IR 05000289/2004006
| ML041320007 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/10/2004 |
| From: | Ray Lorson Division of Reactor Safety I |
| To: | Crane C AmerGen Energy Co |
| References | |
| IR-04-006 | |
| Download: ML041320007 (12) | |
Text
SUBJECT:
THREE MILE ISLAND UNIT 1 - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT NO. 05000289/2004006
Dear Mr. Crane:
On March 26, 2004, the U. S. Nuclear Regulatory Commission (NRC) completed a team inspection at the Three Mile Island Station Unit 1. The enclosed report documents the inspection findings which were discussed during an exit meeting on March 26, 2004, with Mr. B. Williams and other members of your staff.
This inspection was an examination of activities conducted under your license as they relate to the identification and resolution of problems, and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, plant walkdowns and interviews with personnel.
On the basis of the samples selected for review, there were no findings of significance identified during this inspection. The team concluded that, in general, problems were properly identified, evaluated and corrected. However, some minor problems were identified involving narrowly focused condition report evaluations.
In accordance with 10 CFR 10CFR2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Raymond K. Lorson, Chief Performance Evaluation Branch Division of Reactor Safety Docket No: 50-289 License No: DPR-50
Mr. Christopher cc w/encl:
Chief Operating Officer, AmerGen Site Vice President - TMI Unit 1, AmerGen Plant Manager - TMI, Unit 1, AmerGen Regulatory Assurance Manager - TMI, Unit 1, AmerGen Senior Vice President - Nuclear Services, AmerGen Vice President - Mid-Atlantic Operations, AmerGen Vice President - Operations Support, AmerGen Vice President - Licensing and Regulatory Affairs, AmerGen Director Licensing - AmerGen Manager Licensing - TMI, AmerGen Vice President - General Counsel and Secretary, AmerGen T. ONeill, Associate General Counsel, Exelon Generation Company J. Bradley Fewell, Assistant General Counsel, Exelon Nuclear Correspondence Control Desk - AmerGen Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry Township R. Janati, Chief, Division of Nuclear Safety M. Schoppman, Framatome ANP J. Johnsrud, National Energy Committee E. Epstein, TMI-Alert (TMIA)
D. Allard, PADER
Mr. Christopher Distribution w/encl:
Region I Docket Room (with concurrences)
H. Miller, RA J. Wiggins, DRA P. Eselgroth, DRP R. Barkley, DRP D. Kern, SRI J. Jolicoeur, OEDO R. Laufer, NRR D. Skay, PM, NRR T. Colburn, NRR W. Lanning, DRS R. Crlenjak, DRS J. Rogge, DRS R. Fuhrmeister, DRS DOCUMENT NAME: C:\ORPCheckout\FileNET\ML041320007.wpd After declaring this document An Official Agency Record it will be released to the Public.
To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure "N" = No copy OFFICE RI/DRS RI/DRP RI/DRS NAME RFuhrmeister PEselgroth RLorson DATE 05/06/04 05/10/04 05/10/04 05/ /04 05/ /04 OFFICIAL RECORD COPY
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Docket No: 50-289 License No: DPR-50 Report No: 05000289/2004006 Licensee: AmerGen Energy Company LLC Facility: Three Mile Island Station Unit 1 Location: P.O. Box 480 Middletown, PA 17057 Dates: March 8 - 12 and March 22 - 26, 2004 Inspectors: R. Fuhrmeister, Sr. Reactor Inspector, DRS J. Benjamin, Reactor Inspector, DRS C. Colantoni, Reactor Inspector, DRS J. Brand, Resident Inspector Approved By: Raymond K. Lorson, Chief Performance Evaluation Branch Division of Reactor Safety Enclosure
SUMMARY
OF ISSUES
IR 05000289-04-006; on 03/08-03/12/04 and 03/22-03/26/04; Three Mile Island Station Unit 1; biennial baseline inspection of the identification and resolution of problems.
The inspection was conducted by a regional senior reactor inspector, two regional reactor inspectors, and the site resident inspector. No findings of significance were identified during the inspection. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July 2000.
