ML13042A277
| ML13042A277 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 02/11/2013 |
| From: | Hunegs G NRC/RGN-I/DRP/PB6 |
| To: | Pacilio M Exelon Nuclear, Exelon Generation Co |
| HUNEGS, GK | |
| References | |
| IR-12-005 | |
| Download: ML13042A277 (48) | |
See also: IR 05000289/2012005
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BOULEVARD, SUITE 100
KING OF PRUSSIA, PENNSYLVANIA 19406-2713
February 11, 2013
Mr. Michael J. Pacilio
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer (CNO), Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: THREE MILE ISLAND STATION - NRC INTEGRATED INSPECTION REPORT
050000289/2012005
Dear Mr. Pacilio:
On December 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report
documents the inspection results, which were discussed on January 25, 2013, with Mr. Mark
Newcomer, TMI Plant Manager, and other members of your staff.
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 inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents one NRC-identified apparent violation (AV) concerning missing flood
seals in conduits located in the air intake tunnel that lead to the auxiliary building. This violation
has potential safety significance greater than very low safety significance (Green). However,
the violation does not represent an immediate safety concern because flood seals were
permanently installed upstream of the missing seals in November 2012. This violation, with
the supporting circumstances and details, is documented in the inspection report.
This report also documents two NRC-identified findings of very low safety significance (Green).
These findings were determined to involve violations of NRC requirements. However, because
of the very low safety significance, and because they are entered into your corrective action
program, the NRC is treating these findings as NCVs, consistent with Section 2.3.2 of the NRC
Enforcement Policy. If you contest any NCVs in this report, you should provide a response
within 30 days of the date of this inspection report, with the basis for your denial, to the U. S.
Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-
0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement,
United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC
Resident Inspector at Three Mile Island. In addition, if you disagree with the cross-cutting
aspect assigned to any finding in this report, you should provide a response within 30 days of
M. Pacilio 2
the date of this inspection report, with the basis for your disagreement, to the Regional
Administrator, Region I, and the NRC Resident Inspector at Three Mile Island.
In accordance with 10 CFR 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
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).
We appreciate your cooperation. Please contact me at 610-337-5046 if you have any questions
regarding this letter.
Sincerely,
/RA/
Gordon K. Hunegs, Chief
Projects Branch 6
Division of Reactor Projects
Docket No: 50-289
License No: DPR-50
Enclosure: Inspection Report 05000289/2012005
w/Attachment: Supplemental Information
cc w/encl: Distribution via ListServ
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE mmt RI/DRP RI/DRP RI/DRP
NAME DWerkheiser/GKH for SBarber/ GKH for GHunegs/GKH
DATE 02/08 /13 02/08 /13 0208 /13
1
U.S. NUCLEAR REGULATORY COMMISSION
REGION 1
Docket No: 50-289
License No: DPR-50
Report No: 05000289/2012005
Licensee: Exelon Generation Company
Facility: Three Mile Island Station, Unit 1
Location: Middletown, PA 17057
Dates: October 1 through December 31, 2012
Inspectors: D. Werkheiser, Senior Resident Inspector
J. Heinly, Resident Inspector
C. Cahill, Senior Reactor Analyst
S. Galbreath, Reactor Engineer
D. Kern, Senior Reactor Inspector
J. Laughlin, Emergency Preparedness Inspector, NSIR
T. Moslak, Senior Health Physicist
J. Richmond, Senior Reactor Inspector
Approved by: G. Hunegs, Chief
Reactor Projects Branch 6
Division of Reactor Projects
Enclosure
2
TABLE OF CONTENTS
SUMMARY OF FINDINGS ........................................................................................................... 3
REPORT DETAILS ....................................................................................................................... 5
1. REACTOR SAFETY [R] ........................................................................................................... 5
1R01 Adverse Weather Protection ..................................................................................... 5
1R04 Equipment Alignment ............................................................................................... 6
1R05 Fire Protection ........................................................................................................... 7
1R07 Heat Sink Performance ............................................................................................ 8
1R11 Licensed Operator Requalification Program and Licensed Operator Performance . 8
1R12 Maintenance Effectiveness ...................................................................................... 9
1R13 Maintenance Risk Assessments and Emergent Work Control ............................... 10
1R15 Operability Evaluations ............................................................................................ 10
1R19 Post Maintenance Testing ...................................................................................... 11
1R22 Surveillance Testing ............................................................................................... 11
1EP4 Emergency Action Level and Emergency Plan Changes ...................................... 12
1EP6 Drill Evaluation ....................................................................................................... 12
2. RADIATION SAFETY [RS] ..................................................................................................... 13
2RS01 Radiological Hazard Assessment and Exposure Controls ...................................... 13
2RS06 Radioactive Gaseous and Liquid Effluent Treatment ............................................. 14
4. OTHER ACTIVITIES [OA] ...................................................................................................... 17
4OA1 Performance Indicator Verification ......................................................................... 17
4OA2 Identification and Resolution of Problems .............................................................. 18
4OA3 Follow-up of Events and Notices of Enforcement Discretion ................................. 25
4OA5 Other Activities ........................................................................................................ 26
4OA6 Meetings, Including Exit .......................................................................................... 35
SUPPLEMENTARY INFORMATION ........................................................................................ A-1
KEY POINTS OF CONTACT .................................................................................................... A-1
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED ..................................... A-2
LIST OF DOCUMENTS REVIEWED ........................................................................................ A-2
LIST OF ACRONYMS ............................................................................................................. A-10
Enclosure
3
SUMMARY OF FINDINGS
IR 05000289/2012005; 10/01/2012-12/31/2012; Three Mile Island, Unit 1, Integrated Inspection
Report; Problem Identification and Resolution, Inspection of Near-Term Task Force
Recommendation 2.3 Flooding Walkdowns.
The report covered a three-month period of baseline inspection conducted by resident
inspectors and announced inspections performed by regional inspectors. Inspectors identified
one apparent violation and two findings of very low safety significance (Green), both of which
were NCVs. The significance of most findings is indicated by their color (Green, White, Yellow,
Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process
(SDP). The cross-cutting aspects for the findings were determined using IMC 0310,
Components Within Cross-Cutting Areas. Findings for which the SDP does not apply may be
Green, or be assigned a severity level after NRC management review. The NRCs program for
overseeing the safe operation of commercial nuclear power reactors is described in NUREG-
1649, Reactor Oversight Process, Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
Green. The inspectors identified a non-cited violation (NCV) of General Design Criterion 2,
"Performance Standards," because Exelon had not established measures to ensure that the
seismic gap flood seal was adequate to remain watertight during a probable maximum flood
(PMF) event, as required by the TMI design. Specifically, the design requirement for the
seismic gap seal specified that it was to be watertight. However, the installed seal
configuration had measurable leakage when tested. The inspectors determined that the
failure to construct, maintain, and inspect the seismic gap flood seal consistent with its
design (e.g., watertight) was a performance deficiency within Exelon's ability to foresee and
prevent. Exelon entered this issue into their corrective action program, took appropriate
interim corrective actions, and completed permanent modifications to restore the watertight
function of the seismic gap barrier.
This finding was more than minor because it was similar to the more than minor example 3.j
in Inspection Manual Chapter (IMC) 0612 Appendix E, "Examples of Minor Issues," in that
the seal's as-built and maintained configuration resulted in a condition where there was
reasonable doubt regarding the functionality of the seismic gap seal to remain watertight
during a PMF event. Also, this finding was associated with the protection against external
factors attribute of the Mitigating Systems Cornerstone and adversely affected the
cornerstone objective of ensuring the availability, reliability, and capability of systems that
respond to initiating events to prevent undesirable consequences. In accordance with
IMC 0609, Appendix G, "Shutdown Operations Significance Determination Process," the
inspectors performed a bounding risk evaluation using an unavailability period of greater
than one year for the watertight seal, and determined this finding was of very low safety
significance (Green). This finding has a cross-cutting aspect, as described in IMC 0310, in
the area of Human Performance, Decision Making, because Exelon failed to verify the
validity of underlying assumptions or continued functionality of the seismic gap flood seal
following an external flood re-analysis which revised the design basis PMF conditions.
H.1(b) (Section 4OA2.6)
Green. The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B,
Criterion XVI, Corrective Actions, in that Exelon failed to identify and correct conditions
adverse to quality regarding the licensing basis external flood barrier integrity. Specifically,
Enclosure
4
Exelon failed to identify and correct 13 unsealed penetrations through the Intake Screen and
Pump House (ISPH) flood barrier and multiple deficiencies that challenged the fulfillment of
ISPH support equipment capability to maintain the integrity of the licensing basis flood
barrier. The deficiencies were entered into the corrective action program and permanent
corrective actions were taken to seal the penetrations to restore the external flood barrier
integrity and restoration of the support equipment capability for flood protection.
The finding was more than minor because it is associated with the protection against
external factors attribute of the mitigating systems cornerstone to ensure the availability,
reliability, and capability of systems that respond to initiating events to prevent undesirable
consequences. Specifically, Exelon did not identify and correct 13 unsealed penetrations in
a licensing basis external flood barrier and its associated support equipment deficiencies
such that the barrier is fully capable of maintaining the ISPH free of flood water. The
inspectors evaluated the finding in accordance with IMC 0609, Appendix A, Exhibit 2 -
Mitigating Systems Screening Questions and Exhibit 4 - External Events Screening
Questions and determined that a detailed risk evaluation was required based upon the
assumed complete failure of the flood barrier would degrade two trains of Decay Heat
Removal. A detailed risk evaluation modeled in SAPHIRE 8 using the TMI SPAR model
version 8.18 determined the finding to be of very low safety significance (Green). This
finding has a cross-cutting aspect in the area of Problem Identification and Resolution,
Corrective Action Program, because Exelon failed to identify the unsealed penetrations
through the flood barrier and multiple deficiencies in supporting equipment in a timely
manner commensurate with its safety significance. P.1(a) (Section 4OA5.2.b.1)
TBD. The inspectors identified an apparent violation (AV) of 10 CFR 50, Appendix B,
Criterion XVI, Corrective Actions, was identified during the TI-187 flooding walkdowns for
Exelons failure to identify and correct an external flood barrier deficiency. Specifically,
Exelon failed to identify and correct, during external flood barrier walkdowns, that electrical
cable conduits were not flood sealed in the Air Intake Tunnel (AIT), as designed, to maintain
the integrity of the external flood barrier. The deficiency was entered into Exelons
corrective action process and permanent corrective actions were taken to seal the electrical
conduits and restore the external flood barrier integrity.
The finding was determined to be more than minor because it is associated with the
protection against external factors attribute of the mitigating systems cornerstone to ensure
the availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Specifically, Exelon failed, during multiple focused
walkdowns, to identify the degraded external flood barrier in the Crouse-Hinds couplings in
the AIT that challenged the external flood barrier operability. The significance of the
degraded external flood barrier is to be determined and cannot accurately be calculated
until additional testing and analysis of the as-found configuration is complete. Specifically,
Exelon is performing additional testing on the capability of as-found foam fire sealant
material, present in the conduits at the AIT/Aux Building interface, to mitigate flood water
entry into the safety-related structures. These results will be an input into the licensees
flood mitigation aggregate impact review. This finding has a cross-cutting aspect in the area
of Problem Identification and Resolution, Corrective Action Program, because Exelon failed
to review the external flood barrier with a low threshold for identifying issues which resulted
in the failure to identify the unsealed electrical conduits in the AIT in a timely manner
commensurate with its safety significance. P.1(a) [Section 4OA5.2.b.2]
Enclosure
5
REPORT DETAILS
Summary of Plant Status
Three Mile Island, Unit 1 (TMI) began the inspection period at approximately 100 percent rated
thermal power. On December 8, 2012, TMI reduced power to 90 percent for turbine valve
testing and returned to 100 percent on December 9, 2012 and continued to operate at full rated
thermal power for the rest of the inspection period.
1. REACTOR SAFETY [R]
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 2 samples)
.1 Readiness for Seasonal Extreme Weather Conditions - Cold Weather Preparation
a. Inspection Scope
The inspectors walked down risk significant plant areas during the week of October 8
to assess Exelons preparation and protection for cold weather conditions. Focused
inspections were conducted on the borated water storage tank and heat trace system
health to ensure availability of associated systems during cold weather conditions. In
addition, the inspectors reviewed the work maintenance backlog for the heat trace
system and the scheduled corrective maintenance dates. The inspectors reviewed and
observed the implementation of procedure WC-AA-107, Seasonal Readiness, Rev. 10.
Specifically, the inspectors observed winter weather readiness meetings to ensure
adequate attention was provided to potential cold weather impacts on safety equipment
commensurate with its safety significance.
b. Findings
No findings were identified.
.2 Readiness for Seasonal Extreme Weather Conditions - Hurricane Sandy
a. Inspection Scope
On October 29 and 30, 2012, the inspectors performed an inspection of the site
preparations for Hurricane Sandy and the resultant wind and rain impact. The
inspectors reviewed abnormal operating procedures, interviewed operators, and
performed extensive plant walk downs to confirm the adequacy of the licensees risk
mitigation actions in preparation for the storm. In addition, the inspectors independently
reviewed the planned and emergent work activities scheduled during the storm to ensure
the availability and reliability of safety equipment. The resident inspectors maintained
site coverage during the storm and continually monitored plant and weather conditions to
ensure abnormal conditions and deficiencies were promptly identified and appropriately
addressed commensurate with their safety significance.
