ML20049J445
| ML20049J445 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/25/1982 |
| From: | Bores R, Chestnut S, Crocker H, Donaldson D, James M. Levine, Matthew Smith, Wojnas E Battelle Memorial Institute, NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE), Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20049J443 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-289-81-20, NUDOCS 8203180210 | |
| Download: ML20049J445 (45) | |
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U.S. NUCLEAR REGULATORY COMMISSION Region I Report No.
50-289/81-20 Docket No.
50-289 License No. DPR-50 Priority Category C
Licensee:
Metropolitan Edison Company (Met-Ed)
P. O. Box 480 Middletown, Pennsylvania 17057 Facility Name: Three Mlle Island Nuclear Station, Unit-1 Inspection at: Middletown, Pennsylvania Inspection conducted: Jul 13-24 1981 Inspectors 8
M OJ-.
A Zd3 [<f2 Edward J. Wojnas, Radiatior/ Specialist,
'date sisned '
NRC Appraisal Team L der
/
Jh% 2PR Dale E. Dorialdson, Radia)/ ion Specialist
'date s1@ned YEYW Stephen H.T hesnut, EPLB, $RC
/ date signed W
7 E /k Marvin L. Shiith, Battelle Lpratories date s4gned dWWN3 52/sskz Joseph R. Eevine, Meteorol ist, NRR, NRC' dati efigned
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Reviewed by:
4 c25 M
D'r. Robert J.
es, Chief, Independent dats sign'ed Mea
.ments d Environmental Protection ect-on Approved by:
A dd
/
h HilbertW.Crocker,Chpf,'Emergencp date sicaed Preparedness Section Region I Form 12 (Rev. April 77) 8203180210 820305 PDR ADOCK 05000289 G
TABLE OF CONTENT 3 Page a
SUMMARY
1 1.0 ADMINISTRATION OF EMERGENCY PREPAREDNESS 2
2.0 EMERGENCY ORGANIZATION 2
2.1 Onsite Organization 2
2.2 Augmentation Organization 3
3.0 EMERGENCY PLAN TRAINING / RETRAINING 3
3.1 Program Establishment 3
3.2 Program Implementation 4
4.0 EMERGENCY FACILITIES AND EQUIPMENT 5
4.1 Emergency Facilities 5
4.1.1 Assessment Facilities 5
4.1.1.1 Control Room 5
4.1.1.2 Technical Support Center (TSC) 5 4.1.1.3 Operations Support Center (OSC) 6 4.1.1.4 Emergency Operations Facility (EOF) 6 l
4.1.1.5 Post-accident Coolant Sampling and Analysis 7
4.1.1.6 Post-accident Containment Air Sampling and Analysis 8 4.1.1.7 Post-accident Gaseous and Particulate Effluent Sampling and Analysis 9
4.1.1.8 Post-accident Liquid Effluent Sampling and Analysis 9 l
4.1.1.9 Offsite Laboratory Facilities 10 l
4.1.2 Protective Facilities 11 l
4.1.2.1 Assembly / Reassembly Areas 11 4.1.2.2 Medical Treatment Facilities 11 1
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TABLE OF CONTENTS 2
.Pagg 4.1.2.3 Decontamination Facilities 12 4.1.3 Expanded Support Facilities 12 4.1.4 News Center 13 4.2 Emergency Equipment 13 4.2.1 Assessment Equipment 13 4.2.1.1 Emergency Kits and Emergency Survey Instrumentation 13 4.2.1.2 Area and Process Radiation Monitors 14 4.2.1.3 Ncn-radiation Process Monitors 15 4.2.1.4 Meteorological Instrumentation 16 4.2.2 Protective Equipment 17 4.2.2.1 Respiratory Protection 17 4.2.2.2 Protective Clothing 17 4.2.3 Emergency Communications Equipment 17 4.2.4 Damage Control / Corrective Action Equipment 18 4.2.5 Reserve Emergency Supplies and Equipment 18 4.2.6 Transportation 18 5.0 PROCEDURES 19 5.1 General Content and Format 19 l
5.2 Emergency, Alarm, and Abnormal Occurrence Procedures 19 5.3 Implementing Instructions 19 5.4 Implementing Procedures 20 5.4.1 Notifications 20 5.4.2 Assessment Actions 20 5.4.2.1 Offsite Radiological Surveys 22
TABLE OF CONTENTS 3
Pag _e 5.4.2.2 Onsite (out-of-plant) Radiological Surveys 23 5.4.2.3 I,n-plant Radiological Surveys 24 5.4.2.4 Post-accident Primary Coolant Sampling 25 5.4.2.5 Post-accident Primary Coolant Analysis 25 5.4.2.6 Post-accident Containment Air Sampling 26 5.4.2.7 Post-accident Containment Air Sample Analysis 27 5.4.2.8 Post-accident Gaseous and Particulate Effluent Sampling 27 5.4.2.9 Post-accident Gaseous and Particulate Effluent Sample Analysis 28 5.4.2.10 Liquid Effluent Sampling 28 5.4.2.11 Liquid Effluent Sample Analysis 29 5.4.2.12 Radiological Environmental Monitoring Program (REMP) 29 5.4.3 Protective Actions 30 5.4.3.1 Radiation Protection During Emargencies 30 5.4.3.2 Evacuation of Owner Controlled Areas 31 5.4.3.3 Personnel Accountability 32 5.4.3.4 Personnel Monitoring and Decontamination 32 5.4.3.5 Onsite First Aid / Search and Rescue 32 5.4.4 Security During Emergencies 33 5.4.5 Repair / Corrective Actions 33 5.4.6 Recovery 33 5.4.7 Public Information 34 5.5 Supplementary Procedures 34 5.5.1 Inventory, Operational Check and Calibration of Emergency Facilities and Equipment 34 e
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TABLE OF CONTENTS 4
f.agg 5.5.2 Drills and Exercises 35 5.5.3 Review, Revision, and Distribution 35 5.5.4 Audit 36 6.0 COORDINATION WITH OFFSITE GROUPS 36 6.1 Offsite Agencies 36 6.2 General Public 37 6.3 News Media 37 7.0 DRILLS, EXERCISES AND WALK-THROUGHS 37 7.1 Program Implementation 37 7.2 Walk-through Observation 38 8.0 LICENSEE ACTION ON PREVIOUSLY IDENTIFIED ITEMS OF NONCOMPLIANCE 39 l
SUMMARY
The appraisal of the state of onsite emergency preparedness at the Three Mile Island - Unit 1 involved seven general areas:
Administration of the Emergency Preparedness Program; Emergency Organization; Emergency Training; Emergency Facilities and Equipment; Procedures which Implement the Emergency Plan; Coordination with Offsite Agencies; and Walk-throughs of Emergency Duties.
The development of the TMI - Unit 1 Emergency Preparedness Prog;1m was performed by individuals at both the site and corporate office. The results of the appraisal fndicated that the existing program contained some deficient areas:
Administration of the Emergency Preparedness Program and emergency organization was found to be adequate.
The emergency preparedness training program appeared to be generally adeq'; ate, however, one complete iteration of training had not been performed at the time of the appraisal.
Emergency facilities and equipment were for the most part satisfactory, actions in progress to complete modifications to the reactor building evacuation alarm, etc., to the post-accident containment monitoring system and installation of the prompt alerting system need be completed.
Procedures which implement the emergency plan were generally adequate, with the exception of several procedures for collecting, handling and analyzing post-accident samples.
Observation and questioning of selected individuals during walk-throughs of their assigned tasks and functions indicated that the individuals were aware of their assignments and their part in the emergency organization and were able to perform effectively.
The auditors concluded that the licensee appeared to b capable of responding to, managing and mitigating an accident and that an adequate state of emergency l
preparedness exists at Three Mile Island - Unit 1.
1
1.0 ADMINISTRATION OF EMERGENCY PREPAREDNESS Section 4.8 of the TMI Unit-1 Emergency Plan described the Itcensee's organization and assignment of responsibility for the emergency prepared-ness effort.
The Vice President, Nuclear Assurance was assigned overall 1
responsibility for emergency preparedness at the TMI Nuclear Station.
In l
addition, the Itcensee had designated a Manager-Emergency Preparedness and l
a Supervisor-Emergency Preparedness to fulfill the emergency preparedness activities.
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The auditors reviewed job descriptions for the positions in the emergency preparedness organization and noted that they containea selection criteria.
A review of the curricula vital for the personnel filling these positions indicated that they appeared to meet most of the established criteria. The auditors noted that during a July, 1981 audit by the licensee of emergency preparedness, several areas were identified in which improvements were desirable for selection and qualification criteria.
Individuals have been assigned the responsibility for correcting identified deficiencies.
Discussions with licensee personnel in the emergency preparedness area indicated that they possessed a level of understanding and experience adequate to perform their assigned tasks. These discussions, as well as the findings in other areas of the appraisal indicated that coordination between the various elements of the licensee's organization with respect to emergency preparedness was adequate.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
2.0 EMERGENCY ORGANIZATION i
2.1 Onsite Organization The auditors reviewed Section 4.5.1.3 and Table 8 of the THI Unit-1 Emergency Plan, the Emergency Plan Implementing Document, and held discussions with licensee personnel to evaluate the adequacy of the definition of the onsite emergency organization and the assignment of emergency duties and responsibilities.
This evaluation was preliminary to determining the adequacy of the licensee's emergency preparedness training program and the procedures developed to implement the Emergency Plan.
The auditors noted that the licensee's emergency organization had been reviewed during a recent NRC inspection conducted on May 4-7,1981(Ir Inspection Report No. 50-290/81-12). The findings of this report indicated that the organizational structure and assignment of respon-sibilities were consistent with existing NRC regulations and guidance.
Review by the auditors indicated that the status of this item had not changed.
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3 Based on the above findings, this portion of the licensee's program 1
appears to be acceptable.
2.2 Augmentation Organization The auditors performed a similar review of Sections 4.5.1.4, 4.5.1.5, 4.2.4.3, and Table 8 of the Emergency Plan to evaluate the adequacy of the definition of the licensee's augmentation of the onsite emergency organization.
The auditors noted that, as in the case of the onsite organization, j
the definition of the augmentation organization had been reviewed during the previously referenced NRC inspection. The findings in this 4
report indicated that the organizational structure and assignment of responsibilities were consistent with existing NRC regulations and t
guidance.
