by the Respiratory Protection Supervisor, includes all items required by the NUREG.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
i Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
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50 Significant Finding No. 50-289/80-22-33
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development and implementation of a contractor-independent QA program for the bioassay program which includes:
fixed audit schedules; use of NBS traceable sources; acceptance / rejection criteria; accuracy and precision requirements; MDAs; and use and adequacy of licensee procedures.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The licensee will establish oversight of the contractor's QA program through his vendor audit program.
Statement in Reply to Significant Aooraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
RCP 4239 provides the QA Program for the bioassay program and invokes the requirements of ANSI N343-1978. As part of the QA Program, an annual audit and calibration check is performed.
The procedure will be expanded by May 30, 1981 to incorporate the applicable specifica-tions of the ANSI standard.
Evaluation of Licensee Resoonse
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures l.
will be verified by the Office of Inspection and Enforcement prior l
to TMI-1 Restart. '
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51 Significant Finding No. 50-289/80-22-34
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Establishment of portal and hand and foot monitor calibration programs which include the use of NBS traceable radiation sources and instrument acceptance criteria.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
A. procedure has been developed and is currently being reviewed.
Hand and foot monitors are in use in Unit 2.
Unit 1 has portal but no hand and foot monitors.
First Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Use of hand and foot monitor in Unit 1 was discontinued prior to the evaluation. All personnel must perform a contamination survey using a "frisker" when leaving potentially contaminated areas.
The portal monitors are precautionary monitoring devices used only as secondary or tertiary contamination control monitors when leavir.g the Security Protected Areas.
The calibration procedure (RCP 1745) requires that the monitors be calibrated electronically and source checked.
This is an industry practice and has been considered acceptable. Neverthe-less, as an additional improvement to our calibration program, the procedure will be revised by May 30, 1981 to provide source calibration of the portal monitors with NBS traceable sources.
Initial Evaluation of Licensee kesponse
References:
(1) Metropolita. Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
The response'did not address-the establishment of calibration programs for hand and foot monitors in use at Unit 2.
It was discussed and agreed on in the December 17, 1980 management meeting that { Reference I-0 above) that items relating to Unit 2 would be acted upon prior to restart of Unit 1.
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52 Additional Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
The hand and foot counters are currently being electronically cali-brated and source checked. A procedure change is undergoing review and approval which will formalize this calibration / source check.
The revision will be issued by May 30, 1981.
Final NRC Evaluation of Licensee Resoonses Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to THI-1 restart.
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53 Significant Finding No. 50-289/80-22-36
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Provisions for resolving time corrections in GM detector counting procedures and determination of the gross beta efficiency using appropriate backscatter corrections for the medium being counted.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Counting procedures are being revised to include resolving time correction.
Pre : red samples will be sent to NBS for assay and will be used for backscatter corrections.
First Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Resolving time corrections are needed only for counting high level samples with GM detectors.
A provision will be added to the applic-able procedures by May 30, 1981 to either correct for resolving times at high count rates, or to use proportional counters for samples where precise activity levels are required.
The sources used at THI for beta efficiencies are standard sources used throughout the industry and are considered adequate. However, in an effort to continue improving comparisons between the sources used in determining beta efficiencies and the samples taken in the field, Met-Ed/GPU is attempting to locate a supplier of NBS traceable i
sources prepared on air sample filter paper. An earlier verbal report to the NRC indicated that the National Bureau of Standards would supply these sources.
Subsequent to that, the NBS has stated that they cannot supply the sources as requested.
Initial Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated l
December 31, 1980.
The response did not address how the licensee would determine which ar.propriate backscatter corrections would be used pending the resolu-
. tion of this concern.
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l 54 Additional Statement in Reoly to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February 27, 1981.
Licensee has confirmed the appropriateness of continued use of the present detector counting efficiency factor.
This is based on a report of calibration dated July 12, 1979 supplied by the source vendor and a report from the National Bureau of Standards dated August 22, 1979, both of which indicate a finding of essentially the same calibration source surface emission rate.
