IR 05000289/2019003

Integrated Inspection Report 05000289/2019003

ML19310F292
Person / Time
Site:	Three Mile Island
Issue date:	11/06/2019
From:	Matt Young NRC/RGN-I/DRP/PB5
To:	Bryan Hanson Exelon Generation Co
References
EPID I-2019-003-0034 IR 2019003
Download: ML19310F292 (14)

Text

ber 6, 2019

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - INTEGRATED INSPECTION REPORT 05000289/2019003

Dear Mr. Hanson:

On September 30, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Three Mile Island Nuclear Station, Unit 1. On October 8, 2019, the NRC inspectors discussed the results of this inspection with Mr. Trevor Orth, Site Decommissioning Director, and other members of your staff. The results of this inspection are documented in the enclosed report.

No NRC-identified or self-revealing findings were identified during this inspection.

A licensee-identified violation which was determined to be of very low safety significance is documented in this report. We are treating this violation as a non-cited violation (NCV)

consistent with Section 2.3.2 of the Enforcement Policy.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Matthew R. Young, Chief Reactor Projects Branch 5 Division of Reactor Projects Docket No. 05000289 License No. DPR-50

Enclosure:

As stated

Inspection Report

Docket Number: 05000289 License Number: DPR-50 Report Number: 05000289/2019003 Enterprise Identifier: I-2019-003-0034 Licensee: Exelon Generation Company, LLC Facility: Three Mile Island Nuclear Station, Unit 1 Location: Middletown, PA 17057 Inspection Dates: July 1, 2019, to September 30, 2019 Inspectors: Z. Hollcraft, Senior Resident Inspector S. Ghrayeb, Resident Inspector B. Lin, Nuclear Systems Engineer J. Heinly, Senior Resident Inspector R. Rolph, Health Physicist Approved By: Matthew R. Young, Chief Reactor Projects Branch 5 Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at Three Mile Island Nuclear Station,

Unit 1, in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors.

Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. A licensee-identified non-cited violation is documented in report section: 71111.05Q.

List of Findings and Violations No findings or violations of more than minor significance were identified.

Additional Tracking Items None.

PLANT STATUS

Unit 1 began the inspection period at rated thermal power. On September 20, 2019, Unit 1 was shutdown for defueling outage 1D23. The unit was defueled on September 26, 2019, and Certification of Permanent Removal of Fuel Letter ML19269E480 was submitted.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors performed plant status activities described in IMC 2515, Appendix D, Plant Status, and conducted routine reviews using IP 71152, Problem Identification and Resolution. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

71111.04Q - Equipment Alignment Partial Walkdown Sample (IP Section 03.01)

The inspectors evaluated system configurations during partial walkdowns of the following systems/trains:

(1) Train 'A' decay heat river system following inservice testing on August 1, 2019

(2) Nuclear river pump 1C on August 19, 2019

(3) Train 'B' decay heat river system during elevated risk due to reactor coolant system cooldown operations on September 21, 2019

71111.05Q - Fire Protection Quarterly Inspection (IP Section 03.01)

The inspectors evaluated fire protection program implementation in the following selected areas:

(1) Intake screen pump house, 308-foot elevation, on July 2, 2019

(2) Fuel handling building, 281-foot elevation, on August 6, 2019

(3) Fuel handling building, 305/306-foot elevation, on August 6, 2019

(4) Fuel handling building, 329-foot elevation, on August 6, 2019

(5) Control building relay room, 338-foot elevation, on September 6, 2019

71111.11Q - Licensed Operator Requalification Program and Licensed Operator Performance Licensed Operator Performance in the Actual Plant/Main Control Room (IP Section 03.01)

(1) The inspectors observed and evaluated licensed operator performance in the main control room during a plant shutdown on September 20, 2019.

Licensed Operator Requalification Training/Examinations (IP Section 03.02) (1 Sample)

(1) The inspectors observed and evaluated licensed operator performance in the simulator during shutdown/cooldown just-in-time training on September 19, 2019.

71111.12 - Maintenance Effectiveness Routine Maintenance Effectiveness Inspection (IP Section 02.01)

The inspectors evaluated the effectiveness of routine maintenance activities associated with the following equipment and/or safety significant functions:

(1) Repair of station blackout diesel standby lube oil pump due to out of band lube oil temperature on May 3, 2019

(2) 'B' feedwater pipe leak near HD-V-32B on September 3, 2019

71111.13 - Maintenance Risk Assessments and Emergent Work Control Risk Assessment and Management Sample (IP Section 03.01)

The inspectors evaluated the risk assessments for the following planned and emergent work activities:

(1) 'B' main transformer 'B' phase bus connector high temperature on July 24, 2019

