IR 05000320/2022004
| ML23047A032 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/16/2023 |
| From: | Anthony Dimitriadis Decommissioning, ISFSI, and Reactor Health Physics Branch |
| To: | Sauger J TMI-2 Solutions |
| References | |
| IR 2022004, IR 2022401 | |
| Download: ML23047A032 (1) | |
Text
February 16, 2023
SUBJECT:
TMI-2 SOLUTIONS, LLC, THREE MILE ISLAND NUCLEAR STATION, UNIT 2 -
NRC INSPECTION REPORT NOS. 05000320/2022004 and 05000320/2022401
Dear John Sauger:
On December 31, 2022, the U.S. Nuclear Regulatory Commission (NRC) co mpleted an inspection under Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program, at the permanently shutdown Three Mile Island Nuclear Station, Unit 2 (TMI-2). On-site inspections w ere performed September 12-15, and October 25-26, 2022.
Additional inspection activities (in office reviews) were conducted remotely during the inspection period. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and the conditions of your license.
The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records and plant walk-downs. The results of the inspection were discussed with S ergio Vazquez, Project Director, and other members of the TMI -2 staff on January 25, 2023, and are described in the enclosed report.
Within the scope of this inspection, no violations of more than minor safety significance were identified.
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 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, if any, 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).
J. Sauger 2
No reply to this letter is required. Please contact Steve Hammann of my staff at 610-337-5399, if you have any questions regarding this matter.
Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security
Docket No.: 05000320 License No. : DPR-73
Enclosure:
Inspection Report Nos.: 05000320/2022004 and 0 5000320/20224 01
REGION 1
INSPECTION REPORT
Inspection No s. 05000320/2022004 and 05000320/2022401
Docket No.: 05000320
License No.: DPR-73
Licensee: TMI-2 Solutions, LLC (TMI-2 Solutions)
Facility: Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Location: Middletown, PA 17057
Inspection Dates: July 1, 2022 to December 31, 2022
Inspectors: Stephen Hammann, Senior Health Physicist Decommissioning, ISFSI, and Reactor HP Branch Division of Radiological Safety and Security
Katherine Warner, Senior Health Physicist Decommissioning, ISFSI, and Reactor HP Branch Division of Radiological Safety and Security
Dana Caron, Senior Physical Security Inspector Security, Emergency Preparedness, and Incident Response Branch Division of Radiological Safety and Security
Sammy McCarver, Physical Security Inspector Security, Emergency Preparedness, and Incident Response Branch Division of Radiological Safety and Security
Approved By: Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor HP Branch Division of Radiological Safety and Security
EXECUTIVE SUMMARY
TMI-2 Solutions, LLC Three Mile Island Unit 2 NRC Inspection Report Nos. 05000320/2022 004 and 05000320/20224 01
A routine announced decommissioning inspection was completed at the permanently shut-down TMI-2 on December 31, 2022. On -site inspections were performed September 12-15, and October 25-26, 2022. The inspection included a review of fire protection, occupational exposure, decommissioning status, and Title 10 of the Code of Federal Regulations (10 CFR) Part 37 materials security. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. The NRC's program for overseeing the safe monitored storage 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 violations of more than minor safety significance were identified.
1.0 Background
In December 1993, TMI-2 received a possession-only license from the NRC to enter Post-Defueling Monitored Storage (PDMS). Currently, TMI-2 is in long-term monitored storage. On December 18, 2020, the license for TMI-2 was transferred from GPU Nuclear, Inc. to TMI-2 Solutions. An agreement is in place between TMI-2 Solutions and Constellation Energy Generation, LLC (Constellation) regarding TMI-2. Under this agreement, Constellation provides most s ervices, materials, and equipment required to maintain TMI-2 in PDMS status. On March 17, 2021, TMI-2 Solutions submitted Revision 4 of the Post-Shutdown Decommissioning Activities Report (ADAMS No.
ML21084A229). The NRC's program for overseeing the safe monitored storage 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 (IP) 64704, 71801, 83750
The inspectors interviewed personnel, reviewed documentation and performed plant walkdowns to determine if the licensee maintained a fire protection program (FPP) to address the potential for fires that could cause the release or spread of radioactive materials. The inspectors reviewed the fire protection plan and a sample of the implementation procedures to ensure compliance with the plan, to ensure that they reflected the current decommissioning status of the facility, and to ensure they had been properly implemented. The inspectors walked down the fire service pumps to examine their physical condition to determine if they were effectively maintained, and walked down several fire areas to determine if they were as described in the sites pre-fire plans.
The inspectors reviewed surveillances and testing of fire protection equipment to determine if they had been performed on a regular basis.
The inspectors conducted document reviews and interviews with plant personnel to determine if changes made by TMI-2 under 10 CFR 50.59 required prior NRC approval.