Nevertheless, we are pursuing the question of source medium and have placed an order for filter media sources with a firm in California. After receipt of these sources, checks including autoradiographs will be conducted by licensee. Additionally, it is intended that the sources be sent to NBS for their certification. After the sources are returned from NBS, efficiency studies will be conducted by licensee.
The NRC will be advised within 60 days of our progress on procurement, checking and certification of the filter medi':m source, and after completion of the efficiency studies, the NRC wii ' be informed of the findings.
Final NRC Evj!uation of Licensee Responses Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to-TMI-1 restart.
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55 C.
Radioactive Waste Management Significant Finding No. 50-289/80-22-50
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Provisions for weight loading limitations for 17H drums in the applicable procedures.
Licensee Planned Actiqn Refer 6nce:
NRC letter to Metropolitan Edison dated December 31, 1980.
Prceedures are being revised to include this item.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Procedures which allow the use of 17H drums as 00T Specification 7A packages, will be revised to include the specific weight limitation, as defined in the Safety Evaluation for the package.
This action will be completed by April 1, 1981.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edisen dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are t
l acceptable. ' Satisfactory implementation of these corrective measures j
will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
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56 Significant Finding No. 50-289/80-22-51
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Revision of procedures to eliminate references to entire collections of regulatory requirements and incorporate specific Certificate of Compliance requirements.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Procedures will be revised to eliminate the reference to entire document collections.
Statement in Reoly to Significant Aaoraisal Finding
Reference:
Metropolitan Edison ietter to NRC dated February, 1980 (ITL 024).
Procedures involved with radioactive waste handling ar.e currently being reviewed and revised as necescary to eliminate reference to generic regulatory documents.
Included in this effort will be the incorporation of specific Certificate of Compliance requirements.
This effort is scheduled for completion by April 1, 1981.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
(.
Mctropolitan Edison's responses oncer-ing corrective actions are l
acceptable. Satisfactory impl 2ntat.#. of these corrective measures will be verified by the Office of Inspection and Enforcement prior r
to TMI-1 Restart.
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1
57 Significant Finding No. 50-289/80-22-52
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development and implemen'.ation of provisions for performing and documenting radiation surveys of shipping casks prior to intrasite transfer.
l Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The Radioactive Waste Program document will provide for cask surveys.
Statement in Reply to Significant Aporaisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Procedures governing the intrasite movement of shioping casks are being reviewed and revised as necessary to require HP surveys of the vehicle and shipping cask, and to document such surveys, prior to the liner being moved.
This action will be complete by April 1, 1981.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan-Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are t
l acceptable.
Satisfactory implementation of these corrective measures l
will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
i
58 0.
Emergency Plan Implementation Significant Finding No. 50-289/30-22-56
Reference:
NRC letter to Metropolitan Ediscn dated November 26, 1980 Assignment of individuals, by position or title, to the functional areas of emergency activity described in the Emergency Plan and Emergency Plan Implementing Procedures, with such assignments detailed further, by name. in the Emergency Plan Implementing Procedures /
Emergency C:., section Roster (EDSR).
Licensor Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The assignment of individuals by position or title will be provided by a revision to Administrative Procedure (AP) No. 1014.
This will also be addressed in Revision 3 of the Emergency Plan (tentatively planned for implementation January 2, 1981).
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024). to the revised Administrative Procedure 1014, "Administra-tion of the TMI-1 Onsite and Offsite Emergency Duty Rosters," identifies personnel by position title or functional qualifications who are considered to be qualified to serve in specific emergency response positions in the functional areas of emergency activity described iri the Emergency Plan.
Selection and assignment of individuals wil be accomplished by comparing individual qualifications with the position specifications being developed for each emergency response position identified in AP 1014.
Individual assignments, by name, are reviewed and posted periodically in the onsite emergency duty rosters.
AP 1014 is PORC approved and was implemented on January 2, 1981.
Development of position specifications will be completed by August 21, 1981.
