Text

Forwards Response to Notice of Violation & Proposed Issuance of Civil Penalties from IE Investigation of 790328 Accident at TMI-2
	ML20024B243
Person / Time
Site:	Crane
Issue date:	12/05/1979
From:	Arnold R; GENERAL PUBLIC UTILITIES CORP., METROPOLITAN EDISON CO.
To:	Stello V; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
References
	TASK-10, TASK-GB GPU-2317, NUDOCS 8307070492
	Download: ML20024B243 (94)
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j[- Q Post O'fsce Ecx 480 Middletown, Pennsvivania 17057 717 s=4* set 948-8000 Dece=ber 5, 1979 Mr. Vic:or Stello, Jr.

Dirse:or Office of I:spection and Inforce=e :

U. S. Nuclear Regula:ory C

'ssion Washing:en, DC 20f55

Dear Mr. 5:

Clo:

Subj ee:: Docke: No. 50-800

~

Response to Notice of V.iolatics and Notice of ?:oposed Issua=ce of Civil Paral.ies Your le::er of Oc:ober 25, 1979 ::ans=1::ed a Notice of Violazio: ada No: ice of Proposed Issuance of Civil Pe:al ies based upo the Office of Inspe::i== and Inforce=ent's inves: iga:1:= of the March 28, 1979, acciden:

a: Three Mile Island Uni: 2.

Your le::e: also addressed so=a general re= arks ceseerning Metropcli:a Edisc= and its =anage=ent controls for :he operatics of :he Three Mile Island facilities.

Te have carefully censidered the info =ation and conclusi:ns se: forth in your le::e and in :he No:1:es e= closed vi:h 1:.

This considera:ics has bse: aided by =any s:udies, analyses and reviews.which we and others have u der:aken since,:he March 28, 1979 acciden:. We have sough: to fc::h:1gh:1y address each of tha charges while reces 1:ing tha: =any of the issues : urn upc in:e: pre:ations of c = plex procedures.

Our detailed responses are se: for:h in

Vo enclosures to this le::er: Me: opolita Edison Co=pany's S:a:e=es: in Raply to Notice of Viola:1on, and Me:::polita Edison Cc=pany's Answer to No: ice of Proposed I=positics of Civil Penalties.

These respenses are based upon our present understanding of the acciden:.

Cer:sinly, our =utual unders:anding of the acciden: and 1:s underlying causes can be expected to 1 prove as s:udies con:inue.

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Although the specific viola:1cus asserted is the Notice ge=erally addressed the Uni: 2 operati=g organi a:1on, :he cri:1cis= of the oc:ober 25 le::e is a1=ed at Me::opolita Edison's =a: age =es: con:rols.

The proble=s with =anage-can: cos::als were so: obvious fro = even:s prior to March 23, 1979. :te sa:ure ced ex:en: of no=er=pliances identified during NRC inspections did not indica:e funda=es:a1 proble=s vi:h the safe opera:Los of the plant.

During the period I

fro = *f975 to 1978, opera: ors a 'Three Mile Island had a failure ra:e on their NRC vri::e= and oral r e half :he indus: y average. NRC perfor=ance evalua-tions ranked :he Three Mile Island facility above :he average for c== parable plan:s. Me:ropcli:a Edison does =c: feel that there vas any significan: deci::e i

in the Cc=pany's perfor=ance.

What is clea :o us is that changes in the appr:a:

to anage=e:: a d =anage=e== cos::cis =us: be =ade by Me: rope--- ""se: as well as the total suelear c:= plex, :o address the defielencies which :he severe tes:1.g of :he acciden: revealed.

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theter Stello, Jr. Dece=ber 5, 1979 To iden:ify :he nature of the needed changes, we have undertaken ex:en-sive in:ernal reviews of the Cc=pany's corpora:e s =ue:ure and s:affing.

Major changes have been =ade or are in progress in our approach to corporate management and con =ols.

While many, if no: all, of the changes which have occurred or are in progress have already been sub=1::ed to the NRC for re-view, it is appropriate to men: ion the= again here. The TMI Genera:Lon G:=up vas for=ed to in:egrate the nuclear manage =e : and tech =1 cal support capabili-ties of Metropolita Edison and the CPU Service Corpora: ion in a single en:1:y.

As a result, the professienal technical staff for Three Mile Island has bes:

1 pled to a cun en: level in excess of 200 vi:h over 2,600 man-years of nuclear 1

experience. A pri=ary objective of the group is to ensure safe opera:1cus by

=eans which 1 :1ude strict adherence to NRC regula:1ces Technical Specifica-tiens, and plan: procedure. Uni: 1 a:d Uni: 2 line anage=ent responsibilities have been separatad in recognition of :he differen: s:atus of the units and each uni: given dire:: control, to the =ax1=c= possible exte :, over the resources necessary for the effe :1ve and safe condue: of plas: activi:1es. A shif: tech =ical advisor has been added to the nor=al shift ec=pleme== and sub-stas:ial addi:ional attention vill be directed to the operating ex:erience of si=1lar reac:::s and the nuclear indus=y as a whole. I_p;cve=e :s in the organizational status and s.affing of the health physics depar==en:s have been achieved (al: hough we recognize tha: the unique circu=s.ances of Uni: 2 vil".

require further significa:: i= prove =ents).

Upgradd:g of operational quali:7 assurance, specific procedural require =e :s for the independent verifica:1cn of operatic:a1 activi:ies affe :ing safety, and cha=ges to the review end app va'.

provisions for plan and e=erge::7 procedures"have all been under:aken to i= prove

=anage=en: centrols.

Operating and e=ergency procedures are under review and revis1=n as appropria:e. A =ajor revision and expansic in the trai=i=g p:cgra=s for the operating organi:a:1cas has bee =ade and a =anage=ent tra'ad g p =gra:

is under devel:p=en:.

We are taking steps to ::ans=1: the m age =e : cc=-1:=en:s

h:= ugh all levels of :he Cc=pany :o assure : hat all pers-- ' ' ave a high degree of awareness of c -

en: :s safe opera:ics.

~hese 1:e=s have been des =ibed in de: ail in our sub_i::als :o the S:aff in connec:ica vi:h :he Uni: 1 :es:ar:.

These changes and our c d:=en: to ecuti=ued i=preve=ent underscore our c==i:::;ent to correct the i= adequacies which have now beco=e clear. The hard lessons taugh: us by the eve :s surrounding the acciden: have been c:=prehended.

The need to sig=1ficantly upgrade our nuclear progra= has been recogni:ed.

Me=cpolitan Edison, we believe, is cc fronting the issues raised by :he acci-de:: and its af e:=a:h and is taking the steps needed :o resolve these issues.

x The Cc=pany has also cc ducted ex:ensive reviews of the accident and rela:ed issues :o ensure ve have as c==plete an understanding as possible of all fae:=s t

which contribu:ed ec :he accident.

I: is our viev that the accident canno: be traced solely to inappropriate operation ac:Lon. Ra:her, 1: =ust be ascribed :o a much =cre ec= plex set of eve :s.

We find supper: of this view in the findings by,the Adviscry Cer. ittee on Rese:c: Safeguards, the ?residen:'s Co dssion, and rece : Co

ssion stata=en:s.

The key to understanding the accident, in our opinion, lies not so =uch in the procedural violations which are charged, bu: with nere basic causes. We believe that there are two such causes.

Firs:, there was a lack of unders:andin;,

and thus, an absence of clear procedures, to deal vi:h a s=all break less of coolan: acciden: frc= the stea= space of the pressuri:ar.

No guidance was given the operators for a LOCA f c= the pressuri:er, in which pressure decreases whila

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pressuri:e level 1::: cases.

In fact, ::aining and procedures prepared with-i knowledge of this de: ail of system behavior probably inhibi:ed proper ou:

cperator action.

The second basic cause was an exaggerated concern with "taking the plant solid." Tech =ical Specifica:icus a=d procedures pro?.ibited this condition and the reac:or simulator on which operators were trained could not s1=ulate solid ce=ditions.

While opera:or training and plan: procad'tres were deficies: in a nu=ber of areas, these deficiencies arose from the under-lying lack of awareness by Me:ropolitan Efison, the nuclear indus: y, and the Cec =1ssion tha: th7 kind of syste= behavior which the plan: experienced could occur.

The investiga:Lon condue:ed by your Office in the af te==ach of the acci-den vas the larges: ever undertaken by the Co=ission. Even though 1: did

=c: purpor: to be a full analysis of the causes of the accident, the inves:1-gazion was u:preceden:ed i: ter=s of scope, intensity, dura:1cs, and manpower.

It produced a vol ' nous and de: ailed report, NURIG 0600. The investiga:1 =

disclosed se=e viola ions of plan: procedures. We have recognized these and are taking or have already :aken steps to assure that there vill be no repeti-tion.

The investigation disclosed areas in which plan: p =cedures were a=bigu-ous or 1 ::=plete. We are =edidying or have already rewrit:en these proce-dures to in crporate the lessons learned f cm the acciden: and are undertaki=g a ce=prehensive review of all plant procedures. The inves:1gatics disclosed aspects of the acciden: where conditions ven beyond the bounds of plan: pro-cedures and indeed beyond the bounds of previous indus::y assu=ptions of sys-te= behavior is acciden c=nditions. And finally, the inves:1gatics also pre-duced sc=e charges which, based upc= our further analysis, we believe are no:

adequately supported.

The acciden: vas the vors: 1: :he his:ory of the ec=p::ial nucles: pcVer i=dustry. Metropoli:a= Edise=, the nucles: indust:7, and the NRC have been unal:erably changed as a result.

We ree:g=1:e :he ft

's en:a1 need fc these changes and are c=--d::ed to the i plemenza:ics of these that apply to us.

We vill, of course, keep you infor=ed of further develop =en:s, and are ec

'--ad to worki=g with the C

'ssi:n :o assure the opera:ic al safety of our nuclear progra=.

Very ::uly yours,

/ signed / R. C. A :cid R. C. A::cid Senior Vice Preside==

RCA:cib Attachments

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UNITID STATIS C7 AMSRICA NUCLEAR REGULATORY CO?cCSSION In the Ma::er of

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IC30POLITAN EDISON COMPANY

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Docke: No. 50-200

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(Three Mile Island Nuclear

)

Power Sta: ion, Uni: 2)

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ME*ROPOLITAN EDISON COMPANY'S STATEMINT IN REPLY TO NO~ ICE 07 VIOLATION In accordance vi:h 10CTR 2.201 and the No: Ice of Violation of Oc:ober 25, 1979, Metropolitan Edison Co=pany provides the following responses :o the apparen: items of nonco=pliance identified in :he No: ice.

1.

State =ent of Amearen: Nonco==liance:

Technical Specifica: ion 3/4.7.1, " Turbine Cycle," requires in See:icn 3.7.1.2, tha: :hree independen: stea= genera:or e=ergency fesava:er pu=ps and associated flow paths shall be operable during power opera:icas, excep::

if one e=ergency feedvacer syste= is inoperable i: =us: be restored to operable sca:us vi:hin 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months or :he plan: =us: be in Ho:

Shu:down vi:hin the nex: 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Centrary :o the above, for an unde:er=ined period jus: prior to the reac:ct : rip at apprcxi=a:ely 0400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months on March 28, 1979, :he flow pa:hs to both stea= generators were =ade inoperable by feedvater header isolation valve closure.

(In addi: Ion, on.fanuary 3, February 26 and March 26, 1979, the flev paths fre= all three e=ergency feedva:er pu=ps were si=ul:aneously =ade inoperable by feedva:er header isolation valve closure during the perfor=ance of, and in accordance vi:h, an i= proper surveillance tes: procedure.)

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l-Metropolitan Edison agrees that continued plan: operacion with the emergency feedvater header isolation valves (EF-V12A and 123) in :he closed posi:lon is an apparen: breakdown in con::als over the operabili:y of safety rela:ed equipmen: as stated in NURIG 0600 See: ion I 2.3.2.

While Me:Topoli:an Edison does not believe tha: controlled isclacion of the feedva:e header for rou-tine testing is in violation of the Technical Specification, we agree tha: i:

is undesirable and steps will be taken to = edify surveillance test procedures for the e=ergency feedvater syste=, and to provide routine (including some as frequently as each shif:) sea:us checks on co=ponents i=portan: to the safe opera: ion of the plan.

Our analysis supper:s the conclusion of the Ke=eny C:==ission as s:a:ed in the Report of the President 's Cc==ission on The A::i-den: at Three Mile Island, "The loss o e=ergency feedvater for S =inutes had k

no significan: effee: on the ou: o=e e. the acciden:.

Su: i: did add :o :he confusien tha: dis:: acted :he opera: ors as they sough: :o unders:and the cause of : heir pri=ary proble=".

The e=e:gency feedva:e syste=, like =any engineered safeguard fea:ures, is required :o under;c periodic surveillance and testing which in se=e cases reduce the abili:y of the syste= :o perfor= its in: ended fune:ien while in the tes: condi: ion.

Technical Specificatien 3/4.7.1 recog=i:es this condition and specifically allows 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months of inoperability of :he e=ergency feedva:e sys:e= before addi:ional corree:ive ac: ion =ust be s

taken.

Although the Technical Specification is wri::en in ter=s of the inoperability of "one e=e:gency feedva:e syste=", (i= plying the exis-tence of = ore than ene "sys:e=") there is only one e=e:gency feedva:e syste= for TMI-2.

The Safe:y Evalua: ion Repor: for TMI-: (NURIC-0107, Sept. 1976, pg. 7-5) states, "The e=ergency feedvate sys:e= consis:s of one turbine crive punp, :vo =oto_-driven pu=ps and associa:ed piping 9

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c and valvao." Tha Ts:hnien! Specifico:lon tharafere allevs full isola:ien of all or part of the e=e gency feedva:e: sys:e= for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months before proceeding to hot shu:down.

On :his basis, the Surveillance Procedure 2303-M14A/S/C/D/I, "E=ergency Feed Sys:e= Valve 1.ineup Verification and Operability Tes: and Turbine Driven E.F. Pu=p Operability Test", Revision 8, is in compliance wi:h Technical Specification 3/4.7.1.

I: would appear tha: this judge =en:

was confir=ed by NRC inspe:: ion.

"Co=bined Inspection Repor: 50-289/

78-23 and 50-320/78-36", dated January 9, 1979, s:sted "The observa:i:ns and records review were condue:ed to verify that s:ar:up, power and/or shu:down rea::or opera: ion were in confor=ance wi:h Technical Specifica-

ion safety li=i:s, li=i:ing safe:y sys:e= se::ings, and li=i:ing ::n-di: ions for opera: ion".

A=cng :he procedures inspe::ed wi:h a::ep:able resul:s was S? 2303-MI'.A/B/C/D/E Revision 8, and accep:ance cri:eria included require =en:s fr:= Technical Specifica: ion 3.7.1.2.

f This surveillan:e p chedure was followed in January, February, and Mar:h 1979.

!n January and February, as far as we :an deter =ine :he e=er;en:7 sys:e= vas re:urned :o full opera:icn i==edia:ely up:n ce==le:1:n of :he

esting.

The elapsed :i=e frets :he March 26 :es: to the ci=e of dis-covery of the closed valve was 42 hcurs (and, therefore, also vi:hin the Technical Specifica: ion li=i:), if we assu=e tha: :he valve was closed and nc: :eopened af:er ce=pletion of the :es:.

The status of these valves following the Mar:h 26 :es: was reviewed wi:h the people perfor=ing :he surveillance on tha: dare.

Three people have the valves were reopened following co=ple: ion of :he surveil-s:a:ed :ha:

How and when :he valves a :ually beca=e closed following lance procedure.

he perfor=ance of the surveillance has no: been de:er=ined despi:e ex-

ensive inves: iga:icn by =any par:ies..

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The Prasidan:'s Co==ission was cico unchle to d2tsr= ins the racnen for g '-

these valves being closed. Their repor: s:stes:

"A Ce==ission inves:igation has not iden:ified a soecific reas'en as to why the valves were closed a: 8 minutes in:o the acciden:. The mos: likely explanations are:

the valves were never reopened af:er the March 26 test; or the valves were re-opened and the con:rol roo= operators =is:akenly closed the valves during the very firs par: of :he accident; or the valves were :losed =istakenly fro = control points ou: side the con:rol roo= after the tes:."

We agree that the inability to provide any other testi=ony or docu=en:a-

ion :o support cha: the valves were opened af:er :he surveillance tes:ing was co=pleted on March 26 indicates a lack of =anage=ent con:rols, and we have revised our procedures and ::aining :o corree: this deficiency.

To assess :he effec:s of IF-V-12A/3 being closed on :he ou:ce=e of :he accident, a co= para:ive analysis has been =ade of :he TMi-2 acciden: vi:h and vi:hout delay in the ini:ia:icn of e=ergency feedva:er (IFW).

This After a analysis was perfor=ed vi:h :he RITRAN Syste=s Analysis code.

bench = ark agains pl'an: da:a was =ade for ghe firs: eigh: =ir.:es :f the acciden: (:he IF*4 delay :i=e), the sa=e case was reanalyced wi:hou: :he delay.

The results are pr vided in :he a::a:hed figures.

A review of l

Figures 1 and 2 shows :ha: the depressurization ra:e is less severe vi:h-ou: IFW than i: is vi:h nor=al IFW.

This is a::ribu:ed :o the depressuri-i

ation resul:ing fr== the addi:ional cooldown.

In be:h cases, hevever, the pri=ary sys:e= veuld sa: urate as can be seen fro = Figure 3 which shows that :he het leg satura: ion occurs a: al=es: six =inu:es vi:h nor=al IFW flev.

This is app;cxi=ately :he sa=e :i=e cha: the ho: leg l

sa:urated during the acciden.

n-Al-The pressuricer level for each case is shown in Figures 4 and 5.

hough :he pressuricer filled in abou: six =inutes during :he acciden:

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o resul: of high prassure injae:ica flow, Figure 5 shswa ths: the pras-suri er would also fill in abou: nine =inutes for the case vi:h nor=al ITL' as a resul: of void swell in:o :he pressurizer.

High pressure inje:: ion was no: included in this case, so the pressurizer would in fae: be filled even sooner.

In both cases, pressuri=er level is rapidly increasing while pressure is no: responding si=ilarly.

In both cases, :he pri=ary syste=

is voiding and losing = ass through the s:uck open PORV a: the eigh: =inute point.

The conclusions of the above discussions are that syste= behavior, includ-ing pressurizer level, vi:h or without an eight =inu:e delay in ITW, is very si=ilar and that subsequen: operator ac:Lons keyed :o pressurizer level vould be essen:ially the sa=e whe:her or no: :he e=argency feedva:er had been los: for 8 minu:es.

Cerrec:Ive A::lon:

Me:ropolitan Edison believes tha: in :he in:eres: of i= proved plan: safety 1: is i=por:an: to :ake all reasenable steps to assure the =4xi=um avail-abili:y of all safe:y rela:ed syste=s and sys:e=s recuired for safe shu:-

dev=.

T vard this goal, all surveillan:e and :es: procedures are being reviewed for both uni:s I and 2.

