ML20236H600

Insp Repts 50-289/87-14 & 50-320/87-06 on 870720-24 & 0812-14.Violations Noted.Major Areas Inspected:Changes to Emergency Plan & Procedures,Readiness of Emergency Response Facilities & Shift Staffing & Augmentation

ML20236H600
Person / Time
Site:	Three Mile Island
Issue date:	10/20/1987
From:	Amato C, Fox E, Lazarus W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236H594	List: ML20236H591 ML20236H596 ML20236H600
References
50-289-87-14, 50-320-87-06, 50-320-87-6, NUDOCS 8711040225
Download: ML20236H600 (9)

See also: IR 05000289/1987014

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

50-289/87-14

Report Nos. 50-320/87-06

50-289

Docket Nos. 50-320

DRP-50

License Nos. DRP-73 Priority --

Category 1

Licensee: GPU Nuclear Corporation

Post Office Box 480 i

Middletown, PA 17057-0191 '

Facility Name: Three Mile Island Units 1 and 2

Inspection At: Middletown, Harrisburg and Susquehanna Township,

Pennsylvania; Parsippany, New Jersey; and

Kp g of Prussia, Pennsylvania

Inspection Conducted

July 20-24 and August 12-14, 1987  !

Inspectors: 0

C. G. Amat'o, EPS

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Approved by: [M (/' Mvr

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Inspection Summary: Inspection on July 20-24 and August 12-14, Combined Report )

Nos. 50-289/87-14 and 50-320/87-06). 1

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Areas Inspected: Routine, announced, emergency preparedness inspection. The I

inspection areas included: changes to the emergency plan and procedures;

readiness of Emergency Response Facilities; shift staffing and augmentation;

knowledge and performance of duties; licensee audits; response to an actual 3

Unusual Event; Emergency Preparedness-Security Interface; proposed changes to

Emergency Action Levels; and follow-up on previous inspection findings.

Results: One violation was identified regarding failure to submit emergency

plan revision to the NPC.

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DETAILS

1.0 Persons Contacted

C. Dell, Technical Analyst TMI-2 Licensing

G. Giangi, Manager Emergency Preparedness, GPUNC

D. Hassler, Licensing Engineer, TMI-I Licensing

H. Hukill, Vice President and Director, TMI-1

C. Incorvati, Manager, TMI Audits

D. Laudermilch, Support Training Manager, TMI Training

D. Klinepets, Protection Training Instructor, TMI Training

L. Robinson, Media Representative, GPUNC

l R. Rogan, Director, Licensing and Nuclear Safety

l 0. Shalikashvili, Manager Plant Training, TMI

l C. Smyth, Licensing Manager, TMI-1

G. Simonetti, Manager, TMI Emergency Preparedness

F. Standerfer, Vice President and Director, TMI-2

S. Otto, Licensing Engineer, TMI-1

The inspector also interviewed and observed the activities of other

licensee personnel.

2.0 Licensee Action on Previous Inspection Findings

- (Closed) 15-00-18 UNR Emergency Preparedness at Nuclear Power Reactor

FY-1987 Program.

NRC Inspection and Enforcement Office Temporary Instruction

2515/55 is followed and was applied during this inspection.

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(Closed) 79-10-16 IFN Inadequate guidance for Site Area Emergency

declaration.

TMI-1 Implementing Procedure 6410-IMP 1300.01 provides Site Area

Emergency classification guidance based on initiating conditions.

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(Closed) 79-10-17 INF Failure to train certain response team members.

A training program has been developed meeting the requirements of 10

CFR 50.47(b)(15) and is under the direction of the Manager for Plant

Training. Emergency Response Organization positions have been

identified and a training matrix and lesson plans have been

developed. Initial and annual requalification training is required.

Written and practical examinations are administered and records are

retained over plant life time. The proficiency of this training has

been demonstrated during NRC observed exercises.

(Closed) 79-10-19 INF Failure of the Plant Operation Review Committee

(PORC) to review and approve assembly and accountability procedure.

