ML081160408
| ML081160408 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 04/25/2008 |
| From: | Bellamy R NRC/RGN-I/DRP/PB6 |
| To: | Pardee C AmerGen Energy Co, Exelon Generation Co |
| BELLAMY, RR | |
| References | |
| IR-08-002 | |
| Download: ML081160408 (25) | |
See also: IR 05000289/2008002
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD
KING OF PRUSSIA, PA 19406-1415
April 25, 2008
Mr. Charles G. Pardee
Chief Nuclear Officer (CNO) and Senior Vice President
Exelon Generation Company, LLC
Chief Nuclear Officer (CNO)
AmerGen Energy Company, LLC
200 Exelon Way
Kennett Square, PA 19348
SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED
INSPECTION REPORT 5000289/2008002
Dear Mr. Pardee:
On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated
inspection at your Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report
documents the inspection results, which were discussed April 18, 2008, with Mr. Bill Noll and
other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
On the basis of the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its
enclosure, and your response (if any) will be available electronically for public inspection in the
NRC Public Document Room or from the Publicly Available Records (PARS) component of
NRCs document system (ADAMS). ADAMS is accessible from the NRC Website at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
We appreciate your cooperation. Please contact me at 610-337-5200 if you have any questions
regarding this letter.
Sincerely,
/RA/
Ronald R. Bellamy, Ph.D., Chief
Projects Branch 6
Division of Reactor Projects
Docket No: 50-289
License No: DPR-50
2
Enclosure: Inspection Report 05000289/2008002
w/Attachment: Supplemental Information
cc w/encl:
Executive Vice President and Chief Operating Officer, Exelon Generation
Site Vice President - TMI Unit 1, AmerGen
Plant Manager - TMI, Unit 1, AmerGen
Regulatory Assurance Manager - TMI, Unit 1 AmerGen
Senior Vice President - Nuclear Services, AmerGen
Senior Vice President - Mid-Atlantic Operations, AmerGen
Senior Vice President - Operations Support, AmerGen
Vice President - Licensing and Regulatory Affairs, AmerGen
Director Licensing - AmerGen
Manager Licensing - TMI, AmerGen
J. Fewell, Esq., Associate General Counsel, Exelon Nuclear
Correspondence Control Desk - AmerGen
Chairman, Board of County Commissioners of Dauphin County
Chairman, Board of Supervisors of Londonderry township
R. Janati, Director, Bureau of Radiation Protection, State of PA
J. Johnsrud, National Energy Committee
E. Epstein, TMI-Alert (TMIA)
D. Allard, PADEP
J. Powers, Director, PA Office of Homeland Security
R. French, Director, PA Emergency Management Agency
3
Mr. Charles G. Pardee
Chief Nuclear Officer (CNO) and Senior Vice President
Exelon Generation Company, LLC
Chief Nuclear Officer (CNO)
AmerGen Energy Company, LLC
200 Exelon Way
Kennett Square, PA 19348
SUBJECT: THREE MILE ISLAND STATION, UNIT 1 - NRC INTEGRATED
INSPECTION REPORT 5000289/2008002
Dear Mr. Pardee:
On March 31, 2008, the U.S. Nuclear Regulatory Commission (NRC) completed an integrated inspection at your
Three Mile Island, Unit 1 (TMI) facility. The enclosed inspection report documents the inspection results, which were
discussed April 18, 2008, with Mr. Bill Noll and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the
Commissions rules and regulations and with the conditions of your license. The inspectors reviewed selected
procedures and records, observed activities, and interviewed personnel.
On the basis of the results of this inspection, no findings of significance were identified.
In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your
response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the
Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the
NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
We appreciate your cooperation. Please contact me at 610-337-5200 if you have any questions regarding this letter.
Sincerely,
Ronald R. Bellamy, Ph.D., Chief /RA/
Projects Branch 6
Division of Reactor Projects
Distribution w/encl: (VIA EMAIL)
S. Collins, RA
M. Dapas, DRA
D. Lew, DRP
J. Clifford, DRP
R. Bellamy, DRP
S. Barber, DRP
A. Rosebrook, DRP
D. Kern, DRP, Senior Resident Inspector
J. Brand, DRP, Resident Inspector
C. LaRegina, DRP, Resident OA
S. Williams, RI, OEDO
H. Chernoff, NRR
J. Lubinski, NRR
G. Miller, NRR
J. Lubinski, NRR
ROPreportsResource@nrc.gov
Region 1 Docket Room (with concurrences)
SUNSI Review Complete AAR (Reviewers Initials)
DOCUMENT NAME: G:\DRP\BRANCH6a\+++Three Mile Island\TMI Inspection Reports\TMI 08- 002.doc
After declaring this document An Official Agency Record it will be released to the Public.