In par:Icular, the Uni 2 e=ergency feed-water syste= surveillance and :es: procedures vill be =odified to avoid isola:ing all flow capabili:y fr== the emergency feedva:er sys:e= during surveillance and tes:ing so that a: leas: two feed pu=ps and one flow pa:h frem the e=ergency feedvater sys:e= will be operable a: all ti=es.

This ite= is no: an issue for Uni: I due :o the differences in design of :he Unit I syste=.

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In cddition, a farnal routins shif: chcek of enginserad safeguards equip-including the status of emergency feedvater pumps and valves has

ment, been ins:itu:ed for chose sys: ems necessary for safe operation of 1".MI Units I and 2.

The impor:ance of diligen: monitoring of the status of safety equipnen: and the role of the various administrative control systems in assuring proper and safe operacion of plan: systems is being emphasized in our opera:or training progra=.

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St Ate =snt of Aoonren: Non=emoliance:

i The severity and uniqueness of the accident.which occurred a: Three Mile island resul:ed in a marked redue:lon in the nor=al good heal:h physics practices which are mandated by the NRC Regulations. Under the circu=-

s:ances of an acciden: of this magnitude the NRC recognizes tha: in the in:eres: of reae.:or safety a departure from normal health physics prac-ticas and standards may some:imes be mandated by the exigencies that exist during such conditions. However, the NRC also believes tha: the licensee, with the resources available and taking into accoun: the time frame available for conduct of safety-related functions, could have taken additional measures to better control the overall health physics ac: ions and decisions which sere made during the course of the accident.

The following items of noncompliance exemplify unacceptable degradation from health physics practices pertaining to con:rol of access to high radia-tion areas, conduct of radiation surveys, and personnel radiation exposure monitoring.

10 CFR 20.201, " Surveys," requires in Section (b) tha: each licensee shall make or cause to be made such surveys as may be necessary to co= ply wi:h the regulations in 10 CTR 20.

10 CFR 20.202, " Personnel Monitoring," requires tha: the licensee supply appropriate personnel moni:oring equip =en: and requires its use> for each individual uno en:ers a res: ie:ed area and is likely to receive a dose in excess of 25 percen: of the applicable value specified in 10 CFR 20.101.

Technical spe:ifica: ion 6.12, "High Radia: ion Area," requires tha: each area in which the in:ensity of radia: ion is grea:e than 1000 =res/h: be provided with locked doors to prevent unau:horized en::y into the area and :ha: any individual en:ering the area be equipped with a con:inuously indica:ing dose rate =eni:oring device.

10 C7R 20.103, " Exposure of individuals to concen::atiens of radioa :ive

=aterials in air in res::leted areas," requires in See:ioa (a)(3) tha:

he licensee =ake suitable measure =en:s of the con =en::a: ions of radio-ac:ive =aterials in air for detecting and evaluating airborne radioa -

tivity in restrie:ed areas for the purposes of deter =ining co=pliance with the regula: ion in 10 CTR 20.103(a)(1).

10 CTR 20.101, " Exposure of individuals to radia: ion in res: ie:ed areas," requires that no licensee possess, use or transfer licensed ma:erial in such a manner as :o cause any individual in a restrie:ed area to receive in any period of one calendar qua::e a dose in excess of three rem :o the whole body, or 18 3/4 ren to the hands and forearms, or 7 1/2 rem to the skin of the whole body.,

Ceneral Discussion:

ihespecificsta:ementsofapparen: noncompliance (2A through 2F) address apparent break downs in good health physics pra : ices. Although Me:ropolitan Edision does not agree vi:h the conclusions of ncnce=pliance in each case, the to:a1 assess =ent clearly indicates areas where t

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,a i=pr ove=e nt s in e=ergency health physics prac: Ice are needed.

Addi-tional co= men:s are provided i= mediately following each state =ent (2A through 2F) for each exa=ple of apparent nonce =pliance.

In evaluating the execu:lon of the post-accident radiation protection pro-gra= it must be reme=bered that this acciden: vas the wors: experienced in the coc=ercial nuclear power industry.

In addition only five people re-ceived doses exceeding their occupational quarterly dose limi:s during the period i==edia:ely following the accident.

As poin:ed ou: by the NRC above, under the circu= stances of an acciden: of this =agni:ude depar:ure frem normal health physics prac: ices and s:andards

=ay so=ecimes be =andated by :he exigencies tha: exis: during such condi-

ions.

In se=e cases, the ex:re=e levels of radia: ion did no: allow for rapid ce=ple:e area =apping prior :o access.

The heavy use of all available radiation ins:ru=en:ation and conta=ina:Icn of analytical equipmen: req-a quired al:erna:e dose assess =en: =easures. The i==ediate need for equip-opera: ion and surveillance resul:ed in so=e viola: ions of controlled

=en:

access require =en:s.

And :he assign =ent of less experienced personnel :o

=an sta: ions replacing = ore experienced personnel required elsewhere re-suited in delays in radiation assess =en:s.

In all of the above si:ua: ions, al:erna:e measures were sough: and applied in carrying ou: good health physics prac: ices and constant ef fer:s were =ade to =aintain acceptable health physics perfor=ance levels while meeting the operational demands of the acciden:.

I

.a Su==arv of Corrective Actions:

To fur:her streng: hen our program ac:icns including the following are being i=ple=ented. - -

i Mantg:=ent has pleccd incroceed emphcsis on absorvation of goed rcdic-

ion protec: ion practices in all aspee:s of routine daily ac:ivi:y.

Since the i= mediate post-acciden: period there ht; been a substantial ef-for: to upgrade the entire Health Physics / Radiation Protec: ion progra=.

Nu=erous contrac: HP technicians and supervisors have been added to sup-port the s:ation s:aff. Addi:ional people in technician and supervisory positions have also been added to the permanen plan: s:aff.

Fur:her addi: ions to the per=anen: staff are planned.

The revisions to the Radiation Emergency Plan has placed significan: addi-tional r=phasis on In-?lan: Health Physics re: raining on acciden: condi-tions.

Procedures are being developed to define the specific approach :o high airborne ac:ivi:y and :he abili:y to analyze sa=plessvith ex:re=e levels of gaseous ac:ivi:y.

Because of the lack of on-site =enitoring capabill:les, si:e =eni:oring devices vill be reevalua:ed and enhanced as,necessary.

The up rad'i ; of equip =en: recuire=en:s vill enhance and :hus eli=ina:e :he deficiencies in :he respira:ory progra=.

The addi: ion of long handled tools and portable shielding vill be ec=pleced as well as training of chemistry personnel.

Additional air moni:cring equip =en: has been purchased and is in place.

The added.

capabili:les for nor=al opera: ions vill provide increased assurance that response during e=ergencies vill be adequate.

.Re: aining Trogra=s for Radia: ion Protec: Ion Personnel vill also place addi:ional e=phasis on air sa=pling techniques and respiratory protec: ion "5

during nor=al opera: ions.

The procedures covering :he respira:ory pro-tec: ion progra= have been upgraded and are in ef fec:.

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Th2 hac1th physics pecgram will be Gvissd to firmly as tblich the poni-

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tive con:rol concep: and required training of all appropriate personnel i

will be undertaken :o assure tha: full compliance wi:h a positive con::al 1

progra= is a:hieved, even under a::iden: circu=s:an:es.

The Technical j

Specifica:lons 6.12.2 should be modified to per=i: :he imposition of a

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I posi:ive control entry sys:e= during periods when locked doors are i=-

practicable, impos sible or inconsisten: vi:h good heal:h physics prae: ices.

The revised Radiation Protection Plan has been submi:ted to the NRC in A=endmen: 7 to the Uni: 1 Restar: Report and a similar plan is being comple:ed for Uni: 2.

Revisions to :he E=ergency Plan have resulted in specific procedures which will be wri::en :o address pos: acciden: sampling and analysis to insure

=ini=al exposures by personnel involved.

2he revision :o :he I=e: gen:7 Plan includes specific plans for increased Heal:h Physics supper: during

he response to an inciden:.

Included in the plan is the organima: ion :o i

focus on the docu=en:acien and evalua: ion of individuals who are conta=i-na:ed.

P :cedures will be devel: ped and ::aining of personnel vill be a::e=plished :o fully i=ple=en: the e=e:gency plan orio: :o the s:ar: us of Uni: 1.

"he revised I=ergency Plan has been sub=i::ed :o the NRC as par: of :he Uni: 1 Res:ar: Repor: and is currently being reviewed for : heir ac:ep:ance.

The following gives additional ce==ents to be censidered in evalua: ion of

he specific claimed ncnco=pliances.

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3: Ate =ine of Aeocren: Noncomoliance Fre= 1100 hours0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months on March 28,1979 un:11 the af ternoon of March 30, 1979,

he doors to the auxiliary building were no locked and access was no:

otherwise con: rolled even though the building was known to be a high radiation area with radiation levels much grea:er than 1000 mre=/hr during this period; I

Discussion:

Technical Specifica: ion 6.12.2. provides that " locked doors shall be pro-vided to preven: unauthoriced entry in:o... areas" in which the radiation level exceeds 1000 mrem / hour. During the period fre= 1100 hours0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months on March 28,1979 un:i1 the af:ernoon of March 30, 1979, areas vi:hin the auxiliary building had radia: ion levels above 1000 mres/ hour.

The auxi-liary building was no: locked. However, a progrz= of posi:ive control over en:ry was es:ablished as conce=pla:ed by 10CTR 20.203.

Under the circu=s:ances of the acciden:, :here were a r=all nu=ber of cases (:ve of which we are aware) in which the posi:ive control progra= did ne: resul:

in the level of control desired.

The failure to have locked doors con-o s:i:u:ed a devia:icn fre= the Technical Specifica: ion, bu: steps were

aken :o be consisten: vi:h good heal:h physics prac: ices.

Although Metropolitan Edison ackncvledges : hat failure to =ain ain posi:ive cen-

rol in any par:icular ins:ance cons:i:uces a nonce =pliance vi:h 10C7K20, the overall program as i=ple=ented during the March 28 - March 30 period was in confor=ance vi:h 10CTR20.

The locking require =ents of Technical Specifica: ion 6.12.2 are no: wri::en to provide an exceptica for cases in which spaces canno: or should no: be locked.

ICCF120 on the other hand allows control of access to "high radi-in at ton areas" (i.e. areas with radiation levels grea:er :han 100 =re=/ hour) based upon " positive cen:rol over each individual entry" during periods

whon cc:ess :o the crea is rsquirsd.

10CTP. 20.203 (c)(2)(iii).

I:

was this =e:hanis: which was used :o con:rol access to the auxiliary building during :he period in question.

Following declara: ion of the Site and General E=ergency, posi:ive con:rol was es:ablished.

The first steps were positive control of all individuals on si:e, ingress and' egress enatrol to :he station, evacuation of non-essen:ial persennel and individual task assig==en: briefings by responsible individuals prior to entry for =onitoring or other activities.

To the ex-

ent pos s ib le, the =axi=u= a=oun: of pro:ective and =eni:oring equip =en:

vas provided. Under the condi: ions of the acciden:, " positive control" was =aintained during the period in question.

No entry to the auxiliary building was :o be =ade vi:hou: appropria:e authori:ation.

As circu=-

s:ances allowed, infor=a:icn en known condi:icns inside che auxiliary building was ce__anica:ed :o personnel prior :o en:ry.

To i=preve reliability of entry con:rol on March 29, the radiological een-trol poin: vas =cved fre: :he IOC and ICS to :he =ain entrance of :he auxiliary building.

This was possible because of the reduced levels of airborne con:a=ina:icn.

The process of =oving con:rol poin:s con:inued as radiological condi: ions per=i::ed.

As :he No: Ice of Violation recogni:es, departures fr== nor=al heal:h physics prae:1:qs are se=e:i=es =andated by ac:ident conditions.

Un-an:icipated condi: ions arise where nor=al prac: Ices, such as locked doors or local con:rol poin:s, can lead to unnecessary exposures to plan: per-sonnel and :an be cen:rary no: :o be good health physics prac: ices.

By set:ing up a positive control pregra= during the a :ident, :he a::e:p:

vas =ade :o ce= ply vi:h good heal:h physics prac: ices :o the maxi =u=

while =eeting the operational demands of :he ac:iden:.

'Je believe exten:

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ina: the magni:ude of the accident aus: be taken into accoun: in evaluating I'

t the seriousness of the instances where the con:;ols which were established failed to be fully of fec:ive.

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23.

Itatestnt of Annerant Noncemelirnce:

From the evening of March 28,1979 un:i1 the evening of March 29, 1979, at least two en: ries into the auxiliary building were made by individuals who were not equipped with a radiation monitoring device which con:inuous-ly indicated the dose race; Discussion:

Metropolitan Edison agrees that a violation occurred in that the individ-uals specified in NURIO 0600 Section II 3.2.4.6 and II 3.2.4.8 did no:

have radiation monitoring devices which at all times indicated the dose In each case, individuals were making entries into the Auxiliary ra:e.

Building with some awareness of information on dose races and anticipa:ed exposures, and a::emp:s were made to provide moni:oring equipment from :he available equipment.

As indicated in See: ion II 3.2 other individuals who had 'previously en:ered

he areas were questioned and approxi= ace dose rate informa: ion was de:er-mined.

The app;cximate total exposure infor=a: ion for previous en: ries into the Auxiliary Building was also availa,ble for guidance to indi iduals v

planning an entry.

A briefing was generally provided to each individual :o insure : hat he was frniliar vi:h the specifi: :ask :o be perfor=ed and :he exa:: areas :o which he was going.

See: ion 3.2.4.8 indicates : hat this operator was aware of the area vi:h to proximi:y to pri=ary sys:en piping and available shielding.

respec:

See: ion 3.2.4.6 sta:es :ha: personnel did carry dose race ins:rumen:a: Ion but at times the low range instrumen: was off-scale.

Ivery effor: was l

being made to provide each individual vi:h the proper ins::umen:a:Lon.

l However the limited nunber of instru=en:s available during the firs: hours of the acciden: prevented this is s==e cases.

The individual was aware of l

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tha duso rate to which h3 would b2 cxpossd cnd hrd estimated the tocc1 ax-posure to perform his task as 500 arc =.

his was based on discussions with other personnel who had recently exited from the same area.

De exposures received by personnel making Auxiliary Building entries were not as low as we would have liked to have achieved. However, there were few overexposures relative to the number of entries and the associated radiation levels. The highest exposures due to Auxiliary Building entries significantly greater than the occupational limits specified in were not 10CT?.*0.

Also, during the initial days following the accident, evalua: ions were constantly being made to determine the risk associated with each oper-ions and =ain:enance function, based on previous dose-ra:e and exposure info =a: ion, areas which had to be entered and time neede,d to co= place the action. These risks were evaluated assinst the risk to plan: personnel and

he general public due :o no: perfo=ing the function.

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Stetemin: of Anicran: N5ncesslicnce No measurements were made of the concentrations of airborne radioactive

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materials in the Uni: 2 auxiliary building for periods during which individuals were exposed from 1100 hours0.0127 days 0.306 hours 0.00182 weeks 4.1855e-4 months on March 28, 1979 through midnight March 30, 1979, nor in the Unit i nuclear sample room and primary chemis::y laboratory for periods during which individuals were exposed from 0400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months on March 28 through 0800 hours0.00926 days 0.222 hours 0.00132 weeks 3.044e-4 months on March 30, 1979.

Discussion Technical Specifica: ion 6.11 requires tha: procedures for personnel radia-tion protection be prepared consistent with the requirements of 10CTR20.

10CTR20.201(b) requires that each licensee make or cause to be made such surveys as may be necessary for him to comply with the regulations in this Section 20.201(a) states that a " survey means an evaluation of the par:.

radiation ha:ards incident to the produe: ion, use, release, disposal, or presenceofradioactivematerialsorothersourcesofrakiationundera specific set of condi: ions. When appropriate, such evaluation includes a and measure =en:

physical survey of the location of materials and equipment, of levels of radiation or concentrations o' radioac:ive materisi ; esen:."

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2he general guidance of 10CTR20.201 therefore is applicable and Me::cpolitan Edison does no: believe 1: vas in viola: ion of this regulation.

J E=ergency condi: ions existed which made physical measuremen:s impossible.

vas located in a high Specifically, because the on-site analytical equipmen:

background area and the ss=ples that were taken had been gas saturated, :he Ge (Li) capabili:ies were ineffec:ive.

Although a physical survey was de-sirable, the ineffective on-si:e analytical equipmen: prohibited its comple-1 tion.

I: was not felt that a physical survey at tha: ti=e was necessary to comply wi:h 10CTR 20.201(b). Upon the arrival of a mobile labora:ory on March 28 a: the Observation Cen:er, two in plan: air samples were analy:ed

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far iodina cetivity using a C2 (Li) d2tcetar. N2ithar indicated cbsva :he minimum ' detectable activi:7 for I-131 (NURIC 0600 Chapter 3 Section 3.2.4.6).

f This delayed sampling demons:ra:ed tha: tne airborne li=its wre no: exceeded.

The use of Self-Contained 3reathing Appara:us units as demonstrated in NUKIC 0600 Chapter.3 sections 3.2.4.4, 3.2.4.5, 3.2.4.7, 3.2.4.8 and 3.2.4.9 exemplifies the maximum positive action taken in the evaluation

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and protection of inhaled contaminates by the personnel involved.

The referenceu paragraphs also establish that individuals were given whole

body counts as soon as prac:ical.

Results of whole body count analysis showed that the pro:ection afforded was sufficient to main =ain internal exposures within acceptable limits.

Theac:Ionstakenduringtheaccidentwerevi:hinthegenegalguidance and :he in:en: of 10CTR20.201 for the circu=scances that exis:ed.. Ef fer:s were made to es:ablish airborne ac:ivity levels, bu:, since opera:lons which were vital :o directing the plant to a safe condition and minimizing the Lcpact on the heal;h and safety of the 'public were necesr.ary, sene actions were taken vi:hout the benefit of thorough saepling and analysis.

Repea:ed ef for:s :o obtain addi:ional samples and perfor= analyses would have resul:ed in added personnel exposure without assurance that the de-ter=ination accurately represen:ed the hazard.

The data, al: hough infor-mative would no: have caused a change in the heal:h physics prac: ices i

l given :he equipnent available during the emergency.

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' ' ~* 23. Sectemane of Anwrent Naneesslir:nto:

On March 29, 1979, an Auxiliary Operator was permitted to enter areas of l

the auxiliary building where exposure rates of up to 100 R/hr existed.

Radiation survey information and appropriate personnel monitoring were provided to the operator for this en::y.

This contributed to the no:

operator receiving a whole body dose of 3.170 rems. When this dose was added to the opera:or's previous dose for the quarter, the operator's quarterly whole body dose was 3.870 rems as measured by personnel dosi-metry devices:

Discussion:

10CFR20.101 (b)(1) states that "during any calendar quarter the total occupational dose to the whole body shall not exceed 3 rems."

