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{{#Wiki_filter:UNITED STATES               NUCLEAR REGULATORY COMMISSION                                                         REGION I                                               475 ALLENDALE ROAD                               KING OF PRUSSIA, PA 19406-1415  
{{#Wiki_filter:UNITED STATES
April 25, 2008  
                                  NUCLEAR REGULATORY COMMISSION
                                                      REGION I
Mr. Charles G. Pardee   Chief Nuclear Officer (CNO) and Senior Vice President Exelon Generation Company, LLC Chief Nuclear Officer (CNO)  
                                                475 ALLENDALE ROAD
AmerGen Energy Company, LLC 200 Exelon Way             Kennett Square, PA 19348  
                                          KING OF PRUSSIA, PA 19406-1415
SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED INSPECTION REPORT 5000289/2008002  
                                            April 25, 2008
Dear Mr. Pardee:  
Mr. Charles G. Pardee
On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated  
Chief Nuclear Officer (CNO) and Senior Vice President
inspection at your Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report documents the inspection results, which were discussed April 18, 2008, with Mr. Bill Noll and other members of your staff.  
Exelon Generation Company, LLC
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.  
Chief Nuclear Officer (CNO)
On the basis of the results of this inspection, no findings of significance were identified.  
AmerGen Energy Company, LLC
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice", a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the  
200 Exelon Way
NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).  
Kennett Square, PA 19348
We appreciate your cooperation. Please contact me at 610-337-5200 if you have any questions  
SUBJECT:       THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED
regarding this letter. Sincerely,  
                INSPECTION REPORT 5000289/2008002
          /RA/ Ronald R. Bellamy, Ph.D., Chief Projects Branch 6 Division of Reactor Projects Docket No:   50-289 License No: DPR-50
Dear Mr. Pardee:
On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated
Enclosure: Inspection Report 05000289/2008002  w/Attachment:  Supplemental Information
inspection at your Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report
cc w/encl: Executive Vice President and Chief Operating Officer, Exelon Generation 
documents the inspection results, which were discussed April 18, 2008, with Mr. Bill Noll and
Site Vice President - TMI Unit 1, AmerGen Plant Manager - TMI, Unit 1, AmerGen Regulatory Assurance Manager - TMI, Unit 1 AmerGen Senior Vice President - Nuclear Services, AmerGen Senior Vice President - Mid-Atlantic Operations, AmerGen
other members of your staff.
Senior Vice President - Operations Support, AmerGen Vice President - Licensing and Regulatory Affairs, AmerGen Director Licensing - AmerGen Manager Licensing - TMI, AmerGen J. Fewell, Esq., Associate General Counsel, Exelon Nuclear Correspondence Control Desk - AmerGen Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry township R. Janati, Director, Bureau of Radiation Protection, State of PA J. Johnsrud, National Energy Committee E. Epstein, TMI-Alert (TMIA) D. Allard, PADEP
The inspection examined activities conducted under your license as they relate to safety and
J. Powers, Director, PA Office of Homeland Security R. French, Director, PA Emergency Management Agency 
compliance with the Commissions rules and regulations and with the conditions of your license.
3  Mr. Charles G. Pardee  Chief Nuclear Officer (CNO) and Senior Vice President  Exelon Generation Company, LLC 
The inspectors reviewed selected procedures and records, observed activities, and interviewed
Chief Nuclear Officer (CNO)
personnel.
AmerGen Energy Company, LLC 200 Exelon Way              Kennett Square, PA 19348
On the basis of the results of this inspection, no findings of significance were identified.
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 610-337-5200 if you have any questions
regarding this letter.
                                                              Sincerely,
                                                                /RA/
                                                              Ronald R. Bellamy, Ph.D., Chief
                                                              Projects Branch 6
                                                              Division of Reactor Projects
Docket No:     50-289
License No:     DPR-50


                                            2
SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED  INSPECTION REPORT 5000289/2008002 Dear Mr. Pardee: 
Enclosure:     Inspection Report 05000289/2008002
              w/Attachment: Supplemental Information
cc w/encl:
Executive Vice President and Chief Operating Officer, Exelon Generation
Site Vice President - TMI Unit 1, AmerGen
Plant Manager - TMI, Unit 1, AmerGen
Regulatory Assurance Manager - TMI, Unit 1 AmerGen
Senior Vice President - Nuclear Services, AmerGen
Senior Vice President - Mid-Atlantic Operations, AmerGen
Senior Vice President - Operations Support, AmerGen
Vice President - Licensing and Regulatory Affairs, AmerGen
Director Licensing - AmerGen
Manager Licensing - TMI, AmerGen
J. Fewell, Esq., Associate General Counsel, Exelon Nuclear
Correspondence Control Desk - AmerGen
Chairman, Board of County Commissioners of Dauphin County
Chairman, Board of Supervisors of Londonderry township
R. Janati, Director, Bureau of Radiation Protection, State of PA
J. Johnsrud, National Energy Committee
E. Epstein, TMI-Alert (TMIA)
D. Allard, PADEP
J. Powers, Director, PA Office of Homeland Security
R. French, Director, PA Emergency Management Agency


                                                            3
On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report documents the inspection results, which were discussed April 18, 2008, with Mr. Bill Noll and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. On the basis of the results of this inspection, no findings of significance were identified.    
Mr. Charles G. Pardee
In accordance with 10 CFR 2.390 of the NRC's "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 NRC's 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 610-337-5200 if you have any questions regarding this letter. Sincerely, Ronald R. Bellamy, Ph.D., Chief /RA/ Projects Branch 6 Division of Reactor Projects Distribution w/encl
Chief Nuclear Officer (CNO) and Senior Vice President
: (VIA EMAIL) S. Collins, RA M. Dapas, DRA D. Lew, DRP  
Exelon Generation Company, LLC
J. Clifford, DRP  
Chief Nuclear Officer (CNO)
R. Bellamy, DRP  
AmerGen Energy Company, LLC
S. Barber, DRP A. Rosebrook, DRP  
200 Exelon Way
D. Kern, DRP, Senior Resident Inspector  
Kennett Square, PA 19348
J. Brand, DRP, Resident Inspector C. LaRegina, DRP, Resident OA S. Williams, RI, OEDO  
SUBJECT:              THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED
H. Chernoff, NRR  
                      INSPECTION REPORT 5000289/2008002
J. Lubinski, NRR P. Bamford, PM, NRR G. Miller, NRR  
Dear Mr. Pardee:
J. Lubinski, NRR  
On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your
Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report documents the inspection results, which were
discussed April 18, 2008, with Mr. Bill Noll 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.
On the basis of the results of this inspection, no findings of significance were identified.
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 610-337-5200 if you have any questions regarding this letter.
                                                                                    Sincerely,
                                                                                    Ronald R. Bellamy, Ph.D., Chief /RA/
                                                                                    Projects Branch 6
                                                                                    Division of Reactor Projects
Distribution w/encl: (VIA EMAIL)
S. Collins, RA
M. Dapas, DRA
D. Lew, DRP
J. Clifford, DRP
R. Bellamy, DRP
S. Barber, DRP
A. Rosebrook, DRP
D. Kern, DRP, Senior Resident Inspector
J. Brand, DRP, Resident Inspector
C. LaRegina, DRP, Resident OA
S. Williams, RI, OEDO
H. Chernoff, NRR
J. Lubinski, NRR
P. Bamford, PM, NRR
G. Miller, NRR
J. Lubinski, NRR
ROPreportsResource@nrc.gov
ROPreportsResource@nrc.gov
Region 1 Docket Room   (with concurrences)           ML081160408
Region 1 Docket Room (with concurrences)
SUNSI Review Complete AAR (Reviewer's Initials) DOCUMENT NAME: G:\DRP\BRANCH6a\+++Three Mile Island\TMI Inspection Reports\TMI 08- 002.doc  After declaring this document "An Official Agency Record" it will be released to the Public.  
                                                                                              ML081160408
SUNSI Review Complete AAR (Reviewers Initials)
To receive a copy of this document, indicate in the box: "C"= Copy without attachment/enclosure "E"=Copy with attachment/enclosure, "N"=No copy OFFICE RI/DRP RI/DRP RI/DRP RI/DRS NAME DKern/ AAR for ARosebrook/ AAR SBarber/ SB RBellamy/RRB DATE 4 /24 /08 4/24 /08 4/25 /08 4/ 25 /08  
DOCUMENT NAME: G:\DRP\BRANCH6a\+++Three Mile Island\TMI Inspection Reports\TMI 08- 002.doc
    OFFICIAL RECORD COPY  
   After declaring this document An Official Agency Record it will be released to the Public.
1    Enclosure  U.S. NUCLEAR REGULATORY COMMISSION REGION 1  Docket No:  05000289
To receive a copy of this document, indicate in the box: C= Copy without attachment/enclosure E=Copy with
  License No:  DPR-50
attachment/enclosure, N=No copy
OFFICE         RI/DRP                 RI/DRP                   RI/DRP                 RI/DRS
NAME           DKern/ AAR for         ARosebrook/ AAR         SBarber/ SB             RBellamy/RRB
DATE           4 /24 /08             4/24 /08                 4/25 /08               4/ 25 /08
                                          OFFICIAL RECORD COPY


   Report No: 05000289/2008002  
                                  1
 
              U.S. NUCLEAR REGULATORY COMMISSION
Licensee: AmerGen Energy Company, LLC (AmerGen)  
                                  REGION 1
  Facility: Three Mile Island Station, Unit 1  
Docket No:   05000289
  Location: PO Box 480  
License No:  DPR-50
  Middletown, PA 17057  
Report No:   05000289/2008002
  Dates:   January 1 - March 31, 2008  
Licensee:   AmerGen Energy Company, LLC (AmerGen)
Facility:   Three Mile Island Station, Unit 1
Inspectors:  David M. Kern, Senior Resident Inspector   Javier M. Brand, Resident Inspector   Jeffrey Bream, Reactor Engineer   Danté Johnson, Physical Security Inspector  
Location:   PO Box 480
  Kevin Mangan, Senior Reactor Inspector   Ronald M. Nimitz, Senior Health Physicist  
            Middletown, PA 17057
    Approved by: Ronald R. Bellamy, Ph.D., Chief  
Dates:       January 1 - March 31, 2008
  Projects Branch 6   Division of Reactor Projects (DRP)
Inspectors:  David M. Kern, Senior Resident Inspector
2    Enclosure 
            Javier M. Brand, Resident Inspector
TABLE OF CONTENTS 
            Jeffrey Bream, Reactor Engineer
  SUMMARY OF FINDINGS..........................................................................................................3
            Danté Johnson, Physical Security Inspector
  1. REACTOR SAFETY...........................................................................................................4
            Kevin Mangan, Senior Reactor Inspector
1R01 Adverse Weather Protection ...................................................................................4
            Ronald M. Nimitz, Senior Health Physicist
1R04 Equipment Alignment .............................................................................................4
Approved by: Ronald R. Bellamy, Ph.D., Chief
1R05 Fire Protection ........................................................................................................5
            Projects Branch 6
1R11 Licensed Operator Requalification Program ...........................................................6
            Division of Reactor Projects (DRP)
1R12 Maintenance Effectiveness .....................................................................................6
                                                        Enclosure
1R13 Maintenance Risk Assessments and Emergent Work Control ................................7
1R15 Operability Eval
uations ...........................................................................................8
1R18 Plant Modifications .................................................................................................8
1R19 Post Maintenance Testing ......................................................................................9
1R22 Surveillance Testing .............................................................................................10
  2. RADIATION SAFETY.......................................................................................................11
20S1 Access Controls ....................................................................................................11
2OS2 ALARA Planning and Controls ..............................................................................12
2OS3 Radiation Monitoring Instrumentation and Protective Equipment ..........................14
2PS2 Radioactive Material Processing and Transportati on ............................................
14  4. OTHER ACTIVITIES.........................................................................................................15
4OA1 Performance Indicator Verification ........................................................................15
4OA2 Identification and Resolution of Problems .............................................................15
4OA6 Meetings, Including Exit.........................................................................................18
  ATTACHMENT:  SUPPLEMENTAL INFORMATION................................................................18
SUPPLEMENTAL INFORMATION.........................................................................................A-1
KEY POINTS OF CONTACT..................................................................................................A-1
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED.......................................................A-1
LIST OF ACRONYMS............................................................................................................A-4
 
3    Enclosure  SUMMARY OF FINDINGS
IR 05000289/2008002; 1/1/2008 - 3/31/2008; AmerGen Energy Company, LLC; Three Mile Island, Unit 1; Routine integrated report. The report covered a 13-week period of inspection by resident inspectors and announced inspections by regional inspectors.  No findings of significance were identified.  The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Rev. 3, dated July 2000.
A. NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
B. Licensee Identified Violations
  None. 
4    Enclosure  REPORT DETAILS
Summary of Plant Status
Three Mile Island, Unit 1 (TMI) operated at approximately 100 percent rated thermal power for the entire inspection period.
1. REACTOR SAFETY Cornerstones:  Initiating Events, Mitigating Systems, Barrier Integrity 1R01 Adverse Weather Protection (71111.01 - 1 site sample)
  a. Inspection Scope
  Winter storms, including heavy rains and winds, elevated the Susquehanna River level above flood stage and affected river conditions from March 5 to 11, 2008.  The inspectors reviewed procedures, conducted interviews, and performed various inspections to verify that operator actions to address adverse river conditions maintained the readiness of the various river water systems.  Operators closely monitored National Weather Service flood projections and entered procedure 1202-32, Flood, Rev. 65 when the 36-hour forecast projected river level to reach flood stage (286.1 feet at the intake
screen house (issue report (IR) 745543).  The inspectors walked down the intake screen house which houses the fire protection system pumps and safety related cooling water pumps for the decay heat removal system, nuclear service water system, and reactor river water system.  Additionally, after river level receded below flood stage, the inspectors walked down the flood dike which surrounds the entire power plant in
accordance with procedure 3301-SA1, Dike Inspection, Rev. 12 to determine whether the flood barrier had been damaged or needed repair (IRs 734215, 747638).  The inspectors evaluated the adequacy of various emergency and surveillance procedures associated with river water and intake systems to assess AmerGen
=s protection from storms and adverse river conditions.
b. Findings
  No findings of significance were identified.
1R04 Equipment Alignment (71111.04) a. Inspection Scope
  Partial System Walkdowns (71111.04Q - 3 samples) The inspectors performed three partial system walkdown samples on the following systems and components:
* On February 12, 2008, the inspectors walked down portions of the 'A' decay heat removal and reactor building spray systems while the plant was in an unplanned orange risk condition due to an unexpected electrical breaker fault which made the 'B' decay river water pump inoperable. 
 
5    Enclosure
* On February 21, the inspectors walked down portions of the 'B' reactor building spray system while the plant was in a 48 hour limiting condition of operation for scheduled 'A' emergency safeguards and actuation load sequence testing.
* On February 27 and 28, the inspectors walked down portions of the remote safe shutdown panel, while engineers and technicians were performing inspections of the engineered safeguards and actuation system relays.
The partial system walkdowns were conducted on the redundant and standby equipment to ensure that trains and equipment relied on to remain operable for accident mitigation were properly aligned.  Additional documents reviewed are listed in the attachment.


