Text

NRC Integrated Inspection Report 05000289/2014004 (July 1, 2014 - September 30, 2014)
	ML14317A309
Person / Time
Site:	Three Mile Island
Issue date:	11/13/2014
From:	Silas Kennedy; NRC/RGN-I/DRP/PB6
To:	Pacilio M; Exelon Nuclear
	KENNEDY, SR
References
	IR 2014004
	Download: ML14317A309 (45)
	v • d • e

ber 13, 2014

SUBJECT:

THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED INSPECTION REPORT 05000289/2014004

Dear Mr. Pacilio:

On September 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 October 17, 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 one violation of NRC requirements, which was of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements.

However, because of the very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation, consistent with Section 2.3.2a of the NRC Enforcement Policy. If you contest the non-cited violation 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 this 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/

Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-289 License Nos.: DPR-50

Enclosure:

Inspection Report 05000289/2014004 w/Attachment: Supplemental Information

REGION I==

Docket No: 50-289 License No: DPR-50 Report No: 05000289/2014004 Licensee: Exelon Generation Company Facility: Three Mile Island Station, Unit 1 Location: Middletown, PA 17057 Dates: July 1 through September 30, 2014 Inspectors: D. Werkheiser, Senior Resident Inspector, Division of Reactor Projects (DRP)

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

M. Modes, Senior Reactor Inspector, DRS H. Gray, Senior Reactor Inspector, DRS T. Burns, Reactor Inspector, DRS Approved by: S. Kennedy, Chief Projects Branch 6 Division of Reactor Projects (DRP)

Enclosure

SUMMARY

IR 05000289/2014004, 07/01/2014 - 09/30/2014; Three Mile Island, Unit 1, Maintaining

Emergency Preparedness.

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). 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, Aspects 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.

Cornerstone: Emergency Preparedness

Green.

The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2), 10 CFR 50.47(b)(10), and 10 CFR 50, Appendix E, Section IV.4, for failing to maintain the effectiveness of the Three Mile Island Nuclear Station (TMI)emergency plan as a result of failing to provide the station evacuation time estimate (ETE)to the responsible offsite response organizations (OROs) by the required date. Upon identification, Exelon entered this issue into its corrective action program (CAP) as issue reports (IRs) 1525923 and 1578649. Exelon submitted a third ETE for TMI on April 4, 2014, and the NRCs review of that ETE is documented in section 1EP4 of this report.

The finding is more than minor because it is associated with the Emergency Preparedness cornerstone attribute of procedure quality and adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The ETE is an input into the development of protective action strategies prior to an accident and to the protective action recommendation decision making process during an accident. Inadequate ETEs had the potential to reduce the effectiveness of public protective actions implemented by the OROs. The finding is determined to be of very low safety significance (Green) because it is a failure to comply with a non-risk significant portion of 10 CFR 50.47(b)(10). The cause of the finding is related to cross-cutting aspect of Human Performance, Documentation, because Exelon did not appropriately create and maintain complete, accurate and, up-to-date documentation [H.7]. (Section 1EP5)

REPORT DETAILS

Summary of Plant Status

Unit 1 began the inspection period at 100 percent power. On September 6, 2014, operators reduced power to approximately 89 percent to perform planned turbine valve testing and control rod drive exercises. Operators returned the unit to 100 percent on September 7, 2014, and remained at 100 percent 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

External Flooding

a. Inspection Scope

During the week of July 21, 2014, the inspectors performed an inspection of the external flood protection measures for TMI. The inspectors reviewed technical specifications; 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 an external flooding event. The inspectors conducted a general site walkdown of all external areas of the plant, including a detailed review of the control building, and dike to ensure that Exelon erected and maintained flood protection measures in accordance with design specifications. 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. Documents reviewed for each section of this inspection report are listed in the Attachment.

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:

B make-up system alignment during A unplanned system outage on July 14, 2014 Emergency feedwater systems during B emergency feedwater system outage on September 10 - 12, 2014 Nuclear river alignment during seasonal clamicide and heat exchanger backwashes, on September 25 - 26, 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, 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

No findings were identified.

.2 Full System Walkdown

Main article: IP 71111.04S

a. Inspection Scope

On September 26, 2014, the inspectors performed a complete system walkdown of accessible portions of the instrument air system to verify the existing equipment lineup was correct after a system outage of the main air compressor (IA-P-4) and upgrade to the air dryer (IA-Q-2) controller. The inspectors reviewed operating procedures, functional tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required important-to-safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and functionality 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 there were no deficiencies. 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

.1 Resident Inspector Quarterly Walkdowns

Main article: IP 71111.05Q

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.