Enclosure
6
b. Findings
No findings were identified.
1R04 Equipment Alignment (71111.04)
.1 Partial System Walkdowns (71111.04Q - 4 samples)
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
NR-P-1B planned outage on October 24, 2012
A decay closed cooling water system after planned outage on December 14, 2012
MS-V-2 lineup during testing on December 26, 2012
Reactor building emergency coolers during surveillance testing on December 28,
2012
The inspectors selected these systems based on their risk-significance relative to the
reactor safety cornerstones at the time they were inspected. The inspectors reviewed
applicable operating procedures, system diagrams, the UFSAR, technical specifications,
work orders, condition reports, and the impact of ongoing work activities on redundant
trains of equipment in order to identify conditions that could have impacted system
performance of their intended safety functions. The inspectors also performed field
walkdowns of accessible portions of the systems to verify system components and
support equipment were aligned correctly and were operable. The inspectors examined
the material condition of the components and observed operating parameters of
equipment to verify that there were no deficiencies. The inspectors also reviewed
whether Exelon staff had properly identified equipment issues and entered them into the
corrective action program for resolution with the appropriate significance
characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown (71111.04S - 1 sample)
a. Inspection Scope
On November 15, 2012, the inspectors performed a complete system walkdown of
accessible portions of the spent fuel pool cooling system to verify the existing equipment
lineup was correct. The inspectors reviewed operating procedures, drawings, equipment
line-up check-off lists, and the UFSAR to verify the system was aligned to perform its
required safety functions. The inspectors also reviewed electrical power availability,
component lubrication and equipment cooling, hanger and support functionality, and
operability of support systems. The inspectors performed field walkdowns of accessible
portions of the systems to verify system components and support equipment were
aligned correctly and operable. The inspectors examined the material condition of the
components and observed operating parameters of equipment to verify that there were
no deficiencies. Additionally, the inspectors reviewed a sample of related issue reports
Enclosure
7
and work orders to ensure Exelon appropriately evaluated and resolved any
deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Resident Inspector Quarterly Walkdowns (71111.05Q - 5 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material
condition and operational status of fire protection features. The inspectors verified that
Exelon controlled combustible materials and ignition sources in accordance with
administrative procedures. The inspectors verified that fire protection and suppression
equipment was available for use as specified in the area pre-fire plan, and passive fire
barriers were maintained in good material condition. The inspectors also verified that
station personnel implemented compensatory measures for out of service, degraded, or
inoperable fire protection equipment, as applicable, in accordance with procedures. Fire
zones and areas inspected included:
Station blackout diesel area, SBO-FA-1, on October 15, 2012
B Emergency diesel generator area, DG-FA-2, on October 25, 2012
Make-up Valve Alley in auxiliary building, AB-FZ-3, on November 27, 2012
A decay heat vault in auxiliary building, AB-FA-1, on December 06, 2012
General area elevation 305 auxiliary building, AB-FZ-9, on December 28, 2012
b. Findings
No findings were identified.
.2 Fire Protection - Drill Observation (71111.05A - 1 sample)
a. Inspection Scope
The inspectors observed a fire brigade drill scenario conducted on October 5, 2012, that
involved a fire in the Intermediate Building at the A air compressor, near the motor-
driven emergency feedwater pumps. The inspectors evaluated the readiness of the
plant fire brigade to fight fires. The inspectors verified that Exelon personnel identified
deficiencies, openly discussed them in a self-critical manner at the debrief, and took
appropriate corrective actions as required. The inspectors evaluated specific attributes
as follows:
Proper wearing of turnout gear and self-contained breathing apparatus
Proper use and layout of fire hoses
Employment of appropriate fire-fighting techniques
Sufficient fire-fighting equipment brought to the scene
Effectiveness of command and control
Search for victims and propagation of the fire into other plant areas
Enclosure
8
Smoke removal operations
Utilization of pre-planned strategies
Adherence to the pre-planned drill scenario
Drill objectives met
The inspectors also evaluated the fire brigades actions to determine whether these
actions were in accordance with Exelons fire-fighting strategies.
b. Findings
No findings were identified.
1R07 Heat Sink Performance (71111.07A - 1 sample)
a. Inspection Scope
The inspectors reviewed the station blackout diesel fire service heat exchanger
inspection performed under M-164, Station Blackout (SBO) Diesel Generator Major
Inspection (Mechanical), Revision 18, to determine its readiness and availability to
perform its credited functions. The inspectors reviewed the design basis for the
component and verified Exelons commitments to NRC Generic Letter 89-13. The
inspectors reviewed the results of previous inspections of the SBO diesel generator.
The inspectors discussed the results of the most recent inspection with engineering staff
and field technicians and reviewed pictures of the as-found and as-left conditions. The
inspectors verified that Exelon initiated appropriate corrective actions for identified
deficiencies. The inspectors also verified that the number of tubes plugged within the
heat exchanger did not exceed the maximum amount allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program and Licensed Operator Performance
(71111.11 - 2 samples)
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator training on October 23, 2012.
The inspectors evaluated operator performance during the simulated event and verified
completion of risk significant operator actions, including the use of abnormal and
emergency operating procedures. The inspectors assessed the clarity and effectiveness
of communications, implementation of actions in response to alarms and degrading plant
conditions, and the oversight and direction provided by the control room supervisor. The
inspectors verified the accuracy and timeliness of the emergency classification made by
the shift manager and the technical specification action statements entered by the shift
technical advisor. Additionally, the inspectors assessed the ability of the crew and
training staff to identify and document crew performance problems.
Enclosure
9
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed the control room operators support of fire service pump
(FS-P-1) troubleshooting efforts as well as routine plant operations on December 12,
2012. Also, on December 13, the inspectors observed the control room operators
perform the B emergency diesel generator monthly surveillance. The inspectors
observed licensed operator performance to verify that procedure use, crew
communications, and coordination of activities between work groups met the criteria
specified in Exelons OP-AA-1, Conduct of Operations, Revision 000. In addition, the
inspectors verified that licensee supervision and management were adequately engaged
in plant operations and appropriately assessed control room operator performance.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness (71111.12Q - 2 samples)
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of
maintenance activities on structures, systems, and components (SSC) performance and
reliability. The inspectors reviewed system health reports, corrective action program
documents, maintenance work orders, and maintenance rule basis documents to ensure
that Exelon was identifying and properly evaluating performance problems within the
scope of the maintenance rule. For each sample selected, the inspectors verified that
the SSC was properly scoped into the maintenance rule in accordance with 10 CFR
50.65 and verified that the (a)(2) performance criteria established by Exelon staff was
reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the
adequacy of goals and corrective actions to return these SSCs to (a)(2). Additionally,
the inspectors ensured that Exelon staff was identifying and addressing common cause
failures that occurred within and across maintenance rule system boundaries.
Pressurizer a(1) determination for heater bundle leakage on December 17, 2012
A emergency feedwater pump (EF-P-1) vibration functional assessment on
December 31, 2012
b. Findings
No findings were identified.
Enclosure
10
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 4 samples)
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the
maintenance and emergent work activities listed below to verify that Exelon performed
the appropriate risk assessments prior to removing equipment for work. The inspectors
selected these activities based on potential risk significance relative to the reactor safety
cornerstones. As applicable for each activity, the inspectors verified that Exelon
personnel performed risk assessments as required by 10 CFR 60.65(a)(4) and that the
assessments were accurate and complete. When Exelon performed emergent work, the
inspectors verified that operations personnel promptly assessed and managed plant risk.
The inspectors reviewed the scope of maintenance work and discussed the results of
the assessment with the stations probabilistic risk analyst to verify plant conditions were
consistent with the risk assessment. The inspectors also reviewed the technical
specification requirements and inspected portions of redundant safety systems, when
applicable, to verify risk analysis assumptions were valid and applicable requirements
were met.
Yellow station risk during A emergency diesel generator vibration monitoring on
October 02, 2012
Planned station blackout diesel outage on October 18, 2012
Workweek 1243 activities planned and adjusted during hurricane Sandy on
October 29-30, 2012
MU-P-1B removed from service and associated Yellow station risk for planned
system outage on November 12-13, 2012
a. Findings
No findings were identified.
1R15 Operability Evaluations (71111.15 - 3 samples)
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-
conforming conditions:
Review of emergency diesel generator fuel pumps with respect to 10CFR21 review
documented in IR 1421493 on October 01, 2012
Unexpected flood barrier hydrostatic capability test results documented in IR
1428726 on October 19, 2012
Station blackout diesel specific gravity battery inspection issue and damper failure as
documented in IRs 1429564 and 1432623 on November 9, 2012
The inspectors selected these issues based on the risk significance of the associated
components and systems. The inspectors evaluated the technical adequacy of the
operability determinations to assess whether technical specification operability was
properly justified and the subject component or system remained available such that no
unrecognized increase in risk occurred. The inspectors compared the operability and
design criteria in the appropriate sections of the technical specifications and UFSAR to
Enclosure
11
Exelons evaluations to determine whether the components or systems were operable.
Where compensatory measures were required to maintain operability, the inspectors
determined whether the measures in place would function as intended and were
properly controlled by Exelon. The inspectors determined, where appropriate,
compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R19 Post Maintenance Testing (71111.19 - 3 samples)
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed
below to verify that procedures and test activities ensured system operability and
functional capability. The inspectors reviewed the test procedure to verify that the
procedure adequately tested the safety functions that may have been affected by the
maintenance activity, that the acceptance criteria in the procedure was consistent with
the information in the applicable licensing basis and/or design basis documents, and
that the procedure had been properly reviewed and approved. The inspectors also
witnessed the test or reviewed test data to verify that the test results adequately
demonstrated restoration of the affected safety functions.
1302-5.31D, 4160V 1E Bus Loss of Voltage/Degraded Grid Timing Relay Calibration
and Logic Check, after replacing undervoltage agastat relays on October 12, 2012
1107-9, SBO Diesel Generator, after SBO system outage that occurred on
October 14-22, 2012
1303-5.2B, B Emergency Loading Sequence and HPI Logic Channel / Component
Test, Rev. 009, after replacing sequence logic relay on November 30, 2012
b. Findings
No findings were identified.
1R22 Surveillance Testing (71111.22 - 4 samples)
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data
of selected risk-significant SSCs to assess whether test results satisfied technical
specifications, the UFSAR, and Exelon procedure requirements. The inspectors verified
that test acceptance criteria were clear, tests demonstrated operational readiness and
were consistent with design documentation, test instrumentation had current calibrations
and the range and accuracy for the application, tests were performed as written, and
applicable test prerequisites were satisfied. Upon test completion, the inspectors
considered whether the test results supported that equipment was capable of performing
the required safety functions. The inspectors reviewed the following surveillance tests:
1302-5.18, HPI/LPI Flow Channel Calibration on October 3 and 5, 2012
MA-TM-125-031, SBO Battery Load Test on October 15, 2012
Enclosure
12
OP-TM-214-201, IST of BS-P-1A on November 5-6, 2012 (in-service test)
Review of Surveillance Frequency Control Program on December 13-14, 2012
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (71114.04 - 1 sample)
a. Inspection Scope
The NRC nuclear security and incident response headquarters staff performed an in-
office review of the latest revisions of various Emergency Plan Implementing Procedures
(EPIPs) and the Emergency Plan located under ADAMS accession number
ML12192A512 as listed in the Attachment.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in
the revisions resulted in no reduction in the effectiveness of the Plan, and that the
revised Plan continued to meet the requirements of 10 CFR 50.47(b) and Appendix E to
10 CFR Part 50. The NRC review was not documented in a safety evaluation report and
did not constitute approval of licensee-generated changes; therefore, this revision is
subject to future inspection. The specific documents reviewed during this inspection are
listed in the Attachment.
b. Findings
No findings were identified.
1EP6 Drill Evaluation (71114.06 - 1 sample)
.1 Drill Evaluation
a. Inspection Scope
The inspectors evaluated the conduct of a routine TMI emergency drill on October 23,
2012 to identify any weaknesses and deficiencies in the classification, notification, and
protective action recommendation development activities. The inspectors observed
emergency response operations in the simulator and technical support center to
determine whether the event classification, notifications, and protective action
recommendations were performed in accordance with procedures. The inspectors also
attended the station drill critique to compare inspectors observations with those
identified by Exelon staff in order to evaluate Exelons critique and to verify whether
Exelon staff was properly identifying weaknesses and entering them into the corrective
action program.
b. Findings
No findings were identified.
Enclosure
13
2. RADIATION SAFETY [RS]
Cornerstone: Occupational Radiation Safety
2RS01 Radiological Hazard Assessment and Exposure Controls (71124.01 - 1 sample)
a. Inspection Scope
During the period December 10 - 14, 2012, the inspector conducted the following
activities to verify that the licensee was properly implementing physical, administrative,
and engineering controls for access to locked high radiation areas, and other radiological
controlled areas. Implementation of these controls was reviewed against the criteria
contained in 10 CFR 20, relevant TS, and the licensees procedures.
Plant Walkdown and Radiation Work Permits (RWP) Reviews
The inspector toured accessible radiological controlled areas in the auxiliary building,
fuel handling building, and primary chemistry laboratory to verify the proper
implementation of radiological controls. Radiation survey maps were reviewed of
selected areas to identify radiological conditions, and the adequacy of postings.
The inspector identified tasks performed in the radiological controlled areas (RCAs).