It is eviden: by the indicated reading of the individuals TLD that the 3 rem li=i: was exceeded and :herefore the regulation has been violated.

However, Metropolitan Edison feels that appropria:e instrumentation to define radiation levela was provided as well as adequa:e, dosimetry in the for= of TLD's.

As indicated in NURIG 0600 Chapter 3, see: ion 3.2.4.7, was no: available.

As described in a high range self-reading dosime:e 3.2.4.7 of NURIG 0600, the individual did not inform Radiatica Protec: ion s

personnel of his in:en:lon :o =ake a second entry into the duziliary building.

The individual asse=ed that his exposure was abou: 1 rem based o

en dose rate and stay ti=e infor=a: ion. No one was inforced tha: :he in-dividual's Low-Range Self-Reading Dosi=e:e vas off-scale.

Following the second entry by the individual and upon deternination by his supervisor of the of f-scale reading on the self-reading dosi=eter, the individual was removed from radia:lon areas and his TLD processed'.

l The even:s show the intent to follow sound Heal:h Physics practices and provide adequate monitoring during the accident conditions. The events

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a do howevar chew ths ecsd fsr cdditionsi high rcngs monitoring equipaznt and the desire of personnel to respond to the actions necessary to mitigate the consequences of the accident.

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5:ntents: of Ao7 cran: N:ncomslirnes:

On March 29, 1979, a Nuclear Engineer entered an area of the auxiliary 5

1uilding where the radia: ion level was grea:e than that which could be measured by his por:able survey instrumen: ( R/h ).

Failure to perfom a survey of the exposure rate in this area contributed to the individual receiving a whole body dose of 3.14 rems for this entry. When this dose was added to the engineer's previous dose for the quarter, the engineer's quarterly whole body dose was 4.175 rens as measured by personnel desi-metry devices; Discussion:

This i:em is a violation of 10CFR20.101. However, the following circu=-

stance must be considered in evaluating this incident:

In the time period (approximately 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) prior to the Nuclear Engineer's en::y into the auxiliary building, there was considerable concern for va:er leaking into the building from an unknown source. During the day of March 29 accu =ulated water had b,een removed from :he basement floor via floor 1

drains :o the auxiliary building su=p pu=p(s). By 6 PM :he water level had aga,in increased 2 to 3 inches on :he 281' eleva: ion.

This water was though: to be a possible con:ributor to the continuing, uncontrolled release of radioac:ivity to the building and ul:ima:ely :he enviro==en:.

Since the vare level was con:inuing to increase, it was co=-

sidered vi:a1 to iden:ify the source of leakage. An entry team was sen:

into the auxiliary building in an attempt to visually locate sources of Prior to entry the tes=, consisting of two engineers, va's briefed leakage.

on the known radiation areas in the auxiliary building.

Radiation levels that time were limited to infernation ob:ained from previous en-known at tries.

Information was limited because of :he relatively small nu=ber of previous entries and the rapidly changing conditions. The entry team also reviewed the intended locations of the areas to be checked and entry and exit routes.

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Tha Gntry team wcs preperly dressed as indicceed en I&E T cascript of Interview of " Engineer J" (May 2, 1979, Tapes 92-93), p. 13.

Each engineer was provided with a radiation monitor. One had a high range inr::umen:

(0-1000 R/h) and the other had a low range instrument (0-2R/hr). A second high range ins::umen:'was not available. Each was also provided with self-reading dosimeters.

Together, the two engineers intended to jointly inspect a variety of equip-men: and cubicles, frequently monitoring radiation levels.

Shor:17 after entering, the high range monitor failed. Therefore, the engineers tried

o avoid areas wi:5 radiation levels beyond the range of the low range in-s::ument. *dovever, in the one area where they were unable :o avoid radia-tien levels above 2R/hr, they checked their self-reading dosi=eters af:e; leaving :he area.

Self-reading dosimetry was checked af:e: leaving an area in which the low range =enitor reached the full scale reading.

A: tha: :i=e each engineer had sceived less than 500 mR.

The engineers separa:ed af:e 10 =inutes of the 15-20 minu:e,:ocal en: y

i=e., The engineer wi:h :he low range ins:: =en: re:urned :o :he :S1 eleva: ion :o conduct a further investigation.

The other engineer wen: to l

the radwaste panel (a lower radiation area) to adjus: valve positions.

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The engineer wi:h the low range ins::unen: continued the : cur, frequently l

l checking the radiation levels,and attempting to cover as much of the building as possible. After finding that the radiation level at the door-t way to the RC Bleed Tank room was 2R/hr, he checked his lew range self-reading dosimeters and noted that it was off scale.

The engineer i==edia:ely I

lef: the auxiliary building.

The high range dosimeter read in excess of 3R.

Each man was debriefed by a Radiation Protection Foreman for the ic-cation of high radiation areas.

The Supervisor of Radia: ion Pro:ec:len 26-

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's and Ch03iotry instruettd tha cugin;3: with th2 high rarding to h:va his s

TI.D read to confirm the exposure.

The exposure was confirmed and the engineer was restricted from further activities in controlled areas for the remainder of the quarter since his exposure exceeded the 3 Rem / quarter li=it of IOCTR20.

Separate reports and evaluations have been submitted to the NRC regarding this matter.

~

The entry which resulted in the exposure of the Nuclear Engineer in excess of li=ics specified in 10CF120 was made with strong consideration toward exposure control. The entry was considered to be vital to the limiting of release of radioactivity and minimizing the effect on the general public.

Proper radiological practices were followed to the degree possible under the existing conditions.

This dose was well within the annual guidelines of 10C7R20 and far be-lov the guidance of the Na:ional Council on Radiation Protection for emer-gency and accident cenditions.

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Streem n: of Assarant Hence=wlienen:

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On March 29, 1979, a Chemistry Foreman was per=i:ted to repeatedly en:e:

high radia: Ion areas and handle samples of highly radioac:ive reactor coolant. This con:ribu:ed to the Foreman receiving a whole body dose of

hen :his dose was added to the Foreman's previous dose for 4.100 r ems.

the quarter, the Foreman's quarterly whole body dose was 4.115 rems as measured by personnel dosimetry devices; 2G.

Statement of Annarent Nonconoliance:

On March 29, 1979, a chemistry Foreman and a Radiation Protection Foreman were permitted to handle a highly radioactive reactor coolant sample withou: adequa:e personnel monitoring and without first performing a survey of hand and forearm exposure races. Handling of this sample resulted in a calculated dose to the hands and forearms of the Che=istry Foreman of abou: 147 rems and a calculated dose to the hands and forear=s of the Radia: ion Protection Foreman in the range of 44 to 54 rems; Discussion I: ems 27 and 2G deal vi:h the same even: and therefore are covered D

ogether in this discussion. Metropolitan Edison Company agrees that while ob:aining a Reaccer Coolant System samole on 29 March 1979, ex-posure to the whole body of one individual and exposure to the ex::e=-

i:les of several individuals exceeded 10CFR20 limi:s. Also we agree tha:

adequa:e extre=ity =enitoring was no: used by the individuals, however all evalua:icns of ex::e=i:7 exposure have been.eceple:ed and documen:ed.

Me:ropoli:an E11 son feels however that the circums:ances surrounding :he drawing of the sa=ple indicated that serious attention was given to radio-logical prac: ices and that the sanple was obtained in a way that mini =ized exposure using available equipment considering the urgency of the sa=ple requirements.

The individuals involved in the sa=ple were knowledgeable both in :he sample system and radiation protec:icn practices.

A plan to obtain the sa=ple was developed by the individuals which included providing respira-tory protection, protec:ive clothing, high range dose rate instru=en:s, e

_. ~ _ _ _ _ _ _ _ _ __.. _ _ _

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rota: ion of personnel, checking of dose rates after each step cnd chsek-ing of self-reading desi=eters af ter each step.

Tne sample was not obtained until the individuals felt confident that all were aware of the plan and that all reasonable planning had been done. Extremity monitors were not ic=nediately available. The use of vrist badges which were on-site would not have eliminated the need for the evaluations performed but would have simplified them.

During the drawing of the sample, the plan was followed to the degree pos-sible and dose rates and exposures were continually checked.

Although contact dose rates from the sample were greater than the range of the high range instrument available, dose rates at a few inches were measured which provided an indication of the readings on contact."

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5:cteman: of Amocrent Nincomolirnen:

E' On March 28, 1979 and March 29, 1979, several individuals received skin contamination of the hand and o:her parts of the body sufficient to cause exposure ra:es in :he range of 20-100 mR/hr when measured with a hand-held survey ins: ument and no evaluation of the dose to the skin of these individuals was made.

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Discussion:

v Metrcpolitan Idison agrees that in the cases of individuals contaminated on March 28 and Mtreh 29, 1979, a timely evaluation of the dose to the skin of these irdividuals was not performed. To: those individuals whose exposure exceeded the limits of 10CTR20.101, failure to provide a written repor: within 30 days is a violation of 10CTR20.405. Evalus: ions have been mass based on available informa: ion, including whole body coun: data, survey data, and personnel interviews.

A report (Ref. Met-Ed le: er GQL1094 of 21 August 1979) has been submitted for those individuals in which the skin dose due to the con:aminati n was a contribu:ing fac:or in exceeding their quar:erly dose limi:.

For those individuals whose skin dose var below the 10CTR20 specified limi:s, evaluations are e,=p1**e and availab le.

I: should be noted :ha: the exposure rates were measured im=edia:ely fol-Ini:ial loving en: ries in:o the Auxiliary Building or Nuclear Sample Roe =.

decontamina:lon effor:s occurred vi:hin a few hours and in se=e cases, vi:hin minutes.

The deconta=ina: ion effor:s resulted in a signifi:an: re-due:lon of contamina: ion levels for personnel involved.

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3.

S rtament of Aomarcnt Noncomalirn=2:

Technical Specification 6.5.1, " Plant Operations Review Coem:ittee,"

requires:

in Section 6.5.1.6.a. that the Plant Operations Review Commi:-

tee (PORC) review all procedures (and changes thereto) required by h -hnical Specifica: ion 6.8 and any other procedure (or change) deter =in-ed u affec: nuclear safety.

Con:rary to the above, inadequate reviews were performed on bo:h Proce-dure Change Reques: No. 2-78-707, Revision 4 to Surveillance Procedure 2303-M27A/B, and Procedure Change Request No. 2-78-895, Revision 8 to Surveillance Procedure 2303-M14A/5/C/D/E; both were reviewed and approved by the PORC (November 9, 1978 and August 15, 1978 respectively). Each approved change included a valve lineup which resulted in emergency feedva:e; header isolation, con: ary to Technical Specifica:icn 3/4.7.1 requir emen::s.

Discussion:

Me:ropoli:an Edison does not believe tha: it has viola:ed the ci:ed Technical Specification.

On Augus: 15, 1978 the Plan: Operations Review Co==i: ee (PORC) reviewed and approved in 1.ri:i'ng Procedure Change Reques: (PCR) No. 2-78-707, finding tha: this ite= did not constitute an unreviewed safe:y questien.

On Nove=ber 9,1978 the PORC reviewed and approved in writing PCR No.

2-78-395, finding :ha: this i:e= did no: cens:i:u:e an ut eviewed safe:y ques: ion. These a:: ions demons:ra:e confor=ance vi:h Technical Soecifi-ca: ion 6.5.1.6.a and 6.5.1.7.b which requires a vri::en de:er=ina: ion as to whether or no: changes to procedures cons:1:ute an unreviewed safe:y ques: ion.

As discussed in connection with Apparen: Noncompliance 1, Metropoli:an Edison believes that neither PCR was contrary to the interpre:a:icn of the Technical Specification 3/4.7.1 requiremen:s. Therefore the reviews conducted by the PORC vere no: inadequa:e.

This belief is confir=ed by the review and acceptance by the NRC of Revision to Surveillance Pro-cedure 2303-M14A/3/C/D/E docu=ented in their Inspec: ion Repor le::er dated January 9, 1975, "Co=bined Inspe::I:n 50-299-73/03 and 50-300/

78-36."

I./

a.

Many approved surveillance and test prc:edures render safety related sys-tems inoperable for short periods of time and so long as the inoperable period does no: exceed the Technical Specification time limit for system inoperabill:y this practice has been considered acceptable by both Metropoli:an Edison and the NRC.

Examples of similar surveillance and test procedures are:

2303-M2A/3 - Decay Hea: Removal Pump Functional Tes: and Valve Operability Test 2303-SA:

- R3 Hatch 1eak Rate and Interlock Tes:

2303-M25A1B - De:ay Heat Closed Cooling Wa:er Pumps Functional and Valve Operability Tes:.

The reasons for the changes to the surveillance procedures were to take in:o account unnecessary :hermal shock to the emergen:y feedva:er no:zles and to ob:ain repea:able resul:s for res:s required by the"ASME Code See:lon X2.

The thermal shock consideration for the emergency feedva:e noz:les is significan: since the frequency of the tests required by :he ASME Code Sect XI would reduce the number of available thermal cyc1==

associa:ed wi:h mor=al ITW a::ua:icn, thereby reducing :he service life of the no::le conne::len due c higher cu=ula:ive :her: ally indu:ed s:resses.

Corrective A::lon:

3ecause Metropoli:an Edison believes tha: :he subjec PORC PCR reviau was in confor=ance with the Technical Specifica: ions no specific ac: ion is required. We do not believe that these PCR's placed :he A.

emergency feedvater sys:en outside the licensee requirements.

Eovever, as discussed in connection with Apparen: Noncompliance 1,

.a Metropoli:an Edison believes tha: in the in:eres: of i= proved plan:

safety it is impor an: to take all reasonable s:eps to assure :he t

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ma.:imu= availability of c11 enfaty rolotsd cys': ems rsquirsd for cafe shut-down.

Toward this goal, all surveillance and tes: pro:edures are being reviewed for bo:h Units 1 and 2.

In particular, the emergency feedvater system surveillance and tes procedures will be modified to avoid isolating all flow capability,from the emergency feedva:er system during surveillance and testing so that at least two feed pumps and one flow path from the emergency feedva:er system vill be operable at all times.

In addition, a formal routine shift check of engineered safeguards equip-ment, including the status of emergency feedvater pumps and valves, vill be instituted for those systems necessary for safe opera: ion of iY.! Units 1 and 2.

3 4

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.,4.A.

Sectement ef A3Marsn: N nce=slirnes:

Te:hnical Specifica: ion 6.8, " Procedures," requires in Section 6.8.1 tha:

procedures be established, implemented and maintained covering identified activities.

A.

Emergency Procedure 2202-1.5, " Pressurizer System Failure," Revision 3, requires in See: ion A.2.3.1 that electrocatic relief isolation valve RC-R2 be closed if, among other things, the valve discharge line tempera:ure exceeds the normal 130*T.

Con::ary to the above, the electromatic relief valve discharge line temperature had been in the range of 180*-200*F since October of 1978 and isolation valve RC-R2 was not closed as of 0400 hours0.00463 days 0.111 hours 6.613757e-4 weeks 1.522e-4 months on March 28, 1979. Additionally, on March 28, 1979, the discharge line temperature of 283*F was noted at 0521 hours0.00603 days 0.145 hours 8.614418e-4 weeks 1.982405e-4 months , but the isola: ion valve RC-R2 was no:

closed un:i1 0619 hours0.00716 days 0.172 hours 0.00102 weeks 2.355295e-4 months , allowing a significan: loss of RC inventory.

Discussion:

1.

oseration fre= October 1978 Me:ropolitan Edison believes tha Emergency Procedure 2202-1.5, " Pres-surizer System Tailure", was no: violated during the period from October 1978 through March 25, 1979 no:vithstandi=g :he :e=pera:ures of the dis':harge line fro = the pilot operated (electroma:ic) relief valve 4

("PCRV").

Although this pro:edure was unders: cod by the plant staff, i:

is no: clearly written and does no: reflect a::ual plan: conditions.

I:

vill be changed.

However, al: hough Metropoli:an Edison is concerned abou: :he issue, there is no indica: ion tha: this procedure or the history of PORV discharge line :e=peratures delayed recogni: ion that the PORV had stuck open during the course of the a:ciden:.

Emergen:y Procedure 2202-1.5 describes in each of its see: ions a pos-sible failure in :he pressurizer sys:e=, including leaking or inopera-tive PORV and leaking c inopera:ive code relief valves. Each sec: ion "o*I the procedure sets forth a nu=ber of "sy=p:e=s" and several immed-iate and follow-up a:: ices.

2he crux of the claimed nonce =pliance is :he assu=ption tha: :he oe:urrence of a "sy=pto=" au:omatically requires the implemen:a: ion of the associa:ed i= media:e and follev-up p*.

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actions. This assumption is not supported by anything in plant procedures or Technical Specifications and was con::ary to the under-s:anding of Metropolitan Edison personnel at the time of the accident.

A symptom is not a determination that a problem exists. Rather it is a signal that conditions should be examined to det-ermine whether the problem exists. The same symptom may be equally consistent wi:h several underlying situations. For this connection, it should be t

noted that the symp: oms for leaking PORV (Procedure 2202-1.5, Section A) are essentially identical to the procedures for leaking code re-lief valves (Procedure 2202-1.5, Section C).

Thus, the existance of a symptom for leaking PORV does not mean that there i,s,a leaking PORY.

IfthereisnoleakingPORV,thentheprocedureforleakingPORhis no: relevan: and it is not appropriate to apply the immedia:e and follow-up actions of cha procedure.

As described in Section A of Procedure 2202-1.3, ':he immedia:e action fer a leaking PORY is the closure of the Electro =.:ic Relief Isola: ion valve, RC-V2.

The clai=ed noncempliance is that this valve was no:

closed during the October - March period despite the existence of one of 1

the symp: oms of a leaking PORV, specifically

" Relief valve discharge line temperature exceeding the no: mal 130*F.

Alar =s on computer at 200*F."

There is no dispute that relief valve discha:ge line temperature exceeded 130*F during the period in question. The te=perature range during this period was generally 170* to 190*F. However, these temperatures do not a$peartohavebeenthe'resultofaleakingPORV.DuringtheOctober-January period, the reactor coolant drain tank leak rate (which would have reflected leaks pas: the PORV) was essen:ially cero.

Af:er the outage which ended on January 31, the reac:or coolan drain :ank leak rate increased.

-;? -

~35-

Housvar, this w:s cecoepnniod by a shttp incranse in the dicchc ge line tempera:ures for the code relief valves.

In the Oc ober -

January period, these temperatures had been in the 100* - 115*F range.

After.the outage,'the tempera:ures sharply increased to the 160* - 180*F range.

These mat:ers were discussed by the plant staff. Based on temp-1 erature readingr, a determination was made that code relief valve RVIA was leaking and Work Recuest No. C-1137 (February 9, 1979) was prepared for the repair of this valve.

Additional' evidence tha: the 170* - 190*T temperatures on the PORV discharge line did no: result from a leaking PORV can be found by ce=-

paring these :e=pera:ures with plan: conditions. During the oc:cher -

. arch period, this tempera:ure range occurred whether Unir,.1 was a:

M power or in ho: shutdow=. For example, on October 1, 1978, while :he pri=ary sys:e= vas a: 250*F and 265 psi, :he PORV discharge line temp-era:ure was 171.1*T.

