ML20148S178

Forwards Insp Rept 50-289/97-04 on 970512-15 & Nov.Insp Also Assessed Corrective Action Taken by Staff to Correct Four Exercise Weaknesses Identified in March

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: ML20148S178 ML20148S232
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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EA No.97-127

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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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

B. Buckley, PM, NRR, PDI-3

Inspection Program Branch, NRR (IPAS)

R. Correia, NRR

R. Frahm, Jr., NRR

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