ML092310405

From kanterella
Jump to navigation Jump to search
IR 05000289-09-008 on 07/07/2009 for Three Mile Island, Unit 1, Supplemental Inspection of the, Llc'S Application for Renewed License
ML092310405
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 08/19/2009
From: Conte R
Engineering Region 1 Branch 1
To: Pardee C
Exelon Generation Co, Exelon Nuclear
References
IR-09-008
Download: ML092310405 (11)


See also: IR 05000289/2009008

Text

August 19, 2009

Mr. Charles G. Pardee

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer (CNO), Exelon Nuclear

4300 Winfield Rd.

Warrenville, IL 60555

SUBJECT: THREE MILE ISLAND NUCLEAR STATION UNIT 1 - NRC LICENSE RENEWAL

INSPECTION REPORT 05000289/2009008

Dear Mr. Pardee:

On July 7, 2009, the NRC completed an inspection of your application for license renewal of

your Three Mile Island Nuclear Station, Unit 1. The enclosed report documents the results of

the inspection, which were discussed on July 7, 2009, with members of your staff in an exit

meeting conducted at the Exelon Kennett Square office.

The purpose of this inspection was to follow up your augmentation of the operational experience

review portion of your application for a renewed license.

The inspection results supported a conclusion that the augmented operational experience

review will reasonably manage the effects of aging in the systems, structures, and components

to which it was applied. The inspection concluded the documentation for this portion of your

application was in an auditable and retrievable form.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document 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/

Richard J. Conte, Chief

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-289

License No. DPR-16

Enclosure: Inspection Report 05000289/2009008

Mr. Charles G. Pardee

Senior Vice President, Exelon Generation Company, LLC

President and Chief Nuclear Officer (CNO), Exelon Nuclear

4300 Winfield Rd.

Warrenville, IL 60555

SUBJECT: THREE MILE ISLAND NUCLEAR STATION UNIT 1 - NRC LICENSE RENEWAL

INSPECTION REPORT 05000289/2009008

Dear Mr. Pardee:

On July 7, 2009, the NRC completed an inspection of your application for license renewal of

your Three Mile Island Nuclear Station, Unit 1. The enclosed report documents the results of

the inspection, which were discussed on July 7, 2009, with members of your staff in an exit

meeting conducted at the Exelon Kennett Square office.

The purpose of this inspection was to follow up your augmentation of the operational experience

review portion of your application for a renewed license.

The inspection results supported a conclusion that the augmented operational experience

review will reasonably manage the effects of aging in the systems, structures, and components

to which it was applied. The inspection concluded the documentation for this portion of your

application was in an auditable and retrievable form.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its

enclosure will be available electronically for public inspection in the NRC Public Document

Room or from the Publicly Available Records (PARS) component of NRCs document 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/

Richard J. Conte, Chief

Engineering Branch 1

Division of Reactor Safety

Docket No. 50-289

License No. DPR-16

Enclosure: Inspection Report 05000289/2009008 ML092310405

SUNSI Review Complete: RJC (Reviewer=s Initials)

DOCUMENT NAME: G:\DRS\Engineering Branch 1\-- MModes\TMI 05000289_2009008 IP71002 follow up.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/DRS RI/DRP RI/DRS

NAME MModes/MM RBellamy/RB RConte/RC

DATE 08/18 /09 08/18 /09 08/18 /09

OFFICE

NAME

DATE

C. Pardee 2

OFFICIAL RECORD COPY

C. Pardee 2

cc w/encl:

C. Crane, President and Chief Operating Officer, Exelon Corporation

M. Pacilio, Chief Operating Officer, Exelon Nuclear

W. Noll, Site Vice President, TMI Unit 1, Exelon Nuclear

T. Dougherty, Plant Manager, TMI, Unit 1, Exelon Nuclear

D. Atherholdt, Regulatory Assurance, TMI, Unit 1, Exelon Nuclear

Senior Vice President, Nuclear Services, Exelon Nuclear

Senior Vice President, Mid-Atlantic Operations, Exelon Nuclear

Senior Vice President, Operations Support, Exelon Nuclear

Vice President, Licensing and Regulatory Affairs, Exelon Nuclear

P. Cowan, Director, Licensing, Exelon Nuclear

D. Helker, Licensing, Exelon Generation

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

Correspondence Control Desk, Exelon Nuclear

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)