The inspector reviewed the applicable RWPs, and the electronic dosimeter dose/dose
rate alarm setpoints for the associated tasks, to determine if the radiological controls
were acceptable and if the setpoints were consistent with plant policy. Jobs reviewed
included sampling of a waste gas decay tank and performing a walkdown of effluent
monitoring instrumentation and ventilation filtration systems located in the RCA.
The inspector evaluated the effectiveness of radiological controls by reviewing electronic
dosimeter alarm reports, personnel contamination event reports (and related issue
reports), and observing practices at various locations.
Problem Identification and Resolution
The inspectors evaluated the licensees program for assuring that access controls to
radiological significant areas were effective and properly implemented by reviewing
electronic dosimeter alarm reports, personnel contamination event reports, and relevant
issue reports. The inspector determined that problems were identified in a timely
manner, that an extent of condition and cause evaluation were performed when
appropriate, and corrective actions were appropriate to preclude repetitive problems.
b. Findings
No findings were identified.
Enclosure
14
Cornerstone: Public Radiation Safety
2RS06 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
During the period December 10 - 14, 2012, the inspector conducted the following
activities to ensure the gaseous and liquid effluent processing systems are maintained
so that radiological discharges are properly reduced, monitored, and evaluated, and to
verify the accuracy of effluent releases and public dose calculations resulting from
radioactive effluent discharges.
The inspector used the requirements in 10 CFR Part 20, 10 CFR 50 Appendix I,
10 CFR 50.75(g), applicable Industry standards, and licensee procedures, required by
the site Offsite Dose Calculation Manual (ODCM), as criteria for determining compliance.
a. Inspection Scope
Event Report and Effluent Report Reviews
The inspector reviewed the TMI annual radiological effluent release reports for 2010 and
2011. The inspector reviewed sampling results, and trends identified by the licensee.
The inspector determined if these releases were evaluated, and any abnormal releases
were entered in the corrective action program and were adequately resolved.
ODCM and Updated Final Safety Analysis Report Review
The inspector reviewed the TMI Updated Final Safety Analysis Report (UFSAR)
descriptions of the radioactive effluent monitoring systems, treatment systems, and
effluent flow paths to identify system design features and required functions.
The inspector reviewed changes to the TMI ODCM made by the licensee since the last
inspection. The inspector reviewed the evaluations of the changes and determined that
they were technically justified and maintained effluent releases as low as is reasonably
achievable (ALARA).
Groundwater Protection Initiative (GPI) Program
The inspector reviewed reported groundwater monitoring sample results and changes to
the licensees written program for identifying, controlling, and remediating contaminated
spills/leaks to groundwater. The inspector observed a monthly groundwater sample
being taken from MW-20. An in-depth inspection of the GPI was performed in
accordance with Temporary Instruction (TI) 2515/185 and documented in Section
4OA5 of this report.
Procedures, Special Reports, and Other Documents
The inspector reviewed issue reports related to the effluent program issued since the
previous inspection to identify any additional focus areas for the inspection based on the
scope of problems described in these reports.
The inspector reviewed effluent program implementing procedures, including those
associated with effluent sampling, effluent monitor setpoint determinations, and dose
calculations.
Enclosure
15
The inspector reviewed copies of licensee assessment reports of the effluent monitoring
program since the last inspection to gather insights into the effectiveness of the
licensees program.
Walkdowns and Observations
The inspector walked down selected components of the gaseous and liquid discharge
systems, with the responsible system engineers, to verify that equipment configuration
and flow paths align with the descriptions in the TMI UFSAR and to assess equipment
material condition. The inspector reviewed the calibration records for each of the
radiation monitors examined. During the walkdown, special attention was made to
identify potential unmonitored release points, building alterations which could impact
airborne, or liquid effluent controls, and ventilation system leakage that communicate
directly with the environment.
Monitoring equipment inspected included the following:
Gaseous Discharge Monitors:
- Auxiliary Building/Fuel Handling and Reactor Building Purge exhaust radiation
monitors, RM-A-8 and RM-A-9, respectively;
- Waste Gas Disposal Effluent monitor, RM-A-7;
- Fuel Handling ESF Ventilation monitor, RM-A-14;
- Condenser Offgas monitors, RM-A -5 and RM-A-15.
Liquid Discharge Monitors:
- Liquid Radioactive Waste Discharge monitor, RM-L-6;
- Plant Water Discharge monitor, RM-L-7;
- Industrial Water Treatment System monitor, RM-L-12;
The inspector walked down filtered ventilation systems, with the system engineers, to
verify there were no degraded conditions associated with high-efficiency particulate air
(HEPA)/charcoal banks, improper alignment, or system degradation issues that would
impact the performance, or the effluent monitoring capability.
The inspector reviewed the licensee's surveillance test records for air cleaning equip-
ment (i.e., fans, charcoal filters, and HEPA filters for the Unit 1 plant ventilation systems)
to assure that the equipment met the TS operability criteria.
The inspector determined that the licensee had not made any changes to their effluent
release paths.
Sampling and Analyses
The inspector observed technicians obtaining weekly tritium, particulate, iodine, and
noble gas samples from the auxiliary building/fuel handling building and reactor purge
system radiation monitors, RM-A-8 and RM-A-9, respectively. Subsequently, the
inspector reviewed the analytical results for these samples.
Enclosure
16
The inspector observed a technician obtain gas samples from the B-waste decay tank,
prepare a discharge permit (G-2012-12028), and verify that the procedural requirements
were met.
The inspector reviewed the calibration records and daily quality control checks for the
gamma spectroscopy detectors (Nos. 1, 2, 3, 4) and for the two beta scintillation
counters to verify that the instruments operated within the established parameters and
achieved the required lower limit of detectability.
The inspector reviewed the results of the inter-laboratory and intra-laboratory
comparison (cross check) programs to verify the quality of the radioactive effluent
sample analyses. The inspector also determined that the intra and inter-laboratory
comparison program includes hard-to-detect isotopes.
The inspector reviewed liquid and gaseous discharge permits for routine processing and
discharging waste streams. The inspector verified that appropriate effluent treatment
equipment was being used and that radioactive liquid and gaseous waste is being
analyzed, processed, and discharged in accordance with licensee procedures.
Instrumentation and Equipment: Effluent Flow Measuring Instruments
The inspector reviewed the methodology that the licensee uses to determine the effluent
stack and ventilation system flow rates to verify that the flow rates are consistent with
TSs/ODCM and FSAR values.
Instrumentation and Equipment: Air Cleaning Systems
The inspector determined that surveillance test results for the HEPA and charcoal filters
installed in the auxiliary building, fuel handling building, and reactor purge system met
TS/ODCM acceptance criteria.
Dose Calculations
The inspector reviewed five radioactive gaseous and three liquid waste discharge
permits to verify that the projected doses to members of the public were accurate and
based on representative samples from the discharge path.
The inspector evaluated the methods used to determine the isotopes that are included in
the source term to ensure all applicable radionuclides are included, within detectability
standards. The review included the licensees current waste stream analyses to ensure
hard-to-detect radionuclides are included in the effluent releases.
The inspector reviewed the licensees methodology for offsite dose calculations to verify
compliance with the ODCM and RG 1.109. The inspector reviewed meteorological
dispersion and deposition factors used in the ODCM and effluent dose calculations to
ensure appropriate dispersion/deposition factors are being used for public dose
calculations.
The inspector reviewed the latest Land Use Census to verify that changes in the local
land use have been factored into the dose calculations and environmental
sampling/analysis program.
Enclosure
17
The inspector determined that the calculated doses are within the 10 CFR 50,
Appendix I, and ODCM dose criteria. The inspector determined that the licensee was
tracking cumulative doses on a monthly, quarterly, and annual basis, and comparing
dose to the regulatory criteria.
Problem Identification and Resolution
Inspector assessed whether problems associated with the effluent monitoring and
control program are being identified by the licensee at an appropriate threshold and are
properly addressed for resolution in the licensees corrective action program. In
addition, the inspector evaluated the effectiveness of the corrective actions for a
selected sample of problems documented by the licensee.
b. Findings
No findings were identified.
4. OTHER ACTIVITIES [OA]
4OA1 Performance Indicator Verification (71151)
Occupational Exposure Control Effectiveness (1 sample)
a. Inspection Scope
The inspector reviewed implementation of the licensees Occupational Exposure Control
Effectiveness Performance Indicator (PI) Program. Specifically, the inspector reviewed
electronic dosimeter dose and dose rate alarm reports, issue reports, and associated
documents, for occurrences involving locked high radiation areas, very high radiation
areas, and unplanned exposures occurring during the past four (4) calendar quarters.
Data contained in these records was reviewed against the criteria specified in Nuclear
Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline,
to verify that all occurrences that met the NEI criteria were identified and reported as
performance indicators.
b. Findings
No findings were identified.
RETS/ODCM Radiological Effluent Occurrences (1 sample)
a. Inspection Scope
The inspector reviewed relevant effluent release reports and associated dose
assessments for the period October, 2011 through November, 2012, for issues related
to the public radiation safety performance indicator, which measures radiological effluent
release occurrences that exceed 1.5 mrem/qtr whole body or 5.0 mrem/qtr organ dose
for liquid effluents; and 5 mrads/qtr gamma air dose, 10 mrad/qtr beta air dose, and
7.5 mrads/qtr for organ dose for gaseous effluents. This inspection activity represents
the completion of one (1) sample relative to this inspection area; completing the annual
inspection requirements.
Enclosure
18
b. Findings
No findings were identified.
4OA2 Identification and Resolution of Problems (71152 - 3 annual samples)
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the
inspectors routinely reviewed issues during baseline inspection activities and plant
status reviews to verify that Exelon entered issues into the corrective action program at
an appropriate threshold, gave adequate attention to timely corrective actions, and
identified and addressed adverse trends. In order to assist with the identification of
repetitive equipment failures and specific human performance issues for follow-up, the
inspectors performed a daily screening of items entered into the corrective action
program and periodically attended issue report screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample - Multiple Spurious Operation (MSO) Mitigation (1 sample)
a. Inspection Scope
The inspectors performed an in-depth review of Exelons implementation of NEI 00-01
revision 2 at TMI, guidance for post-fire safe shutdown circuit analysis. The inspectors
verified that Exelon followed the guidance to identify fire safe shutdown components
potentially susceptible to MSO in postulated fire scenarios and appropriately entered the
deficiencies into their corrective action program. The inspectors verified that Exelons
actions were appropriately completed within the timeline provided by the enforcement
guidance memorandum (EGM)09-002.
The inspectors assessed Exelons problem identification threshold, cause analyses,
extent of condition reviews, compensatory actions, and the prioritization and timeliness
of Exelons corrective actions to determine whether Exelon was appropriately identifying,
characterizing, and correcting problems associated with this issue and whether the
planned or completed corrective actions were appropriate. The inspectors compared the
actions taken to the requirements of Exelons corrective action program and 10 CFR 50,
Appendix B. In addition, the inspectors performed field walkdowns and interviewed
engineering personnel to assess the effectiveness of the implemented corrective
actions.
b. Findings and Observations
No findings were identified.
Enclosure
19
NEI 00-01 provided a methodology for licensees to conduct post-fire safe shutdown
circuit analysis involving MSO of components. The NEI guidance provided a generic list
of MSO scenarios that licensees would use as the basis for their circuit analysis.
Licensees performed this evaluation if they chose not to adopt 10 CFR 50.48(c), NFPA
805. The NEI 00-01 methodology was to be performed in a manner commensurate with
its safety significance as outlined in Reg Guide 1.189 Rev. 2 and enforcement guidance
memorandum (EGM)09-002. Specifically, licensees were granted enforcement
discretion for the identification and resolution of MSO deficiencies until November 2012.
Exelon chose to perform the NEI 00-01 circuit analysis for TMI. Exelon performed an
expert panel review in accordance with NEI 00-01, Rev. 2, guidance in May 2010. The
expert panel identified permanent circuit modifications, plant configuration changes,
procedure changes and compensatory operator rounds were required to mitigate MSO
deficiencies. Subsequently, Exelon entered the deficiencies into the corrective action
program and completed the required mitigation actions in accordance with Reg Guide
1.189 and EGM 09-002. The inspectors independently performed field walkdowns to
ensure that procedure and plant configuration changes appropriately addressed the
MSO deficiencies. In addition, the inspectors verified that the non-licensed operators
were adequately trained to perform compensatory actions. The inspectors identified no
issues of concern with the MSO mitigation actions.
In the spring of 2012, Exelon identified, through review of NEI 00-01 Rev. 3 and a scope
validation review, that additional components were susceptible to MSO and required
plant modifications, procedure changes and plant configuration changes. The
deficiencies were entered into the corrective action program and Exelon promptly took
corrective actions commensurate with EGM 09-002 completion deadlines. Exelon
completed the required actions and took compensatory actions to address all of the
identified deficiencies except for one wiring modification. Exelon determined that the
remaining modification would require the plant in a shutdown condition to complete.
The inspectors reviewed the additional deficiencies and associated corrective actions
and determined that the licensees actions addressed the issues and were completed in
a manner commensurate with the safety significance. Furthermore, the inspectors
validated that an adequate extent of condition review was performed such that
reasonable assurance that MSO deficiencies were identified. Specific to the outstanding
modification, the inspectors verified that the modification must be worked with the plant
shutdown. In addition, the inspectors validated that the modification was scheduled in
the next planned refuel outage as well as coded for completion in any forced outage
prior to the refueling outage. The inspectors, with consultation with the regional fire
protection specialists, assessed the impact of the outstanding MSO deficiency and
concluded it was not more than minor due to its low safety significance and minimal
impact on post-fire safe shutdown strategy.
