IR 05000289/2016009
| ML16168A169 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/15/2016 |
| From: | Silas Kennedy NRC/RGN-I/DRP/PB6 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Kennedy S | |
| References | |
| IR 2016009 | |
| Download: ML16168A169 (16) | |
Text
June 15, 2016
SUBJECT:
THREE MILE ISLAND STATION, UNIT 1 - PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000289/2016009
Dear Mr. Hanson:
On May 19, 2016, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Three Mile Island Station, Unit 1 (TMI). The enclosed report documents the inspection results, which were discussed on May 19, 2016, with Mr. Thomas Haaf, Plant Manager, and other members of your staff.
This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commissions rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.
Based on the samples selected for review, the inspection team concluded that Exelon Generating Company, LLC (Exelon) was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems and entered them into the corrective action program at a low threshold. Exelon prioritized and evaluated issues commensurate with the safety significance of the problems and corrective actions were generally implemented in a timely manner.
No findings were identified during this inspection. In accordance with Title 10 of the Code of Federal Regulations (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 component of the NRCs Agencywide Documents Access and Management 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 No.
50-289 License No.
Enclosure:
Inspection Report 05000289/2016009 w/Attachment: Supplementary Information
REGION I==
Docket No.
50-289
License No.
Report No.
Licensee:
Exelon Generation Company, LLC
Facility:
Three Mile Island Station Unit 1
Location:
Middletown, Pennsylvania
Dates:
May 2, 2016, through May 19, 2016
Team Leader:
S. Shaffer, Senior Project Engineer
Inspectors:
B. Lin, Resident Inspector
L. Cruz, Project Engineer
T. Hedigan, Operations Engineer
Approved by:
Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects
SUMMARY
Inspection Report 05000289/2016009; 05/02/2016 - 05/19/2016; Three Mile Island Station
Unit 1 (TMI); Biennial Baseline Inspection of Problem Identification and Resolution.
This U.S. Nuclear Regulatory Commission (NRC) team inspection was performed by three regional inspectors and one resident inspector. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.
Problem Identification and Resolution
The inspectors concluded that Exelon Generating Company, LLC (Exelon) was generally effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program (CAP) at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences.
The inspectors also determined that Exelon typically implemented corrective actions to address the problems identified in the CAP in a timely manner.
The inspectors concluded that, in general, Exelon adequately identified, reviewed, and applied relevant industry operating experience to TMI operations. In addition, based on those items selected for review, the inspectors determined that Exelons self-assessments and audits were thorough.
Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual CAP and Employee Concerns Program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the sites safety conscious work environment.
No findings were identified.
REPORT DETAILS
OTHER ACTIVITIES (OA)
4OA2 Problem Identification and Resolution
This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. All documents reviewed during this inspection are listed in the Attachment to this report.
.1 Assessment of Corrective Action Program Effectiveness
a. Inspection Scope
The inspectors reviewed the procedures that described the CAP at TMI. To assess the effectiveness of the CAP, the inspectors reviewed performance in three primary areas:
problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in these areas to the requirements and standards contained in Title 10 of the Code of Federal Regulations (10 CFR) 50, Appendix B, Criterion XVI, Corrective Action, and Exelon procedure PI-AA-125, Corrective Action Program.
For each of these areas, the inspectors considered risk insights from the stations risk analysis and reviewed issue reports (IRs) selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended multiple station ownership committee (SOC) and management review committee (MRC)meetings. The inspectors selected items from the following functional areas for review:
engineering, operations, maintenance, emergency preparedness, radiation protection, chemistry, physical security, nuclear oversight, and the CAP.
- (1) Effectiveness of Problem Identification
In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventative maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as parts of the fire protection system, the component cooling water system, the emergency diesel generators, and the borated storage water tank (BWST). Additionally, the inspectors reviewed a sample of IRs written to document issues identified through internal self-assessments, audits, emergency preparedness drills, and the operating experience program. The inspectors completed this review to verify that Exelon staff entered conditions adverse to quality into their CAP as appropriate.
