Text

IR 05000289-14-002, 01/01/2014-03/31/2014; Three Mile Island, Unit 1, Equipment Alignment, Fire Protection, Surveillance Testing
	ML14134A500
Person / Time
Site:	Three Mile Island
Issue date:	05/14/2014
From:	Kevin Mangan; NRC/RGN-I/DRP/PB6
To:	Pacilio M; Exelon Nuclear
	MANGAN, KA
References
	IR-14-002
	Download: ML14134A500 (46)
	v • d • e

UNITED STATES May 14, 2014

SUBJECT:

THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED INSPECTION REPORT 5000289/2014002

Dear Mr. Pacilio:

On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report documents the inspection results, which were discussed on April 18, 2014, with Mark Newcomer, TMI Plant Manager, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.

The inspectors reviewed selected procedures and records, observed activities and interviewed personnel.

This report documents one self-revealing and two NRC-identified findings of very low safety significance (Green). Two of these findings were determined to involve violations of NRC requirements. Additionally, the NRC has determined that one traditional enforcement Severity Level IV violation occurred and was associated with one of the findings contained in this report.

However, because of their very low safety significance, and because it was entered into your corrective action program, the NRC is treating the findings as NCVs, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Three Mile Island. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Three Mile Island.

Additionally, as we informed you in the most recent NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter 0310.

Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. If you disagree with the cross cutting aspect assigned, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Three Mile Island.

In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs 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/

Kevin A. Mangan, Acting Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-289 License Nos.: DPR-50

Enclosure:

Inspection Report 05000289/2014002 w/Attachment: Supplemental Information

REGION I==

Docket No: 50-289 License No: DPR-50 Report No: 05000289/2014002 Licensee: Exelon Generation Company Facility: Three Mile Island Station, Unit 1 Location: Middletown, PA 17057 Dates: January 1 through March 31, 2014 Inspectors:

D. Werkheiser, Senior Resident Inspector, Division of Reactor Projects (DRP)

J. Heinly, Resident Inspector, DRP S. Barr, Senior Emergency Preparedness Inspector, Division of Reactor Safety (DRS)

E. Burket, Emergency Preparedness Inspector, DRS C. Cahill, Senior Risk Analyst, DRS W. Cook, Senior Risk Analyst , DRS T. OHara, Reactor Inspector, DRS R. Rolph, Health Physicist Inspector, DRS Approved by: K. Mangan, Chief (Acting)

Projects Branch 6 Division of Reactor Projects (DRP)

Enclosure

SUMMARY

IR 05000289/2014002, 01/01/2014-03/31/2014; Three Mile Island, Unit 1, Equipment Alignment,

Fire Protection, Surveillance Testing.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified three findings of very low safety significance (Green) of which one was a Severity Level IV non-cited violation (NCV) and one is an NCV. The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP), dated June 2, 2011. Cross-cutting aspects are determined using IMC 0310, Components Within Cross-Cutting Areas, dated December 19, 2013. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5, dated February 2014.

Cornerstone: Mitigating Systems

Green/SL-IV. The inspectors identified a Severity Level IV (SL-IV), Non-Cited Violation of 10 CFR 50.59, Changes, Tests, and Experiments, and an associated finding of very low safety significance (Green) for Exelons failure to perform a 50.59 evaluation review to determine whether a license amendment was required to align the borated water storage tank (BWST) to non-seismic piping. Specifically, Exelon staffs 50.59 screening accepted the alignment of the seismically qualified BWST to a non-seismically qualified clean-up system. The inspectors determined the alignment would involve a change to the BWST that adversely affects its Updated Final Safety Analysis Report chapter 5.1.1, Classes of Structures and Systems for Seismic Design, described design function of being seismically qualified. Additionally, the inspectors determined that following the 50.59 review Exelon placed the line-up in service. The inspectors determined these two actions were performance deficiencies that were reasonably within Exelons ability to foresee and prevent. Furthermore, the 50.59 screening credited unapproved operator manual actions to ensure functionality of the BWST. Exelon documented this as issue report 1631468 and implemented interim corrective actions to isolate the BWST from the clean-up system until a permanent resolution is determined and implemented.

The inspectors determined the 50.59 violation regarding the failure to perform an evaluation was more than minor because the inspectors could not reasonably determine that the alignment would not have ultimately required NRC prior approval, because the BWST alignment was not in accordance with the current licensing basis and the evaluation credited the use of unapproved operator manual actions. The inspectors also determined that the performance deficiency of accepting and aligning the adverse clean-up line-up, challenging the BWST seismic qualification, was more than minor because it adversely affected the Mitigating Systems cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings At-Power, and determined that this finding required a detailed risk evaluation. The detailed evaluation was performed which determined that the performance deficiency was a finding of very low safety significance (Green). Additionally, In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, the 50.59 violation is categorized as a Severity Level IV.

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution,

Operating Experience, in that the station did not effectively evaluate and internalize relevant external operating experience (Information Notice (IN) 2012-01) regarding connections between safety-related seismic and non-seismic qualified piping and components (P.5)

(Section 1R04)

Green.

The inspectors identified a finding of very low safety significant (Green) for Exelons failure to follow work order instructions in accordance with MA-AA-716-011, Work Execution and Close Out, during planned maintenance activities on the air intake tunnel (AIT) deluge sump pump (SD-P-7). Specifically, in May 2013, a maintenance worker applied epoxy to the sump pumps float switch contrary to work order instructions. Inspectors identified that the float switch was fixed in the OFF position, rendering the pump unavailable, during a system walkdown in March 2014. Exelon documented this as issue report 1628577 and performed prompt corrective actions to remove the epoxy coating from the float switch. In addition, corrective actions were performed to replace the float ball that likely was submerged and filled with water as a result of the float switch being stuck. Exelon successfully post-maintenance tested the float switch and pump on March 6, 2014, and returned it to service.

The inspectors determined the performance deficiency associated with this finding involved Exelons failure to follow work order instructions in accordance with MA-AA-716-011, Work Execution and Close Out, during planned maintenance activities on SD-P-7 was more than minor because it was associated with mitigating systems cornerstone adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, in May 2013, a technician applied epoxy to SD-P-7s float switch, contrary to work order instructions, rendering the pump non-functional. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 4, External Events Screening Questions, and determined, based on operator response to an air intake tunnel deluge alarm, this finding to be of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance because the worker did not follow work order instructions and incorrectly applied epoxy to the SD-P-7 float switch assembly, rendering the pump non-functional and unavailable (H.8). (Section 1R05)

Green.

