ML20056D910
| ML20056D910 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/05/1993 |
| From: | Laughlin J, Mccabe E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20056D906 | List: |
| References | |
| 50-289-93-08, 50-289-93-8, NUDOCS 9308180277 | |
| Download: ML20056D910 (16) | |
See also: IR 05000289/1993008
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U. S. Nuclear Regulatory Commission
Region I
Docket / Report:
50-289/93-08
License: DPR-50
Licensee:
GPU Nuclear Corporation
P. O. Box 480
Middletown, Pennsylvania 17057
Facility Name:
Three Mile Island Nuclear Station Unit No.1
Inspection:
June 7-11,1993
Inspection At:
Londonderry and Susquehanna Townships, Pennsylvania
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Inspectors:
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M. Laughlin, $mergency /reparedness Specialist
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C. Gordon, Senior Emergency Preparedness Specialist
J. Lusher, Emergency Preparedness Specialist
Approved:
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E. McCabe, Chief, Emergency Preparedness Section
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Scope
Announced emergency preparedness (EP) prograra inspection including changes to the
Emergency Plan and implementing procedures, emergency facilities, equipment, instrumentation,
and supplies; organization and management control, training effectiveness, and audits / reviews.
The inspection also followed up on the NRC Incident Investigation Team report of the plant
intrusion by an unauthorized individual of February 7,1993. Inspection findings were based
on inspector observations, personnel interviews, and document reviews.
Results
Acceptable general program implementation was identified, with strengths in management
involvement, EP staff expertise, and Emergency Response Organization management training.
However, two apparent violations were identified: 1) delayed Emergency Response Organization
callout; and 2) Control Room fire doors without proper fire exit hardware. Training of
emergency communicators on callout procedure changes was identified as an unresolved item.
9308180277 930811
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ADOCK 05000289
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TABLE OF CONTENTS
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1.0
Persons Contacted
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2.0
Emergency Plan and Implementing Procedures
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2.1
Timeliness of Emergency Response Augmentation
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2.1.1 Callout Procedure Changes . . . . . . . . . . . . . . . . . . . . . . . . . 6
2.1.2 Training on Callout Procedure Changes . . . . . . . . . . . . . . . . .
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2.1.3 Retesting of Remote Callout
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2.2
Offsite Notifications . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
2.3
Radiological Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
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2.4
Emergency Plan Deviations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
2.5
Emergency Action Levels for a Security Event
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2.6
Site Accountability
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3.0
Emergency Facilities, Equipment, Instrumentation and Supplies
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3.1
Control Room Fire Doors . . . . . . . . . . . . . . . .' . . . . . . . . . . . . . . 9
3.2
Other Facilities and Equipment . . . . . . . . . . . . . . . . . . . . . . . . . .
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3.3
Alternate Facility Usage in an Emergency . . . . . . . . . . . . . . . . . . . . I1
4.0
Organization and Management Control . . . . . . . . . . . . . . . . . . . . . . . . . . . I 1
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5.0
Training
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5.1
Emergency Response Organization Manager Interviews . . . . . . . . . . .
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Independent and Internal Licensee Reviews and Audits . . . . . . . . . . . . . . . .
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7.0
Exit M eeti n g . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
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DETAILS
1.0
Persons Contacted
The following individuals were contacted during the inspection:
R. Boyer, Shift Supervisor
- G. Broughton, Vice President and Director, TMI-1
N. Brown, Lead _ Emergency Planner
W. County, TMI Quality Assurance Audit Manager
S. Cvijic, EP Training Instructor
G. Giangi, Manager, Corporate Emergency Preparedness
R. Goodrich, Senior Security Supervisor
J. Grisewood, Lead Offsite Emergency Planner
E. Hammond, Nuclear Safety Compliance Committee Staff Director
R. Harper, Plant Maintenance Director, TMI-1
- D. Hassler, Licensing Engineer
W. Heysek, Licensing Engineer
- R. Janati, Pennsylvania Bureau of Radiation Protection
R. Maag, Manager, Plant Maintenance
S. Mansfield, FPC Nuclear Team Instmetor
S. Mervine, Support Training Manager
- D. Moyer, Protection Training Lead Instructor
- T. O'Connor, Irad Fire Protection Engineer
J. Paules, Shift Supervisor
- M. Press, Quality Assurance Lead Auditor
D. Ranck, Site Protection Shift Supervisor
- R. Rogan, TMI Licensing Director
M. Ross, Operations and Maintenance Director
- E. Scheyder, Site Services Director
- H. Shipman, Plant Operations Director
- G. Simonetti Jr., TMI Emergency Preparedness Manager
G. Skillman, Engineering Director
- C. Smyth, Manager, Independent Onsite Safety Review Group
- J. Stacey, Site Security Manager
P. Walsh, Technical Functions Director
- M. Wells, Media Relations Manager
- S. Williams, Nuclear Safety Compliance Committee
- Denotes attendance at the exit meeting on June 17,1993.