- (2) Effectiveness of Prioritization and Evaluation of Issues
The inspectors reviewed the evaluation and prioritization of a sample of IRs issued since the last NRC biennial Problem Identification and Resolution inspection completed in May 2014. The inspectors also reviewed IRs that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.
- (3) Effectiveness of Corrective Actions
The inspectors reviewed Exelons completed corrective actions through documentation review and, in some cases, field walkdowns to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed IRs for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelons timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of IRs associated with selected non-cited violations (NCVs) and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelons actions related to deficiencies associated with the BWST.
- (4) Trending
The inspectors reviewed TMIs processes for identifying and addressing emergent and existing adverse trends in equipment and human performance. The inspectors conducted interviews with plant staff who conducted the department trend reviews, reviewed department trend reports, site quarterly trend reports, maintenance rule performance monitoring reports, and a(1) action plans and evaluations as required by 10 CFR 50.65. The inspectors also reviewed the minutes from system health committee meetings.
b.
Assessment
- (1) Effectiveness of Problem Identification
Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon identified problems and entered them into the CAP at a low threshold. Exelon staff at TMI initiated approximately 20,000 IRs between April 2014 and May 2016. The inspectors observed supervisors at the Plan-of-the-Day, SOC, and MRC meetings appropriately questioning and challenging IRs to ensure clarification of the issues. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in IRs.
The inspectors verified that conditions adverse to quality identified through this review were entered into the CAP as appropriate. In general, the inspectors did not identify any issues or concerns that had not been appropriately entered into the CAP for evaluation and resolution. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Exelon personnel promptly initiated IRs and/or took immediate action to address the issues. The inspectors also observed that the SOC went back to the originators of several IRs in order to obtain additional details so the issue was clearly documented in the CAP and could be appropriately evaluated.
- (2) Effectiveness of Prioritization and Evaluation of Issues
The inspectors determined that, in general, Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem.
Exelon screened IRs for operability and reportability, categorized the IRs by significance, and assigned actions to the appropriate department for evaluation and resolution. The IR screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.
Based on the sample of IRs reviewed, the inspectors noted that the guidance provided by Exelon CAP implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. Root cause evaluations and apparent cause evaluations reviewed were completed when required and received management review prior to approval. However, the inspectors noted an observation in Exelons prioritization and evaluation of issues (described below).
The inspectors identified that on April 29, 2016, TMI operations staff performed Surveillance 1301-4.1, Weekly Surveillance Checks. Acceptance criteria of a five degree deviation was not met for one channel of Wide Range T cold (Tc) (RC-TI-961A).
Operations staff wrote IR 02663127 to document the issue and subsequently closed the IR to a Priority 3 action request which was assigned to the fix-it-now maintenance group for resolution. The inspectors noted that operations personnel reported a six degree deviation between RC-TI-961A and the reference analog meter (RC-5A/B TI-1). The Wide Range Tc instrument operability was not changed even though the acceptance criteria of the surveillance was not met. The stations basis for operability was documented in the IR and referenced the engineering evaluation 01345088-03. The engineering evaluation concluded that the actual acceptance criteria for these instruments is 6.6 degrees of deviation. The weekly surveillance was performed again on May 6, 2016, and a 10 degree deviation was noted. Although the step for the acceptance criteria was circled no, operations considered the instrument operable and the determination was documented in IR 02666370. On May 11, 2016, Surveillance 1301-4.1, Weekly Surveillance Checks, was revised to use the plant process computer digital point as the reference instead of the analog meter. The surveillance was performed satisfactorily on May 13, 2016.
Exelon procedure OP-AA-108-115, Operability Determinations, states that, TS
[technical specification] operability considerations require that an SSC [structure, system, or component] meet all surveillance requirements. An SSC that does not meet a surveillance requirement must be declared inoperable. A technical justification cannot be used to justify operability when a surveillance requirement is not met. The inspectors determined that not meeting the acceptance criteria for Wide Range Tc (RC-TI-961A) and not declaring the instrument inoperable was a performance deficiency.
