ML092310405
ML092310405 | |
Person / Time | |
---|---|
Site: | Three Mile Island |
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
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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
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
J. Brand, DRP, RI
C. LaRegina, DRP, OA
L. Trocine, RI OEDO
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
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