Text

IR 05000289-14-003, April 1, 2014 - June 30, 2014, Three Mile Island Station, Unit 1, NRC Integrated Report
	ML14216A487
Person / Time
Site:	Three Mile Island
Issue date:	08/04/2014
From:	Kevin Mangan; NRC/RGN-I/DRP/PB6
To:	Pacilio M; Exelon Generation Co, Exelon Nuclear
	MANGAN, KA
References
	IR-14-003
	Download: ML14216A487 (40)
	v • d • e

ust 4, 2014

SUBJECT:

THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED INSPECTION REPORT 5000289/2014003

Dear Mr. Pacilio:

On June 30, 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 July 18, 2014 with Mr. Rick Libra, TMI Site Vice President, 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 two NRC-identified findings of very low significance. These findings were determined to be violations of NRC requirements, one which was evaluated under traditional enforcement and categorized as Severity Level IV. However, because of the very low safety significance, and because they were entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the non-cited violations 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, 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, Chief (Acting)

Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-289 License Nos.: DPR-50

Enclosure:

Inspection Report 05000289/2014003 w/Attachment: Supplemental Information

REGION I==

Docket No: 50-289 License No: DPR-50 Report No: 05000289/2014003 Licensee: Exelon Generation Company Facility: Three Mile Island Station, Unit 1 Location: Middletown, PA 17057 Dates: April 1 through June 30, 2014 Inspectors: D. Werkheiser, Senior Resident Inspector, Division of Reactor Projects (DRP)

J. Heinly, Resident Inspector, DRP H. Anagnostopoulos, Health Physicist, Division of Reactor Safety (DRS)

B. Bollinger, Project Engineer, DRP J. Brand, Reactor Inspector, DRS R. Rolph, Health Physicist, DRS W. Schmidt, Senior Risk Analyst, DRS J. Tomlinson, Operations Engineer, DRS Approved by: K. Mangan, Chief (Acting)

Projects Branch 6 Division of Reactor Projects (DRP)

Enclosure

SUMMARY

IR 05000289/2014003, 04/01/2014-06/30/2014; Three Mile Island, Unit 1, Maintenance Risk

Assessments and Emergent Work Control, Problem Identification and Resolution This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one finding of very low safety significance (Green), which was a non-cited violation (NCV), and one Severity Level IV finding, which was 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, Rev. 5, dated February 2014.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a finding of very low safety significance (Green) involving a non-cited violation (NCV) of 10 CFR Part 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, because Exelon did not implement risk management actions (RMAs) to manage risk associated with the nuclear service river pump B (NR-P-1B) during excavation for fire service piping replacement. Specifically, the excavation exposed a cable conduit duct bank containing safety-related cables for nuclear service river valve 1B (NR-V-1B) without having adequate RMAs in place to ensure NR-V-1B cabling would remain protected from a tornado generated missiles. Exelon entered the condition into their corrective action program as IR 1670876 and took immediate corrective actions to modify the work instructions to include RMAs for soil restoration over the conduit duct bank in the event of a tornado.

The performance deficiency is more than minor because it is associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstones objective to ensure the availability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors evaluated the findings using IMC 0609.04, Initial Characterization of Findings. The finding involved the licensees management of risk in accordance with 10 CFR 50.65(a)(4) therefore, the inspectors evaluated the significance using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. The inspectors determine that this performance deficiency was of very low safety significance (Green)because the finding was associated with RMAs only and the incremental core damage probability (IDCP) was not >1E-6.

This finding has a cross-cutting aspect in the area of Human Performance, Work Management; because Exelon did not manage risk associated with the underground piping replacement project and did not effectively communicate job activities between work groups to ensure the RMAs would be implemented as required. (H.5) (Section 1R13)

Cornerstone: Public Radiation Safety

Severity Level lV. The inspectors identified a Severity Level lV (SL-lV) NCV of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, because TMI personnel did not update the Updated Final Safety Analysis Report (UFSAR) with information consistent with plant conditions. Specifically, TMI personnel did not remove reference to or correct information in UFSAR Section 14.2.2.3.4.a, Environmental Analysis of Loss of Coolant Accidents - Consequences of LOCA Radioactive Releases to the Environment, to reflect current plant conditions with regard to maximum hypothetical accident doses at the main control room, exclusion area boundary, or low population zone. Exelon documented this in issue report 1662515 to address the UFSAR discrepancy.

This issue was determined to be within the traditional enforcement process because it had the potential to impede or impact the NRC's ability to perform its regulatory functions.

Specifically, the issue was determined to have a material impact on licensed activities and was considered more than minor using section 7.3.D of the NRC Enforcement Manual.

Using example d.3 of section 6.1 of the NRC Enforcement Policy, the inspectors determined that the violation was a SL-IV violation because the erroneous information was not used to make an unacceptable change to the facility or procedure.