A self-revealing non-cited violation (NCV) of 10 CFR 50.63, Loss of All Alternating Current Power, was identified for Exelons failure to properly restore the station blackout (SBO) diesel generator system following maintenance and testing activities, rendering the SBO diesel generator unable to be available in 10 minutes of and cope for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after a postulated SBO event. Specifically, during the restoration from SBO switchgear maintenance during the previous Fall 2013 refueling outage, operators failed to remove a blocking device (gag) from the SBO diesel generator fire service water cooling isolation valve (FS-V-646) as part of its restoration to an automatic, standby configuration. As a result the SBO diesel generator was not in the configuration required by 10 CFR 50.63 (c)(2), which describes acceptable capability standards for alternate AC power systems. Exelon entered this issue into their corrective action program as IR 1608625. Exelon restored the valve configuration and revised affected and related procedures.

The inspectors determined this performance deficiency in that Exelon failed to remove the blocking devise from FS-V-646 prior to restoring the SBO diesel to service was more than minor because it is associated with the mitigating systems affecting the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, in the event of a station blackout, the SBO diesel generator was not able to be started and operated from the control room with no local operations required to allow the prompt restoration of electrical power to at least one vital bus as assumed in the TMI SBO analysis. The inspectors evaluated the finding using IMC 0609, Attachment 4, Initial Characterization of Findings, and Appendix A,

The Significance Determination Process for Findings At-Power, and determined that this finding required a detailed risk evaluation because, with FS-V-646 gagged, the SBO diesel was not capable of performing its safety function. The detailed risk evaluation determined the finding to be of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelons procedure for restoration from the maintenance and testing (OP-TM-731-510, Rev. 5) was not adequate to specify actions to return the cooling water isolation valve (FS-V-646) to its normal automatic condition [H.7]. (Section 1R22)

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On January 5, 2014, operators reduced power to approximately 87 percent in response to a slow closure of turbine control valve 1. Following repairs, operators returned the unit to 100 percent on January 6, 2014.

On February 17, 2014, operators reduced power to 50 percent power for emergent repairs on the A natural draft cooling tower. The repairs were completed and the unit was returned to 100 percent on February 21, 2014. The unit remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

[R]

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 External Flooding

a. Inspection Scope

During the weeks of January 16, and March 10, 2014, the inspectors performed an inspection of the external flood protection measures for Three Mile Island (TMI). The inspectors reviewed TSs, procedures, design documents, and the Updated Final Safety Analysis Report (UFSAR), Chapter 2.4.2.4, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by internal flooding. The inspectors conducted a general site walk-down of all external areas of the plant, including a detailed external and internal inspection of the station effluent exhaust duct to ensure that protection measures were maintained in accordance with design specifications. The duct is a credited external flood boundary which had not had a prior detailed internal/external flood inspection, as documented in issue report (IR) 1467101. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if Exelon planned or established adequate measures to protect against external flooding events.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Exelons preparations for the onset of severe cold weather conditions on January 7, 2014. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during this adverse weather condition. The inspectors walked down the emergency diesel generators and river water systems to ensure system availability during extreme cold temperatures. In addition, the inspectors validated that the intake de-icing lines were operating to prevent frazzle ice formation. The inspectors verified that actions defined in Exelons adverse weather procedure for TMI maintained the readiness of essential systems. Finally, the inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.

b. Findings

No findings were identified.

1R04 Equipment Alignment

Partial System Walkdowns (71111.04Q - 4 samples)

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

A Nuclear Service closed pump following return from maintenance on February 7, 2014 Borated water storage tank during cleanup alignment on February 20, 2014 Reactor coolant make-up system during A make-up pump system outage on March 4, 2014 Engineered-safety actuation system during relay replacement under WO R2222569 on March 25, 2014 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, TSs, work orders, issue reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findings

Introduction.

The inspectors identified a Severity Level IV (SL-IV), Non-Cited Violation of 10 CFR 50.59, Changes, Tests, and Experiments, and an associated finding of very low safety significance (Green) for Exelons failure to perform a 50.59 evaluation review to determine whether a license amendment was required to align the borated water storage tank (BWST) to non-seismic piping. Specifically, Exelon staffs 50.59 screening incorrectly accepted the alignment of the seismically qualified BWST to a non-seismically qualified clean-up system and placed the line-up in-service.

Description.

In January 2012, the NRC issued Information Notice (IN) 2012-01, Seismic Considerations - Principally Issues Involving Tanks which contained recent operating experience related to seismic concerns. Specifically, the IN documented recent examples of licensees that aligned non-seismic piping to seismically qualified, safety-related tanks during operation contrary to their TS and licensing basis. The inspectors determined that TMIs BWST is the seismically qualified, safety-related source of water used for inventory makeup to the reactor coolant system (RCS), as described in UFSAR 5.1.1., during power operations and Exelon routinely aligns the BWST to a non-seismically qualified clean-up system piping through manual isolation valves for source term reduction and particulate removal.

Exelon reviewed IN 2012-01 and documented IR 1421916 to evaluate whether the alignment of the BWST from the non-seismically qualified clean-up system is acceptable. During the review, Exelon took immediate compensatory actions and isolated the BWST from the clean-up system until the TS and licensing basis implications were understood. Exelon engineering performed a 10 CFR 50.59 screening to validate that the alignment of the BWST to the clean-up system is within the current licensing basis. Exelon concluded in their 10 CFR 50.59 screening that aligning the BWST to the clean-up system was acceptable in accordance with the licensing basis of TMI; did not adversely impact its UFSAR described design function; and therefore NRC approval via a license amendment was not required in order to use this system configuration. Subsequently, Exelon resumed clean-up of the BWST with the non-seismic qualified piping on June 1, 2013.

The inspectors reviewed the 10 CFR 50.59 screening and BWST licensing basis and determined that aligning the BWST to non-seismically qualified pipe is contrary to its licensing basis function as described in UFSAR 5.1.1. In addition, the inspectors noted that in the 10 CFR 50.59 screening Exelon credited operator actions to manually restore functionality of the BWST following a seismic event. To credit the use of operator actions in lieu of automatic actions, the inspectors concluded that Exelon would require prior NRC approval. Therefore, the screening evaluation should have required a full 10 CFR 50.59 evaluation and reasonable likelihood existed that NRC approval would have been required. The inspectors communicated their safety concerns on March 10, 2014 to Exelon and were document in IR 1631468. Again, TMI implemented immediate interim corrective actions to isolate the BWST from the clean-up system until a permanent resolution is established.

Analysis.

The inspectors determined that Exelons failure to perform an adequate 10 CFR 50.59, Changes, Tests, and Experiments, evaluation of the BWST piping alignment to maintain the seismic licensing basis requirements was a performance deficiency that was reasonably within Exelons ability to foresee and correct and should have been prevented. The performance deficiency was dispositioned using the traditional enforcement process because it could potentially impede or impact the regulatory process. The inspectors evaluated the violation using the NRC Enforcement Manual, Appendix E, and determined it to be more than minor because the inspectors could not reasonably determine that the alignment would not have ultimately required NRC prior approval, because the BWST alignment was not in accordance with the current licensing basis and the evaluation credited the use of unapproved operator manual actions.