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59 Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31,-1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to THI-1 Restart.
I~
60 Significant Finding No. 50-289/80-22-57
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Developaent of an approved procedure governing the administrative aspects of the EDSR and the selection criteria to be applied in assigning individuals to positions in the onsite emergency organiza-tion if the EDSR approach is to be continued.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item will be addressed in the ensite/offsite roster of AP 1014.
The position requirements will be adcressed in the Position Specifica-tions.
(See Item 80-22-06)
Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
As noted in Item 56 above, AP 1014, implemented on January 2, 1981, establishes procedures governing the administrative aspects of the emergency duty rosters, including preparation, review and maintenance.
AP 1014 also identified functional qualifications or expertise which constitute part of the selection criteria to be applied in assigning individuals to duty positions.
When completed, the position specifications for each emergency response position identified in AP 1014 will be used as additional selection criteria and will form the basis of individual assignment to the onsite emergency response organization.
Development of position specifications will be completed by August 21, 1981.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC Cated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated i
December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforceme:. !. prior to TMI-1 Restart.
L
61 Significant Finding No. 50-289/80-22-58
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Assignment of individuals / contractors to the functional areas of offsite support, by positio:_ or title, with such assignments detailed further, by name in the Emergency Plan Implementing Procedures /EDSR.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
To be addressed in Administrative Procedure (AP) No. 1014.
Statement in Reply'to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
AP 1014 identifies personnel by position title or expertise who are considered to be qualified to serve in specific offsite emergency response positions. Selection and assignment of individuals, by name, will be accomplished by comparing individual qualificat!dns with the position-title or expertise.
Upon completion, position specificat ons, currently under development i
for each emergency response position identified in AP 1014, will provide additonal criteria upon which to base assignment to the offsite emergency response organization.
Position Specifications will be completed by August 21, 1981.
i Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated j
December 31, 1980.
I Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office ci Inspection and Enforcement prior to TMI-1 Restart.
9
62 Significant Finding No. 50-289/80-22-59
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of approved procedure governing the administrative aspects of the offsite EDSR and the selection criteria to be applied in assigning individuals to positions in the offsite emergency organization.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated Decemcer 31, 1980.
To be addressed in Administrative Procecure (AP) No. 1014.
Statement in Reoly to Significant Acoraisal Finding
Reference:
Metrcpolitan Edison letter to NRC dated February, 1980 (LTL 024).
AP 1014 governs the administrative aspects of the develocment, approval, distribution and maintenance of the offsite emergency duty rester.
In conjunction with the position specifications now being developed, AP 1014 provides selection criteria for the assignment of personnel to the offsite emergency response organization.
Position Specifications will be ccmpleted by August 21, 1981.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective _ actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-l Restart.
1
63 Significant Finding No. 50-289/80-22-60
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Description of the interfaces between the elements of the onsite and offs'te emergency organizations with such interfaces reflected in the EPIPs.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The description will be presented in Table 3 of the proposed Revision 3 of the Emergency Plan including:
Title, Functon Interfaces and Communications.
The EPIP's will cover the reporting requirements.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Table 8 of Revision 3 to the TMI-1 Emergency Plan and the Plan, implemented on January 2,1981, incorporate expanded definitions of the specific responsibilities and interfaces between functional elements for emergency response personnel.
Specific responsibilities are also reflected in revision to the applicable Emergency Plan Implementing Procedures.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
9
6 64 Significant iinding No. 50-289/80-22-61
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of formal, approved lesson plans containing student performance objectives and a means to measure performance against those objectives for each functional area of emergency activity, i.e., for each emergency job function / title.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Administrative Procedure (AP) No. 1052 and Section 6.5 of the Training Manual will address this item.
Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Administrative Procedure (AP 1052) and Section 6.5, TMI Training Department Administrative Manual will delineate training requirements for personnel involved in emergency response activities by functional area. The TMI Instruction Manual provides guidance for the development of formal lesson plans which include student performance objectives and the means to measure performance against those objectives.