The inspectors also interviewed and/or observed the actions of other licensee personnel.
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2.0
Emergency Plan and Implementing Procedures
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Inspectors reviewed the Emergency Plan (E-Plan), selected E-Plan Implementing Procedures,
and changes to these documents to ensure that proper review, approval, and related training was
completed. Procedures also were reviewed with respect to the issues identified in the NRC
Incident Investigation Team (IIT) Report of the February 7,1993 plant intrusion by an
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unauthorized individual at Three Mile Island (TMI), which resulted in declaration by the licensee
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of a Site Area Emergency (SAE).
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2.1
Timeliness of Emergency Response Notification
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The IIT report noted that the TMI E-Plan prescribed one hour from the time of notification of
an emergency for licensee emergency responders to report to their station. Specifically, Section
5.1 of the licensee's E-Plan stated, m part.
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The Initial Response Emergency Organization shall report to the duty station withm one
hour of notification of declaration of an Alert, Site Area Emergency or General
Emergency. The Emergency Support Organization shall be fully manned within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />
of notification of declaration of a Site Area or General Emergency; however, the
Emergency Support Director and designated members of the Emergency Operations
Facility staff will respond within one (1) hour....
Upon declaration of the SAE on February 7,1993, onshift personnel delayed Emergency
Response Organization (ERO) callout for about 47 minutes after event declaration, and the
Emergency Operations Facility (EOF) and the Technical Support Center (TSC) were not
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activated until about three hours after declaration. Callout was hampered by the locking of the
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Control Room fire doors during the security event, preventing entry into the Shift Supervisor's
office for normal ERO callout via the auto-dial pager system, and also inhibiting normal shift
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augmentation. Therefore, the ED directed one of the shift foremen to call emergency responders
by individually activating their pagers.
TMI Emergency Response Organization augmentation of the operating shift was by the Initial
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Response Emergency Organization (IREO) and by the Emergency Support Organization (ESO).
IREO personnel were required to report within one hour of notification; ESO personnel were
designated as either one-hour or four-hour responders (after notification). Times and numbers
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of designated IREO and ESO responders used in the following tables were obtained from the
report of the licensee's Site Emergency Review Group.
E-PLAN DESIGNATED RESPONSE TIMES
IREO Responders
ESO Responders
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One Hour After Notification
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Four Hours After Notification
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For the IREO (one-hour responders), response times after event declaration were as follows.
IREO RESPONDER DELAY
HOURS-MINUTES
(AFTER EVENT DECLARATION)
Earliest Responder
0*
Average Response Time
1 Hour 41 Minutes *
Latest Response Time
3 Hours 26 Minutes
- The licensee's Site Emergency Review Group Report omitted the arrival times of three
engineers (electrical, I&C, and mechanical); these were included in this calculation. Also, three
IREO responders were already on-shift and were included in the average response calculation.
Removing these individuals from the calculation produced an average response of two hours.
For one-hour ESO responders, response times after event declaration were as follows.
ONE-HOUR ESO RESPONDER DELAY
HOURS-MINUTES
(AFTER EVENT DECLARATION)
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Earliest Responder
0 Hours 35 Minutes
Average Response Time
2 Hours 15 Minutes
Latest Responder
3 Hours 20 Minutes
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- The Emergency Support Director (ESD), a one-hour responder, was called at 0752 and arrived
at the EOF at 0910; another ESD had, however, arrived at 0841. Therefore, the ESD response
time was based on arrival at 0841.
For four-hour ESO responders, response times after event declaration were as follows.
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4-HOUR ESO RESPONDER DELAY
HOURS-MINUTES
(AFTER EVENT DECLARATION)
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Earliest Responder
2 Hours 51 Minutes
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Average Response Time
3 Hours 20 Minutes'
Latest Responder
4 Hours 55 Minutes
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- This calculation does not include the Joint Information Center Presiding Media Briefer. That
individual reportedly arrived at the Joint Information Center within four hours, but no arrival
time was recorded.
