ML15357A102

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Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051
ML15357A102
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 01/11/2016
From: John Hughey
Japan Lessons-Learned Division
To: Bryan Hanson
Exelon Nuclear
Hughey, John NRR/JLD 415-3204
References
EA-12-049, EA-12-051, TAC MF0803, TAC MF0866
Download: ML15357A102 (29)
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Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 January 11, 2016 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - REPORT FOR THE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT FUEL POOL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND EA-12-051 (TAC NOS. MF0803 AND MF0866)

Dear Mr. Hanson:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" and Order EA-12-051, "Issuance of Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML13059A299), Exelon Generation Company, LLC (Exelon, the licensee) submitted its OIP for Three Mile Island Nuclear Station, Unit 1 (TMI), in response to Order EA-12-049. By letters dated August 28, 2013, February 28, 2014, August 28, 2014, February 27, 2015, and August 28, 2015 (ADAMS Accession Nos. ML13241A035, ML14063A221, ML14241A251, ML15058A264, and ML15243A088, respectively), the licensee submitted its first five six-month updates to the OIP.

By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the TMI interim staff evaluation (ISE) (ADAMS Accession No. ML13225A552) and continues with in-office and onsite portions of this audit.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A540), the licensee submitted its OIP for TMI, in response to Order EA-12-051. By letter dated June 26, 2013 (ADAMS Accession No. ML13176A470), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated July 24, 2013, August 28, 2013, February 28, 2014, August 28, 2014, February 27, 2015, and August 28, 2015 (ADAMS Accession Nos.

ML13205A305, ML13241A036, ML14059A228, ML14241A300, ML15058A255, and ML15243A104, respectively), the licensee submitted its RAI responses and first five six-month updates to the OIP. The NRC staff's review to date led to the issuance of the TMI ISE and RAI

B. Hanson dated November 13, 2013 (ADAMS Accession No. ML13308C188). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audits allow the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted and updated information, audit information provided on ePortals, and preliminary Overall Program Documents/Final Integrated Plans while identifying additional information necessary for the licensee to supplement its plan and staff potential concerns.

In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at TMI from August 1O - 13, 2015, per the audit plan dated July 9, 2015 (ADAMS Accession No. ML15183A434). The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, review of staging and deployment of offsite equipment, and review of installation details for SFPI equipment.

The enclosed audit report provides a summary of the activities for the onsite audit portion.

Additionally, this report contains an attachment listing all open audit items currently under NRC staff review.

B. Hanson If you have any questions, please contact me at 301-415-3204 or by e-mail at John.Hughey@nrc.gov.

pv John D. Hughey, Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket No.: 50-289

Enclosure:

Audit report cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 AUDIT REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO ORDERS EA-12-049 AND EA-12-051 MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS AND RELIABLE SPENT FUEL POOL INSTRUMENTATION EXELON GENERATION COMPANY, LLC THREE MILE ISLAND NUCLEAR STATION, UNIT 1 DOCKET NO. 50-289 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" and Order EA-12-051, "Issuance of Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). Order EA-12-049 directs licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Order EA-12-051 requires, in part, that all operating reactor sites have a reliable means of remotely monitoring wide-range SFP levels to support effective prioritization of event mitigation and recovery actions in the event of a BDBEE. The orders require holders of operating reactor licenses and construction permits issued under Title 1O of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML13059A299), Exelon Generation Company, LLC (Exelon, the licensee) submitted its OIP for Three Mile Island Nuclear Station, Unit 1 (TMI), in response to Order EA-12-049. By letters dated August 28, 2013, February 28, 2014, August 28, 2014, February 27, 2015, and August 28, 2015 (ADAMS Accession Nos. ML13241A035, ML14063A221, ML14241A251, ML15058A264 and ML15243A088, respectively), the licensee submitted its first five six-month updates to the OIP.

By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all Enclosure

licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the TMI interim staff evaluation (ISE) (ADAMS Accession No. ML13225A552) and continues with in-office and onsite portions of this audit.

By letter dated February 28, 2013 (ADAMS Accession No. ML13063A540), the licensee submitted its OIP for TMI, in response to Order EA-12-051. By letter dated June 26, 2013 (ADAMS Accession No. ML13176A470), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated July 24, 2013, August 28, 2013, February 28, 2014, August 28, 2014, February 27, 2015, and August 28, 2015 (ADAMS Accession Nos.

ML13205A305, ML13241A036, ML14059A228, ML14241A300, ML15058A255, and ML15243A104, respectively), the licensee submitted its RAI responses and first five six-month updates to the OIP. The NRC staff's review to date led to the issuance of the TMI ISE and RAI dated November 13, 2013 (ADAMS Accession No. ML13308C188). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audits allow the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted and updated information, audit information provided on ePortals, and preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs) while identifying additional information necessary for the licensee to supplement its plan and address potential staff concerns.

In support of the ongoing audit of the licensee's OIPs, as supplemented, the NRC staff conducted an onsite audit at TMI from August 1O - 13, 2015, per the audit plan dated July 9, 2015 (ADAMS Accession No. ML15183A434). The purpose of the onsite portion of the audit was to provide the NRC staff the opportunity to continue the audit review and gain key insights most easily obtained at the plant as to whether the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. The onsite activities included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, review of staging and deployment of offsite equipment, and review of installation details for SFPI equipment.

Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs, as supplemented; the resulting site-specific OPDs/FIPs; and, as appropriate, other licensee submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a safety determination using the Nuclear Energy Institute (NEI) developed guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," issued in August 2012 (ADAMS Accession No. ML12242A378), as endorsed by NRC Japan Lessons-Learned Directorate (JLD) interim staff guidance (ISG) JLD-ISG-2012-01, "Compliance with Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"' (ADAMS Accession No. ML12229A174).

