ML082140299

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IR 05000320-08-008; 06/03/2008 - 07/03/2008; Amergen Energy Company, LLC; Three Mile Island, Unit 2; Other Activities - Safstor Inspection Report
ML082140299
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 08/01/2008
From: Ray Lorson
NRC Region 1
To: Pardee C
AmerGen Energy Co, Exelon Generation Co, NRC Region 1
References
IR-08-008
Download: ML082140299 (11)


See also: IR 05000320/2008008

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSIA, PA 19406-1415

August 1, 2008

Mr. Charles G. Pardee

Chief Nuclear Officer (CNO) and Senior Vice President

Exelon Generation Company, LLC

Chief Nuclear Officer (CNO)

AmerGen Energy Company, LLC

200 Exelon Way

Kennett Square, PA 19348

SUBJECT: THREE MILE ISLAND STATION UNIT 2 - SAFSTOR INSPECTION REPORT

05000320/2008008

Dear Mr. Pardee:

On July 3, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Three Mile Island Station, Unit 2. The enclosed inspection report documents the

inspection results, which were discussed on June 5, 2008 with Mr. Dougherty and other

members of your staff. In addition, on July 3, 2008, Mr. Miller and Mr. Curry of your staff were

contacted via telephone and a final exit was conducted.

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 inspector reviewed selected procedures and records, observed activities, and

interviewed personnel.

In accordance with 10 CFR Part 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 Web Site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Raymond K. Lorson, Chief

Decommissioning Branch

Division of Nuclear Materials Safety

Docket No. 50-320

License No. DPR-73

C. Pardee 2

Enclosure: Inspection Report No. 05000320/2008008

w/Attachment: Supplemental Information

cc w/encl:

C. Crane, Executive Vice President and Chief Operating Officer, Exelon Generation

W. Noll, Site Vice President - TMI Unit 1, AmerGen

T. Dougherty, Plant Manager - TMI, Unit 1, AmerGen

Manager, Regulatory Assurance - TMI, Unit 1, AmerGen

Senior Vice President - Nuclear Services, AmerGen

Senior Vice President - Mid-Atlantic Operations, AmerGen

Senior Vice President - Operations Support, AmerGen

Vice President - Licensing and Regulatory Affairs, AmerGen

Director, Licensing - AmerGen

Manager, Licensing - TMI, AmerGen

J. Fewell, Esq., Associate General Counsel, Exelon

Correspondence Control Desk - AmerGen

Chairman, Board of County Commissioners of Dauphin County

Chairman, Board of Supervisors of Londonderry Township

R. Janati, Director, Bureau of Radiation Protection, State of PA

D. Allard, Director, PA DEP

J. Johnsrud, National Energy Committee

E. Epstein, TMI-Alert (TMIA)

J. Powers, Director, PA Office of Homeland Security

R. French, Director, PA Emergency Management Agency

August 1, 2008

Mr. Charles G. Pardee

Chief Nuclear Officer (CNO) and Senior Vice President

Exelon Generation Company, LLC

Chief Nuclear Officer (CNO)

AmerGen Energy Company, LLC

200 Exelon Way

Kennett Square, PA 19348

SUBJECT: THREE MILE ISLAND STATION UNIT 2 - SAFSTOR INSPECTION REPORT

05000320/2008008

Dear Mr. Pardee:

On July 03, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at

your Three Mile Island Station, Unit 2. The enclosed inspection report documents the

inspection results, which were discussed on June 5, 2008 with Mr. Dougherty and other

members of your staff. In addition, on July 03, 2008, Mr. Miller and Mr. Curry of your staff were

contacted via telephone and a final exit was conducted.

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 inspector reviewed selected procedures and records, observed activities, and

interviewed personnel.