Fuel handling building 380 elevation (FH-FZ-5) on July 8, 2014 Diesel Room B and Control Panel (DG-FA-2) on July 21, 2014 Control Building A Inverter Room (CB-FA-2D) on August 7, 2014 Fuel handling building 355/365 elevations (FH-FZ-5) on August 25, 2014 South Heating and Ventilation Equipment Room (CB-FZ-5A) on September 4, 2014

b. Findings

No findings were identified.

.2 Fire Protection - Drill Observation

Main article: IP 71111.05A

a. Inspection Scope

The inspectors observed an unannounced fire brigade drill conducted on July 31, 2014, that simulated a fire in the radiological controlled area of the 306 foot elevation of the TMI-1 fuel handling building, specifically at air-handling unit AH-E-26. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Exelon personnel identified deficiencies, openly discussed them in a self-critical manner at the drill debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows:

Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also evaluated the fire brigades actions to determine whether these actions were in accordance with Exelons fire-fighting strategies.

b. Findings

No findings were identified.

1R06 Flood Protection Measures

Main article: IP 71111.06

Internal Flooding Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the corrective action program to determine if Exelon identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors focused on building spray and decay heat pump vaults to verify the adequacy of equipment seals located below the flood-line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.

b. Findings

No findings were identified.

1R08 In-service Inspection

Main article: IP 71111.08

a. Inspection Scope

On September 18, 2014, the inspectors concluded an inspection of Exelon staffs evaluation of the tube wear indications of the two replacement once-through-steam generators which were discovered during the eddy current examination of the generators during the TMI Unit 1 20th refueling outage (T1R20).

Steam Generator (SG) Tube Inspection Activities (IMC Section 02.04)

The inspectors previously noted, in report 05000289/2013005, three SG tubes (48-118,49-118, and 49-119) in SG B containing wear indications that increased from 0%

through-wall-thickness to greater than the administrative plugging limit of 40% through-wall-thickness in one operating cycle. These tube to tube-support plate wear indications required additional review and evaluation by Exelon staff. Tube 49-119 with a wear indication of 62%, at tube support plate (TSP) 13, intersection 13S, was subject to the most limiting in-situ pressure testing criteria prior to plugging, and met the required pressure limits, without leaking, of 1.4 times the main-steam-line-break pressure (3605 psid), and 3 times the operating tube pressure differential (3P of 3830 psid).

The inspectors noted that tube 49-119 was held at 4800 psig for two minutes without structural failure or leakage. The inspectors further noted that tube 49-119 also had 58% wear at 10S, 48% wear at 11S, and 40% wear at 12S.

The inspectors noted that the number of new tube-support wear indications identified in T1R19 was 952 in SG A and 1232 in SG B. This increased during T1R20 to 2668 indications in SG A and 3600 indications in SG B. As a consequence of the 40% through wall wear limit Exelon staff plugged a total of 31 tubes in SG B with one tube preventatively plugged in SG A.

The inspectors reviewed the Exelons probable root-cause report referenced in the to this inspection report. The inspectors verified Exelons conclusion that the most probable cause was TSP partial locking to the shroud at the contact areas (wedges and alignment keys), by evaluating the basis for the identified contributing causes:

1. Reduced preload of the tubes may have increased TSP wear rates.

2. Manufacturing deviation from design specifications for shroud ovality during construction of the B SG may have increased the probability of TSP locking.

3. Higher steam flow exists at the location of the locked TSPs toward the periphery of the upper bundle in the B enhanced once-through-steam-generator.

The inspectors compared the results of Exelons probable root cause with Exelons Condition Monitoring and Operational Assessment (CMOA) report completed after T1R19 (listed in the Attachment to this inspection report). In the condition monitoring report, Exelon staff compared the as-found wear examination results from T1R19 for SG A and B with respect to criteria for structural integrity and accident leakage limits.

The Operational Assessment section provided a forward looking evaluation of the A and B SG conditions to ensure structural integrity and accident leakage performance criteria identified in the TMI Unit 1 technical specifications will not be exceeded during the current operating cycle.

The condition monitoring report documented Exelons conclusions that structural integrity and accident leakage limits were met during the previous operating cycle. The operational assessment report documented Exelons conclusions that the structural integrity and leakage performance criteria were predicted to be met over the next period of operation until the next planned SG inspection.