For Order EA-12-051, the staff will make a safety determination using the NEI developed guidance document NEI 12-02, Revision 1, "Industry Guidance for Compliance with NRC Order

EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"'

(ADAMS Accession No. ML12240A307), as endorsed, with exceptions and clarifications, by NRC ISG JLD-ISG-2012-03, "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation'" (ADAMS Accession No. ML12221A339), as providing one acceptable means of meeting the order requirements. Should the licensee propose an alternative strategy for compliance, additional staff review will be required to evaluate the alternative strategy in reference to the applicable order.

AUDIT ACTIVITIES The onsite audit was conducted at the TMI facility from August 10, 2015, through August 13, 2015. The NRC audit team staff was as follows:

Title Team Member Organization Team Lead/Project Manaoer John Huqhey NRR/JLD Technical Support - Electrical Matthew NRR/JLD McConnell Technical Support - Reactor Joshua Miller NRR/JLD Systems Technical Support - Reactor Laura Okruhlik NRR/JLD Systems Technical Support - SFPI Khoi Nguyen NRR/JLD Technical Support - Balance of Plant Michael Levine NRR/JLD Observer William Cook Reqion I/SRA Observer Justin Heinly TMI Resident Inspector The NRC staff executed the onsite portion of the audit per the three part approach discussed in the July 9, 2015, plan, to include conducting a tabletop discussion of the site's integrated mitigating strategies compliance program, a review of specific technical review items, and discussion of specific program topics. Activities that were planned to support the above included detailed analysis and calculation discussions, walk-throughs of strategies and equipment laydown, visualization of portable equipment storage and deployment, staging and deployment of offsite equipment, and physical sizing and placement of SFPI equipment.

AUDIT

SUMMARY

1.0 Entrance Meeting (August 10, 2015)

At the onsite audit entrance meeting, the NRC staff audit team introduced itself followed by introductions from the licensee's staff. The NRC audit team provided a brief overview of the audit's objectives and anticipated schedule.

2.0 Integrated Mitigating Strategies Compliance Program Overview Per the audit plan and as an introduction to the site's program, the licensee provided a presentation to the NRC audit team describing the site's strategies to meet the NRC orders. The licensee presented a review of its strategy to maintain core cooling,

containment, and SFP cooling in the event of a BDBEE, and the plant modifications being done in order to implement the strategies. Also reviewed were the design and location of the storage facilities for the FLEX equipment, the interface with the National Strategic Alliance for FLEX Emergency Response (SAFER), and the SFPI modification.

3.0 Onsite Audit Technical Discussion Topics Based on the audit plan, and with a particular emphasis on the Part 2, "Specific Technical Review Items," the NRC staff technical reviewers conducted interviews with licensee technical staff, site walk-downs, and detailed document review for the items listed in the plan. Results of these technical reviews and any additional review items needed from the licensee are documented in the audit item status table in Attachment 3, as discussed in the Conclusion Section below.

3.1 Reactor Systems Technical Discussions and Walk-Downs The NRC staff met with licensee staff to discuss the amount of leakage from the reactor coolant pump (RCP) seals and the timing of the injection of borated water into the reactor coolant system (RCS), and the availability of water sources. The NRC staff reviewed the analyses and flow calculations along with applicable procedures, including the plant parameters that will be monitored to indicate the potential for reactor core damage. On November 12, 2015, subsequent to the TMI onsite audit, the NRC issued an endorsement letter regarding the Flowserve technical white paper regarding RCP seal performance (ADAMS Accession No. ML 1531 OA094). The open items listed in Attachment 3 to this report include a confirmation from the licensee that the TMI RCP seal installations conform to the endorsed Flowserve white paper.

The NRC staff also walked down the licensee's strategies and reviewed plant procedures for implementing the core cooling and makeup strategies. The NRC staff also reviewed TMl's modeling of an extended loss of alternating current (ac) power (ELAP) event and its ability to mitigate the event, including the computer code used for the ELAP analysis and input parameters assumed to generate the results of the analysis. The NRC staff also reviewed TMl's strategy to rely on pre-installed equipment and piping to implement the RCS FLEX strategy. This approach is an alternative to the guidance in NEI 12-06 with regard to the use of portable equipment during Phase 2.

The NRC staff identified that the TMI ELAP RCS analysis relied on the main steam lines remaining intact following a BDBEE. However, the main steam lines are routed through the TMI turbine building (TB) which is not designed as a safety-related structure. The integrity of the main steam lines located in the TB must be demonstrated in order to validate the primary strategies developed to provide a BDBEE mitigation capability for TMI. Therefore, the NRC staff requested that TMI perform an analysis demonstrating that the main steam lines will maintain integrity following a BDBEE. This request is included in the list of audit open items in Attachment 3 to this report.

3.2 Electrical Technical Discussions and Walk-Downs The NRC staff reviewed the calculations regarding battery life and FLEX generating sizing in addition to walking down the procedure steps for electrical load shedding. The NRC staff also walked down the main control room, emergency feedwater room, atmospheric dump valve room and battery rooms to evaluate strategies for hydrogen control and temperature control due to heat generating electrical equipment. The NRC staff reviewed the isolation and interactions of electrical power sources regarding the protection of Class 1E equipment from faults in portable FLEX equipment and the design elements that ensure multiple electrical sources do not attempt to simultaneously power electrical buses. The NRC staff also walked down panels used for load shedding to evaluate feasibility and timing. Lastly, the NRC staff conducted a walk-through of portable FLEX diesel generator (DG) procedures, to include power pathways, areas where manual actions are required, and electrical isolation.