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Two ERO personnel did not meet their one-hour-after-notification criterion: the second ECC
Communicator (IREO), who was called at 0928 and arrived at 1031, and the Emergency
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Operations Facility Public Information Representative (ESO), who was called at about 0910 and
arrived at 1025. These individuals were not notified to respond for more than two hours after
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event declaration and the delay in staffing these positions after event declaration was 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />,
26 minutes and 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />,20 minutes, respectively.
The latest four-hour responder (ESO), the Site Services Coordinator, arrived at least two hours
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and 55 minutes after being notified to respond. With the delay in notification, the delay from
event declaration to staffing this position was 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />,55 minutes.
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For this event, the licensee's Emergency Response Facilities were activated as follows (delay
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measured from event declaration).
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EMERGENCY RESPONSE FACILITY
ACTIVATION
ACTIVATION-
TIME
DELAY-
0955
2 Hours 50 Minutes
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1008
3 Hours 3 Minutes
Operations Support Center
~ 1000
~2 Hours 55 Minutes
Interview of the Manager, Corporate EP identified licensee management concern with the callout
delay and the expectation that callout would be done promptly upon declaration. Interviews with
other ERO members generally corroborated that expectation, but with some inconsistency. Two
shift supervisors said they would initiate callout immediately upon event declaration. Two senior
ERO members indicated that 15 minutes was the standard to begin ERO callout, two others
indicated a one-hour criterion for notification. Several other ERO members could not recall a -
specific criterion. These responses indicated that, although emergency response training called
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for initiating ERO callout as soon as possible after emergency declaration, a significant portion
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of the ERO managers did not recall the associated training.
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The licensee's E-Plan, Section 4.1, specified that each emergency classification was associated
with a particular set of immediate actions that included mobilization of the applicable portion of
the emergency organizations to cope with the situation and continue accident assessment
functions, and that activation and mobilization must occur if a prescribed emergency level was
declared. E-Plan Section 4.1.3 stated that, for a Site Area Emergency (SAE), all E-Plan related .
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actions (notifications, etc.) would be carried out in parallel with the remainder of the Operating
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Procedures. E-Plan Table 7A listed the actions to be taken for each class of emergency, and
specified that the emergency response facilities would be activated for a SAE.
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EPIP-TMI .02 (EPIP .02), Emergency Direction, Revision 1, dated 8/21/92, prescribed ERO
callout in the Emergency Director's (ED) checklist. Specifically, Step 1.2.2 stated:
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Assign a communications assistant (initially a maintenance technician) to notify
emergency personnel using the completed Part 4 of the Emergency Report Form -TMI
in accordance with EPIP-TMI .04, Contact /Callout of Emergency Personnel.
Although this instructed the ED to initiate the callout, it specified no timeliness standard for
callout initiation. That was in contrast with the bordered (boxed) note under Step 1.1.1, which
stipulated that offsite agency notifications (another immediate action) must be completed within
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15 minutes of event declaration, while Step 1.1.3 directed those notifications. Another bordered
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note under Step 1.2 stated that plant page announcements (another immediate action) should
occur within 15 minutes of event declaration. This inspection concluded that the listing of ERO
callout after the page announcement note and without specification of an ERO notification
timeliness criterion could contribute to failure to recognize ERO callout as an immediate action
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during 3 PIP .02 implementation.
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EPIP-TMI .04 (EPIP .04), Contact / Call Out of Emergency Personnel, Revision 6, dated
12/4/92, showed an expectation of immediate ER.O callout, in that a bordered note after Step
1 of that procedure instructed the ECC (Control Room) Communicator to seek out the ED or
ED Assistant and request Part 4 of the Emergency Report Form, used to perform callouts, ifit
was not received within 5 minutes of event declaration. The onshift instrumentation and control
(I&C) technician responded to the Control Room to accomplish this. However, the inspectors
also noted that EPIP .04 assumed that this person would respond to the Control Room within
5 minutes of event declaration to initiate callout without explicitly directing him/her to do so.
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This review of the February 7,1993 emergency response staffing concluded the following.
Timely emergency response callout was insufficiently specified in the implementing
procedures, in that there was insufficient carry-through of the E-Plan specification of
callout as an immediate action.
The failure to begin callout of the Emergency Response Organization for 47 minutes after
event declaration was an apparent violation of the E-Plan provision for immediate callout
of the Emergency Response Organization.