Section 7, TMI Training Department Administrative Manual will reflect those requirements.
The TMI Training Department Administrative Manual is scheduled to be published by February 28, 1981.
A formal Emergency Plan Training Program is being developed which will be consistent with all of the aoove.
Completion of program development and commencement of the first iteration of the new training program is scheduled for April 1, 1981.
Evaluation of Licensee Resoonse
References:
(1) Metropolitan Edison letter to NRC dated February, ~ 930 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
65 Significant Finding No. 50-289/80-22-62
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 In the procedure which governs the conduct of the emergency plan training program (EPIP 1004.24) specification of:
a.
The means by which completed training will be documented; b.
The designation of instructors and their qualifications; and, c.
The manner in which members of the emergency organization will be trained in changes to procedures, facilities or equipment which occur in the period between scheduled training session.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item will be addressed in AP No. 1052, and Section 6.5 of the Training Manual. Section 5 of the Training Manual will address Qualification and Selection of Instructors.
Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
The above noted items are specified in the following relevant documen-tation.
AP 1052 and Section 6.5 of the TMI Training Department Administrative Manual provide that the TMI Training Department will document all l
training and will prepare and maintain required records and reports.
Section 5, TMI Training Department Administrative Manual, scheduled I
for publication by February 28, 1981, will establish qualifications and selection criteria for instructor personnel.
This manual, includes selection criteria for those instructors who will conduct emergency plan related instri.ction.
AP 1052 and Section 6, TMI Training Department Administrative Manual, provide that Emergency Plan Training is cyclic in nature.
- Further, Section 6 provides that the program shall be maintained to reflect the following:
66
... Changes in Regulatory Requirements.
... Changes in Applicable Codes, Standards and Guides.
... Experiences at the facility.
... Industry experiences.
... Audit results.
... Critiques (as appropriate).
Changes will be tracked and managed consistent with in place management controls.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edisoit's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
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67 Significant Finding No. 50-289/80-22-63
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Coordination of the content of training for offsite support groups with the offsite support groups to whom the training will be provided.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item will be addressed in Administative Procedure (AP) No.
1052.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Administrative Procedure (AP 1052) provide that the content of all emergency response training provided specifically for offsite emergency support organizations will be coordinated with target audience representatives prior to presentation.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
68 Significant Finding No. 50-289/80-22-64
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Completion of at least one training iteration in accordance with the training program.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This Training will be completed prior to restart.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
The current training program objective is to complete development of a formalized training program, consistent with approved procedures, to commence the first cycle of that program by April 1, 1981 and to complete at least one cycle of that program prior to restart.
In the interim, onsite training continues, to include GET, basic health physics, emergency plan orientation and familiarization training drills.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
69 Significant Finding No. 50-289/80-22-65
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of selection and qualificaticn criteria for emergency planning instructors.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This will be addressed in Section 5 of the Training Administration Procedure.
To be included is the instructor's academic training, experience and teaching ability.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Section 5, TMI Training Department Administrative Manual, currently under develnpment and scheduled for publication by February 28, 1981, will provide specific selection and qualification criteria for those instructors who will conduct emergency plan related training.
In addition, the site emergency preparedness staff will assist in the development and presentation of the training program.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by-the Office of Inspection and Enforcement prior i
to TMI-1 Restart.
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70 Significant Finding No. 50-289/80-22-67
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Evaluate and, as necessary, upgrade communications between the EAC, EOFs and Control Room for the purpose of transmitting and receiving environmental monitoring information and direction.
Licensee Planneu
. tion d
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This action was accomplished in August 1980.
Four separate communica-tion links and a radio system are now available.
Statement in Reoly to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
The dedicated telephone communication systems. required for communica-tion between the EAC, EOF and Control Room, and appropriate redundant systems, were in place and operationally tested during the August 26, 1980 emergency exercise.