The NRC staff also reviewed TMl's strategy to rely on pre-installed equipment, including FLEX DGs, to implement the FLEX strategies. This approach is an alternative to the guidance in NEI 12-06 with regard to the use of portable equipment during Phase 2.

During the onsite audit, the NRC staff identified that the pre-installed FLEX DGs lacked an alternate electrical connection point as described in NEI 12-06, Rev. 0, Section 3.2.2.

The NRC staff is reviewing additional information provided by the licensee in the course of the on-going audit process regarding the provision of an alternate electrical connection point for the pre-installed FLEX DGs.

3.3 SFPI Technical Discussions and Walk-Downs The NRC staff walked down instrument, transmitter, electronics, and display locations for the SFP level instrumentation, along with the associated cable runs. In addition, the NRC staff noted that the licensee had completed design calculations and drawings detailing the installation of the SFPI components, as well as the associated calibration, maintenance, and test procedures.

3.4 FLEX Equipment Storage Configuration Discussion Areas and Walk-Downs The TMI, Unit 2 screen house is a tornado-hardened seismic Class I structure that is being modified to be used as the FLEX equipment storage facility (FSF). The FSF will store FLEX equipment including deployment trucks, debris removal equipment, long-term water supply portable pumps/hoses, and a FLEX portable DG/cables. The FLEX equipment stored in the FSF will be protected from seismic, tornado missile, high wind, and extreme temperature hazards. Procedures are being developed to direct pre-flood preparatory actions to move some equipment from the building if a flood is predicted in order to provide mitigation capability for more severe flood events.

The TMI FSF storage configuration conforms to the FLEX equipment storage guidance in NEI 12-06, Rev. 0, with one outstanding issue identified by the NRC staff related to the flood hazard. Per the TMI severe flood mitigation strategy, FLEX equipment will be relocated to the TMI training center located across the Susquehanna River from the TMI facility which may be isolated by the flood. However, no procedural guidance is in place

to pre-plan and direct the means by which the FLEX equipment will be relocated to the TMI site within the timeframe in which it may be needed. Therefore, the NRC staff has requested that TMI provide the procedure/administrative controls that will used to deploy FLEX equipment to the TMI site from the TMI training center. This request is included in the list of audit open items in Attachment 3 to this report.

Additional long-term water supply submersible FLEX pumps will be stored in the TMI, Unit 1, screen house, which is a tornado-hardened seismic Class I structure. The pumps will be deployed within the screen house if needed. This FLEX storage configuration conforms to the guidance in NEI 12-06, Rev. 0.

Per the TMI mitigating strategies, various FLEX equipment is pre-installed and stored in pre-existing structures. These strategies are proposed alternatives to the guidance of NEI 12-06, Rev. 0, regarding storage of FLEX equipment and the use of pre-installed equipment rather than portable equipment.

The FLEX N and N+ 1 RCS makeup pumps have electric motors and are pre-installed on the 322-foot elevation in the control building. While the pre-installation of the pumps and associated FLEX piping is an alternative to the guidance to use portable equipment, the control building is a seismic Class 1 structure and provides protection from all applicable hazards. Therefore, this configuration conforms to the FLEX equipment storage guidance in NEI 12-06, Rev. 0.

The N and N+ 1 FLEX once-through steam generator (OTSG) feedwater (FW) pumps and N and N+ 1 FLEX DGs with re-fillable diesel fuel tanks are pre-installed and stored in the TMI TB. The TB is a non-safety related structure and storage of the above FLEX equipment in the TB is an alternative to the guidance in NEI 12-06, Rev. 0. Therefore, Exelon must demonstrate that the TB structure will reasonably protect the pre-installed FLEX equipment from the effects of all BDBEEs applicable to the TMI site. The NRC staff requested that TMI perform an analysis demonstrating that the TB structure will reasonably protect the stored FLEX equipment and associated pre-installed piping and cables following a BDBEE and remain safely accessible to TMI personnel.

The TMI TB is also credited as the protected location for the diesel fuel re-fill connection piping used to re-supply the FLEX DG fuel tanks located in the same area as the DGs.

Therefore, the TB structural analysis must also address the protection and accessibility of the diesel fuel re-fill piping connection and hose deployment paths to the FLEX DG fuel tanks.

The request for analyses confirming the protection and accessibility of FLEX equipment in the TMI TB and associated deployment paths, including the diesel fuel re-supply piping connection and hoses, is included in the list of audit open items in Attachment 3 to this report.