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l GPU Nuclear has developed an internal procedure, 1000 ADM-1291.01.

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Procedure for Nuclear Safety and Environment Impact Review and

Approval of Documents," for ensuring appropriate review and approval

of safety and environmentally related documents. A procedure for

assembly, muster and evacuation entitled " Emergency Assembly Area"

(6415-IMP-1300.36) has been developed, reviewed and approved in i

accordance with GPU review and approval procedures. The inspector

noted that the Plant Operating Review Group has been replaced by '

Safety and Plant Review Groups.

- (Closed) 50-82-BC-72 IFI Atomic Safety and Licensing Board (ASLB)

concerns as to the status of off-site emergency preparedness noted in

Docket 50-28-SP, Partial Initial Decision (Restart) of December 14,

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Based on a review of the contents of a letter to E. L. Jordan,

Director of Emergency Preparedness and Response, Office of Inspection

and Enforcement, USNRC from R. W. Krimm, Assistant Associate Director,

Office of Technical and Natural Hazards, USFEMA dated February 10,

1986, the inspectors concluded the Board's concerns had been

addressed by FEMA.

- (Closed) 50-83-BC-05 IFI Cycle 06. E0F and environmental E0F.

A dedicated Emergency' Operations Facility (E0F) and an Environmental

Accident Assessment Center (co-located with the E0F) have been

constructed beyond the ten mile Emergency Planning Zone (EPZ). This

Emergency Response Facility (ERF) has been designed to meet the

requirements of Section 8.4 of Supplement 1 to NUREG-0737 (Generic

Letter No. 82-33). Satisfactory functionality of these facilities

has been demonstrated during a number of exercises. The inspector

did note that an ERF appraisal has not been conducted and cycle 06

has not yet been completed.

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- (Closed) 50-84-26-01 IFI Emergency Director (ED) Training Emergency ]

Preparedness. l

A training program has been established for the ED level which

includes, senior licensed shift personnel, managers and executives.

A review of lesson plans, examinations, training records and

observations during past exercises indicates a satisfactory ED

training program is in place.

- (Closed) 50-85-23-08 IFI Adoption of IE IN 83-23 logic diagram and

associated Protective Action Recommendations.

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NRC Inspection and Enforcement Office, Information Notice No. 83-28

presents a logic diagram partially based on barrier breech analysis.

GPU Nuclear Corporation has modified this logic diagram to reflect

TMI specific needs and has include.d it in implementing procedure

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6410-IMP-1300.02 as Exhibit 3. Proposed Revision 01 to the

Corporate Emergency Plan commits GPU Nuclear to use this logic )

including development of Protective Action Recommendations (PARS)-

and t1mely communications of PARS to offsite authorities.

- (Closed)S0-86-20-06 IFI PTFC duty position and training matrix do

not coincide.

The inspector reviewed the Parsippany Technical Functions Center

(PTFC) staff roster, the PTFC Emergency Response Organization roster

and the training matrix. It was concluded that they now coincide. l

- (Closed) 50-86-20-05 IFI Additional training for call-out.

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A review of procedures, training records and the results of call-out

tests indicate effective call-out training has been provided.

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(Closed) 50-86-16-01 IFI Review Revision 0-00 to the GPU Nuclear

Emergency Plan for the Three Mile Island and Oyster Creek Nuclear

Stations (1000-PLN-1300.01); (Corporate Plan).

Revisions 0.00 and 1 were compared against the sub-items of this

IFI. Based on this review, all of the sub-items were closed.

- (Closed) 50-219/87-03 IFI During the 1987 Oyster Creek exercise, the

Parsippany Technical Functions Center Staff could not locate a j

drawing for a safety related valve, V-20-82.