(2) 'B' feedwater heater drain steam leak response and repair on August 29, 2019

71111.15 - Operability Determinations and Functionality Assessments Operability Determination or Functionality Assessment (IP Section 02.02)

The inspectors evaluated the following operability determinations and functionality assessments:

(1) 'A' train steam supply to turbine driven emergency feedwater pump MS-V-13A slow actuation on July 5, 2019

(2) Diesel fuel storage tank level instrument DF-LI-152 on July 16, 2019

(3) Degraded cable supports in vault E-7 on August 7, 2019

(4) 'C' make up pump high vibrations on August 16, 2019

(5) 'B' train decay river pump elevated vibrations on August 29, 2019

(6) Nuclear service river water through-wall leak on September 6, 2019

71111.18 - Plant Modifications Temporary Modifications and/or Permanent Modifications (IP Section 03.01 and/or 03.02)

The inspectors evaluated the following temporary or permanent modifications:

(1) Spent fuel pool tell-tale drain reroute back to pool on September 19, 2019

71111.19 - Post-Maintenance Testing Post-Maintenance Test Sample (IP Section 03.01)

The inspectors evaluated the following post maintenance tests:

(1) Fire barrier seal #7 repair on July 19, 2019

(2) Leak repair of 'B' feedwater pipe upstream of HD-V-32B on September 3, 2019

71111.20 - Refueling and Other Outage Activities Refueling/Other Outage Sample (IP Section 03.01)

(1) The inspectors evaluated decomissioning outage 1D23 from September 20 to September 27, 2019. This inspection was completed in accordance with Operating Experience Smart Sample (OpESS) 2007/03.

71111.22 - Surveillance Testing The inspectors evaluated the following surveillance tests: Surveillance Tests (other) (IP Section 03.01)

(1) 'A' emergency diesel generator monthly run on August 7, 2019

(2) MU-P-1C run on August 12, 2019

(3) Channel 1 testing of the HPI/LPI engineered safeguards system logic on September 18, 2019

Inservice Testing (IP Section 03.01) (1 Sample)

(1) Inservice testing of 'A' train decay river pump and valves on August 1,

71124.01 - Radiological Hazard Assessment and Exposure Controls Instructions to Workers (IP Section 02.02)

The inspectors evaluated instructions to workers including radiation work permits used to access high radiation areas.

(1) The inspectors reviewed the following:

Radiation Work Packages TM-1-19-00613, Outage Containment Reactor Head Disassembly/Assembly TM-1-19-00614, Outage Containment Reactor Upper Internals Move TM-1-19-00631, Outage Containment Radiation Protection Activities Electronic Alarming Dosimeter Alarms No alarms occurred during the period of this inspection.

Labeling of Containers The inspectors verified labeling of several containers in the Containment.

Radiological Hazards Control and Work Coverage (IP Section 02.04) (1 Sample)

The inspectors evaluated in-plant radiological conditions during facility walkdowns and observation of radiological work activities.

(1) The inspectors also reviewed the following radiological work package for areas with airborne radioactivity:

No work packages were available for review during this inspection.

High Radiation Area and Very High Radiation Area Controls (IP Section 02.05) (1 Sample)

(1) The inspectors evaluated risk-significant high radiation area and very high radiation area controls.

Radiation Worker Performance and Radiation Protection Technician Proficiency (IP Section 02.06) (1 Sample)

(1) The inspectors evaluated radiation worker performance and radiation protection technician proficiency.

71124.03 - In-Plant Airborne Radioactivity Control and Mitigation Use of Respiratory Protection Devices (IP Section 02.02)

The inspectors evaluated the licensees use of respiratory protection devices by:

(1) There were no opportunities to observe workers using respiratory protection devices for this inspection.

71124.04 - Occupational Dose Assessment Source Term Categorization (IP Section 02.01)

(1) The inspectors evaluated the licensees characterization of the source term and use of scaling factors for the use of hard-to-detect radionuclide activity.

OTHER ACTIVITIES - BASELINE

===71151 - Performance Indicator Verification The inspectors verified licensee performance indicators submittals listed below:

MS05: Safety System Functional Failures (SSFFs) Sample (IP Section 02.04) ===

(1) July 1, 2018, through June 30, 2019 MS06: Emergency AC Power Systems (IP Section 02.05) (1 Sample)

(1) July 1, 2018, through June 30, 2019 MS07: High Pressure Injection Systems (IP Section 02.06) (1 Sample)

(1) July 1, 2018, through June 30, 2019

MS08: Heat Removal Systems (IP Section 02.07) (1 Sample)

(1) July 1, 2018, through June 30, 2019 MS09: Residual Heat Removal Systems (IP Section 02.08) (1 Sample)

(1) July 1, 2018, through June 30, 2019 MS10: Cooling Water Support Systems (IP Section 02.09) (1 Sample)