In accordance with 10 CFR Part 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 Web Site at

http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Raymond K. Lorson, Chief

Decommissioning Branch

Division of Nuclear Materials Safety

Docket No. 50-320

License No. DPR-73

Distribution w/encl: S. Barber, DRP C. LaRegina, DRP, R. Nelson, NRR

S. Collins, RA A. Rosebrook, DRP OA H. Chernoff, NRR

M. Dapas, DRA D. Kern, DRP, Sr S. Williams, RI OEDO ROPreports@nrc.gov

D. Lew, DRP Resident Inspector P. Bamford, PM, NRR

J. Clifford, DRP J. Brand, DRP, G. Miller, NRR,

R. Bellamy, DRP Resident Inspector Backup

ADAMS ML082140299

SUNSI Review Complete: LKauffman

DOCUMENT NAME: G:\D&LB\TMI-2\INSPECTIONREPORTS\TMI-2 IR05000320-2008008.doc

After declaring this document AAn Official Agency Record@ it will/will not be released to the Public.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment/enclosure "E" = Copy with attachment/enclosure

"N" = No copy

OFFICE RI/DNMS RI/DNMS

NAME LKauffman RLorson

DATE 8/1/08 8/1/08

OFFICIAL RECORD COPY

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-320

License No.: DPR-73

Report No.: 05000320/2008008

Licensee: AmerGen Energy Company, LLC (AmerGen)

Facility: Three Mile Island Station, Unit 2

Location: P. O Box 480

Middletown, PA 17057-0191

Dates: June 3 - 5, 2008 (on-site)

June 27 - July 3, 2008 (in-office)

Inspectors: Laurie Kauffman, Health Physicist

Division of Nuclear Materials Safety

Kristina Banovac, Project Manager

Decommissioning and Uranium Recovery Licensing Directorate

Division of Waste Management and Environmental Protection

Office of Federal and State Materials and Environmental Management

Programs

Approved by: Raymond Lorson, Chief

Decommissioning Branch

Division of Nuclear Materials Safety

i Enclosure

SUMMARY OF FINDINGS

IR 05000320/2008-008; 06/03/2008 - 07/03/2008; AmerGen Energy Company, LLC; Three

Mile Island, Unit 2; Other Activities - SAFSTOR Inspection

The inspection was performed by one region-based inspector and one project manager from

headquarters. The NRCs program for overseeing the safe operation of a shut-down nuclear

power reactor is described in Manual Chapter (MC) 2561, Decommissioning Power Reactor

Inspection Program.

A. NRC-Identified and Self-Revealing Findings

None

B. Licensee-Identified Violations

None

ii Enclosure

REPORT DETAILS

Summary of Plant Status

The Three Mile Island Station, Unit 2 (TMI-2) has been permanently shutdown since March

1979 and has been in Post-Defueling Monitored Storage (PDMS) since December 1993. Final

decommissioning is expected to begin following the permanent shutdown of Three Mile Island,

Unit 1.

4. OTHER ACTIVITIES

4OA5 Other Activities

.1 Corrective Action Program (40801)

a. Inspection Scope

The inspector reviewed the licensees program for identifying, resolving, and preventing

issues that could impact safety or the quality of decommissioning activities. The

inspector reviewed the procedures describing the corrective action program (CAP) and

reviewed two assignment reports (ARs). The ARs were reviewed to evaluate the

licensees effectiveness at identifying issues that could impact the safe storage of

radioactive material and implementing appropriate corrective actions. The inspector

discussed with cognizant personnel the tracking, current status, and closure of the

selected ARs.

b. Findings

No findings of significance were identified.

The inspector noted that the priority for addressing ARs and implementing corrective

actions was adequate and based upon safety significance. The threshold for identifying

issues entered into the CAP was adequate. Responsible personnel were

knowledgeable of the status of corrective actions and established measures to monitor

completion of corrective actions. No adverse trends or safety concerns were identified.

Enclosure

2

.2 Maintenance and Surveillance (62801)

a. Inspection Scope

The inspector reviewed the licensees preventive maintenance (PM) and surveillance

test program for structures, systems, and components (SSCs) important for maintaining

the safe storage of radioactive material. The inspector reviewed selected surveillance

tests (STs) including the high efficiency particulate air (HEPA) filter Di-Octyl Phthalate

(DOP) tests for the reactor building breather, reactor building purge, fuel handling

building, auxiliary building, and service building; the ventilation heater; the containment

isolation airlocks; and the quarterly containment isolation valves. The inspector toured

plant areas and discussed aspects of the STs with individuals cognizant of the

performance of the above systems and components.

b. Findings

No findings of significance were identified.