On Oc:ober 29, 1978, wi:h primary sys:et :e=p ra-

ure of 566*7 and pressure a: 2155 psi, :he discharge line te=pera:ure was 17 6.4 *T.

Only when :he Uni: was in celd shutdown did :he dischar;s line te=pera:: e fall below the 170* - 190*F range.

For exa=ple, on January 18, 1979, vi:h primary system tempera:ure a: 130*F and pres-O psi, discharge line teepera:ure was recorded a: 80*T.

These sure a:

values make it clear that discharge line tempera:ures did not, of the=-

selves, es:ablish :ha: the PORV was leaking. More likely, the te=pera-l tures resulted from the heating of the line by condue:ivi:y from :he pressurizer itself.

Because the temperature sensors on the code relief valve discharge lines are located much further from the pressuriser than those for the PORV discharge lines, the nor=al tempera:ures fer 4

affec:ed to the same degree by conductive hea:Ing the for=e vere no:

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from the pressuri:er.

~,. - - - - -

- a Corree:ive Action:

Based upon the above discussion, it appears tha: the underlying cause for the claimed non-compliance was the statement in Section A.I.I. that the " normal" temperature of the relief valve discharge line was 130*F.

The normal temperature was actually in the 170* - 190*F range. Once the plant staff determined that this discharge line temperature was no:

normally below 130*F, the procedure should have been changed. Metropolitan Edison's training program vill therefore include steps to assure tha:

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ek these types of changes are initiated when appropriate.

In addition, Metropolitan Edison procedures will be clarified to make explicit the meaning and role of "symp: oms" in these procedures. And, Metropolitan Edison vill address and recognize the deficiencies identified in the procedure by the Staff of the President's Cc==ission on the Accident a:

Three Mile Island.

See Technical 5:aff Analysis Report on Technical of Opera:ing, Abnormal, and Emergency Procedures (Oc:ober, As sessnes i

1979), pp. 14-17.

2.

Failure :o Close Iselation Valve en March 28, 1979 The second aspe : of this claimed nonce =pliance s:a:es tha: a dis-charge line :empera:ure of 2S3*F was no:ed a: 0521 hours0.00603 days 0.145 hours 8.614418e-4 weeks 1.982405e-4 months in March 28, 1979, but tha: the isolation valve RC-R2 was no: closed un:11 0619 hours0.00716 days 0.172 hours 0.00102 weeks 2.355295e-4 months . *While the discharge line temperature at 0521 hours0.00603 days 0.145 hours 8.614418e-4 weeks 1.982405e-4 months was 283*F,

his value was not known by the Shif: Supervisor a: tha: ti=e.

Only a:

0618 did the on-coming Shift Supervisor observe tha: the PORV discharge line te=perature was significantly higher than the tempera:ures for the fode relief valve discharge lines and cause the closing of the PORY isolation valve RC-V2. Since E=ergency Procedure 2202-1.5 does no:

automa:ically require that the isola: ion valve be closed on a high

e=pera:ure reading, f ailure to close it un:11 0619 did no: viola:e :he

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. procedure. However, an explanation of this aspect of the acciden: is nonetheless approp,riate.

Following the turbine trip in the early s: ages of the March 28 acci-dent, the PORY vas expected to open (see Procedure 2203-2.2, Turbine Trip", step 2.A.3).

The operators noted tha: it did open and shor:1y thereafter received an erroneous indication that it had closed.

A: 0425 hours0.00492 days 0.118 hours 7.027116e-4 weeks 1.617125e-4 months , the temperatures for the PORV and code relief valve discharge line were called up from the computer. The reported temp-era:ures were 285'T (PORV), 264*T (relief valve A) and 275*T (relief valve B).*

Since the PORV had just lif:ed, these tempera:ures were no: considered unusual.

Furthermore, the three temperatures were grotped reasonably close together.

A: 0521 hours0.00603 days 0.145 hours 8.614418e-4 weeks 1.982405e-4 months , ano:her se: of discharge line tempera:ures was called up from the computer. The compu: : prin:ou:, a copy of which is a:

ached, ;;in:ed :he :e=pera:ure for code relief valve RVIB twice and physically separa:ed by abou: an inch the 283*T value for the PORV discharge line.

Because of :his prin:ing error, i: tppears tha: the high valve for the PORV discharge line may have been missed.

"he Shif: Supervisor has recalled that the valves were lower than those

aken at 0425 hours0.00492 days 0.118 hours 7.027116e-4 weeks 1.617125e-4 months and :ha: all three readings were similar, :hus not aler:ing hi= :o an abnormal situs: ion, i

Finally a: 0618, the on-coming Shif: Supervise; again called up the tgmperature data fro = the co=:u:er. Perhaps noting tha: the ?ORV

Tnese values were repor:ed to :he Shif: Supervisor.

His later re-collee:lon was cha: the PORV discharge line :e=pera:ure was 225* 230*F.

I&I Transcript of April 12, 1979 Interview of W. E. Zeve, p. 29, I&E Transcrip: of March 30, 1979 In:erview of W. H. Zeve, p. 16.

. _ ~ _

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. discharge line was almost 40*F higher than the code relief valves, he suggested the closing of the PORV isolation valve. With that closing, l

the loss of reactor coolant inventory was atopped.

Corrective Action:

Although this ass'erted noncompliance did not involve any violation of plant procedures, it does point up the need for improved and expanded training of the operating organization and the need for better diagnostic capabilities. With the then existing procedures and training and the availability of instrumentation for identifying a PORV failure, the delayed diagnosis of the POR7 status is not surprising. Better training and procedures and plant instrumentation modifications will be implemented to improve the ability of the operating organization to diagnose such conditions.

These actions vill be co=pleted for Unit 1 prior to re-start of the unit.

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04:44:21 DATA 0387 RC PRESSURIZER WTR LYL 2 (DP) 110.0 04 4.:_3.1_ DATA 0.3.S8__8C_ERESSURIZER_ Wilt LYL 3 (D?)

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05:14: 19:091 3214 RC PJMP IB 0FF OFF l

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101.n 04:52:41 DATA 0153 Coto H HOT PRESS (IN HG) 28.9B..

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05:21:35 DATA 0404 RC PRESS REL VLV RV1B OUT TBi?

218.5 05i 1.:43_ DATA 0405 RC PRES _SUR_f.2,ER_SP_R4Y_LI.NE_TB4P 49G.5 2

05:31:05 DATA 0098 CtOS M4PS OUTLET HOR PRESS 104.5

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0FF 05:14:05:396 3213 RC M4P 2A 0FF

,D 05:14: 19:091 3214 RC PJf4P IB 0FF OFF

05:14:20:275 3195 RP GREEN CH PdR/R_$_TRI P Tdt P 05:14:20:302 3193' RP BLUE CH RlR/R4PS TRIP TRIP D'

05:14:20:303 3195 RP RED CH PdR/R4_P5_TRI_P__

TRIP 0 5: 14:20:365 3197 RP YELLO 4 CH PdR/R4PS TRIP TRIP 0F~

05:14: 23:394_._3.213 RC M4P 2A 0FF _

05:35:55 OATA 1582 PLVL RC PRESSURIZER LYL (IIH2O) 372.0

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I.B.I'5:stement of donaren: Noncomoliance:

B.1 Emergency Procedure 22C2-1.3, " Loss of Reactor Coolant /Rea :or Coolan: System Pressure," Revision 11, requires in Sections 3.2.2.3, 3.3.6.2 and A.3.2.5:

that high pressure injection is initiated on low RCS pressure (1600 psig), and that the operator verify high pressure injection is operating properly as evidenced by flow in all four legs (250 spm); that flows be maintained at this ra:e by throttling as RCS pressure drops; and that *nigh pressure injection not be termina:ed until RCS pressure can be maintained above the reset point (1640 psig) or until low pressure injection flow is es:ablished at 3000 gym.

s Contrary to the above:

1.

A: about 0405 on March 28, 1979, high pressure injee: ion flow was thro:tled to ulnimum conditions even though RCS pressure was less than'1600 psi and falling, and without low pressure injec-tion flow es:ablished.

2.

A: various times :hroughout the day of March 28, 1979, the high pressure inje:: ion sys:en was modified su:h. tha: the required flow rates were not main:ained during continuing low pressure conditions within the RCS following the period when the rea::or

-coolan: pumps were stopped and :he high pressure inje : ion sys:e= vas the only mode available for the removal of core decay heat.

4 Discussion:

Me: opoli:an Edison recognizes : hat, in :he ligh: of de: ailed af:er-

ne-fa:: analysis the failure :o main:ain full High Pressure Inje:: ion flow in :he firs: few hours of the a::iden: 1ed :o severe cere da= age.

1 l

!: is no: clear however :ha: :his failure was a failure :o comply vi:h i

one procedure, as des: ibed in the s:a:e=en: of apparen: noncompliance.

This failure was due :o a co= plex intera::lon of sys:em performance charac:er,istics dictated by design, equip =en: failures, analy:Ical myopia, procedural inadequacies, te:hnical specification conflicts, the s:andards fgeus on regula:lon require =ents as necessary and sufficien:

in the=selves,' and training which reinforced many of :hese inadequa-cies as well as being defi:ien: in the general trea:=en of accidents outside of predefined even:2.

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In order to assess procedural compliance, it must first be determined which procedures were possibly appli:able and then determine which proc, dure was in use.

However it is generally recognized and accepted that specific procedures cannot be written to cover every possible sequence of events or condi: ions.

Thus analysis of these more complex conditions requires a much broader review-of influences beyond the specific guidance of written procedures.

Analysis mus: consider the basis for judgements made by the opera:c: in order to make a determination of non-compliance. The condition.s surround-ing the TMI-2 acciden: require that this latter approach be taken.

The conditions that the opera: ors perceived immediately following the turbine : rip appeared to reflect a normal response to a loss of feedva:er.

The immedia:e a:: ions for :he trip were followed.

These in:1uded verifi-cation of automati: fune: ions, manual star of a second makeup pu=a to account for syste= shrinkage, and isola: ion of le:down to help redu e the effe:: of shrinkage. Sher:1y :hereaf:e :he si:ua: ion deviated

'from normal.

This was apparen: to the opera: cts when the pressuri:e level stopped i:s decline sooner than expe::ed and : hen s:ar:ed a rapid recovery.

The rise in pressurizer level could no: be stopped by :he operator as the level rose through the normal range and continued to fill the pressurizer beyond the Technical Spe:ifica: ion limit of 385 l

inches, until it appeared to be solid or nearly so.

During :his same period two other significan: events occurred.

Emergency feedva:e was discovered to be blocked by the unexplained, closed condition of IT-VI A&E, and High Pressure Injection was au:oma:i: ally ini:iated as RCS pressure i

dropped through 1640 psi. The opera: ors took cerre::ive ac: ion for ea:h:

High Pressure Inje:: ion was pla:ed in manual con:rol and significan:17 l

cu: back to a::emp to preven: going solid, and Emergency Teedwater flow

J

}

. l, '

was ini:iated to both steam genera: ors to restore levels to appraximately j

30" as described by the Loss of Feedwa:er Procedure (EP2202-2.2A).

It i

should be noted tha: the possibility of a loss of bo:h main feedwater pumps and failure to achieve emergen:y feedwater flow is no: addressed by procedure, nor is the condition where Reactor Coolan: System pressure is low (less than 1640 psi) and pressurizer level in high. At this time (approximately 0408), the conditions of the plan: vere outside of the entire se: of unit operating procedures. This situation required the operator to make judgemen:s on the best course of action on the basis of his general training and experience, technical specifica: ion limits, general plant opera:ing limi:s and precau:icas and whatever other guidance, al: hough possibly ince=ple:e, migh: be derived fro = specific emergency procedures.

The response of the opera:or is condi:loned by the order in which he receives, recognizes and rea::s :o conditions in the plan:.

As events continue to develop, early judge =ents are modified, dis =arded or reinfor:ed by the analysis of incoming da:a versus the expe::ation of what should have occurred.

The expe::a: ion of wha: should o::ur is a fune: ion of training and experience.

The specific even:s which followed the brief period of "nermali:y" did no: fall in:o easily recognizable, discre:e even:s. The operators were forced to recognize the corre:: synp:o=s fren several hundred abnormal alarms and indica: ions.

The following brief discussion reflec:s the key precedures which may have been applicable and were used in part, and the events which reflect that these pro:edures may have been applicable to seme degree. Steam Supply Sys:e= Rupture (A?2203-2.3 Rev.5) is iden:Ified by the following sympto=s:

-L*-

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s' e

"1.1 Rapid decrease in secondary pressure. (Both OTSO's start to blev i

down)." At 0407:45 bo:h OTSO's reached their minimum pressure of 788 psi on A and 777 psi on B.

This was the approximate time the Emergency Teedvater valves were opened.

"1.2 Electrical load reducing rapidly." The turbine generator had

~

already tripped.

"1.3 Decrease in pressurizer level, R. C. Pressure, and cold leg temp-erature." Pressurizer level had decreased initally then rose un-expectidly; R.C. Pressure had rapidly decreased below the Safety Injection setpoint of 1640 psi and was still decreasing although more slowly; and following an initial rise during DISC dryou:,

j the RC cold leg temperature began a steady decifne.

"1.4 Tor a rup:ure inside the Rea: tor Building; Indication of increas-ing building pressure and temperature.

(Possible high Radioa:-

tivity Levels on EP-R-227 if a tube leak exists)." At approxi-mately 0415 the Reactor Building pressure started to increase followed shortly by an increase in temperature. This was due to the rupture of the RC Drain Tank bu: was unknown at that time.

"1.5 For a rup:ure outside the Reactor Building; Noise may be heard in Con:rol Roo= or a repor: made fro = personnel ou: side the Con:rol Roo=."

There were no reports of this kind.

"1.6 De:rease in main condenser hoeve 11 level or condensate s:orage tank level." The hoeve 11 level had increased due to a blockage

~ in flow at the condensa:e polisher outlet bu: the condensate storage tank was being slowly depleted by the I=ergency Teewater i

System.

Thes2 are all the sy=pto=s for Stes= Supply Syste= Rup:ure. All of these

p:c=s were essen:ially met in the firs: 15 minu:es of the a:ciden:.

During this early period no: all of the sy=p:o=s con:inued to persis: but the deviations were partially understood by the operator when the co=hined effects of loss of main feedva:er, rea::or trip on high pressure, and sub-sequen: dryou: of the OTSG's were considered.

"hese operators had been previously exposed to the condi: ions of a =ain stes= line break fre= the April 23, 1978 Main Steam Relief Valve failure event en TMI-2, and there-fore the existen:e of low reae:or coolan: pressure vi:hou: a LOCA was an easily conceivable si:ua: ion. Since :his was apparently no: a large rup:ure based on the ra:e of change of para =eters, :he operators had no analytical base or training to rely on in deter =ining whe:her these l. - - -

1. n -

n

, ape:ific condi: ions were fully reflective of a small rup:ure. They were

.. for:ed to make judgemen:s a: this time to assess the nex: appropriate s:eps.

This susmary is supported by the Shift Supervisor and Control Room Opera:or in in:erviews with the NRC (I&E Group Interview, 6/28/79," Tape 319, pg. 38-48).

Specifically, the Control Room Operator and the Shif: Supervisor agreed that a: abou: 0415 they thought they had a leak in the steam gener-a:or. As the Control Room Operator highlights the fact that the principle dis:inguishing fae:or be:veen a LOCA and a steam sys:em rup:ure is the ab-sen:e of a Reaster Building Air Sa=ple alarm on EP-R-227, (which was no:

present un:i1 abou: 0615) and the absence of an alarm on the condenser off gas monitor, VA-R-745, (which indica:es an OTSO tube failure and was re-ceived abou: 0700).

The au:o=ati and =anual i==ediate ac: ions ou: lined by the Steam 5.' e=

,t Rup:ure procedure were followed for the conditions as : hey existed.

Sin:e be:h CTS pressure had no: reached :he feedva:er la::h se:poin:

(sos psig) :he OTS :ha: was leaking had ye no: been isola:ed. Eevever a: abou: 0510 a signifi:an: pressure differen:ial s:arted to exis:

be:veen the :vo OTSG's, with the 3 OTSG rapidly falling.

By 0520 a 150 psi differen:ial exis:ed. A: 0526 the 3 CTSC was isola:ed.

Con:inuing' to perfor= follovup a : ions in this procedure vould have the opera:or ini:ia:e High Pressure Inje:tien if pressurizer level dropped below 20",

RCS pressure decreased below 1600 psig or neutron flux starts to rise.

SEbsequently, when pressurize level returned :o above 100", High Pressure Inje::lon was properly secured.

There are no cri:eria or addi:ional s

guidance on res: oring rea::or coolan: system pressure above 1600 psi.

In:1uded within these s:eps is the requiremen: :o ini:Ia:e a cocidovn with :he unaffee:ed s:ca= generator.

e i--.__ -

..-e...

,,,.-,,r.--

m_

-,--.,,.,.m,_7

y.,,,. - - -

,,,y-_.,

n,

..,-.,.,,e,,.-.

yy9.--..---_ymv-,_

v

- g

.. ' =.,Jpecific condi: ions were fully refle:tive of a small rup:ure.

They were forced to make judgemen:s a: this time to assess the nex: appropria:e s:eps.

This summary is supported by the Shift Supervisor and Control Room Operator in in:erviews with the NRO (I&I Group In:erview, 6/28/79,'*Iape 319, pg. 38-48).

Specifically, the Control Room Operator and the Shift Supervisor agreed tha: a: abou: 0415 they though: they had a leak in the steam gener-a:or.

As the Control Room Operator highlights the fact tha: the principle dis:inguishing fa::or between a LOCA and a steam sys:em rupture is the ab-sen:e of a Reactor Building Air Sa=ple alarm on EP-R-227, (which was no:

presen: un:i1 abou: 0615) and the absence of an alar = on the e,endenser off gas monitor, VA-E-745, (which indicates an OTSG tube failure and was re-ceived abou: 0700).

The au:o=a:i: and =anual in=edia:e ac: ions ou: lined by the Steam S,.ie=

Rup:ure procedure were followed for the condi: ions as : hey existed.

Sin:e be:h CTSO pressure had n=: reached :he feedva:er la:ch se:poin:

(555 psig) the OTSG :ha: was leaking had ye: no: been isola:ed. Ecuever a: abou: 0510 a significan: pressure differen:ial s:arted :o exist between the :vo OTSC's, with :he 3 OTSG rapidly falling.

By 0520 a 150 psi differential existed. A: C526 the 3 CTSO was isola:ed.

Continuing to perform follovup a : ions in this pro:edure would have the operator ini:ia:e High Pressure Inje::lon if pressurizer lev:1 dropped below 20",

RCS pressure decreased belov 1600 psig or neutron flux s.ar:s :o rise.

EEbsequen:1y, when pressuri=e level returned :o above 100", High Pressure

!=je::lon was properly secured.