These include dedicated lines connecting the Control EOF, ECF-EACC and Control Room EACC; radio communications linking the EACC-EOF Control Room; and common-user telephone circuits.
There are provisions for periodic check of the functional operability of these systems.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning carrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office cf Inspection and Enforcement prior to TMI-1 Restart.
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71 Significant Finding No. 50-289/80-22-68
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Determine the audibility of the reactor building evacuation alarm throughout the reactor building.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item is being addressed through Modification No. 29 and will include flashing lights or horns as needed.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
The reactor building evacuation alarm system will be modified to imrpove audibility.
This modification (LM #29) supplements the present warning system with warning lights, additional speakers and expanded intercom terminals to ensure the evacuation message is audible throughout the site. The majority of the required material has been received. Modification will be completed prior to restart.
In addition, the site alert system is being modified by the addition of three electronic siren systems which will provide an additional public address system capability site-wide.
Completion of this modification is scheduled for July 1,1981.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
i Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
72 Significant Findino No. 50-289/80-22-69
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Coordt.iation of EOF emergency work-space allocation with the NRC Region I Office.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The TMI visitor center space allocation has been reviewed and will be discussed with NRC Region I to ensure adequate space is available.
Statement in Reply to Significant Aporaisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Based on recent completion of a project to renovate / upgrade the TMI Observation Center for its primary purpose as a Visitors Center, reorganization and work space and reallocation are in progress.
Upon completion of the basic. internal layout of the interim EOF at the TMI Observation Center, specific work space allocation and relocation of NRC telephones will be accomplished.
This effort is scheduled for completion by April 1,1981.
When the guidance in NUREG 0696 is finalized, selection, design and construction of a permanent EOF will be accomplished.
Specific work space allocation and communications requirements will be coordinated with the NRC Region I during that process.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edis:
, responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
g
o 73 Significant Finding No. 50-289/80-22-71
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Interface emergency, abormal and alarm condition procedures with the Emergency Plan Implementing Instructions (Procedures 1004.1 through 1004.4) to ensure prompt detection and classification of emergencies and to resolve apparent conflicting courses of action for radiation protection and chemistry personnal.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Flagging notes will be placed in the emergency procedures to provide for procedure interfacing.
This will include inclusion of Emergency and Abnormal Alarm Conditions.
Statement in Reoly to Significant Aporaisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Emergency and abnormal procedures have been reviewed to determine which require specific interface with Emergency Plan Implementing Procedures 1004.1 through 1004.4 to assure appropriate emergency response. That review has been completed and procedures have been identified for further review and revision.
The revision process is ongoing and procedures are being cross-referenced to assure prompt detection and classification of emergencies and to resolve apparent response conflicts.
The shift supervisor is required to consult the emergency and abnormal procedures which provide specific reference and interface to the EPIP's.
Therefore, review action for alarm procedures is not appropriate in this context.
The revision process will be completed prior to restart.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
74 Significant Finding No. 50-289/80-22-74
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of procedural guidelines for the conduct of in-91 ant radiological surveys (radiation, air and contamination) to s.,7nort the accident assessment and in plant radiation protection schemes Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Three procedures have been developed to address this item and are currently being reviewed.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
The following Emergency Plan Implementing Procedures have been developed to provide procedural guidelines for the conduct of in plant radiological surveys to support accident assessment and in plant radiation protection programs during emergencies.
1.
EPIP 1004.9 In-Diant Radiological Controls During Emergencies.
2.
EPIP 1004.31 Airborne Radioactivity Sampling and Analysis.
3.
EPIP 1004.15 Post Accident In-Plant Sampling.
The above EPIP's have been PORC approved and were implemented with Revision 3 to the TMI-1 Emergency Plan on January 2,1981.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,_1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are i
acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
75 Significant Finding No. 50-289/80-22-75
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of procedures for sampling and analyzing contain: tent air under accident conditions.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This will be addressed in procedure 1044.31 which is being revised.
In the interim, Procedure RCP 1631 will address this item.
Engineering is currently reviewing the air sampling configuration.