The NRC Enforcement Policy and NRC IMC 0612 Appendix B, Issue Screening, direct the inspectors to evaluate traditional enforcement violations under the SDP, if applicable, in order to determine the significance of the violation. Although the performance deficiencies are related to a common regulatory concern, the SDP does not specifically consider the regulatory process impact so it is necessary to address the performance deficiency using both processes to correctly reflect the regulatory importance of the violation and the safety significance of the associated finding. The inspectors determined this violation has an associated finding when evaluated by the SDP, as described below, and can therefore be communicated with an SDP color reflective of the safety impact of the deficient licensee performance.

The inspectors determined the performance deficiency which resulted in Exelon aligning the BWST to non-seismic clean-up piping is more than minor because it is associated with the protection against external factors attribute of the Mitigating Systems cornerstone and impacted the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, by aligning the BWST to non-seismic clean-up piping, the BWST would not be able to perform its function during a seismic safe shutdown event.

The inspectors evaluated the finding using Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, and determined that this finding was potentially risk significant due to a seismic external event and therefore required a detailed risk evaluation. A detailed evaluation was performed by a regional SRA using the NRC TMI SPAR model. A bounding one year exposure period was utilized. No recovery of the BWST was assumed. The non-seismic piping was assumed to fail at the same seismic input as that assumed for a loss of offsite power (LOOP). The seismically induced loss of offsite power initiating event frequency for TMI was obtained from the Risk Assessment of Operational Events (RASP) Handbook Vol. 2 - External Events, Appendix 1, Table 1. The dominant sequence was a seismically induced non-recoverable loss of offsite power with a failure to control emergency feedwater flow and failure of feed and bleed due to loss of the BWST leading to core damage. The risk was mitigated by the low probability of a seismic event resulting in a LOOP and the use of a dedicated operator for isolation of the non-seismic piping. The analysis determined that the risk increase of the performance deficiency was an increase in core damage frequency less than 1E-6/year, a finding of very low safety significance (Green). Since TMI has a large dry containment and steam generator tube ruptures were not an event of concern for this performance deficiency, an evaluation of a large early release frequency (LERF) was not required.

Therefore, in accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation is categorized as a Severity Level IV, because the issue was evaluated as having very low safety significance (Green) by the SDP.

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Operating Experience, in that the station did not effectively evaluate and internalize relevant external operating experience (IN 2012-01) regarding connections between safety-related seismic and non-seismic qualified piping and components (P.5)

Enforcement.

10 CFR 50.59, Changes, Tests, and Experiments, Section (d)(1), in part, requires a written evaluation which provides the bases for the determination that the change, test, or experiment does not require a license amendment pursuant to paragraph (c)(2). Contrary to the above, Exelon 50.59 screening evaluation did not provide an adequate bases to determine the alignment of the BWST to non-seismic clean-up piping did not require a license amendment prior to implementing the change.

Specifically, from January 2012 to March 2014, Exelon aligned the BWST to non-seismic clean-up piping based upon an inadequate 10 CFR 50.59 screening that incorrectly determined that the alignment was acceptable per the licensing basis and that operator manual action could be used to restore functionality after a seismic event without prior NRC review. Exelons immediate corrective actions included isolating the non-seismic flow path and entering this issue into their CAP as IR 1631468.

Although this violation was evaluated for significance and characterized using both the traditional enforcement and SDP processes, it is considered a single enforcement action and single input into the NRC Plant Assessment process as described in IMC 0305, Operating Reactor Assessment Program.

In accordance with Section 6.1.d.2 of the NRC Enforcement Policy, this violation is categorized as a Severity Level IV, because the resulting conditions were evaluated as having very low safety significance (Green) by the SDP. Because this violation was of very low safety significance and was entered into Exelons CAP (IR 1631468), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (SLIV/NCV05000289/2014002-01, Failure to Perform a 10 CFR 50.59 Evaluation for the BWST Seismic Qualifications)

1R05 Fire Protection

Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

ESAS Room, CB-FA-3D, on January 24, 2014 Natural draft cooling tower A, U1 NDCT A, on February 20, 2014 Fuel Handling Building, FH-FZ-5, on February 24, 2014 Air Intake Tunnel, AIT-FZ-1/1A, on March 3, 2014 Fuel Handling Building, FH-FZ-1, on March 31, 2014

b. Findings

Introduction.

The inspectors identified a finding of very low safety significant (Green) for Exelons failure to follow work order instructions in accordance with MA-AA-716-011, Work Execution and Close Out, during planned maintenance activities on the air intake tunnel (AIT) deluge sump pump. Specifically, in May 2013, a maintenance worker applied epoxy to the sump pumps float switch contrary to work order instructions. This condition resulted in the float switch being fixed in the OFF position, rendering the pump unavailable from May 2013 to March 2014.

Description.

On March 3, 2014 the inspectors performed an inspection of the AIT sump pump area and noted that the baseplate for deluge sump pump (SD-P-7) had been coated with a protective epoxy coating. Upon closer inspection, the inspector determined that the float switch was coated with the epoxy coating, locking it in the OFF position. Exelon confirmed that the float switch would not operate in the as-found condition and the pump was declared unavailable.

The inspectors reviewed the UFSAR and found that TMI is designed with an AIT to protect the air supply to safety-related buildings. The AIT contains a fire deluge system to protect against fire hazards. The inspectors noted that in the event of the actuation of the fire deluge system, the AIT has a sump pump that will start using a float switch and will remove the deluge fire water from the AIT. SD-P-7 is designed to remove water at the rate it enters from all fire protection equipment such that the water does not fill the AIT and create an internal flooding concern for safety-related components. Additionally, the inspectors found that if a deluge of the AIT were to occur, a main control alarm is received and operators have written procedures to a secure deluge, if necessary, to prevent deluge system water from entering the Auxiliary and Fuel Handling Buildings and impact safety-related equipment. Finally, the inspectors found that SD-P-7 performs a defense-in-depth function during a design basis external flooding event. Specifically, the capacity of the pump is credited to mitigate leakage past the flood barrier system.

Exelon performed an evaluation of the as-found condition and identified that a work order was performed in May 2013 to clean and epoxy the baseplate of the pump motor, where the float switch is mounted. The work order instruction required the technician to protect nearby surfaces and equipment from coatings material as required. In addition, MA-AA-716-011, Work Execution and Close Out, requires workers to perform activities in accordance with approved work instructions. Exelon concluded that, contrary to the above, the technician did not protect SD-P-7 supporting equipment and incorrectly coated the float switch, rendering the pump non-functional and unavailable. Exelon entered the issue into their CAP under IR 1628577 and performed prompt corrective actions to remove the epoxy coating from the float switch. In addition, corrective actions were performed to replace the float ball that likely was submerged and filled with water as a result of the float switch being stuck. Exelon successfully post-maintenance tested the float switch and pump on March 6, 2014 and returned it to service. The inspectors reviewed the corrective actions and determined them to be reasonable.

