IR 05000320/2019001

Gpu Nuclear, Inc., Three Mile Island Station, Unit 2 - NRC Inspection Report 05000320/2019001

ML19161A128
Person / Time
Site:	Three Mile Island
Issue date:	06/10/2019
From:	Racquel Powell Decommissioning Branch I
To:	Halnon G FirstEnergy Corp, GPU Nuclear
References
IR 2019001
Download: ML19161A128 (11)

Text

UNITED STATES une 10, 2019

SUBJECT:

GPU NUCLEAR, INC., THREE MILE ISLAND STATION, UNIT 2 - NRC INSPECTION REPORT 05000320/2019001

Dear Mr. Halnon:

On May 13 - 17, 2019, the U.S. Nuclear Regulatory Commission (NRC) conducted an onsite inspection at the Three Mile Island Station Unit 2 (TMI-2). The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and the conditions of your license. The inspection consisted of observations by the inspectors, interviews with personnel, and a review of procedures and records. The results of the inspection were discussed with M. Casey, TMI-2 Project Manager, GPU Nuclear Inc., and E. Callan, Site Vice President, Exelon Generating Company (Exelon),

and other members of Exelon management and staff on May 17, 2019, at the conclusion of the onsite inspection and are described in the enclosed report. No findings of safety significance were identified.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Katherine Warner (610-337-5389) if you have any questions regarding this matter.

Sincerely,

/RA SHammann for/

Raymond Powell, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Nuclear Materials Safety Enclosure: Inspection Report No. 05000320/2019001 cc w/encl: Distribution via ListServ

EXECUTIVE SUMMARY

GPU Nuclear, Inc. (GPUN)

Three Mile Island Station, Unit 2 (TMI-2)

NRC Inspection Report No. 05000320/2019001 A routine announced safety inspection was conducted on May 13 - 17, 2019 at TMI-2.

The inspectors reviewed TMI-2s Post-Defueling Monitored Storage (PDMS) activities related to the safe storage of radioactive material, including site operations, engineering, maintenance, plant support activities, management oversight, and corrective action program (CAP) implementation. The inspection consisted of observations by the inspectors, interviews with the FirstEnergy Corporation/GPUN (FirstEnergy/GPUN) and Exelon personnel, a review of procedures and records, and plant walk-downs including a containment entry. There are currently no ongoing decommissioning activities being conducted at TMI-2. The NRC's program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561,

"Decommissioning Power Reactor Inspection Program."

Based on the results of this inspection, no findings of safety significance were identified.

REPORT DETAILS

1.0 Background GPUN retains the license for TMI-2 and maintains the facility. GPUN is a wholly-owned subsidiary of FirstEnergy. As part of the sale of TMI-2, GPUN entered into an agreement with AmerGen (now Exelon) to conduct services for TMI-2. Under this agreement, Exelon provides all services, materials, and equipment required to maintain TMI-2 in PDMS status. Services provided by Exelon include maintenance, surveillance testing, and implementation of the activities required in the Safety Analysis Report (SAR), Technical Specification (TS), and the GPUN PDMS Quality Assurance (QA)

Plan.

In December 1993, TMI-2 received a possession-only license from the NRC to enter PDMS. Currently, TMI-2 is in long-term monitored storage. In June 2013, GPUN submitted to the NRC a Post-Shutdown Decommissioning Activities Report (PSDAR)

(ADAMS No. ML13190A366) pursuant to 10 Code of Federal Regulations (CFR)50.82(a)(4). GPUN submitted Revision 1 of their PSDAR in November 2013 (ADAMS No. ML13323A497) and Revision 2 in December 2015 (ML15338A222).

The NRC's program for overseeing the safe operation of a shut-down nuclear power reactor is described in IMC 2561.

2.0 Post-Defueling Monitored Storage Performance and Status Review

a. Inspection Scope

[Inspection Procedures (IPs) 36801, 37801, 40801, 62801, 71801, 83750, 84750, 86750 A routine announced safety inspection was conducted on May 13 - 17, 2019 at TMI-2.

The inspection consisted of observations by the inspectors, interviews with FirstEnergy/GPUN and Exelon personnel, a review of procedures and records, and plant walk-downs including a reactor building tour. The inspectors reviewed the PDMS program as outlined in the PDMS SAR, TS, and PSDAR. The inspectors reviewed PDMS activities related to the safe storage of radioactive material, including site operations, engineering, maintenance, plant support activities, management oversight, and CAP implementation. The inspectors also assessed the material condition of TMI-2 facilities during plant tours of the auxiliary building, fuel handling building, and parts of the reactor building.

The inspectors reviewed activities, components, and documentation associated with the following PDMS programs: occupational exposure, radioactive effluent control, and site radiological environmental monitoring program (REMP). The inspectors reviewed the offsite dose calculation manual, the radioactive gaseous effluent release permits, the annual REMP report, the groundwater monitoring program, and the annual effluent report, which included a summary of the radioactive waste management and transportation programs.

The inspectors reviewed QA audit documents and CAP reports associated with TMI-2 to determine if issues were being appropriately identified, assessed, and reviewed and that corrective actions were being appropriately implemented.

b. Observations and Findings

The inspectors confirmed that any design changes were appropriately evaluated through the 50.59 process when necessary. The inspectors confirmed that no dismantlement or decommissioning activities were performed since the previous inspection. The inspectors confirmed that all required reporting submittals were completed in accordance with TS requirements. The inspectors verified that the maintenance and surveillance program for systems and components had been conducted in accordance with the TS requirements and established procedures. During general plant walk-downs the inspectors did not observe any significant water intrusion into buildings and noted that the material condition of structures and components appeared unchanged since the previous inspection.