This performance deficiency was considered minor because there is no allowed outage time and the station maintained the minimum required operable Wide Range Tc instruments in accordance with TS. Exelon entered this issue into the CAP as IR 02675010.
- (3) Effectiveness of Corrective Actions
The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence. The inspectors concluded that in most cases, corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were timely and effective.
- (4) Trending
The inspectors reviewed Exelons processes for identifying and addressing emergent and existing adverse trends in equipment and human performance. Exelon was able to identify trends at a low level using their department trending process. These trends were rolled up to station level on a quarterly basis and action and monitoring plans were developed as appropriate. Additionally, the stations maintenance rule performance monitoring program was effective in evaluating system performance and identifying trends. The SOC members also identified potential trends during their screening meeting and elevated the significance level of low level issues based on the identification of potential trends. During interviews, many staff members commented on the emphasis by management to enter issues into the CAP at a very low level so trends could be identified.
c. Findings
No findings were identified.
.2 Assessment of the Use of Operating Experience
a. Inspection Scope
The inspectors reviewed a sample of IRs associated with review of industry operating experience to determine whether the Exelon staff appropriately evaluated the operating experience information for applicability to TMI and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon staff adequately considered the underlying problems associated with the issues for resolution via their CAP. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.
b.
Assessment
The inspectors determined that Exelon staff, in general, appropriately considered industry operating experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Plan-of-the-Day meetings and pre-job briefs.
c. Findings
No findings were identified.
.3 Assessment of Self-Assessments and Audits
a. Inspection Scope
The inspectors reviewed a sample of audits, including the most recent audit of the CAP, departmental self-assessments, and assessments performed by independent organizations. The inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the CAP, when appropriate, and whether Exelon staff initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.
At the time of the inspection, the Exelon site nuclear oversight group had recently reorganized as part of a fleet-wide restructuring that eliminated the onsite nuclear assessment organization at nuclear plant sites. Since this reorganization had only been effective at TMI since February 1, 2016, the inspectors review of this area was based primarily on open assessments conducted under the previous organizational structure.
b.
Assessment
Based on the inspected sample, the inspectors concluded that self-assessments, audits, and other internal Exelon assessments were critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. When progress in improving performance was not being accomplished in a timely manner, Exelon staff escalated the issues. Exelon completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the CAP for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.
c. Findings
No findings were identified.
.4 Assessment of Safety Conscious Work Environment
a. Inspection Scope
During interviews with station personnel, the inspectors assessed the safety conscious work environment at TMI. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinators to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.
The inspectors reviewed the Employee Concerns Program files to ensure that the Exelon staff entered issues into the CAP when appropriate.
b.
Assessment
During interviews, Exelon staff expressed a willingness to use the CAP to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the CAP and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.
c. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On May 19, 2016, the inspectors presented the inspection results to Mr. Thomas Haaf, Plant Manager, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
E. Callan
Site Vice President
T. Haaf
Plant Manager
T. Alvey
Manager, Chemistry
T. Arnold
Manager, Corrective Action Program
J. Barrett
Acting Director, Site Maintenance
R. Campbell
Manager, Site Security
K. Coughlin
Engineering
S. Diven
Engineering
J. Dullinger
Director, Site Operations
M. Fitzwater
Senior Regulatory Assurance Engineer
L. Florey
Director, Site Training
R. Freeman
Senior Chemist
R. Gerner
Security
J. Goldman
Manager, Regulatory Assurance
J. Grove
Employee Concerns Program
T. Hall
Engineering
J. Karkoska
Manager, Organizational Effectiveness
T. Orth
Director, Site Work Management
J. Piazza
Senior Design Manager
M. Pruskowski
Senior Chemist
D. Reese
Engineering
T. Roberts
Radiation Protection
C. Smith
Manager, Operations Support
J. Smokowicz
Maintenance Support
M. Torberg
Engineering
D. Trostle
Senior Regulatory Specialist
C. Wolpertm
Security
B. Wunderly
Director, Site Engineering
B. Young
Manager, Maintenance
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened and Closed
None