Review by the auditors indicated that the status of this i
area had not changed.
Based on the above findings this portion of the licensee's program appears to be acceptable.
3.0 EMERGENCY PLAN TRAINING / RETRAINING j
I 3.1 Program Establishment Section 4.8.1.2 of the TMI Unit-1 Emergency Plan described the training program planned for members of the licensee's emergency organization, as well as offsite support groups or agcacies which might interface with the licensee in the event of an emergency at TMI Unit-1. The training program called for initici training in two phases:
A.
Introductory Emergency Preparedness Tra'ining - Eight and four-hour seminars / lectures given to essential and non-essential i
personnel, respectively, on the Emergency Plan, implementing l
procedures, classification, communications, etc.
B.
Specialized Emergency Training - Specific functional training for members or groups either in the orisite or offsite emergency organization.
Specialized retraining is to be performed every 12 + 3 months.
The auditors also reviewed the details of the training program con-tained in Administrative Procedure AP-1052, " Emergency Planning Training,"
Section 6.5 of the Training Department Manual, several emergency training lesson plans, as well as tests which are given to emergency response personnel as a part of the training program.
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The Supervisor-Emergency Preparedness was responsible for developing the training program. The site training department was responsible for conducting the emergency training and had assigned a coordinator responsible for tracking, documenting and reporting the assigned emergency training.
The auditors reviewed training schedules and matrices and were able to determine that a system was in place for documenting attendance at emergency plan training sessions. A computer printout listed the emergency training received by both essential and non-essential site personnel.
Detailed student performance objectives were included in lesson plans.
Tests on the performance objectives were attached to each lesson plan.
Although walk-throughs and practical demonstrations had been conducteo during some of the emergency plan training, it was not required by the I
licensee's training program or procedures that performance of the emergency tasks be demonstrated. This item was also identified by the licensee in its own emergency planning audit completed on July 8, 1981, and improvement in this area is planned by the licensee.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
3.2 Program Implementation The auditor reviewed training records and found that although the training program was being implemented in accordance with the TMI Unit-1 Emergency Plan and Administrative Procedure AP-1052, the initial specialized training had not yet been completed. The introductory training for essential and non-essential personnel, as well as special-i ized training for Emergency Directors and Emergency Support Directors had been completed.
The remainder of the specialized training had been scheduled to be completed prior to November 1981, consistent with the cyclic training schedules for shift personnel.
The auditors conducted several walk-throughs and interviews with senior reactor operators, reactor operators, and shift radiological controls personnel assigned to three different shifts (See Section 7.2 of this report). During these walk-throughs the operators displayed an acceptable knowledge and proficiency of their respective emergency tasks and Emergency Plan Implementing Procedures (EPIPs). Discussions with these personnel confirmed that, while the established training program had not yet been completed, several drills and walk-throughs were conducted during April and June 1981 to provide initial indoctri-nation for each shift.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
1 Completion of introductory and specialized emergency plan training for all essential personnel according to the specified training schedule.
(This item was previously identified in Inspection Report 50-289/80-22 as finding 289/80-22-64). (289/81-20-01) l 4.0 EMERGENCY FACILITIES AND EQUIPMENT 4.1 Emergency Facilities i
4.1.1 Assessment Facilities 4.1.1.1 Control Room i
The TMI Unit-1 Control F.oom and the attached Shift Super-visor's Office were designated as the Emergency Control Center (ECC). The auditors toured the area and interviewed several Shift Supervisors during the course of the appraisal to verify the adequacy of the area to function as intended.
i The auditors noted that current copies of the Emergency Plan 1
and Emergency Plan Implementing Procedures were located in the ECC. Status boards, maps, and decisional aids were prepared and in place. A mini-computer programmed to perform dose projections based on monitor readings was also available.
Communications links to offsite groups and authorities including the NRC, were installed and operable. Real-time meteorological data were displayed in the Control Room.
Communications could be continuously maintained with the Environmental Assessment Command Center (EACC) which provides dose projections based on actual meteorology using the MIDAS system.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.1.2 Technical Support Center (TSC)
The TSC was located directly below the Control Room in the Remote Shutdown Room wi'.h equivalent ventilation and shielding as the Control Room.
The equipment, prints and reference material, communication links and decisional aids described in the Emergency Plan were in place with the exception of the CRT with which to display plant data from the plant computers.
Some operational I
data were available through the Remote Shutdown Panel.
l Communications with Parsippany Technical Functions Center, Control Room and offsite authorities were in place.
The auditors discussed with the licensee the adequacy of the number of commercial lines (in addition to the direct lines) l
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which might be required to fulfill all the required functions of the TSC during an emergency.
Based on the above findings, this portion of the Itcensee's program appears to be acceptable, but the following matter should be considered for improvement.
Reevaluation of the number of commercial telephone lines available in the TSC to fully support the functions of the response organizations, 1-1uding the NRC, duringanemergency.(289/81-20-u.)
4.1.1.3 Operations Support Center (OSC)
The Operations Support Center (OSC) was located at the Health Physics Access Point directly below the Control Room and TSC. The communications systems described in Sections 4.7.1.3 and 4.7.5 of the TMI Unit-1 Emergency Plan included portable radios, telephone and the plant paging system.
Personnel reporting to the OSC had available self-contained breathing devices, survey instruments, and other protective equipment.
Those personnel reporting to the OSC were desig-nated as essential personnel and may receive assignments from the OSC Coordinator.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
i 4.1.1.4 Emergency Operations Facility (EOF)
The EOF was located at the licensee's Observation Center approximately 0.7 mile from the TMI Unit-1 containment building. The EOF contained dedicated communications links with the Control Room, TSC, EACC, Parsippany Technical Functions Center, Babcock and Wilcox, and Pennsylvania Bureau of Radiation Protection (BRP). Additionally, the EOF contained Health Physics Network (HPN) and Emergency Notiff-cation System (ENS) lines to the NRC.
Adequate supplies of protective clothing, respiratory equip-ment, status boards and maps were in place.
Plant data were transmitted to the EOF on dedicated lines as well as a CRT displaying information from the plant computer.
Meteorological data were not displayed at the EOF, but were available through the direct lines to the Environmental i
Assessment Command Center (EACC). Dose projection calculations
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were to be performed in the Control Room or the Environmental Assessment Command Center (EACC) and displayed and integrated into the overall assessment scheme at the EOF. After the
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7 EACC is fully staffed, the offsite environmental monitoring teams would be directed by the EACC rather than the EOF or ECC.
The staffing of the EOF and EACC appeared to be adequate to perform the assigned functions with the following exception.
The plans and procedures require that the Emergency Support Director, the Senior Manager at the EOF, be in place within four hours of a declaration of a site emergency. This time-frame exceeds the guidance of NUREG-0696 in this regard.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provisions for having a designated Emergency Support Director in place at the EOF sithin one hour of the decision to activate the EOF. (289/81-20-03) 4.1.1.5 Post-accident Coolant Sampling and Analysis The auditors reviewed Emergency Plan Implementing Procedures 1004.15 " Post-accident In plant Sampling" and 1004.33,
" Handling High Activity Reactor Coolant Sample - Boron, Chloride, and Gamma Spectrun Analysis - Accident Conditions".
The licensee had installed a post-accident primary coolant sampling system which could be used under accident conditions, the location of which would be accessible under accident conditions.
The design and shielding of the reactor coolant sampling area and sample lines are such that radiation doses to sampling technician personnel are ALARA. The original primary coolant sampling system had been modified to reduce personnel exposure and isolate any lines from TMI Unit-2 that enter the sample room.
There was a shielded liquid sample container and remote I
handling tools for use in transporting the sample. The l
sample analysis area would be accessible during accident conditions.
Instruments, detectors and st*ner equipment and tools for analysis which were described in the procedures were in place.
j The sampling technique described in EPIP 1004.15 provides for a 5-minute coolant recirculation period to allow for a representative sample. The sample collection and analysis, as described in EPIP 1004.33, can be completed in one hour for boron and gamma isotopes.
8 Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.1.6 Post-accident Containment Air Sampling and Analysis The containment air sampler, designated as RM-A2, was located on the 281-foot level of the Intermediate Butiding. This i
location is expected to be habitable during an emergency.
No special arrangements had been made to satisfy the ALARA requirement.
l InstrumentRange(RM-A2) lowest concentration maximum etacentration Ci/cc Ci/cc noble gas 2E-6 IE-2 i
particulate IE-11 1E-7 todine
?.F-11 1E-7 The location where RM-A2 was located had no area radiation detector. Monitoring of this location would be done by licensee personnel during entry. The instrument was equipped with valves and snap-in connectors so that the pump could be used to pull air samples through an todine cartr1dge, a particulate filter and to fill a gas sample chamber. These i
samples could be transported to the counting laboratory in a shielded container; tongs were available for remote handling.
l (The sample analysis factitty is addressed in Section 5.4.2.7 of this report and was found acceptable.) The instrument and detectors described in Sections 5.4.2.6 and 5.4.2.7 of this report were in place. The collection media and handling devices were available. The sample could be analyzed and the results known in less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
RM-A9 monitors the noble gases in the purge line from contain-ment. The RM-A9 system had been modified to extend its range by the addition of a GM and a separate measuring and readout circuit to monitor a separate sample volume in a shield.
In addition, a shielded ion chamber was being added to monitor the purge gas line.
These modifications extended the range of measurement to 10E5 C1/cc concentrations of noble gases in containment and provided a remote readout in the Control Room.
RM-A9 was currently located on the 281-foot level of the Intermediate Building and was scheduled to be moved to a new concrete block building over the exhaust duct. This new location' would be accessible from outside the building.
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Based on the above findinp, this portion of the licensee's program appears to be acceptable.
4.1.1.7 Post-accident Gaseous and Particulate Effluent Sampling and Analysis Air sampler RM-A8 monitored the 125,000 cfm exhaust air flow from the Auxiliary and Fuel Handling Buildings. RM-A9 monitored the 50,000 cfm normal exhaust flow from the reactor butiding. These two monitors were located on 281 foot level of the Auxiliary Buildi:ig and may not be accessible in an emergency. The Itcensee had made provisions for moving these samplers to a new location directly over the exhaust i
duct leading to the main vent. This location was accessible from outside of the building. The new location will not be monitored by an area radiation monitor.