To receive a copy of this document, indicate in the box: C= Copy without attachment/enclosure E=Copy with
attachment/enclosure, N=No copy
OFFICE RI/DRP RI/DRP RI/DRP RI/DRS
NAME DKern/ AAR for ARosebrook/ AAR SBarber/ SB RBellamy/RRB
DATE 4 /24 /08 4/24 /08 4/25 /08 4/ 25 /08
OFFICIAL RECORD COPY
1
U.S. NUCLEAR REGULATORY COMMISSION
REGION 1
Docket No: 05000289
License No: DPR-50
Report No: 05000289/2008002
Licensee: AmerGen Energy Company, LLC (AmerGen)
Facility: Three Mile Island Station, Unit 1
Location: PO Box 480
Middletown, PA 17057
Dates: January 1 - March 31, 2008
Inspectors: David M. Kern, Senior Resident Inspector
Javier M. Brand, Resident Inspector
Jeffrey Bream, Reactor Engineer
Danté Johnson, Physical Security Inspector
Kevin Mangan, Senior Reactor Inspector
Ronald M. Nimitz, Senior Health Physicist
Approved by: Ronald R. Bellamy, Ph.D., Chief
Projects Branch 6
Division of Reactor Projects (DRP)
Enclosure
2
TABLE OF CONTENTS
SUMMARY OF FINDINGS.......................................................................................................... 3
1. REACTOR SAFETY ........................................................................................................... 4
1R01 Adverse Weather Protection ................................................................................... 4
1R04 Equipment Alignment ............................................................................................. 4
1R05 Fire Protection ........................................................................................................ 5
1R11 Licensed Operator Requalification Program ........................................................... 6
1R12 Maintenance Effectiveness ..................................................................................... 6
1R13 Maintenance Risk Assessments and Emergent Work Control ................................ 7
1R15 Operability Evaluations ........................................................................................... 8
1R18 Plant Modifications ................................................................................................. 8
1R19 Post Maintenance Testing ...................................................................................... 9
1R22 Surveillance Testing ............................................................................................. 10
2. RADIATION SAFETY ....................................................................................................... 11
20S1 Access Controls .................................................................................................... 11
2OS2 ALARA Planning and Controls .............................................................................. 12
2OS3 Radiation Monitoring Instrumentation and Protective Equipment .......................... 14
2PS2 Radioactive Material Processing and Transportation ............................................ 14
4. OTHER ACTIVITIES......................................................................................................... 15
4OA1 Performance Indicator Verification ........................................................................ 15
4OA2 Identification and Resolution of Problems ............................................................. 15
4OA6 Meetings, Including Exit......................................................................................... 18
ATTACHMENT: SUPPLEMENTAL INFORMATION ................................................................ 18
SUPPLEMENTAL INFORMATION......................................................................................... A-1
KEY POINTS OF CONTACT.................................................................................................. A-1
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED ....................................................... A-1
LIST OF ACRONYMS ............................................................................................................ A-4
Enclosure
3
SUMMARY OF FINDINGS
IR 05000289/2008002; 1/1/2008 - 3/31/2008; AmerGen Energy Company, LLC; Three Mile
Island, Unit 1; Routine integrated report.
The report covered a 13-week period of inspection by resident inspectors and announced
inspections by regional inspectors. No findings of significance were identified. The NRCs
program for overseeing the safe operation of commercial nuclear power reactors is described in
NUREG-1649, Reactor Oversight Process, Rev. 3, dated July 2000.
A. NRC-Identified and Self-Revealing Findings
No findings of significance were identified.
B. Licensee Identified Violations
None.
Enclosure
4
REPORT DETAILS
Summary of Plant Status
Three Mile Island, Unit 1 (TMI) operated at approximately 100 percent rated thermal power for
the entire inspection period.
1. REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection (71111.01 - 1 site sample)
a. Inspection Scope
Winter storms, including heavy rains and winds, elevated the Susquehanna River level
above flood stage and affected river conditions from March 5 to 11, 2008. The
inspectors reviewed procedures, conducted interviews, and performed various
inspections to verify that operator actions to address adverse river conditions maintained
the readiness of the various river water systems. Operators closely monitored National
Weather Service flood projections and entered procedure 1202-32, Flood, Rev. 65 when
the 36-hour forecast projected river level to reach flood stage (286.1 feet at the intake
screen house (issue report (IR) 745543). The inspectors walked down the intake screen
house which houses the fire protection system pumps and safety related cooling water
pumps for the decay heat removal system, nuclear service water system, and reactor
river water system. Additionally, after river level receded below flood stage, the
inspectors walked down the flood dike which surrounds the entire power plant in
accordance with procedure 3301-SA1, Dike Inspection, Rev. 12 to determine whether
the flood barrier had been damaged or needed repair (IRs 734215, 747638). The
inspectors evaluated the adequacy of various emergency and surveillance procedures
associated with river water and intake systems to assess AmerGen=s protection from
storms and adverse river conditions.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment (71111.04)
a. Inspection Scope
Partial System Walkdowns (71111.04Q - 3 samples)
The inspectors performed three partial system walkdown samples on the following
systems and components:
- On February 12, 2008, the inspectors walked down portions of the A decay heat
removal and reactor building spray systems while the plant was in an unplanned
orange risk condition due to an unexpected electrical breaker fault which made the
B decay river water pump inoperable.
Enclosure
5
- On February 21, the inspectors walked down portions of the B reactor building spray
system while the plant was in a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> limiting condition of operation for scheduled
A emergency safeguards and actuation load sequence testing.
- On February 27 and 28, the inspectors walked down portions of the remote safe
shutdown panel, while engineers and technicians were performing inspections of the
engineered safeguards and actuation system relays.
The partial system walkdowns were conducted on the redundant and standby equipment
to ensure that trains and equipment relied on to remain operable for accident mitigation
were properly aligned. Additional documents reviewed are listed in the attachment.
Complete System Walkdown (71111.04S - 1 sample)
On March 3 and 4, 2008, the inspectors performed one complete system walkdown
sample on the B and C makeup and purification system trains, while the A system
train was in a scheduled maintenance outage. The inspectors conducted a detailed
review of the alignment and condition of the system using the applicable one-line
diagram 302-560, Makeup and Purification, Rev. 44. In addition, the inspectors
reviewed and evaluated the corrective action program reports for impact on system
operation, interviewed the system engineer, and interviewed control room operators.
b. Findings
No findings of significance were identified.
1R05 Fire Protection (71111.05)
a. Inspection Scope (71111.05Q - 8 samples)
The inspectors conducted fire protection inspections for several plant fire zones,
selected based on the presence of equipment important to safety within their boundaries.