Statement in Reply to Significant Appraisal Finding.
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
EPIP 1004.31, entitled, " Airborne Radioactivity Sampling and Analysis,"
has been revised te include precedures for sampling and analyzing containment air uncer accident conditions. A new contal.v. ant air sample station, (Task #LM-248), is currently being evaluted by Engineering.
The tentative date for material delivery is 3/1/81.
Implementation date for the system is tentatively set for 8/1/81.
Procedures will be established to reflect its operat on when completed.
Evaluation of Licensee Response
References:
('
Aetropolitan Edison letter to NRC dated February,1980 (LTL.024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective' measures will.be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
76 Significant Finding No. 50-289/60-22-76
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Review of Procedure 1004.15 against actual post-accident sampling system design upon completion of the NUREG 0578 evaluation currently in progress.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Due to ALARA considerations, a procedure demonstration will not be undertaken until the system has been flushed and properly shielded.
Statement in Reoly to Significant Appraisal Findir.g
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Upon completion of the NUREG 0578 evaluation, Procedure 1004.15 will be reviewed against actual post-accident sampling system design.
Completion will be prior to restart.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison lettet-to NRC dated February, 1980 (LTL 024).
(2)'NRC letter to Metropolitan EElson dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
4
77 Significant Finding No. 50-289/80-22-77
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Description of the methods and equipment to be used for environmental radiation and contamination surveys at onsfte locations to include:
a.
Specification of pre-determined survey points or routes; b.
Description of ultimate disposition of original data sheets; c.
Specification of the central collection point for samples; d.
Description of primary and backup communications provisions;
- and, e.
Specification of the means for team transportation.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edi:,on dated December 31, 1980.
This item will be addressed in its entirety in Procedures Nos.
1004.10 and 1004.31.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edisen letter to NRC dated February,1980 (LTi. 024).
Emergency Plan Implementing Pro:edure EPIP 1004.10 identifies pre-determined survey sites, provides for team transportation, describes team communications capabilitie; and procedures, and provides instruc-tions concerning the ultimate r,isposition of survey sheets.
EPIP 1004.31 specifies procPJures to be followed in Collecting samples and the central ccilection point for all samples.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning' corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
e
78 Significant Finding No. 50-289/80-22-78
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Description of the methods and equipment to be used for environmental radiation and contamination surveys at onsite locations to include:
a.
Specification of pre-deta mined survey points or routes; b.
Specification of the collection point for samples; c.
Description of backup communications methods; and, d.
Description of the means to be employed by tne teams to obtain transportation.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item will be addressed in its entirety in Procedures Nos.
1004.11 and 1004.31.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Emergency Plan Implementing Procedure EPIP 1004.10 identifies pre-determined survey sites, provides for team transportation, describes team communications capabilities and procedures, and provides instruc-l tior.s concerning the ultimate disposition of survey sheets.
l EPIP 1004.31 specifies procedures to be followed in collecting samples and the central collection point for all samples.
Procedures are in place for operation of all equipment associated with the l
offsite environmental surveys.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edt,n's responses concerning corrective actions are acceptable.
Satis factory implementation of these corrective measures i
will be verified by the Office of Inspection and Enforcement prior
'~
to THI-1 Restart.
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79 Significant Finding No. 50-289/80-22-79
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of approved procedures describing the detailed actions to be taken to implement the emergency Radiological Environmental Monitoring Program (REMP).
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
The actions will be addressed in Procedure No. 1004.12.
Statement in Reply to Significant Aporaisal Finding Re ft:. 2nce: Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
The TMI REMP consists of an extensive, monitoring program which is functional on a continuing basis during normal operations and an emergency REMP which is guided procedurally by Emergency Plan Imple-menting Precedure 1004.12.
In the event of an emergency, EPIP 1004.12 provides for the implementation of increased environmental monitoring in direct response to a declared emergency.