Sample lines will be short and routed up through the floor of the room directly behind the sampler.
Provisions were made for samples to be taken by snap-in connectors and valving, which would direct the flow through a sample extraction port and a sample chamber. The sampling syst w can then be valved off and the sample chamber removed for direct measurement and laboratory analysis.
Remote handling tools and a shielded sample transport pig were available. The sample would be transported to a counting facility for analysis. The counting facility was located in a location that would be habitable during emergencies. The sample could be taken, analyzed and the results reported in less then three hours. Alternate counting facilities were available at the licensee's environmenal facility at the Harrisburg airport.
Instruments, detectors, pipettes and syringes for analyses described in Environ-mental Procedure 1301 4.7 were available.
In addition, provisions were made for dilution at a dilution station outside of the chemistry laboratory.
Based on the above findings this portion of the licensee's program appears to be acceptable.
4.1.1.8 Post-accident Liquid Eff!sent Sampling and Analysis The auditors reviewed EPIP 1004.14 " Monitoring / Controlling Liquid Discharges for Normally Uncontaminated Systems", and determined that samples of all liquid effluent paths would i
L. taken during an accident, including the normally uncontaa minated liquid effluent systems.
Sample points would be accessible during an emergency. The sample locations were not monitored by the area radiation monitoring system. The anticipated dose rates from samples from these effluent paths would not require special handling or shielding for transport. The sample analysis facility would be accessible l
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during an emergency. The radiological protection equipment described in the precedure was in place and sampling equipment adequate for the task was available.
During normal conditions all effluents were stored in the i
following liquid waste systems:
Industrial Waste Treatment Systems (IWTS)
Industrial Waste Filter System (IWFS)
Secondary Plant Neutralization Tanks (SPNT)
Waste Evaporation Condensate Storage Tanks (WECST) -
TMI Unit-2 During accident conditions it may be necessary to transfer or release liquid waste to obt:in storage space for highly contaminated radioactive liquids. This would require analysis of stored liquids to be known prior to discharge or transfer.
The samples could be taken, analyzed and the results repeled within three hours. The responsibility for evaluation of the sample analysis and release of the liquids was the responsibility of the Radiological Assessment Coordinator (RAC). The RAC provided the Emergency Di.ector with his evaluation and recommendations. The Emergency Director was responsible for authorizing the release of liquid effluents during an emergency.
Based on the above findings this portion of the licensee's program appears to be acceptable.
4.1.1.9 Offsite Laboratory Facilities The auditors reviewed the offsite radiological laboratory facilities in the licer.see's Environmental Assessment Command Center (EACC) at the Harrisburg airport. The facility provided radioanalytical capability remote from the site.
The instrumer.tztf on had the required sensitivity and had been calibrated to make the necessary measurements of iodine and other nuclides in the environs duri::g normal and accident conditions.
In addition, the facility provided backup analyses in the event the stations analytical facilities were out,of service or not accessible.
The Commonwealth of Pennsylvania has radioanalytical laboratory facilities in nearby Harrisburg, operated by the Bureau of Radiological Health.
Because of the proximity of these facilities to the TMI site, they would provide laboratory 1
11 N
backup for the licenses. The Director of PEMA agreed in a letter dated January 3, 1980, to provide full and active assistance in all emergency operations which might be neces-sitated by an accident at Three Mile Island.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.2 Protective Facilities 4.1.2.1 Assembly / Reassembly Areas The auditors reviewed Section 4.6.5.1, " Protective Cover, Evacuation, Personnel Accountability", and Section 4.6.5.2, e
"Use of Onsite Protective Equipment and Supplies", of the Emergency Plan and EPIP 1004.2, " Alert"; EPIP 1004.3, " Site Emergency"; and EPIP 1004.4, " General Emergency". The desig-nated assembly / reassembly areas onsite were the TMI Unit-1 Warehouse, Control Room / Shift Supervisor's Office, Access Control Point / Operations Support Center, Processing Center, and the Unit-1 Service Building Auditorium. Designated offsite assembly / reassembly areas were the 500 kV Substation or the Middletown Substation, depending upon plume pathway.
If a site evacuation is ordered, all non-essentia1' personnel reporting to the warehouse would be logged in and transported to either the 500 kV Substation or Middletown Substation, where a reaccounting of personnel would occur. Contaminated i
personnel would be sent to Crawford Station for decontamination as specified in EPIP 1004.20, " Personnel / Vehicle Monitoring and Decontamination". The assembly areas in the warehouse and access control points contained emergency monitoring kits, protective clothing and TLDs.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.2.2 Medical Treatment Facilities The licensee maintained two first aid areas in the TMI Unit-1 facility; adjacent to the Radiological Controls Area and l
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in the TMI Unit-1 Service Building.
First aid stations at six locations on the site contained stretchers, splints and individual first aid kits. The first aid room near the Radiological Controls Area was locked, but keys were maintained at the Radiological Controls Access Control Point.
Facilities were also available for limited decontamination at these locations.
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Backup support for the treatment of injured and contaminated individuals was available through Hershey Medical Center, Radiation Management Corporation and local physicians who maintain letters of agreement with the licensee. EPIP 1004.19 contained provisions to provide security badges and dostmetry i
to medical support personnel.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.2.3 Decontamination Facilities The auditors reviewed EPIP 1004.20, "~ rsonnel/ Vehicle Monitoring and Decontamination" and S utions 4.6.5.1 and 4.6.5.2 of the Emergency Plan. There were provisions for decontamination of personnel within the protected area at the Health Physics Control Access Area at the 305 foot elevation of the Control Building.
Emergency kits contained decontamination material.
The auditors noted that there were no provisions for decon-tamination of personnel at assembly areas, and that the procedure (EPIP 1004.20) called for transporting contaminated individuals from the assembly area (Warehouse No. 1) to Crawford Station (See Section 4.1.2.1 of this report), where monitoring equipment, showers, sinks, protective clothing and decontamination materials were located.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.3 Expanded Support Facilities Sections 4.7.2.2, 4.7.2.3, and 4.7.2.4 of the licensee's Emergency Plan described the provisions for expanded support of the onsite emergency organization. The licensee had designated three areas:
the Environmental Assessment Command Center (EACC) the Alternate Emergency Operations Facility (AEOF) and the Parsippany Technical Functions Center for corporate, contractor and non-licensee augmentation personnel.
The EACC would be activated whenever the licensee's Emergency Operations Facility (EOF) is activated. This Center is respon-sible for the assessment of all offsite and radiological impacts.
The auditors inspected the facility and noted that it contained adequate space, communications and equipment to permit perform-ance of its intended function. The adequacy of this facility was also demonstrated on June 2, 1981, during a licensee conducted exercise.
(See also Section 4.1.1.4 of this report.)
13 The Alternate Near-Site EOF which is located approximately 3 miles north of the TMI site, was designated as the primary staging location for augmentation personnel in the administrative, mainten-ance, security, chemistry, and radiological controls disciplines.
Examination of this facility indicated that it contained adequate space, communications and equipment to permit performance of its intended function.
l The Parsippany Technical Functions Center was located at the i
General Public Utilities (GPU) headquarters building in Parsippany, N.J.
The Group Leader-Technical Support and his staff (members of the augmentation organization) utilize this center. While the auditors did not visit this center, the licensee stated that the center was equipped witn a dedicated telephone line to Babcock and Wilcox in Q;nchburg, VA, and to the near-site Emergency Operating Facility (EOF) and Technical Support Center (TSC). The center also had access to the in plant operational parameters via a CRT system.
Inspection of the EOF and TSC indicated that the dedicated telephone lines to the Parsippany Technical Functions Center were installed and operable.
In addition the auditors noted that the Parsippany Technical Functions Center had been activated during a large-scale exercise of the licensee's Emergency Plan on June 2, 1981. The results of this exercise indicated that the space and equipment available were adequate to permit per-formance of its intended function (IE, Inspection Report No. 50-289/81-15).
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.1.4 News Center The licensee had provisions for a news center as described in 2
Section 4.7.4 of the Emergency Plan. The center was located in l
Crawford Station, Middletown, PA. The center had provisions for telephone service, electric load to carry added TV requirements, 1
public address system, audio visual equipment, and security. The center appeared to be large enough to accommodate the expected number of media representatives.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2 Emergency Eqc'pment 4.2.1 Assessment Equipment 4.2.1.1 Emergency Kits and Emergency Survey Instrumentation The licensee had stocks of emergency supplies and survey instruments pre positioned at various locations throughout
14 i
the facility. The locations and equipment were as specified in Emergency Plan Implementing Procedure (EPIP) 1053, Rev.
1, " Emergency Equipment Readiness".
~
The auditors reviewed the inventories and equipment in the emergency kits and found them to be as stated. A review of available portable survey instrumentation indicated that their ranges, types and numbers appeared to be adequate to meet anticipated emergency needs as outlined in the procedures.
Instrumentation available for individuals or teams reentering the facility provided the capability to detect and measure radiation fields up to 1000 R/hr.
The licensee identified a deficiency during their audit of the Emergency Plan related to a lack of instrumentation for environmental surveys having a capability to detect and measure particulate activity in air of IE-9 uC1/cc (Cs-137 equivalent) without regard to background radiation. Corrective action to remedy the deficiency was in progress by the licensee.
Licensee actions to correct a second deficiency identified during their audit (lengthening inverter power cords for environmental monitoring equipment for use in any kind of weather) was also noted by the auditors.
Operability checks and inventories appeared to have been routinely performed on all emergency instrumentation, supplies and equipment described in the Emergency Plan and Implementing Procedures.
The inventories and checks performed appeared to have been adequate to maintain emergency supplies and equipment in a constant state of readiness.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.1.2 Area and Process Radiation Monitors i
The auditors examined the following systems:
Area Radiation Monitor Condensor Off Gas Monitor Steamline Monitor Containment Monitor The area radiation monitors (ARMS) were installed in accordance with the Technical Specifications with a range of.1 mR/hr l
to 10 R/hr, except channel RM-G8 which was equipped with a high range ionization chamber and was capable of measuring from 1 R/hr to IE6 R/hr. The Emergency Plan only described the area radiation monitors by reference to the Technical Specifications. All of the area radiation monitors required i
l l
l
15 for accident assessment read out in the Control Room. The area radiation monitors had an upper range of 10 R/hr which was not sufficient to assess the full range of accidents defined in the Emergency Plan.