Complete System Walkdown (71111.04S - 1 sample) On March 3 and 4, 2008, the inspectors performed one complete system walkdown sample on the 'B' and 'C' makeup and purification system trains, while the 'A' system train was in a scheduled maintenance outage. The inspectors conducted a detailed
                                                    2
review of the alignment and condition of the system using the applicable one-line diagram 302-560, Makeup and Purification, Rev. 44. In addition, the inspectors reviewed and evaluated the corrective action program reports for impact on system operation, interviewed the system engineer, and interviewed control room operators
                                            TABLE OF CONTENTS
. b. Findings
SUMMARY OF FINDINGS.......................................................................................................... 3
  No findings of significance were identified.  
1.  REACTOR SAFETY ........................................................................................................... 4
1R05 Fire Protection (71111.05)
   1R01    Adverse Weather Protection ................................................................................... 4
a. Inspection Scope (71111.05Q - 8 samples)
  1R04    Equipment Alignment ............................................................................................. 4
The inspectors conducted fire protection inspections for several plant fire zones, selected based on the presence of equipment important to safety within their boundaries. The inspectors conducted plant walkdowns and verified the areas were as described in the TMI Fire Hazard Analysis Report, and that fire protection features were being
  1R05    Fire Protection ........................................................................................................ 5
properly controlled per surveillance procedure 1038, Administrative Controls-Fire Protection Program, Rev. 69. The plant walkdowns were conducted throughout the inspection period and included assessment of transient combustible material control, fire detection and suppression equipment operability, and compensatory measures established for degraded fire protection equipment in accordance with procedure OP-
  1R11    Licensed Operator Requalification Program ........................................................... 6
MA-201-007, Fire Protection System Impairment Control, Rev. 5. In addition, the inspectors verified that applicable clearances between fire doors and floors met the criteria of Attachment 1 of Engineering Technical Evaluation CC-AA-309-101, Engineering Technical Evaluations, Rev. 9. Fire zones and areas inspected included:
  1R12    Maintenance Effectiveness ..................................................................................... 6
* Fire Zone AB-FZ-2A, Auxiliary Building Elevation 281', Makeup and Purification Pump A; * Fire Zone AB-FZ-2B, Auxiliary Building Elevation 281', Makeup and Purification Pump B; * Fire Zone AB-FZ-3C, Auxiliary Building Elevation 281', Makeup and Purification Pump C;  * Fire Zone DG-FA-1, Diesel Generator Building Elevation 305', Diesel Generator A;
  1R13    Maintenance Risk Assessments and Emergent Work Control ................................ 7
* Fire Zone DG-FA-2, Diesel Generator Building Elevation 305', Diesel Generator B;
  1R15    Operability Evaluations ........................................................................................... 8
* Fire Zone TB-FA-1, Turbine Building Elevation 305' 
  1R18    Plant Modifications ................................................................................................. 8
6   Enclosure 
  1R19    Post Maintenance Testing ...................................................................................... 9
* Fire Zone TB-FA-1, Turbine Building Elevation 322'
  1R22    Surveillance Testing ............................................................................................. 10
* Fire Zone TB-FA-1, Turbine Building Elevation 355'
2.  RADIATION SAFETY ....................................................................................................... 11
b. Findings
  20S1    Access Controls .................................................................................................... 11
  No findings of significance were identified.  
  2OS2    ALARA Planning and Controls .............................................................................. 12
1R11 Licensed Operator Requalification Program (71111.11Q - 1 sample)
  2OS3    Radiation Monitoring Instrumentation and Protective Equipment .......................... 14
  a. Inspection Scope
  2PS2    Radioactive Material Processing and Transportation ............................................ 14
  On March 18, 2008, the inspectors observed licensed operator requalification training at the control room simulator for the 'E' operator crew. The inspectors observed the
4.  OTHER ACTIVITIES......................................................................................................... 15
operators' simulator drill performance and compared it to the criteria listed in TMI Operational Simulator Scenario Number 12, Condenser Vacuum Leak, Stuck Rod, Loss of Offsite Power with Diesel and Emergency Feedwater Failures, Rev. 12. The inspectors reviewed the operators' ability to correctly evaluate the simulator training scenario and implement the emergency plan. The inspectors observed supervisory oversight, command and control, communication practices, and crew assignments to ensure they were consistent with normal control room activities. The inspectors
  4OA1    Performance Indicator Verification ........................................................................ 15
observed operator response during the simulator drill transients. The inspectors evaluated training instructor effectiveness in recognizing and correcting individual and operating crew errors. The inspectors attended the post-drill critiques in order to evaluate the effectiveness of problem identification. The inspectors verified that emergency plan classification and notification training opportunities were tracked and
  4OA2    Identification and Resolution of Problems ............................................................. 15
evaluated for success in accordance with criteria established in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 5.  Additional documents reviewed are listed in the attachment.
  4OA6    Meetings, Including Exit......................................................................................... 18
b. Findings
ATTACHMENT: SUPPLEMENTAL INFORMATION ................................................................ 18
  No findings of significance were identified.
SUPPLEMENTAL INFORMATION......................................................................................... A-1
1R12 Maintenance Effectiveness (71111.12Q - 2 samples)  
KEY POINTS OF CONTACT.................................................................................................. A-1
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ....................................................... A-1
LIST OF ACRONYMS ............................................................................................................ A-4
                                                                                                          Enclosure
 
                                            3
                                    SUMMARY OF FINDINGS
IR 05000289/2008002; 1/1/2008 - 3/31/2008; AmerGen Energy Company, LLC; Three Mile
Island, Unit 1; Routine integrated report.
The report covered a 13-week period of inspection by resident inspectors and announced
inspections by regional inspectors. No findings of significance were identified. The NRCs
program for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, Reactor Oversight Process, Rev. 3, dated July 2000.
    A. NRC-Identified and Self-Revealing Findings
        No findings of significance were identified.
    B. Licensee Identified Violations
        None.
                                                                                Enclosure
 
                                              4
                                        REPORT DETAILS
Summary of Plant Status
Three Mile Island, Unit 1 (TMI) operated at approximately 100 percent rated thermal power for
the entire inspection period.
1.      REACTOR SAFETY
        Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 1 site sample)
  a.    Inspection Scope
        Winter storms, including heavy rains and winds, elevated the Susquehanna River level
        above flood stage and affected river conditions from March 5 to 11, 2008. The
        inspectors reviewed procedures, conducted interviews, and performed various
        inspections to verify that operator actions to address adverse river conditions maintained
        the readiness of the various river water systems. Operators closely monitored National
        Weather Service flood projections and entered procedure 1202-32, Flood, Rev. 65 when
        the 36-hour forecast projected river level to reach flood stage (286.1 feet at the intake
        screen house (issue report (IR) 745543). The inspectors walked down the intake screen
        house which houses the fire protection system pumps and safety related cooling water
        pumps for the decay heat removal system, nuclear service water system, and reactor
        river water system. Additionally, after river level receded below flood stage, the
        inspectors walked down the flood dike which surrounds the entire power plant in
        accordance with procedure 3301-SA1, Dike Inspection, Rev. 12 to determine whether
        the flood barrier had been damaged or needed repair (IRs 734215, 747638). The
        inspectors evaluated the adequacy of various emergency and surveillance procedures
        associated with river water and intake systems to assess AmerGen=s protection from
        storms and adverse river conditions.
  b.    Findings
        No findings of significance were identified.
1R04 Equipment Alignment (71111.04)
  a.    Inspection Scope
        Partial System Walkdowns (71111.04Q - 3 samples)
        The inspectors performed three partial system walkdown samples on the following
        systems and components:
        *  On February 12, 2008, the inspectors walked down portions of the A decay heat
            removal and reactor building spray systems while the plant was in an unplanned
            orange risk condition due to an unexpected electrical breaker fault which made the
            B decay river water pump inoperable.
                                                                                  Enclosure
 
                                            5
    *    On February 21, the inspectors walked down portions of the B reactor building spray
          system while the plant was in a 48 hour limiting condition of operation for scheduled
          A emergency safeguards and actuation load sequence testing.
    *    On February 27 and 28, the inspectors walked down portions of the remote safe
          shutdown panel, while engineers and technicians were performing inspections of the
          engineered safeguards and actuation system relays.
    The partial system walkdowns were conducted on the redundant and standby equipment
    to ensure that trains and equipment relied on to remain operable for accident mitigation
    were properly aligned. Additional documents reviewed are listed in the attachment.
    Complete System Walkdown (71111.04S - 1 sample)
    On March 3 and 4, 2008, the inspectors performed one complete system walkdown
    sample on the B and C makeup and purification system trains, while the A system
    train was in a scheduled maintenance outage. The inspectors conducted a detailed
    review of the alignment and condition of the system using the applicable one-line
    diagram 302-560, Makeup and Purification, Rev. 44. In addition, the inspectors
    reviewed and evaluated the corrective action program reports for impact on system
    operation, interviewed the system engineer, and interviewed control room operators.
b.  Findings
    No findings of significance were identified.
1R05 Fire Protection (71111.05)
a.  Inspection Scope (71111.05Q - 8 samples)
    The inspectors conducted fire protection inspections for several plant fire zones,
    selected based on the presence of equipment important to safety within their boundaries.
    The inspectors conducted plant walkdowns and verified the areas were as described in
    the TMI Fire Hazard Analysis Report, and that fire protection features were being
    properly controlled per surveillance procedure 1038, Administrative Controls-Fire
    Protection Program, Rev. 69. The plant walkdowns were conducted throughout the
    inspection period and included assessment of transient combustible material control, fire
    detection and suppression equipment operability, and compensatory measures
    established for degraded fire protection equipment in accordance with procedure OP-
    MA-201-007, Fire Protection System Impairment Control, Rev. 5. In addition, the
    inspectors verified that applicable clearances between fire doors and floors met the
    criteria of Attachment 1 of Engineering Technical Evaluation CC-AA-309-101,
    Engineering Technical Evaluations, Rev. 9. Fire zones and areas inspected included:
    *    Fire Zone AB-FZ-2A, Auxiliary Building Elevation 281, Makeup and Purification
          Pump A;
    *    Fire Zone AB-FZ-2B, Auxiliary Building Elevation 281, Makeup and Purification
          Pump B;
    *    Fire Zone AB-FZ-3C, Auxiliary Building Elevation 281, Makeup and Purification
          Pump C;
    *    Fire Zone DG-FA-1, Diesel Generator Building Elevation 305, Diesel Generator A;
    *    Fire Zone DG-FA-2, Diesel Generator Building Elevation 305, Diesel Generator B;
    *    Fire Zone TB-FA-1, Turbine Building Elevation 305
                                                                                Enclosure
 
                                            6
    *  Fire Zone TB-FA-1, Turbine Building Elevation 322
    *  Fire Zone TB-FA-1, Turbine Building Elevation 355
b.  Findings
    No findings of significance were identified.
1R11 Licensed Operator Requalification Program (71111.11Q - 1 sample)
a.  Inspection Scope
    On March 18, 2008, the inspectors observed licensed operator requalification training at
    the control room simulator for the E operator crew. The inspectors observed the
    operators simulator drill performance and compared it to the criteria listed in TMI
    Operational Simulator Scenario Number 12, Condenser Vacuum Leak, Stuck Rod, Loss
    of Offsite Power with Diesel and Emergency Feedwater Failures, Rev. 12. The
    inspectors reviewed the operators ability to correctly evaluate the simulator training
    scenario and implement the emergency plan. The inspectors observed supervisory
    oversight, command and control, communication practices, and crew assignments to
    ensure they were consistent with normal control room activities. The inspectors
    observed operator response during the simulator drill transients. The inspectors
    evaluated training instructor effectiveness in recognizing and correcting individual and
    operating crew errors. The inspectors attended the post-drill critiques in order to
    evaluate the effectiveness of problem identification. The inspectors verified that
    emergency plan classification and notification training opportunities were tracked and
    evaluated for success in accordance with criteria established in Nuclear Energy Institute
    (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 5.
    Additional documents reviewed are listed in the attachment.
b.  Findings
    No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12Q - 2 samples)
a.  Inspection Scope
    The inspectors evaluated the listed samples for Maintenance Rule (MR) implementation
    by ensuring appropriate MR scoping, characterization of failed structures, systems, and
    components (SSCs), MR risk categorization of SSCs, SSC performance criteria or goals,
    and appropriateness of corrective actions. Additionally, extent of condition follow-up,
    operability, and functional failure determinations were reviewed to verify they were
    appropriate. The inspectors verified that the issues were addressed as required by 10
    CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear
    Power Plants; Nuclear Management and Resources Council (NUMARC) 93-01, Industry
    Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Rev.
    2; and AmerGen procedure ER-AA-310, Implementation of the Maintenance Rule, Rev.
    6. The inspectors verified that appropriate corrective actions were initiated and
    documented in IRs, and that engineers properly categorized failures as maintenance
    rule functional failures and maintenance preventable functional failures, when applicable.
                                                                                Enclosure
 
                                            7
    *  IR 735277 describes the failure of DR-P-1B to start from the control room. AmerGen
        identified the failure as a Maintenance Rule Functional Failure. Since the cause of
        the failure was attributed to an isolated manufacturing defect, AmerGen determined
        that it was not a Maintenance Preventable Functional Failure. As such, the 10 CFR
        50.65 a(2) determination remains valid.
    *  The inspectors reviewed the TMI hydrogen monitoring system to ensure it was being
        effectively controlled and maintained such that the system remained capable of
        performing its intended function. This inspection sample was based on an NRC
        maintenance rule finding identified in March 2007, at another nuclear power plant
        regarding ineffective controls of the performance and condition of the hydrogen
        monitoring system.
b.  Findings
    No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples)
   a. Inspection Scope
   a. Inspection Scope
  The inspectors evaluated the listed samples for Maintenance Rule (MR) implementation by ensuring appropriate  MR scoping, characterization of failed structures, systems, and components (SSCs), MR risk categorization of SSCs, SSC performance criteria or goals,  
    The inspectors reviewed the scheduling, control, and restoration during the following
and appropriateness of corrective actionsAdditionally, extent of condition follow-up, operability, and functional failure determinations were reviewed to verify they were appropriate.  The inspectors verified that the issues were addressed as required by 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants; Nuclear Management and Resources Council (NUMARC) 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Rev. 2; and AmerGen procedure ER-AA-310, Implementation of the Maintenance Rule, Rev.  
    maintenance activities to evaluate their effect on plant risk. This review was against
6.  The inspectors verified that appropriate corrective actions were initiated and documented in IRs, and that engineers properly categorized failures as maintenance rule functional failures and maintenance preventable functional failures, when applicable.  
    criteria contained in AmerGen Administrative Procedure 1082.1, TMI Risk Management
 
    Program, Rev. 7 and WC-AA-101, On-Line Work Control Process, Rev. 14.
7    Enclosure 
    *  From December 27, 2007 thru January 4, 2008, the TMI sodium hydroxide (NaOH)
* IR 735277 describes the failure of DR-P-1B to start from the control room. AmerGen identified the failure as a Maintenance Rule Functional Failure.  Since the cause of the failure was attributed to an isolated manufacturing defect, AmerGen determined that it was not a Maintenance Preventable Functional FailureAs such, the 10 CFR
        chemical used to achieve a uniform pH in containment post accident was changed to
50.65 a(2) determination remains valid. 
        trisodium phosphate per modification ECR 07-174. The online maintenance risk
* The inspectors reviewed the TMI hydrogen monitoring system to ensure it was being effectively controlled and maintained such that the system remained capable of performing its intended functionThis inspection sample was based on an NRC maintenance rule finding identified in March 2007, at another nuclear power plant regarding ineffective controls of the performance and condition of the hydrogen
        profile remained green during this evolution (Risk Document 1254, Rev. 3).
monitoring system.  
    *  On January 22, 2008, emergency feedwater valve EFW-V-30B was taken out of
  b. Findings
        service for scheduled overhaul of the air actuator. The condition elevated the online
  No findings of significance were identified.  
        maintenance risk profile to yellow (Risk Document 1020, Rev. 4).
    *  On February 12, the B decay river water pump (DR-P-1B) failed to start due to a
        faulted starting relay (IRs 735277 and 735778). The condition elevated the online
        maintenance risk profile to orange (Risk Document 1195, Rev. 3).
    *  On February 12, the C makeup pump auxiliary lubricating oil pump (MU-P-2C) did
        not auto start as expected during a scheduled surveillance test due to a failed
        pressure switch (IR-735063). This condition did not affect operability of MU-P-1C.
        On February 13, after DR-P-1B was returned to service and the on-line risk had been
        returned to green, technicians replaced the failed pressure switch. This work
        elevated the online maintenance risk profile to yellow (Risk Document 1066, Rev. 2).
    *  On February 27, a contact for a reactor building emergency cooling and isolation
        relay 63X-RB6B was replaced due to intermittent indication. The online maintenance
        risk profile remained green during this evolution (Risk Document 551, Rev. 8).
                                                                              Enclosure
 
                                            8
b.  Findings
    No findings of significance were identified.
1R15 Operability Evaluations (71111.15 - 3 samples)
aInspection Scope
    The inspectors verified that degraded conditions in question were properly characterized,
    operability of the affected systems was properly evaluated in relation to Technical
    Specification (TS) requirements, applicable extent of condition reviews were performed,
    and no unrecognized increase in plant risk resulted from the equipment issues. The
    inspectors referenced NRC Inspection Manual Chapter (IMC) Part 9900, Operability
    Determinations & Functionality Assessments For Resolution of Degraded or
    Nonconforming Conditions Adverse to Quality or Safety and AmerGen procedure OP-
    AA-108-115, Operability Determinations, Rev. 5, to determine acceptability of the
    operability evaluations. The inspectors reviewed operability evaluations for the following
    degraded equipment issues:
    *  On December 4, 2007, NS-P-1A breaker operating mechanism became bound
        during breaker inspection (WO-R2039072). This condition occurred after the breaker
        had been cycled satisfactorily eight times. An analysis performed by the
        manufacturer determined that this condition affected only the manual closure of the
        breaker which is used for maintenance and would not come into play during normal
        auto electrical operation of the breaker. Therefore, NS-P-1A operability was not
        impacted (IRs 707261 and 730312).
    *  On December 11, SF-P-1A inadvertently tripped during surveillance testing per 1303-
        4.19, HPI/LPI Analog Channel test, Rev. 26. Engineers determined the cause was a
        misaligned contact in ESAS load shed relay 63Z1B-RC2A. Operability of SF-P-1A
        was not affected because the relay function to trip the pump upon an ESAS actuation
        was not affected (IR-710133).
    *  On January 2, 2008, operators and technicians identified that the reactor building
        emergency cooling and isolation system channel RB2A failed to actuate during
        performance of ESAS surveillance testing. Engineers determined that this condition
        only affected the test circuit and not the safety portion of the circuit (IRs-717254 and
        725846).
b.  Findings
    No findings of significance were identified.
1R18 Plant Modifications (71111.18 - 1 sample)
aInspection Scope
    The inspectors reviewed the following modification to determine whether it was designed
    and/or implemented as required by CC-AA-102, Design Input and Configuration Change
    Impact Screening, Rev. 14 and CC-AA-103, Configuration Change Control, Rev. 17.
    The inspectors verified the modification supported plant operation as described in the
                                                                                  Enclosure
 