The inspectors reviewed the CMOA and requested additional clarifying information from Exelon staff (ADAMS ML14301A200). These information requests and Exelons responses are contained in the Special Attachment to this report. The inspectors subsequently completed onsite reviews of the CMOA and additional supporting analysis.

The operational assessment and supporting analyses was compared against Nuclear Energy Institute (NEI) document 97-06, "Steam Generator Program Guidelines,"

Revision 3 (ADAMS ML111310712), and Electric Power Research Institutes Steam Generator Integrity Assessment Guideline, Rev. 3 (ADAMS ML100480264). The inspectors noted the probability that the tube bundle will meet the minimum 3 delta P is predicated upon the probability of survival of each indication. The inspectors observed that Exelon staff computed over 1x106 Monte Carlo simulations in order to conservatively assess the probability-of-survival for repeat indications returned to service which resulted in a probability of 0.978. The inspectors also noted that Exelon calculated the maximum depth indication for the next outage based on 1 x 104 Monte Carlo simulations and a conservatively increased population of 3000 indications. This resulted in an expectation of a median deep indication of 69% through wall with an upper 95th value of 77% through wall. The probability of a structural flaw that exceeds the structural integrity limit is thus small.

b. Findings and Observations

No findings were identified.

The inspectors concluded:

1. The sensitivity analysis performed provides credibility to the conclusion that the

performance criteria will be met at the next inspection (i.e., tube integrity will be maintained until the next refueling outage).

2. The analysis performed supporting operation until the next refueling outage is at the limits of the methodology/technology since it is based on a benchmark that is highly uncertain.

3. Our initial concern that the operational assessment was inconsistent with past inspection results was supported by the sensitivity study (namely, the Bernard probability function analysis).

1R11 Licensed Operator Requalification Program

Main article: IP 71111.11Q

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on September 9, 2014, which included a steam leak coincident with the failure of all alternating current power.

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. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by the shift technical advisor. 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.

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

a. Inspection Scope

The inspectors observed crew A control room operations on September 10 and 11, 2014. Main activities were line-ups to support emergency feedwater partial system outage and control building ventilation changes for routine plant operations. The inspectors observed licensed operators 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, Revision 0. 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.

1R12 Maintenance Effectiveness

Main article: IP 71111.12Q

a. Inspection Scope

The inspectors reviewed the sample 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 the 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. Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.

North Bridge Structural Repairs on August 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.

Unplanned orange risk condition for an identified A high pressure injection header piping weld leak and subsequent repair on July 10 - 15, 2014 A emergency diesel generator during A air starting air compressor (EG-P-1A)unloader issues documented in IR 1686110 on July 29, 2014 Yellow risk condition for a planned calibration of the 1E 4 kilovolt degraded-grid relays on September 11, 2014 Yellow risk condition for a planned station outage window of the main instrument air compressor (IA-P-4) on September 23, 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:

TMI review of Westinghouse nuclear safety advisory letter #14-1 regarding performance of reactor coolant pump seals during a postulated loss of seal cooling, documented in IRs 1625829 and 1624353, on July 3, 2014 Identification of as-found zero-shift of the B high pressure injection flow transmitter (MU-FT-1127) following recovery of the A high pressure injection header as documented in IRs 1682046 and 1682189, on July 15, 2014 TMI review of potential defects regarding 3 inch and 4 inch valve diaphragms reported by ITT Engineered Valves LLC under 10 CFR 21 (ENs 48976 and 50285),and documented in IRs 1508556 and 1527123, on July 31, 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 the following permanent modifications:

Engineered Safeguards Actuation System (ESAS) relay replacement per engineering change request (ECR) 2013-00503 Instrument Air Compressor Dryer (IA-Q-2) controller upgrade implemented by ECR 2014-00310 The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including observing the physical replacement of the IA-Q-2 controller and the installation of the new ESAS cutler hammer relays. The inspectors also reviewed revisions to operating and test procedures.

a. 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.