Identification and Resolution of Problems The team concluded that AmerGen Energy Company, LLC (AmerGen) was generally effective at identifying problems and entering them into the corrective action program. AmerGens effectiveness at problem identification was evidenced by the relatively few deficiencies identified by external organizations (including the NRC) that had not been previously identified by AmerGen during the review period. AmerGen effectively used risk in prioritizing the extent to which individual problems would be evaluated and in establishing schedules for implementing corrective actions. Corrective actions, when specified, were generally implemented in a timely manner. AmerGen audits and assessments were found to be effective and identified areas for improvement. On the basis of interviews conducted during this inspection, workers at the site utilized the corrective action program to identify problems.
NRC Identified and Self-Revealing Findings
None.
ii
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
a. Effectiveness of Problem Identification
- (1) Inspection Scope The team reviewed selected items across several high risk systems with repetitive problems, and non-cited violations (NCVs) issued since the last problem identification and resolution (PIR) team inspection, to determine if problems were properly identified, characterized, and entered into the corrective action program for evaluation and resolution. The condition reports (CRs) and other documents reviewed are listed in the to this report. The review included two audits of the corrective action program in addition to several additional AmerGen audits and self-assessments. The effectiveness of the audits and assessments was evaluated by comparing the audit and assessment results against self-revealing and NRC-identified findings.
The team evaluated the CRs to determine AmerGens threshold for identifying problems and entering them into the corrective action program. The team also reviewed other pertinent documents including control room logs, work requests, engineering modification packages, self-assessment results, system health reports, and results from surveillance tests and preventive maintenance tasks to determine whether the extent of condition for identified problems was properly considered. The team reviewed each CR to determine whether the evaluations were sufficiently detailed to identify the likely problem causes and to provide appropriate corrective actions. The team also reviewed the assessment of equipment operability and reportability where applicable.
The team conducted walkdowns and interviewed plant personnel to identify other processes that may have been used to identify problems. The team reviewed work requests to understand the interface between the corrective action program and the corrective maintenance process. The team interviewed plant personnel and reviewed the CR initiation data to determine whether personnel were knowledgeable of and utilized the corrective action system to identify problems.
- (2) Observations and Findings No findings of significance were identified.
The team determined that AmerGen was generally effective at identifying problems and entering them into the corrective action system. This was evidenced by the relatively few deficiencies identified by external organizations (including the NRC) that had not been previously identified by AmerGen during the review period. AmerGen audits and assessments were of good depth and identified issues similar to those that were self-revealing or raised during previous NRC inspections.
The team noted that a number of the selected CRs did not receive extent of condition reviews. While reviewing the corrective action program manual, the team noted that the responsibility for determining when an extent of condition review was required was not specifically assigned. This may have contributed to this issue. The team did not identify a violation associated with this observation.
b. Prioritization and Evaluation of Issues
- (1) Inspection Scope The team reviewed CRs listed in the Attachment to determine whether AmerGen adequately prioritized and evaluated the identified problems. Under the program, each problem is assigned a significance level of one through five. Significance level one is the highest level, and is used for issues that have a major plant impact. Significance level five is the lowest level, and is used for plant improvement items. AmerGen also assigns investigation classes to the problems: Class A requires a root cause evaluation, Class B requires an apparent cause evaluation, Class C requires a common cause evaluation, and Class D can be closed to trend or to an assigned action. No significance level one or two issues had been identified since the last PIR inspection.
The team compared the assigned significance level for selected CRs, including equipment-related CRs, to the applicable procedural guidance to determine whether the assigned significance level was appropriate. The team assessed the use of risk in prioritization of corrective actions by comparing the significance level criteria to the NRC Revised Oversight Program assessment criteria thresholds and Technical Specification allowed outage times.
- (2) Observations and Findings No findings of significance were identified.
The team determined that AmerGen specified corrective actions to correct the conditions identified in the CRs. The team also determined that AmerGen appropriately scheduled and tracked the assignments to completion. The team identified several instances where corrective actions were closed to work orders or action requests (ARs)without the work actually being completed. The Exelon corrective action procedure was revised in mid-2003 to preclude recurrence of this problem. The team did not find any risk significant issues which had been closed without completing the work.