The inspectors conducted plant walkdowns and verified the areas were as described in
the TMI Fire Hazard Analysis Report, and that fire protection features were being
properly controlled per surveillance procedure 1038, Administrative Controls-Fire
Protection Program, Rev. 69. The plant walkdowns were conducted throughout the
inspection period and included assessment of transient combustible material control, fire
detection and suppression equipment operability, and compensatory measures
established for degraded fire protection equipment in accordance with procedure OP-
MA-201-007, Fire Protection System Impairment Control, Rev. 5. In addition, the
inspectors verified that applicable clearances between fire doors and floors met the
criteria of Attachment 1 of Engineering Technical Evaluation CC-AA-309-101,
Engineering Technical Evaluations, Rev. 9. Fire zones and areas inspected included:
- Fire Zone AB-FZ-2A, Auxiliary Building Elevation 281, Makeup and Purification
Pump A;
- Fire Zone AB-FZ-2B, Auxiliary Building Elevation 281, Makeup and Purification
Pump B;
- Fire Zone AB-FZ-3C, Auxiliary Building Elevation 281, Makeup and Purification
Pump C;
- Fire Zone DG-FA-1, Diesel Generator Building Elevation 305, Diesel Generator A;
- Fire Zone DG-FA-2, Diesel Generator Building Elevation 305, Diesel Generator B;
- Fire Zone TB-FA-1, Turbine Building Elevation 305
Enclosure
6
- Fire Zone TB-FA-1, Turbine Building Elevation 322
- Fire Zone TB-FA-1, Turbine Building Elevation 355
b. Findings
No findings of significance were identified.
1R11 Licensed Operator Requalification Program (71111.11Q - 1 sample)
a. Inspection Scope
On March 18, 2008, the inspectors observed licensed operator requalification training at
the control room simulator for the E operator crew. The inspectors observed the
operators simulator drill performance and compared it to the criteria listed in TMI
Operational Simulator Scenario Number 12, Condenser Vacuum Leak, Stuck Rod, Loss
of Offsite Power with Diesel and Emergency Feedwater Failures, Rev. 12. The
inspectors reviewed the operators ability to correctly evaluate the simulator training
scenario and implement the emergency plan. The inspectors observed supervisory
oversight, command and control, communication practices, and crew assignments to
ensure they were consistent with normal control room activities. The inspectors
observed operator response during the simulator drill transients. The inspectors
evaluated training instructor effectiveness in recognizing and correcting individual and
operating crew errors. The inspectors attended the post-drill critiques in order to
evaluate the effectiveness of problem identification. The inspectors verified that
emergency plan classification and notification training opportunities were tracked and
evaluated for success in accordance with criteria established in Nuclear Energy Institute
(NEI) 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 5.
Additional documents reviewed are listed in the attachment.
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness (71111.12Q - 2 samples)
a. Inspection Scope
The inspectors evaluated the listed samples for Maintenance Rule (MR) implementation
by ensuring appropriate MR scoping, characterization of failed structures, systems, and
components (SSCs), MR risk categorization of SSCs, SSC performance criteria or goals,
and appropriateness of corrective actions. Additionally, extent of condition follow-up,
operability, and functional failure determinations were reviewed to verify they were
appropriate. The inspectors verified that the issues were addressed as required by 10
CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear
Power Plants; Nuclear Management and Resources Council (NUMARC) 93-01, Industry
Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, Rev.
2; and AmerGen procedure ER-AA-310, Implementation of the Maintenance Rule, Rev.
6. The inspectors verified that appropriate corrective actions were initiated and
documented in IRs, and that engineers properly categorized failures as maintenance
rule functional failures and maintenance preventable functional failures, when applicable.
Enclosure
7
- IR 735277 describes the failure of DR-P-1B to start from the control room. AmerGen
identified the failure as a Maintenance Rule Functional Failure. Since the cause of
the failure was attributed to an isolated manufacturing defect, AmerGen determined
that it was not a Maintenance Preventable Functional Failure. As such, the 10 CFR
50.65 a(2) determination remains valid.
effectively controlled and maintained such that the system remained capable of
performing its intended function. This inspection sample was based on an NRC
maintenance rule finding identified in March 2007, at another nuclear power plant
regarding ineffective controls of the performance and condition of the hydrogen
monitoring system.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13 - 5 samples)
a. Inspection Scope
The inspectors reviewed the scheduling, control, and restoration during the following
maintenance activities to evaluate their effect on plant risk. This review was against
criteria contained in AmerGen Administrative Procedure 1082.1, TMI Risk Management
Program, Rev. 7 and WC-AA-101, On-Line Work Control Process, Rev. 14.
chemical used to achieve a uniform pH in containment post accident was changed to
trisodium phosphate per modification ECR 07-174. The online maintenance risk
profile remained green during this evolution (Risk Document 1254, Rev. 3).
- On January 22, 2008, emergency feedwater valve EFW-V-30B was taken out of
service for scheduled overhaul of the air actuator. The condition elevated the online
maintenance risk profile to yellow (Risk Document 1020, Rev. 4).
- On February 12, the B decay river water pump (DR-P-1B) failed to start due to a
faulted starting relay (IRs 735277 and 735778). The condition elevated the online
maintenance risk profile to orange (Risk Document 1195, Rev. 3).
- On February 12, the C makeup pump auxiliary lubricating oil pump (MU-P-2C) did
not auto start as expected during a scheduled surveillance test due to a failed
pressure switch (IR-735063). This condition did not affect operability of MU-P-1C.
On February 13, after DR-P-1B was returned to service and the on-line risk had been
returned to green, technicians replaced the failed pressure switch. This work
elevated the online maintenance risk profile to yellow (Risk Document 1066, Rev. 2).
- On February 27, a contact for a reactor building emergency cooling and isolation
relay 63X-RB6B was replaced due to intermittent indication. The online maintenance
risk profile remained green during this evolution (Risk Document 551, Rev. 8).
Enclosure
8
b. Findings
No findings of significance were identified.
1R15 Operability Evaluations (71111.15 - 3 samples)
a. Inspection Scope
The inspectors verified that degraded conditions in question were properly characterized,
operability of the affected systems was properly evaluated in relation to Technical
Specification (TS) requirements, applicable extent of condition reviews were performed,
and no unrecognized increase in plant risk resulted from the equipment issues. The
inspectors referenced NRC Inspection Manual Chapter (IMC) Part 9900, Operability
Determinations & Functionality Assessments For Resolution of Degraded or
Nonconforming Conditions Adverse to Quality or Safety and AmerGen procedure OP-
AA-108-115, Operability Determinations, Rev. 5, to determine acceptability of the
operability evaluations. The inspectors reviewed operability evaluations for the following
degraded equipment issues:
- On December 4, 2007, NS-P-1A breaker operating mechanism became bound
during breaker inspection (WO-R2039072). This condition occurred after the breaker
had been cycled satisfactorily eight times. An analysis performed by the
manufacturer determined that this condition affected only the manual closure of the
breaker which is used for maintenance and would not come into play during normal
auto electrical operation of the breaker. Therefore, NS-P-1A operability was not
impacted (IRs 707261 and 730312).