This procedure provides guidance on the dispatch of a mobile environmental assessment laboratory and other mobile monitoring teams, identifies TLD locations and provides guidance on the type environmental samples to be collected, where and in what quantities.
An additional procedure, now under development by the Environmental Assessment Coordinator will specify the procedures to be followed to determine the number and type of samples to be collected based on tha nature of the emergency.
This procedure will be implemented prior to restart.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses conce-ning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to THI-1 Restart.
80 Significant Finding No. 50-289/80-22-80
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of provisions for comparing the results of projected dose calculations with action levels and Protective Action Guides of the Commonwealth of Pennsylvania as a basis for recommending the implementation of protective actions in behalf of the general population.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item will be addressed in Procedure Nos. 1004.1, 1004.2, 1004.3, 1004.4 and 1004.7.
Statement in Reply to Significant Aporaisal Finding
Reference:
Metropolitaa Edison letter to NRC dated February, 1980 (LTL 024).
Emergency Plan Implementing Procedures (EPIP) 1004.2 through 1004.4 (Alert, Site Emergency and Ceneral Emergency) and EPIP 1004.7 (Offsite Dose Projections) implement provisions for comparing the results of projected dose calculations with action levels and protective action guides of the Commonwea?th of Pennsylvania. This comparison serves as the basis for recommending the implementation of protective actions in behalf of the general population.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
81 Significant Finding No. 50-289/80-22-81
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Formulation of provisions for immediate notification of appropriate state or local agencies in the event assessment actions indicate an actual or potential exposure to the whole body or thyroid of persons in the plume exposure EPZ equal to or greater than the lower limits of the EPA Protective Action Guides for the child.
~
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item will be addressed in Procedure Nos. 1004.1 through 1004.4.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Emergency Plan Implementing Procedures EPIP 1004.2 through 1004.4 (Alert, Site Emergency, General Emergency) specify actions to be taken at the various classifications of emergency.
Included are provisions for the prompt notification of the Bureau of Radiation Protection in the event potential exposure is equal to or greater than EPA Protective Action Guides.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
e 82 I
Significant Finding No. 50-289/80-22-82
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Inclusion of high range ncble gas monitors and radioiodine effluent analyses in the assessment scheme.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item will be incorporated into existing procedures when system becomes available.
Statement in Reply to Significant Acoraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
High-range noble gas monitor readings and radioiodine effluent analyses will be included in the offsite dose projection procedure, EPIP 1004.7 (PORC approved 8/12/80) when the high-range capabilities become available by January 1,1982 as discussed in our response to NUREG 0737 of 1/23/81.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
83 Significant Finding No. 50-289/80-22-83
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Procedures for collecting and analyzing adsorbent media for radioiodine in gaseous effluents under accident conditions.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Procedure No. 1004.31 has been revised to addrss this item.
This procedure is currently under review.
Statement in Reply to Significant Aporaisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
EPIP 1004.31, " Airborne Radioactivity Sampling and Analysis" (PORC approved 8/6/80), contains the procedures for collecting and analyzing absorbent media for radiciodine.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
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84 Significant Finding No. 50-289/80-22-84
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of procedures which describe the details actions to be implemented or considered to be implemented to ensure continuity of the radiation protection program during emergencies.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item has been addressed through revision of Procedure EPIP No.
1004.9.
Statement in Reply to Significant Aooraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
EPIP 1004.9, "In-Plant Radiological Controls During Emergencies" has been reviewed and revised to ensure continuity of the radiological protection program during emergencies.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory _ implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
85 Sionificant Findina No. 50-289/80-22-85
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Provisions for monitoring individuals in the Processing Center or assembly areas that will resu1*. in the detection of the 1,000 dpm (100 cpm) action level.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This item has been addressed through revision of Procedure No.
1004.20 and will provide for monitor to the 1,000 dem level at the assembly area.
Statement in Reply to Significant Aporaisal Findina
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 02a).