A high pressure injection header piping weld (near MU-V-1034) repair on July 15, 2014 1A containment purge valve diagnostic testing and repairs on August 6, 2014 B ESAS relays (63X/RC8B & 43/RC4B) replacement on July 17, 2014 B emergency feedwater surveillance testing following system outage that included a rebuild of the pump discharge check valve (EF-V-11B), and B flow control valve controller (EF-V-30B) on September 9 - 12, 2014 Rebuild of the A condensate storage tank cross-connect valve actuator (EF-V-1A)on September 22, 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:

1302-5.18E, Calibration of A Decay Heat Flow Transmitter DH-DPT-802, on July 1, 2014 1300-6F, Spent Fuel Pool Leakage Exam for IST, on July 21, 2014 (in-service test)

OP-TM-541-203, IST of NS-V52A/B/C and NS-V-53A/B/C, on July 30, 2014 (in-service test)1300-3Q.5, Quarterly In-service Testing of CM-V-1/2/3/4 Valves During Normal Plant Operations, on August 11, 2014 (containment isolation valve)

OP-TM-220-252, Primary to Secondary Leak Rate Determination, on August 27, 2014 (leak rate test)

b. Findings

No findings were identified.

Cornerstone: Emergency Preparedness [EP]

1EP4 Emergency Action Level and Emergency Plan Changes (IP 71114.04)

a. Inspection Scope

The staff from the office of Nuclear Security and Incident Response (NSIR) performed an in-office review of the latest revision to Evacuation Time Estimate Analysis for Three Mile Island Nuclear Station, located under ADAMS Accession Number ML14101A164, as listed in the Attachment.

The staff performed a review using the guidance provided in NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies. The Updated Evacuation Time Estimate was found to be complete in accordance with 10 CFR Part 50, Appendix E.IV.3. The NRC review was only intended to verify consistent application of the ETE guidance contained in NUREG/CR-7002; and therefore remains subject to future NRC inspection in its entirety.

b. Findings

No findings were identified.

1EP5 Maintaining Emergency Preparedness (IP 71114.05)

Inspection Scope NRC Emergency Preparedness (EP) rulemaking, which became effective on December 23, 2011, added a new regulation which required a licensee to develop an ETE analysis and submit it to the NRC by December 23, 2012. This inspection was a follow-up of issues identified by the NSIR staff during its review of the Exelon submittal of the ETEs for the ten sites that it operated at the time. The NSIR staff related those issues to Exelon, which provided responses through 2013 and into 2014. During this inspection period, regional EP inspectors reviewed applicable licensee documents, conducted discussions with licensee personnel, and provided assessment of the Exelon responses.

Findings

Introduction:

The inspectors identified a Green NCV of 10 CFR 50.54(q)(2) for failing to maintain the effectiveness of the TMI emergency plan. Specifically, Exelon failed to provide the station ETE to responsible OROs and failed to update its site-specific protective action strategies as necessary as outlined in the requirements listed in 10 CFR 50.47(b)(10), and Section IV, Paragraph 4, of Appendix E to 10 CFR Part 50.

Description:

On November 23, 2011, the NRC issued final new and amended emergency preparedness regulations (76 Federal Register 72560) that required all licensees to update the ETE on a periodic basis. This rulemaking became effective on December 23, 2011. The rulemaking also added a new regulation 10 CFR Part 50, Appendix E, Section IV.4, which required licensees to develop an ETE analysis using the most recent decennial census data and submit it to the NRC within 365 days of December 23, 2011. Concurrently, with the issuance of the rulemaking, the NRC published a new report entitled Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002. The Statements of Consideration for the rulemaking (76 Federal Register 72580) identified that the NRC staff would review the submitted ETEs for completeness using that document. The Statements also provided that the guidance of NUREG/CR-2002 guidance was an acceptable template to meet the requirements and licensees should use the guidance or an appropriate alternative.

By individual letters dated December 12, 2012, Exelon submitted the ETEs for the sites for which it held the operating licenses, including TMI. By letter dated January 23, 2013, Exelon submitted the NUREG/CR-7002 checklists for the ETEs that identified where a particular criterion was addressed in the ETEs, facilitating the NRC review.

As provided in the Statements of Consideration, the NRC staff performed a completeness review using the checklists and found the ETEs (including the ETEs for TMI) to be incomplete due to common and site-specific deficiencies. The staff discussed its concerns regarding the completeness of the ETEs, in a teleconference with Exelon conducted on June 10, 2013. On September 5, 2013, Exelon resubmitted the ETEs and the associated checklists for its sites.

