IR 05000289/2004006

IR 05000289-04-006, on 03/08-04 Through 03/12/04 & 03/22/04 Through 03/26/04, for Three Mile Island Station Unit 1; Biennial Baseline Inspection of Identification and Resolution of Problems

ML041320007
Person / Time
Site:	Crane
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

May 10, 2004

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

Enclosure 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

ii 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.

REPORT DETAILS

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

203254

206114

206819

206114

206507

206614

207707

207791

207841

207894

207914

208003

208044

208553

209210

210181

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,

28-

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