IR 05000289/2011003

IR 05000289-11-003, on 04/01/11 - 06/30/11, Three Mile Island Station, Unit 1 - NRC Integrated Inspection Report

ML112082228
Person / Time
Site:	Three Mile Island
Issue date:	07/27/2011
From:	Bellamy R R NRC/RGN-I/DRP/PB6
To:	Pacilio M J Exelon Nuclear, Exelon Generation Co
BELLAMY, RR
References
IR-11-003
Download: ML112082228 (40)

Text

July 27, 20LIMr. Michael J. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer (CNO), Exelon Nuclear4300 Winfield RoadWarrenville, lL 60555

SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED INSPECTIONREPORT 50002891201 1 003

Dear Mr. Pacilio:

On June 30, 2011, the U,S. Nuclear Regulatory Commission (NRC) completed an integratedinspection at your Three Mile lsland, Unit 1 (TMl) facility. The enclosed inspection reportdocuments the inspection results, which were discussed on July 1 5, 2011, with Mr' Rick Libra,TMI Plant Manager and other members of your staff'The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewedpersonnel.On the basis of the results of this inspection, no findings of significance were identified'ln accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC public Document Room or from the Publicly Available Records (PARS) component ofNRC's document system (ADAMS). ADAMS is accessible from the NRC Website athttp://www.nrc.qovlreadino-rm/adams.html (the Public Electronic Reading Room)'We appreciate your cooperation. Please contact me at 610-337-5200 if you have any questionsregarding this letter.Docket No: 50-289License No: DPR-50

Enclosure:

Inspection Report05000289/2011003

w/Attachment:

Supplemental Information-onald R. Bellamy, July 27, 2OILMr. MichaelJ. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer (CNO), Exelon Nuclear4300 Winfield RoadWarrenville, lL 60555

SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATEDTNSPECTTON REPORT 5000289t201 1 003

Dear Mr. Pacilio:

On June 30,2011, the U.S. Nuclear Regulatory Commission (NRC) completed an integratedinspection at your Three Mile lsland, Unit 1 (TMl) facility. The enclosed inspection reportdocuments the inspection results, which were discussed on July 1 5, 2011, with Mr. Rick Libra,TMI Plant Manager and other members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewedpersonnel.On the basis of the results of this inspection, no findings of significance were identified.In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) component ofNRC's document system (ADAMS). ADAMS is accessible from the NRC Website athttp://www.nrc.qov/readinq-rmiadams.html (the Public Electronic Reading Room).We appreciate your cooperation. Please contact me at 610-337-5200 if you have any questionsregarding this letter.

Sincerely,/RA by Scott Barber Acting For/Ronald R. Bellamy, PhD, ChiefProjects Branch 6Division of Reactor ProjectsDocket No: 50-289License No: DPR-50

Enclosure:

Inspection Report05000289/2011003

w/Attachment:

Supplemental Informationcc w/encl: Distribution via ListServDistribution: see attached pageSUNSI Review Complete: GSB (Reviewer's Initials)Document Name: G:\DRP\BRANCH6\+++THREE MILE ISLAND\TMl INSPECTION REPORTS\TMI 1 1 -OO3_REVISED.DOCXAfter declaring this document "An Official Agency Record" it will be released to the Public.To receive a copv of thisindicate in the box: "C"= Cooy without attachmenUenclosureML1120822287t27t117t271117t 27t11CORD COPYwith attachmenUenclosure,'N"=N0 copy M. PacilioDistribution w/encl:W. Dean, RA (RIORAMAIL Resource)D. Lew, DRA (RIOMMAlL Resource)D. Roberts, DRP (RIDRPMAIL Resource)J. Clifford, DRP (RIDRPMAlL Resource)C. Miller, DRS (RlDRSMail Resource)P. Wilson, DRS (Rl DRSMail Resource)R. Bellamy, DRPS. Barber, DRPC. Newport, DRPN. Lafferty, DRPA. Dugandzic, DRPD. Kern, DRP, SRIJ. Heinly, DRP, RlC. LaRegina, DRP, OAJ. McHale, Rl OEDORidsNrrPMThreeMilelsland ResourceRidsNrrDorlLpl 1 -2 ResourceROPReports Resource Docket No:License No:Report No:Licensee:Facility:Location:Dates:Inspectors:Approved by:1U.S. NUCLEAR REGULATORY COMMISSIONREGION 150-289DPR-5005000289/201 1 003Exelon Generation CompanyThree Mile lsland Station, Unit 1Middletown, PA 17057April 1 through June 30, 2011D. Kern, Senior Resident Inspector, Three Mile lslandJ. Heinly, Resident Inspector, Three Mile lslandE. Bonney, Resident Inspector, Beaver Valley Units 1 and 2R. Nimitz, Senior Health PhYsicistR. R. Bellamy, ChiefProjects Branch 6Division of Reactor Projects (DRP)Enclosure 2

SUMMARY OF FINDINGS

lR 0500028912011003,04/01/2011-06/3012011; Exelon Generation Company, LLC; Three Milelsland, Unit 1, Integrated Inspection Report'The report covered a three-month period of baseline inspection conducted by residentinspeciors and announced inspections by regional specialist inspectors. No findings ofsignificance were identified. The NRC's program for overseeing the safe operation ofcommercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,Rev. 4, dated December 2006.Enclosure

4

REPORT DETAILS

Summarv of Plant StatusThree Mile lsland, Unit 1 (TMl) began the inspection period at approximately 100 percent ratedtf,ermaf power. On tvtay i1, operators rapidly reduced power to 76 percent as requested by.thetransmission system o[erator'due to emergent grid conditions. Reactor power was returned to100 percent on May ii. on May 20, rrut reouced power to 50 percent to remove the 'A' coolingtower from service for pipe repaits. TMI restored power to 100 percent following themaintenance outage oh 'rtrry 22 and continued to operate at full power through the end of theinspection period.1. REACTOR SAFEWGornerstones: Initiating Events, Mitigating Systems, Barrier IntegritylROl Adverse Weather Protection (71111.01).1(1 sample)a. lnspection ScoPeOn April 27, a severe storm approached TMl. Plant on-line maintenance risk wasyellow, due to the station blackout (SBO) diesel generator and the turbine drivenemergency feed water pump (EF-e-t; both being unavailable due to plannedmaintenance activities.'At i:1'0 p.m.,ihe NationilWeather Service declared a TornadoWarning anO operators entered procedure OP-TM-AOP-004, Tornado / High Winds,Rev. 1.-Operaiors and work control personnel reassessed work activities to optimizeequipment availability. Station personnel expedited completion of correctivemaintenance and restoration of the SBO diesel generator. The inspectors met withvarious station personnelto discuss the associated potential impact on offsite poweravailability, the river water intake pathway, emerg.ency response..organization (ERO) andplant operatorTsecurity otficer relief availability. The inspectors discussed stationimplementation of Oi-nn-tOg 411-1001, Severe Weather and Natural DisasterGuidelines, Rev. 5 and op-TM-108-111-1001, TMI Site lnaccessibility Plan, Rev.3' onApril 28, at 1:54 a.m., the tornado watch was terminated' At 3:46 a'm', the NationalWeather Service declared a Severe Thunderstorm Warning' ln accordance with WC-AA-101, On-Line Work Control Process, Rev. 18, station on-line maintenance risk wasnow elevated to Orange, due to the increased potentialfor a loss of offsite power,combined with EF-p-1-being unavailable. The inspectors performed station walkdowns,interviewed opeiators and icurity officers, and observed plant operations prior to,during, and after the storm to veriiy TMI operation was consistent with TechnicalSpeci-ficationt ifS;, plant proceduies, and the Security Plan' The inspectors alsoverified that EiO capabiliiies were maintained in accordance with EP-AA-1009'Radiological Emergency Plan Annex for TMI Station, Rev' 16' The SevereThunderstorm Wairing was cancelled at 6:45 a.m. and station on-line maintenance riskreturned to Green. Ad-ditionat documents reviewed are listed in the Attachment'b. FindinosNo findings were identified.Enclosure

===.2 Power Grid Reliabilitv: Readiness of Offsite and Alternate AC Power Svstems (1sample)a. Inspection ScopeThe inspectors verified plant features and procedures for continued operation andreliability of the offsite power grid and onsite alternate AC power systems during adverseweather (i.e., thunderstorms and hot weather extremes). Reviews included stationprocedures affecting operation of onsite electrical generation sources andcommunication protocols between control room operators and the transmission systemoperator to verify appropriate information is exchanged when issues arise that couldimpact the offsite power system. The inspectors reviewed lssue Report (lR) 1 180791,which evaluated a difference in voltage indication between the two 230KV buses that aresupplied from offsite power. The condition was evaluated and determined to be only anindication anomaly with no potential adverse impact to plant equipment or reliability ofany offsite power source. The inspectors interviewed station personnel, reviewedequipment maintenance and corrective action program records, and performed an in-plant and switchyard walkdown to physically verify material condition, readiness of theoffsite electrical transformers, and readiness of onsite emergency diesel generators.Additional documents reviewed are listed in the Attachment.b. FindinqsNo findings were identified..3 Dike/Flood Control Svstem (1 sample)a. Inspection ScopeThe inspectors reviewed Exelon's externalflooding mitigation strategy includingapplicable sections of the Updated Final Safety Analysis Report (UFSAR) and historicissue reports. The inspectors reviewed station surveillance procedure 3301-S41, DikeInspection, Rev. 14 which was performed by utility technicians during the week of May23, to determine the condition of the flood barrier and whether repairs were needed. Theinspectors accompanied the technicians on the walkdown of the flood protection dike toverify it was capable of performing its design function. Specifically, the inspectorsverified that the dike maintained the appropriate design slope, contained no unwantedvegetation or depressions, and the flood protection valves would operate as designed.Additional documents reviewed are listed in the Attachment.b. FindinosNo findings were identified.