The inspector verified that the maintenance for selected systems and components had

been conducted in accordance with established procedures and met the requirements of

the associated technical specifications (TS). The inspector noted that the individuals

performing the annual STs were knowledgeable of motors, pumps, valves, HEPA filter

DOP tests, and implemented good industrial and radiological safety practices during the

ST.

.3 Occupational Radiation Safety and Effluent Monitoring (83750 and 84750)

a. Inspection Scope

The inspector reviewed implementation of the occupational exposure control program

associated with the TMI-2 PDMS activities and the implementation of primary

containment isolation requirements, TS 3/4.1, Containment Systems. The inspection

consisted of interviews with responsible individuals, and review of the as low as

reasonably achievable (ALARA) plan, and of the post-job review for the reactor building

entry. The inspector reviewed the controls for high radiation areas (HRA), locked high

radiation areas (LHRA) and very high radiation areas (VHRA), and conducted field

observations of radiological postings and signs, and the annual reactor building entry

ST. The reactor building ST included activities such as: conducting radiological surveys

including obtaining grab air samples, smears and area dose rates at locations identified

in the radiological survey procedure. The ST also included performing a visual

inspection to assess the material condition of the containment interior, including

checking for rust, cracks, and water intrusion. The inspector observed the licensee

implement access controls to the VHRA.

The inspector evaluated aspects of the radioactive effluent monitoring program. The

inspector reviewed the radioactive liquid and gaseous effluent release permits and data

from June 2007 through April 2008. The inspector also reviewed the sampling and the

analysis procedures.

Enclosure

3

b. Findings

No findings of significance were identified.

The inspector noted that the radiation workers were knowledgeable of the tasks and

demonstrated a questioning attitude during the job. The radiation protection team

maintained control of the locked high radiation area key in accordance with the

procedure. The associated radiation work permit was commensurate with the

radiological significance of the task and included the appropriate exposure control

measures for the safe implementation of the activity.

The LHRAs and VHRAs were appropriately posted for dose rates and radioactive

material. Radiological postings were readily visible, well-maintained, and reflected

radiological conditions. The ALARA report contained a summary of the estimated

doses, a comparison of the estimated doses to the actual doses, and a detailed

evaluation of the entry.

The licensee conducted the effluent control program according to the Offsite Dose

Calculation Manual and the implementing procedures.

4OA6 Meetings, including Exit

Exit Meeting Summary

On June 5, 2008, the inspector presented the preliminary inspection results to Mr.

Dougherty, and members of the AmerGen staff. The inspector confirmed that

proprietary information was not provided or examined during the inspection. In addition,

on July 3, 2008, the licensee was contacted via telephone and a final summary exit was

conducted.

Enclosure

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Atherholt, Regulatory Assurance Manager, Exelon

E. A. Curry, PDMS Supervisor, AmerGen

G. Darling, Regulatory Assurance Specialist, AmerGen

D. Divittore, Radiation Protection Manager, Exelon

T. Dogherty, Plant Manager Unit 1, Exelon

D. Ethridge, Radiation Protection Manager (Acting), AmerGen

G. Gillespie, TMI-2 Engineer, First Energy

D. Knaby, Radiation Engineer, Exelon

P. Handy, Radiation Engineer, Exelon

R. McDonald, Radiation Protection Supervisor, Exelon

D. Petro, TMI-2 Project Manager, First Energy

D. Smith, PDMS Manager, AmerGen

R. Taylor, Radiation Engineer, Exelon

L. Weber, Environmental Chemist, Exelon

L. Weir, Manager, Nuclear Oversight, Exelon

H. Yeldell, Work Management Director, Exelon

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened and Closed

None

LIST OF DOCUMENTS REVIEWED

Post-Defueling Monitored Storage Safety Analysis Report (PDMS SAR) for TMI-2, Update 7,

dated, August 22, 2007.