2.1.1 Callout Procedure Changes
Locking the Control Room fire doors during the security event resulted in the inability to use
the Shift Supervisor's office for offsite notifications and ERO callout. The licensee took
corrective action on this problem. EPIP .04, Revision 7, dated 2/19/93, specified callout from
a remote location if the Shift Supervisor's office was inaccessible. This revision provided for
callout from any Meridian telephone onsite, but response personnel would be contacted
individually since group pagers could not be used. Subsequently, EPIP .04, Revision 8, dated
4/22/93, provided for callout from any touch-tone telephone onsite and also provided for remote
activation of group pagers upon provision of pager numbers by the Shift Supervisor. This was
noted to be a significant improvement over previous revisions.
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2.1.2 Training on Callout Procedure Changes
Licensee documentation showed that 2 of the 33 I&C technicians who were designated to make
the ERO callout calls had received training on EPIP .04 Revision 7 during annual refresher
training. (Most had already had annual refresher training when this revision was implemented.)
A " read and sign" review sheet had been used to inform the other persons affected by the
change, but the I&C technicians were not included in this follow-up training. The licensee EP
Manager stated that he thought that all I&C technicians had received the training in their annual
refresher, when they actually had not.
Training on EPIP .04 Revision 8 was accomplished via a June 21,1993 memorandum from the
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EP Manager to affected ERO members. Personnel were required to review the change, then
sign and return a form for documentation. This was about two months after the effective date
of the change (and after the end of this NRC inspection).
The incomplete EPIP .04 Revision 7 training and delayed EPIP .04 Revision 8 training indicated
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a lack of training coordination between the EP and Training departments. Also, since 10 CFR 50.47(b)(15) required radiological response training for those who may be called on to assist in
an emergency, completeness and timeliness of related EP training was identified as unresolved
pending further NRC inspection (URI 50-289/93-08-01).
2.1.3 Retesting of Remote Callout
The licensee demonstrated that the remote callout function was operable before implementation,
but periodic retesting was not being accomplished. Further, most I&C technicians had not
actually performed the function from a remote location. No NRC requirement was identified
as having been violated, but the absence of periodic performance of the backup callout function
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by individuals who would be called upon to perform that function in an emergency was noted
as a potential flaw in training effectiveness and equipment operability assurance (IFI 50-289/93-
08-02).
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2.2
Offsite Notifications
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Locking the Control Room fire doors during the intrusion event also prevented access to the
telephone used to notify the Commonwealth and risk counties of the emergency. The ED
assigned this duty to the Shift Foreman (SF), who was not specifically trained to perform this
function. The person trained for this duty was the Control Room Operator (CRO), who became
the ECC Communications Coordinator during the emergency. There were four CROs in the
Control Room at the time of the event. The SAE was declared at 0707, though the ED recorded
the effective time as 0705. The Pennsylvania Emergency Management Agency was the last
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Commonwealth / local notification, at 0721, meeting the 15-minute criterion.
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NRC review concluded that, based on the circumstances and his qualification as a senior reactor
operator, the assignment of the SF to do offsite notifications was reasonable. An interview with
the intrusion event SS/ED revealed that, in an emergeacy, he preferred assigning the CROs to
monitor the control boards with one SF directing them, while he watched overall plant status.
He stated that he assumed that the SF was qualified to do the offsite notifications. He also stated
that he had been assigned the duty of making offsite notifications as SF in a drill (7/92), and did
not meet the 15 minute time limit. This was a licensee-identified finding and EP Action Item
which was closed out on May 5,1993 by providing on-the-job-training to all SROs on offsite
notification procedures.
(This was not intended to qualify them as Control Room
communicators.) The licensee also stated that this item was incorporated into Emergency -
Management training lessons learned. The inspector noted that this matter had become a repeat
licensee finding before corrective action was taken. Therefore, the timeliness of corrective
actions on such matters will be further reviewed. (IFI 50-289/93-08-03).
2.3
Radiological Assessment
The Group Radiological Controls Supervisor (GRCS) assumed the responsibility of Radiological
Assessment Coordinator (RAC) during the intrusion event, in accordance with the E-Plan. He
was informed by the ED to remain in the health physics lab, which is in the Operational Support
Center (OSC). The dose assessment program was available in the OSC and the RAC could have
performed dose projections there if called upon to do so. Later, dose assessment information
was available from the Technical Support Center (TSC), which was staffed in the Training
Center, and from the Emergency Operations Facility (EOF).
