ML101390546
| ML101390546 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/18/2010 |
| From: | Laurie Kauffman Decommissioning Branch I |
| To: | GPU Nuclear |
| References | |
| IR-10-008 | |
| Download: ML101390546 (11) | |
See also: IR 05000320/2010008
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
INSPECTION REPORT
Inspection No. 05000320/2010008
Docket No. 05000320
License No. DPR-73
Licensee: GPU Nuclear. Inc.
Facility: Three Mile Island Station. Unit 2
Location: Middletown, PA 17057-0791
Inspection Dates: February 22, 2010
April 20 - 22, 2010
Inspector: Laurie A. Kauffman
Health Physicist
Decommissioning Branch
Division of Nuclear Materials Safety
Approved By: Judith A. Joustra, Chief
Decommissioning Branch
Division of Nuclear Materials Safety
EXECUTIVE SUMMARY
GPU Nuclear, Inc.
NRC Inspection Report No. 05000320/2010008
The Three Mile Island Nuclear Station, Unit 2 (TMI-2) has been permanently shutdown since
March 1979 and has been in post-defueled monitored storage (PDMS) since December 1993. No
ongoing decommissioning or dismantlement activities are being conducted at TMI-2. The licensee
plans to actively decommission TMI-2 in parallel with the decommissioning of Three Mile Island
Nuclear Station, Unit 1 (TMI-1) after that unit has been permanently shutdown. FirstEnergy/GPU
Nuclear, Inc. (GPUN) sold its electric generator to Siemens Energy, Inc. in 2009. In January 2010,
FirstEnergy/GPUN mobilized Siemens personnel to remove the generator.
A routine announced safety inspection was conducted on February 22, 2010 and April 20 - 22,
2010, at TMI-2 by a Region I inspector. The inspection included a review of operations and
management oversight, maintenance, corrective action program implementation, and plant support
activities while in SAFSTOR status. Specifically, the scope of the inspection included: (1) an
evaluation of the condition and operational status of structures, systems and components
important to the safe storage of radioactive material; (2) a review of the quality assurance and audit
program; (3) a review of the implementation and adequacy of the radiation protection program,
including a review of the electric generator removal from the turbine building; (4) an evaluation of
the licensee's controls and processes regarding the TMI-2 liquid and gaseous radioactive effuents;
(5) an evaluation of the radioactive waste management and transportation programs; and (6) follow
up of corrective actions related to a Non-Cited Violation (NCV), failure to perform audits of the
radioactive waste management program according to Technical Specification (TS) 6.5.3.1, that
was identified during the previous NRC inspection. [See NRC Inspection Report Number
05000320/2009007, dated July 24, 2009, for details. ADAMS Accession Numbers ML092050557
(cover letter) and ML092050569 (inspection report)]
Within the scope of this inspection, no safety concerns or violations were identified.
Organization and Management Control
The licensee's organization was adequate to support PDMS activities. Management oversight of
the PDMS program was adequate for the activities conducted.
Safety Reviews, Design Changes, and Modifications
The licensee submitted the Biennial 10 CFR 50.59 Report, dated February 15, 2010, in
accordance with TMI-2 TS 6.8.1.4 and 10 CFR 50.59 requirements.
Self-Assessment, Auditing, and Corrective Action Programs
The licensee maintained an adequate audit program and effectively utilized the established
corrective action program to self-identify, evaluate, and correct issues and problems. Condition
reports were properly prioritized and corrective actions were tracked in accordance with approved
procedures.
Decommissioning Performance and Status Reviews at Permanently Shutdown Reactors
(PSRs)
No dismantlement or decommissioning activities were performed since the previous inspection.
ii
Maintenance and Surveillance
The licensee effectively implemented the preventive maintenance and surveillance program and
associated procedures.
Occupational Radiation Exposure
Implementation and oversight of the PDMS program was effective for the storage of radioactive
material. The licensee provided adequate controls to limit exposures of workers to external
sources of radiation. Posting and labeling of radioactive materials and radiation areas complied
with regulatory requirements. Radiological controls and dose estimates were effective to achieve
dose goals. Implementation of the occupational exposure control program associated with the
TMI-2 PDMS activities and the electric generator removal project was adequate.