GPU Nuclear Post-Defueling Monitored Storage Quality Assurance Plan (PDMS QA Plan) for

Three Mile Island Unit 2, Revision 11, dated May 15, 2008

Possession Only License No. DPR-73 License Amendment No. 62 and Technical Specifications

Action Reports (ARs)

AR Number 00688884

AR Number 00675139

Attachment

A-2

Work Orders

WO R2088079, Unit 2 Reactor Building Entry, May 31, 2007

WO R2121543, Unit 2 Reactor Building Entry, June 3, 2008

WO 2114837 and WO 212708, Unit 2 Vent Monthly Composite

WO R2113692, Unit 2 Vent Weekly Composite

WO R2116589, Auxiliary and Fuel Handling Building Surveys 2008

WO R2104191, Reactor Building Breather Sample Filters

WO R2087558, Reactor Building (Containment) Radiological Surveys

Procedures

2104-1A, Reactor Building Entry, Revision 005

2104-1B, TMI-2 Reactor Building Purge, Revision 012

2104-1C, TMI-2 Reactor Building Breather Shutdown, Revision 007

2104-1F, Reactor Building Air Sampling Operations, Revision 007

2104-40C, TMI-2 Turbine Building Sump Transfer to IWTS, Revision 1

2104-40D, TMI-2 Control Building Area Sump Transfer to IWTS, Revision 0

2104-40E, TMI-2 Control and Service Building Sump Transfer to IWTS, Revision 0

2104-40F, TMI-2 Tendon Access Gallery Sump Transfer to IWTS, Revision 2

2104-40G, TMI-2 Air Intake Tunnel Sump Transfer to IWTS, Revision 1

2107-2, Operation of TMI-2 Reactor Building Lighting, Revision 005

2301-4.2 Auxiliary and Fuel Handling Building PDMS Radiological Surveys, Revision 8

2301-4.3 TMI-2 Reactor Building (Containment) PDMS Radiological Surveys, Revision 005

2301-4.7, TMI-2 Vent Sampling, Revision 18

2301-4.7D, Sampling and Analysis of the Reactor Building Breather System, Revision 007

2301-9.10, TMI-2 Containment Isolation Verification, Revision 13

2303-5.10, Reactor Building Purge Exhaust Filter Ops Check, Revision 006

2303-11.25, Containment Isolation Air Locks, Revision 006

6610-ADM-4250.14, Releasing Radioactive Gaseous Effluents - TMI-2 Reactor Building

Purges, Revision 004

2OPS-S021, PDMS - Ventilation Heater Verification, Revision 1

MA-AA-796-024, Scaffold Installation, Inspection and Removal, Revision 007

RP-AA-460, Controls for High and Very High Radiation Areas, Revision 11

RP-AA-401, ALARA Plan, Revision 9

RP-TM-220-1002, Special Bioassay Program for Transuranic Areas of TMI-2, Revision 1

Documents

Unit 2 Vent Sample Analysis for Weekly Composites December 2007 to May 2008

Unit 2 Vent Sample Analysis for Monthly Composites July 2007 to January 2008

Containment Isolation Verifications July 2007 to June 2008

Auxiliary and Fuel Handling Building Surveys

Reactor Building Breather Sample Filters

Reactor Building (Containment) Radiological Surveys

Turbine Building Sump Transfer to IWTS (Release Permit WO710028)

Control and Service Building Sump Transfer to IWTS (Release Permit WO803005)

Tendon Access Gallery Sump Transfer to IWTS (Release Permit WO804009)

Air Intake Tunnel Sump Transfer to IWTS (Release Permit WO804008)

Reactor Building Breather HEPA DOP test (WO R2071872)

Attachment

A-3

Reactor Building Purge HEPA DOP test (WO R2074772)

Fuel Handling Building HEPA DOP test (WO R2071842)

Auxiliary Building HEPA DOP test (WO R2078493)

Soiled Exhaust HEPA DOP test (WO R2105902)

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

ALARA as low as reasonably achievable

AR action report

CFR Code of Federal Regulations

CAP corrective action program

DOP Di-Octyl Phthalate

HEPA high efficiency particulate air

HRA high radiation area

LHRA locked high radiation area

MC manual chapter

NRC Nuclear Regulatory Commission

PARS Publicly Available Records System

PDMS Post-Defueling Monitored Storage

PM preventive maintenance

RCA radiologically controlled area

SSC structure, systems and components

ST surveillance test

TMI-2 Three Mile Island Station, Unit 2

TS technical specification

VHRA very high radiation area

WO work order

Attachment