C. Pardee 3

Distribution w/encl: (VIA E-MAIL)

S. Collins, RA

M. Dapas, DRA

D. Lew, DRP

J. Clifford, DRP

R. Bellamy, DRP

S. Barber, DRP

C. Newport, DRP

D. Kern, DRP, SRI

J. Brand, DRP, RI

C. LaRegina, DRP, OA

L. Trocine, RI OEDO

P. Bamford, PM, NRR

E. Miller, NRR, Backup

R. Nelson, NRR

H. Chernoff, NRR

ROPreports@nrc.gov

Region I Docket Room (with concurrences)

D. Roberts, DRS

P. Wilson, DRS

R. Conte, DRS

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No: 50-289

License No: DPR-16

Report No: 05000289/2009008

Licensee: Exelon Generation Group, LLC

Facility: Three Mile Island Nuclear Station, Unit 1

Location: Middletown, PA

Dates: July 7, 2009

Inspector: M. Modes, Senior Reactor Inspector, Division of Reactor Safety

Approved By: Richard Conte, Chief

Engineering Branch 1

Division of Reactor Safety

Enclosure

SUMMARY OF FINDINGS

IR 05000289/2009008; 07/07/2009; Three Mile Island Nuclear Station, Unit 1; Supplemental

Inspection of the Exelon Generation Group, LLCs Application for Renewed License.

This inspection of license renewal activities was performed by a regional office engineering

inspector. The inspection was conducted in accordance with NRC Manual Chapter 2516 and

NRC Inspection Procedure 71002. The purpose of this inspection was to evaluate an

augmented operational experience review as part of the application for a renewed license. The

inspection results concluded the augmented operational experience review reasonably

manages the effects of aging in the systems, structures, and components to which it was

applied. The inspection concluded the documentation for this portion of your application was in

an auditable and retrievable form.

ii

Enclosure

4.0 OTHER ACTIVITIES (OA)

4OA2 Other - License Renewal

a. Inspection Scope

This inspection was conducted by an NRC Region I based inspector in order to evaluate

the thoroughness and accuracy of an augmented operational experience review as part

of the application for a renewed license.

The inspector selected a number of systems for review, using the NRC accepted

guidance in IP 71002, in order to determine if the methodology applied by the applicant

appropriately captured the affects of aging impacting the safety functions of a system,

component, or structure within the scope of license renewal. The selected systems were

reviewed to determine whether the site specific operational experience was adequately

reflected in the proposed aging management programs (AMPs).

The inspector selected a sample of systems to verify the adequacy of the applicants

documentation and implementation activities. The inspectors reviewed supporting

documentation and interviewed applicant personnel to confirm the accuracy of the

operational experience review conclusions. These results were compared against the

aging observed during prior visual examination of accessible portions of the systems

during the initial license renewal inspection.

a.1. Scoping of Non Safety-Related Systems, Structures, and Components

NEI 95-10, Revision 6, June 2005 Industry Guideline for Implementing the

Requirements of 10 CFR Part 54 - The License Rule suggests a plant specific

operating experience review should assess the operating and maintenance history. A

review of the prior five to ten years of operating and maintenance history should suffice.

The results of the review should confirm consistency with the documented industry

operating experience. Differences with previously documented industry experience such

as new aging affects or lack of aging effects allow consideration of plant specific aging

management requirements.

For mechanical systems, in the original license renewal application analysis, Exelon

Generation Group, LLC, substituted for a portion of the 5 years, the information (in lieu of

a plant specific review) contained in EPRI Non-Class 1 Mechanical Implementation

Guideline and Mechanical Tools, Revision 4, January 2006. At Three Mile Island

Unit 1, the handbook was applied up until January of 2005, after which a plant specific

review was performed. This was discussed by the NRC in Inspection Report 05000289/2008010.