The inspector noted that drawings for both Oyster Creek and TMI are

located and controlled at the Parsippany Technical Functions

Center (PTFC) Parsippany, New Jersey. The inspector conducted a

walkthrough at the PTFC and a PTFC staff member correctly located

the drawing and the valve,

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3.0 Operational Status of the En'ergency Preparedness Program

3.1 Changes to the Emergency Preparedness Program

The inspectors reviewed: the Corporate Plan, Unit I and 2 Procedures; i

inspected Document Distribution Center records; reviewed current l

Tables of Organization; and GPU Nuclear procedures prescribing

document, structure, use, and safety review and approval (Procedure

1000-ADM-1218.01, Rev. 2 and 1000-ADM-1219.01 Rev. 2).

The inspectors determined that changes had been made to procedures;  !

and these changes were correctly reviewed and the locator, type and

subject code and sequence numbers were in accord with the specifi-

cations of Exhibit 3, Rev. 1 to Procedures 1000-ADM-1218.01, Rev. 1.

All procedure change blocks contain appropriate signatures and the

approval of the Emergency Preparedness Manager. These conclusions

do not apply to the Parsippany Technical Functions Center (PTFC).

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.The Parsippany Technical Functions Center (PTFC) is classified as an

off-site Emergency Response Facility in Section 7.2.5 of the GPU

Nuclear Emergency Plan. Based on a review of the Corporate. Plan and

THI implementary procedures, it was identified that the operation.of

the PTFC was not described or defined.

Item V of Appendix E to 10 CFR 50 requires submittal to the NRC of

changes to Emergency Plans or Procedures within 30 days of such ,

changes. Contrary to this requirement, Revisions 1-04 (effective

June 2,1987) and 1-03 (no effective date) of " Operation of the

Parsippany Technical Functions Center," Procedure 5000-ADM-3054.01

(Revision 1-04, EPP-033), were not submitted to the NRC. This is a

violation.(50-289/87-14-02and50-320/87-06-02)

Based on the above findings, the inspectors concluded that (with the

exception of PTFL) changes have been appropriately incorporated into

procedures; review, approval and distribution are in accordance with l

established procedures.  ;

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3.2 Emergency Facilities, Equipment, Instrumentation and Supplies '

The inspectors toured and inspected Emergency Response Facilities

-(ERFs), auxiliary ERFs, the media center and assembly areas. It was

determined.that equipment, supplies, procedures, instrumentation and

communication equipment were in place. Instruments were operable and

in calibration; phones functioned; and procedures were current. j

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Based upon the above and the licensee's demonstration of these  !

facilities during previous exercises, the . inspectors concluded that 1

this portion of the licensee's emergency preparedness program is l

acceptable.

3.3 Management and Organization Control

The inspectors interviewed managers to determine their emergency '

preparedness involvement on a day-to-day basis; awareness of

emergency preparedness problems, procedure, and organizational

structure changes; and their Emergency Response Organization (ER0) ]

qualification status. The inspectors determined that management i

routinely tracks emergency preparedness status; managers are aware of

changes and maintain their ER0 qualification. The inspector noted

that there was one organizational change. A new Vice President has

recently been appointed to head Quality and Controls (emergency

preparedness is a unit within this organization). An evaluation of

this individual's involvement in emergency preparedness (EP) will be

performed in a subsequent inspection.

Based on the above, this area of the licensee emergency preparedness

program is acceptable.

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3.4 Training

The inspectors reviewed training records, matrices and lesson plans;

interviewed trainers and their managers; and conducted walkthroughs

with licensed operators. These activities were extended where

applicable to training of off-site, non-GPUNC personnel.

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Licensed operators receive four hours of emergency preparedness

training annually. On simulator, SR0s are expected to classify

accidents, make or direct notification to off-site authorities,

call-in initial and support organization personnel and form and

, comunicate Protective Action Recommendations. The licensee stated

I future quarterly drills will involve the simulator. One Unit 1

shift supervisor and 2 SR0s were walked-through brief, rapidly

breaking accident scenarios. Their responses indicated they cou'Id

correctly classify accidents; make off-site notifications; and

formulate Protective Action Recommendations.