In accordance with inspection manual chapter 0612, section 07.03c, this traditional enforcement violation was not assigned a cross-cutting aspect. (Section 4OA2.1)

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On May 24, 2014, operators reduced power to approximately 50 percent to facilitate reinforcements to the A natural draft cooling tower distribution piping and supports. Following these reinforcements, operators returned the unit to 100 percent later the same day. The unit remained at, or near, 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of Exelons readiness for the onset of seasonal high temperatures. The review focused on the intake screen and pump house (ISPH)ventilation, river water biocide system, and river water pumps. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications, control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Exelon personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Exelons seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during hot weather conditions.

b. Findings

No findings were identified.

.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Exelons procedures affecting these areas and the communications protocols between the transmission system operator and Exelon. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Exelon established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing issue reports and open work orders, and walking down portions of the offsite and AC power systems.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

Main article: IP 71111.04Q

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

A control building ventilation during B train out of service for planned maintenance on April 22, 2014 Intake screen and pump house ventilation during desilting operations on April 22, 2014 B emergency diesel generator during A train out of service during a planned system outage on April 28, 2014 Nuclear service water during relief valve flushing of NS-V-36A under WO C2032080 on May 6, 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, technical specifications, work orders, condition 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 determine if the equipment met their design and licensing requirements.

Finally, the inspectors 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

No findings were identified.

.2 Full System Walkdown

Main article: IP 71111.04S

a. Inspection Scope

On June 26, 2014, the inspectors performed a complete system walkdown of accessible portions of the emergency feedwater system after surveillance testing to verify the existing equipment lineup was in accordance with the design and licensing requirements for the system. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that they met the design requirements. Additionally, the inspectors reviewed a sample of related issue reports and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

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.

1E switchgear room, CB-FA-3B on April 29, 2014 Relay room, CB-FA-3D on April 29, 2014 Main turbine oil reservoir area, TB-FA-1/9, as related to a postulated hot short event documented in IR 1651702 and NRC event notification50059 on April 29, 2014 Turbine-driven main feedwater pump area, TB-FA-1/10, as related to a postulated hot short event documented in IRs 1658837, 1658842, and NRC EN 50108 on May 12, 2014 1P switchgear room, CB-FA-2A, on June 12, 2014

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

Annual Review of Cables Located in Underground Bunkers/Manholes

a. Inspection Scope

The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could affect risk-significant equipment. The inspectors performed walkdowns of risk-significant areas, including cable vaults E-7 and E-9 containing safety-related cables, to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. When applicable, the inspectors verified proper sump pump operation and verified level alarm circuits were set in accordance with station procedures and calculations to ensure that the cables will not be submerged. The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11

.1 Quarterly Review of Licensed Operator Performance in the Main Control Room

(71111.11Q - 1 sample)

a. Inspection Scope

The inspectors observed control room operations in support of heat sink protection system testing and a spent fuel pool in-service test, as controlled from the main control room staff on April 8, 2014. The inspectors observed licensed operator performance to verify that procedure use, crew communications, and coordination of activities between work groups met the criteria specified in Exelons OP-AA-1, Conduct of Operations, Rev. 000. In addition, the inspectors verified that licensee supervision and management were adequately engaged in plant operations oversight and appropriately assessed control room operator performance and similarly met established expectations and standards.

b. Findings

No findings were identified.

.2 Quarterly Review of Licensed Operator Requalification Testing and Training

(71111.11Q - 1 sample)

a. Inspection Scope

The inspectors observed licensed operator just-in-time simulator training on May 22, 2014, in preparation for a planned unit power reduction to 50 percent power and restoration to full power to support shutdown and maintenance on the A natural draft cooling tower. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.

b. Findings

No findings were identified.

.3 Licensed Operator Requalification

Main article: IP 71111.11A

a. Inspection Scope

On May 29, 2014, one NRC region-based inspector conducted an in-office review of results of licensee-administered annual operating tests for 2014, for Three Mile Island, Unit 1 operators. The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, and Operator Requalification Human Performance Significance Determination Process (SDP). The review verified that the failure rate (individual or crew) did not exceed 20%.

1 out of 46 operators failed at least one section of the Annual Exam. The overall individual failure rate was 2.2 percent 0 out of 7 crews failed the simulator test. The crew failure rate was 0.0 percent

b. Findings

No findings were identified.

1R12 Maintenance Effectiveness

Main article: IP 71111.12Q

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or component (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the Maintenance Rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the Maintenance Rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

Review of American Society of Mechanical Engineering (ASME) Code testing issues related to reactor building spray excess-flow check valves (BS-V-1103 thru 1108)documented in IR 1663624 on May 23, 2014 Instrument air dryer (IA-Q-2) on June 23, 2014, as documented in IR 1641028 and Maintenance Rule a(1) determination in IR 16571358 on June 23, 2014 Review of chemical addition pumps (CA-P-1A/B) after in-service testing issues as documented in IR 1670834 on June 18, 2014

b. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

a. Inspection Scope

The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.

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.