=

1R05 Fire Protection (71111.05Q - 9 samples)a. Inspection ScopeThe inspectors conducted fire protection inspections for several plant fire zones whichwere selected based on the presence of equipment important to safety within theirboundaries. The inspectors conducted plant walkdowns and verified the areas were asdescribed in the TMI Fire Hazard Analysis Report, and that fire protection features wereproperly controlled per surveillance proced u re 1 038, Administrative Controls-Fi reProtection Program, Rev. 76. The plant walkdowns were conducted throughout theinspection perioO and included assessment of transient combustible material control, firedetection and suppression equipment operability, and compensatory measuresestablished for degraded fire protection equipment in accordance with procedure OP-MA-201-007, Fire Protection System lmpairment Control, Rev. 6. ln addition, theinspectors verified that applicable clearances between fire doors and floors met thecriteria of Attachment 1 of Engineering Technical Evaluation CC-AA-309-101,Engineering Technical Evaluations, Rev. 11. Fire zones and areas inspected included:Enclosure

. Fire Zone AB-FZ-1 1 , ESF Ventilation Building Elevation 331';. Fire Zone AIT-FZ-111A, Air Intake Tunnel Elevation 281', Air Intake Tunnel;. Fire Zone CB-FA-zG, Control Building Elevation 322','B'Battery Room;. Fire Zone CB-FZ-IA, Control Building Elevation 380', North H&V Equipment Room;. Fire Zone CB-FZ-l1, Control Building Elevation 380', South H&V Equipment Room;o Fire Zone FH-FZ-6, Fuel Handling Building Elevation 285', Chiller Room;o Fire Zone \B-FZ-1, Intermediate Building Elevation 295', Reactor River Valve Area;. Fire Zone \B-FZ-6, lntermediate Building Elevation 322', General Area; ando Fire Zone lB-F7-7, Intermediate Building Elevation 355', General Area.b. FindinqsNo findings were identified.

1R06 Flood Protection (71111.06 - 2 samples)

.1 Underqround Electrical Cable VaultsThe inspectors accompanied engineers during portions of the semi-annual electricalvault inspection performed in accordance with MA-TM-153-001, Inspection andMaintenance of TMI-1 Electrical and Telephone Manholes, Rev,1 . The inspectorsselected electrical vaults E7N and E7S based on the risk significance of equipmentpowered by the cables which pass through these vaults.The inspectors entered the vaults to verify cables and/or splices were intact, supportstructures provided appropriate support for the cables and cable trays, cables were notsubmerged in water, dewatering devices functioned properly, and to verify the as-builtconfiguration matched associated design drawings. The inspectors also verified thatOegrideO conditions were properly identified, documented, corrected, or entered into thecorrective action program for resolution.The inspectors reviewed the documented results of the semi-annual cable vaultinspections tor 17 additional underground cable vaults performed between March andJune 2011. The inspectors discussed the vault inspection results with engineers andmaintenance personnel to verify reasonable corrective actions were implemented whereappropriate (i-e., repairs to verify installed drainage systems worked, repairs to vaultaccess manwaYs),.2 lnternala. lnspection ScopeOn May 6 and May 27, the inspectors performed visual inspections of flood barriers,system boundaries, water line break sources, and floor drains located in 'A'decay heat(DH) vault where internal flooding could adversely affect safety related systems neededfor safe shutdown of the plant. Operators had identified that during periods of heavyrain, rainwater penetrated the vault walls and collected on the vault floor. The inspectorsdetermined the rate of water in-leakage was very low. Since the vault floor drain systemwas in service and periodically maintained, the rainwater did not pose a challenge to'A'DH train operability. The inspectors noted a wide variety of loose material in the vault(i.e., plastic labels, tape, foreign material exclusion caps, wire, paint chips, plastic tieEnclosure Iwraps) which could challenge the ability of the floor drain to remove water from the room.The 'A' DH vault sump alarm remained unaffected and therefore operators would havetime to respond and clear the floor drain before 'A' decay heat pump operability wasaffected. The licensee initiated lRs 1213417 and 1215465 to document and remove theloose debris.b. FindinosNo findings were identified.

1R11 Licenssd Operator Requalification Proqram (71111.11Q- 1 sample)Licensed Operator Simulator Traininqa. Inspection ScopeOn June 21, the inspectors observed licensed operator requalification training at thecontrol room simulator for the 'E' operator crew. The inspectors observed the operators'simulator drill performance and compared it to the criteria listed in TMI OperationalSimulator Scenario TA-TM-LRU-106-5024, Reactor Building Fire Alarm, Hi Vibrations onFW-P,1B, Rising Load on Grid, Loss of FW-P-1B, Loss of Offsite Power, Rev, 1. Theinspectors reviewed the operators' ability to correctly evaluate the simulator trainingscenario and implement the emergency plan. The inspectors observed supervisoryoversight, command and control, communication practices, and crew assignments toensure they were consistent with normal control room activities, The inspectorsobserved operator response during the simulator drill transients. The inspectorsevaluated training instructor effectiveness in recognizing and correcting individual andoperating crew errors. The inspectors attended the post-drill critique and reviewed thewritten ciew critique in order to evaluate the effectiveness of problem identification. Theinspectors verified that emergency plan classification and notification trainingopportunities were tracked and evaluated for success in accordance with criteriaestablished in Nuclear Energy lnstitute (NEl) 99-02, Regulatory AssessmentPerformance Indicator Guideline, Rev. 6. Additional documents reviewed are listed inthe attachment.b. FindinqsNo findings were identified.1R12 Maintenance Effectiveness (71111.12Q - 3 samples)a. lnspection ScopeThe inspectors evaluated the listed samples for Maintenance Rule (MR) implementationby ensuring appropriate MR scoping, characterization of failed structures, systems, andcomponents ISSCs;, 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 wereappropriate. The inspectors verified that the issues were addressed as required by10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at NuclearPower Plants; Nuclear Management and Resources Council 93-01, Industry Guidelinefor Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Rev. 2; andExelon proce-dure ER-AA-310, lmplementation of the Maintenance Rule, Rev. 8. TheEnclosure

9inspectors verified that appropriate corrective actions were initiated and documented inlRs, and that engineers properly categorized failures as maintenance rule functionalfailures and maintenance preventable functional failures, when applicable.. On May 4, operators observed that'A'emergency diesel generator (EDG) starting airreceiver pressure was much lower than normal and although the associated aircompressor was running, receiver air pressure continued to slowly decrease.Mechanics replaced the unloader valve on the air compressor (EG-P-1A), but thisdid not correct the condition. Further troubleshooting determined that an EG-P-1Aoil pressure regulator was controlling pressure too low, which by design caused EG-P-1A to run unloaded and prevented recharging the 'A' EDG air receiver (lR1211448). The licensee equipment failure apparent cause evaluation determinedthe most likely cause was moisture in the air which created small corrosion productsthat blocked the oil pressure adjusting valve. Engineers correctly concluded EDG airbank pressure remained above the value necessary to safely start the EDG in 10seconds and therefore the EG-P-1A failure was not a functional failure of the EDG.Licensee maintenance practices were consistent with the vendor manual. Furtherdiscussion with the vendor identified additional preventive maintenance activities, notpreviously recommended by the vendor, to address this failure mechanism. Thelicensee addressed the recommended additional preventive maintenance in theircorrective action program.r Maintenance technicians identified an elevated vibration reading on the'B'makeuppump motor following an extended makeup pump maintenance outage that replacedthe motor (lR 1 169471). Although the magnitude of the vibration readings met theacceptance criteria, further technical analysis was performed to ensure adequatecontinued operation of the motor. Maintenance technicians reviewed the vibrationfrequency and acceleration data and identified no issues that would correlate to anymechanical or electricalfaults. In addition, technicians performed vibration readingsmonthly and no discernable trend was identified. The inspectors independentlyreviewed the vibration data, performed a walkdown of the 'B' makeup pump motorand interviewed maintenance and engineering personnel. Additionally, theinspectors analyzed the vibration data for the 'B' makeup pump and associated gearunit.. On May 10, the inspectors identified rain water collecting between the rubber roofingmembrane and concrete structure of the auxiliary building. Furthermore, it wasidentified that during periods of heavy rain there was leakage through the concretestructure onto electrical cables associated with nuclear service closed cooling anddecay closed cooling water motors. Operators appropriately entered the conditionsinto the corrective action program (lR 1214063, 1228244). Engineering andmaintenance technicians walked down the auxiliary building to identify the extent-of-condition and impact on plant equipment. Corrective actions were implemented toremove the rain water from under the rubber membrane and repair it in accordancewith vendor recommendations. Engineering staff performed an inspection andevaluation of the impact of the rain water leakage on plant components, Theinspectors reviewed the assessment and repair activities on the roofing membraneand independently assessed the condition of the components affected in theauxiliary building. Additionally, the inspectors reviewed the structural monitoringinspection program for the auxiliary building and assessed the previouscharacterization of issues identified. The inspectors reviewed the maintenance ruleEnclosure 10assessments and corrective actions for this condition and did not identify anydeficiencies.b. FindinqsNo findings were identified.1 R13 Maintenance Risk Assessments and Emerqent Work Control (71111

.13 - 6 samples)a. Inspection ScopeThe inspectors reviewed the scheduling, control, and equipment restoration duringmaintenance activities to evaluate their effect on plant risk. This review was againstcriteria contained in Exelon Administrative Procedure 1082.1, TMI Risk ManagementProgram, Rev. 8 and WC-M-10'1, On-Line Work Control Process, Rev, 18.. On April 25, nuclear river pump'C'was removed from service for plannedmaintenance which resulted in a Yellow station risk condition. The inspectorsreviewed and independently assessed the licensee's compensatory actionsassociated with the elevated risk condition.o On April 28, the turbine driven emergency feedwater pump (EF-P-1) and the stationblackout diesel generator (EG-Y-4) were out of service for planned maintenanceresulting in a Yellow risk condition. Subsequently, an Orange risk condition wasentered due to the presence of severe thunderstorms. Operators took promptactions to return EG-Y-4 to service. The inspectors reviewed and independentlyassessed the operator actions to address the unplanned entry into an Orange riskcondition.. On May 1, operators removed instrument air compressor 4, lA-P-4, from service for aplanned maintenance outage. In addition, motor operated valvg testing wasconducted on make-up system injection valves, MU-V-164/8. The station entered aYellow risk condition based upon the plant configuration. The inspectors verified thatthe 1sk assessment accurately captured the testing performed on the MU-V-16A/8'The inspectors concluded that a Yellow risk condition was appropriate for the plantconfiguration.. On May 4, an unplanned entry into a Yellow risk condition occurred due to anemergent failure of the 'A' emergency diesel generator air start compressor. Theinspectors verified that appropriate compensatory actions were taken to mitigate theunplanned elevated risk condition.. On May 6, technicians performed air operated valve actuator diagnostic testing onthe'A'bH removal heat exchanger component cooling water inlet valve (DC-V-2A)'The automatic safety actuation of this valve was unavailable during this testing'Inoperability of the 'A' DH train would generate an Orange online maintenance riskcondition. Station personnel implemented compensatory measures, including adedicated operator with written instructions, for promptly restoring remote operationof the DC-V-2A. This enabled the licensee to consider the 'A' DH train availableduring the testing. The inspectors verified appropriate controls were implementedand maintained to support crediting manual operator action for'A' DH trainoperability. Accordingly, online maintenance risk remained Green.Enclosure

11o On May 17, divers performed desilting operations in the intake structure whichrequired the breaker to 'A' decay river pump, DR-P-1A, to be placed in the racked outposition. Orange risk condition was not entered due to auxiliary operators beingstaged locally with written instructions to perform manual actions to rack in thebreaker of DR-P-1A, if needed. The inspectors observed the operators briefing,reviewed the written work instructions, and interviewed the operators to verify thewritten instructions could be performed and within the design basis time requirement.Accordingly, online maintenance risk remained Green'b. FindinqsNo findings were identified.