Effluent, Environmental Monitoring and Radioactive Waste and Transportation
The licensee effectively implemented and maintained the radioactive effluent controls program, the
radiological environmental monitoring program, and the radiation protection program.
iii
REPORT DETAILS
1.0 Background
GPUN retains the license for TMI-2 and maintains the facility. Metropolitan Edison C
Company (MetEd), Jersey Central Power & Light Company (JCP&L), and Pennsylvania
Electric Company (Penelec) jOintly own TMI-2. GPUN, Met Ed, JCP&L, and Penelec are
wholly owned subsidiaries of FirstEnergy Corp.
As part of the sale of TMI-2, GPUN entered into an agreement with AmerGen (now
Exelon) for TMI-2 services. Under this agreement and as a contractor subject to GPUN's
ultimate direction and control, Exelon provides all services, materials and equipment
required to maintain TMI-2 in PDMS. Services provided by Exelon include maintenance
and surveillance activities and implementation of the activities required in the Safety
Analysis Report, Technical Specifications, and the GPUN PDMS Quality Assurance
2.0 Organization and Management Controls
a. Inspection Scope (Inspection Procedures OP) 36801)
The inspector evaluated any recent organization, management and staffing changes with
respect to the PDMS QA program outlined in the PDMS QA Plan.
b. Observations and Findings
There were no organizational structure changes since the previous inspection. However,
in June 2009, the Senior PDMS Manager, responsible for TMI-2 PDMS activities, had
retired and a replacement had been named. During discussions with the current PDMS
Manager regarding the PDMS program and evaluations of the implementation of the
program, the inspector determined that the current PDMS Manager demonstrated an
adequate understanding of the PDMS program and the TMI-2 plant. In January 2010,
FirstEnergy announced that the PDMS Senior Specialist and Senior Licensing Engineer,
who were responsible for implementing TMI-2 PDMS activities, were scheduled to retire
in March 2010. FirstEnergy also announced that one of the two FirstEnergy responsible
engineers, who maintained oversight of the PDMS program, was transferring to another
position within the FirstEnergy organization in March 2010. During the inspection, the
inspector noted that a new FirstEnergy responsible engineer had been named in early
April 2010 and that the remaining FirstEnergy responsible engineer will also transfer to
another position within the FirstEnergy organization by the end of June 2010. In order to
assure knowledge transfer, the licensee employed the recently retired PDMS Senior
Specialist as a consultant to assist with the implementation of the PDMS program. The
effectiveness of these management and staff changes will be reviewed during the next
inspection.
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c. Conclusions
The licensee's organization was adequate to support PDMS activities. Management
oversight of the PDMS program was adequate for the activities conducted. No findings
of safety significance were identified.
3.0 Safety Reviews, Design Changes, and Modifications
a. Inspection Scope tiP 37801)
The inspector reviewed the Biennial 10 CFR 50.59 Report, dated February 15, 2010 to
verify the implementation of TMI-2 Technical Specifications (TS) 6.8.1.4 and
10 CFR 50.59 requirements.
b. Observations and Findings
There were no structures, systems, or components in TMI-2 that perform a safety
function as a result of the non-operating and defueled status of the TMI-2 plant.
c. Conclusions
The licensee submitted the Biennial 10 CFR 50.59 Report, dated February 15, 2010 in
accordance with TMI-2 TS 6.8.1.4 and 10 CFR 50.59 requirements. No findings of
safety significance were identified.