.3 Annual Sample: Fire Suppression Spray Nozzle Blockage Operating Experience
Evaluation (1 sample)
a. Inspection Scope
The inspectors performed an in-depth review of Exelons evaluation and corrective
actions for industry operating experience (OpE) regarding fire suppression (FS) system
spray nozzle blockage. Specifically, in October 2010 and September 2011, licensees at
Enclosure
20
two nuclear power plants identified their FS sprinkler systems were inoperable due to
spray nozzles being internally blocked by piping corrosion products. The associated FS
branch piping was normally dry; however, due to inadequate pipe slope and drainage
small amounts of water from FS system testing or actuation remained in the branch
piping. Over a long period of time, repetitive wetting and drying of the FS piping interior
surfaces caused significant corrosion. The corrosion products were flushed down the
branch pipe and blocked the spray nozzle when the FS system was actuated for testing.
The licensees determined the primary cause was inadequate piping design (slope and
drainage) and a contributing cause was deficient FS system test procedures which did
not ensure all branch lines were periodically flushed. Corporate engineers initiated IR
1275720 to assess applicability of this OpE issue at all Exelon sites including TMI.
The inspectors independently reviewed IR 1275720, selected OpE documents including
related licensee event reports, the TMI Unit 1 Updated Final Safety Analysis Report
(UFSAR), the TMI Unit 1 Fire Hazards Analysis Report, FS system drawings, selected
FS system test records, fire protection system modifications and replacements
performed during the last 5 years, and all fire protection system issues entered in the
corrective action program database during the last 5 years. Additionally the inspectors
interviewed station personnel and performed plant walkdowns to verify the condition of
FS spray nozzles and the adequacy of corrective actions including planned visual
inspections of FS piping and nozzles. The inspectors reviewed this issue to determine
whether TMI staff adequately evaluated issue applicability, identified the root and
contributing causes, identified associated lessons learned, implemented appropriate
actions in a timely manner, and communicated the results to appropriate staff. The
inspectors compared the actions taken to the requirements of Exelons corrective action
program.
b. Findings
No findings were identified.
Site engineers reviewed root cause evaluations of the related OpE events from other
power plants and discussed TMI specific actions with the Exelon fleet peer group.
Specific actions included FS piping walkdowns and isometric drawing reviews to assess
FS piping drainage, FS test procedure and surveillance history reviews, and identifica
tion of six sections of FS piping which could be susceptible to similar corrosion and
blockage. Site Engineers initiated additional IRs and work orders with appropriate
schedules to perform and evaluate internal visual inspections of these six FS piping
zones. The inspectors determined engineers thoroughly evaluated the FS spray nozzle
blockage issue, understood the primary and contributing causes, established timely and
appropriate corrective actions, entered the actions into the corrective action program for
implementation, and effectively communicated the results to the TMI organization.
.4 Cumulative Operator-Work-Around (1 sample)
a. Inspection Scope
The inspectors reviewed the cumulative effects of the existing operator work-arounds
(OWAs), the list of operator challenges, equipment deficiencies logs, the list of
operations department concerns, and the list of open main control room deficiencies and
main control room tags to identify any effect on emergency operating procedure
Enclosure
21
operator actions, and impact on possible initiating events and mitigating systems. The
inspectors also interviewed selected operations and engineering personnel to assess
their understanding of the OWAs and other listed control room deficiencies. The
inspectors observed the quarterly OWA meeting to determine whether station personnel
were identifying, assessing, and reviewing OWAs as specified in Exelon administrative
procedure OP-AA-102-103, Operator Work-Around Program, Rev. 3.
b. Findings and Observations
No findings were identified.
The inspectors determined that the issues reviewed did not adversely affect the
capability of the operators to implement abnormal or emergency operating procedures.
The inspectors also verified that Exelon entered operator workarounds and burdens into
the corrective action program at an appropriate threshold and planned or implemented
corrective actions commensurate with their safety significance.
.5 Semi-Annual Trend Review (1 sample)
a. Inspection Scope
The inspectors performed a semi-annual review of TMI issues, to identify trends that
might indicate the existence of more significant safety issues, as required by NRC
Inspection Procedure 71152, Identification and Resolution of Problems. The inspectors
included in this review repetitive or closely-related issues that may have been
documented by Exelon outside of the corrective action program, such as trend reports,
performance indicators, major equipment problem lists, system health reports,
maintenance rule assessments, and maintenance or corrective action program backlogs.
The inspectors also reviewed the Exelon corrective action program database from July
2012 through December 2012, to assess issue reports written in various subject areas
(equipment problems, human performance issues, etc.) as well as individual issues
identified during the NRCs daily IR review (Section 4OA2.1).
b. Findings
No findings were identified.
The inspectors determined that, corrective actions to address limiting condition for
operation (LCO) and fire protection time-clock deficiencies from the first half of 2012
have been effective regarding LCO time-clock entry. However, corrective actions have
been marginally effective regarding fire protection in that minor occurrences continue (IR
1450965). In addition an adverse trend was been identified by both the licensee and
NRC regarding transient combustible control (e.g. IR 1449500 and 1461029) where
materials have been placed and left uncontrolled in transient combustible free zones.
The licensee has implemented prompt actions to arrest the trend via station
communications, focused plant walkdowns, and improved markings and signage.
Exelon continues to evaluate the cause of the trend and is in progress of performing a
common and root cause evaluation.
Enclosure
22
The inspectors evaluated a sample of departments that provide input into the aggregate
trend review, which included maintenance, work planning, and operation departments.
This review included a sample of issues and events that occurred over the course of the
past two quarters to objectively determine whether issues were appropriately considered
or ruled as emerging or adverse trends, and in some cases, verified the appropriate
disposition of resolved trends. The inspectors verified that these issues were addressed
within the scope of the corrective action program, or through department review and
documentation in the aggregate trend review had had appropriate action requests in a
timely manner.
.6 (Closed) Unresolved Item (URI)05000289/2011005-03, Adequacy of Seismic Gap Flood
Seal
a. Inspection Scope
This URI was identified because additional information was required to determine
whether a performance deficiency existed regarding the configuration and qualification of
the hydrostatic seal (i.e., flood seal) in the seismic gap between the reactor building and
adjacent buildings and structures.
The inspectors performed an in-depth in-office review of Exelon's Technical Evaluation
1170013-06, "Consequences of Inadequate Flood Seal in Reactor Building Seismic
Gap." In addition, the inspectors performed on-site observations of field excavation and
examination of seismic gap flood seal samples, interviewed design engineers, and
reviewed corrective actions associated with the hydrostatic qualification of the seismic
gap flood seal to withstand design basis probable maximum flood (PMF) conditions.
b. Findings and Observations
Introduction: The inspectors identified a finding of very low safety significance (Green)
involving a non-cited violation of General Design Criterion 2, "Performance Standards,"
because Exelon had not established measures to ensure that the seismic gap flood seal
was adequate to remain watertight during a PMF event, as required by the TMI design.
Specifically, the design requirement for the seismic gap seal specified that it was to be
watertight. However, the installed seal configuration had measurable leakage when
tested.
Description: As a result of the TMI external flood re-analysis, Exelon modified the TMI
flood barrier system to accommodate a higher predicted flood height for a PMF event.
Engineering Change Request (ECR) TM 11-00426, "Raise Level of External Flood
Protection," in part, re-evaluated the adequacy of the seismic gap flood seal capability.
ECR Attachment-17, "Reactor Building Elevation 305 feet Seismic Gap Flood Seal
Evaluation," described the seismic gap as filled with Dow Corning 3-6548 silicone RTV
foam (i.e., a low density fire resistant penetration seal) to a nominal depth of two feet,
but conservatively assumed only a gap depth of nine inches for the watertight
assessment. In order to evaluate the capability of the existing seal to withstand the
higher predicted water pressure, Exelon used a friction coefficient derived from test
results for a similar material (i.e., BISCO SF-20 foam). NPB-92, "BISCO Seal Test
Equivalency for Use in Conduit Sealing," documented the test results for BISCO SF-20
foam (i.e., a low density fire resistant penetration seal), which had been performed to
determine seal blowout resistance, not to verify or test the seal's hydrostatic properties.
Enclosure
23
The inspectors identified that the NPB-92 test results also documented seal water
leakage, but the leakage rates were not quantified or evaluated. Drawing E-107-012,
"Architectural Special Area Plans, Sections, & Details," provided the installation and
configuration details for the seismic gap seal. The inspectors identified that the drawing
details differed from the assumptions in ECR TM 11-00426. Exelon was unable to
recover additional design information or installation records to demonstrate that the
seismic gap seal was properly installed and configured to the requirements specified in
E-107-012, or was otherwise qualified as a watertight seal. As a result, Exelon sampled
sections of the seismic gap seal and determined that portions of the seal were not
installed to the required minimum depth of nine inches and that the actual seal
installation was configured differently than assumed. Exelon entered this issue into
their corrective action program as issue reports (IR) 1341027 and 1341537, and took
appropriate interim corrective actions. In June 2012, Exelon implemented permanent
modifications to restore the watertight function of the seismic gap barrier, under ECR 12-
00160, "RB Seismic Gap Flood Seal." The inspectors' independent review of that
modification was documented in NRC Inspection Report 05000289/2012003, Section
1R18, Permanent Modifications."
On September 5, 2012, Exelon completed laboratory tests of the as-installed seal
configuration to determine whether it was suitable to satisfy the design basis PMF
hydrostatic demands. Technical Evaluation 1170013-06 assessed the laboratory test
results and concluded that the installed configuration would not satisfy the requirements
for a watertight seal design. Additionally, Exelon quantified the expected leakage that
would be expected during a design basis PMF event to evaluate the consequences on
the ability to maintain the plant in a safe shutdown condition. During a PMF event,
Exelon estimated that approximately 180,000 gallons of water would leak into the tendon
access gallery. Exelon determined that volume of water would fill those areas from the
bottom (265 feet elevation) to an elevation of approximately 286.6 feet. Because the
equipment needed for safe shutdown, specifically the emergency feedwater pumps, was
located on the 295 feet elevation, Exelon concluded that no adverse impact to the plant
was expected. Exelon entered these issues into their corrective action program as IRs
1382505, and 1428726.
Analysis: The inspectors determined that the failure to construct, maintain, and inspect
the seismic gap flood seal consistent with its design (e.g., watertight) was a performance
deficiency within Exelon's ability to foresee and prevent. This issue was more than
minor because it was similar to Inspection Manual Chapter (IMC) 0612, Appendix E,
"Examples of Minor Issues," Example 3.j, in that the seal's as-built and maintained
configuration resulted in a condition where the inspectors had reasonable doubt
regarding the functionality of the seismic gap seal to remain watertight during a PMF
event. In addition, the performance deficiency was associated with the protection
against external factors attribute of the Mitigating Systems Cornerstone and adversely
affected the cornerstone objective of ensuring the availability, reliability, and capability of
systems that respond to initiating events to prevent undesirable consequences.
In accordance with IMC 0609 Attachment 4, "Initial Characterization of Findings," this
issue was evaluated using IMC 0609 Appendix G, "Shutdown Operations Significance
Determination Process (SDP)," Attachment 2, "Phase 2 SDP for PWR during
Shutdown," because the plant was expected to be shutdown and on decay heat removal
(DHR) prior to flood waters reaching the seismic gap seal. A Region I Senior Reactor
Analyst performed a detailed risk evaluation, in accordance with IMC 0609, Appendix G,
Enclosure
24
Attachment 2, Worksheet 3, "Loss of Off-site Power in POS 1 (RCS Closed)." The
following assumptions were made:
The reactor would be shutdown and on DHR before flood water would reach the
seismic gap seal. This was based on the design basis PMF developing slowly and
the Technical Specification requirement to shutdown prior to the river water level
reaching the design basis flood level of 305 feet.
The leakage past the seismic gap seal was bounded by test results evaluated in
Technical Evaluation 1170013-06. Based on the as-found physical configuration, a
total seal failure was not considered credible.
A loss of off-site power was assumed to occur when flood water reached an
elevation of 305 feet, due to flooding of the switchyard.
The emergency diesel generators (EDG) were not affected by the seismic gap seal
leakage issue.
The station black out diesel generator was assumed to be unavailable, due to
flooding of the room or support systems.
The site had some capability to utilize severe flood mitigation strategies.
The initiating event frequency of 2E-4 for the PMF was obtained from the TMI
Individual Plant Examination of External Events.
Flood duration of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> was approximated from the UFSAR.
The unavailability for this watertight seal was assumed to be greater than one year.
The dominant sequence for this event was a flood induced loss of off-site power
combined with:
a failure of the emergency diesel generators, and
a failure to establish steam generator cooling, and
a failure to recover off-site power.
Based on the initiating event frequency and multi-train EDG configuration, the increase
in core damage frequency was determined to be low E-7. No large early release was
considered because TMI had a large dry containment and steam generator tube rupture
was not an event of concern. Therefore, this issue was determined to be of very low
safety significance (Green).