3.5 Other Technical Discussion Areas and Walk-Downs

a. The NRG staff reviewed the licensee's plans to ensure adequate communications, lighting, personnel access, and equipment access, to successfully implement the strategies. The staff interviewed plant personnel responsible for these areas, and observed lighting and communication needs during plant walkdowns.
b. The NRG staff reviewed Revision 2 of the TMI SAFER Response Plan dated August 6, 2015. The initial fly or drive decision checklist, drive times, route options and helicopter company contact information are provided in Chapter 4 of the plan. The SAFER equipment staging areas and locations were noted as being documented in Appendix SC of the plan. Chapter 6 contains the site interface procedure and Chapter 7 provides the Phase 3 equipment list.
c. The NRG staff walked down the FLEX strategies for core cooling, RCS inventory, SFP makeup and FW flow to the OTSGs. The TMI FLEX strategy utilizes pre-installed FLEX pumps and piping as an alternative to the guidance in NEI 12-06, Rev. 0. During the onsite audit, the NRG staff identified that FLEX flowpaths lacked diversity as described in NEI 12-06, Rev. 0, Section 3.2.2 and Table D-1. The NRG staff is reviewing additional information provided by the licensee in the course of the on-going audit process regarding the establishment of diverse FLEX connection points and flowpaths.
d. During the onsite audit the NRG staff reviewed the reasonable protection provisions for FLEX water sources, including the condensate storage tanks (CSTs}. The licensee is preparing additional analyses to confirm that the CSTs are reasonably protected from all BDBEE hazards as described in Attachment 3 to this report.
e. The NRG staff walked down the licensee's strategy for providing forced, once-through ventilation to ensure reliability and personnel habitability for the FLEX equipment that is pre-installed in the TB.
f. The NRG staff walked down the licensee's strategy for ventilating the control room envelope, battery rooms, atmospheric dump valve room, and emergency feedwater room to ensure equipment reliability and personnel habitability.
g. The NRG staff walked down the FLEX equipment deployment paths and reviewed Exelon Technical Position Paper, TPP 2494447-03, "TMl-1 FLEX Debris Removal Plan," September 2, 2015. The plan evaluates the expected debris impact on the plant exterior FLEX equipment staging areas and deployment paths. The plan also identifies the debris removal equipment stored in the FSF as well as primary and alternate deployment paths. The submersible FLEX pumps stored and deployed in the seismic Class 1 Unit 1 screen house is also identified as an alternate long-term water supply intake location.
h. The NRG staff identified that the development of the FLEX maintenance and testing program is in progress. The licensee issued corrective action item ATl-01620407-53 in the TMI corrective action program to track development and completion of the

FLEX maintenance and testing program to include consideration of shelf life and acceptance criteria, manufacture recommendations and plant practices, as well as consideration of the Electric Power Research Institute preventative maintenance templates. The associated audit item was closed to TMI corrective action item ATl-01620407-53.

i. The NRC staff noted that FLEX overview and specific FLEX strategy, equipment, and procedure training for Auxiliary Operators and Licensed Operators has been completed. Training in progress to be completed prior to compliance includes Emergency Operations training, ELAP and simulator based training, including simulator training incorporating RCP seal leakage. Emergency Response Organization (ERO) training is in progress, including FLEX ERO technical training.

Specific FLEX task and procedure performance training has been identified and designated for recurring, periodic training on a 2-year schedule. These training tasks were confirmed to be listed on the long-range training plan. In addition, corrective action item ATl-1620407-60 was generated in the TMI corrective action program to address ERO training.

4.0 Exit Meeting (August 13, 2015)

The NRC audit team conducted an exit meeting with licensee staff following the closure of onsite audit activities. The NRC staff highlighted items reviewed and noted that the results of the onsite audit trip will be documented in this report. The audit items remaining open and the information needed for closure were also discussed with the licensee. Significant open items include the following:

  • The N and N+ 1 FLEX OTSG FW pumps and N and N+ 1 FLEX DGs with re-fillable diesel fuel tanks are pre-installed and stored in the TMI TB. The TB is a non-safety related structure and storage of the above FLEX equipment in the TB is an alternative to the guidance in NEI 12-06, Rev. 0. Therefore, Exelon must demonstrate that the TB structure will reasonably protect the pre-installed FLEX equipment from the effects of all BDBEEs applicable to the TMI site. The NRC staff requested that TMI perform an analysis demonstrating that the TB structure will reasonably protect the stored FLEX equipment and associated pre-installed piping and cables following a BDBEE and remain safely accessible to TMI personnel.
  • The NRC staff identified that the TMI ELAP RCS analysis relied on the main steam lines remaining intact following a BDBEE. However, the main steam lines are routed through the TMI TB, which is not designed as a safety-related structure. The integrity of the main steam lines located in the TB must be demonstrated in order to validate the primary strategies developed to provide a BDBEE mitigation capability for TMI. Therefore, the NRC staff requested that TMI perform an analysis demonstrating that the main steam lines will maintain integrity following a BDBEE.

A complete list of audit open items is listed in Attachment 3 of this report.

CONCLUSION The NRC staff completed all three parts of the July 9, 2015, onsite audit plan. In addition to the list of NRC and licensee onsite audit staff participants in Attachment 1, Attachment 2 provides a list of documents under review during the on-going audit process.

In support of the continuing audit process as the licensee proceeds towards orders compliance for this site, Attachment 3 provides the status of all open audit review items that the NRC staff is evaluating in anticipation of issuance of a combined safety evaluation (SE) for both the Mitigation Strategies (MS) and SFPI orders. The five sources for the audit items referenced below are as follows:

a. ISE Open Items (Ols) and Confirmatory Items (Cls)
b. Audit Questions (AQs)
c. Licensee-identified OIP Ols
d. SFPI RAls
e. Additional SE needed information The attachments provide audit information as follows:
a. Attachment 1: List of NRC staff and licensee staff audit participants
b. Attachment 2: List of documents under review
c. Attachment 3: MS/SFPI SE Audit Items currently under NRC staff review (licensee input needed, as noted)

While this report notes the completion of the onsite portion of the audit per the audit plan dated July 9, 2015, the ongoing audit process continues, as per the letters dated August 28, 2013, and March 26, 2014, to all licensees and construction permit holders for both orders.

Additionally, while Attachment 3 provides a list of currently open items, the status and progress of the NRC staff's review may change based on licensee plan changes, resolution of generic issues, and other NRC staff concerns not previously documented. Changes in the NRC staff review will be communicated in the ongoing audit process.