The NRC staff performed another completeness review and again found the ETEs to be incomplete. Examples of information missing from the submittal included: peak and average attendance were not stated (NUREG/CR-7002 Criteria Item 2.1.2.a); the ETE used a value based on campsite and hotel capacity, vice an average value (2.1.2.b); basis for speed and capacity reduction factors due to weather was not provided (3.4.b); snow removal was not addressed (3.4.c); no bus routes or plans were included in the ETE analysis (4.1.2.a); and, no discussion on the means of evacuating ambulatory and non-ambulatory residents was included (4.1.2.b). The staff communicated the various ETE issues to Exelon through several telephone conference calls.

Upon identification, Exelon entered this issue into its CAP as IRs 1525923 and 1578649.

Exelon submitted a third ETE for TMI on April 4, 2014, and the NRCs review of that ETE is documented in section 1EP4 of this report.

Analysis:

The inspectors determined that the failure to submit a complete updated ETE for the TMI by December 23, 2012, is a performance deficiency because Exelon failed to meet a regulatory requirement that was reasonably within its ability to foresee and correct, and should have been prevented, for both the December 12, 2012, and September 5, 2013, submittals.

Using IMC 0612, Appendix B, Issue Screening, the inspector determined that the performance deficiency is associated with the Emergency Preparedness cornerstone attribute of procedure quality and is more than minor because it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The ETE is an input into the development of protective action strategies prior to an accident and to the protective action recommendation decision making process during an accident. Inadequate ETEs had the potential to reduce the effectiveness of public protective actions implemented by the OROs.

The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process (SDP), to determine the significance of the performance deficiency.

The performance deficiency was associated with planning standard 10 CFR 50.47(b)(10). EP SDP Table 5.10-1, Significance Examples §50.47(b)(10), provides two Green significance examples: ETEs and updates to the ETEs were not provided to responsible OROs, and The current public protective action strategies documented in emergency preparedness implementing procedures (EPIPs) are not consistent with the current ETE. The inspectors concluded that, because the performance deficiency delayed the NRCs approval of the TMI ETE, the ETE was not provided to the site OROs nor was it used to inform the site EPIPs as required by 10 CFR 50.47(b)(10), and Section IV, Paragraph 4 of Appendix E to 10 CFR Part 50. Therefore, in accordance with EP SDP Table 5.10-1, this was determined to be a finding of very low safety significance (Green).

The cause of the finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelon personnel did not create and maintain complete, accurate and, up-to-date documentation. Specifically, the Emergency Preparedness organization did not develop the TMI ETE as required by the new regulation introduced by the NRCs EP Rule [H.7].

Enforcement:

10 CFR 50.54(q)(2) states, in part, that a licensee shall follow and maintain in effective emergency plans which meet the standards in 10 CFR 50.47(b)and the requirements in Appendix E to this part. 10 CFR 50.47(b)(10), states, in part, that licensees shall develop an evacuation time estimate and update it on a periodic basis. 10 CFR Part 50 Appendix E, Section IV.4, states that within 365 days of December 23, 2011, nuclear power reactor licensees shall develop an ETE analysis and submit it under § 50.4. Contrary to the above, the ETEs submitted by Exelon on December 12, 2012, and on September 5, 2013, for TMI were found to be inadequate. Upon identification, Exelon implemented immediate corrective actions by entering this issue into its CAP as IRs 1525923 and 1578649 and revising the ETE to satisfy NRC requirements. Because this finding is of very low safety significance (Green) and was entered into Exelons CAP, this issue is being treated as an NCV consistent with Section 2.3.2.a of the Enforcement Policy.

(NCV 05000289/2014004-01, Inadequate Evacuation Time Estimate Submittals)

OTHER ACTIVITIES

[OA]

4OA1 Performance Indicator Verification

Main article: IP 71151

.1 Safety System Functional Failures (1 sample)

a. Inspection Scope

The inspectors sampled Exelons submittals for the Safety System Functional Failures performance indicator for TMI for the period of July 1, 2013 through June 30, 2014. To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in the NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed Exelons operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, issue reports, event reports and NRC integrated inspection reports to validate the accuracy of the submittals.

b. Findings

No findings were identified.

.2 Mitigating Systems Performance Index (5 samples)

a. Inspection Scope

The inspectors reviewed Exelons submittal of the Mitigating Systems Performance Index for the following systems for the period of July 1, 2013 through June 30, 2014:

[MS 06] Emergency AC Power System (Emergency Diesel Generators)

[MS 07] High Pressure Safety Injection System (Makeup)

[MS 08] Emergency Feedwater System

[MS 09] Decay Heat Removal

[MS 10] Cooling Water Support Systems (Decay Closed, Decay River, Nuclear Closed, Nuclear River)

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, Revision 7. The inspectors also reviewed Exelons operator narrative logs, issue reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.