This finding had a cross-cutting aspect, as described in IMC 0310, "Components with
Cross-Cutting Areas," in the area of Human Performance, Decision Making, because
Exelon failed to verify the validity of underlying assumptions or continued functionality of
the seismic gap flood seal following an external flood re-analysis which revised the
design basis PMF conditions. H.1(b)
Enforcement: The proposed Atomic Energy Commission General Design Criterion 2,
"Performance Standards," dated July 1967, is the applicable regulatory requirement for
TMI Unit 1 and, in part, required that essential systems and components be designed,
fabricated, and erected to performance standards that would ensure the facility to
withstand, without loss of capability to protect the public, the addition forces that might
be imposed by natural phenomena such as flooding conditions (UFSAR Section 1.4.2).
UFSAR Section 2.6.5, "Design of Hydraulic Facilities," in part, stated that the facilities
were constructed and would be maintained and inspected consistent with their design,
and that a commitment was made to the Atomic Energy Commission that the plant
would be provided with component protection to the degree which would assure a safe
Enclosure
25
and orderly shutdown for the level of flooding postulated for a PMF event. Specifically,
Section 2.6.5 stated that "The 3 inch seismic gap between this [the Fuel Handling
Building] and the Reactor Building was made watertight," and "All openings below PMF
elevation that are potential leak paths (ducts, pipes, conduits, cable trays, seismic gaps,
and so forth) are sealed."
Contrary to the above, as of March 14, 2012, Exelon had not constructed, maintained, or
inspected the seismic gap flood seal to ensure that the seal would remain watertight
during a PMF event, as required by the TMI design. Because this issue was of very low
safety significance (Green) and Exelon entered this issue into their corrective action
program (IRs 1341027, 1341537, 1382505, and 1428726), this finding is being treated
as a non-cited violation (NCV) consistent with Section 2.3.2 of the NRC Enforcement
Policy. (NCV 05000289/2012005-01, Adequacy of Seismic Gap Flood Seal)
4OA3 Follow-up of Events and Notices of Enforcement Discretion (71153 - 4 samples)
.1 (Closed) Licensee Event Report (LER) 05000289/2011-001-00: Unanalyzed Condition
Affecting Probable Maximum Flood Level
On September 26, 2011, TMI completed a revised river stage discharge analysis, which
was initiated in 2010 (Pre-Fukushima), that resulted in a higher PMF level than what is
described in their Updated Final Safety Analysis Report (UFSAR). This was reported to
the NRC as an unanalyzed condition under 10 CFR 50.72 (b)(3)(ii)(B) (EN #47294 on
September 26, 2011). LER-related elements were reviewed and documented in the
following NRC reports (see references for ADAMS ML number):
2011005 - Focused PI&R sample review of TMIs flooding protection (section
4OA2.4) and event follow-up (section 4OA3.1), resulting in two unresolved items
and one non-cited violation:
o URI 05-289/2011005-03, Adequacy of Seismic Gap Flood Seal
o URI 05-289/2011005-04, Adequacy of Flood Protection without Consideration of
Wind Generated Wave Activity
o NCV 05-289/2011005-05, Failure to Identify a Non-Conservative Technical
Specification following Revision to River Stage Discharge Analysis
2012002 - Focused PI&R sample review of TMIs flooding analysis (section
4OA2.3), no findings identified.
2012003 - Closure of URI 05-289/2011005-04, Adequacy of Flood Protection
without Consideration of Wind Generated Wave Activity (section 4OA5.1), to no
findings identified.
2012005 - Closure of URI 05-289/2011005-03, Adequacy of Seismic Gap Flood
Seal (4OA2.6), to one non-cited violation:
o NCV 05-289/2012005-01, Adequacy of Seismic Gap Flood Seal
These issues do not pose an immediate safety concern based on Exelons corrective
actions taken and documented in the reference reports. This LER was reviewed and no
new findings or violation of NRC requirements were identified. This LER is closed.
Enclosure
26
.2 (Closed) LER 05000289/2012-003-00: Pressurizer Heater Bundle Leak
On August 22, 2012, TMI discovered an unisolable leak from the upper pressurizer
heater bundle during leak search activities in the reactor building. Exelon conducted a
reactor shutdown and cooldown to cold shutdown conditions in accordance with TS 3.1.6.4 and 3.1.6.6. Exelon determined the root cause of the leak was primary water
stress corrosion cracking of the Alloy 600 pressurizer heater bundle diaphragm plate.
The heater bundle and diaphragm plate was replaced with one of a non-Alloy 600
material and tested satisfactory. The remaining Alloy 600 susceptible heater bundle was
also tested satisfactorily and is planned to be replaced in the next refueling outage. The
unit was returned to service September 4, 2012. The LER was reviewed. No findings or
violation of NRC requirements were identified. This LER is closed.
.3 (Closed) LER 05000289/2012-004-00: Reactor Trip During Downpower Due to
Condensate Booster Pump Trip
On August 22, 2012, during the TS required shutdown related to LER 05-289/2012-003-
00 (see Section 4OA3.2), TMI experienced a reactor protection system trip from a valid
high reactor coolant pressure signal from 30 percent reactor power. The cause of the
reactor high pressure was the loss of main feedwater caused by a logic trip of the only
operating condensate booster pump (CO-P-2C). Exelon determined the logic trip was
caused by a stuck relay in the condensate counting circuit logic. Emergency feedwater
automatically actuated to restore secondary water level. TMI operators took appropriate
actions to stabilize the unit. The stuck relay was replaced and tested prior to startup,
including raising the alarm priority of an early-warning computer alarm related to the
counting circuit logic. The LER was reviewed. No findings or violation of NRC
requirements were identified. This LER is closed.
.4 (Closed) LER 05000289/2012-005-00: Reactor Trip due to RC-P-1C Trip
On September 20, 2012, TMI experienced an automatic reactor runback and trip from
full power in response to a spurious trip of the C reactor coolant pump (RC-P-1C). TMI
operators took appropriate actions to stabilize the unit in hot shutdown. Exelon
determined the cause of the RC-P-1C trip was due to actuation of the motors differential
current relay. Exelon did not determine a definitive root cause of the differential current
trip of RC-P-1C nor evidence that it was a valid trip. The licensee replaced the affected
relay, raised the actuation setpoint, and implemented a monitoring program. This relay
does not have a reactor safety function. Exelon performed an operational decision
evaluation prior to plant restart, in part, since no definitive cause of the RC-P-1C trip was
identified. The LER was reviewed. No findings or violation of NRC requirements were
identified. This LER is closed.
4OA5 Other Activities
.1 Temporary Instruction 2515/185, Revision 1, Follow-up On the Industrys Groundwater
Protection Initiative (2515/185 - 1 sample)
a. Inspection Scope
An NRC assessment was performed of the Three Mile Island Groundwater Protection
Program during December 10 - 14, 2012, to determine whether Exelon (formerly
Enclosure
27
AmerGen in 2007) fully implemented the voluntary industry groundwater protection
initiative, (Nuclear Energy Institute NEI 07-07 Industry Groundwater Protection Initiative
(GPI) - Final Guidance dated August 2007, ADAMS Accession Numbers ML072610036
and ML072600292). The inspector interviewed personnel, reviewed applicable
documents and performed walkdowns of monitoring wells. In addition, the inspector
verified completion for the deviations to the acceptance criteria in NEI 07-07 that were
reported in the NRC integrated inspection report 05000289/20100003:
GPI Objective 1.1 - Site Hydrology and Geology
1.1a Exelon had a hydrogeology study performed in 2006 and re-evaluated the study
in 2011.
1.1b A knowledgeable Exelon employee reviewed the hydrogeology study to
determine the dominant direction of groundwater flow and the effect of site
modifications had on the prevailing groundwater flow direction.
1.1d Exelon has established a frequency to conduct a periodic review of the
hydrogeology studies.
GPI Objective 1.2 - Site Risk Assessment
1.2a Exelon has identified Structures, Systems, and Components (SSCs) and work
practices that could involve or could reasonably be expected to involve licensed
material and for which there is a credible mechanism for licensed material to
reach groundwater.
1.2b Exelon has identified leak detection methods for SSCs and work practices that
could involve or could reasonably be expected to involve licensed material and
for which there is a credible mechanism for licensed material to reach
groundwater.
1.2c Exelon has made enhancements to leak detection systems and programs.
1.2d Exelon has made enhancements to prevent leaks or spills from reaching
groundwater.
1.2f Exelon has established a frequency to conduct periodic reviews of SSCs and
work practices to assure that leak detection methods and enhancements are
effective in identifying and preventing leaks and spills from reaching
groundwater.
GPI Objective 1.3 - On-Site Groundwater Monitoring
1.3f Exelon has established a long-term program for preventive maintenance of
groundwater monitoring wells.
1.3g Exelon has established a frequency for periodic review of the groundwater
monitoring program.
GPI Objective 1.4 - Remediation Process
1.4a Exelon has established written procedures outlining the decision making process
for the remediation of leaks and spills.
GPI Objective 1.5 - Recordkeeping
1.5a. Exelon has established a recordkeeping process to meet the requirements of 10
CFR 50.75(g).
Enclosure
28
GPI Objective 3.2 - Review the program Under the Auspices of NEI
3.2b Exelon has performed an initial review of the groundwater protection program
and has established plans to review the program every five (5) years.
b. Findings and Observations
No findings were identified. The Industry Groundwater Protection Initiative has been
fully implemented at TMI.
.2 Temporary Instruction 2515/187, Inspection of Near-Term Task Force Recommendation
2.3 Flooding Walkdowns (2515/187 - 1 sample)
a. Inspection Scope
Inspectors verified that licensees walkdown packages of the Intake Pumping
Screenhouse (IPSH), Air Intake Tunnel (AIT), and EDG Building contained the elements
as specified in NEI 12-07 Walkdown Guidance document:
The inspectors accompanied the licensee on their walkdowns of the IPSH and AIT and
verified that the licensee confirmed the following flood protection features:
Visual inspection of the flood protection feature was performed if the flood protection
feature was relevant. External visual inspection for indications of degradation that
would prevent its credited function from being performed was performed.
Reasonable simulation
Critical SSCs were measured
Available physical margin, where applicable, was determined
Flood protection feature functionality was determined using either visual observation
or by review of other documents
The inspectors independently performed their walkdown and verified that the following
flood protection features in the EDG building were in place.
Flood protection feature functionality was determined using either visual observation
or by review of other documents
Ensured critical SSCs were measured
External visual inspection for indications of degradation that would prevent its
credited function from being performed was performed.
Verified operability of EDGs during a PMF due to partial obstruction of combustion
air intake
The inspectors independently verified that non-compliances with current licensing
requirements, and issues identified in accordance with the 10 CFR 50.54(f) letter, Item
2.g of Enclosure 4, were entered into the licensees corrective action program. In
addition, issues identified in response to Item 2.g that could challenge risk significant
equipment and the licensees ability to mitigate the consequences will be subject to
additional NRC evaluation.
b. Findings
.1 Failure to Identify and Correct Licensing Basis Flood Barrier and Support Equipment
Deficiencies in Intake Screen and Pump House
Enclosure
29
Introduction. The inspectors identified an NCV of 10 CFR 50, Appendix B, Criterion XVI,
Corrective Actions, in that Exelon failed to identify and correct conditions adverse to
quality regarding the licensing basis external flood barrier integrity. Specifically, Exelon
failed to identify and correct 13 unsealed penetrations through the Intake Screen and
Pump House (ISPH) flood barrier and multiple deficiencies that challenged the fulfillment
of ISPH support equipment capability to maintain the integrity of the licensing basis flood
barrier.
Description. On September 26, 2011, Exelon completed a revised river stage discharge
analysis and concluded that the licensing basis PMF had increased from 310 to 313.3
elevation, as measured at the ISPH. Exelon took prompt actions to modify all the
flooding boundaries to withstand the increased PMF elevation.
The ISPH is a safety-related building that contains the safety-related river water pumps
that provide cooling to TMI systems, structures, or components (SSCs) using the
ultimate heat sink (Susquehanna River). The river water pumps are deep draft pumps
that are located on the 308 elevation and take suction from river water located in a
channel beneath the floor. The PMF flood barrier for the ISPH consists of 3 outer
vertical walls, the floor, drain plugs and flood gates and inner wall at the entrance to the
pump cubicles. The original licensing basis PMF height of 310 was analyzed to have no
impact on safety related equipment in the ISPH due to the elevated location of the SSCs
susceptible to the flood water on the 308 elevation. However, the revised PMF
elevation of 313.3 was determined to impact safety related electrical equipment and
safety related river water system operability. In the fall of 2011, Exelon performed
modifications to the ISPH flood barriers and inspected the remaining flood barriers to
confirm the system remained operable at the revised height of 313.3.
In July 2012, Exelon performed flooding walkdowns of TMI Unit 1 in response to NRC
Recommendation 2.3 Flooding Enclosure 4 of the March 12, 2012 10 CFR 50.54(f) letter
(ADAMS ML12053A340) in order to verify that plant features credited in the current
licensing basis (CLB) for protection and mitigation from external flood events are
available, functional, and properly maintained. Exelon conducted the walkdowns in
accordance with NEI 12-07, Rev. 0-A, Guidelines for Performing Verification
Walkdowns of Plant Flood Protection Features.