4.0 Self-Assessment, Auditing, and Corrective Action Programs
a. Inspection Scope tiP 40801)
The inspector reviewed the licensee's 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 and
reviewed several issue reports (IRs), action reports (ARs), and the associated corrective
actions. The inspector discussed with cognizant personnel the tracking, current status,
and closure of the selected IRs and ARs. The inspector reviewed the PDMS QA Plan,
and the June 2009 Nuclear Oversight (NOS) audit report (Re-Audit NOSA-TMI-09-13
(AR929279929279). The inspector evaluated the corrective actions related to NCV 05000320/2009007-01, failure to perform audits of the radioactive waste management
program according to TS 6.5.3.1, that was identified during the previous NRC inspection.
b. Observations and Findings
The inspector reviewed several IRs, ARs, and the associated corrective actions and
determined that the priority for addressing issue reports and implementation of corrective
actions was adequate and based upon safety significance. Corrective actions were
established to address identified issues, and were being tracked to closure using the
licensee's corrective action program (CAP). No adverse trends or safety concerns were
identified.
2
The inspector evaluated the corrective actions relative to NCV 05000320/2009007-01,
failure to perform audits of the radioactive waste management program according to
TS 6.5.3.1. The inspector noted that NOS had revised the audit plan to include the
radioactive waste management and transportation programs and had performed an
audit, (Re-Audit NOSA-TMI-09-13 (AR929279929279), according to the TMI-2 PDMS QA Plan
and TS 6.5.3.1. The Re-Audit NOSA-TMI-09-13 report was thorough, well balanced, and
sufficiently detailed to identify strengths and weaknesses related to selected aspects of
the TMI-2 PDMS QA Plan. The NOS identified areas for improvement within the
radioactive waste management and transportation programs and within selected areas of
the TMI-2 PDMS program. Where deficiencies and program improvements were
identified, the NOS issued IRs as required by the CAP. The inspector reviewed these
IRs and noted that the issues identified were of low safety significance. The inspector
reviewed the associated corrective actions and determined that the priority for
addressing issue reports and implementation of corrective actions was adequate based
upon safety significance. No adverse trends or safety concerns were identified.
c. Conclusions
The licensee maintained an adequate audit program and effectively utilized the
established corrective action program to self-identify, evaluate, and correct issues and
problems. Condition reports were properly prioritized and corrective actions were tracked
in accordance with approved procedures. No findings of safety significance were
identified.
5.0 Decommissioning Performance and Status Reviews
a. Inspection Scope liP 71801)
The inspector reviewed the licensee's current decommissioning status with respect to the
TMI-2 PDMS QA Plan.
b. Observations and Findings
The licensee plans to actively decommission TMI-2 in parallel with the decommissioning
of TMJ-1 after that unit has been permanently shutdown.
c. Conclusions
No dismantlement or decommissioning activities were performed since the previous
inspection. No findings of safety significance were identified.
6.0 Maintenance and Surveillance
a. Inspection Scope liP 62801)
The inspector reviewed the licensee's preventive maintenance (PM) and surveillance test
(ST) program for structures, systems, and components important for maintaining the safe
storage of radioactive material and the implementation of primary containment isolation
requirements, TS 3/4.1, Containment Systems. Specifically, the inspector evaluated the
3
licensee's implementation of the maintenance program associated with the annual
reactor building entry ST. The inspector reviewed selected STs, including the high
efficiency particulate absolute (HEPA) filter dioctyl phthalate (DOP) tests for the reactor
building breather, reactor building purge, fuel handling building, auxiliary building, and
service building. Additionally, the inspector reviewed selected STs for the ventilation
heater, the containment isolation airlocks, and the quarterly containment isolation valves.
The inspector also toured plant areas and discussed aspects of the STs with individuals
cognizant of the performance of the above systems and components.
b. Observations and Findings
The reactor building entry ST included activities such as: visual inspections for water
intrusion, structural integrity and material condition of structures and components in
containment. The results of the ST indicated that no significant water intrusion was
evident in containment and that the material condition of components remained
unchanged since the previous ST.
The inspector verified that the maintenance and surveillance program for selected
systems and components had been conducted in accordance with the TS requirements
and established procedures. From a review of the STs, the inspector noted that the
results of the preventative maintenance and routine surveillances were complete and
were within the acceptable tolerance limits.
c. Conclusions
The licensee effectively implemented the preventive maintenance and surveillance
program and associated procedures. No findings of safety significance were identified.