Decay river pump availability during planning intake structure desilting on April 22, 2014 Station Yellow risk during a planned system outage of A emergency diesel generator on April 28, 2014 Planned intake structure desilting in areas 4, 5, 6, 7 on May 5 - 9, 2014 Risk mitigation actions during planned replacement of four engineered safeguards actuation system relays on May 19 - 21, 2014 Unscheduled Yellow station risk to support switchyard inspections by the grid local system operator on May 29, 2014 Risk mitigation actions for nuclear river water systems during planned excavations to replace fire service piping on June 17, 2014

b. Findings

Introduction:

The inspectors identified a finding of very low safety significance (Green)involving a non-cited violation (NCV) of 10 CFR Part 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, because Exelon did not implement risk management actions (RMAs) to manage risk associated with the nuclear service river pump B (NR-P-1B) during excavation for fire service piping replacement. Specifically, the excavation exposed a cable conduit duct bank containing safety related cables for nuclear service river valve 1B (NR-V-1B) without having adequate RMAs in place to ensure NR-V-1B cabling would remain protected from a tornado generated missiles.

Description:

The nuclear service river water system contains three river water pumps (NR-P-1A/1B/1C) of which two independent pumps are required to be aligned to the A and B train to satisfy technical specification requirements. NR-P-1B is typically the standby pump that can be aligned to the A or B train and is modeled in the TMI online risk assessment program. The inspectors noted that nuclear river service water system is designed to remain available during external events such as seismic, flooding, and tornados and the unavailability of any one of the pumps changes the station risk color to Yellow which results in an evaluation for RMAs in accordance with Exelon procedures.

On May 28, 2014, Exelon commenced a fire service underground piping replacement project which included excavating an area containing the safety-related cables for NR-V-1B and associated support components to NR-P-1B. The inspectors determined that the risk assessment performed for the piping replacement project assumed RMAs were in place so that NR-P-1B would be available in the event of a tornado. Specifically, the inspectors found that RMA Exelon credited was based on direction in procedure SA-AA-117 Excavation, Trenching, and Shoring and Section 8 of the Excavation Permit which states, in part, to adhere to Tornado Missile Protection requirements, the excavator shall maintain the required equipment and a sufficient reserve of soil adjacent to each excavation to permit placement of at least 4-1 of soil to cover the safety related piping and duct bank in the event of a severe weather (tornado) warning being announced for the immediate plant vicinity. Safety-related commodities with less than 4-1 of existing soil cover shall have the soil depth returned to existing grade.

Exelon described in Section 9 of the excavation permit that the area where the safety-related nuclear service river water cable duct bank is located was part of the excavated area which required the compensatory measures.

However, on June 10, 2014, the inspectors identified that the work order controlling the excavation did not contain the RMAs to backfill above the NR-V-1B duct bank for tornado missile protection. Furthermore, the inspectors interviewed the technicians in the field and confirmed that the RMA activities were not incorporated in the work instructions and would not have been implemented. Therefore, the inspectors concluded that the station was in an unanticipated elevated risk condition (Yellow) due to the absence of RMAs for NR-P-1B. Exelon entered the condition into their corrective action program as IR 1670876 and took immediate corrective actions to modify the work instructions to include RMAs for soil restoration over the conduit duct bank in the event of potential tornado conditions.

Analysis:

The inspectors determined that Exelons failure to have adequate RMAs in place to ensure the nuclear river pump 1B would remain available in a tornado condition was a performance deficiency that was within Exelons ability to foresee and correct and therefore should have been prevented. The finding is more than minor because it is associated with the Protection Against External Factors attribute of the Mitigating Systems cornerstone, and adversely affected the cornerstones objective to ensure the availability and capability of systems that respond to initiating events to prevent undesirable consequences.

The inspectors evaluated the findings using IMC 0609.04, Initial Characterization of Findings. The finding involved the licensees management of risk in accordance with 10 CFR 50.65(a)(4) therefore, the inspectors evaluated the significance using IMC 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process. The inspectors and a Region I Senior Reactor Analyst (SRA)determine that this performance deficiency was of very low safety significance (Green).

Specifically the performance deficiency was associated with RMAs only and the incremental core damage probability (IDCP) was not >1E-6. While not specifically calculated, the SRA estimated the IDCP to be several orders of magnitude below 1E-6, given: the low frequency of a damaging tornado in the TMI area; the limited exposure period of 16 days; the low likelihood of a tornado generated missile strike in the specific area of concern; the appropriately implemented RMA to protect NR piping, and the ability to operate NR-V-1B locally, if needed.

This finding has a cross-cutting aspect in the area of Human Performance, Work Management; because Exelon did not manage risk associated with the underground piping replacement project and did not effectively communicate job activities between work groups to ensure the RMAs would be implemented as required. (H.5)

Enforcement:

10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, requires, in part, that before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.