There are no cri:eria or addi:ional guidance on res:oring rea::or =colan: system pressure above 1600 psi.

In:1uded within these s:eps is :he requiremen: :o ini:ia:e a ec=1down with :he unaffee:ed steam generator.

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.-_m,,.....m-

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.___,.,,,o m.7,-,

=,

w

;e. Thsss' steps esta all follovsd, end ya: th2 plen: vas ns: cdaquntaly pro-i I

e tected. The opera:or did no: understand why pressurize: level was per-for=ing anomalously and because of this con:Inued to evalua:e other possibilities while dealing with the other events of the momen:.

A similar analysis of the symptoms in Emergency Procedure 2202-1.3 " Loss of Reactor Coolant / Reactor Coolant System Pressure", Rev. II, w'ould no:

result in the son:1usion that this procedure should have been followed.

A LOCA of significan: size is iden:ified in EP 2202-1.3 3 by:

"1.1 Rapid continuing decrease of reactor coolan: pressure.

(1) Lo alarm 2055 psis.

(2) Lo-Lo-alarm 1700 psig.

(3) Safety Inje=tica acutation at 1640 psig."

This condizion existed un:i1 pressure initialy stabilized near 1000 psi.

This was subs:antially above the ac=ident, analysis levels of less than 600 psig for classical large and'small break analyses.

"1.2 Rapid continuing decrease of pressuri=e; level.

(1) Lo alar = 200".

(2) Lo-Lo alarm 80" (Interlock heater shutoff)".

Tollowing an initial decrease folleving :he ::ip, pressurize:

level con:inually rose uniti exceeding 4Te:hnical Spe:ifica: ion (385") and procedural (400") limits.

"1.3 Hi Kadiation clar= in Rese:or Building."

A1: hough the specific alar = is not noted in this step, it is discussed in the note below step 1.8 as EP-R-227.

This did ne: alar = un:11 appecxi=a:ely 0615.

"1.4 Rese:or Building A= bien: Te=perature Alar =."

This alar = vas received a: abou: 0420 following :he RC Drain Tank failure.

"1.5 Hi Rea::or 3uilding Su=p level."

This was not recognized un:i1 approximately 0430 when repor:ed by an auxiliary operator to the control room.

"1.6 Hi Rea::or Building pressure (RCS or cain stea= line rupture)."

"1.7 Rapidly decreasing makeup rank levei."

The makeup rank level in : cased steadily.

"1.8 Both core flood tant. levels and pressures decreasing."

This did not happen in the firs: eight hours.

The note a: the end of the sy=pto=s sections s:ates that an opera:or =ay dis:inguish between LOCA's, OTSG t6be ruptures, and stea= breaks inside the reactor building by specifically che: king three condi: Ions "unicue te I

f the aforemen:loned acciden:s." These conditions are:

i

"1.

Loss of coolan: inside Reactor Building particulate, Iodine gas m4nitor alarm on HP-R-227 " Reactor Building Air Sample."

"2.

OTSO tube rupture - Cas monitor alarm on VA-R-745.

"3.

S:eam break inside Rea::or Building:

(1) Low condensa:e storage tank level alarm - and or low hoeve 11 level alarm.

(2) W Latch System Acu stion."

)

None of these criteria were fulfilled un:i1 approximately 0615.

De actual condi: ions of the accident following 0405 did no: clearly fi:

the symptom of a signifi:an: loss of coolan: bu: more closely fit the s

sy=p:o=s of a ::eam system rup:ure. De operators felt they had a s:ca=

sys:em rupture and complied with tha: procedure.

It was 0619 when the opera: ors become aware that the plant had actually suffered a LOCA in the pressurizer s:ca= space.

Bis recogni: ion i=ediately followed the closure of the 70KV block valve, but the plan: conditions had degraded

o a poin: where all subsequen: ac:ivities were clearly outside of pro-cedural guidance. Dere were often proceduras which to a lesser exten:

i could have been considered since sor.: of the sy=p:o=s presen: did exis:

during this period.

However, :hese procedures vould no: have been appropria:e.

The discussion above highlish:s :he potential for a=bigui:y or conflic:s in procedures and the difficul:ies facing plan: ope:a: ions when the plant condi:lons in a co= plex acciden: no longer fall within exis:ing plan: procedures. 'Jhen the condi:lons wi:hin the plan: deteriorate to a point ou: side the scope of procedural guidelines, the operators must be required to exercise judgemen:s on the appropriate course of ac: Ion.

5ese judgements must be founded en training which prepares the opera:or to evalua:e alterna:ive a::icns tha: vill lead to a secuence of even:s which will satisfy the fundamen:a1 require =en:s of decay heat removal, een:rol of radior::ive ma:erial and pro:e::lon of :he general public, plan: s:aff and equip =en:.

y-,

e

--n-,.,,,

c-

,.,---.--...---e-

-,-.--,,v,v,.r

-, n

' 9

)

l

..In the period following the closure of the PORY block valve, the full ex:ent of the ini:ia:ing even:s came in:o clear focus to the operators.

2 Normally this would bo the end of the transien: phase and would be

~

followed by an orderly transition to cold shutdown following existing procedural, guidelines.

The conditions at TMI-2 were no: however within conditions defined by procedure. The operators were therefore required to make judgemen:s in order to fulfill the basic steps towards long

er= s: ability. During this period the opera:or made several a::emp:s to a:hieve long cern stabili:y of opera:lons within the scope of his pro edures and training.

A: cer:ain :i=es the use of Eigh Pressure Inje:: ion fulfilled the b

cooling require =en:s of the core and a: c:her ti=es it supple =ented core hea: re= oval via the steam generators. The use of High Pressure Inje:: ion had to be carefully balan:sd wi:h other plan: condi: ions and para =e:ers.

The opera: ors would no: take the plant to the 2.500 psi safe:y valve se:poin: since this presen:ed an addi:lonal po:en:ial failure :ha: in their =inds vould seriously degrade the plant condi-

icn.

Judge =en: vas sound since a valve which failed open would have ul:ima:ely for:ed :he use of the Decay Hea: Sys:e= in :he re:ircula:lon

=ede fro = :he Rea::or Building su=p.

The con:inued use of the a:=espheri:

es= du=p valves which was removing core hea: via the stea= generators was perceived to be a significar.: release path by off-site au:horities and they exerted pressure to ter=ina:e the use of :his cooling path.

This was done a: apprenima:ely 1230.

Fre= this poin: on, a co=bina: ion b} High Pressure Inje:: ion and core boil off through the PORV block valve was the only ef fe::ive method of cooling.

._,_.-..._,,--.--m

a.

1

.~

Analysis of the plan: ' data of that period would show that cooling appeared to be adequate as eviden:ed by gradually decreasing ho: leg te=pera:ure in the A steam genera:or, un:11 the point the A cold leg temperature be-gan to respond.

At this time the re,sponse in the A cold leg was indica-tive of some natural circulation type flow resulting from partial refill-ing of the A loops. Throughout the nex: period variations in the amount and lo:a: ion of High Pressure injection coupled with the use of the POR'.'s block valve con:inued :o effectively remove core hea: while taking the plan: towards the more stable condition of forced circulation.

The performance of the operaters proved :o be uli:imately effe::ive during the period subsequent to closing the block value a 0619 when no procedural guidance or spe:ific training guidance was available.

I: is re:ognized :ha: this process may no: have been the oo:imum se:hed to achieve s:able, forced circula: ion condition, but there is insufficien:

I analysis availabla :o conclude tha: the performance of :he opera:ers af:er 0619 was a: addi:icnal con:ribu:c :o :he final condizion of the cere.

Corrective Action:

The sher:ce=itgs in procedures and trcining identified by :his acciden:

are beir.g correc:ed in i,th uni:s.

A thorough and on going progra= :o review, upgrade and effectively integra:e those aspe :s of design, ana-lysis, opera:Ing experience and regula:ory requirements essential for a sound nuclear program is undervsy.

Organiza:ional changes necessary

.=

o supper: this program'have been made on bo:h uni:s, vi:h each organ-1:a:icn tailored to the specific needs of :he uni:.

Specific : raining emphasis on the responsibili:les of opera: ors to co=pi-vi:h pro:edures has been added. Guidance on actions :o be taken when 1. '.

s

ou: side of the procedural envelope has been added. Netropolitan Edison is participating in industry program to improve operator guidelines which s

aim toward satisfying the basic requiremen:s of reae:or safety for all transient conditions.

These guidelines will be integrated into the

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training program and procedures as they become available.

Me:ropolitan Idison vill continue to use diverse management tools such as Internal and external examina: ions of opera: ions, independen: safety re-views and expanded quali:y assurance activities on a continuing basis to provide the maximum possible opportunity for issues important to safety to be iden:ified and resolved.

De cen:inual. develop =en: of i= proved analy:ical techniques vil"1 be used to perform bes: es:i=a:e analyses of ::ansien: and ac:iden: sequences using specifi: plan: da:a.

Se resul:s of :hese analyses vill be used as an aid in ~ operator training. These analy:ical models have been initially benchmarked agains: a::ual plan: perfor=ance. Bis vill allow fu:ure predictive analysis to uners:and opera:ional events no: previously an:icipa:ed in safe:y analyses. Procedural change vill resul: when pas:

guidan=e is shown to be in error.

I: is. recognized tha: these changes not specific in : heir i=plemen=ation schedule. Tnese changes are no: quickly conceived or i=plemented, but rather require deligent preparation, careful integra:lon, and ongoing re-view to assure tha: :he improvemen:s ne:essary are achieved and main:ained.

.Hatropoli:an Edison is commi::ed to this effor: and vill con:inue to =ee:

the high s:andards demanded.

t

~he require =en:s in : raining and procedure iden:ified by the NRC in ea:h of their task for:e activities are being. reviewed by :he NRC and will be completed prior to the restar: of Uni: 1.

l

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',*4.'5.2 Statement of Annarent Noncomsliance:

t B.2 Emergency Procedure 2202-1.3, " Loss of Reactor Coolan:/ Reactor Coolant System Pressure," Revision 11, requires certain actions to be taken following the automa:i: initia: ion of high presssure inje:-

tien, including in Section 3.2.1, tha: all ESP equipmen: is verified to be in its EST position (capable of performing its intended fun:cion).

Contrary to the above, during the period of approximately 0600 hours0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months until 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months on March 28, 1979, during continuing low pressure conditions within the RCS, the Core Flood System was removed from i:s ESF pcai: ion (rendered inoperable) by closing both tank isoir-tion valves.

[This portion of the EST was inae:ivated during a period when reduction of Reactor Coolan: System pressure was not the immediate goal.

This removed from servic'e this safety feature during a period when it could have been called upon.

In the course of the accident while a: tempting to depressurize to activate the decay heat removal system NRC recognized that it was necessary to isolate the core flood system and encouraged this a: tion.

This ci:a: ion does not apply to isolation during this attempt.]

e Discussion:

Me:ropolitan Edison does no: believe tha: the Core Flood Tank Isola: ion valves (CF-VIA and 3) were closed during the period from approxima:ely 4

0600 hours0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months un:11 1300 hours0.015 days 0.361 hours 0.00215 weeks 4.9465e-4 months on March 28, 1979.

Therefere, this ite= is not a nonce =plian:e.

In addi: ion, if they were in fa:: closed, no vie-la:lon of E=ergen:y Procedure 2202-1.3 occurred since the cere flood

anks were verified to be in their ESF pesi: ion af:er au:o=a:i: ini:le-tion of high pressure inje:: ion.

A Shif: Supervisor testified that he closed the isola: ion valves.

I&E l

Transcript of In:erview of " Shift Supervisor A" (July 1!,1979), p. E.

However, others in the Con:rol room during this period have s:sted that the valves in fae: were open.

I&E Transcrip: of Interview of Frederick, Tibs:, Scheimann, Zeve and Ross (May 29, 1979, Tapes 269 and 270), pp.

19, 20, 23,24; I&I Transcrip: of Interviev ;f : eve, 5:heimann, Faus: and Frederick (June 25, 1979 Tape 321), pp. 47. Subsequen: events confir=

tha: the isola: ion valves were never shu:. A: about 1230 hours0.0142 days 0.342 hours 0.00203 weeks 4.68015e-4 months , :he rea :or coolan: sys:e= pressure was lov enough to per=i: the discharge

.. ~..,, =,. _ _ _,,..... -...,, _

m. -., _., _ _,, _ -, _ _,....,..,,,,,.,.,,.,,., _,. _., _,.,,, _,.,.,,. _. _ _..,.,, _. _ _

4

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of some of the core flood tank inventory in:o the reactor vessel.

Since there is no indication that anyone opened the valves af:er 0600, the clear indication is that they were never closed.

This implies tha: if Shift Supervisor "A" in fact a::empted to close the core flood tank isola: ion valves, that at:emp: did not succeed. The pos-sible explanation for this hypothesis is tha: the proceduressfor closing the valves require that the electrical breakers (normally locked open) mus: firs: be mar.ually closed a: the motor control cen:ert before the valves can be closed from the con:rol room.

If Shift Supervisor "A"

tried to opera:e the valves prior to manual closing of :he breakers, the valves would no: have closed.

While the breakers were closed a:

some poin: during :he morning of March 2s, I&I Transcript of Interview of Schei= ann and Lauder =ilch (March 30, 1979, Tape 95), p. 27, the open s:atus of the valves indica:es tha: Shift Supervisor.A"'s ac: ions, if taken, occurred before the breakers were closed.

In any case, even if :he isola: ion valves were closed, E=ergency Procedure 2202-1.3 vould not have been viola:ed.

In :his procedure, ene of :he follow up ac: ions to au:oma:ic initiation of engineered safe:y features is:

" Verify tha: all E.S.F. equipment is in its ESF posi: ion, by observing tha: all equipmen: sea:us ligh:s indica:e as shown in Table 3-1" E=ergency Procedure 2202-1.2, see: ion 3.1.

One of the indica: ions in Table 3-1 is that the isola: ion valves be in :he open position.

However, the procedure does not specify that the valves must remain in tha: under 25 all condi: Ions. A: least one other procedure, Opera:ing Procedure 21C -

i 3.2, " Uni: Cooldown", provides for closing the isolazion valves.

In addi:lon, where plan: conditions did no: fall wi:hin exis:ing procedures.

opera:or judgmen: =us: be alleved reasonable discretion.

l I

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, Because Metropolitan Edison' believes tha: the core flood :ank isolation valves were not closed, no corree:ive a::lon is appropriate.

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4.C

,Statamtnt of Annntent Ncncomslicnce:

Operating Procedure 2104-6.2, " Emergency Diesels and Auxiliaries," Revi-sion 9, es:ablishes the procedures for the control of the emergen:y diesel generators:

1.

Section 4.10. " Diesel Generator - Automati Start Upon Engineered Safety Features Actuation," sta:es in the closing s:ep, 4.10.6, ths:

the unit can be shu:down af:er the Engineered Safeguards Feature actuation has been cle'ared.

2.

Section 4.6, " Diesel Generator 1A(13) Shutdown 'to Emergency, Standby,"

sta:es -in the closing step, 4.6.6, to place the diesel generator on standby in accordance with Section 4.2; and 3.

Section 4.2, when completed, establishes condi: ions, for autamatically starting the diesels upon actuation of an Engineered Safeguards Feature (EST) including requiremen:s to place the " Emergency Standby /

Maintenance Exercise" switch in the Emergency 5:andby position and reset:ing the fuel racks.

Con:rary to the above, a: abou: 0430 hours0.00498 days 0.119 hours 7.109788e-4 weeks 1.63615e-4 months on March 28, 1979, both the 1A and 13 diesel genera:or fuel racks were manually tripped, thereby prevent-ing an au:==atic start of the diesel generators upon IST ac:uation and manual s:ar: fre= the con:rol un:i1 0949 hours0.011 days 0.264 hours 0.00157 weeks 3.610945e-4 months .

Discussion:

The shu:down of the emergency diesel genera: ors a: 0430 by manually trip-ping :he fuel racks and :he failure :o rese: the diesels for au:a=a:ic star: viola:ed Opera: Ing ? o:edure 2104-6.2, "I=ergency Diesels and Auxiliaries".

0402 hours0.00465 days 0.112 hours 6.646825e-4 weeks 1.52961e-4 months , the :vo emergency diesel genera: ors s:ar:ed with au:oma:ic A:

~

engineered safeguards actua:lon.

Because the diesels were running un- -

loaded (offsi:e prover con:inued to be available), their shutdown was appropria:e.

See Operating ?:ocedure 2104-6.2, see: ion 2.1.1.4.

A Control Room Operator dispa::hed an Auxiliary Operater to shut down :he diesels by manually tripping the fuel racks, the only me:hed by which the diesels can be shu: down af:er an au:c=a:i: diesel s:ar: on engineered safeguards a::ua: ion.

rf

Since off-site power remained available, the unit was no longer at power, further engineered safeguards actions were possible, and addi:ional manual tripping of the fuel racks would require dispa:ching personnel in:o areas with airborne contamina:lon, the Control Room Opera:or con-templa:ed that the diesels, once tripped, would be rese: in the maintenance exercise position. This would prevent automatic starting on engineered safeguards a::ua:lon but allow diesel star: from the con:rol room in :he even: of tha: effsite power were lost.

Eevever, the Control Room Operator did no: give specifi: ins: uctions to the Auxiliary Operator and the Auxiliary Opera:or did no: report h'is specific ac: ions back to the Con: o1 Room Operator. As a result, the fuel racks were no: reset and :he diesels gould only have been restarted by disps:ching an o'pera:or :o rese: the fuel racks. Only a: 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months was :his si:ua: ion recogni:ed and :he fuel racks rese:. Af::: 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months , the diesels could have been man'ually star:ed fro = the' con:rol room had :here been a 1 css of off-si:e power.

Cc :ective A::ien:

In order to assure :ha: :he situa: ion which exis:ed f c= 0430 to 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months is not repea:ed, the operator accelera:ed re: aining progra='is addressing the i=por:ance of procedural compliance and the Uni: 2 licensed opera:or requalifica:lon program will specifically emphasi:e both the procedural ce=pliance issue and the diesel generator procedures.

Because Operating Procedure 2104-6.2 does not con =e= plate keeping :he emergency diesel generators in the main:enance exercise position under the condi: ions as : hey existed af:e: 0930 hours0.0108 days 0.258 hours 0.00154 weeks 3.53865e-4 months on March 28, 1979, Metrepeli:an-Edison considering amending the procedure to allov :he main-tenance exercise posi: ion when the rea::o is in he: s:andby conditie-

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-e s.n!. whsn chara cro scod racerns (such cs eccupational exposura) to cvoid dispatching opera: ors to manually trip the sfiesels.

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', 5 L. D, Statemen: of Annaren: Viola: ion:

Emergency Procedure 2202-2.2 " Loss of Feedvater," Revision 3, requires in Section 2.3.2.d that the opera:or adjus: feed flow to control s:can generator levels a: 30 inches.