The inspectors attended select meetings, including plan of day meetings, end of day meetings, a critical program update meeting, a working level meeting for upcoming N-Visage survey activities, a safety standdown all hands meeting, and a schedule meeting. Inspectors reviewed documentation and met with TMI-2 Solutions staff and management and discussed staffing, status of decommissioning and upcoming activities, among other topics to verify whether the licensee is conducting activities in accordance with regulatory and license requirements. The inspectors performed plant walk-downs to assess material condition of structures, systems, and components, housekeeping, system configurations, and worker level of knowledge or procedure use and adherence. These walk -downs included portions of the auxiliary, fuel handling, and reactor buildings and portions of the outside areas surrounding TMI-2. The inspectors observed select pre-job briefs and associated work activities, including for auxiliary building surveys and on-site storage container receipt activities.
The inspectors observed activities, reviewed documentation, and interviewed personnel associated with occupational radiation exposure to evaluate the licensees protection of worker health and safety. The inspectors reviewed the qualifications of select individuals in the radiation protection (RP) organization to determine if they met requirements referenced in site technical specifications. The inspectors conducted site walk-downs,
including radiologically controlled areas, to examine and assess radiologi cal postings, airborne and contamination controls, and locked high radiation doors and gates. The inspectors reviewed radiation work permits (RWPs), and As Low As Reasonably Achievable (ALARA) work plans to determine if radiation work activities were pre-p lanned effectively to limit worker exposure. The inspectors observed RP technicians perform work activities to determine if implementation of radiological work controls, training and skill level were sufficient for the activities being performed, including surveys in several areas of the auxiliary building and several instrument source checks. One of the inspectors completed site respiratory protection training requirements for use of a powered air purifying respirator to conduct inspection walkdowns in respirator required areas. The inspectors reviewed a sample of condition reports related to occupational radiation safety to determine if issues were entered into the corrective action program at an appropriate threshold and appropriate actions were taken.
b. Observations and Findings
The inspectors determined that TMI -2 Solutions maintained the FPP within NRC requirements and the fire protection plan to minimize the potential for radiological releases in the event of a fire at the plant. The inspectors verified fire protection and detection systems, suppression systems, barriers, and fire water supply systems had been maintained and appropriately tested and were in a state of operational readiness.
The inspectors verified staffing and training of the on-site incipient fire brigade was adequate and agreements were appropriately established with the local fire department associated with primary response for onsite fires.
The inspectors determined that the reviewed 10 CFR 50.59 screenings and evaluations had been properly performed. The inspectors determined that selected changes under 10 CFR 50.59 did not require prior NRC approval and safety reviews were performed for design changes and modifications in accordance with applicable regulatory requirements, license conditions and the PDMS Safety Analysis Report. One item reviewed of note included the TMI-2 Solutions engineering evaluation and 10 CFR 50.59 evaluation of a chemical decontamination demonstration activity (TMI2-C-RB-WKPG-1013). The inspectors determined that it was thorough and appropriately concluded that prior approval by the NRC was not required for this activity.
The inspectors noted that during this inspection period, TMI-2 Solutions continued preparatory activities for active decommissioning, including radiological surveys of the various building elevations and cubicles, construction of low dose waiting areas in the reactor building, and polar crane maintenance activities. The inspectors noted that for the areas of the plant toured, the material condition and housekeeping was adequate.
The inspectors noted an appropriate level of engagement of staff during meeting observations.
The inspectors verified that RWPs and ALARA plans were implemented and were effective in limiting worker exposure, and occupational dose was appropriate for the scope of the radiological activities performed. The inspectors determined that RP staff effectively controlled work activities, used appropriate instruments for the surveys, and performed adequate instrument source checks. The inspectors determined that RP staffing was adequate for the work activities being conducted. The inspectors determined that the radiation protection manager and other selected personnel met qualification requirements. The inspectors observed a station ALARA committee meeting
and determined that staff had an appropriate level of engagement. The inspectors noted an appropriate level of worker and supervisor knowledge of protective clothing and respirator donning and doffing and continuous coverage by an RP technician during a reactor building entry. The inspectors determined that occupational radiation protection issues were generally entered into the corrective action program at an appropriate threshold and appropriate corrective actions were taken.
c. Conclusions
No violations of more than minor safety significance were identified.
3.0 10 CFR Part 37 Materials Security Program
a. Inspection Scope (IP 87137)
Inspectors interviewed personnel, reviewed documentation, performed walkdowns, and observed activities to determine if the licensee had effectively implemented the requirements of 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material.
Inspectors walked down security zones and observed testing of the monitoring systems to determine if the licensee maintained the capability to continuously monitor and detect without delay all unauthorized entries into its security zones. The inspectors interviewed personnel and reviewed records to determine if the licensee had developed, implemented, and maintained written procedures for implementing the access authorization program and training program. The inspectors interviewed personnel and reviewed records to determine if the licensee had coordinated, to the extent practicable, with a local law enforcement agency (LLEA) to respond to threats to the licensees facility, including any necessary armed response.
b. Observations and Findings
The inspectors determined that the licensees security program was sufficient to detect unauthorized access to a security zone when it occurs, to determine whether the unauthorized access was an actual or attempted theft, and to initiate an appropriate response without delay. The inspectors verified that the licensee conducted training to ensure that individuals implementing the security program possess and maintain the knowledge, skills, and abilities to carry out their assigned duties. The inspectors verified the licensee had coordinated with an LLEA to respond to threats to the licensees facility.
c. Conclusions
No violations of more than minor safety significance were identified.