Contrary to the above, from May 28, 2014 to June 13, 2014, Exelon incorrectly assessed the risk to the station because they did not adequately manage the RMAs they assumed in the risk assessment were in place to ensure the nuclear river pump 1B would remain available and undamaged from potential tornado conditions. Exelons immediate corrective actions included changing the work order to ensure enough materials and soil reserve was in place to provide coverage of the safety related duct bank in the presence of potential tornado condition. Because this finding is of very low safety significance (Green) and Exelon entered this issue into their corrective action program as IR 1670876, this finding is being treated as an NCV consistent with the NRC Enforcement Policy. [NCV 05000289/2014003-01: Risk Mitigation Actions Not Implemented for Excavation of Nuclear River System Cable Conduits]

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:

B emergency feedwater system during maintenance to replace an air switch valve to an intermediate building ventilator (AH-E-24B) under WO R2161851 on April 15, 2014 A emergency diesel generator governor issues and review of common mode failure documented in IR 1654207 on May 2, 2014 TMI review of EN 49875 regarding unfused direct current circuits and issues documented in IRs 1638221 and 1651702 on April 1 and May 2, 2014 Turbine bypass valves from B once-through steam generator valve (MS-V-3C)positioner issues documented in IR 1656953 on May 7, 2014 B emergency diesel generator not ready to load indication as documented in IR 1660323 on May 16, 2014 Reactor building ventilating cooler (AH-E-1B/1C) after inspection hatch discovery open as documented in IR 1664956 on May 28, 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.

1R18 Plant Modifications

Main article: IP 71111.18

Permanent Modifications

a. Inspection Scope

The inspectors evaluated modifications to balance of plant circuits that were identified by the licensee to have an adverse impact on safety-related air compressors (IA-P-1A/1B)resulting from a postulated fire and hot short. See section 1R05 for fire-related details.

The inspectors reviewed the installation of fuses into the control circuits of the balance of plant components under ECRs:

14-00255, Install Control Circuit Fuse for LO-P-6 for Appendix R Protection, on May 6, 2014 14-00279, Install Control Circuit Fuse for LO-P-6A/B for Appendix R Protection, on May 28 - 29, 2014 The inspectors verified that the design bases, licensing bases, and performance capability of the affected air compressor systems were not degraded by the modification.

In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including observation of the circuit medication and fuse installation.

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.

Intake structure cooler (AH-E-95A) heat exchanger repairs on April 2, 2014 Engineered safeguards actuation system (ESAS) relay replacement on April 25, 2014 A emergency diesel generator maintenance outage on May 2, 2014 Direct current fuse circuit installation for LO-P-6 under ECR 14-00255 / A235409 on May 7, 2014 ESAS relay replacement on May 22, 2014 ESAS relay replacement on May 27, 2014 Replacement of station blackout diesel cooling water flow controller to valve FS-V-647 on June 6, 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:

E-136, SBO Diesel Battery Charger Inspection, on April 17, 2014 IST of make-up valve MU-V-14 and decay heat valves DH-V-7A/B, on April, 25, 2014 (in-service test)

ASME code test of Pentair safety relief valve reported by vendor in 10 CFR 21 report 2014-00-00 on May 8, 2014 1303-11.52, Saturation Margin calibration check, on May 23, 2014 OP-TM-212-201, IST of DH-P-1A and Valves from ES Standby Mode, on May 6, 2014 (in-service test)

OP-TM-220-251, Leak Rate Determination, on May 22, 2014 (leak rate)

MA-TM-214-201, IST of BS-V-1103 through BS-V-1108 Excess Flow Check Valves, on May 23, 2014, and 1303-4.14, 30SIG Analog Channels, on June 27, 2014, for building spray excess-flow check valves (in-service tests)

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

Main article: IP 71114.06

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Exelon emergency drill on April 29, 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 simulator, technical support center, and operations support center to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.

The inspectors also attended the station 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 April 21 - 25, 2014, the inspectors 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 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 2013 Exelon performance indicators for the occupational exposure cornerstone for Three Mile Island.

Radiological Hazard Assessment There were no opportunities for the inspector to observe work in potential airborne radioactivity areas during this inspection period.

Instructions to Workers The inspector selected three containers of radioactive material. The inspector assessed whether the containers were labeled and controlled in accordance with 10 CFR Part 20 requirements.

For work activities that could suddenly increase radiological conditions, the inspector assessed Exelon means to inform workers of these changes.

Contamination and Radioactive Material Control The inspector observed one location where Exelon monitors material leaving the radiological control area and inspected the methods used for control, survey, and release of these materials from the area. The inspector observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspector assessed whether the radiation monitoring instrumentation used for equipment release and personnel contamination surveys had appropriate sensitivity for the type(s) of radiation present.

The inspector reviewed Exelons criteria for the survey and release of potentially contaminated material. The inspector evaluated whether there was guidance on how to respond to an alarm that indicates the presence of licensed radioactive material.

The inspector reviewed Exelons procedures and records to verify that the radiation detection instrumentation was used at its typical sensitivity level based on appropriate counting parameters. The inspector selected two sealed sources from Exelons inventory records and assessed whether the sources were accounted for and were tested for loose surface contamination.

The inspector evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with10 CFR Part 20 requirements.

Radiological Hazards Control and Work Coverage The inspector assessed whether radiation monitoring devices were placed on the individuals body consistent with Exelons procedures. The inspector assessed whether the dosimeter was placed in the location of highest expected dose.

The inspector reviewed the application of dosimetry to effectively monitor exposure to personnel in high-radiation work areas with significant dose rate gradients.

The inspector examined the posting and physical controls for selected high radiation areas (HRAs) to verify conformance with the occupational performance indicator.