The team concluded that AmerGen had been effective at utilizing risk insights to prioritize evaluations of and corrective actions for degraded conditions.
c. Effectiveness of Corrective Actions
- (1) Inspection Scope The team reviewed the corrective actions associated with the CRs and the other documents listed in the Attachment to determine whether the corrective actions addressed the identified causes and were scheduled or completed in a timely manner.
The team also reviewed the corrective actions to determine if there were risk significant items that had not been properly resolved that could adversely affect plant safety.
The review included the corrective actions taken by AmerGen in response to a prior violation (NCV-03-03-01, Severity Level IV) regarding the failure to report potentially disqualifying operator medical conditions to the NRC in a timely manner. The following documents were reviewed:
- CR-195798, License Coordinator Not Notified of Change In Operator Medical Condition, dated 1/16/04;
- CR-189592, No License Duties CRO Stood Watch, dated 12/8/03;
- CR-164042, License Operator Failure To Report Changes In Medical Condition, dated 6/19/03;
- NRC Inspection Report 05000289/2003003, dated 7/23/03;
- CR-159904, Late Report of Change in Medical Condition, dated 5/21/03;
- CR-152381, Results of Licensed Operator Medical Exam Self-Audit, dated 4/4/03;
- CR-143977, Audit of TMI Licensed Operator Medical Files, dated 2/11/03;
- CR-197500, Tracking of NRC Notification Not in Compliance With OP-AA-105-101, dated 1/26/04.
- (2) Observations and Findings No findings of significance were identified, however, the team identified one potential problem involving ineffective corrective actions. Specifically, CRs 164042, 189592, and 195798 documented examples where four individuals did not disclose information related to potentially disqualifying medical conditions to the license coordinator. The team identified that for three of these four operators, the conditions were not reported to the NRC within the required 30-day time frame. The time from when the individuals were aware of these conditions until the reporting requirement was recognized and the reports made to the NRC ranged from three to six months. In all cases, the conditions were adequately controlled by medical treatment.
The corrective actions for the prior problems were addressed in CR 143977 and CR 147624. These actions included the training of medical personnel and licensed operators and addition of a checklist to each licensed operator medical file. The teams review of this issue was on-going at the conclusion of the inspection period and was considered a potential violation of 10 CFR 50.74. This issue will remain unresolved pending further review by regional specialists. (URI 05000289/2004006-01)
4OA6 Management Meetings
On March 26, 2003, the team presented the inspection results to Mr. B. Williams and other members of the AmerGen staff . AmerGen acknowledged the findings presented.
Some of the information reviewed during the inspection was marked as proprietary.
Those documents were returned to AmerGen at the conclusion of the inspection.
ATTACHMENT KEY POINTS OF CONTACT Licensee Personnel B. Williams, Site Vice President G. Gellrich, Plant Manager L. Clewett, Director of Engineering G. Chick, Director of Maintenance G. Rombold, Manager of Regulatory Assurance J. Goldman, Plant Engineering Manager L. Brown, Nuclear Oversight Assessor B. Rittle, Maintenance Corrective Actions Coordinator S. Queen, Design Engineer W. Lopkoff, System Engineer A. Miller, Regulatory Assurance Engineer J. Tesmer, Regulatory Assurance Engineer E. Fuhrer, Regulatory Assurance Engineer LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED Opened/Closed 05000289/2004006-01 URI Potential violation for failure to notify the NRC regarding the change in the medical status of a licensed operator as required by 10 CFR 50.74.