                                            9
    Updated Final Safety Analysis Report (UFSAR) and complied with associated TS
    requirements. The inspectors reviewed the function of the changed component, the
    change description and scope, and the associated 10 CFR 50.59 screening evaluation.
      *  Engineering Change Request (ECR) # 06-595, Decay River Strainer, Rev. 0 was
          installed to replace the funnel type strainer media with a flat metal disc media to
          reduce the potential for clogging by filamentous algae. This algae caused
          excessive strainer clogging in May 2006 due to a bloom associated with lower than
          usual river levels. The inspectors also reviewed IR-588605 which evaluated a
          higher than expected differential pressure result during post installation testing of
          the new media. Engineers determined that the higher differential pressure was due
          to improper design of the media (lesser number of holes). The evaluation also
          determined that this media did not affect operability of the strainer and decay river
          system. The inspectors verified corrective actions including revision to the ECR to
          specify the correct number of holes for the media. In addition, actions to replace
          the existing media with the proper design are scheduled for May 2008.
b.  Findings
    No findings of significance were identified.
1R19 Post Maintenance Testing (71111.19 - 7 samples)
aInspection Scope
    The inspectors reviewed and/or observed the following post-maintenance test (PMT)
    activities to ensure: (1) the PMT was appropriate for the scope of the maintenance work
    completed; (2) the acceptance criteria were clear and demonstrated operability of the
    component; and (3) the PMT was performed in accordance with procedures.
    *  On December 12, 2007, operators performed post maintenance testing in
        accordance with 1303-4.19, HPI/LPI Analog Channel Test, Interim Change 24193,
        following replacement of a misaligned contact that caused an inadvertent trip of SF-
        P-1A (Ref: Section 71111.15). The inspectors reviewed the PMT scope adequacy
        and results to ensure the PMT addressed the results of additional relay failure
        analysis performed in January 2008.
    *  On January 23, 2008 operators performed post maintenance testing in accordance
        with OP-TM-424-212, IST of EF-V-30s and EF-V-52s, Rev.2, following replacement
        of the actuator for EFW-V-30B.
    *  On January 24, operators performed post maintenance testing in accordance with
        1303-4.13, RB Emergency Cooling and Isolation System Analog Test, Rev. 40, and
        Interim Change 24192, following replacement of multiple components to address a
        relay (T2/RB2A) failure to de-energize (IR-725846).
    *   On February 13, operators performed post maintenance testing of DR-P-1B in
        accordance with Work Order C2016938 following replacement of a faulted X-relay
        within electrical circuit breaker DR-P-1B-BK.
                                                                                Enclosure
 
                                            10
    *  Control building chiller AH-C-4B was degraded, due to developing insufficient oil
        pressure upon starting from a standby condition. Technicians implemented a
        complex troubleshooting plan including oil samples, auxiliary oil pump voltage and
        current readings, replacement of the auxiliary pump and motor, and borescope
        inspection of the auxiliary oil system and compressor work order C2016844. Post
        maintenance tests were performed from February 15 to March 11, using C2016844
        and E-108, Control Building Chiller AH-C-4A/B Weekly, Quarterly, and Annual
        Inspection, Interim Change 19851.
    *  On February 27, operators performed post maintenance testing of ESAS relay 63X-
        RB6B, in accordance with procedure 1303-4.14, RB 30 PSIG Analog Channels,
        Interim Change 24839, following replacement of a contact that was providing
        intermittent indication.
    *  On March 27, CM-V-3 open and close strokes were successfully verified using
        procedure 1300-3Q.5, Quarterly Inservice Testing of CM-V-1/2/3/4 Valves During
        Normal Plant Operations, Rev. 1 following troubleshooting to address excessive
        valve closure stroke time.
bFindings
    No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a.  Inspection Scope (3 Inservice Testing Samples and 2 Routine Surveillance Samples)
    The inspectors observed and/or reviewed the following operational surveillance tests to
    verify adequacy of the test to demonstrate the operability of the required system or
    component safety function. Inspection activities included review of previous surveillance
    history to identify previous problems and trends, observation of pre-evolution briefings,
    and initiation/resolution of related IRs for selected surveillances.
    *    From December 27, 2007 to January 2, 2008, procedure OP-TM-214-211,
          Verification of TSP, Rev. 0
    *    On January 2, 2008, 1303-4.13, RB Emergency Cooling and Isolation System
          Analog Test, Rev. 40 and Interim Change 24192.
    *    On February 6, procedure OP-TM-211-248, Boric Acid Injection System Functional
          Test, Rev. 0
    *    On February 12, procedure OP-TM-211-208, IST Of MU-P-1C, Rev. 2
    *    On February 12, procedure OP-TM-211-251, Leakage Exam Of MU System, Interim
          Change 23462
b.  Findings
    No findings of significance were identified.
1EP6 Drill Evaluation (71114.06)
aInspection Scope (1 Training Evolution Sample)
                                                                              Enclosure
 
                                            11
    The inspectors observed an emergency event training evolution conducted on March 18,
    2008, at the Unit 1 control room simulator to evaluate emergency procedure
    implementation, event classification, and event notification. The event scenario involved
    multiple safety-related component failures and plant conditions warranting simulated
    Unusual Event and Alert emergency event declarations. The inspectors observed the
    drill critique to determine whether the licensee critically evaluated drill performance to
    identify deficiencies and weaknesses. Additionally, the inspectors verified the
    Drill/Exercise performance indicators were properly evaluated consistent with NEI 99-02,
    Regulatory Assessment Performance Indicator Guideline, Rev. 5. Additional documents
    reviewed are listed in the Attachment.
b. Findings
    No findings of significance were identified.
2.  RADIATION SAFETY
      Cornerstone:Occupational Radiation Safety
20S1 Access Controls (71121.01 - 4 samples)
a.  Inspection Scope
    The inspectors reviewed selected activities and associated documentation in the below
    listed areas. The evaluation of AmerGens performance in these areas was against
    criteria contained in 10 CFR 20, applicable TSs, and applicable AmerGen procedures.
    Plant Walkdowns, Radiation Work Permit Reviews, Job Reviews
    The inspectors walked down selected radiological controlled areas and reviewed
    housekeeping, material conditions, posting, barricading, and access controls to
    radiological areas. The inspectors toured areas of the Auxiliary Building, Spent Fuel
    Area, outdoor areas, and radioactive waste processing area. The inspectors conducted
    selective independent radiation surveys, and verified the adequacy of: selected
    radiological boundaries and postings; that engineering controls were in place; that air
    samplers were properly located; and that TS locked High Radiation Areas (HRA) were
    properly secured and posted.
    The inspectors selectively reviewed the applied radiological controls for personnel entry
    into the Unit 1 reactor building containment at power on March 3, 2008, and movement
    of concentrated radioactive waste on March 6, 2008. The reviews included evaluation of
    the adequacy of all applied radiological controls including radiation work permits,
    procedure adherence, radiological surveys, job coverage, airborne radioactivity sampling
    and controls, and contamination controls. The reviews included, where applicable,
    barrier integrity and the application of engineering controls for potential airborne
    radioactivity areas and radioactive source-term, and radiation levels present. The
    inspectors attended the briefing for workers involved in radioactive waste handling.
    The inspectors also reviewed and discussed electronic dosimeter and
    thermoluminescent dosimeter results to identify anomalies and licensee actions, as
    applicable.
                                                                                  Enclosure


1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples)
                                            12
  a. Inspection Scope
    The inspectors reviewed and discussed internal dose assessments for 2007 to identify
  The inspectors reviewed the scheduling, control, and restoration during the following maintenance activities to evaluate their effect on plant risk.  This review was against criteria contained in AmerGen Administrative Procedure 1082.1, TMI Risk Management Program, Rev. 7 and WC-AA-101, On-Line Work Control Process, Rev. 14. 
    any apparent actual occupational internal doses greater than 50 millirem committed
* From December 27, 2007 thru January 4, 2008, the TMI sodium hydroxide (NaOH) chemical used to achieve a uniform pH in containment post accident was changed to trisodium phosphate per modification ECR 07-174. The online maintenance risk profile remained green during this evolution (Risk Document 1254, Rev. 3).
    effective dose equivalent. The inspectors assessed the adequacy of evaluations for
* On  January 22, 2008, emergency feedwater valve EFW-V-30B was taken out of service for scheduled overhaul of the air actuator.  The condition elevated the online maintenance risk profile to yellow (Risk Document 1020, Rev. 4).
    selected dose assessments and included selected review of the program for evaluation
* On February 12, the 'B' decay river water pump (DR-P-1B) failed to start due to a faulted starting relay (IRs 735277 and 735778).  The condition elevated the online maintenance risk profile to orange (Risk Document 1195, Rev. 3).
    of potential intakes associated with hard-to-detect radionuclides (e.g., airborne
  * On February 12, the 'C' makeup pump auxiliary lubricating oil pump (MU-P-2C) did not auto start as expected during a scheduled surveillance test due to a failed pressure switch (IR-735063).  This condition did not affect operability of MU-P-1C. On February 13, after DR-P-1B was returned to service and the on-line risk had been returned to green, technicians replaced the failed pressure switch. This work elevated the online maintenance risk profile to yellow (Risk Document 1066, Rev. 2).  
    transuranics).
* On February 27, a contact for a reactor building emergency cooling and isolation relay 63X-RB6B was replaced due to intermittent indication.  The online maintenance risk profile remained green during this evolution (Risk Document 551, Rev. 8).  
    High Risk Significant, High Dose Rate HRA and Very High Radiation Area Controls
 
    The inspectors conducted a selective review of HRA controls (e.g., adequate posting
8    Enclosure    b. Findings
    and locking of entrances). The inspectors verified that locked HRAs were properly
 
    secured and posted and that surrounding area dose rates met regulatory criteria. The
No findings of significance were identified.
    inspectors reviewed and observed controls used for ongoing work such as waste
1R15 Operability Evaluations (71111.15 - 3 samples)  
    transfer. The inspectors verified procedure adherence by observation, attendance at
  a. Inspection Scope
    briefings, and questioning radiation protection personnel and workers.
  The inspectors verified that degraded conditions in question were properly characterized, operability of the affected systems was properly evaluated in relation to Technical Specification (TS) requirements, applicable extent of condition reviews were performed, and no unrecognized increase in plant risk resulted from the equipment issues. The  
    Radiation Worker/Radiation Protection Technician Performance and Radiation
inspectors referenced NRC Inspection Manual Chapter (IMC) Part 9900, Operability Determinations & Functionality Assessments For Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety and AmerGen procedure OP-AA-108-115, Operability Determinations, Rev. 5, to determine acceptability of the operability evaluations.  The inspectors reviewed operability evaluations for the following degraded equipment issues:
    Protection Technician Proficiency
* On December 4, 2007, NS-P-1A breaker operating mechanism became bound during breaker inspection (WO-R2039072).  This condition occurred after the breaker had been cycled satisfactorily eight times.  An analysis performed by the manufacturer determined that this condition affected only the manual closure of the breaker which is used for maintenance and would not come into play during normal auto electrical operation of the breaker.  Therefore, NS-P-1A operability was not impacted (IRs 707261 and 730312).
    The inspectors evaluated radiation protection technician performance and proficiency
* On December 11, SF-P-1A inadvertently tripped during surveillance testing per 1303-4.19, HPI/LPI Analog Channel test, Rev. 26.  Engineers determined the cause was a misaligned contact in ESAS load shed relay 63Z1B-RC2A.  Operability of SF-P-1A was not affected because the relay function to trip the pump upon an ESAS actuation was not affected (IR-710133). 
    relative to control of hazards and work activities, as applicable. In addition, the
* On January 2, 2008, operators and technicians identified that the reactor building emergency cooling and isolation system channel RB2A failed to actuate during performance of ESAS surveillance testing. Engineers determined that this condition only affected the test circuit and not the safety portion of the circuit (IRs-717254 and 725846).  b. Findings
    inspectors reviewed issue reports to identify problems with worker or radiation protection
  No findings of significance were identified.
    technician performance.
1R18 Plant Modifications (71111.18 - 1 sample)
    Problem Identification and Resolution
a. Inspection Scope
    The inspectors selectively reviewed self-assessments and audits since the previous
  The inspectors reviewed the following modification to determine whether it was designed and/or implemented as required by CC-AA-102, Design Input and Configuration Change Impact Screening, Rev. 14 and CC-AA-103, Configuration Change Control, Rev. 17. 
    inspection to determine if identified problems were entered into the corrective action
The inspectors verified the modification supported plant operation as described in the 
    program for resolution. The inspectors evaluated the corrective action program
9    Enclosure  Updated Final Safety Analysis Report (UFSAR) and complied with associated TS requirements.  The inspectors reviewed the function of the changed component, the
    database for repetitive deficiencies or significant individual deficiencies to determine if
change description and scope, and the associated 10 CFR 50.59 screening evaluation.
    self-assessment activities were identifying and addressing the deficiencies.
* Engineering Change Request (ECR) # 06-595, Decay River Strainer, Rev. 0 was installed to replace the funnel type strainer media with a flat metal disc media to reduce the potential for clogging by filamentous algae.  This algae caused excessive strainer clogging in May 2006 due to a bloom associated with lower than usual river levels. The inspectors also reviewed IR-588605 which evaluated a
    The review included an evaluation of data to determine if any problems involved
higher than expected differential pressure result during post installation testing of the new media.  Engineers determined that the higher differential pressure was due to improper design of the media (lesser number of holes).  The evaluation also determined that this media did not affect operability of the strainer and decay river system.  The inspectors verified corrective actions including revision to the ECR to
    performance indicator (PI) events with dose rates greater that 25 R/hr at 30 centimeters,
specify the correct number of holes for the media. In addition, actions to replace the existing media with the proper design are scheduled for May 2008. 
    greater than 500 R/hr at 1 meter or unintended exposures greater than 100 millirem total
b. Findings
    effective dose equivalent, 5 rem shallow dose equivalent, or 1.5 rem lens dose
  No findings of significance were identified.
    equivalent. The inspectors also reviewed the corrective action database for non-PI
1R19 Post Maintenance Testing (71111.19 - 7 samples)
    radiological incidents to determine if follow-up activities were being conducted in an
  a. Inspection Scope
    effective and timely manner consistent with radiological risk.
  The inspectors reviewed and/or observed the following post-maintenance test (PMT)
    The inspectors reviewed selected issue reports since the last inspection which involved
activities to ensure:  (1) the PMT was appropriate for the scope of the maintenance work completed; (2) the acceptance criteria were clear and demonstrated operability of the component; and (3) the PMT was performed in accordance with procedures. 
    potential radiation worker or radiation protection personnel errors to determine if there
* On December 12, 2007, operators performed post maintenance testing in accordance with 1303-4.19, HPI/LPI Analog Channel Test, Interim Change 24193, following replacement of a misaligned contact that caused an inadvertent trip of SF-
    was an observable pattern traceable to a similar cause. The review included an
P-1A (Ref: Section 71111.15).  The inspectors reviewed the PMT scope adequacy and results to ensure the PMT addressed the results of additional relay failure analysis performed in January 2008.
    evaluation of corrective actions, as appropriate. (Section 4OA2)
  * On January 23, 2008 operators performed post maintenance testing in accordance with OP-TM-424-212, IST of EF-V-30s and EF-V-52s, Rev.2, following replacement of the actuator for EFW-V-30B.
  * On January 24, operators performed post maintenance testing in accordance with 1303-4.13, RB Emergency Cooling and Isolation System Analog Test, Rev. 40, and Interim Change 24192, following replacement of multiple components to address a relay (T2/RB2A) failure to de-energize (IR-725846).
  * On February 13, operators performed post maintenance testing of DR-P-1B in accordance with Work Order C2016938 following replacement of a faulted X-relay within electrical circuit breaker DR-P-1B-BK.
 
10    Enclosure 
* Control building chiller AH-C-4B was degraded, due to developing insufficient oil pressure upon starting from a standby condition.  Technicians implemented a complex troubleshooting plan including oil samples, auxiliary oil pump voltage and current readings, replacement of the auxiliary pump and motor, and borescope
inspection of the auxiliary oil system and compressor work order C2016844.  Post maintenance tests were performed from February 15 to March 11, using C2016844 and E-108, Control Building Chiller AH-C-4A/B Weekly, Quarterly, and Annual Inspection, Interim Change 19851.
  * On February 27, operators performed post maintenance testing of ESAS relay 63X-RB6B, in accordance with procedure 1303-4.14, RB 30 PSIG Analog Channels, Interim Change 24839, following replacement of a contact that was providing intermittent indication.
* On March 27, CM-V-3 open and close strokes were successfully verified using procedure 1300-3Q.5, Quarterly Inservice Testing of CM-V-1/2/3/4 Valves During Normal Plant Operations, Rev. 1 following troubleshooting to address excessive valve closure stroke time.  
  b. Findings
  No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
  a. Inspection Scope (3 Inservice Testing Samples and 2 Routine Surveillance Samples)
The inspectors observed and/or reviewed the following operational surveillance tests to verify adequacy of the test to demonstrate the operability of the required system or component safety function. Inspection activities included review of previous surveillance
history to identify previous problems and trends, observation of pre-evolution briefings, and initiation/resolution of related IRs for selected surveillances.
* From December 27, 2007 to January 2, 2008, procedure OP-TM-214-211, Verification of TSP, Rev. 0
* On January 2, 2008, 1303-4.13, RB Emergency Cooling and Isolation System Analog Test, Rev. 40 and Interim Change 24192.
* On February 6, procedure OP-TM-211-248, Boric Acid Injection System Functional Test, Rev. 0
* On February 12, procedure OP-TM-211-208, IST Of MU-P-1C, Rev. 2
* On February 12, procedure OP-TM-211-251, Leakage Exam Of MU System, Interim Change 23462
  b.  Findings
  b.  Findings
  No findings of significance were identified.  
    No findings of significance were identified.
1EP6 Drill Evaluation (71114.06)  
2OS2 ALARA Planning and Controls (71121.02 - 2 samples)
  a. Inspection Scope (1 Training Evolution Sample)
a. Inspection Scope
 