Annual requalification is required; this is a repeat of initial

qualification plus introduction of new material reflecting plan and

procedure changes. This training is current and about 300 site

personnel are qualified for on-shift, in':tial and support Emergency

Organization positions for both units.

Parsippany Technical Functions Division (PTFD) personnel provide the

staff for the Parsippany Technical Functions Center. They receive

some Emergency Response Facility Operation training. Additional

training on a seminar basis may be given. PTFD personnel are

qualified technically based on their professional qualifications but

may not receive sufficient EP training. The adequacy of the

training level of these individuals will be assessed in a subsequent

inspection. (IFI-50-289/87-14-01 and 50-320/87-06-01).

Based on this review and with the exception of PTFD Training, the

inspector concluded site training is current, plan and procedures

changes are called to the attention of plant training; and operators

demonstrated acceptable proficiency within the limitations of the

mini-scenarios.

3.5 Licensee Independent / Audits

The annual, independent review / audit was conducted June 1987, in

accordance with 10 CFR 50.54(t) and GPUNC Procedure 6100-QAP-7218.01.

An audit matrix was developed; pre and post audit conferences were

held; drills were observed and drill packets studied; and training

records were reviewed. The audit report which is distributed to

upper management was issued on August 7, 1987; there were three

recommendations, one finding and several areas for improvement. The

finding related to a failure of the Communications Department to

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adhere to Corporate Administrative Procedures when preparing and

distributing the Emergency Public Information Plan. However the

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adequacy of Commonwealth / local governmental interface was evaluated

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Based on this review, this portion of the licensee emergency

l preparedness program is acceptable.

4.0 Unusual Event of May 9, 1987

On the morning of Saturday, May 9, 1987, all dedicated, emergency

response phone lines failed, including the Emergency Notification

System (ENS). An Unusual Event was declared, back-up systems were

used, the NRC was notified, and steps were taken to notify the

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Commonwealth and local governments. The ba d-up microwave system

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(a tie line) functioned and Unit 1 Control Rcom staff contacted the

company dispatcher at both Reading and Lebanon. These dispatchers

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patched calls to NRC's Headquarters and attempted to contact directly  ;

and indirectly the Pennsylvania Emergency Management Agency (PEMA)  !

and Dauphin County Emergency Operations Center (E0C). In addition,

Unit 1 staff activated a tone alerter which sounds in the Dauphin

County E0C; however, there was no response. Dauphin County was j

eventually notified by Lebanon County. The pager system used to  ;

alert off-duty Emergency Response Organization staff would not

function. Communications with the Emergency Operations Facility if

needed, would not have been possible by phone, however, alternative

methods were available.  ;

The cause of the phone system inoperability was a failure of Pennsylvania ,

Bell's Rectifiers and subsequent discharge of system batteries. Attempt

to place stand-bys in service failed. A major switching failure between

Central Offices resulted, and switching calls in and out of Harrisburg was

impossible. Normal and special use circuits including dedicated emergency ,

lines were affected. However, normal phone service on the Three Mile Site {

was not affected. Total System Service was restored at 1:00 P.M. May 9th. l

Bell of Pennsylvania is investigating steps to prevent a re-occurrence and i

estimated the probability of such a failure of this type as once in ten

years.

As a result of this incident, revised notification procedures requiring

the use, if neeoed, of all possible alternate communication links has been

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issued. (TMI-1 Procedure 6410-IMP-1300.03, Rev. 3). Instructions for s

using the site ambulance radio are also included. In addition, the l

licensee is looking into the feasibility of establishing back-up radio j

communications directly with PEMA. Action in this area will be reviewed j

in a subsequent inspection. (IFI-50-289/87-14-03 and 50-320/87-06-03) '

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! 5.0 Communication and Pager Call-In Tests ,

The inspectors reviewed records for each of these tests for the past 12

. consecutive months and observed a radiopager call-in test. Results

indicated 83% of personnel paged responded. These individuals staff

Initial and Support Organizations for both units. In all cases adequate

staffing would have been available. The reasons given for failure to

establish contact were: pager malfunction; pager dead battery, beyond

pager range; and pager not carried by individual. ,

Tests of the emergency communications systems (ECS) indicated satisfactory

performance. However, there were three malfunctions of ENS and HPN (NRC

responsibility) identified. For three months there were no malfunctions

and for six months minor malfunctions in the ECS were identified; all  ;

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malfunctions in the ECS were corrected within one to three days.