(Section 4OA2.c.2)
LIST OF
DOCUMENTS REVIEWED
Condition Reports
00073622 00092697 00093689 00095011 00095753 00097198
00097786 00095371 00096371 00095469 00098680 00099502
00100720 00101994 00102515 00102525 00102002 00102219
00102461 00102572 00103021 00103920 00108821 00109205
00109226 00109861 00110300 00110306 00110314 00110331
00110406 00110903 00111236 00112412 00113437 00114597
00114940 00115285 00115310 00117760 00118154 00118572
00118780 00119399 00102037 00120792 00120480 00121122
00121152 00122996 00123736 00125511 00125792 00125895
00126106 00126271 00126703 00126765 00125847 00128048
00128054 00128057 00128144 00128460 00128565 00129296
00130263 00130713 00130725 00130728 00130838 00131570
00131573 00131765 00132061 00132062 00132502 00132810
00132878 00132880 00133744 00134131 00134168 00134474
00133960 00136995 00137261 00138244 00138783 00138778
00138874 00138930 00139182 00140699 00141090 00141285
00142559 00146995 00147688 00148150 00148233 00148380
00149119 00149291 00143176 00145497 00147808 00148233
00149855 00149885 00152511 00152522 00125538 00155773
00155825 00157427 00158324 00158863 00159445 00163056
00163646 00164725 00165028 00166913 00167117 00167468
00168055 00168068 00166931 00168068 00168106 00168357
00166674 00168676 00169251 00170213 00170728 00170841
00171529 00171925 00172002 00172013 00172142 00173089
00173252 00175247 00178928 00179254 00180343 00181732
00182311 00184752 00183266 00184753 00185821 00187352
00187846 00189173 00189501 00190679 00191452 00193169
00193807 00195104 00203254 00206114 00206819 00206114
206507 00206614 00207707 00207791 00207841 00207894
207914 00208003 00208044 00208553 00209210 00210181
210282
Action Requests
A1721547 A1802311 A2003830 A2003962 A2005094 A2007363
A2024270 A2025250 A2027508 A2028885 A2029975 A2048596
A2048676 A2053471 A2054230 A2057113 A2057824 A2083268
A2084672 A2084673 A2084674 A2084675 A2084676
Work Orders
C2003874 R1831797 R2008533 R2040298 R2040666 R2040668
R2040671 R2040675
Procedures
1041, Rev. 41, IST Program Requirements
1302-5.4A, Rev 1, RPS Channel A Reactor Coolant Flux Flow Comparator
1302-5.4, Rev 27, Reactor Coolant Flux Flow Comparator
1407-4, Rev. 60, TMI Lubrication Program
LS-AA-125, Rev. 4, Corrective Action Program (CAP) Procedure
LS-AA-125, Rev. 5, Corrective Action Program (CAP) Procedure
LS-AA-125, Rev. 6, Corrective Action Program (CAP) Procedure
LS-AA-125-1002, Rev. 1, Common Cause Analysis Report Format and Content
LS-AA-125-1006, Rev 5, Attachment 1, Guidance for Determining Investigation Class
LA-AA-125-1006, Rev 5, CAP Process Expectations Manual
LS-AA-105, Rev 1, Operability Determinations
M138, Rev. 11, Oil Sampling/Draining Oil from Operating Components
MA-AA-716-040, Rev. 2, Control of Pertable Measurement and Test Equipment Program
MA-AA-716-230, Rev 2, Predictive Maintenance Program
MA-AA-716-230-1001, Rev. 2, Oil Analysis Interpretation Guideline
MA-AA-716-230-1002, Rev 0, Vibration Analysis/Acceptance Guideline
MA-AA-716-230-1003, Rev. 0, Thermography Program Guide
OP-TM-214-203, Rev. 1, IST of ECCE Valves - BS Valves
Calculations
C-1101-641-5522-008, Rev 0, TMI-1 RC Pressure/Flow-Reactor Loop Error Analysis
C-1101-641-5522-008, Rev 1, TMI-1 RC Pressure/Flow-Reactor Loop Error Analysis
Miscellaneous Documents
CAP T1999-0307
CAP T2001-0042
CAP T2001-0552
CAP T2001-0276
Root Cause Assessment High Failure Rate 2003 Biennial Licensed Operator Requalification
Examination (Ref 00146995)
Three Mile Island Vibration Program Assessment October 9, 2002
Submittal of a Revised Request for Relief to the Requirements of 10CFR50.55a Concerning
Third Ten-Year Interval Inservice Testing Program, Date: March 10,2004, 5928-
04-20090
Submittal of a Request for Relief to the Requirements of 10CFR50.55a Concerning Third Ten-
Year Interval Inservice and Fourth Ten-Year Interval Inservice Testing Program, Date:
September 24, 2003, 5928-03-20194
Site Integrated Performance Assessment, Third and Fourth Quarters 2003 Report
LIST OF ACRONYMS
AR Action Request
CR Condition Report
NCV Non-Cited Violation
NRC Nuclear Regulatory Commission
PIR Problem Identification and Resolution
URI Unresolved Item