The inspector observed the reactor building entry surveillance test. The surveillance test consisted of visual inspections for water intrusion and a visual inspection to evaluate the structural integrity and material condition of structures and components in selected areas of the reactor building. The results of the surveillance test indicate that no significant water intrusion was evident and that the material condition of components remained unchanged in the areas accessed since the previous surveillance in 2015. The inspector verified that the maintenance and surveillance program for selected systems and components conducted during the reactor building entry were conducted in accordance with the TS requirements and established procedures.

The annual radiological effluent and REMP reports and supporting analyses demonstrated that all calculated doses were well below regulatory dose criteria of 10 CFR 50, Appendix I. The inspectors noted that there were no radioactive waste shipments from TMI-2 during calendar year 2018.

The inspectors determined that scheduled QA audits and self-assessments were conducted timely, and findings or issues identified by these reviews were entered into the stations CAP as Action Reports (AR). Based on the review of ARs, the inspectors noted that required corrective actions appear to be appropriately and timely implemented.

c. Conclusions

Based on the results of this inspection, no findings of safety significance were identified.

3.0

Exit Meeting Summary

On May 17, 2019, the inspectors debriefed the inspection results to M. Casey, TMI-2 Project Manager, GPU Nuclear Inc., and E. Callan, Site Vice President, Exelon and other members of Exelon management and staff. The inspectors confirmed that no proprietary information was retained by the inspectors or documented in this report.

PARTIAL LIST OF PERSONS CONTACTED Licensee J. Boyd, TMI-2 Consultant, FirstEnergy J. Byrne, TMI-2 Consultant, FirstEnergy E. Callan, Site Vice President, Exelon M. Casey, GPUN TMI-2 Responsible Engineer and Project Manager, FirstEnergy M. Fitzwater, Regulatory Assurance, Exelon E. Hertkorn, PDMS Supervisor, Exelon Generation Company, LLC B. Holmes, Manager Site Radiation Protection G. McCarty, Radiation Protection Manager, Exelon T. McLean, RP Technician G. Wright, PDMS Manager, Work Manager, Exelon ITEMS OPEN, CLOSED, AND DISCUSSED None LIST OF

DOCUMENTS REVIEWED

ARs

04093457 04140692 04208421

04097965 04145145 04210220

04100513 04152475 04212040

04106639 04152843 04215363

04106859 04157063 04215740

04110865 04162766 04221863

04112988 04166981 04222306

04120667 04170470 04229911

04123534 04175846 04230188

04125083 04176616 04239814

04127035 04182147 04238461

04127820 04183436 04249567

04131166 04186366 04249561

04137172 04195244

04137817 04205505

1000-PLN-72000.04, GPU Nuclear Post-Defueling Monitored Storage Quality Assurance Plan

(PDMS QA Plan) for Three Mile Island Unit 2, Revision 17

2017 Annual Radiological Environmental Operating Report, dated April 30, 2018

2018 Annual Radiological Environmental Operating Report, dated April 30, 2019

2104-1A, Reactor Building Entry, Revision 10

2104-29, TMI-2 Miscellaneous Liquid Radwaste Disposal in PDMS, Revision 11

2301-4.3, TMI-2 Reactor Building (Containment) PDMS Radiological Surveys, Revision 5

2303-6.1, TMI-2 Reactor Building Unfiltered Leak Rate Test, Revision 6

2303-11.20B, Operability Check of the TMI-2 Ante Room Personnel Airlock Doors, Revision 7

LIST OF DOCUMENTS REVIEWED (Contd)

ALARA Plan 19-006, Unit-2 Rx Bldg. Entry and Personnel & Equipment Hatch PMs, dated May

14, 2019

AP 19-006, TEDE ALARA Evaluation Screening Worksheet, dated May 13, 2019

Combined 2017 Annual Radioactive Effluent Release Report, dated April 30, 2018

Combined 2018 Annual Radioactive Effluent Release Report, dated April 29, 2019

PDMS Total Work Order Backlog, dated April 3, 2019

Post-Defueling Monitored Storage Safety Analysis Report, dated August 24, 2017

Post-Shutdown Decommissioning Activities Report, Revision 2, dated December 2015

Radiation Work Permit TM-2-19-00202- Revision 1

Radiation Work Permit TM-2-19-00211, Revision 01

Survey 15-00898

Survey 15-00899

Survey 2019-044115

Survey 2019-044114

Survey 2019-044310

Technical Specifications for PDMS - Amendment 63 for License 50-320 issued May 1, 2009

TMI-2 2018 Company Nuclear Review Board Annual Report, dated January 11, 2019

TMI-C-19-04-28, TMI-2 Post-Defueling Monitored Storage (PDMS) QA Activity Audit, dated April

2019

Unit 2 RB Contamination Levels data, dated May 13, 2019

Unit 2 RB Radiation Levels data, dated May 13, 2019

Work Orders

04664364-01

04664360-01

LIST OF ACRONYMS USED

AR Action Report

CAP Corrective Action Program

CFR Code of Federal Regulations

Exelon Exelon Generating Company

FirstEnergy FirstEnergy Corp.

GPUN GPU Nuclear, Inc.

IMC Inspection Manual Chapter

IP Inspection Procedure

NRC Nuclear Regulatory Commission

PDMS Post-Defueling Monitored Storage

PSDAR Post-Shutdown Decommissioning Activities Report

QA Quality Assurance

REMP Radiological Environmental Monitoring Program

SAR Safety Analysis Report

TMI-2 Three Mile Island Station, Unit 2

TS Technical Specifications

Attachment