As the NRC Incident Investigation Team for this event noted, there was no specific licensee
consideration of the potential radiological consequences of intruder-caused damage. Additional
NRC review incident to this inspection noted that, because the plant remained stable with no
indication of damage and with no identification of intruder access to vital equipment, a
meaningful assessment of the magnitude and rate of potential radiation release was not
practicable. Therefore, while the licensee should have assessed this consideration during the
event, this specific failure to do so was not a safety-significant lapse.
2.4
Emergency Plan Deviations
The ED deviated from the E-Plan by not staffing the onsite TSC and OSC, and by assuming his
position in the Central Alarm Station (CAS)instead of the Control Room. The licensee's E-Plan
permits the ED to approve and direct deviations from established operating procedures,
emergency operating procedures, normal equipment operating limits, or technical specifications
during attempts to control a plant emergency. In this case, the ED verbally reported a 10 CFR 50.54(x) deviation from the Security Plan to NRC Region I, and the licensee followed that up -
with a Licensee Event Report, which also referred to E-Plan deviations. However, it was not
clear from licensee documentation when the deviations were implemented, or who specifically
approved them. Nor was the implementation specifically reported to the NRC Operations
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Center. The licensee identified this issue and committed to making procedural changes to
prevent recurrence. This was assessed as appropriate corrective action; its implementation will
be reviewed further (IFI 50-289/93-08-04).
2.5
Emergency Action Imrels for a Security Event
EPIP-TMI .01, Emergency Classification and Basis, Revision 2, dated 8/21/92, provided the
licensee Emergency Action Level (EAL) matrix for the classification of emergencies. Exhibit
3, Security, provided the matrix for security events. The EAL basis for a security threat Site
Area Emergency stated, on page E3-4, that the ED must obtain advice from the Site Protection
Shift Supervisor (SPSS) to determine the emergency classification. The SPSS was responsible
for providing information as to the perceived intent of the intruder. In this case, the ED
declared a SAE without consulting the SPSS. The licensee identified this in the their Site
Emergency Review Group (SERG) Report and noted that the ED communicated with a site
protection officer, a CAS operator, and the off-going SF, which constituted an acceptable
altemative to consulting with the SPSS. NRC review concluded that, although the ED appeared
to have sufficient information and made a proper emergency declaration, further licensee
assessment of the security-EP interface might be beneficial to assuring that the ED receives the
best possible information for related emergency classification decisions.
2.6
Site Personnel Accountability
The IIT Report of the February 7,1993 security event stated that personnel accountability was
completed by telephone and appeared to be effective. Since the event occurred on a Sunday
morning with few people onsite, security personnel were able to complete the process. The
report also stated that accountability could have been a problem if the event occurred during a
normal workday or an outage, with many more people onsite. Inspector interviews with licensee
staff revealed that onshift security personnel would necessarily be assigned to plant protection
activities as top priority. Therefore, during security events, the required timely accountability
of personnel may need to be assured by backup accountability provisions (IFI 50-289/93-08-05).
3.0
Emergency Facilities, Equipment, Instrumentation and Supplies
The inspector toured the Control Room (CR), Technical Support Center (TSC), Operational
Support Center (OSC), and the Emergency Operations Facility (EOF) to check for operational
readiness.
3.1
Control Room Fire Doors
The NRC Incident Investigation Team Report considered the use of deadbolts, keyed on both
sides, to lock the Control Room fire doors to be a personnel safety hazard, since the only key
available was in the Control Room. Further NRC review revealed that these doors, C415 and
C418, did not have proper fire exit hardware and that the installed deadbolts did not have a fire
rating that met the three-hour fire rating of these Control Room doors.
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The TMI Unit 1 Operating License, Section 2.c(4), Fire Protection, required the licensee to
implement and maintain in effect all provisions of the Fire Protection Program as described in
the Updated Final Safety Analysis Report (UFSAR). The UFSAR stipulated that plant fire
protection systems will comply with National Fire Protection Association (NFPA) and
Commonwealth of Pennsylvania codes. NFPA 101, Life Safety Code, stated that a latch or other
fastening device on a door shall be provided with a knob, handle, panic bar, or other simple type
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of releasing device, the method of operation of which is obvious, even in darkness. NFPA 80,
Standardfor Fire Doors and Windows, Section 1-4, defined a fire door assembly as any
combination of a fire door, frame, hardware, and other accessories which together provide a
specific degree of fire protection. NFPA 80, Section 2-8.2.1 stated that only labeled locks and
latches or labeled fire exit hardware (panic devices) meeting both life safety and fire protection
requirements could be used. The Control Room fire doors did not meet life safety criteria by
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having the proper fire exit hardware, i.e. retractable bolts which allowed egress without a key.