EPIP 1004.20, " Personnel / Vehicle Monitoring," has been revised to define procedures for monitoring individuals evacuating the protected area at assembly areas. Monitoring procedures provide for detection of the 1000 dpm contamination action level.
The procedure will be implemented under the direction of a Radiation Assessment Coordinator.
The Radiological Controls Coordinator will assign a team leader to each of the monitoring and decontamination teams who will in turn dispatch team members and coordinate their function.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable. Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to THI-1 Restart.
86 Significant Finding No. 50-289/80-22-86
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Inclusion of data sheets in Procedure 1004.20 to record survey results.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
A supply of 200 survey sheets has been provided at each location.
Procedure 1004.20 has been revised to reflect use of the sheets.
Statement in Reply to Significant Acoraisal Finding a
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Individual survey data sheets have been included as part of EPIP 1004.20.
In addition, packets of forms are stored with the monitoring equipment and are available to the monitor teams upon implementation of this procedure.
Forms are provided in sufficient numbers to accomplish initial monitoring and properly record survey results.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are l
acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
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s 87 Significant Finding No. 50-289/80-22-87
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Development of specific action levels and judgement guidance for use in determining the need for evacuation of the protected area and the site for Alert, Site and General Emergencies.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
Procedure Nos. 1004.3 and 1004.4 have bee revised to include the specific action levels. A review is to be conducted to determine necessity of inclusion of Emergency Director guidance to assist his judgement.
Statement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Emergency Plan Implementing Procedure (EPIP) 1004.2 (Alert) will be revised by March 1, 1981 to provide specific judgement guidance concerning potential radiological conditions which may justify a judgemental decision to effect a partial evacuation of the site.
Conditions prevailing for an Unusual Event and specified actions for Site and General Emergencies obviate the need for additiont.1 guidance concerning evacuation.
Evaluation of Licensee Response
References:
(1) Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated l
December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to TMI-1 Restart.
l i
i l
I
88 Significant Finding No. 50-289/80-22-89
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Provisions for notifying the offsite medical treatment facility prior to transport of a contaminated and/or injured individual.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated Decemoer 31, 1980.
This item has been addressed in Procedure No. 1004.16.
Statement in Reply to Significant Acpraisal Findit 3
Reference:
Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
Emergency Plan Implementing Proceduras (EPIP) 1004.16, " Contaminated Injuries / Radiation Overexposure", provides for notification of the
- offsite medical treatment facilities and has been coordinated with the of. ite medical support agencies.
Evaluation of Licensee Resconse
References:
(1) Metropolitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated
^
December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prior to THI-1 Restart, t '
t
=
y J
v w
89 Significant Finding No. 50-289/80-22-91
Reference:
NRC letter to Metropolitan Edison dated November 26, 1980 Description of the management controls to be used for assigning responsibility for corrective actions and their completion dates and to assure that assigned actions are completed in accordance with the established schedule and adequate to resolve the noted deficiency.
Licensee Planned Action
Reference:
NRC letter to Metropolitan Edison dated December 31, 1980.
This matter has been addressed in Administrative Procedure No.1051.
Batement in Reply to Significant Appraisal Finding
Reference:
Metropolitan Edison letter to NRC dated February,1980 (LTL 024).
Administrative Procedure AP 1051, " Emergency Planning Drills",
describes the current action item management system.
This system is a computertracked system which reflects items to be accomplished, responsible indi"'9uals/ organizations and desired completion dates.
The system proviaas periodic status reports to insure proper supervisor /
management involvement and approval of corrective actions.
In the case of AP 1051, the system is generally oriented to tracking and assuring correction of deficiencies in emergency preparedness identified through drills and evaluations.
Evaluation of Licensee Response
References:
(1) Metronslitan Edison letter to NRC dated February, 1980 (LTL 024).
(2) NRC letter to Metropolitan Edison dated December 31, 1980.
Metropolitan Edison's responses concerning corrective actions are acceptable.
Satisfactory implementation of these corrective measures will be verified by the Office of Inspection and Enforcement prier to TMI-1 Restart.