They did have sufficient range to cause the initiation of the Emergency Plan. The licensee had made provisions for the installation of two j
high level monitors in containment with measuring capability up to IE7 R/hr. These operating ranges would be tested and verified by the manufacturer.
The Instrument and Calibrations Group (I&C) was responsible for carrying out the routine calibration of all installed radiological and monitoring systems defined in the pro-cedures.
During the restart period a group called the Startup and Test Group, was charged with the responsibility of verifying that all safety related instrumentation was calibrated and functioning prior to restart.
The sensors of all monitors were not checked to verify that their readouts would accurately reflect their intended use.
Calibration across the meter range of the instrument was not verified for currently installed containment monitors or the new system with the IE7 R/hr range. All detectors were calibrated in mR/hr or R/hr. Only the containment monitoring system was supplied with redundant or vital power.
The condenser off gas monitor had been modified by the installation of a shielded Geiger Mueller (GM) tube to sense the radiation emanating from the gas sample chamber. This-detector was connected to a separate measuring circuit to 1
permit measurement of concentrations of noble gases up to 0.1 C1/cc.
The readout was in the Control Room. An ionization chamber was being installed on the steam line to permit measurement of radiation emanating from the steam line.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.1.3 Non-radiation Process Monitors The non-radiation process monitors described in Section 4.7.6.1.5 of the Emergency Plan which measure vital parameters of a non-radiological nature, such as:
pressure, flow, temperature, fluid level, etc., being relied upon for accident detection, classification and assessment, were in place and operable. All monitor readouts were accessible in the Control Room and were readily observable.
I Based on the above findings, this portion of the licensee's program appears to be acceptable, i
l l
16 4.2.1.4 Meteorological Instrumentation The bases for the auditors review of the licensee's meteoro-logical measurements program included Regulatory Guides 1.23 and 1.97, and criteria set forth in NUREGS-0654, -0696 and -
0737.
Basic meteorological parameters for emergency condit. ions were measured on the ISO-foot meteorological tower on the north end of Three Mile Island. Wind speed, wind direction, atmospheric stability and precipitation data were transmitted to the Control Room directly and recorded on strip charts.
Data was also available via telephone callup from the computer data storage facility. The direct dial-up capability allows offsite agencies access to the following data:
(1) data received from the meteorological tower every four hours, (2) radioactive release data, and (3) various model parameters which can be updated at the user's option.
Warnings of severe weather were available through notification by National Warning System 'hAWAS) to the Control Room, as well as through facsimile equipment from the National Weather Service.
Back-up meteorological data were available from the National Weather Service at the Harrisburg airport.
Maintenance and calibration were done to assure the data recovery requirements would be attained.
The auditors determined that the primary meteorological instruments were not supplied with redundant power sources.
Therefort, loss of power would result in loss of onsite meteorological data.
A supplemental meteorology tower was planned for installation near the south end of Three Mile Island.
Such a tower could also reflect possible valley influences on airflow in the site vicinity.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provision of backup (redundant) power supplies for the primary meteorological instrumentation.
(289/ 81 04)
17 4.2.2 Protective Equipment 4.2.2.1 Respiratory Protection The Itcensee had 29 self-contained breathing apparatus (SCBA) devices reserved for emergency use as described in Radiological Controls Procedure (RCP) 1616.1, Rev. 5, Section i
5.7.1.
There were provisions for refilling SCBA devices in the circulating water pump house using a compressor which would be useable under conditions in which the internal areas of the plant had high airborne / direct levels of radiation.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.2.2 Protective Clothing The auditors reviewed EPIP 1053, Rev.1, " Emergency Equipment Readiness", and inventoried the stores of protective clothing reserved for emergency conditions. The quantity and location were as stated in the procedure and appeared to be adequate for emergency needs.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
l 4.2.3 Emergency Communications Equipment The auditors reviewed Section 4.7.5, Table 18 and Figure 19 of the licensee's Emergency Plan and inspected in place communi-cations equipment at various locations to verify operability. The auditors noted that all equipment was in place and operable.
This audit also included a review of the prompt alerting system for TMI Unit-1, which will consist of approximately 83 sirens supplied by the licensee to be activated by County Emergency Operations Centers. This equipment was in the process of being installed during the appraisal. Discussions with the Itcensee indicated that testing of the system would begin in early August 1981, with the majority of the system installation and testing to be completed by September 1981.
The auditors also reviewed the status of the licensee's actions toward resolution of an item identified during a previous inspection in relation to audibility of the reactor building evacuation alarm. The status of this item was last reviewed during an inspection conducted May 4-7, 1981 (50-289/80-22). At that time, the item was unresolved and the status was found to be unchanged i
-....------.. -~-#
.--_..,,..-,-___.-__,,,.y_
~ -.., -. - _,,.
18 during the current appraisal. This area will be reviewed prior to restart.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Completion of the prompt alerting system for the plume exposure emergency planning zone around Three Mile Island.
(289/81-20-05)
Completion of the modifications to the reactor building evacuation alarm system. (This item was previously identified in Inspection Report No. 50-289/80-22, as finding 289/80 68.) (289/81-20-06) 4.2.4 Damage Control / Corrective Action Equipment The licensee did not maintain reserves of equipment for damage control and corrective actions.
Rather, the Emergency Plan relied upon the availability of generic emergency kits which appeared to contain appropriate instrumentation, protective clothing and equipment. The licensee also relied upon the routine stock of equipment as a back-up to the emergency kits. This concept was reflected in the procedures governing repair and corrective action activities.
Based.on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.5 '
Reserve Emergency Supplies and Equipment For a serious emergency, the licensee relied on the normal inventory of supplies (e.g., survey instruments, dosimetry for the environ-mental radiation monitoring program, protective clothing and equipment, and other instruments and equipment) to support augmented emergency operations and supplement the emergency reserves. The licensee had established inventory controls to include minimum and maximum stock levels.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
4.2.6 Transportation The auditors reviewed Sections 4.6.3.5, 4.6.6.3, and 4.6.5.1 of the Emergency Plan which addressed transportation for offsite monitoring teams, medical emergencies and non-essential personnel.
Three vehicies were set aside to support the offsite monitoring teams, as well as for medical emergencies. Keys were immediately available through the Security Shift Sergeant. The vehicles were y--.-w-
,-y
_,------,.-..,,,--,-w y
19 vans which appeared to be of sufficient size and were properly equipped to perform their assigned functions. Non-essential personnel required to evacuate the site to reassembly areas would use private vehicles.
Based on the above findings, this portion of the licensee's
'l program appears to be acceptable.
5.0 PROCEDURES 5.1 General Content and Format The auditors reviewed the licensee's procedures which implemented and interfaced with the Emergency Plan. Categories of procedures included the Emergency Plan Implementing Procedures (EPIPs), Emergency Proce-dures, Radiation Control Procedures, Chemistry Procedures and Admini-strative Procedures (APs). The purpose of this review was to determine the adequacy of the various procedures in relation to their use in implementing the various aspects of the Emergency Plan.
Generally, the procedures provided guidelines or references for areas in which the user of the procedure would be permitted to exercise judgment.
Steps of the procedures were displayed in a sequential fashion and the procedures specified the individual or organizational element responsible for implementing the procedure or step.
Specific findings related to the form and content of discrete procedures are discussed in subsequent paragraphs.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.2 Emergency, Alarm and Abnormal Occurrence Procedures The auditors reviewed a sampling of the licensee's emergency, abnormal and alarm response procedures to determine whether they were clearly interfaced with the Emergency Plan to permit timely initiation of a response to an actual or potential emergency condition. This area was reviewed during an inspection conducted on May 4-7, 1981 and the findings indicated that the emergency and abnormal procedures did interface with EPIPs 1004.1 through 1004.4.
(IE Inspection Report No.
50-289/81-12) l Based on the above findings, this portion of the licensee's program appears to be acceptable.
[
5.3 Implementing Instructions EPIPs 1004.1 through 1004.4 specified what and when various pre-planned actions would be taken in response to four graded classes of emergencies. The emergency classes covered by these procedures were
tk designated as:
Notification of an Unusual Event (EPIP 1004.1); Alert (EPIP 1004.2); Site Emergency (EPIP 1004.3); and General Emergency (EPIP 1004.4).
The above procedures were written for use by the Emergency Director and clearly specified the assigned responsibilities, highlighting those responsibilities which may not be delegated. Each of the four procedures described specific action levels based on observable inform-ation and orchestrated the implementation of other, more specific procedures which had been developed to implement or support imple-mentation of the Emergency Plan.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4 Implementing Procedures 5.4.1 Notifications The licensee's provisions for notifying personnel that an emergency exists were contained in EPIPs 1004.1 through 1004.4, 1004.6 and 1004.8 and included a sequence of notifications for onsite and offsite organizations.
Notifications that are immediate in nature were incorporated into the Action Steps of EPIPs 1004.1 through 1004.4.
Personnel on site at the time of an emergency would be notified by oral announcements over the plant page and by sounding the radiation emergency alarm and/or containment evacuation alarm..The procedures provided for authentication schemes, lists and telephone numbers, and described the preferred means of contacting response agencies.
There were pre planned messages for the initial notifications of support groups.
The content of these messages was included in the relevant procedures.
Initiation and relative scope of the recall of non-duty personnel i
were clearly tied to the particular class of emergency. This was accomplished by steps within EPIPs 1004.1 through 1004.4.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.2 -
Assessment Actions The licensee's program for dose assessment was coordinated by a Radiological Assessment Coordinator (RAC) assigned to the emergency staff.
The RAC would function from the Technical Support Center (TSC) to collect and interpret information that must be integrated into the assessment actions.
The source of information included:
21 Meteorological instrumentation; Reactor effluent monitors; Process monitors which can provide inferences concerning the i
potential for release of radioactivity to the environment; In plant survey information; Out-of plant onsite survey information; Offsite field survey results; and P,rimary coolant sample results.
The RAC is responsible for interpreting the effluent monitoring data to determine the source term for release of radioactivity from the site. He would determine the current meteorological parameters and apply appropriate dispersion factors to the source term to project the downwind concentration of radioactive materials and the projected dose at the site boundary and in the plume 4
pathway, as detailed in EPIP 1004.7, "Offsite Dose Projections".