(Also, only one key was available.) Further, the doors were listed in the licensee's Fire Hazards
Analysis Report as having a 3-hour Underwriter Laboratory (UL) rating, but their locks did not
have an equivalent rating. The licensee had no record of when the locks were installed or who
approved the installation. This is an apparent violation of NRC requirements (VIO 50-289/93-
08-06).
Inspectors noted that the licensee had evaluated this issue from the standpoint of the locked fire -
doors preventing callouts and notifications. Subsequent to the February 7 intrusion event,
corrective action was taken to change the doors which are locked in an emergency so that only
one Control Room door is locked. That would allow access to the Shift Supervisor's office for
callouts and notifications. Action was taken to correct the personnel hazard after the inspectors
brought it to the licensee's attention during this inspection. The licensee proposed interim and
permanent corrective actions for the fire door locks. The interim solution was to replace the
non-UL deadbolts on Fire Doors C415 and C418 with available locksets that met fire egress
requirements by having deadbolt operating thumbknobs on the Control Room side. That was
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done on June 10,1993 and verified by NRC inspectors. Similar key-operated deadbolt locks
on four other doors, two from the SS's office, one from the I&C Office to the I&C Shop, and
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one from the I&C Shop to the hallway, also were to be replaced with deadbolts having
thumbknobs for egress by June 11,1993 or to have the deadbolts removed. As of June 17,
1993, that action had not been completed. The licensee's permanent solution was to replace all
six locks with UL-listed, fire-rated locks with a turn-piece or thumbknob on the occupant's side.
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After this inspection, the NRC Resident Inspector reported on August 5,1993 that this action
had been completed.
3.2
Other Facilities and Equipment
During review of facilities and equipment, the inspector found two Eberline RO-2A survey
instruments in Operational Support Center (OSC) Imcker 22 with the control switches turned on,
causing the batteries to be discharged. There were spare batteries readily available in the locker.
The Control Room locker contained an Eberline 140N survey instrument which had low batteries
and, again, spare batteries were available in the locker.
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The inspector tested the Emergency Notincation System (ENS) by calling the NRC Operations
Center in Bethesda, MD. The system functioned properly and the Operations Officer indicated
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that the reception was loud and clear. The Radiological Assessment Code computer in the
Control Room was observed to function properly. Also, the Meteorological Information Data
Acquisition System (MIDAS) was functioning as required.
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During the inspection of the OSC, the inspector used the checklist from Procedure 6400-ADM-
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1300.01, Exhibit 3, Revision 2, Unit 1 Operations Support Center (OSC),' to verify that the~
required equipment was available. It was noted that Item f, " Health Physics Network (HPN)
line," was not present. Upon further investigation the inspector found that, in 1992 when the
NRC implemented the FTS-2000 Telephone System, the NRC determined that the HPN line in
the OSC was no longer required. Therefore, during the changeover to FTS-2000, this phone
was eliminated. The HPN phone was removed from service in July 1992, but physically
remained in the OSC until February 1993, when it was removed. The Radiological Controls
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Director had noted on Exhibit 3 that the HPN phone was not applicable since he and EP
personnel knew that the phone was not required. He therefore indicated on Exhibit 8, the form
which is sent to EP for record purposes, that there were no discrepancies. This was potentially
confusing since the phone was there. The licensee immediately initiated a procedure change
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request to update procedure 6410-ADM-1300.01. The revision deleted Exhibit 8 and required
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that the exhibits for each of the facilities be modified so that conditions such as equipment
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present but not required would be noted on the checklist, signed by the responsible department
head or designee, and then forwarded to EP.
The inspector reviewed equipment inventory checklists frorn May 1992 through May 1993. The
Emergency Plan Administrative Procedure 6410-ADM-1300.05, Emergency Equipment
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Readiness, Revision 2, dated 12/4/92, Item 4.1.4, required that removed instruments be replaced
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with alternate equivalent instruments as soon as possible, but prior to the end of the shift.
However, an instrument listed on Attachment 17 (Part 1), Monthly Check of Emergency
Equipment, which was located in Warehouse #3, was out of service from May 19-27, 1992.
The licensee acknowledged this oversight, which the inspector concluded was a minor one.
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Licensee corrective action was found to be acceptable during the inspection.