(1) July 1, 2018, through June 30, 2019 OR01: Occupational Exposure Control Effectiveness Sample (IP Section 02.15) (1 Sample)

(1) July 1, 2018, through June 30, 2019 PR01: Radiological Effluent Technical Specifications/Offsite Dose Calculation Manual Radiological Effluent Occurrences (RETS/ODCM) Radiological Effluent Occurrences Sample (IP Section 02.16) (1 Sample)

(1) July 1, 2018, through June 30, 2019

71152 - Problem Identification and Resolution Annual Follow-up of Selected Issues (IP Section 02.03)

The inspectors reviewed the licensees implementation of its corrective action program related to the following issues:

(1) History of emergency diesel exhaust fires in January 2019 most recently documented in corrective action document incident report (IR) 04207683

(2) Corrective actions taken associated with an inadequate zone of protection under IR

INSPECTION RESULTS

Licensee-Identified Non-Cited Violation 71111.05Q This violation of very low safety significance was identified by the licensee and has been entered into the licensee corrective action program and is being treated as a non-cited violation, consistent with Section 2.3.2 of the Enforcement Policy.

Violation: Three Mile Island Nuclear Station, Unit No. 1, Operating License Condition 2.C(4),

Fire Protection, requires, in part, that the licensee implement and maintain in effect all provisions of the approved fire protection program as described in the updated final safety analysis report. Administrative Procedure 1038, Administrative Controls - Fire Protection Program, Revision 88, Exhibit 2, Section 7.0, Fire Barrier Components, requires that all fire barrier components (penetration seals) protecting safety related areas shall be functional at all times.

Contrary to the above, a fire penetration seal was determined to be nonfunctional from October 2013 to July 16, 2019. The licensee identified a 1-inch long, 1/2-inch wide, and 5-inch deep cavity through fire barrier foam seal #7 separating the 355-foot elevation control room from the 338.5-foot elevation relay room of the Control building.

Significance/Severity: Green. Using IMC 0609, Attachment 4, Initial Characterization of Findings, dated October 7, 2016, the finding was determined to require additional evaluation under IMC 0609, Appendix F, Attachment 1, Fire Protection Significance Determination Process Worksheet, dated September 20, 2013. The finding was screened as a Green finding of very low safety significance in accordance with Step 1.4.4, Fire Confinement, Question B.

Corrective Action References: IR 04264804, IR 04265506 Observation: Review of Root Cause Evalution for Human Performance Issue 71152 Documented in IR 04093679 The inspectors reviewed corrective actions taken associated with an inadequate zone of protection in accordance with Exelon procedure OP-MA-109-101, Clearance and Tagging, which was documented under IR 04093679 in Exelons corrective action program. OP-MA-109-101 is a corporate procedure that provides the guidance and requirements to perform clearance and tagging to ensure adequate zone of protection for individuals performing maintenance on equipment.

On January 15, 2018, while work was in progress to repair a fire service valve, FS-V-224, leak, it was identified that the active clearance had an inadequate zone of protection. All work was stopped and no workers were exposed to hazardous energy. Exelon entered the condition into the corrective action program under IR 04093679 and performed a root cause evaluation. The evaluation determined that a clearance boundary point had been inadvertently deleted from the clearance by the operations clearance writer. The operations supervisory review of the clearance was not performed with adequate technical rigor and failed to identify the missing clearance boundary point. Furthermore, the maintenance supervisor that held the clearance did not walk down the clearance boundary, as required, prior to commencing work to ensure an adequate zone of protection. Exelon determined that the clearance writer, approver, and maintenance supervisor did not follow the requirements of OP-MA-109-101 and personal accountability corrective actions were established to ensure the human performance errors would not be repeated. Furthermore, training exercises were given to all clearance applier/removers, writers, confirmers, and holders to re-certify them prior to performing any additional clearance activities.

The inspectors reviewed Exelons cause evaluation and determined that they adequately identified the causes and that the corrective actions to prevent recurrence were reasonable. Furthermore, the inspectors interviewed qualified clearance and tagging individuals and reviewed the supervisory observation data. The inspectors determined that the corrective actions have adequately reinforced clearance writing/application fundamentals and improved the station clearance and tagging performance. The inspectors did note that Exelon implemented additional improvement actions to consistently observe and track performance of all aspects of the clearance process. The inspectors did not identify any issues of concerns.