Contrary to the above, from approximately 0532 hours0.00616 days 0.148 hours 8.796296e-4 weeks 2.02426e-4 months un:i1 0543 hours0.00628 days 0.151 hours 8.978175e-4 weeks 2.066115e-4 months , the level in A stea= generator decreased to 10 inches (the minimum level indica: ion) while the A steam generator level was being con: rolled manually.

Discussion:

Me:ropolitan Edison does no: believe tha: the item is a noncompliance.

During the period in ques: ion, Imergency Procedure 2202-2.2A (which re-quires maintaining steam generator level at 30 inches under certain con-di: ions) did not apply.

2n :he period jus prior to 0532 hours0.00616 days 0.148 hours 8.796296e-4 weeks 2.02426e-4 months on March 28, 1979, the steam gen-era:or were being con: rolled manually since au:e=atic mode had behaved erra:ically in :he early s: ages of the accident. I6E Transcript of In:e;-

view of Frederick, Taus:, Schei= ann, Zeve and Ross (May 29, 1979, Tapes 259 and 270), pp. 42-43.

Wi:h feedva:er being supplied through :he e=er-ency feedva:er syste=, levels were being kep:.at essen:ially a s:cady s:a:e.

A: 0514 hours0.00595 days 0.143 hours 8.498677e-4 weeks 1.95577e-4 months , reae:or coolan: pu=ps 13 and 23 vere tripped due to vibra: ion levels.

With the loss of primary side flow in the 3 steam generator, heat ::ansfer was los:. "his caused a rapid reduccion in s:ca= generator pressure and a pressure differential between the A and 3 steam generators.

As a result, e=ergency feedva:er flow preferen:ially to steam generator 3, and the A stea= genera:or level dropped rapidly.

went

.}heopera:ortookcorrectiveac:lontorestorelevelslowly.

"he claimed nonce:pliance s:a:es tha: section 2.5 2.d. cf E=ergency Proc ed ure 2202-2.2A, " Loss of Main Feedva er T1ov to Bo:h OTSO's",

vas violated.

"his manual a::ica procedure did no: apply during :he period in ques: ion.

Section 2.5 2.d s:a:es:

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"If roc: tor c olcat temperature cnd praosura scans b2 caintain2d, or if feedva:er flow canno: be restored, or if the rea::or trips, start the emergency feed pu=ps and maintain 30 inches in the steam generators (S/U range indication)."

However, this provision only applies to " Loss of feedwater due to valves closing".

See: ion 2.3.2.

That condition did not occur during the acci-dent. The other manual action alternative, "If loss of feedvater is due

o loss of bo:h feed pumps" (section 2.3.1), was applicable in the early s: ages of the accident.

However, the applicable step in section 2.3.1 (see: ion 2.3.1.d) is based upon automa:i: opera: Ion of the emergency feedwa:er valves:

'Terify emergency feedvater valves (EF-llA (3)) are in automatic and con: rolling OTSG level at 30 inches (S/U range indica: ion)."

2here was no procedure in this se:: ion 2.3.1 governing manual opera: ion.

As of :he 0532-0543 hour :ime period, the more appropriate procedure was Emergency Procedure 2202-2.23, " Loss of Main Feedva:er Flov :o One

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CTSG", since :he condition which led :o :he ' low level in A s:eam genera:or was the loss of flow to 1: alone. Under this procedure, which is the enly one :o anti:ipate a steam genera:or boiling dry, the appropria:e ac:ien is to " establish feed flow using emergency feedva:er pu=p through the emergency feed valves EF-V-llA(3) verv sleviv (2 inches per minute)." Emergen:y Procedure 2202-2.23, see: ion 3.2 Note. (original e=phasis).

2he opera:or complied wi:5 this procedure.

Corrective Action:

Although no nonce =pliance is involved, Metropolitan Edison's revised and augmented : raining programs will s:ress the impor:ance of careful ::::rol of plan: functions in the manual =ede.

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4.E Statement of Anoaren: Noncomoliance:

.Three Mile Island Nuclear S:a: ion, Administrative Procedure 2004, "Th:ee Mile Island Emergency Plan 2004," Revision 2, dated February 15, 1978 1.

Requires in Section 2.1, that the " Station Superintenden:/ Senior Uni:

Superintenden:, Unit Supt./ Shift Supervisor / Uni: Sup:.- Technical Suppor: in the Control Room vill, after reviewing the emergency conditions, classify the emergen:y as one of the following:

"a.

Personnel or Local Emergency, "b.

Si:e Emergency, and "c.

General Emergency "He vill make this classification according to the condition of Table I of this Plan, and iniziate actions according to the Emergency Plan Implemen:ing Procedures, and according to his own bes: judgment;"

and 2.

S:a:es in Table 1 of Section 2.1 that a Site Emergency exis:s when there is a rea::or building high range gamma monitor aler: alarm (Conditica No. e).

Con:rary to the above:

1.

Adequa:e vri::en pro:edures were not es:ablished and implemented in tha: Section 2.1 of Procedure 2004 for implementing the Emergenew Plan lacked sufficien: specificity and failed to result in a Site E=ergency being declared at approxima:ely 0430 on Mar:h 28, 1979, even though pri=ary syste= pressure had decreased to the poin: where safe:y injee:lon was au:ematically initia:ed and a reae:or building se=p high level alarm exis:ed; and l

Discussien:

i The claimed noncomplian:e is :ha: see:lon 2.1 of Administra:ive Procedure 2004 was no: adequa:e, ra:her than that Me:ropolitan Edison failed to comply vich i:s pro edures. While Me:ropolitan Edison thus believes that Administra-

ive Procedure 2004, rev. 2, see:lon 2.1 was not in noncomplian:e, Me:ropoli:an Edison recognices the need for grea:er specificity in its emergency procedures.

The No: 1:e of Violation does no: asser: tha: Metropolitan Edison failed :o co= ply vi:h i:s procedures by no: declaring a Site Emergency a: 0430 hours0.00498 days 0.119 hours 7.109788e-4 weeks 1.63615e-4 months .

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" Loss of primary coolant pressure, coincident with high rea::or building pressure and/or high reactor building sump. level."

Administrative Procedure 1004, section 2.1, Table 1 (Site Emergency, Con-dition (c)). Unless there were a " loss of primary coolant pressure",

condition (c) would not be operative. As se: forth in NUREG 0600, p. II-2-1, pri=ary coolant pressure had dropped from 2435 psig to 1275 psig, a level below the reactor coolant low pressure : rip se:poin: and the se:-

poin: for emergency core cooling system initia: ion. The Shif: Supervisor deter =ined tha: primary system pressure, while it had decreased, had s:abilized.

he pressure was several hundred psi above the level which would o::ur during a large break loss of coolan: ac cide n':.

In the absen:e of a definizion of "less of pri=ary coolant pressure", the Shif: Super-visor interpreted :he phrase as rela:ing to a LOCA or other a:ciden:s (such as Main Stea= Line Break) which could give si=ilar synp:o=s.

Ab-sen: a "less of pri=ary coolan: pressure" as ints pre:ed by the Shif:

Superviser, condition (c) was no: satisfied and

.Si:e E=ergency was no:

de:lared.

Corrective A::ien:

Me:ropolitan Edison has to: ally revised i:s e=ergency procedures and has sub=i::ed them to :he Commission.

The revised procedures grea:1y expand the ca:egories and conditions for declara:lon of emergencies.

They have also been made much more specific in orce to avoid a=biguities and un=er:ain:y to ex:en: possible.

The revised procedures vill be covered in :he

he;grea:es:

Operator Acclerated P.e: aining program and vill be tested in the emergency i

drill progra=.

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';- '2., A site caergsney vns at dsclared at 0635 h:urs en March 28, 1979, c:

which time Condition "e" of Three Mile Island Emergency Plan 1004 had occurred.

Dis =ussion:

Condition (e) for declaring a Si:e Emergency is " Reactor building high range ga==a monitor aler: alarm".

Adminis:rative Procedure 1004, see: ion 2.1, Table 1.

The claimed noncompliance is that this condition occurred at 0635 hours0.00735 days 0.176 hours 0.00105 weeks 2.416175e-4 months on March 28, 1979. Metropolitan Edison does no: believe tha:

this i:e= is a nonce =pliance.

Its bes informa:lon is tha: Condition (e) o: urred a: 0643 hours0.00744 days 0.179 hours 0.00106 weeks 2.446615e-4 months and that the Site Emergency was declared some seven minu:es later. Under the circu=s:ances, this sequence was not unreason-able and did no: violate any procedure.

The apparen: basis for :he 0635 hour0.00735 days 0.176 hours 0.00105 weeks 2.416175e-4 months figure is a review by a Inspe:: ion &

Infor:emen: investiga:or of the strip char: from the char recorder (EP-CR-1901) for the de=e coni:or (EP-R-224).

The investiga:or's recons: ue-

ion of the char: is presa.n=ed in NUREG 0600 as Figure II-3-3 (p. II ~-751.

This recens: rue: ion would have the aler: alarm (25 mR/hr) o::ur a: 0635 hours0.00735 days 0.176 hours 0.00105 weeks 2.416175e-4 months .

The exae: :Ime a: whi:h :he aler: alarm oc:urred canno: be de:er=ined fro =

he mul:1prin: s: rip char:.

The ti=e anno:a: ions on the char: are no:

exact. Nor can the specified char: speed of eight inches per hour be used l

to attive a: a precise :ime since that speed varies vi:h the radius of the char: roll, a radius which changes over :ime.

By at:e p:ing to duplica:e the NUREG 0600 reconstrue:lon, i: appears tha: the 0635 hours0.00735 days 0.176 hours 0.00105 weeks 2.416175e-4 months ti=ing of the aler: alarm was based on an assump: ion that the actual char: speed a: tha: time was eigh: inches per hour.

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'A coro cccurcto cathod of reccnstructing tha tisa of tha ciert cleru is to loca:e on the strip chart two events for which the timing is precisely known and to interpolate the :iming of the event in question.

In this case, the reactor trip and the con:ainmen: dome monitor reading of 8 R/ hour (causing the declaration of a general Emergency) can be both precisely located 6n the strip char: and iden:ified with a specific time,

" i.e. reac:or trip a: 0400:37 (NURIC 0600, Appendix I-A) and 8 R/hr a:

0724 (NURIG 0600, p. II 2-6).

Ey interpola: ion, the time a: which the do=c monitor reached the aler alarm level (25 mR/hr) would be a: abou:

0643.

The bes: infor=s: ion ca :he ti=e a: which the Site Emergency was declared indica:es tha: this occurred a: 0650 hours0.00752 days 0.181 hours 0.00107 weeks 2.47325e-4 months . The shift Supervisor has con-sis:en:1y iden:ified 0650 as the ti=e of the declara: ion.

I&I Transcrip:

of March 30, 1979 In:erview of W. E. Zeve, p. 22; I&I Transcrip: of April 23, 1979 In:erview of W. E. Zeve, p. 67; I&E Transcript of In:erview sf W. E. Zeve (undated, tape 273), p. 7.

"he :i=e of the declara: ion was re-corded on a blackboard in :he Uni: 2 con:rol rec = and subsequently trans-cribed fer his:crical purposes (I&I Recues: i:e= 116.1).

This :co shows a :ime of 0650 hours0.00752 days 0.181 hours 0.00107 weeks 2.47325e-4 months for the declara: ion.

The only c:her ti=e record was a no:a: ion in :he Uni: 1 con:rol room of 0655 hours0.00758 days 0.182 hours 0.00108 weeks 2.492275e-4 months based on the annuncia-l tien over the plan: page sys:e=.

I&E interviewers also used 0650 hours0.00752 days 0.181 hours 0.00107 weeks 2.47325e-4 months for the ti=ing of the declara: ion.

I&E Transcript of June 28, 1979 Group In:erview (Tape 319), p. 37 (ques:lon by Dale Donaldson).

The Site Imergin:y was declared when many of the radiation moni: ors began to alar = and aler: toge:her, when "the Chris:=as tree [ven:) off" I&E Transcript of June 2f,1979 Croup In:erview (Tape 319), p. 54.

Ihese

4

..- alarr.: and alerts were recollected as occurring between 0645 and 0650 hours0.00752 days 0.181 hours 0.00107 weeks 2.47325e-4 months . M ; Fresident's Commission in:erview of Brian Mehler (May 10, 1979, Tape 5), Transcript, p. 15-16. The time in:erval of seven minu:es or less from the alert alarm level of the dome monitor to the declaration of the site Emergency was not unreasonable under the cireursstances surrounding the accident. Administrative Procedure 2004 does not require tha: the declara: ion occur simultaneously with the occurrence of the particular condition.

Instead it provides that "af:er reviewing the emergency condi: ions", the Shif: Supervisor will classify the emergency "eccording to the condi: ions in Table 1 of this plan... and according to his own best judgment." Adminis: a:ive Procedure 1004, section 2.1.

2.ere is no indica: ion :ha: the Shif: Supervisor failed to comply.with this procedure.

Corree:ive Actien:

As no:ed above, Metropolitan Edison has dramatically revised its emergency procedures and vill i=plemen: an expanded training and drill progra= to

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assure tha: :he opera:Ing organi:a: ion is :horoughly familiar vi:h these procedures and can effe::ively carry :he= ou:.

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s'.'49.T ' Srattmant af Aemarant Nuncom31irn=2; Three Male Island Nuclear Sta: Ion Health Physics Procedure 1670.9,

" Emergency Training and Emergency Drills," Revision 4, dated January 16, 1978:

1.

Identifies in Section 3 1, the on-site emergency job categories and requires that training programs for these ca:egories will be condue:ed on an annual (calendar year) basis; and 2.

Describes in section 3.1.1 through 3.1.9, the training program for all on-site emergency job categories.

Contrary to the above, during calendar year 1978, no: all individuals having emergency responsibilities were trained in that two Emergency Direc: ors, one Acciden-Assessment individual, eigh: Radiological Monitoring Team Members, and 37 Repair Party Team Members had no:

received the specified training.

In addition on March 28, 1979, during an emergency, at least four individuals who were assigned as required me=bers of a Radiological Monitoring Team and seven indivi-duals who were assigned as required members of a Repair Party Team performed emergency du:ies for which they were not trained.

Discussion:

Me:ropoli:an Idison agrees tha: the adminis::a:lon of the emergency training ' requirements was not co=plete. Two potential Emergency Directors t

(both shif: fore =en), and one po:en:isi Acciden: Assessmen: individual (a Shif: Supervisor) did not receive the : raining during the year 1973.

I: is i=por:an: to no:e however :ha: a :o:a1 of 27 potential Emergency Direc: ors and 29 po:en:ial Acciden: Assess =en: personnel did receive the training and that each shif: co=plemen: did a: all times have personnel on site who :eceived : raining in ea:h ca:egory.

On March 28, 1979, none -

of the three individuals mentioned acted in a capaci:y for which he did have up-to-da:e, documented training.

no i

Of the eigh: Radiological Meni:oring Team members, two did not have docu=en-training in 1978 and six are believed to have received : raining which te to: ally in accerdance vi:h the : raining procedure requirements.

was no:

Training which var no: received, due :o an administration error, was in areas tha: are si=ilar to the rou:Ine moni:oring fune:Icns performed by Health Physics :echnicians with which :hese individuals are fa:Ilar.

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,.V *, dditisn311y, proceduras for th2 monitsring team rasp:nso, including f

opera:Ing procedures for the monitoring equipment, were immedia:ely avail-able to the monitoring team members. Although the 1978 training require-completely fulfilled, the response of the monitoring teams ment was no:

was sufficien: to properly implement the ersergency plan and provide radia:lon monitoring informa: ion that di3 ensure proper assessment of the effect of the inciden: on the health and safety of the general public.

Due to ad=inistrative problems, none of the individuals specifically des-ignated as Repair Party Team me=bers received in 1978 the cogpiece training program as required by the emergency plan. Bovever, all of the individuals are radia: ion workers and have received ex:ensive training and have experi-ence in radiation pro:e:: ion relative to their nor=al repair fune:icas. I:

on.. arch 28, 1979 as well as the should be no:ed tha: during the inciden:

v days following, many functions, be:h opera: ions and main:enan=e, were per-formed tha: could be classified as emergency Repair Party fune: ions. As the need for any task was de:er=ined, individuals mos: qualified to perfor=

the :ask were assigned. Qua$ifications included specific job knowledge, familiari:y vi:h the syste=s, radia: ion prote::lon knowledge and previous exposure.

Tae in:en: vas also to equalize as mu:h as possible the exposure over all quelified personnel. As a result, the individual sele::ed for a particular task was the mos: qualified individual available although tha:

individual may no: have completed the entire training program.

Correerive Action:

A ryvision to the Radia: ion E=ergency Plan has placed significan: emphasis on in plan: Heal:h Physics during an acciden:. Pro:edures vill be devel-In-oped to clearly define r.he : raining requiremen:s of all personnel.

plan: Heal:h Physics will be:eme a major fae:or in the ::aining of all

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em,e rga n:y ercannel. Trcining in th2 implementatica of tha prc:cdurcs dill be im;lemented prior to start-up of Unit 1.

Additionally management has increased the==phasis on all aspects of radiation protection during daily operation. Additional training of operations and maintenance personnel as well as radiation protection personnel will provide increased

' ' assurance that response during emergencies will be adequate.

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.5:ation Adminis:r ktive Procedure 1002, " Rules for the Protec: Ion of i

Employees Working on Electrical and Mechanical Apparatus," Revision 1

34, requires in Section 4.3, 4.4 and 4.5 that on restora:lon of equip-i men: to service, removed tags vill have all required iaformation entered thereon and then be sui: ably stored, and that the shift foreman shall approve equipment operation by signing the original tagging application.

Additionally, S:stion Corree:ive Maintenance Procedure 1407-1, Revision 0, specifies in Section 5.0, " Job Ticket (Work Request) Flow," the c:ep-by-step process for initiating, processing, obtaining approvals and ultimate filing of the " Job Package" which will include, among other things, documenta: ion of corrective action taken (resolu: ion descrip: ion an'd cer:ification of sa:isfactory post main:enance testing) and Station Preventative Maintenance Procedure E-2, " Dielectric check of Insula: ion, Motors and Cables," specifies how to make the measurements and contains data sheets for recording the values measured.

Contrary to the above, when inspected on June 20, 1979, the tagging application could no: be found for maintenance performed in January, 1979, on Emergency Feedva:er isolation valves (EF-V12A,123, 32A, 323, 33A, and 333). No suitable documenta: ion to de:er=ine whether the maintenance work had been ce=ple:ed, tags re=oved, acceptance criteria met, or valves approved for opera: ion could be found. The TMI-2 main-tenance log lis:s this work'eques: as being in an open s:stus as of r

June 20, 1979.

Discussien:

Me:ropolitan Edison agrees tha: this was a viola: ion of procedures in that a tagging application could no; be found for :his main:enance.

As of July 10, 1979 the TMI-2 maintenance log lis:s this verk recuest as being in a closed s:a:us and associated documenta:lon is filed in :he Main:enance Depar: men:.

The subjec: Job Ticke: vas closed ou: by the operations Depar:=ent en January 25, 1979, signed off by Quality Control on June 12, 1979, and signed by the Supervisor of Main:enance on July 10.