- On December 11, SF-P-1A inadvertently tripped during surveillance testing per 1303-
4.19, HPI/LPI Analog Channel test, Rev. 26. Engineers determined the cause was a
misaligned contact in ESAS load shed relay 63Z1B-RC2A. Operability of SF-P-1A
was not affected because the relay function to trip the pump upon an ESAS actuation
was not affected (IR-710133).
- On January 2, 2008, operators and technicians identified that the reactor building
emergency cooling and isolation system channel RB2A failed to actuate during
performance of ESAS surveillance testing. Engineers determined that this condition
only affected the test circuit and not the safety portion of the circuit (IRs-717254 and
725846).
b. Findings
No findings of significance were identified.
1R18 Plant Modifications (71111.18 - 1 sample)
a. Inspection Scope
The inspectors reviewed the following modification to determine whether it was designed
and/or implemented as required by CC-AA-102, Design Input and Configuration Change
Impact Screening, Rev. 14 and CC-AA-103, Configuration Change Control, Rev. 17.
The inspectors verified the modification supported plant operation as described in the
Enclosure
9
Updated Final Safety Analysis Report (UFSAR) and complied with associated TS
requirements. The inspectors reviewed the function of the changed component, the
change description and scope, and the associated 10 CFR 50.59 screening evaluation.
- Engineering Change Request (ECR) # 06-595, Decay River Strainer, Rev. 0 was
installed to replace the funnel type strainer media with a flat metal disc media to
reduce the potential for clogging by filamentous algae. This algae caused
excessive strainer clogging in May 2006 due to a bloom associated with lower than
usual river levels. The inspectors also reviewed IR-588605 which evaluated a
higher than expected differential pressure result during post installation testing of
the new media. Engineers determined that the higher differential pressure was due
to improper design of the media (lesser number of holes). The evaluation also
determined that this media did not affect operability of the strainer and decay river
system. The inspectors verified corrective actions including revision to the ECR to
specify the correct number of holes for the media. In addition, actions to replace
the existing media with the proper design are scheduled for May 2008.
b. Findings
No findings of significance were identified.
1R19 Post Maintenance Testing (71111.19 - 7 samples)
a. Inspection Scope
The inspectors reviewed and/or observed the following post-maintenance test (PMT)
activities to ensure: (1) the PMT was appropriate for the scope of the maintenance work
completed; (2) the acceptance criteria were clear and demonstrated operability of the
component; and (3) the PMT was performed in accordance with procedures.
- On December 12, 2007, operators performed post maintenance testing in
accordance with 1303-4.19, HPI/LPI Analog Channel Test, Interim Change 24193,
following replacement of a misaligned contact that caused an inadvertent trip of SF-
P-1A (Ref: Section 71111.15). The inspectors reviewed the PMT scope adequacy
and results to ensure the PMT addressed the results of additional relay failure
analysis performed in January 2008.
- On January 23, 2008 operators performed post maintenance testing in accordance
with OP-TM-424-212, IST of EF-V-30s and EF-V-52s, Rev.2, following replacement
of the actuator for EFW-V-30B.
- On January 24, operators performed post maintenance testing in accordance with
1303-4.13, RB Emergency Cooling and Isolation System Analog Test, Rev. 40, and
Interim Change 24192, following replacement of multiple components to address a
relay (T2/RB2A) failure to de-energize (IR-725846).
- On February 13, operators performed post maintenance testing of DR-P-1B in
accordance with Work Order C2016938 following replacement of a faulted X-relay
within electrical circuit breaker DR-P-1B-BK.
Enclosure
10
- Control building chiller AH-C-4B was degraded, due to developing insufficient oil
pressure upon starting from a standby condition. Technicians implemented a
complex troubleshooting plan including oil samples, auxiliary oil pump voltage and
current readings, replacement of the auxiliary pump and motor, and borescope
inspection of the auxiliary oil system and compressor work order C2016844. Post
maintenance tests were performed from February 15 to March 11, using C2016844
and E-108, Control Building Chiller AH-C-4A/B Weekly, Quarterly, and Annual
Inspection, Interim Change 19851.
- On February 27, operators performed post maintenance testing of ESAS relay 63X-
RB6B, in accordance with procedure 1303-4.14, RB 30 PSIG Analog Channels,
Interim Change 24839, following replacement of a contact that was providing
intermittent indication.
- On March 27, CM-V-3 open and close strokes were successfully verified using
procedure 1300-3Q.5, Quarterly Inservice Testing of CM-V-1/2/3/4 Valves During
Normal Plant Operations, Rev. 1 following troubleshooting to address excessive
valve closure stroke time.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing (71111.22)
a. Inspection Scope (3 Inservice Testing Samples and 2 Routine Surveillance Samples)
The inspectors observed and/or reviewed the following operational surveillance tests to
verify adequacy of the test to demonstrate the operability of the required system or
component safety function. Inspection activities included review of previous surveillance
history to identify previous problems and trends, observation of pre-evolution briefings,
and initiation/resolution of related IRs for selected surveillances.
- From December 27, 2007 to January 2, 2008, procedure OP-TM-214-211,
Verification of TSP, Rev. 0
- On January 2, 2008, 1303-4.13, RB Emergency Cooling and Isolation System
Analog Test, Rev. 40 and Interim Change 24192.
- On February 6, procedure OP-TM-211-248, Boric Acid Injection System Functional
Test, Rev. 0
- On February 12, procedure OP-TM-211-208, IST Of MU-P-1C, Rev. 2
- On February 12, procedure OP-TM-211-251, Leakage Exam Of MU System, Interim
Change 23462
b. Findings
No findings of significance were identified.