Observation: History of Emergency Diesel Exhaust Fires 71152 The inspectors reviewed the licensee's actions in response to a trend of diesel exhaust fires. Specifically, since 2005, Exelon experienced small exhaust fires on the emergency diesel generators during regularly scheduled surveillance runs. The cause of these fires was traced to a known issue with Fairbanks Morse opposed piston style diesels (the style at Three Mile Island) where excess fuel collects in the cylinders and then exhausts into the hot exhaust manifold where it can catch fire. This generic issue was discussed in NRC Information Notice 2008-05. Exelon implemented a modification to its diesels in 2017 that installed a drain on the ring catcher on the exhaust lines. By blowing down the exhaust regularly the licensee ensures there is no excess oil that can catch fire in the line.

In January 2019, during a surveillance run, the 'A' emergency diesel experienced a small fire on the exhaust manifold. Given the recently implemented corrective actions to prevent exhaust fires, the inspectors reviewed this particular issue to determine if the actions were inadequate. The licensee determined the cause to be oil weeping from the front cover that had collected over time and saturated into the outer insulation of the exhuast manifold. That is, the cause was different than the previous documented issues. This caused the inspectors to review the previously mentioned information notice which also contained instances similar to this new phenomenon. The cause of those issues at other sites was inadequately torqued fasteners on diesel top covers. The inspectors verified that the licensee correctly torqued the front cover fasteners and checked the tightness following the January event. As a corrective action, the licensee replaced the mastic coating on the insulation to ensure that the oil could not seep through to the insulation below. This issue was documented in IR

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

On October 8, 2019, the inspectors presented the integrated inspection results to Mr. Trevor Orth, Site Decommissioning Director, and other members of the licensee staff.

On September 26, 2019, the inspectors presented the radiological safety inspection results to Mr. Ed Callan, Site Vice President, and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

71111.04Q Drawings 302-202 Nuclear Services River Water System Revision 84

71111.04Q Procedures OP-TM-533-000 Decay Heat River System Revision 11

71111.04Q Procedures OP-TM-541 Primary Component Cooling Revision 24A

71111.05Q Fire Plans FH-FZ-1/2/3 Fuel Handling Bldg. Elev. 281', 305'/306', 324'; General Area Revision 4

71111.05Q Fire Plans IPSH-FA-2 Intake Screen Pump House Elevation 308'; FS-P-3 Revision 3

71111.05Q Fire Plans ISPH-FZ-1 Intake Screen Pump House Elevation 308'; 1R Switchgear Revision 6

and Pump Area

71111.05Q Fire Plans ISPH-FZ-2 Intake Screen Pump House Elevation 308'; 1T Switchgear Revision 6

and Pump Area

71111.05Q Fire Plans ISPH-FZ-3 Intake Screen Pump House Elevation 308'; Trash Rake and Revision 4

Screen Area

71111.12 Corrective Action 04246208

Documents

71111.12 Engineering Lube Oil Temperature Failure for the Station Blackout Diesel Revision 0

Evaluations

71111.13 Procedures OP-TM-421-429 Removing HP Heater String B from Service at Power Revision 6

71111.13 Work Orders 04939826

71111.15 Corrective Action 04250784

Documents

71111.15 Corrective Action 04261982

Documents

71111.15 Corrective Action 04262035

Documents

71111.15 Corrective Action 04264368

Documents

71111.15 Corrective Action 04267770

Documents

71111.15 Corrective Action 04271246

Documents

71111.15 Corrective Action 04274937

Documents

71111.15 Corrective Action 42770203

Documents

71111.15 Engineering 629211 Code Case N-513 Analysis of Leak Near NR-V-12B Revision 0

Changes

71111.18 Corrective Action 04280615

Documents

Resulting from

Inspection

71111.18 Engineering 628655 SFP Tell-Tale Reroute Back to Pool Revision 0

Changes

71111.19 Procedures CC-AA-404 Maintenance Specification: Application Selection, Revision 8

Evaluation, and Control of Temporary Leak Repairs

71111.19 Work Orders 04942171

71111.20 Corrective Action 04281100

Documents

Resulting from

Inspection

71111.20 Miscellaneous T1D23 Shutdown Safety Plan Revision 0

71111.20 Procedures 1102-10 Plant Shutdown Revision 102A

71111.20 Procedures 1102-11 Plant Cooldown Revision 157

71111.20 Procedures 1102-4 Power Operation Revision 138

71111.20 Procedures 1103-11 RCS Water Level Control Revision 77A

71111.20 Procedures 1507-1 Polar Crane Operation Revision 27

71111.22 Procedures 1303-4.11 HPI/LPI Logic and Analog Channel Test Revision 60

71111.22 Procedures OP-TM-211-208 IST of MU-P-1C Revision 9

71111.22 Work Orders 04919400

71124.01 Corrective Action 04230795

Documents

71124.01 Corrective Action 04267683

Documents

71124.01 Corrective Action 04268319

Documents

71124.01 Corrective Action 04269054

Documents

71152 Corrective Action 04207683

Documents

2