1R15 Operabilitv Evaluations (71111.15 - 7 samples)a. lnspection ScopeThe inspectors verified the selected degraded conditions were properly characterized,operability of the affected systems was properly evaluated in relation to TSrequirements, applicable extent-of-condition reviews were performed, and nounrecognized increase in plant risk resulted from the equipment issues. The inspectorsreferenLed NRC Inspection Manual Chapter Part 9900, Operability Determinations &Functionality Assessments for Resolutions of Degraded or Nonconforming ConditionsAdverse to Quality or Safety, Exelon procedure OP-M-108-1 15, OperabilityDeterminations, Rev. 10, and OP-M-108-115-1002, Supplemental Consideration forOn-Shift lmmediate Operability Determinations, Rev. 2 to determine acceptability of theoperability evaluations. Additional documents reviewed during this inspection are listedin the attachment.o In late March, the inspectors identified two large aluminum l-beam segments,temporarily installed with clamps above safety related components FW-V-16A andFW-V-17A on the 322'elevation of the turbine building (lR 1 1 96247). Althoughseveral C-clamps held the l-beams in place, the inspectors questioned whether thebeams could reposition and damage the safety related valves during a seismic event'Engineers determined the l-beams were originally installed to support lifting andperforming periodic maintenance on FW-V-164 and FW-V-17A during a plantoutage, The temporary rigging beams were inadvertently left in place after the lastrefueling outage. Engineers performed Technical Evaluation A21 821 43-01,Aluminum Rigbing l-Beam Load Capacity and Evaluation, to address the inspectors'concerns, and-concluded it was safe to leave the beams in place until the nextrefueling outage.. On April 8, station engineering documented corrosion on the building spray pump,BS-p-18, support base (lR 1 199943). The initial assessment supported operabilitybased upon adequate pump performance and vibration data and confirmed noapparent structural weakness was present. In addition, non-destructive testing wasperformed along the base plate support to determine the extent of the corrosion. Theiesting identified slight material loss had occurred, however, adequate design marginwas maintained to support pump operation during a seismic event'Enclosure

12on April 30, technicians performed engineered safeguards actuation system (ESAS)[gi" i"iting and ESAS relay inspections. The relays were inspected to verify fullJr6p-out wis achieved as ah exient of condition review for a previous rela.y. failureattributed to incomplete drop-out (lR 11 52443). Several (23) relays were identified toexhibit an incomplete drop-out condition, which was indicative of relay degradationoue to oxidation of the relay contacts. The inspectors interviewed the systemengineers, reviewed vendor manuals, maintenance/testing history and operating"*p"r"n." to verify the significance of incomplete drop-out and oxidation on relayoperation. The inspectors"concluded that the relays were capable of performing their,it"ty function and'remained operable. Furthermore, the condition was entered intothe corrective action program and corrective actions were scheduled includingreplacement of the "tr".t"o relays. The inspectors reviewed the scheduledreplacement dates for the relays and concluded that the corrective actions weresineduted commensurate with the safety significance'The inspectors verified the continued operability of aging power supplies in thereactor protection system (RPS) and heat sink protection system (HSPS)'Specitijaffy, the insfiectors reviewed recent operating experience regarding licenseeoperation *itr po*"r supplies exceeding the vendor recommended life expectancy inRpS. The inspectors u"rifi"d that the isiue had been entered into the corrective"ition program (lR 1 1 1S0BO) and that appropriate preventive maintenance (PM)work orders were planned oi performed to inspect, test, and replace any susceptiblepo*"1' supplies. The inspectors independently verified appropriate PMs werescheduled or have been performed for both HSPS and RPS'on May 13, emergency feedwater valve, EF-V-3QD, was removed from Service forplannei maintenan"" 6n the air operated actuator. The planned maintenance, infart, included the replacement ofjoul cap screws connecling the diaphragm base tothe actuator frame IAZOO+ZOZ). Engineering requested the replacement in re-sponseio operating experience of identical Lap screws experiencing fatigue failure (lR6ggbg9) "tiO trOr"luent valve failure. The replacement of the cap screws was notcorpfei,-.0 during the maintenance outage. TMl.engineering engaged themanufacturer and received afailure analysis of the cap screws that concluded the""p ,.r"*. would withstand 6000 cycles under the most conservative conditions'The inspectors reviewed the assumptions, inputs and co-nclusions of the failureanalysii as well as the extent-of-condition review to verify the condition of EF-V-30Dactuator and similar inservice valve actuators. Also, the inspectors verified that even,nJ"t heavy loading, EF-V-30D actuator maintains a life of 60 years and fatiguefailure is not expected in any cap screw. The inspectors concluded that continuedoperability of EF-V-30D was maintained'on June 17, nuclear river water pump (NR-P-1C) failed its quarterly inservice testtrSriJu" to tow now 1tn p30188). Station personnel developed a troubleshootingilfun'"nO retested the'pump in several configurations. The measured pump flow ratemet acceptance criteria. Engineers perform-ed lsT evaluation 219 and determinedthat the initial low flow indicalion was inaccurate due to not properly aligning theannubar flow measurement instrument when it was installed for the test' On retests,NR-P-1C met acceptance flow criteria. operators determined the pump wasoperable and would continue to be tested on an increased frequency due to lowmargin above the acceptance criteria'Enclosure 13room temperature signal (e.g. fire). AH-D-43A and 44A are designed to isolateduring a CO2 actuation for a fire in the relay room and allow the carbon dioxidesystem (CARDOX) to perform its safety function. Engineering analysis determinedthat fire dampers FD-21 and FD-22 would actuate and provide an adequate relayroom isolation boundary. The relay room CARDOX fire suppression systemremained operable. The inspectors reviewed the engineering analysis andventilation calculations to validate that the CARDOX system remained operable. Inaddition, the inspectors walked down the ventilation boundaries identified in theanalysis to ensure the calculations represented actual plant conditions.b. FindinqsNo findings were identified.

1R18 Plant Modifications (71111.18 - 1 sample)a. Inspection ScopeThe inspectors reviewed the following plant modification to determine whether they weredesigned and/or implemented as required by Exelon documents CC-AA-102, DesignInput and Configuration Change lmpact Screening, Rev. 20 and CC-M-103'Configuration Change Control, Rev. 21. The inspectors verified the modificationsupported plant operation as described in the UFSAR and complied with TSrequirements. The inspectors reviewed the function of the changed components, thechange description and scope, and the 10 CFR 50.59 screening evaluation.r Engineering Change Request (ECR) TM 11-201, AH-P-3A Discharge Pipe Re-Alignment, Rev. 0 was a permanent plant modification that reconfigured the pipingsupports for the 'A' control building chilled water system. On April 2, techniciansidentified a leak from the interface of the chilled water piping and an expansion joint,AH-XJ-41A. Troubleshooting identified that the interface between expansion jointand the pipe was misaligned. Maintenance technicians reconfigured the pipingsupports to realign the pipe with the expansion joint and eliminate the leakage. Theinspectors walked down the modification and interviewed maintenance techniciansand design engineers to verify the modification was installed in accordance with ECR11-201. Also, the inspectors validated that the appropriate calculations for pipestress were revised due to the manipulation of the piping supports.b. FindinqsNo findings were identified.1R19 Post Maintenance Testinq (71111.19 - 6 samples)a. Inspection ScopeThe inspectors reviewed and/or observed the following post maintenance testing (PMT)activities to ensure (1) the PMT was appropriate for the scope of the maintenance workcompleted (2) the acceptance criteria were clear and demonstrated operability of thecomponent and (3) the PMT was performed in accordance with procedures.Enclosure

14. On April27, operators performed 1107-9, SBO Diesel Generator, Rev, 644 followinga planned maintenance outage of the station blackout diesel. Specifically, theoutage involved the replacement of a K-1 relay used to flash the field of thegenerator (WO R21 76834).. On April 28, operators performed OP-TM-424-203, IST of EF-P-1 and Valves, Rev.9, following a planned maintenance outage of the turbine driven emergencyfeedwater pump (WO R2077734).. On May 1, operators performed 1107-3, Diesel Generator, Rev. 130, following aplanned maintenance outage of the 'A' emergency diesel generator to blow downfuel oil drain lines and perform preventive maintenance (WO R2180365).. On May 5, operators performed 1104-25,Instrument and Control Air System, Rev.144, following a planned outage of the instrument air compressor (lA-P-4) for anoverhaul of the motor (WO R21 7 1413).o On June 13, operators performed 1303-4.16, Emergency Power System, Rev. 127,following an extended planned maintenance overhaul outage of the 'B' emergencydiesel generator (WO R2174164).. On June 22, operators tested the control building emergency ventilation fans, AH-E-17B., 18B, and 198 in accordance with 1 104-19, Control Building Ventilation System,Rev. 77, following planned preventive maintenance (WO R2058226).b. FindinqsNo findings were identified.