The licensee had assigned on each shift a health physics foreman who would fill the posittor, of the Radiologica! Assessment Coordi-nator.
Implementing procedures were provided to assist the RAC in determ-ining that all sources of information were tabulated and considered 1
in evaluating the source term and in making dose assessment decisions. These procedures, EPIPs 1004.7 and 1004.9, provided guidance on assigning priorities to the.available information.
The responsibility for radioanalytical support was assigned by the licensee to radiological support engineers located in the Environmental Assessment Command Center. The Radiological Assess-ment Coordinator would be provided information and evaluations by this support group once that center is activated. Prior to manning the center, the RAC is charged with the responsibility for directing onsite and offsite radiological menitoring teams and providing radiological support analyses to tre Emergency Director.
l The licensee had detailed procedures to support the personnel who must perform the necessary functions to provide information necessary for assessment actions.
Each of the following pro-cedures were reviewed by the auditors and were found to be accept-able.
EPIP 1004.7, Rev. 2, Offsite Dose Projection t
EPIP 1004.9, Rev. 1, In-Plant Radiological Controls during Emergencies EPIP 1004.10, Rev. 1, Onsite Radiological Monitoring
22 EPIP 1004.11, Rev. 1, Offsite Radiological Monitoring EPIP 1004.12, Rev. O, Environmental Monitoring EPIP 1004.15, Rev. O, Post-accident In plant Sampling RCP 1602, Rev. 7, Radiation Dose Rate Surveys RCP 1607, Rev. 3, Sampling of Radioactive Gas The auditors noted that the procedures appeared to integrate assessment actions to allow dose projections to be based on plant parameters, meteorology, plant chemistry and field survey infor-mation. The procedures generally identified sources and types of required information.
Action levels and protective action guides that would be used by assessment personnel as a basis for considering or recommending the initiation of protective actions, as well as emergency measures to terminate or mitigate the actual or projected consequences determined from the assessment process were specified; however, evacuation time estimates were not included. There was a means, based on installed control room instrumentation, for initially projecting exposures or exposure rates to the whole body and thyroids of individuals located within the Emergency Planning Zone (EPZ) and to personnel onsite.
Provisions were made in the procedures for immediate notific& tion of state and local agencies if the offsite dose projections indicated dose levels to the public in excess of the lower limits of the Protective Action Guides (PAGs) established by the Environmental Protection Agency (EPA). There were provisions for trend analysis of assessmen,t data.
Based on the above findings, improvement in the following area is required to achieve an acceptable program:
Inclusion of high range noble gas and effluent analyses in the accident assessment scheme.
(This item was previously identified in Inspection Report 50-289/80-22 as finding 289/80-22-82).
(289/81-20-07) 5.4.2.1 Offsite Radiological Surveys The auditors reviewed Section 4.7.6.2, " Facilities and Equipment for Offsite Monitoring", of the Emergency Plan, :s well as Emergency Plan Implementing Procedures (EPIPs) 1004.1, 1004.7, 1004.11, 1004.12, and 1053. The purpose of EPIP 1004.11 and EPIP 1004.1 were to provide adequate proce-dures for offsite monitoring of radiation levels and concentra-tions of radiotodine in the air after an accidental release
2__.
m.
23 of radioactive materials to the environment. These procedures also established the monitoring team actions required to ensure the safety of the monitoring teams while assessing and verifying the magnitude of the release of radioactive material. The procedures defined the equipment available and their locations.
EPIP 1004.12 defined the TLD and sample locations normally monitored.
Predetermined survey points were identified in EPIP 1053,
" Emergency, Survey Kits". These survey points were identified on a topographical map with detailed descriptions of the location of each survey point.
EPIP 1004.11, however, did not identify the predetermined survey locations, nor did it reference EPIP 1053.
i A means of recording offsite survey results was provided in attachment I to EPIP 1004.11. Attachment II, titled " Dosimetry Log," was not in the current revision of EPIP 1004.11, however, a Procedure Change Request (PCR) was in process to correct this discrepancy. A central collection point for environmental samples was not addressed in EPIP 1004.11 or in 1004.12. This item was identified in the licensee's emergency plan audit and PCR was issued to correct this finding.
The identification of collected environmental samples was defined in Environmental Sampling Procedure 1503.3 and 1503.4.
Based on the above findings, this portion of the licensee's program appears to be acceptable, however, the following matter should be considered for improvement:
Provision of a description in EPIP 1004.11 of the predetermined offsite sample locations and the method to be used for identification of collected samples, such that this information is readily available to f
j offsite teams.
(289/81-20-08) 5.4.2.2 Onsite (out-of-Plant) Radiological Surveys
(
Guidance to radiation monitoring teams performing measure-ments of radiation levels and air concentrations of radio-nuclides in the outside air during emergenciss was provided in EPIP 1004.10, "Onsite Radiological Monitoring". The procedure included the equipment required, survey points and a check list to verify each step completed. Attachments provided a format for data recording.
Samples were labeled in accordance with Environmen+al Monitoring Procedures 1503 and 1504.
24 4
A designated central collection point for onsite samples was not defined in EPIP 1004.10.
i The method of communication between the field teams and the team coordinator was defined. Communication equipment was available and operable.. The equipment's location was defined as well as a backup means of communication for transmission of data to appropriate elements of the emergency organization.
Radiation protection guidance, protective equipment and protective clothing were not addressed in the procedure.
Based on the above findings this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provision of radiation protection guidance as well as identification of a central sample collection point for i
onsite samples in EPIP 1004.10.
(289/81-20-09)
I 5.4.2.3 In-plant Radiological Surveys The " Emergency Actions Section" of EPIP 1004.9, "In plant Radiological Controls During Emergencies", addressed radiation exposure controls during emergencies and provided for pre-mission briefings on potential hazards by the Health Physics Coordinator and debriefing after exiting the radiation area.
Check lists of survey and protectiva equipment was provided in Attachment 2 of EPIP 1004.9. Section 4.7.1 of EPIP 1004.9 described methods of controlling access to prevent inadvertent entry into hazardous locations during an emergency. Attachment 1 of EPIP 1004.9 provided a check list to be used during briefing and debriefing of personnel assigned reentry or rescue operations.
The procedure did not provide precautions and checklists to ensure that appropriato instrumentation, protective clothing and devices and personnel monitoring equipment were used.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provision of a checklist in EPIP 1004.9 to ensure that appropriate instrumentation, protective clothing, respiratory devices and personnel monitoring equipment are used for in plant surveys.
(289/81-20-10)
,,,,-,,,.---m,,
,-n,
,,,,,_--,. _ -,... - - -, - - -, _,,,,, -,,, - -.,,,, - -. + -.,,, -,,,, - -,,. -, -, -,.,,, - - -. - - -, -.,
25 5.4.2.4 Post-accident Primary Coolant Sampling i
EPIP 1004.15. " Post-accident In plant Sampling", specified.
the method of obtaining and analyzing primary coolant samples under accident conditions. The Radiological Assessment Coordinator (RAC) was assigned the responsibility for imple-menting this procedure. The procedure provided detailed instructions for the operation of the sampling system and the sample line purge requirements to. assure that the collected sample was representative of the primary coolant. The procedure also defined special equipment and sampling apparatus to be used but did not address data sheets to accompany each sample nor the labeling requirements.
The EPIP 1004.15 adequately defined how the sample was to be handled and transported to the chemistry facilities for dilution and analysis. The sample could be obtained within i
one hour and delivered to the chemistry facility. The licensee had provided tongs for remote handling and a shield for storage and transport to the dilution station where the cor. centration in the sample was reduced to a level which could be handled in the chemistry laboratory.
EPIP 1004.15 did not address specific precautions and prerequisites to protect personnel from excessive exposure during sample collection, transport and handling.
Likewise, methods to minimize contamination during sample handling and analyses were not addressed.
Based on the above findings, improvements in the following areas are required to achieve an acceptable program:
Provision of precautions and prerequisites in the applicable procedures appropriate to protect personnel from excessive l
radiation exposures during post-accident primary coolant sample collection, transport, handling and analyses.
(289/81-20-11) 5.4.2.5 Post-accident Primary Coolant Analysis The auditors reviewed EPIP 1004.33, Revision 1, " Handling l
High Activity Reactor Coolant Sarple - Boron, Chloride, and l
Gamma Spectrum Analysis - Accident Conditions", which described the method of handling, analysis ano storage of post-accident primary coolant samples.
EP.tP 1004.33 established an administrative upper limit on personnel radiation exposure that would be allowed in the processing of a sample.
Routine chemistry procedures provided for labeling and tracking, as well as sample dilution and handling. Analyses were to be performed using a GeLi detector and a gamma spectrometer described in Procedure SCP 1958.3.
The pror= dure required d
,.,,n,
---,,.--.,n.
i 26 that the dose rate from the sample to be gamma analyzed be Ifmited to less than 1 mR/hr. This limited the amount of material permitted in the counting laboratory and reduced laboratory background and the chance of contamination of the facility.
Analytical data sheets were not keyed to the EALs. The data were transmitted to the Radiological Assessment Coordinator (RAC), who was responsible for relating the data to the EALs and notifying the Emergency Director. Data sheets would be transmitted to the RAC or the Emergency Director.
j Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.2.6 Post-accident Containment Air Sampling Section II.B.3 of NUREG-0737 specifies that licensees should be able to sample the containment air and complete the analyses within three hours under accident conditions. The auditors reviewed available precedures and held discussions with licensee personnel to evaluate the licensee's conformance with NUD.EG-0737.
TMI Unit-1 Surveillance Procedures in the 1301 Series appeared l
to cover the sampling of containment air under normal condi-tions. The licensee had been making modifications to the installed containment air monitor to extend the range for nobel gases as discussed in Section 4.1.1.6 of this report.
i The auditors reviewed EPIPs and determined that no procedure relevant to post-accident containment air sampling for radioactive gases, particulates or todines existed.
Conse-quently, neither the sampling methodology including sample handling, transport and storage, nor the special precautions and prerequisites necessary to protect the involved personnel had been addressed.
(See also Sections 5.4.2.7, 5.4.2.8 and 5.4.2.9 of this report).
Based on the above findings, improvements in the following area are required to achieve an acceptable program:
Provision of precautions and prerequisites in the applicable procedures appropriate to protect personnel from excessive radiation exposures during post-accident sampling and analyses regarding airborne radioiodines in the containment atmosphere.
