IR 05000289/2002004

IR 05000289/02-04, on 3/31- 5/11/2002, Amergen Energy Company, LLC, Three Mile Island Unit 1, Resident Inspector Report. No Violations Identified

ML021490441
Person / Time
Site:	Three Mile Island
Issue date:	05/29/2002
From:	Rogge J NRC/RGN-I/DRP/PB7
To:	Skolds J Exelon Generation Co, Exelon Nuclear
References
IR-02-004
Download: ML021490441 (14)

Text

SUBJECT:

THREE MILE ISLAND STATION, UNIT 1 - NRC INSPECTION REPORT 50-289/02-04

Dear Mr. Skolds:

On May 11, 2002, the NRC completed an inspection at your Three Mile Island Unit 1 facility.

The enclosed report documents the inspection findings that were discussed on May 17, 2002, with Mr. George Gellrich and other members of your staff.

This 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.

No findings of significance were identified.

Immediately following the terrorist attacks on the World Trade Center and the Pentagon, the NRC issued an advisory recommending that nuclear power plant licensees go to the highest level of security, and all promptly did so. With continued uncertainty about the possibility of additional terrorist activities, the Nation's nuclear power plants remain at the highest level of security and the NRC continues to monitor the situation. This advisory was followed by additional advisories, and although the specific actions are not releasable to the public, they generally include increased patrols, augmented security forces and capabilities, additional security posts, heightened coordination with law enforcement and military authorities, and more limited access of personnel and vehicles to the sites. The NRC has conducted various audits of your response to these advisories and your ability to respond to terrorist attacks with the capabilities of the current design basis threat (DBT). On February 25, 2002, the NRC issued an Order to all nuclear power plant licensees, requiring them to take certain additional interim compensatory measures to address the generalized high-level threat environment. With the issuance of the Order, we will evaluate AmerGens compliance with these interim requirements.

In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARs) component of NRCs document system

Mr. (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

We appreciate your cooperation. Please contact me at 610-337-5146 if you have any questions regarding this letter.

Sincerely, John F. Rogge, Chief Projects Branch 7 Division of Reactor Projects Docket No: 50-289 License No: DPR-50

Enclosure:

NRC Inspection Report 50-289/02-04 Attachment: Supplemental Information

REGION 1 Docket No: 50-289 License No: DPR-50 Report No: 50-289/02-04 Licensee: AmerGen Energy Company, LLC (AmerGen)

Facility: Three Mile Island Station, Unit 1 Location: PO Box 480 Middletown, PA 17057 Dates: March 31 - May 11, 2002 Inspectors: J. Daniel Orr, Senior Resident Inspector Craig W. Smith, Resident Inspector Approved by: John F. Rogge, Chief Projects Branch 7 Division of Reactor Projects

SUMMARY OF FINDINGS IR 05000289/02-04, on 3/31 - 5/11/2002, AmerGen Energy Company, LLC, Three Mile Island Unit 1, resident inspector report.

The report covered a six-week period of inspection by resident inspectors. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using IMC 0609 Significance Determination Process (SDP). Findings for which the SDP does not apply are indicated by No Color or by the severity level of the applicable violation. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described at its Reactor Oversight Process website at http://www.nrc.gov/reactors/operating/oversight.html.

A. Inspector Identified Findings

• No findings of significance were identified.

B. Licensee Identified Violations C No violations were identified.

ii

Report Details Summary of Plant Status AmerGen Energy Company, LLC (AmerGen), operated Three Mile Island, Unit 1 (TMI) at or near 100 percent power throughout the inspection period.

1. REACTOR SAFETY Initiating Events/Mitigating Systems/Barrier Integrity [REACTOR - R]

1R01 Adverse Weather Protection a. Inspection Scope The inspectors reviewed AmerGens adverse weather procedures for risk-significant systems susceptible to extreme high temperatures and high winds. The inspectors walked-down abnormal procedure 1203-34, Control Building Ventilation, operating procedure 1104-30, Nuclear River Water, and emergency procedure 1202-33, Tornado/High Winds. The inspectors verified that adequate instructions existed in the procedures and that portable equipment referenced in the procedures was readily accessible. The inspectors reviewed the corrective action program data base to determine if AmerGen was identifying and resolving weather related equipment problems.

b. Findings No findings of significance were identified.