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The ERO callout phone in the Shift Supervisor's office was tested during the monthly
communications equipment test. The alternate callout method, using any other Meridian
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telephone as indicated in Exhibit 2 of EPIP-TMI .04, Contact /Callout ofEmergency Persannel,
was not tested on a monthly basis. The licensee stated that the Meridian voice mail system was
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used on a daily basis and should not have to be tested during the monthly communication test.
However, as noted in Detail 2.1, regular testing of the alternate method would better assure
effective communications and system operability in an actual emergency.
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The inspector viewed the alternate plant shutdown panels located adjacent to the Technical
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Support Center.
Communications equipment in the TSC could be used for emergency
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notifications when operating from this location. State and local notifications would have to be
made by the alternate method as there was no auto-dialer phone system in the TSC.
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3.3
Alternate Facility Usage in an Emergency
The licensee's Site Emergency Review Group (SERG) Report identified, as Significant
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Effectiveness issue #12, Emergency Director response to an alternate facility instead of the CR
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in an emergency. This was assigned licensee licensing action item #93-9096 and given to the
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Operations and Maintenance Director for resolution, with a response date of June 30,1993. The
inspector requested that the licensee provide final resolution of this issue when completed (IFI
50-289/93-08-07).
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Other than the apparent violation concerning the Control Room fire doors, this area was
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acceptably implemented.
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4.0
Organization and Management Control
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Inspectors interviewed the Director, TMI-1, the Manager, Corporate EP, and the TMI
Emergency Preparedness Manager (EPM), and reviewed the EP Department structure to
determine the adequacy of EP Program administration. The TMI EPM had a full-time staff of
five, including senior reactor operator, technician, and health physics expertise. All had specific
department duties, including scenario-writing, which was done within the group. EP had a
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department assistant position for administrative support which was recently eliminated. The
EPM now shares a department assistant with the Manager, Corporate EP. Overall, department
staffing was stable.
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The EP Department was the responsibility of the Nuclear Assurance Division. Mr. C. Mascari
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had replaced Mr. P. Fiedler as the Vice President, Nuclear Assurance. The site EPM reported
through the Manager, Corporate EP to this vice president. There were no other changes in EP
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management responsibilities. Senior management interacted with site EP personnel through
quarterly staff meetings, site visits, and attendance at drills and exercises. The Manager,
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Corporate EP maintained an office at the TMI Emergency Operations Facility, and was
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accessible through frequent visits and phone conversations, though no formal meetmgs were
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scheduled with the site EPM.
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The Manager, Corporate EP rotated to the position of Training and Education Director from
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October 92 through January 93. During this time, the EPM functioned as the Manager,
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Corporate EP, and the Lead Offsite Planner became the EPM. The inspector noted that these
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temporary positions were a positive initiative to round out the 51evelopment of the participants.
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Key ERO positions were generally stable. One Group Leader, Radiological and Environmental
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Control, was replaced by a person experienced in health physics. There was no change in
Emergency Directors or Emergency Support Directors. The Initial Response Emergency
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Organization was three-deep in qualified staff in all positions except Operations Support Center
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Coordinator. An individual was being trained for that position and, when qualified, will be the
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third qualified OSC Coordinator. Personnel were assigned to a weekly duty roster and all
carried pagers for rapid recall. Emergency Suppon Organization (ESO) personnel were listed
on a quanerly duty roster and ESO positions were also three-deep in qualified personnel.
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The overall status of ERO staffing was assessed as very good, as was performance in EP
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program implementation in organization and management control aspects.
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5.0
Training
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The inspector interviewed the Support Training Manager and EP Training Instructor, reviewed
lesson plans, training records and other documentation to assess EP training program adequacy.
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EP training was under the cognizance of the Support Training Manager (STM), who reported '
to the Manager, Plant Training. The STM had a Protection Lead Instructor (PLI), in charge of-
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EP, security, and fire protection training. The PLI had two instructors, one of whom was the
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EP Instructor. The inspector reviewed the background and qualification records of the EP
Instructor. She had been working in training for about seven years, the last three of which were -
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in EP. Her qualification training was completed according to licensee procedures, and inspector
review noted no associated training inadequacy.
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The inspector reviewed the last EP Training Status Report. That repon was produced monthly
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by the EP Instructor and listed each ERO member by name, training courses required, and
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qualification status. All ERO personnel had received their required annual EP requalification
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training in the allotted time except one, and that one was still within the 3-month grace period.