Analysis.

The inspected determined that Exelons failure to follow work order instructions in accordance with MA-AA-716-011, Work Execution and Close Out, during planned maintenance activities on SD-P-7 was a performance deficiency that was reasonably within Exelons ability to foresee and correct and should have been prevented. This finding is more than minor because it was associated with the human performance attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, in May 2013, a technician applied epoxy to SD-P-7s float switch contrary to work order instructions rendering the pump non-functional and unavailable from May 2013 to March 2014. The inspectors evaluated the finding using Manual Chapter 0609, Attachment 4, Initial Characterization of Findings, and Appendix A, The Significance Determination Process for Findings At-Power, and Exhibit 4, External Events Screening Questions, because the loss of function of SD-P-7 specifically affects internal flood mitigation.

Based on operator response to an air intake tunnel deluge alarm, the inspectors determined the finding to be of very low safety significance (Green) because the finding did not directly cause a plant trip or initiating event; would not degrade two or more trains of a multi-train system or function; would not degrade one or more trains of a system that supports a risk significant system or function; and would not involve the total loss of any safety function.

This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because the worker did not follow work order instructions and incorrectly applied epoxy to the SD-P-7 float switch assembly, rendering the pump non-functional and unavailable (H.8).

Enforcement.

This finding does not involve enforcement action because no violation of a regulatory requirement was identified. Because this finding does not involve a violation and is of very low safety significance, it is identified as a FIN. (FIN 05000289/2014002-02, Loss of Air Intake Tunnel Sump Pump Function due to Inadequate Work Execution)

1R06 Flood Protection Measures

Main article: IP 71111.06

The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.

Planned yellow station risk and emergent ESAS relay replacement on January 9, 2014 Heat-sink protection system testing during a grid Maximum Generation Action on January 30, 2014 Planned maintenance on the 1C battery charger with the station air compressor (IA-P-4) out of service on March 3, 2014 Planned removal of the A make-up pump and C battery charger from service on March 4, 2014 Emergent ESAS relay (63Z3B/RB2A) replacement on March 25, 2014

b. Findings

No findings were identified.

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:

Increased closure time of the reactor building purge valve (AH-V-1) documented in IR 1605812, on Feb 8, 2014 Condensate storage supply evaluation for emergency feedwater pumps as documented in IR 1621232 on February 20, 2014 Anomalies during fire service pump loss of power testing documented in IR 1625375, on February 24, 2014 Borated water storage tank operability when on clean-up while critical as documented in IR 1631468 on March 10, 2014 Pressurizer level instrument (RC-LT-777) calibration issues documented in A2286065-E3 and IR 1630769 on March 26, 2014 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to Exelons evaluations to determine whether the components or systems were operable.

Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

Main article: IP 71111.19

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

1303-5.2A, High pressure injection logic and component test, after 63Z2A-RCZA ESAS relay replacement, on January 10, 2014 OP-TM-541-208, A nuclear service pump in-service testing after bearing replacement under WO C2031412, on February 7, 2014 OP-TM-826-202, IST of AH-P-3B and valves, after check-valve maintenance, on February 26, 2014 OP-TM-211-205, A make-up pump in-service test after system outage window maintained under WO R2231522, on March 5, 2014 OP-TM-541-203, IST of NS-V-52C and 53C after valve actuator maintenance, on March 12, 2014 1303-11.39A, Emergency feedwater initiation test, after heat-sink protection system card replacement under WO C2031310-04, on March 21, 2014

b. Findings

No findings were identified.

1R22 Surveillance Testing

Main article: IP 71111.22

a. Inspection Scope

The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:

1107-9, SBO Diesel Generator, on January 15, 2014 1302-6.17, HSPS Emergency Feedwater Initiation on Loss of Feedwater, on January 17, 2014 OP-TM-533-201, IST of DR-P-1A and Valves, on January 26, 2014 (in-service test)

OP-TM-534-210, IST of RR-V-5 and RR-V-6, on February 25, 2014 (in-service test)

IC-10, Level Switch/Indicator Functional Check, on March 8, 2014

b. Findings

Introduction.

A Green, self-revealing non-cited violation (NCV) of 10 CFR 50.63, Loss of All Alternating Current Power, was identified for Exelons failure to properly restore the station blackout (SBO) diesel generator system following maintenance and testing activities. As a result the SBO diesel generator was unable to be available in 10 minutes of and cope for four hours after a postulated SBO event. Specifically, during the restoration from switchgear maintenance during the previous Fall 2013 refueling outage, operators failed to ungag the SBO diesel generator fire service water cooling isolation valve (FS-V-646) as part of its restoration to an automatic, standby operation.

Description.

On January 15, 2014, during quarterly testing of the SBO diesel generator, in accordance with 1107-9, SBO Diesel Generator, the control room received an SBO D/G Running Coolant Flow Lo after SBO diesel generator start. A local operator confirmed no coolant flow. The control room operators entered Alarm Response Procedure SBO-4-2, which specifies cooling water flow should be established within three minutes of starting the diesel engine to prevent overheating, and secured the SBO diesel generator to investigate the cause and inspect the machine for damage. Exelon determined that no temperature limits were exceeded and no damage was identified.

Exelon performed a walkdown of the cooling water system and identified the fire service water cooling isolation valve (FS-V-646) for the SBO diesel generator cooling system was closed with the gagging device T-handle turned-in (gagged) which prevented the valve from repositioning open as required during SBO diesel generator operation.

Exelon initiated immediate corrective actions to ungag valve FS-V-646 and performed a valve position verification of the SBO cooling system. Exelon documented this issue in their CAP as IR 1608625 and initiated a root cause investigation. Additional corrective actions were implemented to revise procedures to include quantitative criteria to verify the position of FS-V-646, and similar valves, and reinforce stop-work criteria.

Exelon determined that during the Fall 2013 refueling outage, on November 11, 2014, while restoring from maintenance under procedure OP-TM-731-510, De-energizing 1F 4160V SBO Switchgear, Rev. 5, valve FS-V-646 gagging device was not turned-out (ungagged) when the procedure step specified returning the valve to automatic operation. Exelons root cause evaluation determined the cause was inadequate instruction in the procedure step to restore the valve to automatic operation and to verify the valve is not gagged. This conclusion is consistent with the inspectors review of the procedure.

The inspectors determined that the SBO diesel generator serves as an alternative AC power source for plant shutdown loads under the station blackout rule (10 CFR 50.63).