1R22 Surveillance Testino (71111.22 - 3 samples)a. Inspection Scope (1 inservice testing samples and 2 routine surveillance samples)The inspectors observed andlor reviewed the following operational surveillance tests inaccordance with Exelon procedure WC-TM-430 Surveillance Testing Program, Rev. 0and WC-TM-430-1001 Surveillance Testing Program Database lnterface andMaintenance, Rev. 1" lnspection activities included review of previous surveillancehistory to identify problems and trends, observation of pre-evolution briefings, andinitiation/resolution of related lRs for selected surveillances.. On May 9, technicians calibrated the'A' core flood tank level instrumentation inaccordance with 1302-5.15A.4, CF2-LT2 Level Channel Calibration, Rev. 0 (lRs1 21 3553, 1 21 3637, 1 21 5829);. On May 14, technicians performed OP-TM-543-202, lnservice Test of DC-P-1B, Rev.2; and. On May 19, technicians performed 1303-1 1

.378 , Heat Sink Protection System -Once Through Steam Generator Level and Pressure Channel ll Tests, Rev. 29.Enclosure

15c. FindinosNo findings were identified.2.

RADIATION SAFETY

Cornerstone:

Occupational Radiation Safety2RS1 Access Control to Radioloqicallv Siqnificant Areas (71124.01)a. Inspection ScopeThe inspectors reviewed selected activities and associated documentation. Theevaluation of Exelon's performance was against criteria contained in 10 CFR 20, TSs,and station procedures.Inspection PlanningThe inspectors reviewed Performance Indicators (Pls) for the Occupational ExposureCornerstone. The inspectors also reviewed the results of recent radiation protectionprogram audits and assessments and any reports of operational occurrences related tooccupational radiation safety since the last inspection.Radioloqical Hazard AssessmentThe inspectors discussed plant operations to identify any significant new radiologicalhazard for onsite workers or members of the public. The inspectors assessed thepotential impact of the changes (e.9,, fuel integrity status) and the implementation ofperiodic monitoring to detect and quantify the radiological hazard.The inspectors toured various radiological controlled areas and reviewed radiologicalsurveys from the auxiliary building, spent fuel pool, and containment access areas toverity the thoroughness and frequency of surveys were appropriate for the givenradiological hazard. The inspectors toured onsite radioactive material and radioactivewaste storage areas to assess adequacy and implementation of radiological controls.The inspectors made independent radiation measurements to verify conditions.lnstructions to WorkersThe inspectors toured the radiological controlled areas and reviewed the labeling ofradioactive material containers.Contamination and Radioactive Material ControlsThe inspectors selectively observed and inspected the methods used for control, survey,and release of potentially contaminated material from the radiological controlled area.The inspectors observed technicians surveying and releasing material for unrestricteduse to verify procedure compliance and assess the adequacy of the procedures toprevent unintended release of radioactive materials. The inspectors selectively verifiedradiation monitoring instrumentation had appropriate sensitivity for the type(s) ofradiation present.Enclosure 16The inspectors selected two sealed sources from the licensee's inventory records thatpresent the greatest radiological risk. The inspectors verified that the sources wereaccounted for and their integrity was maintained.The inspectors verified that any transactions involving nationally tracked sources werereported in accordance with 10 CFR 20.2207. The inspectors verified the licenseesubmitted its source reconciliation report.b. FindinosNo findings were identified.Cornerstone: Occupational and Public Radiation Safety2RSs Radiation Monitorinq lnstrumentation (7 1122.05)a. Inspection Scopelnspection PlanninqThe inspectors reviewed the UFSAR to identify radiation instruments designed tomonitor radiological conditions in the air, process streams, effluents, materials/articles,and plant employees. The inspectors identified instrumentation and associated technicalspecification req uirements for post-accident monitoring instrumentation.The inspectors obtained copies of Exelon and third-party evaluation reports of theradiation monitoring program, including audits of the offsite calibration facility. Theinspectors reviewed the reports for insights into the licensee's program and to aid inselecting areas for review.The inspectors reviewed effluent monitor alarm set-point bases and the calculationmethods provided in the Offsite Dose Calculation Manual (ODCM)'Walk-downs and ObservationsThe inspectors walked down three effluent radiation monitoring systems (station vent,reactor building purge, and fuel handling building) and one liquid system (turbine buildingsump). The inspectors focused on flow measurement devices and all accessible point-of-discharge liquid and gaseous effluent monitors of the selected systems. TheinspectorJselectively verified that effluent and process monitor configurations alignedwith ODCM descriptions.The inspectors selected various portable survey instruments in use or available forissuance. The inspectors checked calibration source check stickers for currency,assessed instrument material condition and reviewed instrument data sheets, asapplicable.Calibration and Testino Proqram- Process and Effluent MonitorsEnclosure b.17The inspectors verified that channel calibration and functional tests were performedconsistent with radiological effluent technical specifications (RETS)/ODCM. Theinspectors verified that primary calibration adequately represented the plant nuclidemix, the secondary calibration verified the primary calibration, and the channelcalibrations encompassed the instruments' alarm set-points. The inspectorsfocused on point of discharge effluent monitors.The inspectors verified that effluent monitor alarm set-points were established asprovided in the ODCM and station procedures.The inspectors evaluated changes to effluent monitor set-points, to ensure that anadequate justification exists.- LaboratorvlnstrumentationThe inspectors reviewed calibration of laboratory analytical instruments used forradiological analyses (e.9,, gross alpha, gross beta, proportional counters, gammaspectroscopy (including germanium-lithium, high purity-intrinsic germanium) andliquid scintillation counters). The inspectors verified that daily performance checksand calibration data indicated that the frequency of calibration was adequate andthere were no indications of degraded instrument performance'- Post-acgident Monitgfinq InstrumentationThe inspectors reviewed the calibration documentation since the last inspection onthe containment high-range monitors. The inspectors verified that an electroniccalibration was completed for all range decades above 10 rem/hour and that at leastone decade at or below 10 rem/hour was calibrated using an appropriate radiationsource. The inspectors verified the calibration acceptance criteria were reasonable,accounting for the large measuring range and the design of the instruments.The inspectors selected high-range effluent monitors that operators would useduring implementation of the emergency operating procedures as a basis fortriggering emergency action levels and subsequent emergency classifications, or tomake protective action recommendations during an accident. The inspectorsevaluated the calibration and availability of these instruments.- Calibration aryJ Check SourcesThe inspectors reviewed the licensee's 10 CFR Part 61 , "Licensing Requirementsfor Land Disposal of Radioactive Waste," source term to determine if the calibrationsources used were representative of the types and energies of radiationencountered in the plant.FindinqsNo findings were identified.Enclosure 2RS618Public Radiation SafetyRadioactive Gaseous and Liquid Effluent Treatment (71124.06 - 1 sample)Inspection ScopeODCM and UFSAR ReviewsThe inspectors reviewed UFSAR descriptions of the radioactive effluent monitoringsystems, treatment systems, and effluent flow paths so they could be verified duringinspection walk-downs.The inspectors reviewed changes to the ODCM made by the licensee since the lastinspection, as applicable. The inspectors reviewed changes against the guidance inNUREG-1301 and 0133, and Regulatory Guides 1

.109 , 1 .21 and 4.1 . The inspectorsreviewed the technical basis or evaluations of any changes during the onsite inspection.The inspectors determined if the licensee had identified, since the last inspection, anynon-radioactive systems (e.9., sewage)that have become contaminated since the lastinspection. The inspectors reviewed 10 CFR 50.59 evaluations that have beenperformed for systems that have been identified as contaminated since the lastinspection. The inspectors determined if any newly contaminated systems had anunmonitored effluent discharge path to the environment, whether any required ODCMrevisions were made to incorporate these new pathways and whether the associatedeffluents were reported in accordance with Regulatory Guide 1.21.Procedures. Special Reports and Other DocumentsThe inspectors reviewed and discussed event reports and/or special reports related tothe effluent program issued since the previous inspection to identify any additionalfocusareas.The inspectors reviewed effluent program implementing procedures, particularly thoseassociated with effluent sampling, effluent monitor set-point determinations, and dosecalculations.The inspectors reviewed self assessments and third party evaluation reports of theeffluent monitoring program since the last inspection. The inspectors reviewed thereports for insights into the licensee's program and to aid in selecting areas for review.The inspectors reviewed licensee check- in assessments and quality assurance audits.Walk-downs and ObservationsThe inspectors walked down selected accessible components of the gaseous and liquiddischarge systems to verify equipment configuration and flow paths and to assessequipment material condition. The inspectors evaluated the material condition of thestation vent, reactor building purge sampling systems, and turbine building sump inconcert with observing sample collections.The inspectors walked down the reactor building purge and auxiliary/fuel handlingbuilding ventilation filter trains. The inspectors visually inspected the trains to verify thatthere were no apparent conditions that would impact the performance or the effluentmonitoring capability of the system.a.Enclosure

19The inspectors observed gaseous effluent sample collections and analysis for the stationvent and the reactor building purge. The inspectors observed collection of a turbinebuilding sump composite liquid sample.The inspectors discussed, for liquid waste processing, the routine processing anddischarge of effluents (including sample collection and analysis). The inspectorsdiscussed effluent treatment equipment used to determine if radioactive liquid waste wasbeing processed and discharged in accordance with procedure requirements and alignswith discharge permits (e.9., release rates). The inspectors reviewed any significantchanges to its effluent release points (e.9., changes subject to a 10 CFR 50.59 review orrequire NRC approval of alternate discharge points).Samplinq and AnalvsesThe inspectors discussed the licensee's effluent sampling activities and efforts to ensurecollection of representative samples. The inspectors selected two gaseous and oneliquid effluent sampling activities (station vent, reactor building purge, and turbinebuilding sump effluent sampling)and verified that adequate controls were implementedto ensure representative samples.The inspectors validated discharges made with inoperable effluent radiation monitorshad appropriate controls in place and compensatory sampling performed in accordancewith the RETS/ODCM and that the controls were adequate to prevent the release ofunmonitored liquid and gaseous effluents.The inspectors selectively reviewed the results of both the inter- and intra-laboratorycomparison program to verify the quality of the radioactive effluent sample analyses.The inspectors verified that the inter laboratory comparison program include hard-to-detect isotopes as approPriate.lnstruments and Equipment- Effluent Flow Measurino lnstrumentsThe inspectors reviewed the methodology to determine the effluent stack and ventflow rates. The inspectors verified that the flow rates were consistent withRETS/ODCM or UFSAR values, and that differences between assumed and actualstack and vent flow rates did not affect the results of the projected public doses,- Air Cleaninq SvstemqThe inspectors verified surveillance test results (auxiliary building, fuel handlingbuilding) since the previous inspection for ventilation effluent discharge systems(high-efficiency particulate air and charcoal filtration ).Dose CalculationsThe inspectors evaluated changes in reported dose values compared to the previousRadiological Effluent Release Report to evaluate the factors which may have resulted inthe change.The inspectors selectively reviewed three radioactive liquid and gas waste dischargepermits to verify that the projected doses to members of the public were accurate andbased on representative samples of the discharge path'Enclosure 20The inspectors selectively evaluated the methods used to determine the isotopes thatwere included in the source term to ensure all applicable radionuclides were included,within detectability standards. The inspectors reviewed the current Part 61 analyses toensure hard{o-detect radionuclides were included in the source term,The inspectors reviewed changes in the ODCM dose calculations since the lastinspection to verify the changes were consistent with the ODCM and Regulatory Guide1