(This item was previously identified in Inspection Report 50-289/80-22 as finding 289/80-22-83) (289/81-20-12)
27 5.4.2.7 Post-accident Containment Air Sample Analysis The auditors reviewed chemistry analytical procedures for handling high level samples and determined that the licensee had established calibration for analysis of radionuclides using a GeLi detector with geometries out to 10 cm from the i
detector. The procedures limited the quantity of material that could be brought into the chemistry and counting labora-tories. Analytical sheets were provided and used for all samples including high level samples. Analytical results would be reported to the Radiological Assessment Coordinator (RAC) who would relate them to emergency action levels (EALs) and report the results to the Emergency Director.
Although chemistry procedures existed for post-accident i
containment air sample analysis, review of EPIPs determined that no procedure relevant to containment air sample analysis existed nor was a means provided to get to the relevant procedures.
Based on the above findings, improvements in the following area are required to achieve an acceptable program:
See Item 289/81-20-12 of this report.
5.4.2.8 Post-accident Gaseoes and Particulate Effluent Sampling The auditors reviewed Environmental Procedure 1301 4.7 for stack effluent sampling which covered the current equipment installed in the Auxiliary Butiding. The equipment provided for continuous monitoring and sampling of the reactor butiding and the auxiliary building exhausts upstream of the main vent. The location of the sampling equipment was subjected to radiation levels which made the location inaccessible during the accident at TMI Unit-2. NUREG-0737 requires the location of the sampling system to be improved to ensure that it will be habitable under post-accident conditions.
The licensee was in the process of relocating the sampling l
j equipment and modifying the monitor to increase its capability to measure high concentrations of radioactive materials in the exhaust air (See Section 4.1.1.7 of this report.)
Environmental Procedure 1301 4.7 was relevant to the current (unmodified) equipment and location. An implementing procedure relevant to the relocated post-accident sampling system was j
not in place during the appraisal period.
Based on the above findings, improvements in the following area are required to achieve an acceptable program:
i
28 See Item 289/81-20-12 of this report.
5.4.2.9 Post-accident Gaseous and Particulate Effluent Sample Analysis The auditors reviewed Environmental Procedure 1301 4.7, Revision 10. The procedure adequately defined the steps to be followed to take and analyze samples of the exhaust gas from the main vent. The procedure did not discuss how the data obtained would be related to emergency a: tion levels (EALs).. The procedure was prepared for normal, not accident conditions and it did not specify who was to receive the data and how it would be evaluated.
Based on the above findings, improvements in the following area are required to achieve an acceptable program:
See Item No. 289/81-20-12 of this report.
5.4.2.10 Liquid Effluent Samplina The auditors reviewed EPIP 1004.14, " Monitoring / Controlling Liquid Discharges for Normally Uncontaminated Systems." The procedur? identified the systems that would require sampling and analysis of liquid effluents prior to discharge during an emergency.
It also delineated the emergency actions to be taken to terminate the release of contaminated liquids to the environment. Attachment I of the procedure provided the format for documenting the release point sampled, the concen-trations measured, as well as the source flow. Attachment II to'EPIP 1004.14 was the emergency release form used to authorize the release of effluent to the environment after it had been determined that the liquid in the system was not contaminated. The Radiological Control Coordinator and Chemistry Coordinator evaluated the analytical results and made recommendations to the Emergency Director who would authorize the release of liquid effluents during emergencies.
The above procedure did not address the sampling of those systems known to be contaminated or normally contaminated, so as to determine whether these liquids can or must be transferred to storage, processed or discharged during accident conditions. No sampling precautions or immediate actions required to evaluate the radiological status of liquid effluent were noted.
Based on the above findings, improvements in the following area are required to achieve an acceptable program:
29 Provision of guidance in the procedures for sampling and anlyzing liquids after an accident, from systems known to be contaminated or normally contaminated with radioactive material to determine whether the liquids can or should be transferred to other storage facilities, processed or discharged; those precrations to be taken during sampling; and those immediate actions required to evaluate the radiation levels of'the Itquids.
(289/81-20-13) 5.4.2.11 Liquid Effluent Sample Analysis The auditors reviewed EPIP 1004.14 " Monitoring / Controlling Liquid Discharges for Normally Uncontaminated Systems". The procedure did not address the sample analysis as the ifcensee considered appropriate chemistry procedures for the analytical laboratory and the counting facility adequate for this purpose, nor did this procedure address the radiological precaution and prerequisites necessary to analyze highly contaminated liquid effluents.
Based on the above findings, improvements in the following area are required to achieve an acceptable program:
See Item No. 289/81-20-13 of this report.
5.4.2.12 Radiological Environmental Monitoring Program (REMP)
The auditors reviewed EPIP 1004.12, Revision 1, " Environ-mental Monitoring"; Environmental Control Procedure (ECP) 1502, Revision 2, " Radiological Environmental Monitoring Program"; and associated 1500 and 1600 Series procedures in the Radiological Environmental Monitoring Program (REMP).
These procedures appeared to adequately cover the sample l
l collection, sample analyses, data recording, analysis of i
results, routine and non-routine reporting and quality assurance, but did not address personnel protection measures.
The REMP program adequately defined the sample collection, labeling, handling, recording of sample information, sample and data an.slysis and reporting of results. The procedures did not address environmental monitoring and sampling during emergencies; plume tracking by field survey personnel; or da,e rate monitoring and dose trigger points for survey team members to request replacement, protective clothing and respiratory protection.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
_. _ _,.. ~ _ _ _ _.. _
30 Provision of protective measures in EPIP 1004.12 necessary.
to protect personnel conducting radiolegical environ-mental monitoring.,(289/81-20-14) 5.4.3 Protective Actions 5.4.3.1 Radiation Protection During Emergencies The licensee addressed radiation protection during emer-gencies by establishing a Radiological Control Coordint. tor responsible for all emergency radiological conditions.
In this position he had the assistance on each shift of foer health physics technicians with pre-assigned emergency functions. The technicians received specialized training in their assigned functions.
In addition, the licensee had provided the following special procedures:
EPIP 1004.7 Offsite Dose Projections EPIP 1004.9 In plant Radiological Control During Emergencies EPIP 1004.10 Onsite Radiological Monitoring EPIP 1004.11 Offsite Radiological Monitoring EPIP 1004.12 Environmental Monitoring EPIP 1004.15 Post-accident In plant Sampling EPIP 1004.16 Contaminated Injury / Radiation Exposure EPIP 1004.18 Search and Rescue EPIP 1004.19 Emergency Dosimetry / Security Badge Issuance l
EPIP 1004.20 Personnel / Vehicle Monitoring and l
Decontamination l
EPIP 1004.21 Emergency Repair / Operations EPIP 1004.30 Activation of Emergency Centers EPIP 1004.31 Airborne Radioactive Sampling and Analysis EPIP 1004.33 Handling of High Activity Reactor Coolant Sampling
--v-r 4
._--,-.,---,,-,,--.na-
e.
31 Also, the licensee had upgraded the normal radiation monitoring program to include correction of deficiencies noted as a result of the accident experience at TMI Unit-2 as well as the deficiencies noted in the Health Physics Appraisal conducted in August, 1980.
No procedure was available for use by the Radiological Control Coordinator which orchestrated or provided overall coordination of individual procedures relative to radiological controls.
Based on the above findings, this portion of the licensee's program appears to be acceptable, but the following matter should be considered for improvement:
Provision of a procedure which ties together the separate emergency implementing procedures and orchestratos the emergency radiological protection actions to be imple-mented by the Radiological Control Coordinator. (289/81-20-15 5.4.3.2 Evacuation of Owner Controlled Areas The auditors reviewed Section 4.6.5.1, " Protective Cover, Evacuation, Personnel Accountability", of the Emergency Plan which specified the actions to be taken by personnel and identified the routes to be utilized by non-essential personnel for evacuation of the site.
According to the Emergency Plan, evacuation of the site is a three-step process as follows:
(1) an announcement is made over the site public address system for personnel to immedi-ately proceed to their predesignated assembly areas or emergency assignments for accountability; (2) when designated by the Emergency Director, all non-essential personnel will be evacuated using private vehicles to the 500 kV Substation or the Middletown Substation; and (3) personnel are accounted for upon arrival and radiation worker trained personnel will monitor persons and vehicles for radioactive contamination and take appropriate decontamination action. Site evacuation of non-essential personnel is.equired during Site and General Emergencies or at the descretion of the Emergency Director.
No onsite routes were marked for evacuation, however, there are only two bridges from Three Mile Island and one designated evacuatton route (PA 441) offsite.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
32 5.4.3.3 Personnel Accountability The auditors reviewed Section 4.6.5.1, " Protective Cover, Evacuation, Personnel Accountability", of the Emergency Plan and Security Procedure SP 1005.12, " Personnel AccoJntab111ty During a Site or General Emergency", and determined that the procedure and emergency plan section for personnel account-ability provided for full accounting of all individuals on site or identification of missing individuals within 30 minutes from declaration of an emergency.
i The procedure (SP 1005.12) designated the individuals (Site Protection Officers) who would perform the accountability and report the results to the Emergency Director.
Site security personnel wculd direct a search of all buildings, trailers, and other areas of the owner controlled area to ensure that all persons have assembled and/or evacuated the site.
Search arid rescue operations would be implemented to locate any missing personnel. There were provisions for continuous accountability on site after initial accountability had been completed.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.3.4 Personnel Monitoring and Decantamination
~
The auditors reviewed the licensee's provisions for imple-menting Section 4.6.6.2 of the Emergency Plan, "Decontam-ination". During the inspection of May 4-7, 1981, this area was reviewed and found to be acceptable (IE Inspection Report No. 50-289/81-12). The auditors noted that the status of this item had not changed since that time.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.3.5 Onsite First Aid / Search and Rescue EPIPs 1004.16 and 1004.18 described the methods of searching for and recovering injured personnel. The procedures discussed team actions and the actions of various members of the emergency organization in preparing for search and rescue operations.
The procedures addressed the precautions to be observed prior to reentering a radiation area. This was cccomplished by reference to EPIP 1004.19. The means to be used to transport and handle injured persons who may also be con-taminated were specified. There were provisions for notifying
33 the Hershey Medical Center that a contaminated / injured patient was being transported fgr treatment. There were preplanned messages covering this notification.