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 CAP 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 CAP and periodically attended issue report screening meetings.

b. Findings

No findings were identified.

.2 Annual Sample: Underground Pipe Leak from the A Decay River (DR) System

a. Inspection Scope

The inspectors performed an in-depth review of Exelon staffs identification, evaluation and corrective actions related to a leak in underground pipe from the TMI Unit 1 Intake Screen and Pump House (ISPH) in January 2012. Exelon staff observed indications of a leak on January 7, 2012. Exelon staff manipulated Decay Heat River Water System flows to determine the source of the water leaking to the surface was from A train of the Decay Heat River Water (DR-A) buried system piping. Exelon staff completed an operability evaluation and concluded the DR-A remained operable in part because the measured leak rate was well below the allowable leak rate of 160 gallons per minute for the DR system. Exelon staff established leakage limits for the remainder of the operating cycle under an adverse condition monitoring plan with action levels. During the refuel outage in November 2013, Exelon staff excavated the area where the surface water had accumulated and identified a circumferential crack in the DR piping. This component is pre-stressed concrete lined cylinder pipe twenty-four inches in diameter.

The crack was located 14 foot south of the ISPH wall. Subsequently, an additional crack was discovered in the adjacent Secondary Services River Water (SR) system about one foot north of the DR-A failure. Exelon staff removed these pipe sections and completed testing and analysis to determine the causes of the pipe cracks.

Based on metallurgical analysis at the Exelon Power Labs, Exelon staff concluded cause of the pipe failures was due to pipeline settlement and likely thrust block movement resulting from a substandard installation during original construction. This conclusion was supported by a detailed analysis of the pipe failure and the as-found positions of the pipelines. The failures of the DR-A and SR pipe sections likely occurred over a substantial period of time. Inadequate pipe installation during initial plant construction, as noted during the pipeline excavation, caused pipeline and likely thrust block movement. The settling was not rapid and initially precipitated mortar cracks at the bottom outside diameter of the subject pipelines. The breech in the mortar coating enabled ground water to contact the inner steel liner and initiated a stress amplified corrosion process that eventually resulted in leakage from the pipe.

The DR-A piping was replaced during refuel outage T1R20. The SR pipe crack was repaired with an external seal and internal Weko Seals. Exelon staff concluded that since the SR pipe has been repaired, the degradation process has been arrested and structural integrity should be maintained. In addition, Exelon staff utilized flowable fill for the repair of the DR-A and SR Piping. The flowable fill provided bedding that does not have voids and cures to form a stable mass similar to a cast in place thrust block.

The inspectors reviewed Exelon staffs problem identification threshold, apparent cause analyses, extent of condition reviews, and timeliness of corrective actions related to this issue. The inspectors reviewed the documents noted in the Attachment to this report and interviewed engineering personnel to assess the effectiveness of the planned, scheduled, and completed corrective actions to arrest the system leakage.

b. Findings and Observations

No findings were identified.

The inspectors reviewed action requests, issue reports, system health reports, drawings, photographs, and procedures and determined the pipe repair was appropriately identified, documented, characterized and entered into Exelons corrective action process consistent with Exelon CAP guidance and in compliance with 10 CFR Part 50, Appendix B requirements. Exelon Power Labs personnel determined that cracking was caused by corrosion and movement of pipe sections (bending) resulting from inadequate soil support.

The inspectors determined that this issue received appropriate management attention as indicated by the immediate corrective action taken to perform inspection and evaluation of both the A and B trains and the subsequent replacement of leaking pipe sections.

The evaluations were of sufficient technical detail to identify the likely causes of the pipe leaks and to develop corrective actions that will likely be effective. Additionally, the inspectors concluded the extent of condition reviews were sufficient and involved locating and inspecting similar buried pipe sections that did not identify additional leaks.

The inspectors determined that the corrective actions taken and planned adequately address the DR and SR piping.

.3 Annual Sample: Foxboro Power Supply 10 CFR 21 Corrective Actions

a. Inspection Scope

The inspectors performed an in-depth review of Exelons assessment and corrective actions in response to a reported deficiency (10 CFR 21) of Foxboro Nuclear SPEC-200 power supply potential failures due to defective cable ties and cable tie anchors (EN 48863). TMI identified that their current in-service and in-stock Foxboro power supplies were subject to the reported 10 CFR 21 deficiencies. Specifically, the cable ties and associate anchors had been known to degrade and fall into the power supply chassis, potentially causing a malfunction of the power supply. Exelon performed a review of the current power supply population at TMI and developed corrective actions to address the issue under IR 1496437.