Attachments:

1. NRG and licensee staff onsite audit participants
2. Audit documents under review
3. MS/SFPI audit items currently under NRG staff review

Onsite Audit Participants NRC Staff:

John Hughey NRR/JLD/JOMB Joshua Miller NRR/JLD/JERB Khoi Nguyen NRR/JLD/JERB Laura Okruhlik NRR/JLD/JERB Matthew McConnell NRR/JLD/JERB William Cook Region I/SRA Michael Levine NRR/JLD/JCBB Justin Heinly Resident Inspector TMI Staff:

Ray Brown FLEX Project Manager Bill Mcsorley FLEX Lead Responsible Engineer Pat Mullens FLEX Engineer Earl Showalter SFPI Lead Responsible Engineer Bob Brady FLEX Operations Lead John Blair FLEX Operations Stu Brantley FLEX Operations Ed Carreras Training Manager Brad Shumaker Emergency Planning Manager Rich Gerner Security Representative Jim Randisi Auxiliary Operator Frank Waple Control Room Operator Barry Thurston Corporate Support Becky Montagnola Administration Support Attachment 1

Documents Under Review

  • Calculation No. C-1101-202-E620-471, "TMl-1 Cycle-Specific Shutdown Margin Verification During Emergency Cooldown, Rev. 1.
  • Calculation No. C-1101-212-5360-020, "BWST [borated water storage tank] Gravity Feed During Loss of OHR [decay heat removal]," Rev. 0.
  • Calculation No. C-1101-213-5450-010, "An Analysis of the Potential for Nitrogen Gas Entrainment in the RCS During Core Flood Discharge, Rev. 0.
  • Calculation No. C-1101-251-E410-002, "Spent Fuel Pool Gravity Feed After Loss of OHR, Rev. 0.
  • Calculation No. C-1101-734-E420-009, "TMl-1 Extending Battery Life to 6 hours0.25 days <br />0.0357 weeks <br />0.00822 months <br /> under ELAP, Rev. 0.
  • Calculation No. C-1101-852-5360-004, "Two Hour Backup Instrument Air system As-Built Capacity Calculation and Evaluation, Rev. 3.
  • Calculation No. C-1101-919-E410-001, "FLEX Feedwater System Hydraulic Evaluation, Rev. 1.
  • Calculation No. C-1101-919-E410-003, "Turbine Building Structural Analysis Model for BDBEE," Rev. 0. ~
  • Calculation No. C-1101-919-E410-011, "Turbine Building Structural Analysis for BDBEE, Rev. 0.
  • Calculation No. C-1101-919-E420-009, "FLEX Electrical Performance Analysis (ETAP)" Rev. 0.

Rev. 1a.

Rev. O - Draft.

  • OP-TM-919-907, "FSG-7-Alternate Monitoring of Essential Instrumentation,"

Rev. O - Draft.

  • Design Analysis No. TM-FLEX-001, "Core Cooling Analysis for FLEX," Rev. 0.
  • Design Analysis No. TM-FLEX-002, "Reactor Building Pressure Analysis for FLEX,"

Rev. 2.

  • TMI SAFER Response Plan: "SAFER Response Plan for Three Mile Island Nuclear Station, Rev. 2, August 6, 2015.

Attachment 2

Three Mile Island - Unit 1 Mitigation Strategies/Spent Fuel Pool Instrumentation Safety Evaluation Audit Items:

Audit Items Currently Under NRC Staff Review, Requiring Licensee Input As Noted Audit Item Item Description Licensee Input Needed Reference Provide the analysis supporting the licensee's The integrity of the main steam lines located in the mitigation strategy (WCAP-17792-P) for NRC staff TB must be demonstrated in order to validate the review; identify the specific calculation(s) in WCAP- primary strategies developed to provide a BDBEE ISE 013.2.1.1.B 17792-P considered applicable to demonstrating the mitigation capability for TMI. Therefore, the NRC feasibility of the proposed strategy, and justify the staff requested that TMI perform an analysis applicability of the calculation(s) relied upon in WCAP- demonstrating that the main steam lines will 17792-P to TMl-1. maintain inteqritv followinq a BDBEE.

As applicable, provide additional analyses for core Closure of this item is dependent on results of the ISE 013.2.1.1.C cooling, RCS makeup, and shutdown margin that are main steam line integrity analysis requested under relied upon, but not included in WCAP-17792-P. item 01 3.2.1.1.B.

The licensee appears to use a probabilistic approach to reach a conclusion that at least one of the three tanks depended on for RCS makeup will survive an ELAP Licensee to provide technical evaluation/analyses ISE 01 3.2.4.7.A event. NEI 12-06 guidance does not include this for NRC staff review.

option. Provide further justification for this alternate approach.

Attachment 3

Audit Item Item Description Licensee Input Needed Reference The licensee stated that protection of associated The TMI FLEX equipment storage configuration is portable equipment from external hazards would be an alternative to the guidance in NEI 12-06, Rev. 0.

provided in structures that will be constructed to meet The NRC staff has requested that TMI provide an the requirements of NEI 12-06 Section 11. However, analysis demonstrating that the TB structure will the licensee did not specify the type of configuration, reasonably protect the stored FLEX equipment and how FLEX equipment would be secured, or how stored associated pre-installed piping and cables following equipment and structures would be protected from all a BDBEE and remain safely accessible to TMI external hazards. personnel.

The TB structural analysis must also address the protection and accessibility of the diesel re-fill piping connection and hose deployment paths to the FLEX DG fuel tanks.

ISE Cl 3.1.1.1.A Per the TMI severe flood mitigation strategy, FLEX equipment will be relocated to the TMI training center located across the Susquehanna River from the TMI facility which may be isolated by the flood.

However, no procedural guidance is in place to pre-plan and direct the means by which the FLEX equipment will be relocated to the TMI site within the timeframe in which it may be needed.