Risk-Significant HRA and Very High Radiation Area (VHRA) Controls The inspector discussed with first-line health physics supervisors the controls in place for areas that have the potential to become very high radiation areas during certain plant operations. The inspector assessed whether these plant operations require communication beforehand with the health physics group, so as to allow corresponding timely actions to properly post, control, and monitor the radiation hazards.

Radiation Worker Performance The inspector observed the performance of radiation workers with respect to stated radiation protection (RP) work requirements. The inspector assessed whether workers were aware of the radiological conditions in their workplace and the radiation work permit (RWP) controls/limits in place, and whether their behavior reflected the level of radiological hazards present.

The inspector reviewed three radiological condition reports since the last inspection that attributed the cause of the event to human performance errors. The inspector evaluated whether there was an observable pattern traceable to a similar cause. The inspector assessed whether this perspective matched the corrective action approach taken by Exelon to resolve the reported problems.

b. Findings

No findings were identified.

2RS2 Occupational ALARA Planning and Controls

Main article: IP 71124.02

a. Inspection Scope

During April 21 - 25, 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 any changes in the radioactive source term by reviewing the trend in average contact dose rates with reactor coolant piping.

Radiological Work Planning For problems that were identified in post job reviews, the inspector verified that worker suggestions for improving dose and contamination reduction techniques were entered into Exelons corrective action program.

Source Term Reduction and Control The inspector used licensee records to determine the historical trends and current status of plant source term that contribute to elevated facility collective dose. The inspector assessed whether the licensee had made allowances or developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.

Radiation Worker Performance The inspector observed radiation worker and RP technician performance during work activities being performed in radiation areas and HRAs. The inspectors evaluated whether workers demonstrated the ALARA philosophy in practice and whether there were any procedure or radiation work permit (RWP) compliance issues.

b. Findings

No findings were identified.

2RS5 Radiation Monitoring Instrumentation

Main article: IP 71124.05

a. Inspection Scope

During June 23 - 27, 2014, the inspectors reviewed the accuracy and operability of radiation monitoring instruments that are used to protect occupational workers and to protect the public from nuclear power plant operations. The inspectors used the requirements in 10 CFR Part 20, 10 CFR Part 50 Appendix A - Criterion 60 Control of Release of Radioactivity to the Environment and Criterion 64 Monitoring Radioactive Releases, 10 CFR 50 Appendix I Numerical Guides for Design Objectives and Limiting Conditions for Operation to meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, 40 CFR Part 190 Environmental Radiation Protection Standards for Nuclear Power Operations, NUREG 0737 Clarification of Three Mile Island Corrective Action Requirements, TSs/Offsite Dose Calculation Manual (ODCM), applicable industry standards, and Exelon procedures required by TSs as criteria for determining compliance.

Inspection Planning

The inspectors reviewed the TMI Updated Final Safety Analysis Report (UFSAR) to identify radiation instruments associated with monitoring area radiation, airborne radioactivity, process streams, effluents, materials/articles, and workers. Additionally, the inspectors reviewed the associated TS requirements for post-accident monitoring instrumentation. The inspectors reviewed in-service survey instrumentation including:

air samplers, small article monitors (SAM), radiation monitoring instruments, personnel contamination monitors, portal monitors, and whole-body counters. The inspectors assessed whether an adequate number and type of instruments were available to support operations.

The inspectors reviewed Exelon and third-party evaluation reports of the radiation monitoring program since the last inspection including evaluations of offsite calibration facilities or services, if applicable. The inspectors reviewed instrument source check and calibration procedures including instruments used for monitoring transient high radiological conditions and instruments for performing underwater surveys. The inspectors reviewed the area radiation monitor (ARM) alarm set-point values and bases as provided in the TSs and the UFSAR. The inspectors reviewed effluent monitor alarm set-point bases and the calculation methods provided in the ODCM.

Walkdowns and Observations The inspectors walked down five effluent radiation monitoring systems, including one liquid and one gaseous effluent system that included flow measurement devices and all accessible point-of-discharge liquid and gaseous effluent monitors. The inspectors assessed whether the effluent/process monitor configurations align with the UFSAR and/or ODCM.

The inspectors selected five portable survey instruments that are available for issuance and assessed calibration and source check stickers for currency and instrument material condition and operability. The inspectors observed Exelon staff demonstrate source checks for PM-7s, SAM-12s, RO-20, RO-2A, and a Telepole portable survey instrument.

The inspectors assessed whether high-range instruments are source checked on all appropriate scales.

The inspectors walked down five ARMs and five continuous airs monitors (CAMs) to determine whether they are located and operated appropriately. The inspectors compared ARM remote control room indications with actual area radiological conditions for accuracy.

The inspectors selected two personnel contamination monitors, two portal monitors, and three SAMs and evaluated whether source checks were performed in accordance with the manufacturers recommendations and Exelon procedures.