The inspectors reviewed Report 990-1879, Three Mile Island Unit 1 Station Blackout Evaluation Report, and determined that TMI is required to make the SBO diesel generator available in 10 minutes of and capable to cope for four hours after a station blackout event to allow prompt restoration of electrical power to at least one vital bus.

As a result of the failure to reposition the valve gagging devise, the inspectors determined that the SBO diesel generator was not automatically capable of performing this function. The inspectors also reviewed Alarm Response Procedure SBO-4-2, which specifies cooling water flow should be established within three minutes of starting the diesel engine to prevent overheating. The inspectors noted that for operator actions to successfully respond to a control room SBO diesel trouble alarm the operators would have to report to the SBO diesel room; diagnose the cause Coolant Flow LO with Diesel On alarm condition at the local alarm panel; and then open/ungag FS-V-646 within a short time span. Additionally, the inspectors noted that the operator actions would have been significantly challenged based upon the actual concurrent inoperability of local emergency lighting in the SBO building and dependence upon use of portable lighting.

Therefore, the inspectors concluded that the SBO diesel generator was not available to supply back-up power, within the 10 minutes required by analysis, from November 11, 2013 through January 15, 2014, while FS-V-646 was gagged closed.

Analysis.

The inspectors determined Exelons failure to ungag SBO diesel generator cooling isolation valve (FS-V-646) and properly restore the station blackout (SBO) diesel generator system following maintenance and testing activities was a performance deficiency and was reasonably within Exelons ability to foresee and prevented. The performance deficiency is more than minor, because it is associated with the Mitigating Systems cornerstone attribute of procedure quality and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the SBO diesel generator was not able to be started and operated from the control room, with no local operations, in order to promptly restore electrical power to at least one vital bus in the event of a station blackout.

This performance deficiency required a detailed risk evaluation (DRE) in accordance with IMC 0609.04, Initial Characterization of Findings, and IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, Exhibit 2, Mitigating Systems Screening Questions, because, with FS-V-646 gagged, the SBO diesel was not capable of performing its safety function; therefore, required a detailed risk evaluation (DRE). Specifically, during remote start of the SBO from the control room FS-V-646 would not automatically open resulting in overheating of the diesel engine unless operator action to promptly respond to a control room SBO diesel trouble alarm; diagnose the cause of the Coolant Flow LO with Diesel On alarm condition at the local alarm panel; and then open/ungag FS-V-646 within a short time span was successful.

Regional SRA inspectors conducted a DRE. The SRA used the TMI Standardized Plant Analysis Risk (SPAR) Model, Version 8.19 and the Systems Analysis Program for Hands-on Integrated Reliability Evaluations (SAPHIRE) software, Revision 8.0.9, to estimate a low E-7 per year range increase in core damage frequency using the following assumptions:

Basic event - EPS-AOV-CC-V646, Air-Operated Valve FS-V-646 Fails on Demand, failure probability changed from its nominal value of 9.51E-4 to 1.0 to replicate the failure to open automatically on the SBO diesel start signal Exposure time is 64 days - based upon the time of discovery (January 15, 2014)back to the day the valve was improperly restored (November 11, 2013) from a protective tag-out configuration All other basic events and initiating events were left at nominal values and the normal test and maintenance model was run An operator recovery credit of 0.19 was used based upon a detailed evaluation using NUREG/CR-6883, SPAR-H Human Reliability Analysis Method, and the associated SPAR Human Error Worksheets The SPAR model dominant core damage sequences involve steam line breaks in the turbine building (plant-related offsite power sources compromised) with a subsequent loss of both emergency diesel generators and resulting small break loss of coolant accidents (LOCAs) via the reactor coolant pump seals upon loss of seal cooling. Other dominant sequences involve loss of offsite power events (grid, switchyard, and weather-related) and the subsequent loss of emergency AC and resultant seal LOCAs. Because the SBO diesel is not safety-related or specifically credited for fire, flooding, or seismic event mitigation, there is no external event contribution to overall risk. Using IMC 0609, Appendix H, Containment Integrity SDP, the SRA determined that there is no significant risk associated with large early release frequency (LERF). Accordingly, the safety significance of the failure to properly restore the SBO diesel generator fire service water cooling system to a standby configuration was of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelons procedure for restoration from the maintenance and testing (OP-TM-731-510, Rev. 5) was not adequate to specify actions to return the cooling water isolation valve (FS-V-646) to its normal automatic condition [H.7].

Enforcement.

10 CFR 50.63 (c)(2), states, in part, that the alternate ac power source, as defined in section 50.2, will constitute acceptable capability to withstand station blackout provided the plant has this capability from onset of the station blackout until the alternate ac source(s) and required shutdown equipment are started and lined up to operate.

Three Mile Island Unit 1 Station Blackout Evaluation Report 990-1879 identifies the SBO diesel generator as the alternate AC power source, that the SBO diesel generator will be available to provide emergency power to safe shutdown buses within 10 minutes from the onset of an SBO event, and specifies that TMI is required to cope for four hours after an SBO event.

Contrary to the above, from November 11, 2013, to January 15, 2014, Exelon did not have an analyzed capability to respond to a station blackout until the alternate AC source was available. Specifically, the SBO diesel generator would have been required to be shut down to prevent high engine temperature due to a gagged cooling water isolation valve (FS-V-646) if required to operate during a SBO event. This condition rendered the SBO diesel generator unable to be available in 10 minutes, as assumed in Exelons coping analysis, and cope for four hours after a postulated SBO event. Exelon corrective actions to restore compliance included ungagged and verified proper operation of FS-V-646 and successfully tested the SBO diesel generator. Because this violation was of very low safety significance and was entered into Exelons CAP (IR 1608625), this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000289/2014002-03, Failure to Restore Station Blackout Diesel Generator Cooling Water Lineup following Maintenance and Testing Activities)

Cornerstone: Emergency Preparedness [EP]

1EP2 Alert and Notification System Evaluation (71114.02 - 1 Sample)

The inspectors reviewed a number of activities to evaluate the efficacy of Exelons efforts to maintain the TMI emergency preparedness (EP) program. The inspectors reviewed: letters of agreement with offsite agencies; the 10 CFR 50.54(q) emergency plan change process and practice; TMIs maintenance of equipment important to EP; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary and backup emergency response facility (ERF) maintenance.

The inspectors also verified Exelons compliance at TMI with NRC EP regulations regarding: emergency action levels for hostile action events; protective actions for on-site personnel during events; emergency declaration timeliness; ERO augmentation and alternate facility capability; evacuation time estimate updates; on-shift ERO staffing analysis; and, ANS back-up means.

The inspectors further evaluated Exelons ability to maintain their TMI EP program through their identification and correction of EP weaknesses, by reviewing a sample of drill reports, actual event reports, self-assessments, 10 CFR 50.54(t) reviews, and EP-related condition reports. The inspectors reviewed a sample of EP-related condition reports initiated at TMI from March 2012 through January 2014. The inspection was conducted with Title 10 CFR 50.47(b) and the related requirements of 10 CFR Part 50, Appendix E, as reference criteria.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a focused area drill of crew C ERO section leads on March 4, 2014, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities.