4.0 Exit Meeting Summary
On January 25, 2023, the inspectors presented the inspection results to Sergio Vazquez, Project Director, and other members of TMI-2 Solutions staff. No proprietary information was retained by the inspectors or documented in this report.
PARTIAL LIST OF PERSONS CONTACTED S. Vazquez, Project Director D. Allison, Construction Manager A. Ball, Radiation Protection Supervisor T. Devik, Manager, Nuclear Licensing D. Divittore, Radiation Protection Operations Manager P. Dix, Radiation Protection Technical Support Manager F. Eppler, Engineering Manager G. McCarty, Radiation Protection Manager H. Pell, Licensing Engineer R. Williams, Radiation Protection Technician
Constellation D. Kenny, Senior Manager, Site Security S. Magaro, Manager, Site Security Operations C. Smith, Regulatory Assurance Manager R. Holmes, Senior Manager RP/Chem/Environmental J. Troiano, Engineering
ITEMS OPEN, CLOSED, AND DISCUSSED None
LIST OF DOCUMENTS REVIEWED
Licensing Bases Documents TMI-2 Post-Defueling Monitored Storage Safety Analysis Report, Update 14, August 10, 2021 Three Mile Island Nuclear Station, Unit No. 2 Possession Only License, Amendment 64
Procedures and Programs TMI2-FP-EVA- 0001, Rev. 0, Three Mile Island Unit 2 Fire Protection Program Evaluation TMI2-FP-PN-001, Rev. 0, TMI-2 Fire Protection Plan TMI2-QA-PR-003, TMI-2 Corrective Action Process, Revision 0 TMI2-RP8-PR-002, Instrument Issue and Operational Testing, Revision 0 TMI1-RP-AA-700- 1208, Operation of a Shepherd Model Calibrator, Revision 3 TMI2-RP1-WI-001, Radiological Protection Technician Qualification, June 28, 2022 TMI2-SE-PN-001, Rev. 0, TMI-2 Materials Security Plan
Corrective Action Documents ES-TMI-CR-2022- 0042, 0043, 0045 0046, 0067, 0069, 0071, 0086, 0087, 0106, 0126, 0153, 0184
Miscellaneous 50.59 Screening 2022- 0024, 0031, 0033, 0038, 0039 AP 22-001, ALARA Plan - U-2 RP Reactor Building Surveys, July 7, 2022 AP 22-004, ALARA Plan - U-2 RB Setup Low Dose Waiting Area, August 3, 2022 AP 22-005, ALARA Plan - U-2 RP Reactor Building Directional Surveys, August 2, 2022 AP 22-006, ALARA Plan - U-2 RB N-Visage Scanning, October 13, 2022 Doffing Instructions for Exiting the U2 Reactor Building Radiation Work Permit 22-2-401, U-2 RB Initial/Directional RP Surveys, Revision 3 Radiation Work Permit 22-2-404, U-2 RB Set Up Low Dose Waiting Areas, Revision 0
Miscellaneous (Cont.)
Three Mile Island ESJ Radiation Protection, August 11, 2022 TMI-2 White Paper - 10 CFR 50.59 Applicability of Radiological Surveys Under PDMS TMI2-C-RB-WKPG-1013, Work Package: Chemical Decontamination Proof of Concept, Revision 0 TMI2-C-RB-WKPG-1018, Work Package: Robotic Radiation Surveys and Scans in the Reactor Building Elevation 305 and above (by N-Visage), Revision 0 TMI2-C-RB-WKPG-1038, Work Package: Core Bore Sampling at Reactor Building Elevations 305 and 347, Revision 0 TMI2-ESJ-1B, 2023 Schedule, August 16, 2022 TMI2-M-RB-WKPG-1018, RB N-Visage Scans, Revision 0 TMI2-RP1-WI-001, Attachment 5.4 - RP Technician Qualification Card, Various TMI2-RP3-PR-003, Attachment 5.2 - TEDE ALARA Evaluation Screening Worksheet, Various TMI2-RP-TRN-PAPH-201, TR-600 Series Blower M-Series Headgear TMI2-TRG-QUAL-ANSI-001, Attachment 5.12 - ANSI Qualification Form, Various Radiological Surveys, Various
LIST OF ACRONYMS USED ADAMS Agency Documentation and Management System ALARA As Low As Reasonably Achievable CFR Code of Federal Regulations Constellation Constellation Energy Generation, LLC FPP Fire Protection Program GPO Government Printing Office IMC Inspection Manual Chapter IP Inspection Procedure LLEA Local Law Enforcement NRC U.S. Nuclear Regulatory Commission PDMS Post-Defueling Monitored Storage RP Radiation Protection RWP Radiation Work Permit TMI-2 Three Mile Island, Unit 2 TMI-2 Solutions TMI-2 Solutions, LLC
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