.109 . The inspectors selectively reviewed meteorological dispersion and depositionfactors used in the ODCM and effluent dose calculations to ensure appropriate factorswere being used for public dose calculations.The inspectors reviewed the latest Land Use Census to verify that changes (e.9.,significant increases or decreases to population in the plant environs, changes in criticalexposure pathways, the location of the public or critical receptor, etc.) have beenfactored into the dose calculations. The inspectors evaluated public dose projections toverify that the calculated doses (monthly, quarterly, and annual dose) were within 10CFR Part 50, Appendix I and TS dose criteria.The inspectors selectively reviewed any abnormal gaseous or liquid tank discharges(e.g., discharges resulting from misaligned valves, valve leak-by) and evaluated thereleases in accordance with 10 CFR 20.1501 .GPI lmplementationThe inspectors verified that the licensee continued to implement the voluntaryNEI/lndustry Groundwater Protection Initiative (GPl).The inspectors selectively reviewed identified leakage, spill events and subsequententries made into 10 CFR 50.75 (g) records to review any remediation action. Theinspectors reviewed onsite contamination events involving contamination ofgroundwater. The inspectors assessed whether the source of the leak or spill wasidentified and mitigated.The inspectors assessed whether sufficient radiological surveys were performed toevaluate the extent of the contamination and the radiological source term. Theinspectors verified that a survey/evaluation was performed to include consideration ofhard-to-detect radion uclides.The inspectors verified that on-site groundwater sample results and a description of anysignificant on-site leaks/spills into groundwater for each calendar year were documentedin the Annual Radiological Environmental Operating Report for the RadiologicalEnvironmental Monitoring Program (REMP) or the Annual Radiological Effluent ReleaseReport for the RETS.b. FindinqsNo findings were identified.2RS7 Radioloqical Environmental Monitorinq Proqram (REMP)a. Inspectign Scope (71 124.07 - 1 sample)Inspection PlanninqEnclosure

21The inspectors selectively reviewed the annual radiological environmental and effluentoperating reports (2009, 2010) and the results of licensee assessments since the lastinspection, to verify that the REMP was implemented in accordance with the TS andODCM. The inspectors reviewed the report for changes to the ODCM with respect toenvironmental monitoring, commitments in terms of sampling locations, monitoring andmeasurement frequencies, land use census, inter-laboratory comparison program, andanalysis of data.The inspectors reviewed the annual effluent release report and the 10 CFR Part 61,"Licensing Requirements for Land Disposal of Radioactive Waste," report, to determine ifthe licensee was sampling, as appropriate, for the predominant and dose-causingradionuclides likely to be released in effluents.Site InspectionThe inspectors walked down and observed sample collection for three air samplingstations (F1-3, G2-1 , H3-1 ), four thermoluminescent dosimeter (TLD) monitoring stations(H1-1 , F1-1, H3-1 , G10-1 ), one drinking water station (G15-3), one surface water sample(J1-2), and one milk sampling location (G2-1) to determine whether they were locatedas described in the ODCM. In addition, the inspectors reviewed material conditions ofmonitoring equipment. Consistent with smart sampling, the inspectors selected airsampling station locations based on the locations with the highest )(/Q, D/Q windsectors, and the inspectors selected the TLDs based on the most risk-significantlocations,The inspectors observed the collection and preparation of various environmentalsamples from different environmental media (three particulate and iodine air monitoringstations, one drinking water location, one surface water location, and one milk samplinglocation). The inspectors verified that environmental sampling was representative of therelease pathways as specified in the ODCM and that sampling techniques were inaccordance with procedures.For the air samplers and TLDs, the inspectors reviewed the calibration and maintenancerecords to verify that they demonstrate adequate operability of these components.Additionally, the inspectors reviewed calibration of the composite water samplers.The inspectors verified that the licensee had initiated sampling of other appropriatemedia upon loss of a required sampling station.Based on direct observation and review of records, the inspectors verified that themeteorological instruments were operable, calibrated, and maintained in accordancewith guidance contained in the FSAR, NRC Regulatory Guide 1.23, "MeteorologicalMonitoring Programs for Nuclear Power Plants," and licensee procedures. Theinspectors verified that the meteorological data readout and recording instruments in thecontrol room and, if applicable, at the tower were operable. The inspectors toured themeteorological tower.The inspectors verified that missed and or anomalous environmental samples wereidentified and reported in the annual environmental monitoring report. The inspectorsselected events that involved a missed sample, inoperable sampler, lost TLD, oranomalous measurement, and verified that the licensee has identified the cause andimplemented corrective actions. The inspectors reviewed the licensee's assessment ofany positive sample results. The inspectors reviewed the associated radioactive effluentrelease data that was the source of the released material'Enclosure b.a.2RS822The inspectors verified that appropriate detection sensitivities with respect to TS/ODCMwere used for counting samples (i.e., the samples meet the TS/ODCM required LLDs).The inspectors reviewed quality control charts for maintaining radiation measurementinstrument status and actions taken for degrading detector performance. For vendorlaboratory analysis results for REMP samples, the inspectors reviewed the results of thevendor's quality control program, including the inter-laboratory comparison program, toverify the adequacy of the vendor's program.FindinqsNo findings were identified.Radioactive Solid Waste Processinq and Radioactive Material Handlinq. Storaoe, andTransportationlnsoection Scope (71124.08 - 1 sample)Insoection PlanninqThe inspectors reviewed the solid radioactive waste system description in the UFSAR,the Process Control Program (PCP), and the recent radiological effluent release reports(2010) for information on the types, amounts, and processing of radioactive wastedisposed.The inspectors reviewed the scope and results of any QA audits in this area to gaininsights into the licensee's performance and inform the "smart sampling" inspectionplanning.Radioactive Material StoraqeThe inspectors toured and reviewed four areas (intermediate storage area, yard area,waste frandling and processing facility, and steam generator storage building)wherecontainers of radioactive waste were stored, to verify that the containers were labeled inaccordance with 10 CFR 20.1904, "Labeling Containers," or controlled in accordancewith 10 CFR 20.1905, "Exemptions to Labeling Requirements," as appropriate.The inspectors selectively toured the facility to verify that the radioactive materialsstorage areas were controlled and posted in accordance with the requirements of10 CFR Part20, "Standards for Protection against Radiation." Areas toured includedinterior and exterior storage facilities (steam generator storage building, waste handlingprocessing facility, yard areas, intermediate waste storage area, and auxiliary building.)The inspectors selectively verified that the licensee had established a process formonitoring the impact of long-term storage (e.g., buildup of any gases produced bywaste deComposition, chemical reactions, container deformation, loss of containerintegrity, or re-release of free-flowing water) to identify potential unmonitored, unplannedreleases or nonconformance with waste disposal requirements.Radioactive Waste Svgtem WalkdownThe inspectors selected accessible portions of the liquid and solid radioactive wasteprocessing systems and walked down accessible portions of systems to verify that thecurrent system configuration and operation agreed with the descriptions in the FSAR,Enclosure 23ODCM, and PCP. The inspectors also selectively reviewed various photographs, livecamera views, and radiological surveys to access material conditions of rooms andtanks. ln addition, the inspectors selectively reviewed system "Health Reports."The inspectors discussed radioactive waste processing and radioactive waste equipmentthat was not operational to determine if the equipment was abandoned in place. Theinspectors discussed if the licensee had established administrative and/or physicalcontrols (i.e., drainage and isolation of the system from other systems) to ensure that theequipment would not contribute to an unmonitored release path and/or affect operatingsystems or be a source of unnecessary personnel exposure. The inspectors discussedif the licensee had reviewed the safety significance of systems and equipmentabandoned in place in accordance with 10 CFR 50'59.The inspectors reviewed the adequacy of any changes made to the radioactive wasteprocessing systems since the last inspection, to verify that changes from what isdescribed in the FSAR were reviewed and documented in accordance with10 CFR 50.59. The inspectors reviewed and discussed the impact, if any, on radiationdoses to workers or members of the public.The inspectors reviewed the processes for transferring radioactive waste resin and/orsludge discharges into shipping/disposal containers. The inspectors verified (for theselected processes) that the waste stream mixing, sampling procedures, andmethodology for waste concentration averaging were consistent with the PCP, andprovided representative samples of the waste product for the purposes of wasteclassification as described in 10 CFR 61.55, "Waste Classification."The inspectors discussed and evaluated whether the tank recirculation procedure andmeans used provided sufficient mixing.The inspectors reviewed the licensee's PCP to determine if it correctly described thecurrent methods and procedures for dewatering and waste stabilization (e.9., removal offreestanding liquid).Waste Characterization and ClassificationThe inspectors selected two radioactive waste streams to verify that the licensee'sradiochemical sample analysis results were sufficient to support radioactive wastecharacterization as required by 10 CFR Part 61 , "Licensing Requirements for LandDisposal of Radioactive Waste." The inspectors selectively verified that the ljcensee'suse of scaling factors and calculations to account for difficult-to-measure radionuclideswas technically sound and based on current 10 CFR Part 61 analyses'The inspectors verified that, for plant waste streams, changes to plant operationalparameiers were being trended and monitored and were taken into account to (1)maintain the validity of the waste stream composition data between the annual orbiennial sample analysis update, and (2) verify that waste shipments continue to meetthe requirements of 10 CFR Part 61 .The inspectors reviewed the licensee's QA program to determine if the licensee hasestablished and maintained an adequate QA program to ensure compliance with thewaste classification and characterization requirements of 10 CFR 61.55 and10 CFR 61.56, "Waste Characteristics"'Enclosure 24Shipment PreparationThe inspectors observed and selectively reviewed non-exempt shipment package(RS-11-036-1) surveys, labeling, marking, placarding, emergency instructions, disposalmanifest, shipping papers for the driver, and licensee verification of shipment readiness.The inspectors verified that the appropriate package design and requirements had beenmet.The inspectors observed radiation workers during conduct of radioactive waste shipmentpreparation for shipment (RS-1 1-036-1). The inspectors reviewed trainingdocumentation and determined that the shippers were knowledgeable of the shippingregulations and that shipping personnel demonstrated adequate skills to accomplish thepackage preparation requirements for public transport with respect to NRC Bulletin 79-19, "Packaging of Low-Level Radioactive Waste for Transport and Burial," and49 CFR Part 172,"Hazatdous Materials Table, Special Provisions, Hazardous MaterialsCommunication, Emergency Response Information, Training Requirements, andSecurity Plans," Subpart H, "Training."Shippino RecordsThe inspectors reviewed six non-excepted radioactive material package shipments (RS-10-005-1, RS-10-036-1, RS-11-014-1, RS-11-013-1, RS-11-005-1, and RS-10-085-l). Theinspectors verified that the shipping documents indicated the proper shipper name,emergency response information and a 24-hour contact telephone number, accuratecurie content and volume of material, and appropriate waste classification, transportindex, and UN number. The inspectors discussed the shipment placarding to determineif it was consistent with the information in the shipping documentation. The inspectorsselectively discussed characterization of shipment contents including radionuclidecalculations. The inspectors selectively confirmed, by hand calculation, radionuclidecontent of packages based on current 10 CFR Part 61 analyses and scaling factors,b. FindinqsNo findings were identified.4.

4OA1 Performance Indicator Verification (71 151)

.1 Cornerstone: Barrier Inteoritv (1 sample)The inspectors reviewed selected station records, corrective action program documents,calculation methods, and definitions of terms to verify NRC performance indicators (Pls)had been accurately reported as specified in NEI 99-02, Regulatory AssessmentPerformance Indicator Guideline, Rev. 5 and 6. The Pl sample listed below was verifiedfor the period July 2010 to June 2011.. Reactor Coolant System ldentified Leak Rateb. FindinqsNo findings were identified,Enclosure 4c.42.1a.25ldentification and Resolution of Problems (71152)Review of lssue Reports and Cross-References to Problem ldentification and Resolutionlssues Reviewed ElsewheqeInspection ScopeThe inspectors performed a daily screening of items entered into the licensee'scorrective action program. This review was accomplished by reviewing a list of daily lRs,attending daily screening meetings, and accessing the licensee's computerizedcorrective action program database.FindinqsNo findings were identified.Cumulative Operator-Work-Around (1 sample)lnspection ScopeThe inspectors reviewed the cumulative effects of the existing operator work-arounds(OWAs), the list of operator challenges, equipment deficiencies logs, the list ofoperations department concerns, and the list of open main control room deficiencies andmain control room tags to identify any effect on emergency operating procedure operatoractions, and impact on possible initiating events and mitigating systems. The inspectorsalso interviewed selected operations and engineering personnelto assess theirunderstanding of the OWAs and other listed control room deficiencies. The inspectorsobserved the quarterly OWA meeting to determine whether station personnelwereidentifying, assessing, and reviewing OWAs as specified in Exelon administrativeprocedure OP-AA-102-103, Operator Work-Around Program, Rev' 3.Findinos and ObservationsNo findings were identified.Semi-Annual Review to ldentifv Trends (1 sample)Inspection ScopeThe inspectors performed a semi-annual review of site issues, to identify trends thatmight indicate the existence of more significant safety issues, as specified in NRCf nspection Procedure 71152,ldentification and Resolution of Problems. The inspectorsincluded in this review repetitive or closely-related issues that may have beendocumented by Exelon outside of the corrective action program, such as trend reports,performance indicators, major equipment problem lists, system health reports,maintenance rule assessments, and maintenance or corrective action program backlogs.The inspectors also reviewed the Exelon corrective action program database for Januarythrougl'r June 2011, to assess issue reports written in various subject areas (equipmentproblems, human performance issues) as well as individual issues identified during theNRCs daily lR review (Section 4OA2.1)..2b..3Enclosure b.26FindinqgNo findings were identified. The inspectors determined that corrective actions toaddress configuration control performance deficiencies from the first half of 2010 andtransient material control deficiencies from all of calendar year 2010 continued to beeffective. The number and potential safety significance of configuration control relateddeficiencies identified in the first half of 2011 were notably reduced from the first half of2010. Station personnel performed extent-of-condition reviews associated withadequacy of preventive maintenance (PM) for critical station components. This reviewidentified several additional PMs to be developed and scheduled to support continuedreliable equipment performance.Additionally, the inspectors identified several instances for which corrective actiontimeliness was not commensurate with potential significance of degraded equipmentconditions. Examples included leakage from the auxiliary building roof into the 305'elevation in the vicinity of safety related component cooling water pumps (lR 1214063),evaluation of BS-P-1A pedestal corrosion (lR 1199943), loose debris present in the 'A'DH vault (lRs 1213417,1215465), degraded auxiliary building/fuel building charcoalfilters since 2009, and incorrect implementation dates for new PMs for critical integratedcontrol system components (lR 1195102). The inspectors observed that when stationpersonnel initially evaluated the issues above, the evaluations focused on justification ofoperability or functionality, but did not emphasize restoration of design/operationalmargin. The inspectors discussed these issues with various station personnel, includingstation management. Station management acknowledged the issues, verified they werecaptured in the corrective action program, and initiated several significant station-wideactions to reemphasize worker performance fundamentals. The inspectors determinedthese corrective actions were appropriate and observed improved worker fundamentalperformance through the end of June 2011.Findinos and ObservationsNo findings were identified.Radiation Safetv ( 7 1 1 24.01 . 7 1 1 24.Q5. 7 1 1 24.06. 7 1 1 24.Q7 . 7 1 1 24.08\Inspection ScopeThe inspectors selectively reviewed corrective action documents to determine ifidentified problems were entered into the corrective action program for resolution and toevaluate Exelon's threshold for entering issues into the program. The review included acheck of possible repetitive issues, such as radiation worker or radiation protectiontechnician errors. Also selectively reviewed were recent audits and assessments, asappropriate, and corrective action program documents. Additional documents reviewedare listed in the Attachment.The review was against the criteria contained in 10 CFR 20, TSs, and stationprocedures.b. FindinosNo findings were identified..4a.Enclosure 40A340A5.1b.27Event Follow-up (71153 - 1 sample)Inspection ScopeOn May 11, at 3:13 p.m., TMI operators commenced a rapid downpower to 76% ratedthermal power. The transmission system operator (TSO) directed the downpower due toa fault on a 500KV offsite power line that feeds the TMI switchyard. TMI operatorsperformed the downpower using the unit load demand controller in manual inaccordance with procedure 1102-4, Power Operation, Rev. 120. The plant wasstabilized al760/o. Subsequently, the 500KV line was removed from service for repairs.At 5:50 p.m., the TSO notified TMI that the 500KV line repairs were completed whichallowed power escalation to 100%. TMI achieved 100% power at 9:30 p.m. on May 11.The inspectors responded to the control room and observed the operator actions andplant response during the downpower and while stabilizing reactor power. Theinspectors verified that appropriate TSs had been evaluated for the plant conditions.Furthermore, the inspectors reviewed operator logs, plant process computer data forpertinent plant parameters, interviewed station personnel, and performed plantwalkdowns to verify operators responded in accordance with station procedures and thatthe plant responded as designed. The inspectors identified no issues of concern relatedto operator performance or plant performance during the power change evolution.FindinosNo findings were identified.Other Activities(Closed) NRC Temporarv lnstruction 2515/183. "Follow-up to the Fukushima DaiichiNuclear Station Fuel Damaqe Event"The inspectors assessed the activities and actions taken by TMI personnel to assess itsreadiness to respond to an event similar to the Fukushima Daiichi nuclear plant fueldamage event. This included (1) an assessment of TMI's capability to mitigateconditions that may result from beyond design basis events, with a particular emphasison strategies related to the spent fuel pool, as required by NRC Security Order Section8.5.b issued February 25,2002, as committed to in severe accident managementguidelines, and as required by 10 CFR 50.54(hh); (2) an assessment of TMI's capabilityto mitigate station blackout (SBO) conditions, as required by 10 CFR 50.63 and stationdesign bases; (3) an assessment of TMI's capability to mitigate internal and externalflooding events, as required by station design bases; and (4) an assessment of thethoroughness of the walkdowns and inspections of important equipment needed tomitigate fire and flood events, which were performed by TMI personnel to identify anypotential loss of function of this equipment during seismic events possible for the site.Inspection Report 05000289/201 1009 (ML1 1 1310788) documented detailed results ofthis inspection activity.(Closed) NRC Temporarv Instruction 2515/184, "Availabilitv and Readiness Inspection ofSevere Accident Manaqement Guidelines (SAMGS)"On May 23,2011, the inspectors completed a review of TMI's severe accidentmanagement guidelines (SAMGs), implemented as a voluntary industry initiative in the.2Enclosure

.3 a.281990's, to determine (1) whether the SAMGs were available and updated, (2) whetherTMI had procedures and processes in place to control and update its SAMGS, (3) thenature and extent of the licensee's training of personnel on the use of SAMGS, and (4)TMI personnel's familiarity with SAMG implementation.The results of this review were provided to the NRC task force chartered by theExecutive Director for Operations to conduct a near-term evaluation of the need foragency actions following the Fukushima Daiichifuel damage event in Japan. Plant-specific results for Three Mile lsland Station were provided in an Attachment to amemorandum to the Chief, Reactor Inspection Branch, Division of Inspection andRegional Support, dated May 27,201 1 (ML1 11470361).(Closed) NRC Temporary Instruction 25151179, "Verification of Licensee Responses toNRC requirements for Inventories of Materials Tracked in NSTS"lnsoection Scope (Tl 2515/179)During the period May 9-12, the inspectors conducted the following activities to confirmthe inventories of materials possessed at TMI were appropriately reported anddocumented in the National Source Tracking System (NSTS) in accordance with10 cFR 20.2207.Inspection PlanninoThe inspectors retrieved and reviewed a copy of the licensee's submitted NSTS sourceinventory. The inspectors also reviewed reconciliation reports.lnventorv VerificationThe inspectors performed a physical inventory of the sources listed on the licensee'sinventory to identify each source listed on the inventory.The inspectors verified the presence of the nationally tracked sources by conducting aradiation survey of the source shield, as possible, and discussions with personnel,The inspectors examined the physical condition of the source containers, evaluated theeffectiveness of the procedures for secure storage and handling, discussed maintenanceof the device including source leak tests, and verified the posting and labeling of thesource was appropriate.The inspectors reviewed licensee records for the source (source certification documents)and compared the records with the data from the NSTS source inventory. Theinspectors evaluated the effectiveness of procedures for updating the inventory records.Determine the Location of Unaccounted-for Nationallv Tracked Source(s)The inspectors reviewed the licensee's source inventory and verified TMI has nounaccounted-for source(s).Review of Other Administrative InformationThe inspectors reviewed the administrative information contained in the NSTS inventoryprintout with licensee personnel to determine if all administrative information (e.9.,Enclosure

b.-29mailing address, docket number, and license number)were correct. The inspectorsdiscussed updates/corrections to the information. The inspectors reviewed reconciliationreports.FindinqsNo findings were identified.Meetinqs. Includino ExitExit Meetinq SummarvOn May 12, May 27, and June 23, the inspectors presented the inspection results tomembers of TMI senior management. TMI management acknowledged the inspectionresults. No proprietary material was identified.On June 7, 2011, Ronald Bellamy met with TMI Plant Manager, Rick Libra, to discussthe results of TMI-1 performance for 2010.On July 15,2011, the resident inspectors presented the inspection results to Mr. GlenChick and other members of the TMI staff. The inspectors asked the licensee whetherany of the material examined during the inspection should be considered proprietary. Noproprietary information was identified.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Manager, Regulatory AssuranceManager, Design Engineering - MechanicalSite Vice PresidentChemistManager, Radiological EngineeringDesign EngineerSenior Regulatory Assurance EngineerShift Operations SuperintendantSystem Engineer-Flood ProtectionDirector, MaintenanceManager, Site SecurityRisk Management EngineerComponent Monitoring EngineerPlant ManagerSystem Engineer-lnservice Testing Program OwnerProcedures and Flood ProtectionManager, Emergency PreparednessSite Vice President (former)Manager, ChemistrySenior Manager, Design EngineeringSystem EngineerSystem EngineerSystem EngineerChemistManager, Design Engineering - Electrical and Instrumentation &ControlSupervisor, PlanningSenior Work Week ManagerManager, Training SupportNuclear Safety SpecialistPennsylvania Department of Environmental ProtectionBureau of Radiation ProtectionAttachment

A-2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Closed05000289/25151183500028912515118405000289/25151179Opened and

Closed

NoneTITIFollowup to the Fukushima DaiichiNuclear Station Fuel Damage Event(Section 4OA5.1)Availability and ReadinessInspection of Severe AccidentManagement Guidelines(Section 4C.45.2)Verification of Licensee Responsesto NRC requirements for Inventoriesof Materials Tracked in NSTSSection 4OA5.3)TIAttachment

A-3

Section 1R01: Adverse WeatherProcedures1107-11, Grid Operations, Rev. 24OP-AA-108-107, Switchyard Control, Rev. 2OP-AA-108-107-1001, Station Response to Grid Capacity Conditions, Rev. 3Drawinqs13L,

TMI 230KV, Rev. 1OtherlRs9304001 088859111827711625509637551 104955111828711653252102485011076671123886118079110781131 1 1633811325781 2001 56wo R2173663

Section 1R04: Equipment AlisnmentProcedures1067, Independent Verification Program, Rev. 411107-3, Diesel Generator, Rev. 130OP-TM-424-000, Emergency Feedwater System, Rev. 11OP-TM-424-271, Standby Lineup and Flow Path Verification Check of

EFW System, Rev. 7OP-TM-424-902, EFW Alternate Inventory, Rev. 4OP-TM-424-921, EFW From Fire Service Using

FS-P-15, Rev. 3OP-TM-534-000, Reactor Building Emergency Cooling Water System, Rev. 1Drawinqs302-082, Emergency Feedwater Flow Diagram, Rev. 24302-101, Condensate Flow Diagram, Rev.64302-611, Reactor Building Normal and Emergency Cooling Water System, Rev. 13OthertR 1214328Section 1Rl 1: Licensed Operator RequalificationProceduresEP-AA-1009, Radiological Emergency Plan Annex for the Three Mile lsland Station, Rev. 17OP-TM-AOP-001, Fire, Rev. 8OP-TM-AOP-020, Loss of Station Power, Rev. 13OP-TM-AOP-041, Loss of Seal Injection, Rev. 5OP-TM-EOP-001, Reactor Trip, Rev. 10OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 7OP-TM-EOP-010, Emergency Procedure Rules, Guides, and Graphs, Rev. 11Section'1Rl2: Maintenance EffectivenessProceduresER-AA-450, Structures Monitoring, Rev. 0Attachment

A-4ES-035T, Reference Manual for Inspection of Structures, Rev. 3MA-AA-7 1 6 -230-1002, Vibration Analysis/Acceptance Guideline, Rev. 3U-1, Structural Facility Inspection, Rev. 12DrawinqsE-214-024, Reactor Aux Building - Below 331' and 329', Rev. 13SS-208-351, Electrical Elementary Diagrams 480V 1P-3C, Rev. 8S-211-001, Terminal Box T25, Rev. 0OtherlRs

0692081,

1169471, 1

190100,

1217318,

1218817,

1219598, 1226703TR-160, Maintenance Rule Structures In-Scope lnspection Report for Auxiliary Building andHeat Exchanger Vault, 713012010wo R2037082, R2148357, R2126997

Section 1Rl3: Maintenance RiskProcedures1301-9.7, Intake Pump House Floor, Silt Accumulation and Inspections, Rev. 26HU-AA-1211, Pre-Job Briefings, Rev. 7OP-AA-108-117, Protected Equipment Program, Rev. 1OP-MA-109-101, Clearance and Tagging, Rev. 11OP-TM-211-212,IST of

MU-V-16A and

MU-V-168, Rev. 3OP-TM-21 1-901, Emergency Injection (HPl/LPl), Rev. 5OP-TM-533-000, Decay Heat River System, Rev. 10OP-TM-732-404, Rack in 480V ES Breaker, Rev. 3SA-AA-129, Electrical Safety, Rev. 7TMI-PM-003, Success Criteria Notebook, Rev. 0TR-122, HPl/Makeup & Purification, Rev. 3WC-AA-101, On-line Work Control Process, Rev. 18Drawinqs302-645, Decay Heat Closed Cycle Cooling Water Flow Diagram, Rev. 39302-661, Make-Up and Purification Flow Diagram, Rev. 59OtherClearance 1 0501 47 5, 11 500473lRs

1212813,

1213436, 1218707WOs R2074716, R2164163

Section 1Rl5: Operabilitv EvaluationsProcedures1104-45F,

CO2 Fire Extinguishing System for 338' Elevation Relay Room, Rev. 261303-12.88, Fire Protection Instrumentation Function Test, Rev. 24AP-1038, Fire Protection Program, Rev. 76ER-AA-310-1004, Functional Failure Cause Determination Evaluation, Rev. IlC-120A, Reactor Protection System Power Supply Checks, Rev. 1MA-TM-'123-002, Joslyn Clark Relay Maintenance PMT/Inspection, Rev. 1Drawinos209-639, Engineered Safeguard R.B. lsolation on Reactor Trip and High-High RB Pressure,Rev.4Attachment

2-842, Control building an Machine Shop Ventilation Flow Diagram, Rev. 57OtherAR A2181740Failure of Actuator Cap Screws, SPX Process Equipment, Rev.1lRsMaterial Evaluation of Two Socket-Head Cap Screws removed from a Copes-Vulcan, ExelonPowerLabs, 6/10/08Material Evaluation of Two Socket-Head Cap Screws removed from a Copes-Vulcan, ExelonPowerLabs, 02129108MPR Calculation for Transient Analysis of CO2 Discharge in TMI U1 Relay Room, Oct. 30, 2008PES-S-002, Shelf Life, Rev. 6wo R2094292

Section lR19: Post Maintenance TestinqProceduresOP-TM-424-451, Water Removal From

EF-P-1 Steam Lines, Rev. 4OP-TM-864-901, SBO Diesel Generator (EG-Y-4) Operations, Rev. 10Drawinqs302-011, Main Steam Flow Diagram, Rev. 72302-082, Emergency Feedwater Flow Diagram, Rev.24616-006, Schematic Station Blackout Diesel Generator, Sheet 5, Rev. 0OtherlRsWOs

Section 2RS1: Access Controlto Radiolosicallv Siqnificant AreasProceduresNF-AA-390, Spent Fuel Pool Material Control, Rev. 4RP-AA-460, Controls for High and Locked High Radiation Areas, Rev' 20RP-AA-460-001, Control for Very High Radiation Areas, Rev. 2RP-AA-460-002, Additional High Radiation Exposure Control, Rev. 0RP-TM-460-1002, Access Controlfor Locked High Radiation Areas, Rev. 1RP-TM-460-1003, Access to Reactor Incore UndervesselArea, Rev' 1RP-TM-460-1007, Access to

TMI 1 Reactor Building, Rev. 5RP-TM-460-1008, Locked High Radiation Area Key Control, Rev' 26817349875211 05281 6113200412104156999901 01 8893'1060541115520312310448854091046748111508612158921064102121018012278201228439122970011321871210463122828212285821249707121245512283151229136c2024072R2044943R21 1531 1R2141909R2173375c2025113R2052437R2137206R2153005R2177067c2025185R2058455R2139680R2153642R21 80365c2025189R2064005R21 39701R2153711c2025194R2064965R2139903R21 5371 3c2025543R2070823R2141666R2172053Attachment

A-6RP-TM-460-1011, Establishment of Robust Barriers for lrradiated Fuel Movement, Rev. 0OtherGeneral Source Term Datalnstrument Calibration Records (SAM NOs.

714543,

PCMl-710938,

PCM2-714558,

PM-7714502)Locked High Radiation Key InventoryRadioactive Source RecordsSource Reconciliation Report and Leak Test Data

Section 2RS2: OccupationalALARA Planninq and ControlsOtherALARA Post-Job ReviewsGeneral Source Term DataRadiation Work Permits and associated

ALARA plans and post-job reviews (409, 509, 534,601 ,602, 605, 609, 621 )Work In Progress Reviews

Section 2RS5: Radiation Monitorins InstrumentatioEProcedures1101-2.1, Radiation Monitor System Set-points1302-3.1,

RMS Calibration1302-3.1A, Victoreen Effluent Gas Channel Calibration1302-3.18, RML 6 Calibration and Linearity Check1302-3.3

WDL-FT-84, Channel Calibration1302-3.4.8, FHB Ventilation System Effluent Flow Calibration1302-3.4C,

AH-FT-148A, 1488, 149, and 150 Flow Loops1302-3.4D, Flow and Vacuum Calibration for TMI Atmospheric Effluent Radiation Monitors1302-4.2.1, Post-Accident Radiation Monitors Channel Test .1302-15, High Range RMS Containment Monitor Calibration1302-17.1NB,

RM-A-S, Gas Hi Calibration1302-17.4,

RM-L-1 2, Calibration1303-4.10,

RM-L-12 Interlock Test1303-4.15, Radiation Monitoring System Operating Test Liquid Channel1 303-4. 1 5, Radiation Monitoring System Quarterly Test-Atmospheric Channel1303-4.15A, Radiation Monitoring System Test - Atmospheric1303-4.15E,

RM-A14, Radiation Monitor and Sample Flow lnstrument ChannelTestCY-AA-1 1 0-200, SamplingCY-AA-1 30-201, Radiochemistry Quality ControlCY-AA-1 30-320, Packard 2900TFy3 1 00TR Liq uid Scintillation CounterCY-TM-130-9930, Operation of the Genie 2000 SystemCY-TM-170-300, Offsite Dose Calculation Manual Rev. 17EP-AA-1 009, Radiological Emergency Plan Annex-TMl,EP-EAL-0609, Criteria for Choosing Radiological Gaseous Effluent EAL Thresholds N1828,NEI-99-01, Methodology for Development of Emergency Action levelsQuality Assurance Program for Radiological Effluent MonitoringRP-AA-1 7, Radiological Instrument Program DescriptionRP-AA-700, Controls for Radiation Protection InstrumentationSDBD-Tl-661, Rev.6, System Design Basis Document for Radiation Monitoring ProgramSR-FT-1 46, Channel CalibrationAttachment

A-7OtherAMS-3/4 Operational Check DataCalibration Portable Instrument Source Check and InventoryContamination Monitoring Instrument MatrixCounting Equipment Daily Status LogFrisker Source Check DataGeneral Source Term DataInstrument Smear Test DataLaboratory Instrumentation Calibration Data - liquid scintillation, gamma spectroscopyTechnical Specification 6.8.4.b, Radioactive Effluent ProgramTechnical Specification 6.9.4, Annual Radioactive Effluent Release Report

Section 2RS6: Radioactive Gaseous and Liquid Effluent TreatmentProcedures1303-1 1 .15, Auxiliary and Fuel Handling Building Filter Efficiency Test1 440-F -1 B, Charcoal Filter SamplingCY-TM-170-301 , Liquid and Gaseous Effluent Monthly Cumulative Dose Contribution andProjection, Rev.0MA-TM- 1 54-902, Nontechnical Specification Ventilation Fi lter TestingU-36, Ventilation Filter

DOP and Halide TestingOtherComposite Sample table 3.2-1EPRI Technical Report - Estimate of Carbon 14 in Nuclear Power Plant Gaseous Effluents -2010Gaseous Dose ProjectionsMonthly Dose ProjectionsNUREG 1301, Offsite Dose Calculation Manual GuidancePWR C-14 Source Term Calculation

Section 2RS7: Radioloqical Environmental Monitorinq ProqramProceduresCY-AA-170-000, Radioactive Effluent and Environmental Monitoring Programs, Rev. 4CY-AA-1 70-1 00, Radiological Environmental Monitoring Program, Rev. 2CY-AA-170-1000, Radiological Environmental Monitoring Program and Meteorological Programlmplementation, Rev.5CY-AA-170-1100, Quality Assurance for Radiological Monitoring Program, Rev. 1CY-M-170-200, Radioactive Effluent Control Program, Rev. 1CY-AA-1 7

0-210, Potentially Contaminated System Control Program, Rev. 0CY-TM-170-300, Offsite Dose Calculation Manual, Rev.2CY-TM-170-1002, Radiological Environmental Monitoring Program TLD Program Data Review,Rev.0CY-170-2000, Annual Radioactive Effluent Release Report, Rev. 5ER-TMl-06, Water Sampler Calibration CertificateN1855, Sampling of Unmonitored Potential Radioactive Release Paths, Rev.

IRP-AA-228, Rev.1, 10

CFR 50.75(g) and 10

CFR 72.30 Documentation RequirementsOther10

CFR 50.75 (g) filesAir Sampler Orifice Calibration Certificates (2782155,2782146,2782153, and 2782154)Annual Radiological Environmental, Effluent Release Reports- 2009, 2010Attachment

A-8Annual Site Survey (Tree Survey-Meteorological Tower)

TMI 2011Audit Repoft2011-009Corrective Action Documents (ARs)Corrective Action Plan Audit March 22,2Q11EN-TM-408-41 60, RGPP Reference MaterialGroundwater Well Data- 2010 (Groundwater Monitoring Report)Monthly Surveillance dataNUPf C Audit 22937, April 28,2011Quality Assurance Confirmatory Testing of Environmental TLDsRAF 10-005, Pathway Analysis, August 11, 2010Regional Groundwater Discharge Schematic TMI Hydro-geologic lnvestigation Report,September 2006Teledyne Brown Environmental Service, Annual Quality Assurance Report January-December2010TMI 2010 Land Use Census, October 31 , 201QVacuum Gauge for Pump Tests - Calibration (2743152)Vacuum Gauge Calibration 274152

Section 2RS8: Radioactive Solid Waste Processins and Radioactive Material. HandlinsStoraqe. and TransPortationProcedures1104-28A, Evaporator Concentrate Processing, Rev. 331104-28C, Primary Resin and Pre-coat Processing, Rev.21COP-TM-232-434, Recirculation of the Spent Resin Storage Tank, Rev. 3OP-TM-232-545, Transfer of the Spent Resin Storage Tank to the Hittman Building, Rev. 1RP-AA-500, Radioactive Material (RAM) Control, Rev. 14,RP-AA-500-1001, Requirements for Radioactive Material Stored Outdoors, Rev. 2RP-AA-601, Surveying Radioactive Material Shipments, Rev. 13RP-AA-602, Packaging of Radioactive Material Shipments, Rev' 15RP-AA-602-1001, Packaging of Radioactive Material/ Waste Shipments, Rev' 11RP-AA-603, Inspection and Loading of Radioactive Material Shipments, Rev' 5RP-AA-603-1001, Inspection and Loading of Radioactive material/ Waste Shipments, Rev. 2RP-AA-605, 10

CFR 61 Program, Rev. 3RP-AA-631, Dry Radioactive Waste Generation and Reduction, Rev' 1RP-TM-500-1004, Outage Equipment Storage Building, Rev. 1RP-TM-503-1001, Volumetric Material Control, Rev. 0RW-AA-100, Process Control Program, Rev. 7OtherttOSn Audit-

TMI-10-04 and Audit template (Chemistry Radioactive Effluent and EnvironmentalMonitoring, Handling and Storage and Shipment), Rev. 4Radwaste/Chem istry Checki n- 1 1 32237 -02RAF-10-007, Rev. 0-, RAM Storage in the WHPF Yard Areas and RUBB Building IAW

RP-500and

RP-AA-500-1001 October 1, 2010RCS Trending Report - Third Quarter 2010Shipment Reiords (RS-10-005-1,

RS-10-036-1,

RS-1 1-014-',

RS-11-013-1,

RS-11-005-1,

RS-10-085-l)TMI Radiation Protection Calc Sheet

RAF 10-003 2009 DAW Waste Stream RADMAN WMGUpdated Results Review 06-18-10Attachment

A-9Section 4OM: ldentification and Resolution of ProblemsProceduresOP-AA-102-103-1001 , Operator Burden and Plant Significant Decisions lmpact AssessmentProgram, Rev.3WC-AA-101, On Line Work Control Process, Rev. 18WC-M-101-1002, On Line Scheduling Process, Rev. 11WC-AA-106, Work Screening and Processing, Rev. 12OtherAdverse Condition Monitoring and Contingency Plan Tracking Sheet, June 22,2011Audit NOSA -TMl-10-04, Chemistry, Radioactive Waste, Effluent, and Environmental MonitoringAudit Repoft2011-009Check-in assessment- ChemistryCheck- In Self Assessment Solid Waste Processing and RAM Storage and Transportation -130987-02Corrective Action Plan- NUPIC AuditCorrective Action Plan Audit March 22,2011NOS-TMl-10-04, Chemistry, Radwaste, Effluent and Environmental Monitoring Audit Report,June 25,2010NUPIC Audit 22937, April2011Operators Aggregate Assessment, June 2,2011Teledyne Brown Environmental Service Annual 2010 Quality Assurance Report 2010Teledyne Brown Environmental Service, Annual Quality Assurance Report January-December2010Section 40A5 (Tl 2515/179)Procedures1301-7.2, Inventory and Leak Testing of Radioactive Sources, Rev. 28RP-AA-500, Radioactive Material RAM Control, Rev. 14RP-AA-800, Source Leak Test Record, Rev. 6PR-AA-800-001, Nationally Tracked Source Program, Rev. 0RP-TM-500-1002, Radioactive Material Transfer, Rev. 2Other2011 Inventory List of Radioactive Sources, National Source Tracking Registry (as of May 9,2011)lRs09299861 0691 021 1 350591203298123172910593901 081 998118474712200201231737106046410820431 1

852351

2200361

9047931 063662111764421192534122004410658141 1 3098711973521220063Attachment