1EP6 Drill Evaluation (71114.06)
a. Inspection Scope (1 Training Evolution Sample)
Enclosure
11
The inspectors observed an emergency event training evolution conducted on March 18,
2008, at the Unit 1 control room simulator to evaluate emergency procedure
implementation, event classification, and event notification. The event scenario involved
multiple safety-related component failures and plant conditions warranting simulated
Unusual Event and Alert emergency event declarations. The inspectors observed the
drill critique to determine whether the licensee critically evaluated drill performance to
identify deficiencies and weaknesses. Additionally, the inspectors verified the
Drill/Exercise performance indicators were properly evaluated consistent with NEI 99-02,
Regulatory Assessment Performance Indicator Guideline, Rev. 5. Additional documents
reviewed are listed in the Attachment.
b. Findings
No findings of significance were identified.
2. RADIATION SAFETY
Cornerstone:Occupational Radiation Safety
20S1 Access Controls (71121.01 - 4 samples)
a. Inspection Scope
The inspectors reviewed selected activities and associated documentation in the below
listed areas. The evaluation of AmerGens performance in these areas was against
criteria contained in 10 CFR 20, applicable TSs, and applicable AmerGen procedures.
Plant Walkdowns, Radiation Work Permit Reviews, Job Reviews
The inspectors walked down selected radiological controlled areas and reviewed
housekeeping, material conditions, posting, barricading, and access controls to
radiological areas. The inspectors toured areas of the Auxiliary Building, Spent Fuel
Area, outdoor areas, and radioactive waste processing area. The inspectors conducted
selective independent radiation surveys, and verified the adequacy of: selected
radiological boundaries and postings; that engineering controls were in place; that air
samplers were properly located; and that TS locked High Radiation Areas (HRA) were
properly secured and posted.
The inspectors selectively reviewed the applied radiological controls for personnel entry
into the Unit 1 reactor building containment at power on March 3, 2008, and movement
of concentrated radioactive waste on March 6, 2008. The reviews included evaluation of
the adequacy of all applied radiological controls including radiation work permits,
procedure adherence, radiological surveys, job coverage, airborne radioactivity sampling
and controls, and contamination controls. The reviews included, where applicable,
barrier integrity and the application of engineering controls for potential airborne
radioactivity areas and radioactive source-term, and radiation levels present. The
inspectors attended the briefing for workers involved in radioactive waste handling.
The inspectors also reviewed and discussed electronic dosimeter and
thermoluminescent dosimeter results to identify anomalies and licensee actions, as
applicable.
Enclosure
12
The inspectors reviewed and discussed internal dose assessments for 2007 to identify
any apparent actual occupational internal doses greater than 50 millirem committed
effective dose equivalent. The inspectors assessed the adequacy of evaluations for
selected dose assessments and included selected review of the program for evaluation
of potential intakes associated with hard-to-detect radionuclides (e.g., airborne
transuranics).
High Risk Significant, High Dose Rate HRA and Very High Radiation Area Controls
The inspectors conducted a selective review of HRA controls (e.g., adequate posting
and locking of entrances). The inspectors verified that locked HRAs were properly
secured and posted and that surrounding area dose rates met regulatory criteria. The
inspectors reviewed and observed controls used for ongoing work such as waste
transfer. The inspectors verified procedure adherence by observation, attendance at
briefings, and questioning radiation protection personnel and workers.
Radiation Worker/Radiation Protection Technician Performance and Radiation
Protection Technician Proficiency
The inspectors evaluated radiation protection technician performance and proficiency
relative to control of hazards and work activities, as applicable. In addition, the
inspectors reviewed issue reports to identify problems with worker or radiation protection
technician performance.
Problem Identification and Resolution
The inspectors selectively reviewed self-assessments and audits since the previous
inspection to determine if identified problems were entered into the corrective action
program for resolution. The inspectors evaluated the corrective action program
database for repetitive deficiencies or significant individual deficiencies to determine if
self-assessment activities were identifying and addressing the deficiencies.
The review included an evaluation of data to determine if any problems involved
performance indicator (PI) events with dose rates greater that 25 R/hr at 30 centimeters,
greater than 500 R/hr at 1 meter or unintended exposures greater than 100 millirem total
effective dose equivalent, 5 rem shallow dose equivalent, or 1.5 rem lens dose
equivalent. The inspectors also reviewed the corrective action database for non-PI
radiological incidents to determine if follow-up activities were being conducted in an
effective and timely manner consistent with radiological risk.
The inspectors reviewed selected issue reports since the last inspection which involved
potential radiation worker or radiation protection personnel errors to determine if there
was an observable pattern traceable to a similar cause. The review included an
evaluation of corrective actions, as appropriate. (Section 4OA2)
b. Findings
No findings of significance were identified.
2OS2 ALARA Planning and Controls (71121.02 - 2 samples)
a. Inspection Scope
Enclosure
13
The inspectors conducted the following activities to determine if AmerGen was properly
implementing operational, engineering, and administrative controls to maintain personnel
occupational radiation exposure as low as is reasonably achievable (ALARA).
Implementation of these controls was reviewed against the criteria contained in 10 CFR 20, applicable industry standards, and applicable AmerGen procedures.
Inspection Planning, Radiological Work Planning
The inspectors determined the plants current 3-year rolling average collective exposure.
The inspectors evaluated site specific trends in collective exposures (using NUREG-
0713 and plant historical data). The inspectors discussed proposed occupational
radiation exposure estimates for 2008.
Job Site Inspections and ALARA Controls
The inspectors observed ongoing work activities (e.g., radioactive waste handling) to
evaluate implementation of ALARA controls for the activities. The inspectors reviewed
exposures of individuals from selected work groups to identify significant exposure
variations which may exist among workers.
Verification of Dose Estimates and Exposure Tracking
The inspectors reviewed Station ALARA Committee and sub-committee meeting minutes
for the fall 2007 outage and post-outage to date. The inspectors compared aggregate
exposure sustained per work activity, with initial estimates, to evaluate effectiveness of
ALARA actions and accuracy of dose estimates. The inspectors compared results
achieved with the intended dose established for the work tasks reviewed.