Du,r to the delay in closing ou: :his work reques:, a re:rospective re-view vas conducted :o deter =ine what assurances there were that the valves were operable a: the time be:veen the January =ain:enance and March 28th.' The electrica) supervisor for the ce=pany which perfer=ed. _ - -

e l,'th2' task *varballyesnfirmedthetthem;gg2rraedingswarotakancndwaro a:cep:able but there are no written records to suppor: this s:a:emen:.

As part of the uni: startup on January 30:h, the valves were cycled with-dif fi:ul:y in accordance with surveillance pro:edure 2303-MI4(A/3).

09:

This was done prior to exceeding a main s:eam pressure of 850 psi.

Throughout the remaining period the nor=al surveillance procedures were cc o=plished with satisfa= tory results.

The January work request was closed on July 10, 1979.

The motors for EF-V12ATA vere satisfactorily tested in accordan=e with the procedure prescribed in the work request C2555.

Revision to station Ad=instra:ive Procedure 2002 dated July 25, 1979 deletes the requirements for storage of tags because it is not felt t

to be a necessary fea:ure of re:ords = sin:enance.

Corrective Action:

The re:ords =anage=en: fune:icn a: Three Mile Island is curren:1y being ex-ptnded to in:1ude a significan:1y larger s:sff of professienal and clerical personnel dedi:sted to the collection and re:ention of re==rds.

Fase-4=n:-

"This function will be led by a department level manager.

Separate groups vill be established for Unit I and Unit II procedure control and drawing control under a single supervisor.

Likewise, data canagement will have separate groups for Unit I and Unit II under a single supervisor. Groups for reprographics, document coding, records retention, and technical library will Among the improvement in records re:ention vill be ce=puter-sided filing, i= proved storage and control, and advanced reproduction me: hods.

The emphasis ^on records re:en: ion and con:rol vill be complemen:ed by gen-r i

era,1 training tha: e=phasizes the ne:essi:y to properly comple:e each as-pe : of any work, in:1uding :he documen:a: ion. Finally the staff and supervision of the on-site Quality Assurance Depar: men: has taken on an E

expanded role to assure :ha: each area of perfer=an:e pres:ribed by s:a-tion pro:edures and practices are followed.

e..

a The, ovars11 crgcnizatianni structuro for cecomplishing th2s3 thcngas will b,e subje=t to thorough revie+* by the NRC as part of the review of Unit 1 prior to its restart. The Unit 2 portion of these changes will be sep-arately submitted to the NRO and will reflect the spe:ial nature of ac-tivities in that unit.

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' Statem7nt of Aspernnt Ncncomslienen:

Technical specification 6.8 "Frocedures," requires in Section 6.8.2 tha:

changes to procedures which implement the Emergency Plan shall be reviewed by the Plan: Operatio*ns Review Committee and approved by the Unit Super-intenden: prior to implemen:ation.

Con:rary to the above, a change to 5:ation Health Physics Procedure 1670.7, " Emergency Assembly, Accountability and Evaluation," was made without the required review and approval. An additional assembly area was designated and the method used to perform accountability was modified t

by a memorandum dated October 13, 1978, from the Radiation Protection Supervisor to all departments.

As a result, on March 28, 1979, in response to an emergency, some licenses personnel followed the approved procedure while others followed the guidance in the October 13, 1978 memorandum, creating some confusion and delaying promp: attainment of full accountability.

Discussion:

On 0=:ober 13, 1978, the Radiation Protection Supervisor issued a memor-andu=, "A::ountability During Radiation E=ergency", which added 'an addi-tional asse=bly poin: to those already specified in Sta:icn Health Physics Pro:edure 1670.7, " Emergency Assembly, A:=oun: ability and Evacuation".

This memorandum did no: receive formal review by the Plant opera: ion.

Review Co=mi :ee or approval by the Uni: Superintenden prior to its i=-

piemen:ation.

This was a failure to co= ply with Technical specifica: ion 6.8.0, whic. requires such review and approval for changes :o such pre-cedures.

No:vithstanding the lack of review and approval, the change made by the memorandu= did no:, to the bes: of Me:ropolitan Edison's knowledge, delay promp: a::ainment of personnel ac:oun: ability er cause confusion.

The change made by the 0::ober 13 memorandum was to have non-essen:ial perkonnelou:sidethesecuri:yfencereport to the N ::h k*arehouse.

Prio to this change, these people were recuired :o assemble in the North Audi-1

orium, a location within the se:uri:y fen:e.

Requiring these people to

e

, pass through s2curity to got to cn cas:e.bly point was falt to be an un-necessary, time-consuming step.

Following the October 13 memorandus, He:ropolitan Edison conducted seven radia: ion emergency drills with a scope equivalent to a Site / General Emergency. See NUREG-0600, pp. II-1,-17,18.

n e requirements of the October 13 memorandum were carried out in each of these drills. ne final 1978 drill, on November 8,1978, was abserved by NRC.

As s:sted in the Combined Inspection Report Nos. 50-289/78-21 and 50-320/78-34, NRO made " detailed observations" of a number of emergency drill activities, Including accoun: ability. ne inspectors' dete==ina: ions included the following findings:

1.

"n e licensee's respense was generally in accordance with exis:ing procedures"., and 2.

"n e response was coordina:ed, orderly, and :imel;'."

No ite=s of neneo=pliance were observed.

5 On March 25, 1978, accoun: ability was achieved within approxi=a:ely 1-1/2 hours. khile this was no: as prompt as in some of the drills, i:

was in fae: bet:er than ir. others. Given the facts tha: a real accident

'was in progress, that personnel recall and shif: changes were in progress,

+ tha: plan personnel were fa::ing severe operational demands, and tha:

there are no s:andards for timeliness, full accoun: ability within 1-1/2 hours was :imely.

As to the assertion tha: the October 13 mederandwrintroduced any addi:icnal confusion into the accountabili:y procedure, Me:ropolitan Edison is aware of no infor=ation which would supper: this clai=.

hJEEO-0600 con:ains no

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suppor:ing rafaran=es.

Th2 fact that osysa drills in lete 1978 inplemsnted the revised assembly poin:s makes such confusion much less likely.

And interviews of members of the securi:y prote:: ion force indicate their awareness that the Nor:h Warehouse var a designa:ed assembly poin:.

l See I&E Transcript of Interview of Mr'. William J. Susansky and James F.

Stacey (May 7, 1879, Tape 161), pp. 5, 8.

Corrective Ae: ion:

Accountability require =ents are now in:orpora:ed in the Emergency Plan and its supporting procedures.

These have been reviewed by the Plan:

Operating Review Cc==ittee and approved by the Uni: Superin:endent.

They are also being sub=itted as par: cf the infor=ation to be reviewed by

R* prior to restar: of Uni: 1.

Training in the use of the procedures is a par: of the on going and accelers:ed training progrs=s in Units 1 and 2.

Addi:ional training for supervisory personnel vill be under:aken

o assure adherence to :he review and approval recuiremen:s of the Teah-ni:a1 Specifica: ions.

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5tatement of Aenaren: Noncomoliance:

Environmental Technical Specification 5.7 requires that detailed.wri: ten procedures for instrumen: calibra: ion be prepared and followed.

i Three Mile Island Nuclear Station Surveillance Pro:edure 1302-5.24, Revision 3, dated December 19, 1974, specifies the method of calibration and requires tha: it be performed annually.

j Contrary to the above, as of March 29, 1979, eight environmen:a1 samplers I

had no: been calibrated since 1974.

Discussion:

Although noncompliance vi:h Surveillance Procedure 1302-5.24 was tsch-nically not a viola: ion of any Unit 2 procedures, Metropolitan Idison

~

acknowledges that the procedures should have complied with or withdrawn.

Inviron=en:a1 Technical Spe:ifica: ion 5.5 requires tha: detailed wri: en procedures he prepared and followed :o i=ple=ent the environmental te:h-nical specifica: ions and :ha: :hese procedures include "instru=en: cali-bration".

A Uni: 1 procedure, Surveillance Procedure 1302-5.24

("Inviren=en:a1 Moni: ors Calibra:or") se: for:h a procedure to calibra:e

he con:inuous air =eni: ors le:a:ed around :he si:e and required :ha:

calibra: Ion be performed annually.

As no:ed in NURIG 0600, p.11-1-45, there was no Uni: 2 pro:edure equivalent to Surveillance Procedure 1302-5.24 I: was however lis:ed as an active procedure for Uni: 1.

The Surveillance Procedure had been prepared in 1974 to address a draf:

Technical Specification. Although tha: draf: Te:hni:a1 Specifica: ion included in the final Technical Specifica:lons, the procedure was not was'lnot dele:ed.

The procedure was not, however, follovud because of dif ficul:les in ob:aining useful results and because UO1, the vender of the =eni: ors, had orally info:ned Me:-Ed tha: :he conitors (par-ricularly their flovme:ers) were considered to be pri=ary s:andards and no: subject to accura:e calibra:ien.

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1:,should be noted : hat IEE was aware :ha: these monitors were not being rou:inely calibra:ed.

Combined Inspe:: ion Repor: 50-289/78-03 and 50-320/78-16 (May 31,1978), p.10, included the following discussion:

Discussions with the licensee indicated that at the present time, air sampling units are on a limi:ed pre-ven:ive maintenance schedule. When a sampler fails, plant personnel either replace or repair the failed unit. The timeliness of this action is dependen:,

however, on plan: operational status a: the time of failure. The licensee stated that at the present 1

time the dry gas meters employed with the air sa=p-lers are no: routinely calibrated. The licensee s:ated that the preven:ive maintenance program for the air sa=pling sys: ems and the calibration of the dry gas meters would be re-evaluated. The inspector sta:ed that pending completion of these evaluations, this item is cosidered unresolved.

(289/78-08-03; 320/78-15-02)

Thus, I&E considered the absen=e of routine calibra: ion of these monitors to be an unresolved ite= ra:her than a nonce =plicace.

Corrective A:: ion:

The NRC S:aff in 0::ober 1979 published a draf: Regula:ory Guide, "Calibra:lon and I ::: Li=i:s of Air Sa=pling Ins:rumen:s f : To:a1 Volume of Air Sa= pled" (Division 8, Task OE 905-4). The draf: Reguia-tory Guide identifies me: hods acceptable to the Staf for calibracing air sampling ins: u=ents such as the continuous air moni:crs covered by Surveillance Procedure 1302-5.24 Me:ropolitan Edison vill reviev the procedures described in the draft Regulatory Guide agains: :he de-sign "of the con:inuous air monitors. If calibration can be performed as described in the draf: Regulatory Guide and if i: produces a::ura:e, repr'oduelble results, Metropolitan Edison vill modify the Surveillan:e Procedure accordingly and include this calibra:lon as pst: of the station surveillan:e progrs=. If su:h calibra: ion canno: be perfor=ed, the pro:edure vill be deleted.

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This item also poin:s ou: the need to thoroughly review all s:a:lon procedures. If there are other procedures which need not exist, they will be removed from the active procedure file so that there can be no confusion as to which procedures are to be implemen:ed. At the same time, the ongoing and accelerated training program will emphasize the requirement to comply with all written procedures as well as describe the adminstration controls for addition, modifica:lon or deletion of procedures. The Opera:ional Quality Assurance ?lan is also being re-vised to improve ch'e efficiency and validity of that progra= in support i

of its role in assuring compliance with station and unit procedures.

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Sts:emen: of Annaren: Noncomoliance:

Technical Specification 6.2, "Organiza: ion," states in Section 6.2.1 and 6.2.2 tha: the unit organization and the organization of the corporate te:hnical suppor: staf f shall be as shown on Figure 6.2-1.

Contrary to the above, on March 26, 1979, the organization of the unit and corporate technical support staff was differen: from that specified in Figure 6.2-1 in tha::

.~

A.

A position titled, " Superintendent of Administration and Technical Support" was added to the organization on September 18, 1978 and filled on March 1,1979, auch that the " Supervisor, Radiation Protec-tion and Chemistry," reported to this new position rather than directly to the " Station Superintendent / Senior Unit Superin:endent;"

and 3.

2here were two " Supervisor of Maintenance" positions, une for each unit, rather than one; and C.

A posi: ion titled "Superintenden: of Main:enance" had been added such

. that the " Supervisors of Maintenance" repor: to this new position ra:her than direc:ly to the " Station Superin:enden: (5:a: ion Manager)/

Senior Unit Superin:enden:;" and D.

The position of "Che=ical Supervisor" had been vacan: since the issuan:e of the. Technical Specifica: ions.

6 CY. March 28, 1979 through March 30, 1979, the above organizational discrepancies decreased the ef fe::iveness of the licensee's response to the accident.

Dis==rsion:

i Me:ropoli:an Edison agrees the organi:a: ion in effe:: at the time of the c:ciden: was differen: chan that specified in Figure 6.2-1 of the Uni: 2 Te:hnical Specifications.

However, the impact of these changes had no tdverse effe:: on Metropoli:an Edison's performance following the ac-cident.

The following comments should be considered in evalua:Ing this cpparent nonc==pliance.

A.

A1: hough a Superin:endent of Administration and Technical Support was I

(

added to the organi:a: ion prior to approval of a Technical Specifi-cation change, this position was n : par: of :he emergen:y crgan-f i:a: ion put in place in response to the declara:icn of :he si:e and general e=ergencies. The E=ergency plan organi:a: ion was =anned as l

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prescribed.

The Supervisor of Radiation Pro:ection and Chemistry led the Radiological Assessmen: Effort in the Emergency Con:rol l

Center (the Uni: 2 Con:rol Room), reporting directly to the Emerg-eney Director (Station Manager). The Superintendent of Administra-

]

l tion and Technical Support did not have an intervening role.

1 B/C.Although a position of Superintendent of Maintenance was added to the organization prior to approval of a Technical Specifica: ion char.ge, the specific individual who filled this position had' pre-viously held the position of Supervisor of Maintenance for the s:a: ion. ?rior to the acciden he was promo:ed to the new posi-tion of Superintenden: of Maintenance and two managemen: posi:lons were crea:ed below him at Supervisor of Maintenancs for each uni:.

This change provided i= proved managemen: a::en: ion and capabili:y of the on-site maintenance department structure by no: leaving :he i

firs: level main:enance supervisory a::en:lon spli: be:veen uni:s, and by introducing a middle menagemen: posi: ion belov :he S:a: ion Manage: level who could focus on :he s:a: ion needs and resources in :he main:enance area.

As described in NUKEG 0600, (pg. 11-2-11) following :he emergency declara: ions, "a Repair Party composed of six maintenance shif:

verkers was formed a the ECS under the control of. Maintenance Foreman B. (Int. 187). A second Repair Par:y, composed primarily of daylight instrument and con:rol personnel, was formed in the Unit 2 control room under the direction of the Superintenden: of Maintenance and the Unit 2 Supervisor of Maintenance. The Superintenden: of Maintenance and Unit 2 Supervisor of Maintenance were aware tha:

the assigned location for ei:her of the= during an emergency was

he ECS where they would ac: as the Repair Party leader.

F.ovev e r,

to ensure pro =p: availabili:y of their expertise, and since a Repair Party was already formed at the ECS under the direction of a main-tenance foreman, they decided to remain in the control room (In:.

120). This decision was reinforced by :he S:a: ion Manager.

On assu=ing the position of Eme:gency Director, he announced :r.a: :he Superin:enden: cf Maintenance would be the one in :he con:rol ree ::

be in charge of emergency repair functions (Ref. 72, In:. 120). t l

'g e.

Some time later, the superintenden: of Main:enance direc:ed the Repair Party a: the ECS to move to the Unit 2 control room.

By 0800, all Repair Party personnel were assembled in the Unit 2 control room, separa:ed from the ICS."

This organize:ional' alignment placed the control of the Repair Party Teams with the senior maintenance personnel who, by their location and proximity to up-to-date operational and radiological informati~on, could best control and coordinate their activities.

Bad the organ-i:stional changes prior to the accident not taken place, the response would have been the same.

,D.

Although the position of Chemical Supervisor had been vacant, this posi: ion was being filled in each unit by a Senior Chemistry Foreaan.

Iach of these individuals were fully qualified as required by ANSI /

ANS 3.1-1978 and in fact exceeded these minimu= requirements. Al-though not specifically designated as supervisors, having tvc quali-i fied individuals assigned, one to each unit, provided improved super-visien and control over ea:h uni:'s che=istry.progra=s.

"here is no eviden:e tha: the lack of a spe:ific individual designa:ed as Che=istry Supervisor resulted in inappropria:e ac: ions.

I l

The organiza:ional changes identified above were discussed with the NRC at the time of i=ple=en:ation on March 5,1979.

On the same day the office of Inspec: ion and Inforcement was also notified in writing of :he changes to be made. It was agreed verbally that a Te:hnical Specification change would be sub=itted. These changes had been pre-

'}ared bu: no: ye: submi:ted a: the :ime of :he acciden:.

It has been CPU's experience in the past tha: organizational changes to Te:hni al Specifications =ay take as long as 6 months fro = the ti=e of initial discussion vi:5 the NRC to final inple=en:a: ion. A recen:

conte = plated organiza:ional change a: Oyster Creek took 4 =enths from the L.~.,~..

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s tLae of submit:a1 until final approval by the NRC.

The final changes were essen:ially the same as these discussed initially with the NRC.

J The Company believes that it is not in the best interests of public health and safety to delay changes that will streng: hen the organi:a-tion. Mechanisms similar to those in place for changes to the QA and security plans need to be developed for haplementing changes in the organiza:lonal structure.

Corree:ive Ac: ion:

The organiza:ional s:ructure for both Units i and 2 has been re-documen:ed with the NRC and we are attempting to provide for some flexibility to necessary minor organizational changes within these specifica: ions.

rea:

a The Uni: 2 Technical Specifica: ions are under final review and should be issued in :he near future by the NRC.

The Uni: 1 organizatien has been re-defined in :he TMI-1 Restar: Report Amendmen 6, sub=itted November 25, -

4 1979. This organiza: ion will be incorpora:ed in the Technical Spec'ifica: ions prior to restar:.

Major changes :o address the organiza:icnal deficiencies no:ed :hrough

he many post-acciden: inves:igations have been discussed with the NRC.

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i/T and i=plemen:ed with their agreement.

j 3

-v The Energency Plan has also been modified to improve the emergency organ-ita: ion.

The revised plan has been documented in the TMI-I Res:ar: Repor:

L and is currently under review by the NRC. Drills will be condue:ed prior to restar: of Uni: 1 to :es: :he effectiveness of the revised emergency plan.

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,1 Statement of Annarent Noncomoliance:

8 Technical Specifica: ion 6.4'" Training," requires that a retraining and replacemen: training program for the unit staff be maintained that meets or exceeds.the requiremen:s and recommendations of Section 5.5 of ANSI N18.1-1971.

Contrary to the above, as of March 28, 1979, a retraining program meeting

. or exceeding ANSI N18.1:1971 recommendations had not been maintained for members of the radiation protection and chemistry staff in that only 2 of the 10 copics recommended were included in the program.