In accordance with TI-187, Inspection of Near-Term Task Force Recommendation 2.3
Flooding Walkdowns, the NRC inspectors performed an inspection to verify that the
licensees external flood protection walkdown activities were conducted using NEI 12-07,
which included inspector walkdowns of the ISPH flood protection features. As a result
of the flood walkdowns, on July 24, 2012, the inspectors identified 13 unsealed
penetrations in the floor of the ISPH. The penetrations were a direct bypass of the flood
barrier (floor) which allowed river water access during a PMF to enter the protected
pump cubicle area. Exelon entered the deficiency in the corrective action program under
IR 1392609 and determined that the in-leakage, as a result of the penetrations, would be
approximately 86 gpm. Exelon determined that the current proceduralized compen-
satory actions to address potential unidentified in-leakage into the pump cubicles would
support operability. Specifically, two safety-related powered sump pumps are pre-
staged in the ISPH during a PMF and the combined pump capacity is 100 gpm
therefore; operations determined the flood barrier remained operable but degraded.
Enclosure
30
However, Exelon identified additional deficiencies related to the quantity, location and
configuration of the pre-staged equipment used to mitigate in-leakage into the ISPH
pump cubicles during their flood walkdowns in accordance with NEI 12-07. Specifically,
on July 24, 2012 Exelon identified that the required quantity of drain line plugs and one
of the ISPH sump pumps, FP-P-4B, were not stored in the designated storage location.
TMI entered the issue in IR 1392569 and performed prompt corrective actions to
replace/relocate the support equipment. Additionally, on August 29, 2012, Exelon
identified that the discharge hose piping of the pre-staged sump pump was the incorrect
size and could not be assembled and used as staged. TMI entered this deficiency into
the CAP as IR 1406603. The proper discharge pipe was received onsite the following
day. The combination of the above deficiencies further challenged the support
equipment and compensatory actions capability to mitigate the PMF floodwater in-
leakage through the floor flood barrier. The deficiencies were entered into the CAP and
permanent corrective actions were taken to seal the penetrations and fully restore the
support equipment capability for flood protection.
Analysis. The inspectors determined that the failure to identify and correct 13 unsealed
penetrations through the ISPH flood barrier and multiple deficiencies that challenged the
fulfillment of ISPH support equipment used to maintain the integrity of the licensing basis
flood barrier was a performance deficiency that was within Exelons ability to foresee and
correct. The finding was determined to be more than minor because it is associated with
the protection against external factors attribute of the mitigating systems cornerstone to
ensure the availability, reliability, and capability of systems that respond to initiating
events to prevent undesirable consequences. Specifically, Exelon did not identify and
correct 13 unsealed penetrations in a licensing basis external flood barrier and its
associated support equipment deficiencies such that the barrier is fully capable of
maintaining the ISPH free of flood water. The inspectors evaluated the finding in
accordance with IMC 0609, Appendix A, Exhibit 2 - Mitigating Systems Screening
Questions and Exhibit 4 - External Events Screening Questions and determined that
a detailed risk evaluation was required based upon the assumed complete failure of the
IPSH flood barrier would degrade two trains of decay heat removal. The regional senior
risk analyst (SRA) performed a detailed risk evaluation using the TMI SPAR model
(version 8.18) in SAPHIRE 8 and determined the finding to be of very low safety
significance (Green). The plant is assumed to be shutdown and on decay heat in
accordance with station flood level response. Additionally, off-site power is assumed to
be lost as a result of flooding of the switchyard. An event was created in the TMI SPAR
model to represent the flooding condition that would challenge the flood barriers. The
necessity of safety-related powered sump pumps to compensate for the in-leakage was
modeled as a support dependency to the decay heat removal (DHR) system. The
resulting change in core damage probability was less than 1E-7. The dominant
sequence was a flooding event that challenged the DHR system and emergency
feedwater in addition to the inability to implement extensive flood mitigation strategies.
This finding has a cross-cutting aspect in the area of Problem Identification and
Resolution, Corrective Action Program, because Exelon failed to identify the unsealed
penetrations through the flood barrier and multiple deficiencies in supporting equipment
in a timely manner commensurate with its safety significance. P.1(a)
Enforcement. 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, require in part,
that measures be established to assure that conditions adverse to quality, such as
failure, malfunctions, deficiencies, deviations, defective material and equipment, and
non-conformances are promptly identified and corrected. Contrary to the above, Exelon
Enclosure
31
failed to identify and correct 13 unsealed penetrations through the ISPH flood barrier and
multiple deficiencies that challenged the fulfillment of ISPH support equipment used to
maintain the integrity of the licensing basis flood barrier. Because this violation was of
very low safety significance and was entered into Exelons corrective action program,
this violation is being treated as an NCV, consistent with section 2.3.2 of the NRC
Enforcement Policy. (NCV 05000289/2012005-02, Failure to Identify and Correct
Licensing Basis Flood Barrier and Support Equipment Deficiencies in Intake
Screen and Pump House)
.2 Failure to Identify and Correct Missing Electrical Conduit Flood Seals in the Air Intake
Tunnel
Introduction. The inspectors identified an apparent violation (AV) of 10 CFR 50,
Appendix B, Criterion XVI, Corrective Actions, during the TI-187 flooding walkdowns for
Exelons failure to identify and correct an external flood barrier deficiency. Specifically,
Exelon failed to identify and correct, during external flood barrier walkdowns, that
electrical cable conduits were not flood sealed in the Air Intake Tunnel (AIT), as
designed, to maintain the integrity of the external flood barrier. The deficiency was
entered into Exelons CAP and prompt corrective actions were taken to seal the
electrical conduits and restore the external flood barrier integrity.
Description. In July and August 2012, Exelon performed flooding walkdowns of TMI in
response to NRC Recommendation 2.3 Flooding Enclosure 4 of the March 12, 2012
10 CFR 50.54(f) letter (ADAMS ML12053A340) in order to verify that plant features
credited in the CLB for protection and mitigation from external flood events are available,
functional, and properly maintained. Exelon conducted the walkdowns in accordance
with (IAW) NEI 12-07, Rev. 0-A, Guidelines for Performing Verification Walkdowns of
Plant Flood Protection Features.
In accordance with TI-187, Inspection of Near-Term Task Force Recommendation 2.3
Flooding Walkdowns, NRC inspectors performed an inspection to verify that the
licensees external flood protection walkdown activities were conducted IAW NEI 12-07.
In August 2012, the inspectors accompanied the licensee during walkdowns of the AIT
flood protection features. The AIT is a safety-related structure that is primarily below
grade that provides an outside air source for the ventilation system of safety-related
structures. Also, both safety and non-safety related cable conduits are routed
underground from yard cable vaults through the AIT, beginning with a Crouse-Hinds
coupling and ultimately terminate in the Auxiliary/Fuel Handling Building (Aux/FHB)
where the cables exit the conduits through foam fire seals. The Crouse-Hinds coupling
is attached to the solid cable conduit just after it enters the AIT and would be injected
with flood sealant during construction to provide a design/licensing basis flood barrier
function.
On August 02, 2012, during the TI-187 inspector-accompanied walkdown of the AIT, the
inspectors identified numerous Crouse-Hinds couplings with visible external degradation
due to being exposed to a wet environment. In addition, the inspectors identified that the
couplings were missing plugs in the bottom drain ports and visually observed exposed
cables from the open port. Subsequently, the inspectors informed Exelon that there was
reasonable doubt of the existence of the flood seals based on the inspectors assess-
ment of the Crouse-Hinds coupling as-found condition and observing the cables. The
licensee took prompt actions to address the concern and confirmed, by visual and
boroscopic inspections through the drain ports, that the flood sealant material was not
Enclosure
32
present in the Crouse-Hinds couplings or in the conduit. This finding is considered NRC-
identified based upon the NRC value added during the AIT walkdown in that the
inspectors concerns regarding the reasonable doubt of the seal integrity lead to the
licensees discovery of the missing flood barrier sealant. The condition was entered into
the CAP (IR 1399510) and an extent of condition review identified a total of 43 Crouse-
Hinds Couplings had deficient external flood barriers. This degraded condition was
reported to the NRC in EN 48179 on August 10, 2012. Specifically, during a PMF
without flood seal in the Crouse-Hinds couplings, flood water would become entrained in
the cable conduits and flow through the AIT and ultimately into the Aux/FHB. The
termination location of the cable conduits in the Aux/FHB would allow the flood water to
impact safety-related equipment, most importantly decay heat removal. Exelon
implemented prompt interim compensatory actions to restore operability of the flood
barrier which included staging sand and large earth-moving equipment which would be
used to fill the yard cable vaults containing the entrance to the aforementioned cable
conduits and limit flood water leakage in order to maintain the decay heat removal
function during a PMF.
Upon further review, the inspectors recognized that Exelon had prior opportunities to
identify the degraded flood seal condition during previous focused flood barrier
walkdowns. Specifically, in 2010, Exelon performed a comprehensive review and
inspection of all, TMI Unit 1, external flood barriers, which included the AIT. Exelon
conducted the review in response to an NRC inspection (see URI 05-289/2010009-04,
ADAMS ML102530521 and NCV 05-289/2010005-02, ADAMS ML110340532) and to
create a complete documented list of the credited external flood barriers and understand
the condition of those barriers. During that review, Exelon identified that two pathways
were not adequately sealed and would allow water to infiltrate the AIT, as reported in EN 46194, dated August 21, 2010. Exelon took immediate corrective actions as well as
conducted a thorough extent of condition evaluation of flood boundaries in TMI Unit 1,
including the AIT, to ensure the flood barrier was capable of performing its design basis
function (IR 1104245). During the initial review, as well as the subsequent extent of
condition, the licensee did not question the condition of the Crouse-Hinds couplings
degraded condition. Exelon did not document significant issues regarding these
couplings in the CAP or work order entries. The inspectors identified, during interviews,
that engineering staff had relied on design and construction documentation to ensure the
external flood barrier existed in the Crouse-Hinds coupling and that the external/internal
condition of the coupling was not fully assessed. In addition, during the TI-187
walkdowns, the inspectors identified that the licensee did not fully assess the as-found
condition and that the inspectors concerns regarding the material condition of the
Crouse Hinds coupling and reasonable doubt of the seal integrity lead to the discovery
that the flood boundary was not installed. The inspectors concluded that Exelon had
reasonable opportunities to identify the deficiency in 2010 during the comprehensive and
extent of condition reviews as well as during the NEI 12-07 flood walkdowns in the
summer of 2012.
The finding does not present an immediate safety concern because Exelon implemented
permanent corrective actions to seal the conduits identified in the AIT. Specifically, the
unsealed electrical conduits were sealed by the injection of a watertight qualified sealant
material into the associated cable conduits from the yard cable vaults. The sealant
material, as well as the underground concrete encased conduits, became the credited
external flood barrier and met the current licensing basis requirements. These actions
were completed in November 2012.
Enclosure
33
Analysis. The inspectors determined that the failure to identify and correct, during
external flood barrier walkdowns, that electrical cable conduits were not sealed in the
AIT, as designed, to maintain the integrity of the external flood barrier was a perfor-
mance deficiency that was within Exelons ability to foresee and correct. The finding
was determined to be more than minor because it is associated with the protection
against external factors attribute of the mitigating systems cornerstone to ensure the
availability, reliability, and capability of systems that respond to initiating events to
prevent undesirable consequences. Specifically, Exelon failed, during multiple focused
walkdowns, to identify the degraded external flood barrier in the Crouse-Hinds couplings
in the AIT that challenged the external flood barrier operability. The safety significance
of the degraded external flood barrier is to be determined and cannot accurately be
calculated until additional testing and analysis of the as-found configuration is complete.
Specifically, Exelon is performing additional testing on the capability of as-found foam
fire sealant material, present in the conduits at the AIT/Aux Building interface, to mitigate
flood water entry into the safety-related structures. These results will be an input into the
NRCs safety significance determination and the licensees flood mitigation aggregate
impact review.
This finding has a cross-cutting aspect in the area of Problem Identification and
Resolution, Corrective Action Program, because Exelon failed to review the external
flood barrier with a low threshold for identifying issues which resulted in the failure to
identify the unsealed electrical conduits in the AIT in a timely manner commensurate
with its safety significance. P.1(a)
Enforcement. 10 CFR 50, Appendix B, Criterion XVI, Corrective Actions, require in part,
that measures be established to assure that conditions adverse to quality, such as
failure, malfunctions, deficiencies, deviations, defective material and equipment, and
non-conformances are promptly identified and corrected. Contrary to the above, Exelon
failed to identify, during external flood barrier walkdowns, that electrical cable conduits
were not sealed in the Air Intake Tunnel (AIT), as designed, to maintain the integrity of
the external flood barrier. Exelon entered the issues into their corrective action program
(IR 1399510). These issues are being characterized as an apparent violation in
accordance with the NRC's Enforcement Policy, and its final significance will be
dispositioned in separate future correspondence. (AV 05000289/2012005-03, Failure to
Identify and Correct Missing Electrical Conduit Flood Seals in the Air Intake
Tunnel)
.3 Temporary Instruction 2515/188, Inspection of Near-Term Task Force Recommendation
2.3 Seismic Walkdowns (2515/188 - 1 sample)
a. Inspection Scope
The inspectors accompanied the licensee on their seismic walkdowns of:
Control Tower, 380 elev. on August 14, 2012
Fuel handling building, 305 elev. and spent fuel pool area on August 15, 2012
Auxiliary building, 281 elev. on August 15, 2012
Control Tower, 322 and 338, and intake screen / pump house on August 16, 2012
Electrical cabinets in control tower at various elevations on November 11, 2012
SWEL items observed included B emergency ventilation fan (AH-E-18B), spent fuel
valves 4, 5, 6, 35, 37 and the B spent fuel pool cooling pump. Other items include the
1B inverters, 4160V switchgear, engineering safeguards acculation cabinets, heat sink
Enclosure
34
protection system cabinets, reactor trip breaker control centers, B reactor river pump
and strainer, B nuclear river pump, and B decay heat river pump.