Source-Term Reduction and Control
The inspectors reviewed and discussed AmerGens understanding of the Unit 1 plant
source-term, including knowledge of input mechanisms to reduce the source term, and
the source-term control strategy in place. The inspectors reviewed reactor coolant
chemistry data to evaluate the effectiveness of post shutdown source-term reduction
efforts including strategies employed such as system flushes, installation of temporary
shielding, and chemistry controls. The inspectors reviewed efforts to reduce Unit 1
reactor cavity and spent fuel pool radionuclide concentrations in support of ongoing work
activities.
Radiation Worker/Radiation Protection Technician Performance
The inspectors selectively observed radiation worker and radiation protection technician
performance in the area of ALARA practices during transfer of radioactive materials on
March 6, 2008. The inspectors selectively questioned workers and radiation protection
personnel in the field to evaluate their understanding of ambient radiological conditions.
The inspectors evaluated performance to determine whether the training/skill level was
sufficient with respect to the radiological hazards involved.
Problem Identification and Resolution
Enclosure
14
The inspectors selectively reviewed issue reports in this area since the last inspection to
determine if AmerGen was including ALARA deficiencies and issues in its corrective
action program. (See Section 4OA2)
The review included self-assessments, audits, and corrective action reports related to
the ALARA program since the last inspection to determine if the follow-up activities were
being conducted in an effective and timely manner commensurate with their importance
to safety and risk.
b. Findings
No findings of significance were identified.
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03 - 1 sample)
a. Inspection Scope
The inspectors reviewed selected activities and associated documentation in the below
listed areas. The evaluation of AmerGens performance in these areas was against
criteria contained in 10 CFR 20, applicable TSs, and applicable station procedures.
Self-Contained Breathing Apparatus
The inspectors reviewed the functional testing and inspection of self-contained breathing
apparatus (SCBA) to ensure equipment was being properly maintained and inspected in
accordance with the manufacturers recommendations and applicable regulatory
requirements. The functional testing of three SCBA units, ready for use in the Unit 1
Control Room, was reviewed (Kit Nos. 1, 2, 3). The inspectors also visually inspected
the SCBA kits and additional mask units. The components of the three kits were also
checked against approved component lists published by the SCBA manufacturer and the
National Institute for Occupational Safety and Health. The inspectors reviewed periodic
testing of the SCBA units components (i.e., hydro testing of tank, maintenance and
testing of regulators, low pressure alarms) and reviewed conformance of the SCBAs with
published certification lists.
Problem Identification and Resolution
The inspectors reviewed issue reports in this area since the last inspection to determine
if AmerGen was including instrument deficiencies and issues in its corrective action
program (Section 4OA2). The review included self-assessments, audits, and corrective
action reports.
b. Findings
No findings of significance were identified.
Cornerstone: Public Radiation Safety
2PS2 Radioactive Material Processing and Transportation (71122.02 - 1 sample)
a. Inspection Scope
Enclosure
15
The inspectors selectively reviewed the packaging and shipment preparation of a non-
exempt radioactive material shipment (RS-08-029-1). Matters reviewed included:
packaging and vehicle radiation dose rates; placarding of vehicle; completion of
applicable shipping papers; qualification of personnel overseeing and processing
shipment; emergency instructions; general truck and trailer condition; closure and use
requirements.
The inspectors also selectively reviewed training provided for station personnel relative
to 49 CFR 172, and NRC Bulletin 79 -19.
b. Findings
No findings of significance were identified.
4. OTHER ACTIVITIES
4OA1 Performance Indicator Verification (71151 - 3 samples)
a. Inspection Scope
Cornerstone: Initiating Events
The inspectors reviewed selected station records to verify NRC PIs had been accurately
reported to the NRC as specified in NEI 99-02, Regulatory Assessment Performance
Indicator Guideline, Rev. 5. The three PI samples listed below were verified for the
period January to December 2007.
$ Unplanned Scrams per 7000 Critical Hours
$ Unplanned Scrams with Complications
$ Unplanned Power Changes per 7000 Critical Hours
The inspectors reviewed operator logs, licensee event reports, monthly station operating
reports, corrective action program database documents, calculation methods, definition
of terms, and use of clarifying notes. The inspectors also verified accuracy of the
number of reported critical hours used in the calculations.
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems (71152)
.1 Review of Issue Reports and Cross-References to Problem Identification and Resolution
Issues Reviewed Elsewhere
The inspectors performed a daily screening of items entered into the licensees
corrective action program. This review was accomplished by reviewing a list of daily IRs,
reviewing selected IRs, attending daily screening meetings, and accessing the licensees
computerized corrective action program database.
.2 Annual Sample: Access Control Deficiencies
Enclosure
16
a. Inspection Scope (1 sample)
The inspectors reviewed AmerGen=s actions in response to issue reports generated as a
result of multiple issues associated with access control deficiencies. The inspectors also
reviewed AmerGens procedures on searching personnel and process facility operations.
In addition, the inspectors interviewed applicable members of AmerGens staff including
site security officers and a corporate security system engineer.
b. Findings
No findings of significance were identified. The inspectors reviewed issue reports
documenting issues related to four access control deficiencies identified in 2007. In
each case, the actions taken to address the issues were appropriate. The inspectors
verified that the site has provided adequate training and guidance on process facility
operations to the security staff.
.3 Problem Identification and Resolution for Radiological Protection Activities
a. Inspection Scope
The inspectors reviewed issue reports and self-assessments to determine if identified
problems were entered into the corrective action program for resolution. The inspectors
selectively reviewed the reports to evaluate AmerGens threshold for identifying,
evaluating, and resolving problems (Apparent Cause 698893, NOS Audit 07-4Q,). The
review included a check of possible repetitive issues, such as worker or technician errors
(Issue Nos. 706402, 706624, 707298, 707789, 712475, 715167, 722282, 723723,
726821, 727146, 7377511, 740021, 689317, 695488, 689423, 689435, 689562, 696907,
692640, 707288, 744382, and 745372).