                                                                                Enclosure
11    Enclosure  The inspectors observed an emergency event training evolution conducted on March 18, 2008, at the Unit 1 control room simulator to evaluate emergency procedure
 
implementation, event classification, and event notification. The event scenario involved multiple safety-related component failures and plant conditions warranting simulated Unusual Event and Alert emergency event declarations.  The inspectors observed the drill critique to determine whether the licensee critically evaluated drill performance to identify deficiencies and weaknesses. Additionally, the inspectors verified the  
                                        13
Drill/Exercise performance indicators were properly evaluated consistent with NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 5. Additional documents reviewed are listed in the Attachment.  
The inspectors conducted the following activities to determine if AmerGen was properly
  b. Findings
implementing operational, engineering, and administrative controls to maintain personnel
  No findings of significance were identified.  
occupational radiation exposure as low as is reasonably achievable (ALARA).
Implementation of these controls was reviewed against the criteria contained in 10 CFR
2. RADIATION SAFETY
20, applicable industry standards, and applicable AmerGen procedures.
  Cornerstone: Occupational Radiation Safety
Inspection Planning, Radiological Work Planning
20S1 Access Controls (71121.01 - 4 samples)  
The inspectors determined the plants current 3-year rolling average collective exposure.
  a. Inspection Scope
The inspectors evaluated site specific trends in collective exposures (using NUREG-
  The inspectors reviewed selected activities and associated documentation in the below  
0713 and plant historical data). The inspectors discussed proposed occupational
listed areas. The evaluation of AmerGen's performance in these areas was against criteria contained in 10 CFR 20, applicable TSs, and applicable AmerGen procedures.  
radiation exposure estimates for 2008.
  Plant Walkdowns, Radiation Work Permit Reviews, Job Reviews
Job Site Inspections and ALARA Controls
  The inspectors walked down selected radiological controlled areas and reviewed housekeeping, material conditions, posting, barricading, and access controls to radiological areas.  The inspectors toured areas of the Auxiliary Building, Spent Fuel Area, outdoor areas, and radioactive waste processing area.  The inspectors conducted selective independent radiation surveys, and verified the adequacy of: selected
The inspectors observed ongoing work activities (e.g., radioactive waste handling) to
radiological boundaries and postings; that engineering controls were in place; that air samplers were properly located; and that TS locked High Radiation Areas (HRA) were properly secured and posted.  
evaluate implementation of ALARA controls for the activities. The inspectors reviewed
The inspectors selectively reviewed the applied radiological controls for personnel entry
exposures of individuals from selected work groups to identify significant exposure
into the Unit 1 reactor building containment at power on March 3, 2008, and movement of concentrated radioactive waste on March 6, 2008. The reviews included evaluation of the adequacy of all applied radiological controls including radiation work permits, procedure adherence, radiological surveys, job coverage, airborne radioactivity sampling and controls, and contamination controls. The reviews included, where applicable, barrier integrity and the application of engineering controls for potential airborne radioactivity areas and radioactive source-term, and radiation levels present.  The
variations which may exist among workers.
inspectors attended the briefing for workers involved in radioactive waste handling.
Verification of Dose Estimates and Exposure Tracking
The inspectors also reviewed and discussed electronic dosimeter and thermoluminescent dosimeter results to identify anomalies and licensee actions, as applicable.  
The inspectors reviewed Station ALARA Committee and sub-committee meeting minutes
 
for the fall 2007 outage and post-outage to date. The inspectors compared aggregate
12    Enclosure  The inspectors reviewed and discussed internal dose assessments for 2007 to identify any apparent actual occupational internal doses greater than 50 millirem committed
exposure sustained per work activity, with initial estimates, to evaluate effectiveness of
effective dose equivalent.  The inspectors assessed the adequacy of evaluations for selected dose assessments and included selected review of the program for evaluation of potential intakes associated with hard-to-detect radionuclides (e.g., airborne transuranics).
ALARA actions and accuracy of dose estimates. The inspectors compared results
  High Risk Significant, High Dose Rate HRA and Very High Radiation Area Controls
achieved with the intended dose established for the work tasks reviewed.
  The inspectors conducted a selective review of HRA controls (e.g., adequate posting and locking of entrances).  The inspectors verified that locked HRAs were properly secured and posted and that surrounding area dose rates met regulatory criteria.  The
Source-Term Reduction and Control
inspectors reviewed and observed controls used for ongoing work such as waste transfer.  The inspectors verified procedure adherence by observation, attendance at briefings, and questioning radiation protection personnel and workers.
The inspectors reviewed and discussed AmerGens understanding of the Unit 1 plant
Radiation Worker/Radiation Protection Technician Performance and Radiation Protection Technician Proficiency
source-term, including knowledge of input mechanisms to reduce the source term, and
  The inspectors evaluated radiation protection technician performance and proficiency relative to control of hazards and work activities, as applicable.  In addition, the inspectors reviewed issue reports to identify problems with worker or radiation protection technician performance.  
the source-term control strategy in place. The inspectors reviewed reactor coolant
  Problem Identification and Resolution
chemistry data to evaluate the effectiveness of post shutdown source-term reduction
  The inspectors selectively reviewed self-assessments and audits since the previous inspection to determine if identified problems were entered into the corrective action program for resolution. The inspectors evaluated the corrective action program
efforts including strategies employed such as system flushes, installation of temporary
database for repetitive deficiencies or significant individual deficiencies to determine if self-assessment activities were identifying and addressing the deficiencies.  
shielding, and chemistry controls. The inspectors reviewed efforts to reduce Unit 1
  The review included an evaluation of data to determine if any problems involved performance indicator (PI) events with dose rates greater that 25 R/hr at 30 centimeters,
reactor cavity and spent fuel pool radionuclide concentrations in support of ongoing work
greater than 500 R/hr at 1 meter or unintended exposures greater than 100 millirem total effective dose equivalent, 5 rem shallow dose equivalent, or 1.5 rem lens dose equivalent.  The inspectors also reviewed the corrective action database for non-PI radiological incidents to determine if follow-up activities were being conducted in an effective and timely manner consistent with radiological risk.  
activities.
The inspectors reviewed selected issue reports since the last inspection which involved potential radiation worker or radiation protection personnel errors to determine if there was an observable pattern traceable to a similar cause.  The review included an evaluation of corrective actions, as appropriate. (Section 4OA2)
Radiation Worker/Radiation Protection Technician Performance
  b. Findings
The inspectors selectively observed radiation worker and radiation protection technician
  No findings of significance were identified.  
performance in the area of ALARA practices during transfer of radioactive materials on
2OS2 ALARA Planning and Controls (71121.02 - 2 samples)  
March 6, 2008. The inspectors selectively questioned workers and radiation protection
personnel in the field to evaluate their understanding of ambient radiological conditions.
The inspectors evaluated performance to determine whether the training/skill level was
sufficient with respect to the radiological hazards involved.
Problem Identification and Resolution
                                                                          Enclosure
 
                                            14
      The inspectors selectively reviewed issue reports in this area since the last inspection to
      determine if AmerGen was including ALARA deficiencies and issues in its corrective
      action program. (See Section 4OA2)
      The review included self-assessments, audits, and corrective action reports related to
      the ALARA program since the last inspection to determine if the follow-up activities were
      being conducted in an effective and timely manner commensurate with their importance
      to safety and risk.
b.   Findings
      No findings of significance were identified.
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 1 sample)
a.   Inspection Scope
      The inspectors reviewed selected activities and associated documentation in the below
      listed areas. The evaluation of AmerGens performance in these areas was against
      criteria contained in 10 CFR 20, applicable TSs, and applicable station procedures.
      Self-Contained Breathing Apparatus
      The inspectors reviewed the functional testing and inspection of self-contained breathing
      apparatus (SCBA) to ensure equipment was being properly maintained and inspected in
      accordance with the manufacturers recommendations and applicable regulatory
      requirements. The functional testing of three SCBA units, ready for use in the Unit 1
      Control Room, was reviewed (Kit Nos. 1, 2, 3). The inspectors also visually inspected
      the SCBA kits and additional mask units. The components of the three kits were also
      checked against approved component lists published by the SCBA manufacturer and the
      National Institute for Occupational Safety and Health. The inspectors reviewed periodic
      testing of the SCBA units components (i.e., hydro testing of tank, maintenance and
      testing of regulators, low pressure alarms) and reviewed conformance of the SCBAs with
      published certification lists.
      Problem Identification and Resolution
      The inspectors reviewed issue reports in this area since the last inspection to determine
      if AmerGen was including instrument deficiencies and issues in its corrective action
      program (Section 4OA2). The review included self-assessments, audits, and corrective
      action reports.
  b.  Findings
      No findings of significance were identified.
Cornerstone: Public Radiation Safety
2PS2 Radioactive Material Processing and Transportation (71122.02 - 1 sample)
a.   Inspection Scope
                                                                              Enclosure
 
                                            15
    The inspectors selectively reviewed the packaging and shipment preparation of a non-
    exempt radioactive material shipment (RS-08-029-1). Matters reviewed included:
    packaging and vehicle radiation dose rates; placarding of vehicle; completion of
    applicable shipping papers; qualification of personnel overseeing and processing
    shipment; emergency instructions; general truck and trailer condition; closure and use
    requirements.
    The inspectors also selectively reviewed training provided for station personnel relative
    to 49 CFR 172, and NRC Bulletin 79 -19.
  b. Findings
    No findings of significance were identified.
4.  OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151 - 3 samples)
   a. Inspection Scope
   a. Inspection Scope
 
    Cornerstone: Initiating Events
13    Enclosure 
    The inspectors reviewed selected station records to verify NRC PIs had been accurately
The inspectors conducted the following activities to determine if AmerGen was properly
    reported to the NRC as specified in NEI 99-02, Regulatory Assessment Performance
implementing operational, engineering, and administrative controls to maintain personnel occupational radiation exposure as low as is reasonably achievable (ALARA).  Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and applicable AmerGen procedures.
    Indicator Guideline, Rev. 5. The three PI samples listed below were verified for the
Inspection Planning, Radiological Work Planning
    period January to December 2007.
  The inspectors determined the plant's current 3-year rolling average collective exposure. The inspectors evaluated site specific trends in collective exposures (using NUREG-0713 and plant historical data). The inspectors discussed proposed occupational
    $        Unplanned Scrams per 7000 Critical Hours
radiation exposure estimates for 2008.
    $        Unplanned Scrams with Complications
Job Site Inspections and ALARA Controls
    $        Unplanned Power Changes per 7000 Critical Hours
  The inspectors observed ongoing work activities (e.g., radioactive waste handling) to evaluate implementation of ALARA controls for the activities. The inspectors reviewed exposures of individuals from selected work groups to identify significant exposure
    The inspectors reviewed operator logs, licensee event reports, monthly station operating
variations which may exist among workers.
    reports, corrective action program database documents, calculation methods, definition
  Verification of Dose Estimates and Exposure Tracking
    of terms, and use of clarifying notes. The inspectors also verified accuracy of the
  The inspectors reviewed Station ALARA Committee and sub-committee meeting minutes
    number of reported critical hours used in the calculations.
for the fall 2007 outage and post-outage to date.  The inspectors compared aggregate exposure sustained per work activity, with initial estimates, to evaluate effectiveness of ALARA actions and accuracy of dose estimates. The inspectors compared results achieved with the intended dose established for the work tasks reviewed.  
   b. Findings
Source-Term Reduction and Control
    No findings of significance were identified.
   The inspectors reviewed and discussed AmerGen's understanding of the Unit 1 plant source-term, including knowledge of input mechanisms to reduce the source term, and the source-term control strategy in place. The inspectors reviewed reactor coolant
4OA2 Identification and Resolution of Problems (71152)
chemistry data to evaluate the effectiveness of post shutdown source-term reduction efforts including strategies employed such as system flushes, installation of temporary shielding, and chemistry controls. The inspectors reviewed efforts to reduce Unit 1 reactor cavity and spent fuel pool radionuclide concentrations in support of ongoing work activities.  
.1   Review of Issue Reports and Cross-References to Problem Identification and Resolution
Radiation Worker/Radiation Protection Technician Performance
    Issues Reviewed Elsewhere
   The inspectors selectively observed radiation worker and radiation protection technician performance in the area of ALARA practices during transfer of radioactive materials on March 6, 2008.  The inspectors selectively questioned workers and radiation protection personnel in the field to evaluate their understanding of ambient radiological conditions.  The inspectors evaluated performance to determine whether the training/skill level was sufficient with respect to the radiological hazards involved. 
    The inspectors performed a daily screening of items entered into the licensees
Problem Identification and Resolution
    corrective action program. This review was accomplished by reviewing a list of daily IRs,
 
    reviewing selected IRs, attending daily screening meetings, and accessing the licensees
14    Enclosure  The inspectors selectively reviewed issue reports in this area since the last inspection to determine if AmerGen was including ALARA deficiencies and issues in its corrective  
    computerized corrective action program database.
action program. (See Section 4OA2)
.2  Annual Sample: Access Control Deficiencies
The review included self-assessments, audits, and corrective action reports related to the ALARA program since the last inspection to determine if the follow-up activities were being conducted in an effective and timely manner commensurate with their importance
                                                                              Enclosure
to safety and risk.  
  b. Findings
  No findings of significance were identified.


2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 1 sample)  
                                            16
  a. Inspection Scope
  a. Inspection Scope (1 sample)
  The inspectors reviewed selected activities and associated documentation in the below listed areas. The evaluation of AmerGen's performance in these areas was against
    The inspectors reviewed AmerGen=s actions in response to issue reports generated as a
criteria contained in 10 CFR 20, applicable TSs, and applicable station procedures.  
    result of multiple issues associated with access control deficiencies. The inspectors also
   Self-Contained Breathing Apparatus
    reviewed AmerGens procedures on searching personnel and process facility operations.
  The inspectors reviewed the functional testing and inspection of self-contained breathing
    In addition, the inspectors interviewed applicable members of AmerGens staff including
apparatus (SCBA) to ensure equipment was being properly maintained and inspected in accordance with the manufacturer's recommendations and applicable regulatory requirements. The functional testing of three SCBA units, ready for use in the Unit 1 Control Room, was reviewed (Kit Nos. 1, 2, 3).  The inspectors also visually inspected the SCBA kits and additional mask units.  The components of the three kits were also
    site security officers and a corporate security system engineer.
checked against approved component lists published by the SCBA manufacturer and the National Institute for Occupational Safety and Health. The inspectors reviewed periodic testing of the SCBA units' components (i.e., hydro testing of tank, maintenance and testing of regulators, low pressure alarms) and reviewed conformance of the SCBAs with published certification lists.  
   b. Findings
Problem Identification and Resolution
    No findings of significance were identified. The inspectors reviewed issue reports
   The inspectors reviewed issue reports in this area since the last inspection to determine if AmerGen was including instrument deficiencies and issues in its corrective action  
    documenting issues related to four access control deficiencies identified in 2007. In
program (Section 4OA2). The review included self-assessments, audits, and corrective action reports.  
    each case, the actions taken to address the issues were appropriate. The inspectors
  b. Findings
    verified that the site has provided adequate training and guidance on process facility
  No findings of significance were identified.
    operations to the security staff.
Cornerstone: Public Radiation Safety
.3  Problem Identification and Resolution for Radiological Protection Activities
  2PS2 Radioactive Material Processing and Transportation (71122.02 - 1 sample)
   a. Inspection Scope
  a. Inspection Scope
    The inspectors reviewed issue reports and self-assessments to determine if identified
 
    problems were entered into the corrective action program for resolution. The inspectors
15    Enclosure  The inspectors selectively reviewed the packaging and shipment preparation of a non-exempt radioactive material shipment (RS-08-029-1). Matters reviewed included:
    selectively reviewed the reports to evaluate AmerGens threshold for identifying,
packaging and vehicle radiation dose rates; placarding of vehicle; completion of applicable shipping papers; qualification of personnel overseeing and processing shipment; emergency instructions; general truck and trailer condition; closure and use requirements.
    evaluating, and resolving problems (Apparent Cause 698893, NOS Audit 07-4Q,). The
The inspectors also selectively reviewed training provided for station personnel relative to 49 CFR 172, and NRC Bulletin 79 -19.  
    review included a check of possible repetitive issues, such as worker or technician errors
  b. Findings
    (Issue Nos. 706402, 706624, 707298, 707789, 712475, 715167, 722282, 723723,
 
    726821, 727146, 7377511, 740021, 689317, 695488, 689423, 689435, 689562, 696907,
No findings of significance were identified.  
    692640, 707288, 744382, and 745372).
4. OTHER ACTIVITIES
    This review was against criteria contained in 10 CFR 20, Technical Specifications, and
  4OA1 Performance Indicator Verification (71151 - 3 samples)  
    station procedures.
  a. Inspection Scope
  b. Findings
  Cornerstone:  Initiating Events 
    No findings of significance were identified.
  The inspectors reviewed selected station records to verify NRC PIs had been accurately reported to the NRC as specified in NEI 99-02, Regulatory Assessment Performance
4OA5 Other Activities
Indicator Guideline, Rev. 5. The three PI samples listed below were verified for the period January to December 2007.
.1  Temporary Instruction 2515/166 - Pressurized Water Reactor Containment Sump
$ Unplanned Scrams per 7000 Critical Hours
    Blockage (NRC Generic Letter 2004-02)
$ Unplanned Scrams with Complications
a. Inspection Scope
$ Unplanned Power Changes per 7000 Critical Hours
    The inspectors performed an inspection in accordance with Temporary Instruction (TI)
The inspectors reviewed operator logs, licensee event reports, monthly station operating reports, corrective action program database documents, calculation methods, definition of terms, and use of clarifying notes.  The inspectors also verified accuracy of the  
    2515/166, Pressurized Water Reactor Containment Sump Blockage, Rev. 1. The TI was
number of reported critical hours used in the calculations.
    developed to support the NRC review of licensee activities in response to NRC Generic
  b. Findings
    Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Sump
  No findings of significance were identified.
    Recirculation at Pressurized Water Reactors. Specifically, the inspectors verified that
    the implementation of the modifications and procedure changes was consistent with the
    actions committed to in AmerGens supplemental response to GL 2004-02, dated
    December 28, 2007. The supplemental response provided the remaining information
                                                                              Enclosure


4OA2 Identification and Resolution of Problems (71152) 
                                            17
.1 Review of Issue Reports and Cross-References to Problem Identification and Resolution Issues Reviewed Elsewhere
    regarding the actions and methodologies used at TMI to resolve the issues in the GL,
  The inspectors performed a daily screening of items entered into the licensee's corrective action program. This review was accomplished by reviewing a list of daily IRs, reviewing selected IRs, attending daily screening meetings, and accessing the licensee's computerized corrective action program database.  
    which included the downstream effects and chemical effects analyses.
  .2 Annual Sample: Access Control Deficiencies
    Additionally, the inspectors reviewed the TS and the UFSAR, to verify that required
 
    changes to the TS had been approved by the NRC and that the UFSAR had been or
16    Enclosure    a. Inspection Scope (1 sample)
    was in the process of being updated to reflect the plant changes. Portions of the TI were
The inspectors reviewed AmerGen
    performed during the 2007 refueling outage to verify the containment sump
=s actions in response to issue reports generated as a result of multiple issues associated with access control deficiencies. The inspectors also reviewed AmerGen's procedures on searching personnel and process facility operations. In addition, the inspectors interviewed applicable members of AmerGen's staff including
    modifications; the results of that inspection were documented in Inspection Report No.
site security officers and a corporate security system engineer.  
    05000289/2007005.
  b. Findings
  bEvaluation of Inspection Requirements
  No findings of significance were identified.  The inspectors reviewed issue reports
    The TI requires the inspectors to evaluate and answer the following questions:
documenting issues related to four access control deficiencies identified in 2007.  In each case, the actions taken to address the issues were appropriate.  The inspectors verified that the site has provided adequate training and guidance on process facility operations to the security staff. 
    1.     Did the licensee implement the plant modifications and procedure changes
            committed to in their GL 2004-02 response?
.3 Problem Identification and Resolution for Radiological Protection Activities
            The inspectors verified that AmerGen implemented the plant modifications and
    a. Inspection Scope
            procedure changes committed to in their GL 2004-02 responses. The inspection
  The inspectors reviewed issue reports and self-assessments to determine if identified
            performed in 2007 verified the implementation of the sump screen modifications
problems were entered into the corrective action program for resolution. The inspectors selectively reviewed the reports to evaluate AmerGen's threshold for identifying, evaluating, and resolving problems (Apparent Cause 698893, NOS Audit 07-4Q,). The review included a check of possible repetitive issues, such as worker or technician errors (Issue Nos. 706402, 706624, 707298, 707789, 712475, 715167, 722282, 723723,  
            related to the GL. The inspectors verified that the modifications previously
726821, 727146, 7377511, 740021, 689317, 695488, 689423, 689435, 689562, 696907, 692640, 707288, 744382, and 745372).  
            installed met the assumptions of AmerGens completed analyses, which included
This review was against criteria contained in 10 CFR 20, Technical Specifications, and station procedures.  
            the chemical effects analysis. The inspectors reviewed changes to AmerGens
  b. Findings
            emergency operating procedures and verified that the procedures ensured the
   No findings of significance were identified.
            assumptions described in the licensee supplemental response to the GL were
4OA5 Other Activities
            valid. Finally, the inspectors verified the modifications to address downstream
 
            effects had been performed.
.1 Temporary Instruction 2515/166 - Pressurized Water Reactor Containment Sump Blockage (NRC Generic Letter 2004-02)
    2.     Has the licensee updated its licensing basis to reflect the corrective actions taken
            in response to GL 2004-02?
            The inspectors verified that AmerGen had either updated, or was in the process
            of updating, the licensing basis to reflect the actions taken in response to GL
            2004-02. Specifically, the inspectors verified that changes to the facility or
            procedures as described in the UFSAR that were identified in the licensees GL
            2004-02 responses were reviewed and documented in accordance with 10 CFR
            50.59. The inspectors also verified that changes to the technical specifications
            had been approved by the NRC, and that required changes to the UFSAR,
            describing the changes to the plant, were in the process of being updated.
    The inspection requirements of the Temporary Instruction are complete and the TI is
    closed. The Office of Nuclear Reactor Regulation will perform a technical review of
    AmerGens GL responses to ensure the licensee corrective actions adequately address
    Generic Safety Issue 191, Assessment of Debris Accumulation on Pressurized Water
    Reactor Sump Performance, and Generic Letter 2004-02. The NRC will document the
    results of this review in a separate letter to AmerGen.
.2   Radiological Review of Steam Generator Replacement Transportation Plans (50001)
   a. Inspection Scope
   a. Inspection Scope
  The inspectors performed an inspection in accordance with Temporary Instruction (TI) 2515/166, Pressurized Water Reactor Containment Sump Blockage, Rev. 1.  The TI was developed to support the NRC review of licensee activities in response to NRC Generic Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Sump Recirculation at Pressurized Water Reactors.  Specifically, the inspectors verified that
                                                                                Enclosure
the implementation of the modifications and procedure changes was consistent with the actions committed to in AmerGen's supplemental response to GL 2004-02, dated December 28, 2007.  The supplemental response provided the remaining information 
 
17    Enclosure regarding the actions and methodologies used at TMI to resolve the issues in the GL, which included the downstream effects and chemical effects analyses.
                                          18
Additionally, the inspectors reviewed the TS and the UFSAR, to verify that required changes to the TS had been approved by the NRC and that the UFSAR had been or was in the process of being updated to reflect the plant changes.  Portions of the TI were performed during the 2007 refueling outage to verify the containment sump
    The inspectors selectively reviewed the preliminary plans for transport to, and storage of,
modifications; the results of that inspection were documented in Inspection Report No. 05000289/2007005.
    the replaced Unit 1 steam generators at the proposed storage facility. The inspectors
b. Evaluation of Inspection Requirements
    reviewed projected public dose calculations.
  The TI requires the inspectors to evaluate and answer the following questions:
    The review was against criteria contained in 10 CFR 20, site TSs, and the Offsite Dose
1. Did the licensee implement the plant modifications and procedure changes committed to in their GL 2004-02 response?
    Calculation Manual.
The inspectors verified that AmerGen implemented the plant modifications and procedure changes committed to in their GL 2004-02 responses.  The inspection
  b. Findings
performed in 2007 verified the implementation of the sump screen modifications related to the GL.  The inspectors verified that the modifications previously installed met the assumptions of AmerGen's completed analyses, which included the chemical effects analysis.  The inspectors reviewed changes to AmerGen's emergency operating procedures and verified that the procedures ensured the
    No findings of significance were identified.
assumptions described in the licensee supplemental response to the GL were valid.  Finally, the inspectors verified the modifications to address downstream effects had been performed.
4OA6 Meetings, Including Exit
2. Has the licensee updated its licensing basis to reflect the corrective actions taken in response to GL 2004-02?
    Exit Meeting Summary
The inspectors verified that AmerGen had either updated, or was in the process of updating, the licensing basis to reflect the actions taken in response to GL 2004-02.  Specifically, the inspectors verified that changes to the facility or 
    On April 18, 2008, the resident inspectors presented the inspection results to Mr. Bill Noll
procedures as described in the UFSAR that were identified in the licensee's GL 2004-02 responses were reviewed and documented in accordance with 10 CFR 50.59.  The inspectors also verified that changes to the technical specifications had been approved by the NRC, and that required changes to the UFSAR, describing the changes to the plant, were in the process of being updated.
    and other members of the TMI staff who acknowledged the findings. The regional
The inspection requirements of the Temporary Instruction are complete and the TI is closed.  The Office of Nuclear Reactor Regulation will perform a technical review of AmerGen's GL responses to ensure the licensee corrective actions adequately address Generic Safety Issue 191, Assessment of Debris Accumulation on Pressurized Water Reactor Sump Performance, and Generic Letter 2004-02.  The NRC will document the results of this review in a separate letter to AmerGen.
    specialist inspection results were previously presented to members of AmerGen
.2 Radiological Review of Steam Generator Replacement Transportation Plans (50001)
    management. The inspectors asked the licensee whether any of the material examined
    a. Inspection Scope
    during the inspection should be considered proprietary. No proprietary information was
 
    identified.
18    Enclosure  The inspectors selectively reviewed the preliminary plans for transport to, and storage of,   the replaced Unit 1 steam generators at the proposed storage facility. The inspectors  
ATTACHMENT: SUPPLEMENTAL INFORMATION
reviewed projected public dose calculations.  
                                                                              Enclosure
The review was against criteria contained in 10 CFR 20, site TSs, and the Offsite Dose Calculation Manual.  
 
   
                                              A-1
  b. Findings
                                SUPPLEMENTAL INFORMATION
  No findings of significance were identified.  
                                      KEY POINTS OF CONTACT
4OA6 Meetings, Including Exit
Licensee Personnel
  Exit Meeting Summary
D. Atherholt                   Manager, Regulatory Assurance
  On April 18, 2008, the resident inspectors presented the inspection results to Mr. Bill Noll and other members of the TMI staff who acknowledged the findings. The regional specialist inspection results were previously presented to members of AmerGen management. The inspectors asked the licensee whether any of the material examined  
C. Baker                       Manager, Chemistry
during the inspection should be considered proprietary. No proprietary information was identified.  
B. Carsky                     Director, Operations
ATTACHMENT: SUPPLEMENTAL INFORMATION  
T. Dougherty                   Plant Manager
A-1   Attachment  SUPPLEMENTAL INFORMATION KEY POINTS OF CONTACT Licensee Personnel
E. Eilola                     Director, Site Engineering
D. Atherholt   Manager, Regulatory Assurance C. Baker   Manager, Chemistry B. Carsky   Director, Operations T. Dougherty   Plant Manager  
R. Godwin                     Training
E. Eilola   Director, Site Engineering R. Godwin   Training J. Heischman   Director, Maintenance W. Laudenbach System Engineer A. Miller   Regulatory Assurance  
J. Heischman                   Director, Maintenance
D. Mohre   Manager, Security P. Mussleman   Security Supervisor D. Neff   Manager, Emergency Preparedness W. Noll   Site Vice President T. Roberts   Radiation Protection D. Trostle   Operations Security Analyst L. Weir   Manager, Nuclear Oversight Services  
W. Laudenbach                 System Engineer
C. Wend   Manager, Radiation Protection R. West   Vice President, TMI Unit 1 H. Yeldell   Work Management  
A. Miller                     Regulatory Assurance
  LIST OF ITEMS OPENED, CLOSED AND DISCUSSED Opened & Closed
D. Mohre                       Manager, Security
NRC TI 2515/166 Pressurized Water Reactor Containment Sump Blockage (NRC Generic Letter 2004-02)  
P. Mussleman                   Security Supervisor
  LIST OF DOCUMENTS REVIEWED  
D. Neff                       Manager, Emergency Preparedness
Section 1R04: Equipment Alignment
W. Noll                       Site Vice President
Procedures
T. Roberts                     Radiation Protection
1105-20, Remote Shutdown Systems, Rev. 14 1107-4, Electrical Distribution Panel Listing, Rev. 213 OP-TM-211-000, Makeup and Purification System, Rev. 16 OP-TM-212-000, Decay Heat Removal System, Rev. 11 OP-TM-214-000, Building Spray System, Rev. 8  
D. Trostle                     Operations Security Analyst
OP-TM-533-000, Decay Heat River System, Rev. 9 OP-TM-541-000, Primary Component Cooling System, Rev. 6 OP-TM-543-000, Decay Heat Closed System, Rev. 7  
L. Weir                       Manager, Nuclear Oversight Services
Drawings Dwg. 302-712, Reactor Building Spray, Rev. 49
C. Wend                       Manager, Radiation Protection
     
R. West                       Vice President, TMI Unit 1
A-2   Attachment  Section 1R011: Licensed Operator Requalification Program
H. Yeldell                     Work Management
Procedures
                        LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
OP-TM-AOP-014, Loss of 1E 4160V Bus, Rev. 3 OP-TM-AOP-020, Loss of Station Power, Rev. 12 OP-TM-AOP-041, Loss of Seal Injection, Rev. 2 OP-TM-AOP-062, Inoperable Rod, Rev. 1 OP-TM-EOP-001, Reactor Trip, Rev. 9  
Opened & Closed
OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5 OP-TM-EOP-009, HPI Cooling - Recovery from Solid Operations, Rev. 5 EP-AA-1009, Radiological Emergency Plan Annex for TMI Station, Rev. 10  
NRC TI 2515/166         Pressurized Water Reactor Containment Sump Blockage (NRC Generic
Section 1R012: Maintenance Rule
                        Letter 2004-02)
Procedures
                                LIST OF DOCUMENTS REVIEWED
Alarm Response Procedure MAP NN-1-8, Main Annunciator Panel NN, Rev.4 Alarm Response Procedure, HM, Hydrogen Monitor Pane, Rev. 0 1105-18, Containment Hydrogen Monitor, Rev. 12 1104-62, Hydrogen Recombiner, Rev. 22 OP-TM-EOP-008, LOCA Cooldown, Rev. 6 IC-252, Channel Test of Reactor building Post LOCA Hydrogen Monitor, Rev. 0  
Section 1R04: Equipment Alignment
Procedures
1105-20, Remote Shutdown Systems, Rev. 14
1107-4, Electrical Distribution Panel Listing, Rev. 213
OP-TM-211-000, Makeup and Purification System, Rev. 16
OP-TM-212-000, Decay Heat Removal System, Rev. 11
OP-TM-214-000, Building Spray System, Rev. 8
OP-TM-533-000, Decay Heat River System, Rev. 9
OP-TM-541-000, Primary Component Cooling System, Rev. 6
OP-TM-543-000, Decay Heat Closed System, Rev. 7
Drawings
Dwg. 302-712, Reactor Building Spray, Rev. 49
                                                                        Attachment
 
                                          A-2
Section 1R011: Licensed Operator Requalification Program
Procedures
OP-TM-AOP-014, Loss of 1E 4160V Bus, Rev. 3
OP-TM-AOP-020, Loss of Station Power, Rev. 12
OP-TM-AOP-041, Loss of Seal Injection, Rev. 2
OP-TM-AOP-062, Inoperable Rod, Rev. 1
OP-TM-EOP-001, Reactor Trip, Rev. 9
OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5
OP-TM-EOP-009, HPI Cooling - Recovery from Solid Operations, Rev. 5
EP-AA-1009, Radiological Emergency Plan Annex for TMI Station, Rev. 10
Section 1R012: Maintenance Rule
Procedures
Alarm Response Procedure MAP NN-1-8, Main Annunciator Panel NN, Rev.4
Alarm Response Procedure, HM, Hydrogen Monitor Pane, Rev. 0
1105-18, Containment Hydrogen Monitor, Rev. 12
1104-62, Hydrogen Recombiner, Rev. 22
OP-TM-EOP-008, LOCA Cooldown, Rev. 6
IC-252, Channel Test of Reactor building Post LOCA Hydrogen Monitor, Rev. 0
IC-253, Reactor Building Post-LOCA Hydrogen Monitoring Calibration, Rev. 1
IC-253, Reactor Building Post-LOCA Hydrogen Monitoring Calibration, Rev. 1
  Other Documents
Other Documents
IR-736664, Response to NRC Question On Hydrogen Recombiners And Monitoring System System Health Report, Containment hydrogen Monitoring, dated December 2007  
IR-736664, Response to NRC Question On Hydrogen Recombiners And Monitoring System
Section 1EP6: Drill Evaluation
System Health Report, Containment hydrogen Monitoring, dated December 2007
Procedures
Section 1EP6: Drill Evaluation
1202-33, High Winds, Rev. 28 EP-AA-111, Emergency Classification and Protective Action Recommendations, Rev. 13  
Procedures
EP-AA-1009, Radiological Emergency Plan Annex for TMI Station, Rev. 10 OP-TM-EOP-001, Reactor Trip, Rev. 9 OP-TM-EOP-003, Excessive Primary to Secondary Heat Transfer, Rev. 5 OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5 OP-TM-EOP-010, Abnormal Transients Guides, Rules, and Graphs, Rev. 9  
1202-33, High Winds, Rev. 28
 
EP-AA-111, Emergency Classification and Protective Action Recommendations, Rev. 13
Other Documents
EP-AA-1009, Radiological Emergency Plan Annex for TMI Station, Rev. 10
Licensed Operator Drill Scenario No. 51, Low System Grid voltage, High Winds, Generator/Turbine Trip, ATWS, Stem Leak in Containment Causing Excessive Primary to Secondary Heat Transfer, Rev. 1  
OP-TM-EOP-001, Reactor Trip, Rev. 9
OP-TM-EOP-003, Excessive Primary to Secondary Heat Transfer, Rev. 5
OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5
OP-TM-EOP-010, Abnormal Transients Guides, Rules, and Graphs, Rev. 9
Other Documents
Licensed Operator Drill Scenario No. 51, Low System Grid voltage, High Winds,
Generator/Turbine Trip, ATWS, Stem Leak in Containment Causing Excessive Primary to
Secondary Heat Transfer, Rev. 1
Section 2OS1, 2OS2, 2OS3, 2PS2: Occupational and Public Radiation Safety
Procedures
RP-TM-503-1001, Rev. 1, Volumetric Material Controls
RP-TM-460-1007, Rev. 5, Access to TMI -1 Reactor Building
RP-AA-400, Rev. 4, ALARA Program
RP-TM-605-1001, Rev. 1, TMI Waste Characterization
RP-TM-850, Rev. 0, Radiation Protection Emergency Equipment Readiness.
6610-OPS-4510.03, Rev. 2, Inspection and Maintenance of Respiratory Equipment
Other Documents
TMI Radiological Protection T1R17 Refueling Outage Report 2007
Primary Water Chemistry Sampling Results
                                                                          Attachment


                                            A-3
Section 2OS1, 2OS2, 2OS3, 2PS2:  Occupational and Public Radiation Safety
Fuel Transfer Tube Radiation Surveys November 2005
Procedures
Self-contained Breathing Apparatus Vendor Manual
RP-TM-503-1001, Rev. 1, Volumetric Material Controls RP-TM-460-1007, Rev. 5, Access to TMI -1 Reactor Building RP-AA-400, Rev. 4, ALARA Program RP-TM-605-1001, Rev. 1, TMI Waste Characterization
Section 4OA2: Problem Identification & Resolution
RP-TM-850, Rev. 0, Radiation Protection Emergency Equipment Readiness. 6610-OPS-4510.03, Rev. 2, Inspection and Maintenance of Respiratory Equipment 
Issue Reports
Other Documents
00565138, Improper Verification of Protected Area Badge
TMI Radiological Protection T1R17 Refueling Outage Report 2007  
00670299, Security Explosive Detector Failed to Alarm During Testing
Primary Water Chemistry Sampling Results 
00652352, Access Not Verified Prior to P/A Entry Through MAF
A-3    Attachment   Fuel Transfer Tube Radiation Surveys November 2005  Self-contained Breathing Apparatus Vendor Manual
00685064, Access Not Verified Prior to P/A Entry MAF
00699966, Improper Response to Explosive Detector Alarm
Procedures
SY-AA-101-112, Searching Personnel, Vehicles, Packages and Cargo, Rev. 12
SY-TM-1005, Processing Center Operations, Rev. 11
Other Documents
VM-TM-0946, Entry Scan Explosives Detector Model 85, Rev. 4
NRC Generic Letter 91-10, Explosives Searches at Protected Area Portals, July 8, 1991
Section 4OA5: Other
Procedures
OP-TM-214-901, RB Spray Operation, Rev. 3
OP-TM-EOP-010, Emergency Procedures Rules, Guides and Graphs, Rev. 9
Other Documents
C-1101-210-E610-011, LPI BS Pump NPSH Margin Available from the RB Sump Following a
      LBLOCA, Rev. 7
ECTM005-CALC-05, Hydraulic Analyses of the Reactor Building Recirculation Sump Strainer,
      Rev. 3
Inspection Report 05000289/2007005, Three Mile Island Station, Unit 1 - NRC Integrated
      Inspection Report
NRC Docket No. 50-289, Technical Specification Change Request No. 337 - Reactor Building
      Emergency Sump pH control System Buffer Change
PC 22736, Ops Procedures due to RB Sump Mod per ECR-06-0207, 06-0205 &
06-0206
PC 24164, EOP/EP Revisions for TSP Mod (ECR-07-00174) and GL 2004-02
Three Mile Island Unit 1 Supplemental Response to NRC Generic Letter 2004-02, Potential
      Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at
      Pressurized-Water Reactors, dated December 28, 2007
TM 06-00256-000, Replace DH-V-19A/B Internals
TM-07-00743-000, Generic Letter 2004-02/GSI-191 Supplemental Response
                                                                          Attachment


                                    A-4
Section 4OA2:  Problem Identification & Resolution
                              LIST OF ACRONYMS
Issue Reports
ADAMS   Agencywide Documents and Management System
00565138, Improper Verification of Protected Area Badge 00670299, Security Explosive Detector Failed to Alarm During Testing
ALARA   As Low As is Reasonably Achievable
00652352, Access Not Verified Prior to P/A Entry Through MAF 00685064, Access Not Verified Prior to P/A Entry MAF 00699966, Improper Response to Explosive Detector Alarm
AmerGen AmerGen Energy Company, LLC
Procedures
AR     Action Request
SY-AA-101-112, Searching Personnel, Vehicles, Packages and Cargo, Rev. 12 SY-TM-1005, Processing Center Operations, Rev. 11
CFR     Code of Federal Regulations
Other Documents
DRP     Division of Reactor Projects
VM-TM-0946, Entry Scan Explosives Detector Model 85, Rev. 4 NRC Generic Letter 91-10, Explosives Searches at Protected Area Portals, July 8, 1991
ECR     Engineering Change Request
Section 4OA5:  Other
ESAS   Engineered Safeguards and Actuation System
Procedures
GL     Generic Letter
OP-TM-214-901, RB Spray Operation, Rev. 3 OP-TM-EOP-010, Emergency Procedures Rules, Guides and Graphs, Rev. 9
HRA     High Radiation Area
Other Documents
IMC     Inspection Manual Chapter
C-1101-210-E610-011, LPI BS Pump NPSH Margin Available from the RB Sump Following a LBLOCA, Rev. 7 ECTM005-CALC-05, Hydraulic Analyses of the Reactor Building Recirculation Sump Strainer, Rev. 3 Inspection Report 05000289/2007005, Three Mile Island Station, Unit 1 - NRC Integrated Inspection Report NRC Docket No. 50-289, Technical Specification Change Request No. 337 - Reactor Building Emergency Sump pH control System Buffer Change PC 22736, Ops Procedures due to RB Sump Mod per ECR-06-0207, 06-0205 & 
IR     Issue Report
06-0206 PC 24164, EOP/EP Revisions for TSP Mod (ECR-07-00174) and GL 2004-02 Three Mile Island Unit 1 Supplemental Response to NRC Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at Pressurized-Water Reactors," dated December 28, 2007 TM 06-00256-000, Replace DH-V-19A/B Internals TM-07-00743-000, Generic Letter 2004-02/GSI-191 Supplemental Response
LOCA   Loss of Coolant Accident
 
LPI     Low Pressure Injection
A-4    Attachment  LIST OF ACRONYMS  
MAF     Main Access Facility
ADAMS Agencywide Documents and Management System  
MR     Maintenance Rule
ALARA As Low As is Reasonably Achievable AmerGen AmerGen Energy Company, LLC AR Action Request CFR Code of Federal Regulations  
NCV     Non-Cited Violation
DRP Division of Reactor Projects ECR Engineering Change Request ESAS Engineered Safeguards and Actuation System GL Generic Letter HRA High Radiation Area  
NEI     Nuclear Energy Institute
IMC Inspection Manual Chapter IR Issue Report LOCA   Loss of Coolant Accident LPI Low Pressure Injection MAF Main Access Facility MR Maintenance Rule NCV Non-Cited Violation  
NRC     Nuclear Regulatory Commission
NEI Nuclear Energy Institute NRC Nuclear Regulatory Commission NUMARC Nuclear Management and Resources Council P/A Protected Area PADEP Pennsylvania Department of Environmental Protection  
NUMARC Nuclear Management and Resources Council
PARS Publicly Available Records PI Performance Indicator PMT Post-Maintenance Test SCBA Self Contained Breathing Apparatus SSC Structures, Systems, and Components  
P/A     Protected Area
TI Temporary Instruction TMI Three Mile Island, Unit 1 TS Technical Specifications UE Unusual Event UFSAR Updated Final Safety Analysis Report
PADEP   Pennsylvania Department of Environmental Protection
PARS   Publicly Available Records
PI     Performance Indicator
PMT     Post-Maintenance Test
SCBA   Self Contained Breathing Apparatus
SSC     Structures, Systems, and Components
TI     Temporary Instruction
TMI     Three Mile Island, Unit 1
TS     Technical Specifications
UE     Unusual Event
UFSAR   Updated Final Safety Analysis Report
                                                            Attachment
}}
}}

Latest revision as of 12:10, 22 March 2020

IR 05000289-08-002 on 01/01/08 - 03/31/08 for TMI, Unit 1
ML081160408
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 04/25/2008
From: Bellamy R
NRC/RGN-I/DRP/PB6
To: Pardee C
AmerGen Energy Co, Exelon Generation Co
BELLAMY, RR
References
IR-08-002
Download: ML081160408 (25)


See also: IR 05000289/2008002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

475 ALLENDALE ROAD

KING OF PRUSSIA, PA 19406-1415

April 25, 2008

Mr. Charles G. Pardee

Chief Nuclear Officer (CNO) and Senior Vice President

Exelon Generation Company, LLC

Chief Nuclear Officer (CNO)

AmerGen Energy Company, LLC

200 Exelon Way

Kennett Square, PA 19348

SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED

INSPECTION REPORT 5000289/2008002

Dear Mr. Pardee:

On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated

inspection at your Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report

documents the inspection results, which were discussed April 18, 2008, with Mr. Bill Noll 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.

On the basis of the results of this inspection, no findings of significance were identified.

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 610-337-5200 if you have any questions

regarding this letter.

Sincerely,

/RA/

Ronald R. Bellamy, Ph.D., Chief

Projects Branch 6

Division of Reactor Projects

Docket No: 50-289

License No: DPR-50

2

Enclosure: Inspection Report 05000289/2008002

w/Attachment: Supplemental Information

cc w/encl:

Executive Vice President and Chief Operating Officer, Exelon Generation

Site Vice President - TMI Unit 1, AmerGen

Plant Manager - TMI, Unit 1, AmerGen

Regulatory Assurance Manager - TMI, Unit 1 AmerGen

Senior Vice President - Nuclear Services, AmerGen

Senior Vice President - Mid-Atlantic Operations, AmerGen

Senior Vice President - Operations Support, AmerGen

Vice President - Licensing and Regulatory Affairs, AmerGen

Director Licensing - AmerGen

Manager Licensing - TMI, AmerGen

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

Correspondence Control Desk - AmerGen

Chairman, Board of County Commissioners of Dauphin County

Chairman, Board of Supervisors of Londonderry township

R. Janati, Director, Bureau of Radiation Protection, State of PA

J. Johnsrud, National Energy Committee

E. Epstein, TMI-Alert (TMIA)

D. Allard, PADEP

J. Powers, Director, PA Office of Homeland Security

R. French, Director, PA Emergency Management Agency

3

Mr. Charles G. Pardee

Chief Nuclear Officer (CNO) and Senior Vice President

Exelon Generation Company, LLC

Chief Nuclear Officer (CNO)

AmerGen Energy Company, LLC

200 Exelon Way

Kennett Square, PA 19348

SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED

INSPECTION REPORT 5000289/2008002

Dear Mr. Pardee:

On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your

Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report documents the inspection results, which were

discussed April 18, 2008, with Mr. Bill Noll 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.

On the basis of the results of this inspection, no findings of significance were identified.

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 610-337-5200 if you have any questions regarding this letter.

Sincerely,

Ronald R. Bellamy, Ph.D., Chief /RA/

Projects Branch 6

Division of Reactor Projects

Distribution w/encl: (VIA EMAIL)

S. Collins, RA

M. Dapas, DRA

D. Lew, DRP

J. Clifford, DRP

R. Bellamy, DRP

S. Barber, DRP

A. Rosebrook, DRP

D. Kern, DRP, Senior Resident Inspector

J. Brand, DRP, Resident Inspector

C. LaRegina, DRP, Resident OA

S. Williams, RI, OEDO

H. Chernoff, NRR

J. Lubinski, NRR

P. Bamford, PM, NRR

G. Miller, NRR

J. Lubinski, NRR

ROPreportsResource@nrc.gov

Region 1 Docket Room (with concurrences)

ML081160408

SUNSI Review Complete AAR (Reviewers Initials)

DOCUMENT NAME: G:\DRP\BRANCH6a\+++Three Mile Island\TMI Inspection Reports\TMI 08- 002.doc

After declaring this document An Official Agency Record it will be released to the Public.

To receive a copy of this document, indicate in the box: C= Copy without attachment/enclosure E=Copy with

attachment/enclosure, N=No copy

OFFICE RI/DRP RI/DRP RI/DRP RI/DRS

NAME DKern/ AAR for ARosebrook/ AAR SBarber/ SB RBellamy/RRB

DATE 4 /24 /08 4/24 /08 4/25 /08 4/ 25 /08

OFFICIAL RECORD COPY

1

U.S. NUCLEAR REGULATORY COMMISSION

REGION 1

Docket No: 05000289

License No: DPR-50

Report No: 05000289/2008002

Licensee: AmerGen Energy Company, LLC (AmerGen)

Facility: Three Mile Island Station, Unit 1

Location: PO Box 480

Middletown, PA 17057

Dates: January 1 - March 31, 2008

Inspectors: David M. Kern, Senior Resident Inspector

Javier M. Brand, Resident Inspector

Jeffrey Bream, Reactor Engineer

Danté Johnson, Physical Security Inspector

Kevin Mangan, Senior Reactor Inspector

Ronald M. Nimitz, Senior Health Physicist

Approved by: Ronald R. Bellamy, Ph.D., Chief

Projects Branch 6

Division of Reactor Projects (DRP)

Enclosure

2

TABLE OF CONTENTS

SUMMARY OF FINDINGS.......................................................................................................... 3

1. REACTOR SAFETY ........................................................................................................... 4

1R01 Adverse Weather Protection ................................................................................... 4

1R04 Equipment Alignment ............................................................................................. 4

1R05 Fire Protection ........................................................................................................ 5

1R11 Licensed Operator Requalification Program ........................................................... 6

1R12 Maintenance Effectiveness ..................................................................................... 6

1R13 Maintenance Risk Assessments and Emergent Work Control ................................ 7

1R15 Operability Evaluations ........................................................................................... 8

1R18 Plant Modifications ................................................................................................. 8

1R19 Post Maintenance Testing ...................................................................................... 9

1R22 Surveillance Testing ............................................................................................. 10

2. RADIATION SAFETY ....................................................................................................... 11

20S1 Access Controls .................................................................................................... 11

2OS2 ALARA Planning and Controls .............................................................................. 12

2OS3 Radiation Monitoring Instrumentation and Protective Equipment .......................... 14

2PS2 Radioactive Material Processing and Transportation ............................................ 14

4. OTHER ACTIVITIES......................................................................................................... 15

4OA1 Performance Indicator Verification ........................................................................ 15

4OA2 Identification and Resolution of Problems ............................................................. 15

4OA6 Meetings, Including Exit......................................................................................... 18

ATTACHMENT: SUPPLEMENTAL INFORMATION ................................................................ 18

SUPPLEMENTAL INFORMATION......................................................................................... A-1

KEY POINTS OF CONTACT.................................................................................................. A-1

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ....................................................... A-1

LIST OF ACRONYMS ............................................................................................................ A-4

Enclosure

3

SUMMARY OF FINDINGS

IR 05000289/2008002; 1/1/2008 - 3/31/2008; AmerGen Energy Company, LLC; Three Mile

Island, Unit 1; Routine integrated report.

The report covered a 13-week period of inspection by resident inspectors and announced

inspections by regional inspectors. No findings of significance were identified. The NRCs

program for overseeing the safe operation of commercial nuclear power reactors is described in

NUREG-1649, Reactor Oversight Process, Rev. 3, dated July 2000.

A. NRC-Identified and Self-Revealing Findings

No findings of significance were identified.

B. Licensee Identified Violations

None.

Enclosure

4

REPORT DETAILS

Summary of Plant Status

Three Mile Island, Unit 1 (TMI) operated at approximately 100 percent rated thermal power for

the entire inspection period.

1. REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity

1R01 Adverse Weather Protection (71111.01 - 1 site sample)

a. Inspection Scope

Winter storms, including heavy rains and winds, elevated the Susquehanna River level

above flood stage and affected river conditions from March 5 to 11, 2008. The

inspectors reviewed procedures, conducted interviews, and performed various

inspections to verify that operator actions to address adverse river conditions maintained

the readiness of the various river water systems. Operators closely monitored National

Weather Service flood projections and entered procedure 1202-32, Flood, Rev. 65 when

the 36-hour forecast projected river level to reach flood stage (286.1 feet at the intake

screen house (issue report (IR) 745543). The inspectors walked down the intake screen

house which houses the fire protection system pumps and safety related cooling water

pumps for the decay heat removal system, nuclear service water system, and reactor

river water system. Additionally, after river level receded below flood stage, the

inspectors walked down the flood dike which surrounds the entire power plant in

accordance with procedure 3301-SA1, Dike Inspection, Rev. 12 to determine whether

the flood barrier had been damaged or needed repair (IRs 734215, 747638). The

inspectors evaluated the adequacy of various emergency and surveillance procedures

associated with river water and intake systems to assess AmerGen=s protection from

storms and adverse river conditions.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment (71111.04)

a. Inspection Scope

Partial System Walkdowns (71111.04Q - 3 samples)

The inspectors performed three partial system walkdown samples on the following

systems and components:

  • On February 12, 2008, the inspectors walked down portions of the A decay heat

removal and reactor building spray systems while the plant was in an unplanned

orange risk condition due to an unexpected electrical breaker fault which made the

B decay river water pump inoperable.

Enclosure

5

  • On February 21, the inspectors walked down portions of the B reactor building spray

system while the plant was in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limiting condition of operation for scheduled

A emergency safeguards and actuation load sequence testing.

  • On February 27 and 28, the inspectors walked down portions of the remote safe

shutdown panel, while engineers and technicians were performing inspections of the

engineered safeguards and actuation system relays.

The partial system walkdowns were conducted on the redundant and standby equipment

to ensure that trains and equipment relied on to remain operable for accident mitigation

were properly aligned. Additional documents reviewed are listed in the attachment.

Complete System Walkdown (71111.04S - 1 sample)

On March 3 and 4, 2008, the inspectors performed one complete system walkdown

sample on the B and C makeup and purification system trains, while the A system

train was in a scheduled maintenance outage. The inspectors conducted a detailed

review of the alignment and condition of the system using the applicable one-line

diagram 302-560, Makeup and Purification, Rev. 44. In addition, the inspectors

reviewed and evaluated the corrective action program reports for impact on system

operation, interviewed the system engineer, and interviewed control room operators.

b. Findings

No findings of significance were identified.

1R05 Fire Protection (71111.05)

a. Inspection Scope (71111.05Q - 8 samples)

The inspectors conducted fire protection inspections for several plant fire zones,

selected based on the presence of equipment important to safety within their boundaries.

The inspectors conducted plant walkdowns and verified the areas were as described in

the TMI Fire Hazard Analysis Report, and that fire protection features were being

properly controlled per surveillance procedure 1038, Administrative Controls-Fire

Protection Program, Rev. 69. The plant walkdowns were conducted throughout the

inspection period and included assessment of transient combustible material control, fire

detection and suppression equipment operability, and compensatory measures

established for degraded fire protection equipment in accordance with procedure OP-

MA-201-007, Fire Protection System Impairment Control, Rev. 5. In addition, the

inspectors verified that applicable clearances between fire doors and floors met the

criteria of Attachment 1 of Engineering Technical Evaluation CC-AA-309-101,

Engineering Technical Evaluations, Rev. 9. Fire zones and areas inspected included:

  • Fire Zone AB-FZ-2A, Auxiliary Building Elevation 281, Makeup and Purification

Pump A;

  • Fire Zone AB-FZ-2B, Auxiliary Building Elevation 281, Makeup and Purification

Pump B;

  • Fire Zone AB-FZ-3C, Auxiliary Building Elevation 281, Makeup and Purification

Pump C;

  • Fire Zone DG-FA-1, Diesel Generator Building Elevation 305, Diesel Generator A;
  • Fire Zone DG-FA-2, Diesel Generator Building Elevation 305, Diesel Generator B;
  • Fire Zone TB-FA-1, Turbine Building Elevation 305

Enclosure

6

  • Fire Zone TB-FA-1, Turbine Building Elevation 322
  • Fire Zone TB-FA-1, Turbine Building Elevation 355

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program (71111.11Q - 1 sample)

a. Inspection Scope

On March 18, 2008, the inspectors observed licensed operator requalification training at

the control room simulator for the E operator crew. The inspectors observed the

operators simulator drill performance and compared it to the criteria listed in TMI

Operational Simulator Scenario Number 12, Condenser Vacuum Leak, Stuck Rod, Loss

of Offsite Power with Diesel and Emergency Feedwater Failures, Rev. 12. The

inspectors reviewed the operators ability to correctly evaluate the simulator training

scenario and implement the emergency plan. The inspectors observed supervisory

oversight, command and control, communication practices, and crew assignments to

ensure they were consistent with normal control room activities. The inspectors

observed operator response during the simulator drill transients. The inspectors

evaluated training instructor effectiveness in recognizing and correcting individual and

operating crew errors. The inspectors attended the post-drill critiques in order to

evaluate the effectiveness of problem identification. The inspectors verified that

emergency plan classification and notification training opportunities were tracked and

evaluated for success in accordance with criteria established in Nuclear Energy Institute

(NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 5.

Additional documents reviewed are listed in the attachment.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness (71111.12Q - 2 samples)

a. Inspection Scope

The inspectors evaluated the listed samples for Maintenance Rule (MR) implementation

by ensuring appropriate MR scoping, characterization of failed structures, systems, and

components (SSCs), MR risk categorization of SSCs, SSC performance criteria or goals,

and appropriateness of corrective actions. Additionally, extent of condition follow-up,

operability, and functional failure determinations were reviewed to verify they were

appropriate. The inspectors verified that the issues were addressed as required by 10

CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear

Power Plants; Nuclear Management and Resources Council (NUMARC) 93-01, Industry

Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Rev.

2; and AmerGen procedure ER-AA-310, Implementation of the Maintenance Rule, Rev.

6. The inspectors verified that appropriate corrective actions were initiated and

documented in IRs, and that engineers properly categorized failures as maintenance

rule functional failures and maintenance preventable functional failures, when applicable.

Enclosure

7

  • IR 735277 describes the failure of DR-P-1B to start from the control room. AmerGen

identified the failure as a Maintenance Rule Functional Failure. Since the cause of

the failure was attributed to an isolated manufacturing defect, AmerGen determined

that it was not a Maintenance Preventable Functional Failure. As such, the 10 CFR

50.65 a(2) determination remains valid.

  • The inspectors reviewed the TMI hydrogen monitoring system to ensure it was being

effectively controlled and maintained such that the system remained capable of

performing its intended function. This inspection sample was based on an NRC

maintenance rule finding identified in March 2007, at another nuclear power plant

regarding ineffective controls of the performance and condition of the hydrogen

monitoring system.

b. Findings

No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples)

a. Inspection Scope

The inspectors reviewed the scheduling, control, and restoration during the following

maintenance activities to evaluate their effect on plant risk. This review was against

criteria contained in AmerGen Administrative Procedure 1082.1, TMI Risk Management

Program, Rev. 7 and WC-AA-101, On-Line Work Control Process, Rev. 14.

  • From December 27, 2007 thru January 4, 2008, the TMI sodium hydroxide (NaOH)

chemical used to achieve a uniform pH in containment post accident was changed to

trisodium phosphate per modification ECR 07-174. The online maintenance risk

profile remained green during this evolution (Risk Document 1254, Rev. 3).

  • On January 22, 2008, emergency feedwater valve EFW-V-30B was taken out of

service for scheduled overhaul of the air actuator. The condition elevated the online

maintenance risk profile to yellow (Risk Document 1020, Rev. 4).

  • On February 12, the B decay river water pump (DR-P-1B) failed to start due to a

faulted starting relay (IRs 735277 and 735778). The condition elevated the online

maintenance risk profile to orange (Risk Document 1195, Rev. 3).

  • On February 12, the C makeup pump auxiliary lubricating oil pump (MU-P-2C) did

not auto start as expected during a scheduled surveillance test due to a failed

pressure switch (IR-735063). This condition did not affect operability of MU-P-1C.

On February 13, after DR-P-1B was returned to service and the on-line risk had been

returned to green, technicians replaced the failed pressure switch. This work

elevated the online maintenance risk profile to yellow (Risk Document 1066, Rev. 2).

  • On February 27, a contact for a reactor building emergency cooling and isolation

relay 63X-RB6B was replaced due to intermittent indication. The online maintenance

risk profile remained green during this evolution (Risk Document 551, Rev. 8).

Enclosure

8

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations (71111.15 - 3 samples)

a. Inspection Scope

The inspectors verified that degraded conditions in question were properly characterized,

operability of the affected systems was properly evaluated in relation to Technical

Specification (TS) requirements, applicable extent of condition reviews were performed,

and no unrecognized increase in plant risk resulted from the equipment issues. The

inspectors referenced NRC Inspection Manual Chapter (IMC) Part 9900, Operability

Determinations & Functionality Assessments For Resolution of Degraded or

Nonconforming Conditions Adverse to Quality or Safety and AmerGen procedure OP-

AA-108-115, Operability Determinations, Rev. 5, to determine acceptability of the

operability evaluations. The inspectors reviewed operability evaluations for the following

degraded equipment issues:

  • On December 4, 2007, NS-P-1A breaker operating mechanism became bound

during breaker inspection (WO-R2039072). This condition occurred after the breaker

had been cycled satisfactorily eight times. An analysis performed by the

manufacturer determined that this condition affected only the manual closure of the

breaker which is used for maintenance and would not come into play during normal

auto electrical operation of the breaker. Therefore, NS-P-1A operability was not

impacted (IRs 707261 and 730312).

  • On December 11, SF-P-1A inadvertently tripped during surveillance testing per 1303-

4.19, HPI/LPI Analog Channel test, Rev. 26. Engineers determined the cause was a

misaligned contact in ESAS load shed relay 63Z1B-RC2A. Operability of SF-P-1A

was not affected because the relay function to trip the pump upon an ESAS actuation

was not affected (IR-710133).

  • On January 2, 2008, operators and technicians identified that the reactor building

emergency cooling and isolation system channel RB2A failed to actuate during

performance of ESAS surveillance testing. Engineers determined that this condition

only affected the test circuit and not the safety portion of the circuit (IRs-717254 and

725846).

b. Findings

No findings of significance were identified.

1R18 Plant Modifications (71111.18 - 1 sample)

a. Inspection Scope

The inspectors reviewed the following modification to determine whether it was designed

and/or implemented as required by CC-AA-102, Design Input and Configuration Change

Impact Screening, Rev. 14 and CC-AA-103, Configuration Change Control, Rev. 17.

The inspectors verified the modification supported plant operation as described in the

Enclosure

9

Updated Final Safety Analysis Report (UFSAR) and complied with associated TS

requirements. The inspectors reviewed the function of the changed component, the

change description and scope, and the associated 10 CFR 50.59 screening evaluation.

  • Engineering Change Request (ECR) # 06-595, Decay River Strainer, Rev. 0 was

installed to replace the funnel type strainer media with a flat metal disc media to

reduce the potential for clogging by filamentous algae. This algae caused

excessive strainer clogging in May 2006 due to a bloom associated with lower than

usual river levels. The inspectors also reviewed IR-588605 which evaluated a

higher than expected differential pressure result during post installation testing of

the new media. Engineers determined that the higher differential pressure was due

to improper design of the media (lesser number of holes). The evaluation also

determined that this media did not affect operability of the strainer and decay river

system. The inspectors verified corrective actions including revision to the ECR to

specify the correct number of holes for the media. In addition, actions to replace

the existing media with the proper design are scheduled for May 2008.

b. Findings

No findings of significance were identified.

1R19 Post Maintenance Testing (71111.19 - 7 samples)

a. Inspection Scope

The inspectors reviewed and/or observed the following post-maintenance test (PMT)

activities to ensure: (1) the PMT was appropriate for the scope of the maintenance work

completed; (2) the acceptance criteria were clear and demonstrated operability of the

component; and (3) the PMT was performed in accordance with procedures.

  • On December 12, 2007, operators performed post maintenance testing in

accordance with 1303-4.19, HPI/LPI Analog Channel Test, Interim Change 24193,

following replacement of a misaligned contact that caused an inadvertent trip of SF-

P-1A (Ref: Section 71111.15). The inspectors reviewed the PMT scope adequacy

and results to ensure the PMT addressed the results of additional relay failure

analysis performed in January 2008.

  • On January 23, 2008 operators performed post maintenance testing in accordance

with OP-TM-424-212, IST of EF-V-30s and EF-V-52s, Rev.2, following replacement

of the actuator for EFW-V-30B.

  • On January 24, operators performed post maintenance testing in accordance with

1303-4.13, RB Emergency Cooling and Isolation System Analog Test, Rev. 40, and

Interim Change 24192, following replacement of multiple components to address a

relay (T2/RB2A) failure to de-energize (IR-725846).

  • On February 13, operators performed post maintenance testing of DR-P-1B in

accordance with Work Order C2016938 following replacement of a faulted X-relay

within electrical circuit breaker DR-P-1B-BK.

Enclosure

10

  • Control building chiller AH-C-4B was degraded, due to developing insufficient oil

pressure upon starting from a standby condition. Technicians implemented a

complex troubleshooting plan including oil samples, auxiliary oil pump voltage and

current readings, replacement of the auxiliary pump and motor, and borescope

inspection of the auxiliary oil system and compressor work order C2016844. Post

maintenance tests were performed from February 15 to March 11, using C2016844

and E-108, Control Building Chiller AH-C-4A/B Weekly, Quarterly, and Annual

Inspection, Interim Change 19851.

  • On February 27, operators performed post maintenance testing of ESAS relay 63X-

RB6B, in accordance with procedure 1303-4.14, RB 30 PSIG Analog Channels,

Interim Change 24839, following replacement of a contact that was providing

intermittent indication.

  • On March 27, CM-V-3 open and close strokes were successfully verified using

procedure 1300-3Q.5, Quarterly Inservice Testing of CM-V-1/2/3/4 Valves During

Normal Plant Operations, Rev. 1 following troubleshooting to address excessive

valve closure stroke time.

b. Findings

No findings of significance were identified.

1R22 Surveillance Testing (71111.22)

a. Inspection Scope (3 Inservice Testing Samples and 2 Routine Surveillance Samples)

The inspectors observed and/or reviewed the following operational surveillance tests to

verify adequacy of the test to demonstrate the operability of the required system or

component safety function. Inspection activities included review of previous surveillance

history to identify previous problems and trends, observation of pre-evolution briefings,

and initiation/resolution of related IRs for selected surveillances.

  • From December 27, 2007 to January 2, 2008, procedure OP-TM-214-211,

Verification of TSP, Rev. 0

  • On January 2, 2008, 1303-4.13, RB Emergency Cooling and Isolation System

Analog Test, Rev. 40 and Interim Change 24192.

Test, Rev. 0

  • On February 12, procedure OP-TM-211-251, Leakage Exam Of MU System, Interim

Change 23462

b. Findings

No findings of significance were identified.

1EP6 Drill Evaluation (71114.06)

a. Inspection Scope (1 Training Evolution Sample)

Enclosure

11

The inspectors observed an emergency event training evolution conducted on March 18,

2008, at the Unit 1 control room simulator to evaluate emergency procedure

implementation, event classification, and event notification. The event scenario involved

multiple safety-related component failures and plant conditions warranting simulated

Unusual Event and Alert emergency event declarations. The inspectors observed the

drill critique to determine whether the licensee critically evaluated drill performance to

identify deficiencies and weaknesses. Additionally, the inspectors verified the

Drill/Exercise performance indicators were properly evaluated consistent with NEI 99-02,

Regulatory Assessment Performance Indicator Guideline, Rev. 5. Additional documents

reviewed are listed in the Attachment.

b. Findings

No findings of significance were identified.

2. RADIATION SAFETY

Cornerstone:Occupational Radiation Safety

20S1 Access Controls (71121.01 - 4 samples)

a. Inspection Scope

The inspectors reviewed selected activities and associated documentation in the below

listed areas. The evaluation of AmerGens performance in these areas was against

criteria contained in 10 CFR 20, applicable TSs, and applicable AmerGen procedures.

Plant Walkdowns, Radiation Work Permit Reviews, Job Reviews

The inspectors walked down selected radiological controlled areas and reviewed

housekeeping, material conditions, posting, barricading, and access controls to

radiological areas. The inspectors toured areas of the Auxiliary Building, Spent Fuel

Area, outdoor areas, and radioactive waste processing area. The inspectors conducted

selective independent radiation surveys, and verified the adequacy of: selected

radiological boundaries and postings; that engineering controls were in place; that air

samplers were properly located; and that TS locked High Radiation Areas (HRA) were

properly secured and posted.

The inspectors selectively reviewed the applied radiological controls for personnel entry

into the Unit 1 reactor building containment at power on March 3, 2008, and movement

of concentrated radioactive waste on March 6, 2008. The reviews included evaluation of

the adequacy of all applied radiological controls including radiation work permits,

procedure adherence, radiological surveys, job coverage, airborne radioactivity sampling

and controls, and contamination controls. The reviews included, where applicable,

barrier integrity and the application of engineering controls for potential airborne

radioactivity areas and radioactive source-term, and radiation levels present. The

inspectors attended the briefing for workers involved in radioactive waste handling.

The inspectors also reviewed and discussed electronic dosimeter and

thermoluminescent dosimeter results to identify anomalies and licensee actions, as

applicable.

Enclosure

12

The inspectors reviewed and discussed internal dose assessments for 2007 to identify

any apparent actual occupational internal doses greater than 50 millirem committed

effective dose equivalent. The inspectors assessed the adequacy of evaluations for

selected dose assessments and included selected review of the program for evaluation

of potential intakes associated with hard-to-detect radionuclides (e.g., airborne

transuranics).

High Risk Significant, High Dose Rate HRA and Very High Radiation Area Controls

The inspectors conducted a selective review of HRA controls (e.g., adequate posting

and locking of entrances). The inspectors verified that locked HRAs were properly

secured and posted and that surrounding area dose rates met regulatory criteria. The

inspectors reviewed and observed controls used for ongoing work such as waste

transfer. The inspectors verified procedure adherence by observation, attendance at

briefings, and questioning radiation protection personnel and workers.

Radiation Worker/Radiation Protection Technician Performance and Radiation

Protection Technician Proficiency

The inspectors evaluated radiation protection technician performance and proficiency

relative to control of hazards and work activities, as applicable. In addition, the

inspectors reviewed issue reports to identify problems with worker or radiation protection

technician performance.

Problem Identification and Resolution

The inspectors selectively reviewed self-assessments and audits since the previous

inspection to determine if identified problems were entered into the corrective action

program for resolution. The inspectors evaluated the corrective action program

database for repetitive deficiencies or significant individual deficiencies to determine if

self-assessment activities were identifying and addressing the deficiencies.

The review included an evaluation of data to determine if any problems involved

performance indicator (PI) events with dose rates greater that 25 R/hr at 30 centimeters,

greater than 500 R/hr at 1 meter or unintended exposures greater than 100 millirem total

effective dose equivalent, 5 rem shallow dose equivalent, or 1.5 rem lens dose

equivalent. The inspectors also reviewed the corrective action database for non-PI

radiological incidents to determine if follow-up activities were being conducted in an

effective and timely manner consistent with radiological risk.

The inspectors reviewed selected issue reports since the last inspection which involved

potential radiation worker or radiation protection personnel errors to determine if there

was an observable pattern traceable to a similar cause. The review included an

evaluation of corrective actions, as appropriate. (Section 4OA2)

b. Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02 - 2 samples)

a. Inspection Scope

Enclosure

13

The inspectors conducted the following activities to determine if AmerGen was properly

implementing operational, engineering, and administrative controls to maintain personnel

occupational radiation exposure as low as is reasonably achievable (ALARA).

Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and applicable AmerGen procedures.

Inspection Planning, Radiological Work Planning

The inspectors determined the plants current 3-year rolling average collective exposure.

The inspectors evaluated site specific trends in collective exposures (using NUREG-

0713 and plant historical data). The inspectors discussed proposed occupational

radiation exposure estimates for 2008.

Job Site Inspections and ALARA Controls

The inspectors observed ongoing work activities (e.g., radioactive waste handling) to

evaluate implementation of ALARA controls for the activities. The inspectors reviewed

exposures of individuals from selected work groups to identify significant exposure

variations which may exist among workers.