The inspectors observed emergency response operations in the technical support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate Exelons critique and to verify whether the Exelon staff was properly identifying weaknesses and entering them into the corrective action program.

b. Findings

No findings were identified.

RADIATION SAFETY

[RS]

Cornerstones: Public and Occupational Radiation Safety

2RS1 Radiological Hazard Assessment and Exposure Controls

Main article: IP 71124.01

a. Inspection Scope

During March 24 - 28, 2014, the inspector reviewed Exelons performance in assessing the radiological hazards and exposure control in the workplace. The inspector used the requirements in 10 CFR Part 20 and guidance in Regulatory Guide (RG) 8.38 Control of Access to High and Very High Radiation Areas for Nuclear Plants, TSs, and the Exelon procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspector reviewed the results of radiation protection (RP) program audits. The inspector reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection.

Radiological Hazard Assessment The inspector determined if any changes to plant operations, since the last inspection, may have resulted in any new radiological hazards. The inspector evaluated whether Exelon assessed the impact of these changes. The inspector reviewed the last two radiological surveys of make-up pumps A, B, and C. The inspector conducted walk-downs and independent radiation measurements in the facility, including the chemical addition room, all levels of the auxiliary building, and the spent fuel pool.

The inspector selected the following risk-significant work activities for review:

Control rod drive replacement during TMI Unit 1 refueling outage (T1R20)

Scaffolding during T1R20 Reactor coolant pump seal replacement during T1R20 For these work activities, the inspector reviewed surveys performed and evaluated the radiological survey program to determine if radiological hazards were properly identified.

The inspector reviewed the use of continuous air monitors. The inspector reviewed the monitoring of contamination in the plant.

Instructions to Workers The inspector reviewed the radiation work permits (RWP) used to access high radiation areas (HRA) and evaluated if the specified work control instructions and control For the RWPs reviewed, the inspector assessed permissible dose for work under each RWP and Electronic Personal Dosimeter (EPD) alarm set-points. Additionally, the inspector reviewed two occurrences where a workers EPD malfunctioned or alarmed. The inspector assessed whether the issue was included in the corrective action program and whether compensatory dose evaluations were conducted as appropriate.

Radiological Hazards Control and Work Coverage The inspector reviewed plant radiological conditions and performed independent radiation measurements during walk-downs of the facility. The inspector assessed whether the conditions were consistent with applicable posted surveys, RWPs, and associated worker briefings. The inspector evaluated the adequacy of radiological controls, such as required surveys, radiation protection job coverage and contamination controls. The inspector evaluated Exelons use of EPDs in high noise areas in HRAs.

and evaluated airborne radioactive controls and monitoring. The inspector examined Exelons access controls for highly activated or contaminated materials stored within spent fuel pool. RWPs reviewed are listed in the Attachment.

Risk-Significant HRA and Very High Radiation Area (VHRA) Controls The inspector discussed with the Radiation Protection Manager the controls and procedures for high-risk HRAs and VHRAs. The inspector evaluated Exelon controls for VHRAs and areas with the potential to become a VHRA to ensure that an individual was not able to gain unauthorized access to these VHRAs.

RP Technician Proficiency The inspector observed the performance of the RP technicians with respect to controlling radiation work.

Problem Identification and Resolution The inspector evaluated whether problems associated with radiation monitoring and exposure control were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the licensees corrective action program. The inspector assessed the appropriateness of the corrective actions for a selected sample of problems documented by Exelon that involve radiation monitoring and exposure controls. The inspector assessed Exelons process for applying operating experience to their plant.

a. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

Main article: IP 71124.02

a. Inspection Scope

During March 24 - 28, 2014, the inspector assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspector used the requirements in 10 CFR Part 20, RG 8.8, - Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Plants will be As Low As Is Reasonably Achievable, RG 8.10, -

Operating Philosophy for Maintaining Occupational Radiation Exposure As Low as Is Reasonably Achievable, TSs, and Exelon procedures required by TSs as criteria for determining compliance.

Inspection Planning The inspector reviewed TMI collective dose history, current exposure trends, and planned work activities and the plants three year rolling average collective exposure.

The inspector compared the site trends in collective exposures against the industry and those values from similar vintage reactors. The inspector reviewed procedures associated with maintaining occupational exposures ALARA, which included a review of processes used to estimate and track exposures from specific work activities.

Radiological Work Planning The inspector reviewed the following work:

Control rod drive replacement during T1R20 Scaffolding during T1R20 Reactor coolant pump seal replacement during T1R20 The inspector reviewed the ALARA work activity evaluations, exposure estimates, and exposure reduction requirements.

The inspector assessed whether Exelon planning identified appropriate dose reduction techniques; and estimated reasonable dose goals. The inspector reviewed Exelons ALARA evaluation of assessment worker efficiency from use of respiratory protective devices and/or heat stress mitigation equipment; the use of remote technologies, and operating experience. The inspector reviewed the integration of ALARA requirements into work procedure and RWP documents.

The inspector compared the results achieved (dose rate reductions, actual dose) with the intended dose established in Exelon ALARA planning for these work activities. The inspector compared the person-hour estimates provided by maintenance planning and other groups to the RP group actual person-hours for the work activity, and evaluated the accuracy of these time estimates. The inspector assessed the reasons for any inconsistencies between intended and actual work activity doses.

The inspector determined whether post-job reviews were conducted to identify lessons learned.

Verification of Dose Estimates and Exposure Tracking Systems The inspector reviewed the assumptions and basis for the current annual collective dose estimate. The inspector reviewed procedures for estimating exposures for specific work activities and for department and station collective dose goals. The inspector evaluated the measures to track, trend, and to reduce occupational doses for work activities. The inspector evaluated the licensees method of adjusting exposure estimates, when unexpected changes in scope or emergent work were encountered.

Problem Identification and Resolution The inspector evaluated whether problems associated with ALARA planning and controls are being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensees corrective action program. The inspector assessed Exelons process for applying operating experience to TMI.

a. Findings

No findings were identified.

2RS3 In-Plant Airborne Radioactivity Control and Mitigation

Main article: IP 71124.03

a. Inspection Scope

During March 24 - 28, 2014, the inspector reviewed in-plant airborne concentrations and the use of respiratory protection devices. The inspector used the requirements in 10 CFR Part 20, the guidance in RG 8.15, Acceptable Programs for Respiratory Protection, RG 8.25, Air Sampling in the Workplace, NUREG-0041, Manual of Respiratory Protection Against Airborne Radioactive Material, TSs, and Exelons procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspector reviewed the TMI UFSAR to identify areas of the plant designed as potential airborne radiation areas and associated ventilation systems and airborne monitoring instrumentation. This included a review of the respiratory protection program.