The inspectors verified that the licensee confirmed that the following seismic features
associated with SWEL items inspected were free of potential adverse seismic
conditions:
Anchorage was free of bent, broken, missing or loose hardware
Anchorage was free of corrosion that is more than mild surface oxidation
Anchorage was free of visible cracks in the concrete near the anchors
Anchorage configuration was consistent with plant documentation.
SSCs will not be damaged from impact by nearby equipment or structures.
Overhead equipment, distribution systems, ceiling tiles and lighting, and masonry
block walls are secure and not likely to collapse onto the equipment.
Attached lines have adequate flexibility to avoid damage.
The area appears to be free of potentially adverse seismic interactions that could
cause flooding or spray in the area.
The area appears to be free of potentially adverse seismic interactions that could
cause a fire in the area.
The area appears to be free of potentially adverse seismic interactions associated
with housekeeping practices, storage of portable equipment, and temporary
installations (e.g., scaffolding, lead shielding).
The inspectors independently performed their walkdown and verified that the following
SSCs were free of potential adverse seismic conditions:
B Emergency Diesel Generator fuel oil day tank and air reservoirs on August 16,
2012
Motor-driven Emergency feedwater pumps on August 20, 2012
RC-23 hydraulic snubber (and associated attachments) to the pressurizer spray line
in the A D-ring in reactor building on August 22, 2012
Pressurizer attachments in the A D-ring in reactor building on August 25, 2012
Observations made during the walkdown that could not be determined to be acceptable
were entered into the licensees corrective action program for evaluation.
Additionally, inspectors verified that items that could allow the spent fuel pool to drain
down rapidly were added to the SWEL and these items were walked down by Exelon.
b. Findings
No findings were identified
.4 Correction to Previous Report
In report 05000289/2012004 the cross-cutting aspect description of NCV 2012004-01
in Section 1R05 incorrectly stated Human Performance, Resources. The correct
description is Human Performance, Work Control, that corresponds to the documented
MC 0310 cross-cutting aspect of H.3(b). There is no change in the documented cross-
cutting aspect of the finding.
Enclosure
35
4OA6 Meetings, Including Exit
USNRC Chairman MacFarlane visit to Three Mile Island
On November 2, 2012, Chairman Macfarlane, accompanied by UN & IAEA Ambassador
Macmanus and their staff and Mr. W. Dean, NRC Region I Regional Administrator,
toured Three Mile Island Unit 1 and Three Mile Island Unit 2 control room and discussed
station performance with Mr. R. Libra, Site Vice President, and other senior members of
Exelon.
Annual PI&R Sample: Fire Suppression Spray Nozzle Blockage Operating Experience
Evaluation
On December 13, 2012, the results of this inspection were discussed with Mr. Joe
Dullinger, Director, Site Engineering, and other members of the licensee's staff.
Closure of URI 05000289/2011005-03, Adequacy of Seismic Gap Flood Seal
On December 14, 2012, inspectors presented a summary of the inspection results to Mr.
David Atherholt, TMI-1 Regulatory Assurance Manager, Mr. John Piazza, TMI-1 Design
Engineering Manager and other members of the engineering staff.
Quarterly Inspection Report Exit
On January 25, 2013, the inspectors presented the inspection results to Mr. Mark
Newcomer, TMI Plant Manager, and other members of the TMI staff. The inspectors
verified that no proprietary information was retained by the inspectors or documented in
this report.
ATTACHMENT: SUPPLEMENTARY INFORMATION
Enclosure
A-1
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
D. Atherholt Manager, Regulatory Assurance
T. Alvey Manager, Chemistry, Environmental, & Radwaste
J. Bare Systems Engineer, Ventilation
J. Baron Chemistry Technician
J. Bomgardner Chemistry Technician
F. Brown Work Control Supervisor
J. Dullinger Director, Site Engineering
J. Cavanaugh Engineering
K. Coughlin Senior Reactor Operator
S. Cvijic Chemistry
D. Divittore Manager, Site Radiation Protection
M. Fitzwater Senior Regulatory Assurance Engineer
T. Flemming System Engineer
T. Hanlon Senior Instrument Chemist
M. Harrison System Engineering Supervisor
M. Jewell Fire Protection System Engineer
A. Krause Manager, Balance of Plant Engineering
R. Libra Site Vice President
G. McCarty Supervisor, Radiation Protection
W. McSorley Flood Protection Engineer
J. Morrissey I&C Supervisor
M. Myers Systems Engineer, Radiation Monitoring
R. Myers Fire Marshall
M Newcomer Plant Manager
D. Oshall Senior Reactor Operator
J. Piazza Senior Manager, Design Engineering
J. Popielarski Work Management Director
T. Roberts Manager, Radiological Engineering
C. Six Operations Superintendent
C. Smith Manager, Operations Services
M. Sweigart Chemistry Laboratory Supervisor
S. Taylor Fire Protection Program Engineer
P. Wagner Supervisor, Electrical Maintenance
L. Weber Environmental Chemist
M. Willenbecher Work Week Manager
Other
D. Dyckman Nuclear Safety Specialist, Pennsylvania Department of Environmental
Protection, Bureau of Radiation Protection
M. Miller Environmental Technician - Normandeau Associates
Attachment
A-2
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
05000289/2012005-01 NCV Adequacy of Seismic Gap Flood Seal (Section 4OA2.6)05000289/2012005-02 NCV Failure to Identify and Correct Licensing Basis Flood
Barrier and Support Equipment Deficiencies in Intake
Screen and Pump House (Section 4OA5.2.b.1)
Opened
05000289/2012005-03 AV Failure to Identify and Correct Missing Electrical Conduit
Flood Seals in the Air Intake Tunnel (Section 4OA5.2.b.2)
Closed
05000289/2011005-03 URI Adequacy of Seismic Gap Flood Seal (Section 4OA2.6)
05000289/2011-001-00 LER Unanalyzed Condition Affecting Probable Maximum Flood
Level (Section 4OA3.1)
05000289/2012-003-00 LER Pressurizer Heater Bundle Leak (Section 4OA3.2)
05000289/2012-004-00 LER Reactor Trip During Downpower Due to Condensate
Booster Pump Trip (Section 4OA3.3)
05000289/2012-005-00 LER Reactor Trip due to RC-P-1C Trip (Section 4OA3.4)
2515/185, Rev. 1 TI Follow-up on the Industrys Groundwater Protection
Initiative (Section 4OA5.1)
2515/187 TI Inspection of Near-Term Task Force Recommendation 2.3
Flooding Walkdowns (Section 4OA5.2)
2515/188 TI Inspection of Near-Term Task Force Recommendation 2.3
Seismic Walkdowns (Section 4OA5.3)
LIST OF DOCUMENTS REVIEWED
Section 1R01: Adverse Weather Protection
Procedures
OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Rev. 8
OP-TM-739-500, Response to Loss of 13.2kv Off-Site Power, Rev. 0
OP-TM-AOP-004, Tornado/High Winds, Rev. 3
SY-AA-101-146, Severe Weather Preparation and Response, Rev. 0
WC-AA-107, Seasonal Readiness, Rev. 10
Attachment
A-3
Other
Hurricane Sandy Plant Status Matrix, 10/29/12
Hurricane Sandy Plant Status Matrix, 10/30/12
IRs 1432689 1432853 1432910 1432943 1432947 1433075
1433219 1433198 1433221 1433227 1433246 1433422
1402688
Section 1R04: Equipment Alignment
Procedures
1104-6, Spent Fuel Cooling System, Rev. 45
1104-29C, Spent Fuel Cleanup Processes, Rev. 35
1104-30, Nuclear River Water, Rev. 72
OP-TM-212-000, Decay Heat Removal System, Rev. 16
OP-TM-411-211, IST of MS-V-2A and MS-V-2B, Rev. 002
OP-TM-541-000, Primary Component Cooling, Rev. 16
OP-TM-541-461, IC & NS Temperature Control, Rev. 6
OP-TM-543-000, Decay Heat Closed System, Rev. 8
OP-TM-543-461, Makeup to DC-T-1A, Rev. 2
ST1303-4.13, RB Emergency Cooling and Isolation System Analog Test, Rev. 045
Drawings
302-202, Nuclear Services River Water System, Rev. 78
302-630, Spent Fuel Cooling System Flow Diagram, Rev. 32
302-640, Decay heat Removal Flow Diagram, Rev. 83
302-641, Decay Heat Pumps 1A/B Aux Systems Flow Diagram, Rev. 6
302-645, Decay Heat Closed Cycle Cooling Water Flow Diagram, Rev. 39
Other
IRs 1430534 1447940 1447801 1447752 1447490 1448256
1448185 1448096
TMI-1/FSAR 9.4 Spent Fuel Cooling System, Update-18, dated 4/2006
Section 1R05: Fire Protection
Procedures
MA-MA-796-024-1001, Scaffolding Criteria for the Mid-Atlantic Stations, Rev. 8
OP-TM-201-009, Control of Transient Combustible Material, Rev. 11
OP-TM-861-910, Emergency Ventilation of EG-Y-1A Room, Rev. 1
Other
Fire Hazard Analysis Report, Rev. 23
Three Mile Island Nuclear Station, Pre-Fire Plan, Rev. 3
WO R2163835 R2116796 R2163596
Section 1R07: Heat Sink Performance
Procedures
1107-9, SBO Diesel Generator, Rev. 69
M-164, Station Blackout (SBO) Diesel Generator Major Inspection (Mechanical), Rev. 18
Attachment
A-4
Other
WOs R2163624 R2205534 R2073309 R2117165
Section 1R12: Maintenance Effectiveness
IRs 1442224 1403278 1456412
Section 1R13: Maintenance Risk
Procedures
WC-AA-104, Integrated Risk Management, Rev. 19
Other
IRs 1438881, 1439670, 1440244
Tech Spec 3.5.7 and 3.3.1.1
Three Mile Island MA Plants Plan of the Day, 10/18/2012
TMI-1 Shirt Operation Logs, 11/12/12 and 11/13/12
Work Order #R2176705, 03, Integrated Risk Screening for MU-P-1B Outage
WorkWeek 1243 Rev. 2
Work Week 1246 Rev. 1, Bravo Workweek
Section 1R15: Operability Evaluations
Procedures
OP-AA-108-115, Operability Determinations (CM-1), Rev. 11
Other
NRC Part 21 documented in EN 48359 on September 28, 2012
IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid
Batteries for Stationary Applications, 450-2010
IRs: 1428726, 1429564, 1432623
System Design Basis Document for Flood Protection Systems, Rev. 2
Section IR19: Post Maintenance Testing
Procedures
1107-9, SBO Diesel Generator, Rev. 69
1302-5.18A, HPI/LPI Flow Channel Calibration, Rev. 38
1302-5.31D, 4160 V 1E Bus Loss of Voltage/Degraded Grid Timing Relay Calibration & Logic
Check, Rev. 20A
E-135, SBO Diesel Batteries Inspection, Rev. 9
OP-TM-211-000, Makeup and Purification System, Rev. 24
Other
WO R2130741 R2189788
IRs 1426488 1426591 1426683 1426958 1427040 1427062
1427387 1427714 1427761 1428198 1428302 1428433
1428591 1428929 1428979 1428989 1429096 1429108
1429151 1429178 1429182 1429276 1429302 1429432
1429482 1429527 1429564 1429565 1429567 1429704
1429967 1430324 1430327 1432623 1438142
Attachment
A-5
Section IR22: Surveillance Testing
Procedures
1302-5.18, HPI/LPI Flow Channel Calibration, Rev. 38a
OP-TM-211, Makeup and Purification System, Rev. 24
OP-TM-214-201, IST of BS-P-1A and Valves, Rev. 11
OP-TM-EOP-010, Emergency Procedure Rules Guides and Graphs, Rev. 16
OP-TM-EOP-0101, Emergency Procedure Rules Guides and Graphs Basis Document, Rev. 7
Surveillance Frequency Control Program, TMI-1, Rev. 1
Drawings
302-661, Make-up & Purification Flow Diagram, Rev. 60
Other
WO R2206745 R2163732
AR A2186859
Work Week Plan 1245 A Train Work Week, Rev. 0
C-1101-864-E420-001, SBO Battery and Charger Sizing and Hydrogen Generation Calculation,
Rev. 0A
Section 1EP4: Emergency Action Level and Emergency Plan Changes
EP-AA-1000, Standardized Radiological Emergency Plan, Revision 21
EP-AA-112, Emergency Response Organization (ERO) Emergency Response Facility (ERF)
Activation and Operation, Revision 16
Section 2RS01: Radiological Hazard Assessment and Exposure Controls
Procedures
RP-AA-203-1001 Personnel Exposure Investigations
RP-AA-210 Dosimetry Issue, Usage, and Control