7.0 Occupational Radiation Exposure
a. Inspection Scope (IP 83750)
The inspector reviewed the licensee's occupational exposure control program associated
with the removal of the electric generator from the turbine building. The inspector
reviewed procedure RP-AA-300, Radiological Survey Procedure, and the survey records
of the cooler dome, the rotor and the stator, which are the largest components of the
generator. The inspector also reviewed the radiological survey results for selected
components of the electric generator, such as the generator hood, generator shaft, blade
rings, end bells, bearing covers, air baffles, and gland brackets.
The inspector evaluated the 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. Specifically, the
inspector conducted direct observations of the licensee's implementation of the annual
reactor building entry ST and an evaluation of the associated As Low As Reasonable
Achievable (ALARA) report. The inspection consisted of interviews with responsible
individuals and field observations of radiological postings and signs in the radiologically
controlled area (RCA).
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b. Observations and Findings
On February 22, 2010, the inspector observed the licensee's activities related to the
removal of the electric generator from the TMI-2 turbine building. The generator was
removed in sections from the TMI-2 turbine building deck to a transporter. Some of the
larger components of the generator included the cooler dome, the rotor and the stator.
The inspector noted that the licensee had wrapped the rotor with a weather protective
cover and placed the rotor onto a transporter for transfer to its final destination. The
inspector reviewed the radiological survey records and noted that the direct frisk results
were less than the maximum detectable activity (MDA), 60 counts per minute (cpm), and
the large area wipe results were less than MDAIwipe, 60 cpm/wipe. No detectable
radioactivity above background (100 cpm) was identified. No adverse trends or safety
concerns were identified.
The inspector observed the licensee conduct direct frisk surveys and collect large area
wipes of selected accessible areas of the stator. The direct frisk results were less than
MDA (60 cpm) and the large area wipe results were less than MDAIwipe (60 cpm/wipe).
The inspector conducted side-by-side direct frisk surveys of selected accessible areas of
the stator using a Ludlum Model 14-C (Serial Number 235126) with a Ludlum Model 44-9
pancake probe, calibrated June 9, 2009. No detectable radioactivity above background
(100 cpm) was identified. No adverse trends or safety concerns were identified.
The inspector also reviewed the radiological survey results for selected components of
the electric generator, such as the cooler dome, generator hood, generator shaft, blade
rings, end bells, bearing covers, air baffles, and gland brackets. All results were less
than background (100 cpm) and MDA (60 cpm).
From April 20 through 22, 2010, the inspector verified that the licensee posted the RCA
for dose rates and radioactive material. The radiological postings were readily visible,
well-maintained, and reflected radiological conditions. The inspector observed the
licensee's implementation of the reactor building entry ST. The reactor building entry ST
included activities such as: radiation level and airborne activity surveys; radiological
surveys and wipes; and analysis of the surveys and wipes. The results of the surveys
indicated that radiological conditions in containment were stable. The ALARA report
contained a summary of the estimated doses and a detailed evaluation of the reactor
building entry. The actual dose total was significantly less than the dose goal (396
mrem) for the entry. The associated radiation work permit was commensurate with the
radiological significance of the task and included exposure control measures for the safe
implementation of the ST.
c. Conclusions
Implementation and oversight of the PDMS program was effective for the storage of
radioactive material. The licensee provided adequate controls to limit exposures of
workers to external sources of radiation. Posting and labeling of radioactive materials
and radiation areas complied with regulatory requirements. Radiological controls and
dose estimates were effective to achieve dose goals. Implementation of the
occupational exposure control program associated with the TMI-2 PDMS activities and
5
the electric generator removal project was adequate. No findings of safety significance
were identified.
8.0 Effluent, Environmental Monitoring and Radioactive Waste and Transportation
a. Inspection Scope (IPs 84750 and 86750)
The inspector reviewed the radioactive effluent control program and the site radiological
environmental monitoring program. The evaluation included a review of the annual
radioactive effluent release report for 2009, the annual radiological environmental
operating report for 2009, and the associated analytical results for each program. The
inspector also reviewed the data for the TMI-2 vent sampling procedures, the TMI-2
sump release permit procedures, and the supporting radioactive liquid and radioactive
gaseous effluent release permits and data, from June 2009 through April 2010. The
inspector reviewed the radioactive waste management and transportation programs fo
determine whether the licensee properly processed, packaged, stored, and shipped
radioactive materials.
b. Observations and Findings
The inspector verified that the licensee collected and analyzed the TMI-2 vent and sump
samples within the required frequencies and that the sample collection was conducted in
accordance with associated procedures. The annual effluent and environmental
monitoring reports demonstrated that all calculated doses were well below regulatory
dose criteria of 10 CFR 50, Appendix I. No radioactive waste shipments were conducted
from June 2009 through April 2010.
c. Conclusions
The licensee effectively implemented and maintained the radioactive effluent controls
program, the radiological environmental monitoring program, and the radiation protection
program. No findings of safety significance were identified.
Exit Meeting Summary
On April 22, 2010, the inspector presented the preliminary inspection results to Mr. Casey,
Responsible Engineer, FirstEnergy and other members of your organization, and members of
the Exelon management and staff. The inspector confirmed that proprietary information was not
provided or examined during the inspection.
6
PARTIAL LIST OF PERSONS CONTACTED
C. Baker, Manager Chemistry/Environmental/RadWaste, Exelon
R. Campbell, Work Management, Exelon
M. Casey, Responsible Engineer, FirstEnergy
M. Croushore, Radiation Protection/Shipping Specialist, Exelon
E.A. Curry, PDMS Consultant, Shaw
D. Divittore, Radiation Protection Manager, Exelon
T. Dupes, Senior Health Physicist, Exelon
M. Ford, PDMS Manager, Exelon
J. Fox, Manager, FirstEnergy
G. Gillespie, Responsible Engineer, FirstEnergy
P. Handy, Radiation Protection/ALARA Specialist, Exelon
D. Neff, Regulatory Assurance, Manager, Exelon
W. Noll, Senior Vice President, Exelon
L. Weber, Environmental Chemist, Exelon
L. Weir, Manager, Nuclear Oversight, Exelon
E. Schmeichel, NOS Auditor, Exelon
M. Sweigert, Radwaste Engineer, Exelon
D. Deiter, Senior Health Physicist, Exelon
INSPECTION PROCEDURES USED
36801 Organization, Management, and Cost Controls at Permanently Shutdown
Reactors (PSRs)
37801 Safety Reviews, Design Changes, and Modifications at PSRs
40801 Self Assessment and Corrective Action at PSRs
62801 Maintenance and Surveillance at PSRs
71801 Decommissioning Performance and Status Reviews at PSRs
83750 Occupational Radiation Exposure
84750 Radioactive Waste Treatment and Effluent and Environmental Monitoring
86750 Solid Radioactive Waste Management and Transportation
ITEMS OPEN, CLOSED, AND DISCUSSED
Opened, Closed and Discussed - None
LIST OF ACRONYMS USED
ADAMS Agencywide Documents Access and Management System
ALARA as low as reasonably achievable
AR action report
CAP corrective action program
cpm counts per minute
DAW dry active waste
DOP dioctyl phthalate
GPUN GPU Nuclear, Inc.
HEPA high efficiency particulate absolute
7
IP Inspection Procedure
IR issue report
JCP&L Jersey Central Power & Light Company
LHRA locked high radiation area
MDA maximum detectable activity
MetEd Metropolitan Edison Company
NCV Non-Cited Violation
NOS Nuclear Oversight
NOSA Nuclear Oversight Audit
NRC Nuclear Regulatory Commission
PDMS Post-Defueling Monitored Storage
PDMS QA Plan PDMS Quality Assurance (QA) Plan
Penelec Pennsylvania Electric Company
PM preventive maintenance
PSR Permanently Shutdown Reactor
QA quality assurance
RCA radiologically controlled area
ST surveillance test
TMI-1 Three Mile Island Station, Unit 1
TMI-2 Three Mile Island Station, Unit 2
TS technical speCification
VHRA very high radiation area
8