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The inspector reviewed a sampling of training records to verify completion of training. These
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records were properly documented and easily retrievable, deconstrating effeedve training
documentation.
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The inspector reviewed the Emergency Management lesson plan used for Emergency Directors
(EDs), Emergency Support Directors (ESDs), their assistants, Radiological and Environmental
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Control Group leaders, and EP Representatives. That training was administered by EP
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Department personnel while the remainder was done by the EP Instructor. The inspector noted
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that initial qualification and requalification were different with requalification focusing on lessons
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learned, procedure changes, industry changes, and a table-top exercise. This was assessed as
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a good initiative. EP Department personnel periodically monitor the training provided by the -
Training Department to ensure quality.
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The licensee had no training requirement for drill participation or a practical densonstration of
ability prior to placing personnel on the duty roster. However, licensee policy for new ERO
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members was to provide classroom training, then have the person observe a drill, play in a drill
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under instruction, and actually have the position in a drill. That was assessed as a very good
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way to maintain the response capabilities by ERO personnel. The licensee was informed that
accurate documentation of such training was desirable.
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5.1
Emergency Response Organization Manager Interviews
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Inspectors interviewed five Emergency Support Directors (ESDs), four Emergency Directors
(EDs), and two Shift Supervisors (SSs) to assess the quality of Emergency Management training.
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The results were as follows:
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ED/SS personnel demonstrated a very good knowledge level on the questions asked. There was
consistent good knowledge of their responsibilities and the Protective Action Recommendation
(PAR) Imgic Diagram. Some areas for potential improvement were:
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Individuals were not consistent on the time available to the onshift crew to initiate callout
of the ERO.
They generally knew there was no specific guidance; some said
immediately, since they were trained that way, two said 15 minutes, one said I hour.
Also, one said that the NRC must be notified in 15 minutes. Generally, however, all
said it should be done as soon as possible.
Individuals were unclear on the location and performance of ERO callout. All knew that
the normal location was the SS office, but one did not know who was trained to do it.
All generally knew it could be done from the CR and that pager numbers were available
in the Shift Foreman's locker, but some were unclear how to use these numbers,
especially for calling from outside the CR. They generally knew that callout could be
done from the TSC, but were unsure of the method, i.e. one thought the " codes" were
available in the TSC, one thought there was an auto-dialer in the TSC.
ESD personnel generally demonstrated a very good knowledge level. Overall, training program
implementation was assessed as a strength.
6.0
Independent and Internal Licensee Reviews and Audits
Inspectors reviewed the 1991 and 1992 audit reports, and the 1992 audit plan and checklist. The
plan and checklist were thorough and reports were appropriately distributed to upper
management. There were no major findings in either report, only recommendations for
improvement, and no repeat items. Reports were properly forwarded to State and local officials,
meeting the requirements of 10 CFR 50.54(t).
Critiques and action items for ten drills and a graded exercise were reviewed by the inspector.
Critiques were generally well-written, with both positive and negative comments. An action
item in the review indicated that the tracking of trends for root cause analysis needed
improvement. For example: 1) There were several instances of pager system problems with no
final resolution; and 2) The issue of shift foremen performing offsite notifications, which
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occurred in the July 1992 drill, was repeated in the February 7,1993 intrusion event, while the
original item was not closed out until May 5,1993 (see Detail 2.2).
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Licensee Procedure 6410-SUR-1310.03, Action Item hacking System, Revision 2, dated 1/7/92,
required trending of action items on a semi-annual basis to determine adverse trends. That
procedure was replaced by 6400-ADM-1310.01, Action Item Tracking, Revision 0, dated
2/22/93, which still required the semi-annual review. NRC review concluded that the process
was a good initiative, but that it has not proven effective in identifying root causes for
resolution. The trending of action items will be reviewed for effectiveness in a future inspection -
(IFI 50-289/93-08-08).
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Except for the concern on trending and root cause analysis of corrective actions, this area was
being effectively implemented.
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7.0
Exit Meeting
The inspection team leader, EP Section Chief, and Deputy Director of the Division of Radiation
Safety and Safeguards met with the licensee personnel identified in Detail 1.0 on June 17,1993
to discuss the inspection findings. The licensee was informed of the apparent violations and of
the other areas of NRC concern. The licensee acknowledged the findings and indicated they
would be evaluated for appropriate corrective action.
The unresolved item was not discussed at the exit meeting; it resulted from information provided
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to the NRC subsequent to that meeting.
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