1R04 Equipment Alignments a. Inspection Scope The inspectors conducted a partial system walkdown on the B emergency diesel generator and its associated engineered safeguards electrical distribution system while the A emergency diesel generator (EDG) was out of service for a scheduled inspection and overhaul. The inspectors verified that the B EDG alignment was in accordance with operating procedure 1107-3, Diesel Generator, and that operating parameters were normal. The diesel generator and engineered safeguards electrical distribution system provide a reliable electric power source to safety related systems during a loss of off-site power event.

b. Findings No findings of significance were identified.

1R05 Fire Protection a. Inspection Scope The inspectors conducted fire protection inspections for the following plant zones:

• intermediate building steam driven emergency feedwater pump room

• intermediate building motor driven emergency feedwater pump room

• main control room and adjacent areas

• control tower fifth floor The rooms and areas were selected based on enclosing equipment important to safety.

The inspectors conducted plant walkdowns and verified the areas were as described in the fire hazard analysis report. The plant walkdowns included observations of combustible material control, fire detection and suppression equipment operability, and compensatory measures established for degraded fire protection equipment.

b. Findings No findings of significance were identified.

1R11 Licensed Operator Requalification a. Inspection Scope The inspectors observed a simulator requalification training session on April 24, 2002.

The inspectors reviewed the lesson plans, assessed operator performance during the training sessions, and observed the evaluators critique of the training scenario.

b. Findings No findings of significance were identified.

1R12 Maintenance Rule Implementation a. Inspection Scope The inspectors verified AmerGens implementation of the maintenance rule for the following equipment performance problems:

• degraded auxiliary condenser vacuum indication

• high pressure injection valve push button maintenance preventable functional failure

• integrated control system functional failures

• A main turbine electro-hydraulic control system pump functional failure The high pressure injection (HPI) valve push button failure involved a risk significant function of the HPI system, while the other equipment problems listed could have increased the likelihood of an initiating event.

The aspects of maintenance rule implementation inspected included safety significance classification, a(2) performance monitoring or a(1) goal setting and corrective actions, and maintenance preventable functional failure determinations. The inspectors referenced 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Plants, and AmerGen administrative procedure 1082, NRC Maintenance Rule.

b. Findings No findings of significance were identified.

1R13 Maintenance Risk Assessments and Emergent Work Evaluation a. Inspection Scope The inspectors reviewed AmerGens planning and risk assessments for two risk significant maintenance activities: desilting and underwater inspection of the river water intake structure and station blackout diesel generator output feeder breaker preventive maintenance and repair. The inspectors reviewed the risk assessment of these planned maintenance activities with respect to 10 CFR 50.65(a)(4). The inspectors referenced AmerGen administrative procedure 1082.1, TMI Risk Management Program, and NUMARC 93-01, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants.

b. Findings No findings of significance were identified.

1R14 Personnel Performance During Non-Routine Plant Evolutions a. Inspection Scope The inspectors evaluated the main control room operators response to an unanticipated reactor coolant system (RCS) letdown isolation. The isolation occurred during process radiation monitor surveillance testing on April 16, 2002. Control room logs and AmerGens corrective action condition report were reviewed. The inspectors verified that the plant response, a minor reactor coolant system pressure transient from steady state 2155 psig to 2202 psig, was as expected. The inspectors also verified through log review that operators restored RCS letdown in a timely manner using plant procedure, 1104-2, Makeup and Purification.

Findings b. No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope The inspectors reviewed an operability evaluation for a degraded steam trap on the steam supply line to the turbine driven emergency feedwater pump. The inspectors verified that the operability of the turbine driven emergency feedwater pump was properly justified and that no unrecognized increase in plant risk resulted from the degraded steam trap.

b. Findings No findings of significance were identified.

1R16 Operator Work-Arounds a. Inspection Scope The inspectors reviewed identified operator work-arounds. The inspectors reviewed plant operating logs, turnover checklists, out of service equipment lists, active clearances, and interviewed plant operators and system engineers for potential unidentified operator work-arounds. The reviews were performed to determine the cumulative effect of equipment deficiencies on system performance, operator response, or increased likelihood for an initiating event.

b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing a. Inspection Scope The inspectors reviewed post-maintenance tests performed by AmerGen in conjunction with the following work activities on risk significant equipment:

C A emergency diesel generator biennial inspection and overhaul C turbine driven emergency feedwater pump steam trap internals replacement C station blackout diesel generator feeder breaker auxiliary contact repair The inspectors verified that the post-maintenance test procedures and test activities were adequate to verify operability and functional capability prior to the affected systems being returned to service.

b. Findings No findings of significance were identified.