Based on the above findings, this portion of the licensee's program appears to be acceptable, 5.4.4 Security During Emergencies The auditors reviewed Security Procedures 1005.9, " Bomb Threats";
1005.12, " Personnel Accountability During a Site or General Emergency"; and 1005.4, " Civil Disorders".
Licensee security i
personnel were interviewed'and exhibited an understanding and working knowledge of the above procedures. The procedures were developed in accordance with the requirements of Appendix C to 10 CFR 73 and complimented the Emergency Plan.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.5 Repair / Corrective Actions The auditors reviewed procedure EPIP 1004.21, " Emergency Repair /
i Operations", which described the concept of operations for repair and other corrective action activities. The individuals responsible for implementing the procedure were specified and there were provisions for briefing team membe';s prior to commencing repair /
corrective action operations.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.4.6 Recovery The auditors reviewed procedure EPIP 1004.24, " Recovery Operations",
which described the licensee's recovery program. Organizational authority for declaring that a recovery mode is to be entered is assigned to the Emergency Director. Action levels for :ntering the recovery plan were clearly specified and plant operating conditions, as well as in plant and environmental radiological conditions were included.
In addition, there were provisions for notifying key non-licensee personnel and groups, as well as members of the licensee's emergency organization that a recovery mode was in effect. The procedure delineated key positions and duties in the recovery organization and assigned individuals, by title, to the positions.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
s
34
)
5.4.7 Public Information The auditors reviewed Appendix B of the Emergency Plan which specified the general authorities, responsibilities and specific duties of the Manager - Public Information.
The Manager - Public Information would :;erve as the primary contact for representatives of the news media; state, county, and local public information officers; and the GPU Communications Section in Parsippany, NJ.
He/she would activate the public information staff who would report to their work locations in the Visitors Center Office, Media Center or TMI Administration Building, depending upon the circumstances and severity of the emergency.
There were provisions for a TMI Pubite Information Duty Person on-call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.
This person would contact the Manager -
Public Information who would determine the level of activation of the Public Information Emergency Plan and provide the single source for release of all public information. An organization chart on page 9 of Appendix B of the Emergency Plan clearly defined the Emergency Public Information Organization.
The Manager - Public Information would provide for the coordination of information among various spokespersons of the various organiz-ations and groups.
Provisions were made for responding to public inquiries separate from the news media.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5 Supplementary Procedures 5.5.1 Inventory, Operational Check and Calibration of Emergency Facilities and Equipment The auditors reviewed procedure EPIP 1053, " Emergency Equipment Readiness", which provided a specific listing of all equipment reserved for use during emergencies and specified the location of the equipment.
The frequency at which thn amergency equipment is inventoried, operationally checked and/or calibrated is specified as quarterly in Section 3.1.1 of EPIP 1053.
Items inventoried and checked, other than instruments, included such items as polyethylene sheeting, masking tape, pads, pencils, etc.
The responsibility for the performance of the emergency equipment readiness checks and for correcting any noted deficiencies was assigned in Section 2.0 of EPIP 1053 to the Radiation Controls Manager.
t 35 Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5.2 Drills and Exercises The auditors reviewed Section 3.8 of Administrative Procedure 1051 which designated the Emergency Planning Coordinator as the administrator of drills and exercises at TMI Unit-1.
Each drill and exercise conducted was to be in accordance with a scenario developed in advance of the drill as was described in Sections 3.8.1 and 3.8.2 of AP 1051. Enclosure 5, AP 1051 provided the documentation and evaluation of observer and participant comments of the drill or exercise. An exercise was performed on June 2, 1981 in accordance with the above procedure.
(IEInspection Report No. 50-289/81-15).
Management controls existed for the assignment of responsibility for corrective actions and for assignment of completion dates to assure that the corrective actions are completed in accordance with an established schedule and are adequate to resolve the noted deficiency.
The licensee did not consider response to an actual event a substitute for the drills or exercises.
Section 3.5.3 of AP 1051 provided for backshift drills and exercises once every 6 years.
AP 1051 provided for the following drills and exercises at the noted frequencies: communications (quarterly), fire (annually, +
3 months), radiological monitoring (annually, 1 3 months), health physics (annually, 1 3 months) and a full-scale exercise (annually, 1 3 months).
There were provisions for routinely inviting offsite groups and agencies to participate in drills and exercises as witnessed by observer personnel during the June 2, 1981 exercise. There were provisions in Appendix.B. " Emergency Public Information Plan", of the Emergency Plan for' news media facilities, equipment and procedures that would be used during an actual emergency.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5.3 Review, Revision and Distribution i
The Emergency Plan indicated that the Manager - Emergency Prepared-ness would be responsible for insuring that the telephone numbers listed in the Emergency Plan Implementing Procedures were updated quarterly. The current te'7 phone number listing at the time of the appraisal was dated Ma,ch 25, 1981, meeting the criteria of the Emergency Plan.
36 Section 4.8.2 of the Emergency Plan provided that the Quality Assurance Department would review the Emergency Plan and imple-menting procedures at least annually and incorporate any required changes.
The plan and procedures had been reviewed, approved and updated as required.
Fifty-five controlled copies were distributed in accordance with an approved distribution list dated June 15, 1981. The distribution list included offsite agencies. The Emergency Plan and implementing procedure distri-button and the names, titles and telephone numbers in the imple-menting procedures appeared to be correct after a random sampling of the Itsted recipients.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
5.5.4 Audit i
The auditors reviewed Administrative Procedure (AP) 1055, Draft B; Quality Assurance Audit Procedure No. 7-18-01; and Section 4.8.2 of the Emergency Plan. The Emergency Plan and procedures which implement the Emergency Plan were audited at least annually, the last of which was completed on July 8, 1981. The audits involved discussions with personnel and inspection of equipment, as well as a paper review and observation of an emergency drill /
exercise. A follow-up system by the Itcensee to ensure identified audit deficiencies were corrected was in place.
l Based on the above findings, this portion of the Itcensee's j
program appears to be acceptable.
6.0 COORDINATION WITH OFFSITE GROUPS i
6.1 Offsite Agencies The auditors reviewed the licensee's program for coordinating the TMI Unit-1 emergency preparedness program with the various non-licensee agencies, individuals and groups who support or augment the licensee's program.
In this regard, the auditors reviewed provisions for:
training; participation in drills and exercises; and review, revision and distribution of licensee plans and procedures to the various support groups.
(See Sections 3.0, 5.5.2, 5.5.3, and 7.1 of this report.)
The auditors reviewed available documentation and noted that the Itcensee had contacted key supporting agencies for the purpose of conducting drills / exercises, and where applicable, training. The various agencies having response roles within the EPZ had been provided with controlled copies of the licensee's Emergency Plan and applicable Emergency Plan Implementing Procedures (EPIPs). The licensee's protec-tive action guides and related recommendations were compared with
37 those of the Commonwealth of Pennsylvania and were found to be consistent.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
6.2 General Public The auditors reviewed Appeadix B of the Emergency Plan which described the licensee's provisions fbr disseminating emergency planning infor-mation to residents of the piame exposure EPZ. This emergency action information was to be coordint.ted, approved, and disseminated by state and local agencies.
Information is to be updated and disseminated at least annually. The Pennsylvania Emergency Management Agency (PEMA) had distributed a booklet entitled,."What you Should Know About Nuclear Radiation Incidents", to residents of the EPZ.
Five counties, as well as local townships, planned to. distribute emergency information to residents when it 'ecomes available. The Public Affai-s Group located o
in the Zubey House would provide a single point of contact for additional information.
Licensee representatives stated that they are financially supporting state and local efforts for printing and distribution of emergency planning information to the general public.
Based on the above findings, this portion of the licensee's program appears to be acceptable.
6.3 News Media The auditors reviewed Appendix B of the Emergency Plan, " Emergency Public Information Plan for the Three Mile Island Nuclear Generating Station", and the GPU Nuclear Public Information Plan dated May 15, 1981.
Press kits were available for distribution to media personnel and were examined by the auditors. The kits contained information about emergency planning; points of contact for the release of infor-mation; information about radiation and accident ~ classification; views of the site; diagrams of the site layout; maps; and short biographies of key GPU personnel.
Based on the above findings, this portion of the Itcensee's program appears to be acceptable.
7.0 DRILLS, EXERCISES AND WALK-THROUGHS 7.1 Drill and Exercise Program Implementation The auditors reviewed a sampling of drill and exercise records and noted that critique sheets and drill scenarios had been prepared as required by procedures.
Items noted as being targeted for improvement were highlighted and integrated into the computer tracking system to l
38 ensure resolution. The NRC was also present and observed the conduct of a licensee conducted exercise on June 2, 1981 (IE Inspection Report No. 50-289/81-15). The auditors noted that the licensee had implemented the drill / exercise program consistent with the emergency plan requirements of Section 4.8.12 (See Section 5.5.2 of this report.)
Based on the above findings, this portion of the ifcensee's program appears to be acceptable.
7.2 Walk-Through Observations The auditors observed performance during walk-throughs in the areas of emergency detection and classification, notifications,' dose calculations,
~
in plant radiciodine sampling and analysis, and protective action decision-making.
During the walk-throughs, the auditors selected initiating conditions for a steam generator tube failure, high coolant temperatures, and a variety of abnormal process and effluent monitor readings. The shift supervisors and shift foremen were able to identify the conditions, refer to and follow the applicable alarm and emergency procedures and implement the Emergency Plan Implementing Procedures (EPIPs). The emergency and alarm procedures referred the operators to the proper accident classification in each event selected by the auditors. Onct the event was classified, the shift supervisors announced that they would become the Emergency Director and would implement the applicable Emergency Plan Implementing Procedure (EPIP 1004.1 through 1004.4) and took or simulated the proper actions to implement the applicable EPIP.
Walk-throughs of three operators to determine their ability to promptly notify appropriate offsite agencies of an emergency were conducted during one dayshift and two backshifts. During each walk-through, l
once the operator classified an event as one of four categories of emergencies, he was given the appropriate notification attachment of procedures EPIP 1004.1 through 1004.4. The attachments directed licensee personnel to make notification in a predetermined sequential fashion.
Licer.see personnel were familiar with the primary communi-cations lines to use for each notification. During one walk-through the primary notification method to Dauphin County was simulated to be inoperable and licensee personnel displayed familiarity with the backup means to notify Dauphin County via radio transceiver, tone alert and radio scanner.