The inspector reviewed the UFSAR, TSs, and emergency planning documents to identify the location and quantity of respiratory protection devices stored for emergency use.

The inspector reviewed the procedures for maintenance, inspection, and use of respiratory protection equipment including self-contained breathing apparatus (SCBA),and procedures for air quality maintenance.

Engineering Controls The inspector reviewed the use of permanent and temporary ventilation systems as part of its engineering controls to control airborne radioactivity.

Use of Respiratory Protection Devices The inspector reviewed records of air testing for supplied-air devices and SCBA bottles.

The inspector selected three individuals qualified to use respiratory protection devices, and assessed the currency of these qualifications. Additionally, the inspector selected three individuals assigned to wear a respiratory protection device and observed them donning, doffing, and functionally checking the device. Through interviews with these individuals, the inspector evaluated whether they knew how to safely use the device and how to properly respond to any device malfunction or unusual occurrence.

SCBA for Emergency Use The inspector reviewed the status and surveillance records of selected SCBAs staged in-plant for use during emergencies. The inspector reviewed the licensees capability for refilling and transporting SCBA air bottles to and from the control room and the operations support center.

The inspector selected three individuals on control room shift crews and from designated departments currently assigned emergency duties to assess their current qualification requirements. The inspector evaluated whether personnel assigned to refill bottles were trained and qualified for that task.

The inspector reviewed the past two years of maintenance records for four SCBA units to assess the maintenance and repairs of self-contained breathing apparatus units were performed by individuals certified by the manufacturer of the device to perform the work.

The inspector verified that for those self-contained breathing apparatuses that were ready for use, that periodic air cylinder hydrostatic testing was documented and up to date.

Problem Identification and Resolution The inspector evaluated whether problems associated with the control and mitigation of in-plant airborne radioactivity were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee corrective action program. The inspector assessed whether the corrective actions were appropriate for a selected sample of problems involving airborne radioactivity and were appropriately documented by the licensee.

b. Findings

No findings were identified.

2RS4 Occupational Dose Assessment

Main article: IP 71124.04

During March 24 - 28, 2014, the inspector verified that occupational dose is appropriately monitored, assessed and reported by Exelon. The inspector used the requirements in 10 CFR Part 20, the guidance in RG 8.13, Instructions Concerning Prenatal Radiation Exposures, RG 8.36, Radiation Dose to Embryo Fetus, RG 8.40, Methods for Measuring Effective Dose Equivalent from External Exposure, TSs, and the licensees procedures required by TSs as criteria for determining compliance.

a. Inspection Scope

External Dosimetry The inspector assessed the use of EPDs to determine if Exelon uses a correction factor to address the response of the EPD as compared to the dosimeter of legal record for situations when the EPD is used to assign dose. The inspector reviewed four dosimetry occurrence reports related to EPDs. The inspector assessed whether Exelon had implemented appropriate corrective actions.

Internal Dosimetry Routine Bioassay (In Vivo)

The inspector reviewed procedures used to assess the dose from internally deposited radionuclides using whole body count (WBC) equipment. The inspector selected two WBCs and evaluated whether the counting had appropriate measurement sensitivity.

The inspector reviewed the radionuclide library used for the count system to determine if it included the gamma-emitting radionuclides that exist at the site. The inspector evaluated how Exelon accounts for hard-to-detect radionuclides in their internal dose assessments.

Internal Dose Assessment - WBC Analyses The inspector reviewed two dose assessments performed by Exelon using the results of WBC analyses.

Special Dosimetric Situations The inspector assessed whether Exelon informs workers of the risks, and the specific process to be used for (voluntarily) declaring a pregnancy. The inspector reviewed the records for two individuals who had declared pregnancy during the current assessment period and evaluated the radiological monitoring program for the declared pregnant workers.

b. Findings

No findings were identified.

OTHER ACTIVITIES

[OA]

4OA1 Performance Indicator Verification (71151 - 6 Samples)

.1 Unplanned Scrams, Unplanned Power Changes, and Unplanned Scrams with

Complications

a. Inspection Scope

The inspectors reviewed Exelons submittals for the following Initiating Events cornerstone performance indicators (PI) for the period of January 01, 2013 through December 31, 2013.

Unplanned Scrams Unplanned Power Changes Unplanned Scrams with Complications To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed Exelons operator narrative logs, maintenance planning schedules, condition reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Drill and Exercise Performance, ERO Drill Participation, and ANS Reliability

a. Inspection Scope

The inspectors reviewed data for the following EP PIs:

Drill and exercise performance ERO drill participation ANS reliability The last NRC EP inspection at TMI was conducted in the second calendar quarter of 2013. Therefore, the inspectors reviewed supporting documentation from EP drills and equipment tests from the second calendar quarter of 2013 through the fourth calendar quarter of 2013 to verify the accuracy of the reported PI data. The acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7, was used as reference criteria.

b. Findings

No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended issue report screening meetings.

b. Findings

No findings were identified.

.2 Annual Sample: Re-analysis of Toxic Gas Release Impact on Control Room Habitability

a. Inspection Scope

The inspectors performed an in-depth review of Exelons assessment and corrective actions in response to IR 930833, improvements needed for offsite chemical analysis.

Specifically, TMI identified deficiencies in the toxic gas release risk analysis used to support the TS required control room envelope habitability program. Exelon performed an updated risk analysis to address toxic gas release impact on control room habitability.

Upon completion and integration of the revised analysis within current design and implementation documents, Exelon identified deficiencies in the stations procedures and preparation for coping with a toxic gas release event. The additional issues were documented in the corrective action program (CAP) under IRs 1519604 and 1523311.

The inspectors assessed Exelons problem identification threshold, cause analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of Exelons corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with this issue and whether the planned and completed corrective actions were appropriate. The inspectors compared the actions taken to the requirements of Exelons corrective action program and 10 CFR 50, Appendix B. In addition, the inspectors performed field walkdowns and interviewed personnel to assess the effectiveness of the implemented corrective actions.

b. Findings and Observations

No findings were identified. In 2009, TMI performed a functional area self-assessment of the control room habitability program and identified that the previous control room habitability study did not fully support statements documented in the TS basis.

Specifically, the analysis did not provide a numerical risk associated with a toxic gas release that could cause an immediately dangerous to life and health (IDLH)environment per RG 1.78, Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release. Exelon appropriately documented the issue in the CAP under IR 930833 and performed a detailed quantitative risk analysis. The inspectors reviewed the assumptions, methodology, and outputs of the risk analysis to ensure it met the requirements of RG 1.78 and TSs as identified in IR 930833. The inspectors identified no issues of concern.