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 and timely. The inspectors compared the actions taken to the requirements of Exelons CAP and 10 CFR 50, Appendix B. In addition, the inspectors performed field walkdowns and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions.

b. Findings and Observations

No findings were identified.

In 2013, Integrated Resources Inc. reported the discovery of repeated defects in the Foxboro power supplies used in Foxboro SPEC-200 cabinetry and reported the defects in a 10 CFR 21 report (EN 48863). The vendor identified that the tie wraps used to hold and route the power supply cable bundles throughout the chassis had experienced age related failures. In addition, the metallic tie wrap anchors adhesive would degrade over time and the failure of both the tie wrap and the anchor adhesive allowed the metallic anchor to fall into the chassis and potentially damage a circuit.

Exelon performed an immediate review of the Foxboro power supply 10 CFR 21 report.

Consequently, the defective components were identified during refurbishment of TMI Foxboro power supplies. Therefore, TMI was susceptible to the failure mechanism reported. Exelon performed an immediate operability review for the Foxboro power supplies currently in use in safety related applications and determined that no immediate operability concerns existed. However, expeditious replacement of the power supplies was warranted. Exelon entered the condition adverse to quality into the CAP under IR 1496437. Corrective actions include the removal and refurbishment of the in-service power supplies at the next opportunity commensurate with plant risk and operating mode. In addition, the warehouse stock of power supplies was refurbished to preclude the introduction of future failures.

The inspectors reviewed Exelons prompt operability determination, list of applicable power supplies in-service and actions to preclude future failures of the Foxboro power supplies. The inspectors determined that Exelons actions were reasonable and completed commensurate with the safety significance of the condition. In addition, the inspectors reviewed the refurbishment work order activity that resolved the condition adverse to quality and identified no issues of significance.

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

Main article: IP 71153

.1 Plant Events

a. 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.

Through-Wall Leak on High Pressure Injection (HPI) A Train Root Valve MU-V-1034 Socket Weld on July 10, 2014

b. Findings

No findings were identified.

.2 Notice of Enforcement Discretion (NOED) 14-1-03: NOED for Exelon Generation

Company, LLC Regarding Three Mile Island Unit 1

a. Inspection Scope

On July 10, 2014, at 5:30 p.m., the A train of HPI was declared inoperable, and a 72-hour limiting condition for operation (LCO) time clock was entered, when a small leak (1 drop every 2 minutes) was identified from a welded connection upstream on the line-side of an instrument root isolation valve (MU-V-1034). TMI Technical Specification 3.3.2 allows one train of HPI to be removed from service for maintenance during reactor operations for no more than 72 consecutive hours. During the execution of system isolation and non-destructive evaluation, Exelon determined that additional equipment was needed to obtain the necessary isolation of the system to complete the repairs.

Exelon requested enforcement discretion of TMIs Technical Specification 3.3.2 for 46.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months past the original expiration time (5:30 p.m. July 13, 2014) to affect repairs and restore the system.

The NRC staff reviewed Exelons request, which adequately addressed IMC 0410 criteria, and verbally granted the NOED during a telephone call at 5:19 p.m. on July 13, 2014. Exelon subsequently submitted a letter (ADAMS ML14197A293) on July 14, 2014, documenting information previously discussed with the NRC on telephone conferences held on July 13, 2014. Following completion of repairs and post-maintenance testing, Exelon exited Technical Specification LCO 3.3.2 at 9:53 a.m.

on July 15, 2014, incurring 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months and 23 minutes of the 46.5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months granted. The NRC documented the NOED details and confirmation that Exelons letter was consistent with the verbal NOED request in a letter dated July 17, 2014 (ADAMS ML14198A494).

Inspector activities during the NOED process included review and evaluation of technical documents, participation in teleconferences concerning the NOED request, verification, to the extent practicable, of Exelons oral assertions before the NOED was granted, and verification of Exelon compensatory actions to reduce the risk associated with plant configurations during HPI weld repairs.

The inspectors monitored licensee activities throughout the socket weld repairs including system isolation, troubleshooting, repair, and restoration. The inspectors also observed control room activities including use of procedures to configure the systems, technical specification adherence, NRC notification of the event, and operator actions during the system restoration.

b. Findings and Observations

No findings were identified.