1R22 Surveillance Testing a. Inspection Scope

The inspectors observed portions of and reviewed the results of the following surveillances:

• river water intake structure underwater inspections

• high and low pressure injection system analog channel tests

• air intake tunnel fire protection system test The inspectors reviewed AmerGens corrective action program for problems identified during previous performances of the tests to determine if problems involving surveillance testing were being identified and resolved at an appropriate threshold.

b. Findings No findings of significance were identified.

1R23 Temporary Plant Modifications a. Inspection Scope On April 19, 2002, equipment operators identified a degraded steam trap on the turbine driven emergency feedwater pump steam supply line. As a compensatory measure, AmerGen installed a temporary modification to measure the level of condensate in the steam supply line when the trap was bypassed. The inspectors verified that the installation of the modification was consistent with the written documentation and that there were no adverse effects on system operability.

b. Findings No findings of significance were identified.

Emergency Preparedness [EP]

1EP6 Drill Evaluation a. Inspection Scope On April 10, 2002, the inspectors observed a simulator scenario that AmerGen credited toward the Drill/Exercise Performance NRC performance indicator. The inspectors evaluated the opportunities for classification and notification of the emergency action levels presented in the simulator scenario. The inspectors verified that AmerGen correctly evaluated the simulator participants classifications and notifications.

b. Findings No findings of significance were identified.

4. OTHER ACTIVITIES 4OA1 Performance Indicator Verification

a. Inspection Scope The inspectors verified the performance indicator for the initiating events cornerstone.

The inspectors reviewed the performance indicator data for unplanned scrams per 7,000 critical hours, scrams with loss of normal heat removal, and unplanned power changes for 7,000 critical hours for the previous four calendar quarters. The inspectors reviewed licensee event reports (LERs), control room logs, and monthly operating reports.

b. Findings No findings of significance were identified.

4OA2 Identification and Resolution of Problems

.1 Human Performance Corrective Actions Follow-up a. Inspection Scope The inspectors reviewed AmerGens root cause evaluation and corrective actions in response to an August 2001 degraded main condenser vacuum event. The event was documented in NRC Inspection Report 50-289/2001-006, dated October 17, 2001, and determined to be of very low safety significance. AmerGens root cause and corrective actions are documented in its corrective action process (reference number CR 00072497). AmerGen determined the root cause for the event to be human performance errors. AmerGen also identified several contributing causes: inadequate pre-job briefing, lack of supervisory oversight, and poor verification practices. The inspectors reviewed AmerGens corrective actions for each of the identified causes.

b. Findings No findings of significance were identified.

.2 Maintenance Practices Corrective Actions Follow-up a. Inspection Scope The inspectors reviewed AmerGens corrective actions in response to an NRC identified non-cited violation involving inadequate maintenance practices related to the A nuclear services river water pump. The maintenance problems were documented in NRC Inspection Report 50-289/2001-002, dated May 9, 2001, and were determined to be of very low safety significance. The inspectors determined that AmerGens corrective actions were appropriate and completed in a timely manner.

b. Findings

No findings of significance were identified.

4OA6 Management Meetings Exit Meeting Summary On May 17, 2002, the resident inspectors presented the inspection results to members of AmerGen management led by Mr. George Gellrich. AmerGen acknowledged the findings presented. AmerGen did not indicate that any of the information presented at the exit meetings was proprietary.

ATTACHMENT SUPPLEMENTAL INFORMATION a. Key Points of Contact M. Bruecks, Site Security Manager G. Gellrich, Plant Manager L. Clewett, Director, Site Engineering D. McDermott, Director, Maintenance G. Rumbold, Manager, Regulatory Assurance S. Queen, Senior Manager, Plant Engineering J. Robertson, Plant Operations Director B. Williams, Vice President, TMI Unit I b. Acronyms ADAMS Agencywide Documents and Management System AmerGen AmerGen Energy Company, LLC CAP Corrective Action Process CFR Code of Federal Regulations DBT Design Basis Threat EDG Emergency Diesel Generator HPI High Pressure Injection IR Inspection Report LER Licensee Event Report NCV Non-cited Violation NRC Nuclear Regulatory Commission PARs Publicly Available Records psig Pounds per square inch gauge RCS Reactor Coolant System SDP Significance Determination Process TMI Three Mile Island, Unit 1