Process and Effluent Monitors

The inspectors selected three effluent monitor instruments and reviewed their channel calibration and functional test results and assessed whether Exelon calibrated its effluent monitors with National Institute of Standards and Technology (NIST) traceable sources; primary calibrations adequately represent the plant radionuclide mix; secondary calibration sources used were verified by comparison with primary calibration sources; and Exelon channel calibrations encompassed the instruments alarm set-point range.

The inspectors reviewed the effluent monitor alarm set-points with respect to TMI ODCM and station procedure requirements. For changes to effluent monitor set-points, the inspectors evaluated the basis for these changes.

Laboratory Instrumentation

The inspectors assessed laboratory analytical instruments to determine whether daily performance checks and calibration data indicate that the frequency of the calibrations is adequate and there were no indications of degraded instrument performance.

Whole Body Counter (WBC)

The inspectors reviewed calibration records for the WBC and reviewed the methods and sources used to perform functional checks on the WBC before daily use. The inspectors assessed whether calibration and check sources were appropriate based on the plants radionuclide mix and that appropriate calibration phantoms were used. The inspectors looked for anomalous results or other indications of instrument performance issues.

Post-Accident Monitoring Instrumentation

Inspectors reviewed calibration documentation for a containment high-range monitor.

The inspectors assessed whether the electronic calibration was completed for all range decades and that the detector calibration used an appropriate radiation source.

The inspectors selected one effluent/process monitor that is included in emergency operating procedures. The inspectors evaluated the calibration and availability of this instrument. The inspectors reviewed the current capability to collect high-range, post-accident effluent samples. There was no opportunity for inspectors to observe electronic and radiation calibration of those instruments associated with the post-accident radiation monitoring.

Portal Monitors, Personnel Contamination Monitors, and SAMs The inspectors selected one of each type of these instruments and verified that the alarm set-point values ensure that radioactive material is not released from the site.

The inspectors reviewed calibration documentation for each instrument selected and reviewed the calibration methods to determine consistency with procedure and manufacturers recommendations.

Portable Survey Instruments, ARMs, Electronic Dosimetry, and Air Samplers/CAMs The inspectors reviewed calibration documentation for at least one of each type of portable instrument in use. For portable survey instruments and ARMs, the inspectors reviewed detector measurement geometry, calibration methods, and use of the instrument calibrator in conducting these calibrations.

Instrument Calibrator

The inspectors reviewed the current radiation output values for the licensees portable survey and ARM instrument calibrators. The inspectors assessed whether the licensee periodically verifies calibrator output over the range of the exposure rates/dose rates using an ion chamber/electrometer. The inspectors assessed whether the measuring devices had been calibrated by a facility using NIST traceable sources as required.

Calibration and Check Sources

The inspectors reviewed the licensees waste stream characterization per 10 CFR Part 61, Licensing Requirements for Land Disposal of Radioactive Waste, to assess whether calibration sources used were representative of the types and energies of radiation encountered in the plant.

Problem Identification and Resolution The inspectors evaluated whether problems associated with radiation monitoring instrumentation were being identified by the licensee at an appropriate threshold and were properly addressed for resolution in the licensee corrective action program.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA1 Performance Indicator Verification

Main article: IP 71151

.1 Reactor Coolant System (RCS) Specific Activity and RCS Leak Rate (2 samples)

a. Inspection Scope

The inspectors reviewed Exelons submittal for the RCS specific activity and RCS leak rate performance indicators for TMI for the period of April 1, 2013 through April 1, 2014.

To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 6. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements of RCS leakage, and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate.

b. Findings

No findings were identified.

.2 Occupational Exposure Control Effectiveness (1 sample)

Inspection Scope The inspector reviewed licensee submittals for the occupational exposure control effectiveness performance indicator for the period from the January 1, 2013 through December 31, 2013. The inspector used the performance indicator definitions and guidance contained in the Nuclear Energy Institute Document 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 7, dated August 31, 2013, to determine the accuracy of the performance indicator data reported.

To assess the adequacy of the licensees performance indicator data collection and analyses, the inspector discussed with radiation protection staff, the scope and breadth of its data review and the results of those reviews. The inspector independently reviewed electronic personal dosimetry accumulated dose alarms, dose reports, and dose assignments for any intakes that occurred during the time period reviewed to determine if there were potentially unrecognized performance indicator occurrences.

The inspector also conducted walkdowns of numerous locked high radiation area entrances to determine the adequacy of the controls in place for these areas.

Findings No findings were identified.

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review of Problem Identification and Resolution Activities

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.

Findings

Introduction.

The inspectors identified a Severity Level IV (SL-IV) NCV of 10 CFR 50.71(e), Maintenance of Records, Making of Reports, because TMI personnel did not update the Updated Final Safety Analysis Report (UFSAR) with information consistent with plant conditions. Specifically, TMI personnel did not remove reference to or correct information in UFSAR Section 14.2.2.3.4.a, Environmental Analysis of Loss of Coolant Accidents - Consequences of LOCA Radioactive Releases to the Environment, to reflect current plant conditions with regard to maximum hypothetical accident doses at the main control room, exclusion area boundary, low population zone.

Description.

In April 2012, TMI personnel identified that UFSAR Section 14.2.2.3.4.a, regarding maximum hypothetical accident doses at the main control room, exclusion area boundary, low population zone was not consistent with current plant conditions.