Verification of Dose Estimates and Exposure Tracking

The inspectors reviewed Station ALARA Committee and sub-committee meeting minutes

for the fall 2007 outage and post-outage to date. The inspectors compared aggregate

exposure sustained per work activity, with initial estimates, to evaluate effectiveness of

ALARA actions and accuracy of dose estimates. The inspectors compared results

achieved with the intended dose established for the work tasks reviewed.

Source-Term Reduction and Control

The inspectors reviewed and discussed AmerGens understanding of the Unit 1 plant

source-term, including knowledge of input mechanisms to reduce the source term, and

the source-term control strategy in place. The inspectors reviewed reactor coolant

chemistry data to evaluate the effectiveness of post shutdown source-term reduction

efforts including strategies employed such as system flushes, installation of temporary

shielding, and chemistry controls. The inspectors reviewed efforts to reduce Unit 1

reactor cavity and spent fuel pool radionuclide concentrations in support of ongoing work

activities.

Radiation Worker/Radiation Protection Technician Performance

The inspectors selectively observed radiation worker and radiation protection technician

performance in the area of ALARA practices during transfer of radioactive materials on

March 6, 2008. The inspectors selectively questioned workers and radiation protection

personnel in the field to evaluate their understanding of ambient radiological conditions.

The inspectors evaluated performance to determine whether the training/skill level was

sufficient with respect to the radiological hazards involved.

Problem Identification and Resolution

Enclosure

14

The inspectors selectively reviewed issue reports in this area since the last inspection to

determine if AmerGen was including ALARA deficiencies and issues in its corrective

action program. (See Section 4OA2)

The review included self-assessments, audits, and corrective action reports related to

the ALARA program since the last inspection to determine if the follow-up activities were

being conducted in an effective and timely manner commensurate with their importance

to safety and risk.

b. Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 1 sample)

a. Inspection Scope

The inspectors reviewed selected activities and associated documentation in the below

listed areas. The evaluation of AmerGens performance in these areas was against

criteria contained in 10 CFR 20, applicable TSs, and applicable station procedures.

Self-Contained Breathing Apparatus

The inspectors reviewed the functional testing and inspection of self-contained breathing

apparatus (SCBA) to ensure equipment was being properly maintained and inspected in

accordance with the manufacturers recommendations and applicable regulatory

requirements. The functional testing of three SCBA units, ready for use in the Unit 1

Control Room, was reviewed (Kit Nos. 1, 2, 3). The inspectors also visually inspected

the SCBA kits and additional mask units. The components of the three kits were also

checked against approved component lists published by the SCBA manufacturer and the

National Institute for Occupational Safety and Health. The inspectors reviewed periodic

testing of the SCBA units components (i.e., hydro testing of tank, maintenance and

testing of regulators, low pressure alarms) and reviewed conformance of the SCBAs with

published certification lists.

Problem Identification and Resolution

The inspectors reviewed issue reports in this area since the last inspection to determine

if AmerGen was including instrument deficiencies and issues in its corrective action

program (Section 4OA2). The review included self-assessments, audits, and corrective

action reports.

b. Findings

No findings of significance were identified.

Cornerstone: Public Radiation Safety

2PS2 Radioactive Material Processing and Transportation (71122.02 - 1 sample)

a. Inspection Scope

Enclosure

15

The inspectors selectively reviewed the packaging and shipment preparation of a non-

exempt radioactive material shipment (RS-08-029-1). Matters reviewed included:

packaging and vehicle radiation dose rates; placarding of vehicle; completion of

applicable shipping papers; qualification of personnel overseeing and processing

shipment; emergency instructions; general truck and trailer condition; closure and use

requirements.

The inspectors also selectively reviewed training provided for station personnel relative

to 49 CFR 172, and NRC Bulletin 79 -19.

b. Findings

No findings of significance were identified.

4. OTHER ACTIVITIES

4OA1 Performance Indicator Verification (71151 - 3 samples)

a. Inspection Scope

Cornerstone: Initiating Events

The inspectors reviewed selected station records to verify NRC PIs had been accurately

reported to the NRC as specified in NEI 99-02, Regulatory Assessment Performance

Indicator Guideline, Rev. 5. The three PI samples listed below were verified for the

period January to December 2007.

$ Unplanned Scrams per 7000 Critical Hours

$ Unplanned Scrams with Complications

$ Unplanned Power Changes per 7000 Critical Hours

The inspectors reviewed operator logs, licensee event reports, monthly station operating

reports, corrective action program database documents, calculation methods, definition

of terms, and use of clarifying notes. The inspectors also verified accuracy of the

number of reported critical hours used in the calculations.

b. Findings

No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152)

.1 Review of Issue Reports and Cross-References to Problem Identification and Resolution

Issues Reviewed Elsewhere

The inspectors performed a daily screening of items entered into the licensees

corrective action program. This review was accomplished by reviewing a list of daily IRs,

reviewing selected IRs, attending daily screening meetings, and accessing the licensees

computerized corrective action program database.

.2 Annual Sample: Access Control Deficiencies

Enclosure

16

a. Inspection Scope (1 sample)

The inspectors reviewed AmerGen=s actions in response to issue reports generated as a

result of multiple issues associated with access control deficiencies. The inspectors also

reviewed AmerGens procedures on searching personnel and process facility operations.

In addition, the inspectors interviewed applicable members of AmerGens staff including

site security officers and a corporate security system engineer.

b. Findings

No findings of significance were identified. The inspectors reviewed issue reports

documenting issues related to four access control deficiencies identified in 2007. In

each case, the actions taken to address the issues were appropriate. The inspectors

verified that the site has provided adequate training and guidance on process facility

operations to the security staff.

.3 Problem Identification and Resolution for Radiological Protection Activities

a. Inspection Scope

The inspectors reviewed issue reports and self-assessments to determine if identified

problems were entered into the corrective action program for resolution. The inspectors

selectively reviewed the reports to evaluate AmerGens threshold for identifying,

evaluating, and resolving problems (Apparent Cause 698893, NOS Audit 07-4Q,). The

review included a check of possible repetitive issues, such as worker or technician errors

(Issue Nos. 706402, 706624, 707298, 707789, 712475, 715167, 722282, 723723,

726821, 727146, 7377511, 740021, 689317, 695488, 689423, 689435, 689562, 696907,

692640, 707288, 744382, and 745372).

This review was against criteria contained in 10 CFR 20, Technical Specifications, and

station procedures.

b. Findings

No findings of significance were identified.

4OA5 Other Activities

.1 Temporary Instruction 2515/166 - Pressurized Water Reactor Containment Sump

Blockage (NRC Generic Letter 2004-02)

a. Inspection Scope

The inspectors performed an inspection in accordance with Temporary Instruction (TI)

2515/166, Pressurized Water Reactor Containment Sump Blockage, Rev. 1. The TI was

developed to support the NRC review of licensee activities in response to NRC Generic

Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Sump

Recirculation at Pressurized Water Reactors. Specifically, the inspectors verified that

the implementation of the modifications and procedure changes was consistent with the

actions committed to in AmerGens supplemental response to GL 2004-02, dated

December 28, 2007. The supplemental response provided the remaining information

Enclosure

17

regarding the actions and methodologies used at TMI to resolve the issues in the GL,

which included the downstream effects and chemical effects analyses.

Additionally, the inspectors reviewed the TS and the UFSAR, to verify that required

changes to the TS had been approved by the NRC and that the UFSAR had been or

was in the process of being updated to reflect the plant changes. Portions of the TI were

performed during the 2007 refueling outage to verify the containment sump

modifications; the results of that inspection were documented in Inspection Report No.

05000289/2007005.

b. Evaluation of Inspection Requirements

The TI requires the inspectors to evaluate and answer the following questions:

1. Did the licensee implement the plant modifications and procedure changes

committed to in their GL 2004-02 response?

The inspectors verified that AmerGen implemented the plant modifications and

procedure changes committed to in their GL 2004-02 responses. The inspection

performed in 2007 verified the implementation of the sump screen modifications

related to the GL. The inspectors verified that the modifications previously

installed met the assumptions of AmerGens completed analyses, which included

the chemical effects analysis. The inspectors reviewed changes to AmerGens

emergency operating procedures and verified that the procedures ensured the

assumptions described in the licensee supplemental response to the GL were

valid. Finally, the inspectors verified the modifications to address downstream

effects had been performed.

2. Has the licensee updated its licensing basis to reflect the corrective actions taken

in response to GL 2004-02?

The inspectors verified that AmerGen had either updated, or was in the process

of updating, the licensing basis to reflect the actions taken in response to GL 2004-02. Specifically, the inspectors verified that changes to the facility or

procedures as described in the UFSAR that were identified in the licensees GL 2004-02 responses were reviewed and documented in accordance with 10 CFR

50.59. The inspectors also verified that changes to the technical specifications

had been approved by the NRC, and that required changes to the UFSAR,

describing the changes to the plant, were in the process of being updated.

The inspection requirements of the Temporary Instruction are complete and the TI is

closed. The Office of Nuclear Reactor Regulation will perform a technical review of

AmerGens GL responses to ensure the licensee corrective actions adequately address

Generic Safety Issue 191, Assessment of Debris Accumulation on Pressurized Water

Reactor Sump Performance, and Generic Letter 2004-02. The NRC will document the

results of this review in a separate letter to AmerGen.

.2 Radiological Review of Steam Generator Replacement Transportation Plans (50001)

a. Inspection Scope

Enclosure

18

The inspectors selectively reviewed the preliminary plans for transport to, and storage of,

the replaced Unit 1 steam generators at the proposed storage facility. The inspectors

reviewed projected public dose calculations.

The review was against criteria contained in 10 CFR 20, site TSs, and the Offsite Dose

Calculation Manual.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On April 18, 2008, the resident inspectors presented the inspection results to Mr. Bill Noll

and other members of the TMI staff who acknowledged the findings. The regional

specialist inspection results were previously presented to members of AmerGen

management. The inspectors asked the licensee whether any of the material examined

during the inspection should be considered proprietary. No proprietary information was

identified.

ATTACHMENT: SUPPLEMENTAL INFORMATION

Enclosure

A-1

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

D. Atherholt Manager, Regulatory Assurance

C. Baker Manager, Chemistry

B. Carsky Director, Operations

T. Dougherty Plant Manager

E. Eilola Director, Site Engineering

R. Godwin Training

J. Heischman Director, Maintenance

W. Laudenbach System Engineer

A. Miller Regulatory Assurance

D. Mohre Manager, Security

P. Mussleman Security Supervisor

D. Neff Manager, Emergency Preparedness

W. Noll Site Vice President

T. Roberts Radiation Protection

D. Trostle Operations Security Analyst

L. Weir Manager, Nuclear Oversight Services

C. Wend Manager, Radiation Protection

R. West Vice President, TMI Unit 1

H. Yeldell Work Management

LIST OF ITEMS OPENED, CLOSED AND DISCUSSED

Opened & Closed

NRC TI 2515/166 Pressurized Water Reactor Containment Sump Blockage (NRC Generic

Letter 2004-02)

LIST OF DOCUMENTS REVIEWED

Section 1R04: Equipment Alignment

Procedures

1105-20, Remote Shutdown Systems, Rev. 14

1107-4, Electrical Distribution Panel Listing, Rev. 213

OP-TM-211-000, Makeup and Purification System, Rev. 16

OP-TM-212-000, Decay Heat Removal System, Rev. 11

OP-TM-214-000, Building Spray System, Rev. 8

OP-TM-533-000, Decay Heat River System, Rev. 9

OP-TM-541-000, Primary Component Cooling System, Rev. 6

OP-TM-543-000, Decay Heat Closed System, Rev. 7

Drawings

Dwg. 302-712, Reactor Building Spray, Rev. 49

Attachment

A-2

Section 1R011: Licensed Operator Requalification Program

Procedures

OP-TM-AOP-014, Loss of 1E 4160V Bus, Rev. 3

OP-TM-AOP-020, Loss of Station Power, Rev. 12

OP-TM-AOP-041, Loss of Seal Injection, Rev. 2

OP-TM-AOP-062, Inoperable Rod, Rev. 1

OP-TM-EOP-001, Reactor Trip, Rev. 9

OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5

OP-TM-EOP-009, HPI Cooling - Recovery from Solid Operations, Rev. 5

EP-AA-1009, Radiological Emergency Plan Annex for TMI Station, Rev. 10

Section 1R012: Maintenance Rule

Procedures

Alarm Response Procedure MAP NN-1-8, Main Annunciator Panel NN, Rev.4

Alarm Response Procedure, HM, Hydrogen Monitor Pane, Rev. 0

1105-18, Containment Hydrogen Monitor, Rev. 12

1104-62, Hydrogen Recombiner, Rev. 22

OP-TM-EOP-008, LOCA Cooldown, Rev. 6

IC-252, Channel Test of Reactor building Post LOCA Hydrogen Monitor, Rev. 0

IC-253, Reactor Building Post-LOCA Hydrogen Monitoring Calibration, Rev. 1

Other Documents

IR-736664, Response to NRC Question On Hydrogen Recombiners And Monitoring System

System Health Report, Containment hydrogen Monitoring, dated December 2007

Section 1EP6: Drill Evaluation

Procedures

1202-33, High Winds, Rev. 28

EP-AA-111, Emergency Classification and Protective Action Recommendations, Rev. 13

EP-AA-1009, Radiological Emergency Plan Annex for TMI Station, Rev. 10

OP-TM-EOP-001, Reactor Trip, Rev. 9

OP-TM-EOP-003, Excessive Primary to Secondary Heat Transfer, Rev. 5

OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5

OP-TM-EOP-010, Abnormal Transients Guides, Rules, and Graphs, Rev. 9

Other Documents

Licensed Operator Drill Scenario No. 51, Low System Grid voltage, High Winds,

Generator/Turbine Trip, ATWS, Stem Leak in Containment Causing Excessive Primary to

Secondary Heat Transfer, Rev. 1

Section 2OS1, 2OS2, 2OS3, 2PS2: Occupational and Public Radiation Safety

Procedures

RP-TM-503-1001, Rev. 1, Volumetric Material Controls

RP-TM-460-1007, Rev. 5, Access to TMI -1 Reactor Building

RP-AA-400, Rev. 4, ALARA Program

RP-TM-605-1001, Rev. 1, TMI Waste Characterization

RP-TM-850, Rev. 0, Radiation Protection Emergency Equipment Readiness.

6610-OPS-4510.03, Rev. 2, Inspection and Maintenance of Respiratory Equipment

Other Documents

TMI Radiological Protection T1R17 Refueling Outage Report 2007

Primary Water Chemistry Sampling Results

Attachment

A-3

Fuel Transfer Tube Radiation Surveys November 2005

Self-contained Breathing Apparatus Vendor Manual

Section 4OA2: Problem Identification & Resolution

Issue Reports

00565138, Improper Verification of Protected Area Badge

00670299, Security Explosive Detector Failed to Alarm During Testing

00652352, Access Not Verified Prior to P/A Entry Through MAF

00685064, Access Not Verified Prior to P/A Entry MAF

00699966, Improper Response to Explosive Detector Alarm

Procedures

SY-AA-101-112, Searching Personnel, Vehicles, Packages and Cargo, Rev. 12

SY-TM-1005, Processing Center Operations, Rev. 11

Other Documents

VM-TM-0946, Entry Scan Explosives Detector Model 85, Rev. 4

NRC Generic Letter 91-10, Explosives Searches at Protected Area Portals, July 8, 1991

Section 4OA5: Other

Procedures

OP-TM-214-901, RB Spray Operation, Rev. 3

OP-TM-EOP-010, Emergency Procedures Rules, Guides and Graphs, Rev. 9

Other Documents

C-1101-210-E610-011, LPI BS Pump NPSH Margin Available from the RB Sump Following a

LBLOCA, Rev. 7

ECTM005-CALC-05, Hydraulic Analyses of the Reactor Building Recirculation Sump Strainer,

Rev. 3

Inspection Report 05000289/2007005, Three Mile Island Station, Unit 1 - NRC Integrated

Inspection Report

NRC Docket No. 50-289, Technical Specification Change Request No. 337 - Reactor Building

Emergency Sump pH control System Buffer Change

PC 22736, Ops Procedures due to RB Sump Mod per ECR-06-0207, 06-0205 &

06-0206

PC 24164, EOP/EP Revisions for TSP Mod (ECR-07-00174) and GL 2004-02

Three Mile Island Unit 1 Supplemental Response to NRC Generic Letter 2004-02, Potential

Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at

Pressurized-Water Reactors, dated December 28, 2007

TM 06-00256-000, Replace DH-V-19A/B Internals

TM-07-00743-000, Generic Letter 2004-02/GSI-191 Supplemental Response

Attachment

A-4

LIST OF ACRONYMS

ADAMS Agencywide Documents and Management System

ALARA As Low As is Reasonably Achievable

AmerGen AmerGen Energy Company, LLC

AR Action Request

CFR Code of Federal Regulations

DRP Division of Reactor Projects

ECR Engineering Change Request

ESAS Engineered Safeguards and Actuation System

GL Generic Letter

HRA High Radiation Area

IMC Inspection Manual Chapter

IR Issue Report

LOCA Loss of Coolant Accident

LPI Low Pressure Injection

MAF Main Access Facility

MR Maintenance Rule

NCV Non-Cited Violation

NEI Nuclear Energy Institute

NRC Nuclear Regulatory Commission

NUMARC Nuclear Management and Resources Council

P/A Protected Area

PADEP Pennsylvania Department of Environmental Protection

PARS Publicly Available Records

PI Performance Indicator

PMT Post-Maintenance Test

SCBA Self Contained Breathing Apparatus

SSC Structures, Systems, and Components

TI Temporary Instruction

TMI Three Mile Island, Unit 1

TS Technical Specifications

UE Unusual Event

UFSAR Updated Final Safety Analysis Report

Attachment