Based on a review of these results, the inspectors concluded that the

licensee surveillance procedure is followed and is adequate to determine

operability of systems under licensee control. However, additional

emphasis should be placed on the importance of personnel, particularly

managers, to carry pagers at all times.

6.0 Security / Emergency Preparedness Interface j

The inspector interviewed members of the Security organization and

reviewed the current emergency plan and emergency organization to

determine security interface / involvement in emergency response. The basis

for this review was NUREG/CR-4093, " Safety / Safeguards Interactions During j

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Safety Related Emergencies at Nuclear Power Facilities".

The inspector determined that security is involved in emergency l

preparedness exercises and the current organization (Emergency Plan,

Section 5.2.7.2.d(16), figures 17 through 19) does provide for security

interface in emergencies. Additionally, the inspector noted that

provisions for emergency response in the form of security procedures and a

plan are available to the security force. These appear to fit with

emergency preparedness. Discussions with security personnel indicated

that training for a contaminated environment, other than General Employee i

Training, was not provided.

It appears that functions which will be provided by off-site response

agencies have been identified and coordinated, and that the coordination

mechanisms necessary to assure the required support will be available

during Security Related Emergencies (SREs). The current organization

allows for coordination between the security and emergency response

organizations to take place at the plant site level and that the existing

chain of command and organization arrangements for security have not been

modified substantially for SREs.

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Based upon the above, it appears security involvement in emergency

preparedness is specified but its interface with operations will have to

be followed-up during a future inspection (IFI-50-289/87-14-04 and

50-320/87-06-04).

7.0 Public Information

The inspectors selected at random a number of Pennsylvania Bell and

Donnelly Telephone directories and determined all contained a seven page

insert advising the public of what steps to take in the event of an

incident at TMI. These inserts contained maps showing evacuation routes

and listed the call letters and frequencies of Emergency Broadcast

Stations.

Based on this review, this portion of the licensee emergency preparedness

program is acceptable.

8.0 Revision 1 to the Corporate Emergency Plan

Revision 1 is based on the altered status of Unit 2 from active

reactor to one in Post Defueling Monitored Storage (PDMS). GPUNC

representatives have stated Rev. I will not be implemented until NRC

approves it. GPUNC will then revise procedures, as needed, and train

staff in the revisions. The NRC review is on-going. Review comments

have been provided to the licensee. No significant inadequacies were

identified.

9.0 Communications System Failure of August 13, 1987

At approximately, 9:40 a.m. on August 13, 1987, a sewer construction crew

working in Swatara Township cut a Bell of Pennsylvania Cable carrying all

dedicated lines from Three Mile Island including ENS. All site lines

continued to function but service to and from Harrisburg was not possible.

The ENS control room phone blinking light indicated a malfunction and the

licensee confirmed the loss. The back-up microwave, company tie line was

used to reach the Reading Dispatcher. The NRC, the Commonwealth of

Pennsylvania and the counties were notified. Service was restored to ENS

at 5:46 p.m. and complete restoration was effected by 7:15 p.m. Licensee

response was appropriate.

10.0 Exit Meeting

The inspectors met with licensee personnel noted in Section 1 at the

conclusion of the inspection. The licensee was informed of the findings

as detailed in this report. The licensee acknowledged these findings and

agreed to evaluate them and institute corrective actions as appropriate.

At no time during the inspection was written material provided to the

licensee by the inspectors.

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