This review was against criteria contained in 10 CFR 20, Technical Specifications, and
station procedures.
b. Findings
No findings of significance were identified.
4OA5 Other Activities
.1 Temporary Instruction 2515/166 - Pressurized Water Reactor Containment Sump
Blockage (NRC Generic Letter 2004-02)
a. Inspection Scope
The inspectors performed an inspection in accordance with Temporary Instruction (TI)
2515/166, Pressurized Water Reactor Containment Sump Blockage, Rev. 1. The TI was
developed to support the NRC review of licensee activities in response to NRC Generic
Letter (GL) 2004-02, Potential Impact of Debris Blockage on Emergency Sump
Recirculation at Pressurized Water Reactors. Specifically, the inspectors verified that
the implementation of the modifications and procedure changes was consistent with the
actions committed to in AmerGens supplemental response to GL 2004-02, dated
December 28, 2007. The supplemental response provided the remaining information
Enclosure
17
regarding the actions and methodologies used at TMI to resolve the issues in the GL,
which included the downstream effects and chemical effects analyses.
Additionally, the inspectors reviewed the TS and the UFSAR, to verify that required
changes to the TS had been approved by the NRC and that the UFSAR had been or
was in the process of being updated to reflect the plant changes. Portions of the TI were
performed during the 2007 refueling outage to verify the containment sump
modifications; the results of that inspection were documented in Inspection Report No.
b. Evaluation of Inspection Requirements
The TI requires the inspectors to evaluate and answer the following questions:
1. Did the licensee implement the plant modifications and procedure changes
committed to in their GL 2004-02 response?
The inspectors verified that AmerGen implemented the plant modifications and
procedure changes committed to in their GL 2004-02 responses. The inspection
performed in 2007 verified the implementation of the sump screen modifications
related to the GL. The inspectors verified that the modifications previously
installed met the assumptions of AmerGens completed analyses, which included
the chemical effects analysis. The inspectors reviewed changes to AmerGens
emergency operating procedures and verified that the procedures ensured the
assumptions described in the licensee supplemental response to the GL were
valid. Finally, the inspectors verified the modifications to address downstream
effects had been performed.
2. Has the licensee updated its licensing basis to reflect the corrective actions taken
in response to GL 2004-02?
The inspectors verified that AmerGen had either updated, or was in the process
of updating, the licensing basis to reflect the actions taken in response to GL 2004-02. Specifically, the inspectors verified that changes to the facility or
procedures as described in the UFSAR that were identified in the licensees GL 2004-02 responses were reviewed and documented in accordance with 10 CFR
50.59. The inspectors also verified that changes to the technical specifications
had been approved by the NRC, and that required changes to the UFSAR,
describing the changes to the plant, were in the process of being updated.
The inspection requirements of the Temporary Instruction are complete and the TI is
closed. The Office of Nuclear Reactor Regulation will perform a technical review of
AmerGens GL responses to ensure the licensee corrective actions adequately address
Generic Safety Issue 191, Assessment of Debris Accumulation on Pressurized Water
Reactor Sump Performance, and Generic Letter 2004-02. The NRC will document the
results of this review in a separate letter to AmerGen.
.2 Radiological Review of Steam Generator Replacement Transportation Plans (50001)
a. Inspection Scope
Enclosure
18
The inspectors selectively reviewed the preliminary plans for transport to, and storage of,
the replaced Unit 1 steam generators at the proposed storage facility. The inspectors
reviewed projected public dose calculations.
The review was against criteria contained in 10 CFR 20, site TSs, and the Offsite Dose
Calculation Manual.
b. Findings
No findings of significance were identified.
4OA6 Meetings, Including Exit
Exit Meeting Summary
On April 18, 2008, the resident inspectors presented the inspection results to Mr. Bill Noll
and other members of the TMI staff who acknowledged the findings. The regional
specialist inspection results were previously presented to members of AmerGen
management. The inspectors asked the licensee whether any of the material examined
during the inspection should be considered proprietary. No proprietary information was
identified.
ATTACHMENT: SUPPLEMENTAL INFORMATION
Enclosure
A-1
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
D. Atherholt Manager, Regulatory Assurance
C. Baker Manager, Chemistry
B. Carsky Director, Operations
T. Dougherty Plant Manager
E. Eilola Director, Site Engineering
R. Godwin Training
J. Heischman Director, Maintenance
W. Laudenbach System Engineer
A. Miller Regulatory Assurance
D. Mohre Manager, Security
P. Mussleman Security Supervisor
D. Neff Manager, Emergency Preparedness
W. Noll Site Vice President
T. Roberts Radiation Protection
D. Trostle Operations Security Analyst
L. Weir Manager, Nuclear Oversight Services
C. Wend Manager, Radiation Protection
R. West Vice President, TMI Unit 1
H. Yeldell Work Management
LIST OF ITEMS OPENED, CLOSED AND DISCUSSED
Opened & Closed
NRC TI 2515/166 Pressurized Water Reactor Containment Sump Blockage (NRC Generic
Letter 2004-02)
LIST OF DOCUMENTS REVIEWED
Section 1R04: Equipment Alignment
Procedures
1105-20, Remote Shutdown Systems, Rev. 14
1107-4, Electrical Distribution Panel Listing, Rev. 213
OP-TM-211-000, Makeup and Purification System, Rev. 16
OP-TM-212-000, Decay Heat Removal System, Rev. 11
OP-TM-214-000, Building Spray System, Rev. 8
OP-TM-533-000, Decay Heat River System, Rev. 9
OP-TM-541-000, Primary Component Cooling System, Rev. 6
OP-TM-543-000, Decay Heat Closed System, Rev. 7
Drawings
Dwg. 302-712, Reactor Building Spray, Rev. 49
Attachment
A-2
Section 1R011: Licensed Operator Requalification Program
Procedures
OP-TM-AOP-014, Loss of 1E 4160V Bus, Rev. 3
OP-TM-AOP-020, Loss of Station Power, Rev. 12
OP-TM-AOP-041, Loss of Seal Injection, Rev. 2
OP-TM-AOP-062, Inoperable Rod, Rev. 1
OP-TM-EOP-001, Reactor Trip, Rev. 9
OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5
OP-TM-EOP-009, HPI Cooling - Recovery from Solid Operations, Rev. 5
EP-AA-1009, Radiological Emergency Plan Annex for TMI Station, Rev. 10
Section 1R012: Maintenance Rule
Procedures
Alarm Response Procedure MAP NN-1-8, Main Annunciator Panel NN, Rev.4
Alarm Response Procedure, HM, Hydrogen Monitor Pane, Rev. 0
1105-18, Containment Hydrogen Monitor, Rev. 12
1104-62, Hydrogen Recombiner, Rev. 22
OP-TM-EOP-008, LOCA Cooldown, Rev. 6
IC-252, Channel Test of Reactor building Post LOCA Hydrogen Monitor, Rev. 0
IC-253, Reactor Building Post-LOCA Hydrogen Monitoring Calibration, Rev. 1
Other Documents
IR-736664, Response to NRC Question On Hydrogen Recombiners And Monitoring System
System Health Report, Containment hydrogen Monitoring, dated December 2007
Section 1EP6: Drill Evaluation
Procedures
1202-33, High Winds, Rev. 28
EP-AA-111, Emergency Classification and Protective Action Recommendations, Rev. 13
EP-AA-1009, Radiological Emergency Plan Annex for TMI Station, Rev. 10
OP-TM-EOP-001, Reactor Trip, Rev. 9
OP-TM-EOP-003, Excessive Primary to Secondary Heat Transfer, Rev. 5
OP-TM-EOP-004, Lack of Primary to Secondary Heat Transfer, Rev. 5
OP-TM-EOP-010, Abnormal Transients Guides, Rules, and Graphs, Rev. 9
Other Documents
Licensed Operator Drill Scenario No. 51, Low System Grid voltage, High Winds,
Generator/Turbine Trip, ATWS, Stem Leak in Containment Causing Excessive Primary to
Secondary Heat Transfer, Rev. 1
Section 2OS1, 2OS2, 2OS3, 2PS2: Occupational and Public Radiation Safety
Procedures
RP-TM-503-1001, Rev. 1, Volumetric Material Controls
RP-TM-460-1007, Rev. 5, Access to TMI -1 Reactor Building
RP-AA-400, Rev. 4, ALARA Program
RP-TM-605-1001, Rev. 1, TMI Waste Characterization
RP-TM-850, Rev. 0, Radiation Protection Emergency Equipment Readiness.
6610-OPS-4510.03, Rev. 2, Inspection and Maintenance of Respiratory Equipment
Other Documents
TMI Radiological Protection T1R17 Refueling Outage Report 2007
Primary Water Chemistry Sampling Results
Attachment
A-3
Fuel Transfer Tube Radiation Surveys November 2005
Self-contained Breathing Apparatus Vendor Manual
Section 4OA2: Problem Identification & Resolution
Issue Reports
00565138, Improper Verification of Protected Area Badge
00670299, Security Explosive Detector Failed to Alarm During Testing
00652352, Access Not Verified Prior to P/A Entry Through MAF
00685064, Access Not Verified Prior to P/A Entry MAF
00699966, Improper Response to Explosive Detector Alarm
Procedures
SY-AA-101-112, Searching Personnel, Vehicles, Packages and Cargo, Rev. 12
SY-TM-1005, Processing Center Operations, Rev. 11
Other Documents
VM-TM-0946, Entry Scan Explosives Detector Model 85, Rev. 4
NRC Generic Letter 91-10, Explosives Searches at Protected Area Portals, July 8, 1991
Section 4OA5: Other
Procedures
OP-TM-214-901, RB Spray Operation, Rev. 3
OP-TM-EOP-010, Emergency Procedures Rules, Guides and Graphs, Rev. 9
Other Documents
C-1101-210-E610-011, LPI BS Pump NPSH Margin Available from the RB Sump Following a
LBLOCA, Rev. 7
ECTM005-CALC-05, Hydraulic Analyses of the Reactor Building Recirculation Sump Strainer,
Rev. 3
Inspection Report 05000289/2007005, Three Mile Island Station, Unit 1 - NRC Integrated
Inspection Report
NRC Docket No. 50-289, Technical Specification Change Request No. 337 - Reactor Building
Emergency Sump pH control System Buffer Change
PC 22736, Ops Procedures due to RB Sump Mod per ECR-06-0207, 06-0205 &
06-0206
PC 24164, EOP/EP Revisions for TSP Mod (ECR-07-00174) and GL 2004-02
Three Mile Island Unit 1 Supplemental Response to NRC Generic Letter 2004-02, Potential
Impact of Debris Blockage on Emergency Recirculation during Design Basis Accidents at
Pressurized-Water Reactors, dated December 28, 2007
TM 06-00256-000, Replace DH-V-19A/B Internals
TM-07-00743-000, Generic Letter 2004-02/GSI-191 Supplemental Response
Attachment
A-4
LIST OF ACRONYMS
ADAMS Agencywide Documents and Management System
ALARA As Low As is Reasonably Achievable
AmerGen AmerGen Energy Company, LLC
AR Action Request
CFR Code of Federal Regulations
DRP Division of Reactor Projects
ECR Engineering Change Request
ESAS Engineered Safeguards and Actuation System
GL Generic Letter
IMC Inspection Manual Chapter
IR Issue Report
LOCA Loss of Coolant Accident
LPI Low Pressure Injection
MAF Main Access Facility
MR Maintenance Rule
NCV Non-Cited Violation
NEI Nuclear Energy Institute
NRC Nuclear Regulatory Commission
NUMARC Nuclear Management and Resources Council
P/A Protected Area
PADEP Pennsylvania Department of Environmental Protection
PARS Publicly Available Records
PI Performance Indicator
PMT Post-Maintenance Test
SCBA Self Contained Breathing Apparatus
SSC Structures, Systems, and Components
TI Temporary Instruction
TMI Three Mile Island, Unit 1
TS Technical Specifications
UE Unusual Event
UFSAR Updated Final Safety Analysis Report
Attachment