RP-AA-401 Operational ALARA Planning and Controls
RP-AA-403 Administration of the Radiation Work Permit Program
RP-AA-403-1001 Radiation Work Permit Processing
RP-AA-460 Controls for High and Locked High Radiation Areas
RP-TM-460-1008 Locked High Radiation Area Key Controls
Issue Reports
1438379, 1438379, 1435432, 1429605, 1432989, 1443912
Personnel Exposure Investigations12-023, 12-0414,12-059
Miscellaneous Reports
Electronic Dose and Dose Rate Alarm Report for 2012
Performance Indicator Monthly Reports and associated Issue Reports
Attachment
A-6
Section 2RS6 Radioactive Gaseous and Liquid Effluent Treatment & TI-2515/185
Procedures
EN-AA-407 Response to Inadvertent Releases of Licensed Materials to
Groundwater, Surface Water or Soil
EN-AA-408 Radiological Groundwater Protection Program
EN-AA-408-4000 Radiological Groundwater Protection Program Implementation
EN-TM-408-4160 RGPP Reference Material for Three Mile Island
CY-AA-130-201 Radiochemistry Quality Control
CY-AA-130-320 Packard 2900TR/3100TR Liquid Scintillation Counter
CY-TM-170-203 Unit Vent (RM-A-8 and RM-A-9) Sampling
CY-TM-170-300 Offsite Dose Calculation Manual
CY-TM-170-301 Liquid and Gaseous Monthly Cumulative Dose Contributions and
Projections
CY-TM-170-3003 Waste Evaporator Condensate Storage Tank Compositing
CP-N-1982 Operation of the Tri-Carb 2100 TR Spectrophotometer
CP-N-1853 Sampling of Waste Gas Decay Tanks
6610-ADM-4250.11 Releasing Radioactive Gaseous Effluents - Waste Gas Tanks
A/B/C
OP-1101-2.1 Radiation Monitoring System Setpoints
OP-1104-27 Waste Disposal - Gaseous
OP-TM-232-551 Liquid Release of A WECST with WDL-P-14A
OP-TM-232-554 Liquid Release of B WECST with WDL-P-14B
OP-TM-823-406 RB Purge - Containment Closed
RP-AA-228 10 CFR 50.75(g) and 10 CFR 72.30(d) Documentation
Requirements
6610-ADM-4250.01 Releasing Radioactive Liquid Waste
EML Collection of Groundwater Samples for Radiological Analysis
Issue Reports
1229945, 924237, 1081998, 1041403, 1394915, 1436848, 1413406, 1329284, 1282812,
1231780
Nuclear Oversight Performance Assessment (PA) Reports
Audit NOSA-TMI-12-04 (AR 1310431), Chemistry, Radwaste, Effluent, and Environmental
Monitoring Audit June 2012
Effluent Discharge Permits:
Gaseous
G-2012-08610, Reactor Trip Secondary Steam Release - Non-Routine
G-2012-00027, Waste Gas Decay Tank - A
G-2012-10026, Waste Gas Decay Tank - C
G-2012-08020, Reactor Building Purge
G-2012-12028, Waste Gas Decay Tank - B
Liquid
L-2012-11046, WDL-T-11B
L-2012-11045, WDL-T-11A
L-2012-11044, WDL-T-11B
Attachment
A-7
Effluent Radiation Monitor Calibration Procedure Records
SP-1302-3.1, R.M.S. Calibration
RM-A-8G, Auxiliary Building/Fuel Handling Building - Particulate/Iodine Channels
RM-A-9G, Reactor Building Purge Exhaust - Particulate/Iodine Channels
SP-1302-3.1A, Victoreen Effluent Gas Channel Calibration
RM-A-8G, Auxiliary Building/Fuel Handling Building - Noble Gas Channel
RM-A-9G, Reactor Building Purge Exhaust - Noble Gas Channel
Gaseous HEPA/Charcoal Filters Test Records
U-36 Ventilation Filter DOP and Halide Testing
SP-1303-11.56 Fuel Handling Building ESF Air Treatment System Air Filter Testing
Liquid Monitor Functional Interlock Test Records
SP 1303-4.10 RM-L-12 Interlock Test
SP 1303-4.15B Radiation Monitoring System Operability Test Liquid Channel RM-L-6
IC -174 Radiation Monitoring System Channel Test Liquid Channels RM-L-1Hi,
1Lo, 2,3,4,5,7,9
Miscellaneous Reports
Groundwater Sampling Results for October 2012
Laboratory Cross Check Results for 1st, 2nd, and 3rd quarters 2012 and 4th quarter 2011
2011 Annual Radioactive Effluent Release Report
2012 Land Use Census Report
System Health Report for Radiation Monitors- 4th quarter 2012
System Health Report for Aux/Fuel Handling Buildings - 4th quarter 2012
50.75 (g) Decommissioning Files
April-May 2012 RGPP Summary Monitoring Report (2ND Quarter 2012)
Performance Indicator Monthly Reports and associated Issue Reports
Section 4OA1: Performance Indicators
See Section 2RS01 and 2RS06 References
Section 4OA2: Identification and Resolution of Problems
Procedures
1104-45C, Fire Service Sprinkler System, Rev. 24
1104-45D, Fire Service Deluge System
1104-45E, Fire Service Pre-Action System
1104-45Q, TMI Outbuilding Fire Protection Systems, Rev. 19
1104-45R, Fire Service System Operations Surveillance, Rev. 56
1303-12.13, Fire System Flush 2 Drain - Deluge/Sprinkler Systems, Rev. 31
1303-12.16, Fire System Testing Air Tunnel Deluge Functional Test, Rev. 29
1303-12.17, Fire System Misc Deluge Function Test, Rev. 33
1303-12.18.1/2/3/4/5, Fire System Nozzle Flow Test (Exh 2, 3.4.1.7)
3303-A2, Fire Main Header Flush and Loop Test (Exh 2, 2.4.1.4, 2.4.1.7)
AP-1038, Administrative Controls - Fire Protection Program, Rev. 79
MA-TM-133-002, 50 Year Sample Testing of Fire Water System Sprinkler Heads, Rev. 0
MA-AA-716-008, Foreign Material Exclusion Program, Rev. 7
OP-AA-102-103-1001, Operator Burden and Plant Significant Decisions Impact Assessment
Program, Rev. 4
Attachment
A-8
OP-TM-226-901, Loss of All RCP Seal Cooling, Rev. 5
PLB-6-3, Diesel River Fire Pump Sprinkler, Rev. 121
Drawings
302-231, Fire Service Water Flow Diagram, Sheet 1, Rev. 109
302-231, Fire Service Water Flow Diagram, Sheet 2, Rev. 16
E-107-012, Architectural Special Area Plans, Sections, & Details, Rev. 5
Engineering Documents
Other
DC Cook 2 Licensee Event Report 1981-008, Fire Protection Spray Nozzle Blockage
DC Cook 2 Licensee Event Report 1981-009, Fire Protection Spray Nozzle Blockage
ECR TM 11-00426, Raise Level of External Flood Protection, Rev. 0
ECR 12-00160, RB Seismic Gap Flood Seal, Rev. 0
EGM-09-002, Enforcement Discretion for Fire Induced Circuit Faults, May 14, 2009
Exelon Nuclear Event Report LS-10-054, Clogging of the Uni 0 Over Lab Pre-action Spray
System
Fitzpatrick Licensee Event Report 1981-052, Fire Protection Spray Nozzle Blockage
NEI 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis, Rev 2, 3
NFPA 13A, Recommended Practice for the Inspection, Testing, and Maintenance of Sprinkler
Systems
NPB-92, BISCO Seal Test Equivalency for Use in Conduit Sealing, Rev. 1
NRC Event Notification 47237, Monticello Blockage of Intake Structure Sprinkler System
Regulatory Guide 1.189, Fire Protection for Nuclear Power Plants, Rev. 2
Root Cause Evaluation 01302334, Intake Structure Fire Sprinkler Piping Blockage
Technical Evaluation 1170013-06, Consequence of Inadequate Flood Deal in Reactor Building
Seismic Gap, Rev. 0
TMI Unit 1 Fire Hazards Analysis Report, Rev. 25
TQ-TM-106-MSO-C002, MSO Changes 2012, October 30, 2012
Maintenance Work Orders
R2063822 R2166971 R2171168
Issue Reports
0765796 1360221 1370566 1371055
1017441 1360224 1370608 1371056
1059605 1360225 1370618 1381850
1120517 1360230 1370667 1405549
1179612 1370504 1370837 1405553
1331081 1370545 1370839 1426736
1360162 1370558 1371044 1426736
1360216 1370561 1371048 1426736
Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion
IRs
1406234 1403278 0184753 0878425
1403366 1321322 0187903
NRC Inspection Reports
05-289/2011005, ADAMS ML12039A087
05-289/2012002, ADAMS ML12122A131
05-289/2012003, ADAMS ML12214A466
Attachment
A-9
Other
Apparent Cause Evaluation for IR 1406234
LER 50-289/2003-003-00, Reactor Coolant Pressure Boundary Leakage Due to Degradation of
an Alloy 600 Pressurizer Heater bundle Diaphragm Plate
Event Notification, 47294, September 26, 2011
Event Notification, 48220, August 22, 2012
Event Notification, 48221, August 22, 2012
MPR-3814, TMI RC-P-1C Pump Trip - Root Cause Investigation, dated October 11, 2012
PowerLabs Failure Analysis Report for Relay CO-P-2/52X5B, dated September 24, 2012
Root Cause Evaluation Report for IR 1403366
Root Cause Evaluation Report for IR 1416103
Section 4OA5 : Identification and Resolution of Problems
Procedures
MA-TM-122-901, Install U1 Flood Barriers, Rev. 2
NEI 12-07, Guidelines for Performing Verification Walkdowns of Plant Flood Protection
Features, Rev. 0-A
SDBD-T1-122, System Design Basis Document for Flood Protection Systems, Rev. 2
Drawings
4692-51-120-1-0, TMI-1 Emergency Ventilation Fan Mounting, Rev. 1
1E-122-01-1002, TMI Flood Barrier System, Control Building Details, Rev. 1
1E-122-01-1007, TMI Flood Barrier System Air Intake Tunnel, Rev. 1
1E-122-01-1005, TMI Flood Barrier System Auxiliary Building Details, Rev. 0
E-216-022, Electrical Manholes & Underground Ducts Aux Building to Screen House Area,
Rev. 17
1E-155-02-001, General Arrangement Control Room Tower, Rev. 12
D-215-162, Electrical Conduit and Cable Layouts Air Intake Tunnel, Rev. 22
E-107-012, Architectural Special Area Plans, Sections, & Details, Rev. 5
Engineering Documents
ECR TM 11-00426, Raise Level of External Flood Protection, Rev. 0
ECR 12-00160, RB Seismic Gap Flood Seal, Rev. 0
NPB-92, BISCO Seal Test Equivalency for Use in Conduit Sealing, Rev. 1
Seismic Walkdown Checklist for SWEL items
Seismic Walkdown Report - Stevenson & Associates 12Q0108.70-R-001, Rev. 1
Technical Evaluation 1170013-06, Consequence of Inadequate Flood Deal in Reactor Building
Seismic Gap, Rev. 0
Other
Electric Power Research Institute (EPRI) document 1025286 titled, Seismic Walkdown
Guidance, May 2012, (ADAMS Accession No. ML12164A181)
Electric Power Research Institute (EPRI) document 1025286 titled, Seismic Walkdown
Guidance, Final, June 2012
Flooding Walkdown Report, November 2, 2012
ECR 10-00545, Rev. 0, 1
ENs 46194 48179
IRs 1104245 1442527 1415285 1399510 1401686 1413215
1406827 1407003 1407060 1404291 1403814 1403177
1403172 1403154 1399136 1399702 1401842 1401487
1401589 1400966 1400309 1396910 1393442 1392609
1399630 1399143 1399702 1399510 1268247 1276881
1341027 1341537 1382505 1428726
Attachment
A-10
Operability Evaluation for AH-E-18B mounting (IR 1400723/1400762), dated September 13,
2012
Operability Evaluation for RC-23 hydraulic snubber (IR 1403542)
Scaffold Evaluation A2053402-01
LIST OF ACRONYMS
ADAMS Agencywide Documents and Management System
ALARA As Low As Reasonably Achievable
AH Air Handling
AV Apparent Violation
CFR Code of Federal Regulations
DRP Division of Reactor Projects
DRS Division of Reactor Safety
ECR Engineering Change Request
EDG Emergency Diesel Generator
EML Environmental Midwest Laboratory
EPIP Emergency Plan Implementing Procedures
ESF Engineered Safety Features
FS Fire Suppression
FSAR Final Safety Analysis Report
GPI Groundwater Protection Initiative
HEPA High Efficiency Particulate Air
IAEA International Atomic Energy Agency
IMC [NRC] Inspection Manual Chapter
IR Issue Report
LCO Limiting Condition for Operation
NRC Nuclear Regulatory Commission
NSIR [NRC] Office of Nuclear Security and Incident Response
OpE Operating Experience
ODCM Offsite Dose Calculation Manual
PADEP Pennsylvania Department of Environmental Protection
PEI Personnel Exposure Investigation
PMF Probable Maximum Flood
RB Reactor Building
RCA Radiological Controlled Area
RTV Room Temperature Vulcanization
RWP Radiation Work Permit
SDP Significance Determination Process
SER Safety Evaluation Report
SSC Structures, Systems and Components
ST Surveillance Test
TMI Three Mile Island, Unit 1
TS Technical Specifications
UFSAR Updated Final Safety Analysis Report
UN United Nations
URI Unresolved Item
WECST Waste Evaporator Condensate Storage Tank
WGDT Waste Gas Decay Tank
Attachment