Therefore, the NRC staff has requested that TMI provide the procedure/administrative controls that will used to re-deploy the FLEX equipment to the TMI site that was re-located to the TMI training center.

Audit Item Item Description Licensee Input Needed Reference The licensee needs to confirm that the transition to the backup feedwater system will occur without a The NRC staff is reviewing information provided by ISE Cl 3.2.1.A significant interruption of feedwater to the steam the licensee in the course of the on-going audit generators. process.

The 1A and 1B ES motor control center (MCC) will be energized using the FLEX diesel generators as Closure of this item is dependent on results of the described in Safety Functions Support section and the ISE Cl 3.2.1.2.A main steam line integrity analysis requested under FLEX RCS makeup pump will be started within 4 hours0.167 days <br />0.0238 weeks <br />0.00548 months <br />.

item 01 3.2.1.1.B.

The analysis to confirm the timeline is not yet complete.

Information should be provided to justify that the procedures are effective to keep the RCS temperatures within the limits of the seal design temperatures, and Closure of this item is dependent on results of the ISE Cl 3.2.1.2.B address the adequacy of the seal leakage rate (2 main steam line integrity analysis requested under gallons per minute (gpm)/seal) used in the ELAP item 01 3.2.1.1.C.

analysis.

For plants such as TMl-1 that credit low leakage seals to maintain the initial maximum leakage rate of 2 Licensee to confirm consistency with Flowserve gpm/seal for the ELAP analyses of the RCS response, RCP seal technical white paper endorsed by the ISE Cl 3.2.1.2.C a discussion of the information (including seal leakage NRC on November 12, 2015 (ADAMS Accession testing data) should be provided to justify the use of 2 No. ML15310A094).

gpm/seal in the ELAP analysis.

Audit Item lte111 Description Licensee Input Needed Reference The licensee did not provide any further description of specific initial key plant parameters specified in NEI 12-06, Sections 3.2.1.2 and 3.2.1.3 except the assumption regarding SSCs [structures, systems and components],

The NRG staff is reviewing information provided by and the items from the sequence of events (SOE)

ISE Cl 3.2.1.4.A the licensee in the course of the on-going audit Attachment 1A. The licensee did not provide the initial process.

conditions used in the RCS and SFP calculations used in the TMI Training and Reference Manual, ER-TM-TSC-0016, the TMI.

During the ELAP and LUHS [loss of ultimate heat sink]

beyond-design-basis external event, the licensee has identified that times to complete actions in the Events Timeline are based on operating judgment, the conceptual designs, and the current supporting analyses. The TMI mitigation strategy is not based upon the PWROG [Pressurized Water Reactor Owners Group] WCAP-17601-P ELAP mitigation strategy. In the audit process, the licensee stated that the current Licensee to provide SOE timeline validation ISE Cl 3.2.1.6.A SOE is for the seismic event only and that another SOE information.

would be developed for the flood event. Based on the information provided by the licensee, it is not possible to determine the validity of the time constraints provided in the preliminary sequence of events timeline for all hazards. The final timelines will be validated once detailed designs are completed and procedures are developed. The results will be provided in a future 6-month update.

Audit Item Item Description Licensee Input Needed Reference The licensee stated that the FLEX diesel generators (FX-Y-1A & B), fuel storage tank (FX-T-2), and FLEX MCC will be located north of the turbine pedestals on the turbine building 322-foot elevation. The FLEX diesel generators and FLEX MCC will be designed for operation if subjected to twice the Safe Shutdown Earthquake (SSE), as part of the "augmented Closure of this item is dependent on the results of ISE Cl 3.2.1.9.A approach." Protective barriers will be installed to the TMI TB structural analysis requested under item ensure this equipment remains functional following a Cl 3.1.1.1.A.

tornado. Feasibility analysis has been completed which shows that the turbine building should be adequate to support these loads during an SSE. Further analysis is being performed to determine if any structural modifications are necessary to support that conclusion.

The Integrated Plan table titled, "PWR [pressurized-water reactor] Portable Equipment Phase 2," lists two diesel-driven pumps. The second table titled, "PWR Portable Equipment Phase 3," lists several pumps to be obtained from the RRC [NSRC - National SAFER The NRC staff is reviewing information provided by Response Center]. The licensee did not discuss how ISE Cl 3.2.1.9.B the licensee in the course of the on-going audit the operator actions are modeled in the ELAP to process.

determine the required flow rates of the portable pumps listed in the "PWR Portable Equipment Phase 3," or justify that the capacities of each of the above discussed pumps are adequate to maintain core cooling during phases 2 and 3 of ELAP.

Audit Item Item Description Licensee Input Needed Reference The licensee stated that initial SFP cooling calculations were used to determine the fuel pool timelines and that formal calculations will be performed to validate this The NRC staff is reviewing information provided by information during development of the detailed design.

ISE Cl 3.2.2.A the licensee in the course of the on-going audit The licensee also stated that these strategies utilize a process.

vent path for steam, and that the effects of this steam on other systems and equipment will be evaluated, and the results will be provided in a future 6-month update.

The licensee specified that a strategy for extreme cold, snow and ice events is being developed. Preliminary plans include the use of heat tracing for some piping The NRC staff is reviewing information provided by ISE Cl 3.2.4.3.A and tanks, e.g. the borated water storage tank, and the licensee in the course of the on-going audit minimum flow paths or steam heating in other situations process.

(e.g. the CSTs). The final plans will be reviewed when complete.