Exelon entered the issue into their CAP (IR 1680680) and performed an Equipment Apparent Cause Evaluation to determine the cause of the failed welded connection upstream on the line-side of an instrument root isolation valve (MU-V-1034) and evaluate the cause of delays in achieving system isolation and plant conditions to allow leak repair. The most-probable cause of the weld leak was determined to be stress corrosion cracking. The cause of the delays in achieving conditions to commence repairs was determined to be due primarily to challenges in the availability of adequate freeze seal jackets and vender technical support in determining an adequate freeze seal.

The inspectors determined that the actions taken by Exelon to achieve early isolation for repairs, though initially unsuccessful, were timely and appropriate based on operating experience and plant conditions. The inspectors concluded there was no performance deficiency related to causes which led to the need for the NOED.

The inspectors identified a minor violation of NRC requirements while monitoring licensee activities during the initial response to the weld leak. Specifically, on July 11, 2014, during the draining of the A HPI header, in preparation for welding activities, operators exceeded the total maximum allowable leakage of 15 gallons per hour (GPH)into the auxiliary building sump as specified in Technical Specification Surveillance Requirement 4.5.4.1. The crew took immediate corrective actions to station a dedicated operator for prompt isolation, as needed, and continued to monitor sump in-leakage during draining. The inspectors determined the issue to be minor based on in-leakage did not exceed the 30 gallons per hour value assumed in the UFSAR (section 14.2.2.5)and that it had low safety impact considering the affected system (A HPI) was out of service. This issue was documented in IR 1681075. The failure to comply with Technical Specification Surveillance Requirement 4.5.4.1 constitutes a minor violation that is not subject to enforcement action in accordance with the NRCs Enforcement Policy.

In most cases, the inspectors would open an unresolved item (URI) when the NOED was granted in accordance with IMC 0410, Notices of Enforcement Discretion. The purpose of the URI would be to determine if there is a performance deficiency for causes which led to the need for the NOED. Because this inspection activity occurred during the same quarter in which the NOED was granted and the inspectors did not identify any performance deficiency associated with the NOED, the inspectors determined that an URI was not required for this issue.

.3 (Closed) Licensee Event Report (LER) 05000289/2013-001-00 and Supplement 01:

Reactor Coolant B Cold Leg Drain Line Flaw

a. Inspection Scope

During the November 2013 refuel outage (1R20) a flaw, a short crack approximately 66% thru wall, was identified in the reactor coolant "B" cold leg 2-inch drain line elbow to pipe weld RC-289. No leakage was associated with the flaw. As this flaw represented a degraded reactor coolant system pressure boundary, the condition was reported to the NRC as required by 10 CFR 50.72(b)(3)(ii)(A), and LER 2013-001-00, "Reactor Coolant "B" Cold Leg Drain Line Flaw" was initiated by the TMI Staff. The area surrounding the flaw was removed and provided for metallurgical laboratory analysis, and replacement to American Society of Mechanical Engineers Code standards of the material in the flaw area was completed. The pipe section was destructively tested for analysis and results documented in supplemental LER 2013-001-01.

As part of the in-service inspection by the NRC during the 1R20 refueling outage, the ultrasonic examination results were observed by the inspector and the previous weld examination results and history were reviewed. Additionally, the inspector reviewed the initial root cause report dated December 20, 2013, the LERs dated January 6 and June 20, 2014, and the final root cause report dated May 16, 2014, that included the metallurgical laboratory results. The inspectors did not identify any new issues during the review of the LERs. These LERs are closed.

.4 (Closed) LER 05000289/2014-002-00: Through-Wall Leak on High Pressure Injection

(HPI) A Train Root Valve MU-V-1034 Socket Weld The description of the event related to this LER is documented in section 4OA3.2, NOED 14-1-03: NOED for Exelon Generation Company, LLC Regarding Three Mile Island Unit 1. As this represented a condition prohibited by plant technical specifications, it was reported to the NRC as required by 10 CFR 50.72(a)(2)(i)(B),and LER 2014-002-00. The LER was reviewed and no new findings were identified.

However, the inspectors identified a minor violation of Technical Specification Surveillance Requirement 4.5.4.1 which is documented in section 4OA3.2. This LER is closed.

4OA6 Meetings, Including Exit

Quarterly Inspection Report Exit On October 17, 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.

ATTACHMENT: