ML20148S178
| ML20148S178 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/27/1997 |
| From: | Wiggins J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Langenbach J GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20148S183 | List: |
| References | |
| 50-289-97-04, 50-289-97-4, EA-97-127, NUDOCS 9707080128 | |
| Download: ML20148S178 (4) | |
See also: IR 05000289/1997004
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June 27, 1997
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Mr. James W. Langenbach
Vice President and Director, TMI
GPU Nuclear Corporation
Three Mile Island Nuclear Station
P. O. Box 480
Middletown, PA 17057-0191
SUBJECT:
THREE MILE ISLAND REMEDIAL, EMERGENCY PREPAREDNESS EXERCISE
INSPECTION NO. 50-289/97-04 and NOTICE OF VIOLATION
Dear Mr. Langenbach:
This letter refers to the remedial emergency preparedness (EP) exercise inspection led by
Mr. J. Laughlin, at Three Mile Island Nuclear Generating Station, Middletown,
Pennsylvania, during the period of May 12-15,1997. The inspection evaluated the
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performance of your emergency response organization (ERO) during the May 13,1997,
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Three Mile Island remedial exercise; an exercise unclertaken due to the weak performance
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of the ERO during the March 5,1997 full-participation exercise. The inspection also
assessed the corrective actions taken by your staff to correct the four exercise
weaknesses identified in March. The NRC inspectors discussed the findings of this
inspection with you and your staff on May 15,1997. The findings were also presented to
you and your staff on May 28,1997, during a formal exit meeting, open for public
observation.
Overall, the performance of your ERO during the remedial exercise was good and showed
much improvement over the March 5 exercise. The weakness (inadequate dose
assessment activities) and unresolved item (PAR methodology not conforming to Federal
guidance) noted by the NRC during the April,1995 exercisa are closed. Remediation of
the four weaknesses displayed during the March exercise was adequately demonstrated
during this exercise, satisfying our concern from a performance standpoint. However, two
of those weaknesses (i.e., the failure to recognize a , aneral Emergency condition, and the
failure to assess the need for a protective action recommendation (PAR) outside 10 miles)
are apparent violations which remain open, pending consideration of escalated enforcement
action in accordance with the " General Statement of Policy and Procedure for NRC
Enforcement Actions," (Enforcement Policy) NUREG-1600. In keeping with our stated
enforcement policy, action may be appropriate where exercises reveal: 1) training,
procedural, or repetitive failures for which corrective actions have not been taken; 2) an
overall concern regarding the licensee's ability to implement its plan in a manner that
adequately protects public health and safety; or 3) poor self critiques of the licensee's
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exercises.
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Mr. James W. Langenbach
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The circumstances surrounding these apparent violations, the significance of the issues,
and the need for lasting and effective corrective action were discussed with you and your
staff at the exit meeting and the April 30 management meeting; as well as during the
inspection conducted during the remedial exercise. As a result, it may not be necessary to
conduct a predecisional enforcement conference in order to enable the NRC to make an
enforcement decision. However, a Notice of Violation is not presently being issued for
these inspection findings. Before the NRC makes its enforcement decision, we are
providing you an opportunity to either: 1) respond to the apparent violations addressed in
inspection report 97-02 within 30 days of the date of this letter or 2) request a
predecisional enforcement conference within 7 days of the date of this letter. Please
contact Michael Modes at (610) 337-5198 within 7 days of the date of this letter to notify
the NRC of your intended response.
Although EP program improvements were observed, three additional issues were identified
during the inspection of your corrective actions taken for the exercise weaknesses, not
directly a consequence of your remedial exercise, which we determined were not in
compliance with NRC requirements. First, there is no documentation of the continuous on-
line assessment or quick calculation computer codes used for dose projection calculations,
nor are there written procedures to aid dose assessors in performing those calculations.
This condition has existed since the April,1995 biennial exercise when the NRC brought to
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your attention an exercise weakness in the area of inadequate dose assessment.
Secondly, you assigned individuals to your ERO duty roster whose qualifications had
lapsed. Lastly, although the EP program audits identified the ERO qualification issue and
other deficiencies, the audit process was inadequate to correct those deficiencies. These
violations are a concern since they represent a failure to adequately resolve identified
problems over a prolonged period of time. They are cited in the enclosed Notice of
Violation (Notice) and the circumstances surrounding them are described in detail in the
subject inspection report.
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In summary, the four exercise weaknesses, two of which are apparent violations, and the
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three violations in the enclosed Notice, represent a significant degradation in your EP, and
potentially in your quality assurance audit program. We generally agree with your senior
management evaluation of the root causes for the poor exercise performance, that recent
management oversight and involvement in EP was not sufficient, and that management
expectations for support of the EP program must be clearly defined, communicated, and
continuously reinforced. We will closely monitor your progress on these issues in future
inspections of your EP program.
Please note that you are required to respond to this letter and should follow the
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instructions specified in the enclosed Notice when preparing your response. The NRC will
use your response, in part, to determine whether further enforcement action is necessary
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to ensure compliance with regulatory requirements.
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Mr. James W. Langenbach
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in accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter,
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its enclosures, and your response will be placed in the NRC Public Document Room (PDR).
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Sincerely,
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James T. Wiggins, Director
Division of Reactor Safety
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Docket No. 50-289
Enclosures:
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1. Inspection Report No. 50-289/97-04
2. TMl-1 Emergency Preparedness Root Cause Update and Progress Report
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3. Response to: Confirmatory Action Letter 1-97-011
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cc w/ encl:
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E. L. Blake, Shaw, Pittman, Potts and Trowbridge (Legal Counsel for GPUN)
Commonwealth of Pennsylvania
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J. C. Fornicola, Director, Licensing and Regulatory Affairs
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M. J. Ross, Director, Operations and Maintenance
TMI-Alert (TMIA)
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J. S. Wetmore, Manager, TMI Regulatory Affairs
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Mr. James W. Langenbach
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Distribution w/ encl:
Region i Docket Room (with concurrences)
NRC Resident inspector
Nuclear Safety Information Center (NSIC)
PUBLIC
J. Lieberman, OE
D. Holody, ORA
J. Wiggins, DRS
T. Kenny,DRS
P. Eselgroth, DRP
D. Haverkamp, DRP
C. O'Daniell, DRP
D. Screnci, PAO
T. Essig, NRR
D. Barss, NRR
DRS File
Distribution w/enci (VIA E-MAIL):
W. Dean, OEDO
P. Milano, NRR, PDI-3
Inspection Program Branch, NRR (IPAS)
R. Correia, NRR
R. Frahm, Jr., NRR
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