A review was conducted of Exelon's plans for the development of mitigating strategies with respect to the procedural interface considerations for seismic hazards associated with large internal flooding sources that are not seismically-robust and do not require ac power, the use of ac power to mitigate ground water in critical Closure of this item is dependent on the results of locations, or the existence of non-seismically robust the TMI TB structural analysis requested under item AQ2 downstream dams, but it was determined that there Cl 3.1.1.1.A and associated post-BDBEE FLEX was insufficient information in the plans to conclude equipment access evaluations.

that there is reasonable assurance that these aspects of the requirements of Order EA-12-049 and NEI 12-06, Section 5.3.3, Consideration 2-4, will be met. Please provide a discussion of these considerations in the appropriate six-month update.

Audit Item Item Description Licensee Input Needed Reference The integrated plan for TMl-1 did not provide any information regarding how decay heat rates were The NRC staff is reviewing information provided by determined in the analyses for reactor core and spent AQ 13 the licensee in the course of the on-going audit fuel pool cooling. Please identify how decay heat was process.

modeled for these analyses and provide justification for its adequacy. '

The FLEX emergency feedwater pumps and two diesel generators and fuel tanks are located in the turbine building, which is a non-seismic Class 1 building. As noted on page 11 of the submittal, the pumps are only designed for the flood condition. It is not clear if these pumps will be available in a seismic event due to their location. Please clarify the availability of these pumps during a seismic event, including accessibility of any ~

instrumentation and controls needed to support their operation, and identify how makeup to the steam Closure of this item is dependent on the results of generators would be provided for such an event. If the AQ 19 the TMI TB structural analysis requested under item FLEX emergency feedwater pumps are credited for a Cl 3.1.1.1.A.

seismic event, please provide adequate justification.

Please clarify whether the diesel generators and fuel tanks located in a protected enclosure in the turbine building (reference page 37 of submittal) will be adequately protected from damage from beyond-design-basis external events (e.g., seismic, tornado, etc.). Please further clarify whether access to the protected enclosure could be restricted by damage to non-seismic structures and equipment.

Audit Item Item Description Licensee Input Needed Reference Since the FLEX emergency feedwater pumps and the emergency RCS charging pumps are permanently installed they do not appear to qualify for portable status per NEI 12-06. The rationale for having portable equipment is that it can be stored or located in such a way that it is protected from all of the external events listed in NEI 12-06 (seismic, flooding, high wind, extreme cold and heat). The FLEX emergency The NRC staff is reviewing information provided by AQ20 feedwater pumps do not appear to be protected from the licensee in the course of the on-going audit seismic events. A justification is needed related to how process.

these two permanently installed systems qualify as FLEX equipment under NEI 12-06, Section 3.1.2.12.

Also, a discussion of how these two systems and their respective power supplies are any more survivable than the normally-installed plant equipment is needed.

Please discuss this issue.

Provide a discussion on the diesel fuel oil supply (e.g.,

fuel oil storage tank volume, supply pathway, etc.) for the diesel-driven FLEX pumps and generators and how continued operation to ensure core and spent fuel pool cooling is maintained indefinitely (i.e., Phase 2 and 3).

Also, explain how fuel quality will be assured if stored for extended periods of time. The staff also requests Licensee to provide technical FLEX fuel oil supply AQ40 the licensee provide a refueling strategy for the and quality plan for NRC staff review.

diesel-driven FLEX equipment, to include fuel consumption estimates for the FLEX diesel driven FW pumps taking suction from the UHS [ultimate heat sink],

and the time for refueling, and how the fuel will be provided.

Audit Item Item Description Licensee Input Needed Reference Please clarify whether a single FLEX pump will be used to provide cooling flow to multiple destinations (e.g., the reactor core, steam generators, and the spent fuel pool). If so, please confirm that the FLEX pump can supply adequate flow and clarify whether the pumped flow will be split and simultaneously supplied to all The NRC staff is reviewing information provided by destinations or whether the flow will be alternated AO 51 the licensee in the course of the on-going audit between them. If simultaneous flow will be used, then process.

clarify how the flow splits will be measured and controlled (i.e., whether control exists for the total flow on a common line or on lines to individual destinations) to ensure that adequate flow (i.e., sufficient but not excessive) reaches each destination.

The licensee plans to secure the main generator seal oil pump when the hydrogen pressure decreases to 15 psig. The staff requests the licensee to explain why the pressure decrease is stopped at 15 psig and the main The NRC staff is reviewing information provided by AQ56 generator is not purged with C02. The licensee is also the licensee in the course of the on-going audit requested to describe the consequences of securing process.

the seal oil pump with 15 psi, of hydrogen remaining in the generator casing.

The licensee's strategy for RCS injection includes using water from the spent fuel pool. The staff requests the licensee provide an evaluation of the consequences on The NRC staff is reviewing information provided by AO 59 the spent fuel pool using this strategy and the the licensee in the course of the on-going audit consequential actions required by the operators to process.

maintain adequate spent fuel pool cooling.

Audit Item Item Description Licensee Input Needed Reference The table titled, "PWR Portable Equipment Phase 2,"

lists two diesel driven-pumps. The pumps have flow rates and required head of 240 gpm and 250 psid

[pounds per square inch differential], and 600 gpm and 245 psid, respectively. The second table titled, "PWR Portable Equipment Phase 3," cites a positive displacement high pressure pump with the specifications of 1000-3000 psi shutoff head and 60 gpm capacity and three low pressure pumps of 300 psi The NRG staff is reviewing information provided by shutoff head and 2500 gpm max flow, 500 psi shutoff AQ64 the licensee in the course of the on-going audit head and 500 gpm max flow, and 150 psi shutoff head process.

and 5000 gpm max flow. Specify the required times for the operator to realign each of the above discussed pumps and confirm that the required times are consistent with the results of the ELAP analysis.

Discuss how the operator actions are modeled in the ELAP to determine the required flow rates of the portable pumps, and justify that the capacities of each of the above discussed pumps are adequate to maintain core coolinQ durinQ phases 2 and 3 of ELAP.

A portable refueling vehicle with a large diesel oil bladder will be available on site to support refilling our portable equipment diesel tanks. An additional means Licensee to provide technical evaluation for NRG OIPOl 9 (river makeup is available) of delivering condensate staff review.

may also be developed; details to be provided in a future 6-month update.

A plan will be developed to re-supply borated water to The NRG staff is reviewing information provided by OIP 0113 the borated water storage tank or SFP. the licensee in the course of the on-going audit process.

Audit Item Item Description Licensee Input Needed Reference

a. Discuss the design of the suction strainers used with FLEX pumps taking suction from raw water sources, including perforation dimension(s) and approximate surface area.
b. Provide reasonable assurance that the strainers will not be clogged with debris (accounting for conditions following flooding, severe storms, earthquakes or other natural hazards), or else that the strainers can be cleaned of debris at a frequency that is sufficient to provide the required flow. In the response, consider the The NRG staff is reviewing information provided by SE 2 following factors: the licensee in the course of the on-going audit
i. The timing at which FLEX pumps would take process.

suction on raw water relative to the onset and duration of the natural hazard.

ii. The timing at which FLEX pumps would take suction on raw water relative to the timing at which augmented staffing would be available onsite.

iii. Whether multiple suction hoses exist for each FLEX pump taking suction on raw water, such that flow interruption would not be required to clean suction strainers.

Audit Item Item Description Licensee Input Needed Reference Discuss all areas where local manual actions are credited in FLEX strategies (e.g., steam generator (SG)

?tmospheric dump valves, auxiliary feedwater flow control, making connection points, control room, etc.)

Can operators safety enter these areas to complete necessary actions during extreme hot and cold hazard during an ELAP (heat, cold, humidity, etc.)? Are these actions feasible based on ELAP conditions and time The NRC staff is reviewing information provided by SE 3 constraint restrictions? the licensee in the course of the on-going audit process.

Will sufficient lighting be available to complete tasks (e.g., portable lighting, headlamps, flashlights, etc.)?

Is communication with the control room possible based on noise in area of local manual actions?

Will portable ventilation be established? When will it be established?

Identification of FLEX pump (RCS makeup, FW, and SFP makeup) connection points and diverse flowpaths.

The NRC staff is reviewing information provided by Confirmation that the connection points are reasonably SE4 the licensee in the course of the on-going audit protected from all applicable, external hazards and will process.

remain accessible when needed during an ELAP event.

The NRC staff is reviewing information provided by Verify that appropriate human factors are applied for SE 6 the licensee in the course of the on-going audit the implementation of the FLEX strategies.

process.

Audit Item Item Description Licensee Input Needed Reference The licensee needs to confirm that the temperature and pressure within containment, other areas within the plant (i.e., electrical switchgear room), and atmospheric dump valve rooms will not exceed the qualification of The NRC staff is reviewing information provided by SE14 electrical equipment that is being relied upon as part of the licensee in the course of the on-going audit the FLEX strategy. The licensee needs to ensure that process.

the qualification of the required electrical equipment remains bounding during the entire duration of the event (i.e., indefinitely).

Clarify MSIV [main steam isolation valve] behavior during ELAP at TMI. Understand that MSIVs are motor-operated and that the operator cabling may not be qualified during seismic event. Understand position of MSIVs during different scenarios. Open MSIVs implies potential for cross-tied SG pressure. Closed MSIVs implies potential for independent pressures in SGs. Obviously this could influence RCS loop Closure of this item is dependent on results of the temperatures and flows for cases where asymmetry SE 18 main steam line integrity analysis requested under may arise.

item 01 3.2.1.1.B.

Also, because of potential inability to close MSIVs if electrical power unavailable to valve operator, confirm whether downstream piping is robust to turbine stop valves, or whether there is potential for uncontrolled cooldown that must be addressed. This situation could arise if downstream steam lines or connected piping is non-robust in one or more ELAP scenarios.

Audit Item Item Description Licensee Input Needed Reference The licensee's strategy relies on a single connection point for the Phase 2 DGs to provide power to the The NRC staff is reviewing information provided by SE20 TMI 480 V electrical distribution system. Please the licensee in the course of the on-going audit address the guidance in NEI 12-06 regarding multiple process.

FLEX electrical connection points.

The licensee needs to provide an analysis that shows that staging the N and N+ 1 Phase 2 FLEX DGs in close proximity to one another does not reduce the The NRC staff is reviewing information provided by reliability of either Phase 2 FLEX DG to perform its SE 21 the licensee in the course of the on-going audit required function (i.e., a catastrophic failure on one process.

Phase 2 FLEX DG will not adversely impact the other FLEX DG or its associated equipment (cabling, connections, etc.)).

How will seismic water sources (e.g. condensate The NRC staff is reviewing information provided by storage tanks CO-T-1 A I 1B) be protected from the SE 22 the licensee in the course of the on-going audit impact of a seismic or tornado event on other process.

connected tanks?

ML15357A102 OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NRR/JLD/JCBB/BC(A) NRR/JLD/JERB/BC NAME JHughey Slent BTitus (CRoque-Cruz for) SBailey DATE 12/31/2015 12/23/2015 12/28/2015 12/30/2015 OFFICE NRR/JLD/JOMB/BC NRR/JLD/JOMB/PM NAME GBowman JHughey DATE 01/08/2016 01/11/2016

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