Enclosure

2

After having reviewed the relevant Exelon Generation Group, LLC procedures, the EPRI

handbook, and independently searching the corrective actions system for a year when

Exelon gave the handbook credit for the specific plant review of operational experience,

the inspectors concluded the approach taken by Exelon Generation Group, LLC,

although not a direct plant specific operating experience review as described in

NEI 95-10 was indirectly a comprehensive review of the aging effects that might be

applicable and took into account more then just the local experience recorded in the

Three Mile Island corrective actions program history.

The inspectors concluded, in Inspection Report 05000289/2008010, there was

reasonable assurance that the operational experience review was adequate.

Subsequently the Advisory Committee on Reactor Safeguards, subcommittee for license

renewal, reviewed the Exelon application and NRC Inspection Report 5000289/2008010.

During the meeting, a member of the ACRS questioned the NRC staff and Exelon about

this approach to operational review. As a consequence of the exchange with the

Advisory Committee on Reactor Safeguards, Exelon revised their position and

implemented a full review of the site specific operational records as stated in B.1.4 of

their application for the period of January 2005 to November 2006, the period previously

covered by the handbook. The revised approach brought the review into direct

alignment with the language used in the original application for a renewed license:

Each AMP summary in this appendix contains a discussion of operating

experience relevant to the program. This information was obtained through the

review of in-house operating experience captured by the Corrective Action

Program, Program Self-Assessments, and Program Health Reports, and through

the review of primarily post-2005 industry operating experience (industry

operating experience prior to 2005 having been addressed by Revision 1 to

NUREG-1801). Additionally, operating experience was obtained through

interviews with system and program engineers. The operating experience in each

AMP summary identifies past corrective actions that have resulted in program

enhancements and provides objective evidence that the effects of aging have

been, and will continue to be, adequately managed.

The inspector randomly selected three mechanical systems, susceptible to age related

degradation, and reviewed the results of Exelons operating experience for the period

noted above:

Auxiliary Steam System - the inspector reviewed reference A2031848 and

A2098380 to determine if the operational experience reflected in these to

corrective action reports was appropriately disposed of by the Exelon reviewer.

Circulating Water System - For OE Reference A2129388 the Exelon reviewer

appropriately flagged the report as reflecting relevant age related information

because it reported that CW-P-1A had pressure ports clogged with corrosion

product. The following references were appropriately flagged as not relevant:

Enclosure

C. Pardee 3

A2154376 Heat Trace Setpoint Maintenance

A2029701 Fabricate Replacement Screens

A2031879 CW-P-1C Seal Water Strainer CW-S-3C is Clogged

The inspector asked the responsible Exelon reviewer if the fabrication of

replacement screens, noted in A2029701, could have been precipitated by age

related degradation. The answer indicated the screens were replaced for this

purpose on a regular basis making them a short lived component and not part of

license renewal.

Open Cycle Cooling System - The inspector reviewed A2040923 Water Leak at

SW-V-23A which was caused by the deterioration of the threaded nipple and

appropriately recognized by the Exelon reviewer as an example of Galvanic

Corrosion in Piping and Components. Also reviewed were:

A2043726 Replace SW-V-5C,

A2033499 MIC on NR Piping, and

A2103866 Remove Paint and NDE Pipe.

b. Overall Findings

The inspection verified there is reasonable assurance that the effects of aging will be

adequately managed so that the intended function(s) of systems, structures, and

components, for which an aging management review is required, will be maintained

consistent with the current licensing basis during the period of extended operation. The

inspection verified documentation, procedures, guidance, and personnel, appropriately

supported the license renewal application.

A-1

ATTACHMENT

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel:

Mike Gallagher, Vice President License Renewal Exelon

Al Fulvio, Manager License Renewal Exelon

Chris Wilson, Licensing Lead, Exelon TMI License Renewal Team

Ed Fuhrer, Site Lead Exelon TMI License Renewal Team

Attachment