Specifically, Section 14.2.2.3.4.a documented maximum hypothetical accident doses at the main control room, exclusion area boundary, and low population zone different from data documented in UFSAR Table 14.2-20. Exelon determined that data in UFSAR Table 14.2-20 was revised in April 2010 and incorporated in UFSAR, Rev. 21, in April 2012, but Exelon failed to revise the data in section 14.2.2.3.4.a. Exelon documented this in their corrective action program as IR 1333165 (March 2012) with an action (action

5) to revise the data in Section 14.2.2.3.4.a with the next UFSAR update. However, Exelon did not post in their electronic tracking system that there were changes pending for that section of the UFSAR.

In August 2012, a separate IR (1400518) was generated documenting the same UFSAR discrepancy. Exelon created an action request to revise the data, but the action stayed in review status until February 2014. TMI personnel continued to identify that the UFSAR remained inconsistent with current plant conditions but only annotated in their tracking system that there were revisions pending for UFSAR Section 14.2.2.3.4.a after completing the action request in February 2014. UFSAR Rev. 22 was submitted to the NRC in April 2014 without a revision to Section 14.2.2.3.4.a.

In May 2014, the inspectors identified that UFSAR Section 14.2.2.3.4.a remained inconsistent with current plant conditions and should have been updated in a timeframe consistent with the standards and expectations delineated in Exelon procedure LS-AA-107, UFSAR Update Procedure, and 10 CFR 50.71(e) which requires UFSAR revisions to reflect all changes made up to six months prior to the date of filing the revision.

The inspectors identified that the issue was originally identified in March 2012 and that actions assigned to correct the issue were not appropriately tracked or were assigned completion dates after the six month cut-off date for the April 2014 UFSAR update.

Exelon documented this issue in IR 1662515 to address the UFSAR inconsistencies, verify tracking of the pending update against UFSAR Section 14.2.2.3.4.a, and to review extent of condition.

Analysis.

The inspectors determined that the failure to update the UFSAR in accordance with 10 CFR 50.71(e) was a performance deficiency that was reasonably within Exelon's ability to foresee and correct, and should have been prevented. Because the issue had the potential to affect the NRC's ability to perform its regulatory function, the inspectors evaluated this performance deficiency with the traditional enforcement process. The issue was determined to have a material impact on licensed activities and, therefore, was considered more than minor in accordance with section 7.3.D of the NRC Enforcement Manual. Using example d.3 of section 6.1 of the NRC Enforcement Policy, the inspectors determined that the violation was a SL IV violation because the erroneous information was not used to make an unacceptable change to the facility or procedure.

In accordance with inspection manual chapter 0612, section 07.03c, this traditional enforcement violation was not assigned a cross-cutting aspect.

Enforcement.

10 CFR 50.71(e) requires that licensees shall periodically update the UFSAR, originally submitted as part of the application for the operating license, to assure that the information included in the report contains the latest information developed. In part, the submittal shall include the effects of all changes made in the facility or procedures as described in the UFSAR such that the UFSAR, as updated, remains complete and accurate. Contrary to the above, since 2012, Exelon became aware of contrary information and did not update the UFSAR to accurately reflect the maximum hypothetical doses as described in UFSAR section 14.2.2.3.4.a. Not adequately updating the UFSAR as required by 10 CFR 50.71(e) is characterized as a Severity Level IV violation. However, because the violation was of very low safety significance and was entered in the corrective action program (IR 1662515), this violation is being treated as an NCV consistent with section 2.3.2 of the NRC Enforcement Policy. (NCV 05000289/2014003-02: UFSAR Max Hypothetical Dose Not Updated, Consistent with Current Plant Conditions)

.2 Semi-Annual Trend Review

Inspection Scope The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Exelon outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed Exelons corrective action program database for the first and second quarters of 2014 to assess issue reports written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily condition report review (Section 4OA2.1). The inspectors reviewed the current Exelon trend report (dated April 25, 2014), conducted under PI-AA-125-1005, Coding and Analysis Manual, to verify that Exelon personnel were appropriately evaluating and trending adverse conditions in accordance with applicable procedures.

Findings and Observations No findings were identified.

The station has identified three main focus areas: collective radiation exposure, equipment reliability, and human performance. The inspectors consider radiation exposure and human performance adequately monitored and controlled by the licensee.

The inspectors noted that degraded equipment has been a challenge to the station over the past three quarters based on impactful malfunctions that required downpowers to correct including two separate main turbine control valve servo malfunctions, B RCP oil piping failure, and A cooling tower failures. Station management has made this a focus area. A review of the quarterly trend report also identified weaknesses in documentation and procedure adequacy. The inspectors have observed examples of these weaknesses and considered this to be a work in progress based on the licensees improvement plan.

A prior negative trend observed by the inspectors regarding configuration control performance, which began during the fourth quarter of 2013 at TMI, has been addressed by the station in part by improving procedures, enforcing existing standards, and increased number of in-field observations.