During the integration of the revised analysis as documented in IR 930833, Exelon identified deficiencies in their current controls and preparations to mitigate a toxic gas release. The inspectors reviewed TMIs current controls for onsite chemical storage and preparations for any chemical release that may create an IDLH environment in the TMI control building. The inspector performed a review of procedures that administratively control the amount of chemicals allowed to be stored onsite to within RG 1.78 limits. A walkdown of TMIs warehouse and chemical storage locations verified that Exelon adequately controls chemical hazards on site.

The inspectors reviewed Abnormal Operating Procedure (AOP) 58, Toxic Gas Release, to ensure the licensee had established proceduralized actions to mitigate hazards to control room operators from a toxic gas release. The inspectors identified that AOP-58 did not appropriately alert operators to evaluate for a unit shutdown in accordance with RG 1.78. Furthermore, the AOP contained steps for Exelon technicians to perform onsite sampling for toxic gas concentrations in support of returning the station to normal operations. The inspectors identified that the station did not have the trained personnel or the equipment to perform those sampling and analysis actions. Exelon documented the issue in their CAP under IR 1639250. Exelon performed an immediate change to the procedure steps to have operations staff evaluate for a plant shutdown, consistent with RG 1.78. Furthermore, Exelon identified that the local county, whose contact information was referenced in AOP-58, maintained hazard material response crews and could respond and perform onsite sampling within a reasonable amount of time. The inspectors determined that a performance deficiency existed for AOP-58 in that the procedure did not include a shutdown evaluation step and clear guidance for confirmatory sampling to return to normal operations however, it was considered minor because alternate means were identified to provide reasonable assurance that the procedure could be performed as currently written.

The inspectors reviewed the licensees corrective actions that addressed prior deficiencies (IR 1519604) related to the proficiency of operators to don SCBAs within two minutes upon recognition of a toxic gas condition in accordance with RG 1.78.

Exelon performed time validation testing to ensure all licensed operators could don their SCBAs within two minutes. However, the inspectors identified that the time validation study was not incorporated into annual training and resulted in a one-time only training.

Exelon documented this concern under IR 1639250 and took corrective actions to revise annual training to include time validation training. The inspectors determined this issue was minor based on all operators having a current time validation within the annual training period.

4OA5 Other Activities

.1 Cross Cutting Aspect Cross-Reference

The table below provides a cross-reference from the 2013 findings and associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects, and any others identified since January 2014, will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review:

Finding Old Cross-Cutting Aspect New Cross-Cutting Aspect 05000289/2013005-01 P.1(d) P.3

.2 Temporary Instruction (TI) 2515/182 - Review of the Industry Initiative to Control

Degradation of Underground Piping and Tanks, Phase 2 (2515/182 - Phase 2; 1 sample)

a. Inspection Scope

The licensees buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.a of Temporary Instruction (TI) 2515/182, and it was confirmed that activities which correspond to the completion dates, specified in the program, which have passed since the Phase 1 inspection was conducted, are planned to be completed before the milestone dates in the TI.

The licensees buried piping and underground piping and tanks program was inspected in accordance with paragraph 03.02.b of the TI and responses to specific questions found in http://ww.nrc.gov/reactors/operating/ops-experience/buried-pipe-ti-phase-2-insp-req-2011-11-16.pdf were submitted to NRC headquarters staff.

b. Finding No findings were identified.

4OA6 Meetings, Including Exit

Temporary Instruction (TI) 2515/182 - Review of the Industry Initiative to Control Degradation of Underground Piping and Tanks, Phase 2 (2515/182 - Phase 2), (section 4OA5.2)

On January 30, 2014, the inspectors presented the inspection results to Mr. Mark Torborg, TMI Engineering Manager and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

Emergency Preparedness (sections 1EP2, 1EP3, 1EP5, and 4OA1.2)

On February 7, 2014, the inspectors conducted a debrief meeting and presented the preliminary inspection results to Mr. Mark Newcomer, TMI Plant Manager, and other members of the Exelon staff. A final exit meeting was held via telephone conference on March 24, 2014, with Mr. V. Cwietniewicz, Exelon Mid Atlantic EP Manager, and other Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

Radiation Safety (sections 2RS1, 2RS2, 2RS3, and 2RS4)

On March 28, 2014, the inspectors presented the inspection results to Mr. Rick Libra, TMI Site Vice President, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or would be documented in this report.

2013 Annual Assessment Discussion On April 17, 2014, Kevin Mangan, NRC Branch Chief for TMI, discussed TMI performance for 2013 with Mr. Rick Libra, TMI Site Vice President, prior to the public annual assessment meeting.

Quarterly Inspection Report Exit On April, 18, 2014, the inspectors presented the inspection results to Mark Newcomer, Plant Manager, and other members of the TMI staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

ATTACHMENT:

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

T. Alvey Manager, Chemistry

D. Atherholt Manager, Regulatory Assurance, ERO Team C Leader

M. Benson Maintenance Rule Expert Chair

S. Burger In-Field Supervisor

R. Campbell Manager, Site Security

V. Cwietniewicz Manage, Exelon Mid-Atlantic Emergency Preparedness

K. Coughlin Operations Shift Manager

A. Crawford Design Engineering

S. Darkes RP Supervisor

D. Divittore Manager, Radiological Engineering

M. Fitzwater Senior Regulatory Assurance Engineer

T. Flemming SBO Engineer

R. Green Buried Piping Program Owner

T. Hall Program Engineering

B. Hreha Risk Engineer

K. Hummert Radwaste Operator

J. Levengood Auxiliary Operator

R. Libra Site Vice President

G. McCarty Manager RP Technical Support

B. McSorely Design Engineering

M. Newcomer Plant Manager

D. Oshall In-Field Supervisor

B. Parfitt Shift Manager, Operations

J. Piazza Senior Manager, Design Engineering

M. Reed System Engineering

S. Scarborough RP Technician

C. Six Director, Operations

G. Smith Director, Maintenance

B. Shumaker Manager, Emergency Preparedness

S. Taylor Fire System Engineer

B. Vuxta Manager Radiological Engineering

L. Weber Senior Chemist

D. Willenbecher Manager, Maintenance

Other Personnel

D. Dyckman Nuclear Safety Specialist

Pennsylvania Department of Environmental Protection

Bureau of Radiation Protection

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000289/2014002-01 SLIV/NCV Failure to Perform a 10 CFR 50.59 Evaluation for the BWST Seismic Qualifications (Section 1R04)

05000289/2014002-02 FIN Loss of Air Intake Tunnel Sump Pump Function due to Inadequate Work Execution (Section 1R05)

05000289/2014002-03 NCV Failure to Restore Station Blackout Diesel Generator Cooling Water Lineup following Maintenance and Testing Activities (Section 1R22)

LIST OF DOCUMENTS REVIEWED