Dose calculational methods were also examined during the same walk-through. The auditors selected a hypothetical set of initiating conditions which would indicate that a release was in progress or that a potential for release existed.
The interviewed Radiological Controls Foreman demonstrated an acceptable knowledge of the dose projection procedures, EPIP 1004.7, "Offsite Dose Projections"; EPIP 1004.10, "Onsite Radiological Monitoring"; and EPIP 1004.11, "Offsite Radio-logical Monitoring".
i 39 The auditors also interviewed the individual assigned as the Emergency.
Environmental Assessment Coordinator. During the interview, he demon -
strated an acceptable knowledge of his assigned responsibilities as well as dose projection and' environmental sampling techniques.
A backshift health physics technician was walked-through in plant iadiation protection practices. He was able to acquire and use the appropriate health physics and emergency plan implementing procedures required. Discussion of survey instrumentation in use revealed that all dose rate instruments currently in use were sensitive to beta and had beta calibration charts attached to the instrument.
Iodine sampling used either charcoal or silver zeolite as the collection medium.
~
Analytical procedures in the health physics facility were established for both types of media. The calibration of air sampling. flow meters was routinely accomplished by substituting a calibrated flow meter in place of the normal flow meter and comparing the results.
During the licensee's exercise of June 2, 1981, the auditors accompanied offsite monitoring teams to determine the useability and adequacy of procedures, as well as the proficiency of personnel in taking and evaluating air samples.
The auditors noted that the offsite teams followed applicable procedures and experienced no problems obtaining air samples and evaluating the samples using assigned instrumentation.
A team change occurred in the field with approximately twenty minutes of down-time while instrumentation was switched between vehicles indicating that assigned personnel were trained and knowledgeable in their assigned emergency functions.
The auditors walked two shift supervisors through procedures EPIP 1004.3, " Site Emergency", and EPIP 1004.4, " General Emergency". Included in this was a discussion of the criteria to be used for recommending protective actions to the Commonwealth in the event that such action was necessary prior to the arrival of the onsite emergency organization.
The individuals interviewed did not appear to be knowledgeable of the i
criteria used to make such decisions and indicated that training in this area had not been completed.,
The auditors also observed that evacuation time estimates were not factored into procedures EPIP 1004.3 and EPIP 1004.4.
Since the time required to conduct an evacuation is factored into protective action recommendations, this data should be included in the appropriate procedures.
The findings and observations summarized above were evaluated as part of Sections 3.2, 4.2, 5.2, 5.3, 5.4.1, and 5.4.2 of this report.
8.0 LICENSEE ACTION ON PREVIOUSLY IDENTIFIED ITEMS OF NONCOMPLIANCE The following previously identified items were reviewed during the Emergency Preparedness Appraisal (50-289/81-20) conducted July 13-24, 1981:
i 40 79-BU-17 Audibility proMess encountered on evacuation.
79-IR-16 Failure to have and to implement procedures for classifying a site emergency.
79-IR-17 Failure to implement procedures for emergency training.
79-IR-19 Unauthorized change to accountability procedure.
79-IR-22 Inadequate retraining program for radiation protection and chemistry staff.
80-19-02 Put Teciinical Support Center (TSC) reference materials in place, including as-built drawings and other technical documents.
80-19-03 Install dedicated telephone lines between the TSC and corporate headquarters.
80-19-04 Implement EPIP describing the operation, activinton, and roles of the TSC and Operations Support Center (OSC).
80-19-07 Implement training program for offsite personnel who would be called upon to respond to an emergency.
80-22-55 Positions in the emergency planning organization should be filled with Met-Ed/GPU Nuclear personnel who meet selection and qualification criteria of ANSI N18.1.
80-22-66 Availability of dedicated, high range (1000 R/hr) survey instru-mentation for use by teams or individuals who may re-enter the facility.
80-22-70 The appropriateness of reliance on Unit-2 health physics decon-tamination facility should be reviewed to ensure its availability when Units 1 and 2 are physically separated.
80-22-72 Improve pr'ocedures 1004.1 thru 1004.4 by specifying all of the Emergency Director's actions therein rather than including some of his actions in other EPIPs.
80-22-73 Development of action levels for emergency recall in relation to the declared class of emergency.
80-22-88 Consider interface of Unit-2 accountability with that of Unit-1.
80-22-90 Review inventory, operational check and calibration of emergency equipment and facilities.
80-22-92 Provisions for formal input of participant comments relative to deficiencies or improvements.
5 41 80-22-93 Provisions for backshifts drills.
80-22-94 Filing of drill packets by the emergency planning group.
80-22-95 Review, revision and distribution of the Emergency Plan and EP!'.
80-22-96 Review licensee's provisions for auditing the emergency planning program.
80-22-97 Review emergency planning coordination with offsite support groups.
80-22-98 Observe an emergency drill / exercise.
Based on examination of the licensee's stated corrective actions, discussions with licensee representatives, and examination of selective radiological operations and procedures, the appraisal team determined that adequate corrective actions were completed for the above items. The above items are considered closed and only those items identified in Sections 1.0 through 6.0 of this report are considered outstanding in the area of emergency preparedness at TMI Unit I at this time.
i 7
r ANNEX A INDIVIDUALS CONTACTED 1.
Principal Licensee Individuals G. Baker, Environmental Controls (GPU)
R. Dubiel, Supervisor, Radiological Engineering Unit 1 (Met-Ed)
G. Giangi, Emergency Planning Coordinator (Met-Ed)
H. Hukill, Director, Unit 1 (GPU)
R. Jones, Emergency Planning (NSS)
W. Kelly, Administrative Manager (GPU)
D. Kluscik, Public Information Representative (Mct-Ed)
M. McBride, Environmental Controls (GPU)
K. Peters, Security (THI)
- 5. Polon, Employee Communications Manager (Met-Ed)
W. Potts, Radiation Controls Manager (TMI)
R. Reithal, Environmental Controls (GPU)
R. Rogan, Manager, Emergency Preparedness (GPU)
M. Ross, Operations Superintendent (GPU) l T. Smith, Emergency Planning (GPU)
C. Smyth, Licensing Supervisor (Met-Ed)
J. Whitehead, Emergency Planning (NSS)
R. Zechman, Training (TMI)
Denotes those also present at the exit meeting.
2.
In addition to the above, members of the appraisal team also interviewed licensee members of plant operations, radiation protection, and corporate staffs.
l l
l
O
,a Additional Distribution of Inspection Report 50-289/81-20, March 5, 1982 Dr. Linda W. Little Administrative Judge
- Gary J. Edles, Chairman L.W. Little Associate Atomic Safety & Licensing Appeal 1312 Annapolis Dr., Suite 214 Board Panel U.S. Nuclear Regulatory Commission Raleigh, N.C.
27608 Washington, D. C.
20555 George F. Trowbridge, Esq.
- Christine N. Kohl Shaw, Pittman, Potts and Atomic Safety & Licensing Appeal Trowbridge Board Panel 1800 M Street, N.W.
U.S. Nuclear Regulatory Commission Washington, D. C.
20036 Washington, D.C.
20555 Robert Adler, Esq.
- Dr. John H. Buck 505 Executive House Atomic Safety & Licensing Appeal P. O. Box 2357 Harrisburg, Pennsylvania 17120 Board Panel U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Honorable Mark Cohen 512 D-3 Main Capital Bldg.
Harrisburg, Pennsylvania 17120
- Ivan W. Smith Administrative Judge Atomic Safety & Licensing Board Panel Ms. Marjorie Aamodt U.S. Nuclear Regulatory Commission R.D. f5 Washington, D. C.
20555 Coatesville, Pennsylvania 19320 Dr. Walter H. Jordan Mr. Thomas Gerusky Bureau of Radiation Protection Administrative Judge 881 W. Outer Drive Dept. of Environmental Resources Oak Ridge, Tennessee 37830 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Gary L. Milhollin, Esq.
1815 Jefferson Street Madison, Wisconsin 53711
I
,..
- Mr. Harvin I. Lewis 6504 Bradford Terrace
- Atomic Safety and Licensing Appeal Board.
.~
Philadelphia, PA 19149 U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. C. W. Smyth, Supervisor Licensing THI-1
- Atomic Safety and Licensing Board Panel Three Mile Island Nuclear Station U.S. Nuclear Regulatory Commission "9
idie n
ennsylvania 17057 Ms. Jane Lee
- Secretary R.D. 3; Box 3521 U.S. Nuclear Regulatory Commission Etters, PA 17319 ATTN:
Chief, Docketing & Service Br.
Walter W. Cohen, Consumer Advocate Department of Justice William S. Jordan, III, Esq.
Strawberry Square,14th Floor Harmon & Weiss Harrisburg, PA 17127 1725 I Street, N.W.
Suite 506 Thoraas J. Germine Washington, DC 20006 Deputy Attorney General Division of Law - Room 316 John Levin, Esq.
1100 Raymond Boulevard Pennsylvania Public Utilities Comm.
Newark, New Jersey 07102 Box 3265 Harrisburg, PA 17120 Allen R. Carter, Chairman Joint Legislative Comittee on Energy Jordan D. Cunningham, Esq.
Post Office Box 142 Fox, Farr and Cunningham Suite 513 2320 North 2nd Street Senate Gressette Building Harrisburg, PA 17110 Columbia, South Carolina 29202 Louise Bradford Robert Q. Pollard Three Mile Island Alert 609 Montpelier Street 1011 Green Street Baltimore, Maryland 21218 Harrisburg, PA 17102 Chauncey Kepford Ms. Ellyn R. Weiss Judith Johnsrud Harmon & Weiss Environmental Coalition on Nuclear Power 1725 I Street, N.W.
433 Orlando Avenue Suite 506 State College, PA 16801 Washington, DC 20006 Ms. Frieda Berryhill, Chairman Mr. Steven C. Sholly Coalition for Nuclear Power Plant Union of Concerned Scientists Postponement 1346 Connecticut Avenue, NW 2610 Grendon Drive Dupont Circle Building, Suite 1101 Wilmington, Delaware 19808 Washington, DC 20036 Gail Phelps ANGRY 245 W. Philadelphia Street York, Pennsylvania 17401
- Judge Reginald L. Gotchy Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory. Commission Washington, DC 20555
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