.3 Annual Sample: Radiation Release in Containment Associated with Steam Generator

Removal Inspection Scope The inspector performed an in-depth review of Exelons root cause analysis, apparent cause analysis, and corrective actions associated with 10 CFR 72.75(b)(2) notification number 45514, Radiation Release in Containment Associated with Steam Generator Removal. This issue was discussed in NRC inspection report 050002894/2010007 which documented three Green NCVs.

Specifically, during late fall 2009, TMI was undergoing a refueling and steam generator replacement outage. On November 21, Exelon conducted primary pipe interior vacuuming operations within the reactor building (containment) in preparation for pipe end decontamination of the A steam generator cold leg. Workers used a vacuum cleaner designated for "Wet Use," which was not equipped with a high efficiency particulate air (HEPA) filter, to vacuum dry and damp highly radioactive material from the pipe interior. This vacuuming dispersed airborne radioactive particulate contamination into containment. 145 workers were determined to have sustained either low-level external radioactive contamination or low-level intakes of airborne radioactivity.

To accomplish the steam generator replacement, Exelon had previously completed cutting an approximate 24 foot (ft.) X 26 ft. construction opening into the TM containment. The opening provided an access point to support removal of the old steam generators and subsequent installation of the new steam generators. Exelon did not effectively manage the containment openings and ventilation systems to prevent unfiltered radioactive releases from the containment during the unintended generation of airborne radioactive contamination.

The inspector 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 to determine whether the planned or 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.

Findings and Observations No findings were identified.

Exelon determined that the root cause for the generation and spread of airborne radioactive contamination in containment was that radiological protection control of RCA wet vacuum cleaners was inadequate. Specifically, Exelon determined that most of their sites actively restrict the use of non-HEPA filter equipped vacuum cleaners from use within radiologically controlled areas (RCAs). The use of non-HEPA equipped vacuum cleaners within RCAs at TMI was allowed, but required careful oversight and evaluation of each application by trained TMI health physics personnel. Steam generator replacement project personnel (contract workers) at TMI did not have this training and were not aware that non-HEPA equipped vacuum cleaners were present (and might be used) in the RCA; therefore the necessary careful evaluation was not performed. Also, the TMI procedure for the control of RCA vacuum cleaners did not clearly state that non-HEPA equipped vacuums were to only be used on standing liquids.

Exelon determined that the apparent cause for the unfiltered radioactive releases from the containment was that procedural controls did not implement the requirements listed in the text of the engineering change request (ECR) (i.e., operation of the purge system and compensatory measures to be taken on a loss of purge). Specifically, procedure OP-TM-823-408 did not establish criteria for monitoring air flow, and for personnel to contact and actions to be taken upon the loss of containment purge flow. The ECR reviewers allowed the ECR to be issued without making the procedural changes needed to drive implementation of the ECR requirements.

Exelons extent of condition review identified that the TMI vacuum cleaner practices were not aligned with industry standards, and that Exelon does not have a corporate procedure to control the use of vacuum cleaners. Exelon also reviewed all outage-related ECRs to determine if any other procedure changes were needed to drive the implementation of ECR requirements, and reviewed outage work for any other openings in containment which might be affected.

Corrective actions included revising the TMI vacuum cleaner use procedure to preclude the use of non-HEPA filtered units, removal from service all non-HEPA filtered vacuum cleaners, and the inspection of all remaining vacuum cleaners. Other action included revising OP-TM-823-408 to implement the controls provided in the ECR for the containment construction opening, and providing training to ECR reviewers.

The inspectors determined that Exelons overall response to the issue was commensurate with the safety significance, was timely, and included appropriate corrective actions. The inspector determined that the actions taken were reasonable to resolve the issues of the airborne particulate radioactivity release and the loss of containment purge during high contamination work.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

Main article: IP 71153

.1 Plant Events (1 sample)

Inspection Scope For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the events to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.

Postulated hot short fire events that could adversely impact safe shutdown equipment, documented in IRs 1651702, 1658837, 1658842 and reported to NRC as EN 50059, 50108 on April 25 and May 12, 2014 Findings No findings were identified.

4OA6 Meetings, Including Exit

Radiation Safety Inspection (71124.01, 02, and 71151)

On April 25, 2014, the inspector presented the inspection results to Mr. Rick Libra, TMI Site Vice President, and other members of Exelon staff. The inspector verified that no proprietary information was retained by the inspector or would be documented in this report.

Problem Identification and Resolution - Annual Sample (71152)

On June 20, 2014, the inspector presented the inspection results to Mr. Brad Shumaker, Regulatory Assurance Manager (Acting), and other members of Exelon staff. The inspector verified that no proprietary information was retained by the inspector or would be documented in this report.

Radiation Monitoring Instrumentation (71124.05)

On June 27, 2014, the inspectors presented the inspection results to Mr. Mark Newcomer, TMI Plant Manager, and other members of Exelon staff.

The inspectors verified that no proprietary information was retained by the inspectors or would be documented in this report.

Quarterly Inspection Report Exit On July 18, 2014, the inspectors presented the inspection results to Mr. Rick Libra, TMI Site Vice President, and other members of the TMI staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.

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