N Discussion:

Metropolitan Edison believes that the retraining program established for the radiation pro:ection and chemistry staff met the requirements of I

Technical Specification 6.4 and Sectica 5.5 of ANSI N18.1-1971. Me:ro-politan Edison therefore disagrees that this item is a nonec=pliance.

Technical Specification 6.4 co==its Metropoli:an Edison to a retraining program for,the unit staff which "=eets or exceeds the requiremen:s and recommenda: ions of See: ion 5.5 of ' ANSI N18.1-1971 dnd Appendix 'A' of 10 C7R part 55."

(Ihe la::e: regula: ion applies only :o opera:c s).

See: ion 5.5 of ANSI N18.1-1971 requires a training pEsgra= "which =sintains the proficiency of the onera:ine creani a: ion......" See:ics 5.5.1 of the l

ANSI s:andard s:ates:

"A retraining program should include:

1.

Plant startup and shutdown procedures; 2.

Normal plant operating conditions and procedures; 3.

Operational limita: ions, precautions, and se: points; 4.

Emergency plans and securit7 procedures; 5.

Abnor=al opera:ing procedures; 6.

Emergency shutdown systems; 7.

Changes in equipment and operating procedures;

,7, 8.

General safety, first aid, and radiation safe:y; 9.

Alarms and instrumenta: ion signals; and 10.

Operation of sele::ed auxiliary syste=s i=por:an: :o overall plant safety."

The charged violation assumes tha: all =e=bers of the operating organi-za: ion mus: have retraining in each of these ten areas.

There is no A.

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basis in the language of Section 5.5 or elsewhere to our knowledge for this assu=p: Ion. The retraining progra= described in Section 5.5.1 is for the entire " operating organiza: ion," no: for each job category. Mahy of th2se areas are relevan: to plant operators but not to radia: ion /che=istry this understanding.

The Station procedures clearly reflec:

tachnicians.

52s Health Physics Procedure 1690, described in NURIO-0600 at p. II-I-16.

Thus, the re: raining program for radiation / chemistry technicians did no:

include ite=s 1-3, 5-7 and 9-10.

The interpretation of Section 5.5.1 implied by the charged viola: ion with the general training provisions of would also be incensisten:

tha: the training LNSI N18.1-1971. Thus, see: ion 5.1 provides in par:

progra= "shall be for=ulated :o provide the required ::sining based (e=phasis en individual e=picyee experience and in: ended esi:ien."

areas is noi appropria:e for cdded) If re: raining in particular subjec:

se:: ion the "in: ended posi: ion", then it would be illogical to in:e pre:

5.5.1 :o require such training.

he : raining progra= for radia: Ion /che=is: y It should also be no:ed :ha:

vi:h Me:-Id's

echnicians as described in the TSAR (13.2.1.5) is consisten:

50-289/7S-09 and Turcher= ore, I&I e==bined Inspection Report posit ion.

reviewed Me:-Ed's general e=ployee crain-50-320/78-18 (dazed May 25, 1978) ing and craf: and :e hnician training.

(The la::er was specifically ad-dressed to Metropolitan Idison's "progra= for training and re: raining of to ei:her craf; and technician personnel who are available for assign =en:

I r

No 1:ees of non-::=plian:e were identified.

uni:.")

Corre::ive Ac:fon:

believe :ha: i:s retraining preg::n Although Me:repoli:an Idison does no:

for radia: ion pro:cezion and che=is: y staf f was in non-c:=plianze vi:5 4

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Section 5.5 of ANSI NI8.1-1971, Metropolitan Edison recognizes the need for more and better training of these and other components of the operating organization.

The upgraded training and retraining program is especially necessary in light of the particular level of challenge associated with Unit 2.

A improved and expanded training program to address these concerns is under development and will be in place prior to the restart of Unit 1.

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statement of Ansaren: Noncomoliance:

Technical Specifica: ion 3/4.4.6, " Reactor Coolant Sys:em Leakage," requires in Section 3.4.6.2, tha: Rea::or Coolant System (RCS) leakage be limited to I gallon per minute (CPM) of " Unidentified Leakage," and tha: unless rates above this limit are reduced to within the limi: eithin four hours, the plan: must be placed in " Hot Standby" in the next six hours and in

" Cold Shu:down" in the next thirty hours.

Contrary to the above, krom March 22 until March 28, 1979, RCS "Unidenti-fied Leakage" remained above 1 gym, and the plan: vas no: placed in " Cold Shutdown."

s Discussion:

Due to an error in the calculational procedure, co=putations of unidentified reactor coolan: system leakage for the March 22-28, 1979, period mistakenly produced values less than 1 gp=.

As a result, Te:hnical Specification 3.4.6.2 was viola:ed.

Surveillan:e Procedure 2301-3D1, "R25 Inventory", calculates leak rates in terms of gpc at rea :or coolant system operating conditions.

TCN 2-79-070, issued on March 16, 19~9, made a ec:re:: ion :o the calcula:ional pro:edure by correcting changes gn the reae:or coolan: drain tank inv'en:ory to rea::or coolan: sys:em operating condi: ions.

Ecuever, the Temporary Change No: Ice failed to recognize that a similar corree:lon for additions,

o the askeup rank was also needed.

The resul: vas to remove an off-setting error.

By corree:ing only one of the two errors, the leak rate calcula: ion become ina ura:e.

Correction Aerion:

The-procedure has been thoroughly reviewed and changes have been prepared.

The proposed procedure change was provided to the NRC (Site Office) on l

l Augus: 24, 1979. Upon receip: of co=ments, the procedure change vill be e

completed.

A simila: review of :he Uni: 1 pro:edure has been condu::ed l

/

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To enable future reviews of the survey da:a to be fully understood, an explana:ory documen: vill be developed tha: vill provide the shorthand method utilized for the 500 offsite radia: ion measuremen: taken immedi-ately following the TMI-2 acciden:. This documen: vill be provided as part of the per=anen: record requirement of 10CFR20.401 for the accident.

To improve the quality and clarity of future offsi:e survey records, for=s will be developed and included in ea:h emergency kit and a: otjhe-locations as appropriate. These forms vill include field survey team iden:ifiers, iden:ifica: ion of instruments used, person condue:ing survey, lo: : ion, reading time, level of radiation, type of radia: ion, and a -

remarks cole =n to note ite=s such as directionality, shielding or'c:her per:enen: fa::s.

Ihese forms will be required to be filled out by the survey team at the time of each measuremen:, and vill be collected and re:ained for historical purposes as required.

Infobmation fro = th'ese surveys radioed to a cen::a1 lo:a: ion vill be recorded in an abbrevia:ed fashion noting the survey :ea= iden:ifier, time of measure =en:, lo:a:Lon, level and :ype of radia:lon, and remarks.

Training vill emphasi:e the need to establish survey prae:i:es which will provide high quali:y measurements to aid in the response to radiological emergencies.

It will also emphasize that producing clear, comple:e, unders:andable records of those surveys is essential in order to allev historical evaluations of exposures to people not provided with individual dos [Eetry.

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10.3 S:stement of Annarent Noncoenlience:

10 CFR 20.401, " Records of surveys, radiation monitoring, and disposal,"

requires in Section (a) that each licensee maintain records showing the radia: ion exposure for all individuals for whom personnel monitoring is required on a Form NRC-5 or equivalent and in section (b) requires that each licensee main:ain records of the results of surveys required by 10 CFR 20.201(b).

Contrary to the above:

3.

The records of the radiation exposure for at least 5 individuals exposed during the period March 1 to 31, 1979 had not been recorded or maintained on a form NRC-5 or equivalent as of July 5,1979.

Further-more, as of July 5,1979 the assessmen: of their dosus had no: been completed.

Discussion:

Herropolitan Edison agrees tha: a recording error has been made in :ha:

of the more than 1000 individuals for whom personnel moni:oring was re-quired during March,1979, the records for 5 individuals were not properly main:ained.

This recording error is a direct resul: of :he heavy work load *placed on a li=ited staff under emergency conditions and is no: be-4 lieved to represent a shortcoming in the =aintaining of radiation ex-posure records during nor=al opera:ien.

k'i:hin a few days of the accident, the number of individuals for vnich radiation exposure records was required nearly doubled from approximately 600 :o approximately 1200.

A: the same ti=e, experienced people con:ri-bu:ing to the maintenance of radiation exposure records during normal operation were called upon to perform other fun:tions during :he emergency response to the acciden:. Less experienced people were :herefore u:lliced to maintain a large volune of nev radia: ion exposure records.

As a resul: a few records were not properly maintained.

No viola: ion of exposure limi:s or increases in occupa:ional exposure resui:ed from this error in record keeping.

9 _ _ _..__ -_

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Correctivt Actien:

In order to correc: for the errc in records maintenance for :he 5 in-dividuals iden:ified above, and to assure that no o:her errors exis: in the radia: ion exposure records of all persons for whem personnel monitor-ing has been required from March 28 to June 30, 1979, a review of exposure records will be completed by January,1980.

This review will involve examining all radia: ion exposure records during the time period of the accident and iden:ifying those records for which For those records any sort of abnonnality or incompleteness exists.

showing abnbraalities or incompleteness, a re-evaluation will be completed using telephone and personal interviews.

Re-evaluations will also te in an performed for all individuals identified as having been presen:

area wi:h abnornal condi: ions, such as the auxiliary building, during :he period of Merch 28 to June 30, 1979.

t I: Is not expec:ed that this program can be co= pitted before the end cf January 1980 because a: leas: 2000 exposure records will need to be evalua:ed, requiring the full time effort of six pertennel.

This progra=

l I

is documented in a Metropolitan Idison let:e to the NRC dated Oc:ober l

29, 1979.

In addition to the above records cor:ection program, to assure proper records maintenance in the course of future emergencies, the revised site Emergency ?lan specifically charres the Emergency Director with :he responsibility for assuring that accura:e exposure records are maintained.

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This will require appropriate training for any persons assigned temporary responsibilities for re:ords maintenance and advance planning to assure the capabill:y :o handle :he expected increase in records processing in the even: of a radiological emergency-

~90-

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. A "II, Statement of Ansarent Noncompliance:

10 CFR 50, Appendix B, Criterion X, " Inspection,"' requires that a program for inspection of ac:ivities affecting quality shall be established and executed to verify conformance with documented instructions, procedures and drawings for accomplishing the activity.

Three Mile Island Nuclear Station - Unit 2. Final Safety Analysis Report, Chapter 17.2.15,Section I, requires that the inspection program include random observation of operations and functional testing by individuals independent of the activity being performed.

Procedure GP 4014. "QQA Surveillance Program," Revision 0, requires independent observation of activities affecting quality to verify confor=-

ance with established requiremen:s utilizing both inspection and auditing techniques...for compliance with written procedures and the Technical Specifications.

Contrary to the above, as of March 28, 1979, the normal opera: ions sur-veillanen testing activities had not been made subject to random and/or routine inspections by independent methods.

Discussion:

Metropolitan Edison believes that there is no noncompliance in connec: ion vi:h normal opera: ions surveillance testing.

In accordance with C:401,

Rev. O, the Metropolitan Edison QC Department scheduled and perfor=ed inspections of TMI-2 operations Technical Specification surveillance testing as documen:ed by the following QC Surveillance Reports prio-to March 28, 1979.

Date Surv. Res. No.

Surv. Proc. No.

Title 9/78 78-175 2303-M15A/3 Control Roo Emergency Ven:llation System 9/78 78-181 2322-Al k'aste Gas and Uni: Ven: Dis-charge Functional Test 10/78 78-191 2303-M14C E.F. Sys. Valve Lineup Verification and Opera-bility Tes:; and Turbine Driven E. Feedpump Opera-

~~ '

bility Test 11/78 78-196 2334-Q1 Diesel Fuel Testing 11/78 78-205 2303-M34 Safety Inj. Manual Actua-tion and Act. Logic Func.

Tes:

11/78 78-219 2303-M15 MU Pu=p & Valve Functional Test

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Date Sury. Ren. No.

Surv. Pro =. No.

Title 12/78 78-235 e

2301-MS Con:ainment Integri:y veri-fication 1/79 79-04 2612-R4 LIQ Radiation Monitor Cali-bration 2/79 79-12 2302-R23 FW Line Rupture Auto Detec-tion Calibration' Technical-Specification surveillance procedures were selected for per-formance inspe= tion a: random and witnessed when performed to verify confor=ance with documen:ed procedures.

This process was in accordance with 10CFR30, Appendix B, criterion I.

Corrective Action:

Although this ite= does not involve ncnce=pliance with reg 4 ations, 1

Technical Specifica: ions or procedures, Me:ropolitan Edisen is planning to expsnd i:s progra= for inspe::lon of surveillance testing activities.

Ini:ial s:eps to expand this program had begun prior to March 03, Iri9.

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Respect fully sub=it ted,

/ signed / R. C. Arnold R. C. Arneld Senior Vice Presiden:

Metropoli:an Edison C: pany Dece=ber 5, 1979 g

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UNITED STATES OT AMERICA NUCLEAR REOULATORY COMMISSION In the Matter of

)

METROPOLITAN EDISON CONTANT

)

Docket No. 50-320

)

(Three Mile Island Nuclear

)

Power S:a:lon, Unit 2)

)

l METROPOLITAN EDISON COMPANY'S ANS*E.R TO NOTICE OF PROPOSED IMPOSITION OF CIVIL PENALTIES Pursuant to IOCFR2.205(b) and the Notice of Proposed Imposition of Civil Penalties of October 25, 1979, Metropolitan Edison company provides the follow-ing written answer.

The answer to each apparen: noncompliance incorporates by reference the statemen: in reply to tha: item set forth in Me:ropoli:an

' Edison Ccmpany's 5:atement in Reply to Notice of Violation (her' after e

"Sca emen:").

Annarent Nonce =eliance 1: Metropoli:an Edison believes tha: this i:em,is no: a nonce =pliance.

See State =en:, pp.

1 4

Metropolitan Ed/ son believes that this Ascaren: Neneo=oliance 2A:

item is a noncompliance. However, the S:stement, pp.

16, se:s forth what Me:ropolitan Edison believes are extenuating circu=-

s:ances and requests remission or mitiga: ion of the proposed penalty.

j Asmaren: Non===mliance 23:

Me:ropolitan Edison believes tha: this item is a noncompliance.

However, the Statement, pp.

19, se:s forth wha: Metropoli:an Edison believes are ex:enuating circum-s:ances and requests re=ission or mitigation of the proposed penalty.

Aeoaren: Noncomsliance 2C: Metropoli:an Edison believes tha: this i:em is not a noncomplian e.

See 5:acement, pp.

21 Anoarent Noncomsliance 2D: Metropolitan Edison believes that this item is a noncompliance.

However, the Statement, pp.

23, sets forth what Metropolitan Edison believes are extenuating circu=-

stances and requests remission or mitigation of the proposed penalty.

Aonarent None==ollance 2E: Metropoli:an Edison believes tha: this i:e= is a noncompitance.

However, the 5:a:emen:, pp.

25, se:s forth what Metropolitan Edison believes are ex:enua:Ing cir:u=-

stances and reques:s remission or mitiga: Ion cf the proposed penalty.

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Anoaren: Noncomoliance 2T: Metropolitan Edison believes that this item is a noncomplian=e.

However, the Statement, pp.

28, sets forth what Metropolitan Edison believes are extenua:ing circum-stances and, requests remission or mitiga: ion of the p oposed penalty.

Apparent Noncomoliance 2C: Metropolitan Edison believes that this item is a non ompliance.

However, the Statement, pp.

28, se'ts forth what Metropolitan Edison believes are extenuating circum-s:ances and requests remission or mitiga: ion of the proposed penalty.

Aonaren: Noncomoliance 2H: Metropolitan Edison Company believes that this item is a noncompliance.

Annarent Noneemoliance 3: Metropolitan Edison believes that this item is not a noncompliance.

See Statement, pp.

31 Ansarent Noncemoliance 4A: Metropolitan Edison believes th,at this i:em is no: a noncomplian:e.

See S:a:emen:, pp.

34 Assaren: Noncemoliance 4.3.1:

Metropoli:an Edison believes tha:

this item is a no: nonce =pliance.

See S:stement, pp.

42 Anearent Noneemoliance 4.3.2:

Metropolitan Edison believes tha: this i:em is not a noncompliance.

See S:a:emen:,'pp.

52 Accaren: Non:o=cliance 4.C: Metropolitan Edison C:=pany believes

nac :his item is a noncompliance.

Annarent Nonce =eliance 4.D: Metropoli:an Edison believes that this i:ec is no: a noncomplian e.

See 5:stemen:, pp.

58 Annaren Noncomoliance 4.E: Metropoli:an Edison believes that this I

i:en is no: a nonccmpliance.

See Statement, pp.

60 Aeoarent Nonco=oliance 4.T: Metropolitan Edison believes that this i

item is a noncompliance.

Aenaren Noncomellance 4.C: Metropoli:an Edison believes tha: this item is a noncompliance.

Annarent Noncomoliance 5: Metropolitan Edison believes that this item is a noncompliance.

However, the Statemen:, pp.

71, sets forth wha: Metropoli:an Edison believes are ex:enua:Ing circu=-

... stances and reques:s remission or mi: Iga: ion of the proposed penalty.

Aenaren: Noncomeliance 6: Metropoli:an Edison believes tha: this i:e= is a noncomplian:e.

However, the Sta:emen:, pp.

74, sets forth wha: Metropoli:an Edison believes are ex:enua:Ing circu=-

s:ances and requests remission or mi: Iga:1:n of :he proposed penalty.

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this Me:ropolitan Edison believes that However, the Statement, pp.

__77_,

sets Noncomoliance 1:

.r extenuating circum-Annaren:

i:en is a noncompliance.forth what Me:ropolitan Edison believes areit stances and requests remission or m i

Metropolitan Edi, son believes that th s penalty.

Asoarent Noncompliance JB:

See Statemen:, pp.,81__,.

a item is not a noncompliance.' Metropolitan Edison Company believes Ansarent Noncomoliance 9:this item is a noncomp i

tha Asmarent Noncomoliance 10.A:

See Statement, pp.,j[6_,.

Metropolitan Edison believes that this a noncompliance.

i:em is not ts However, the Statemen:, pp.,jB9_,,. sere exten Noneo=eliance 10.3:

Annaren:

i:es is a nonco=plia' ace.for:h what Me:ropolitan Edison believ stances and reques:s remission or m ihis penalty.

Me:ropolitan Edison believes tha:

Nonco=311ence 11; See Sta e=en:, pp. 1 Accaren:

a noncompliance.

i:en is no:

litan Edison Company resrectfully d Enforcement appropriately re-Based upon the above answers, Me ropoof civil pena proposed.

the Of fice of Inspection an requests :ha:

duced the cumulative amoun:

Respectfully yours,

/ signed / R. C. Arnold R. C. Arnold Senior Vice Presiden:

Metropolitan Edison 5, 1979 December Date:

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ML20024B243

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Dear Mr. 5:

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