IR 05000320/2018011

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NRC Inspection Report 05000320/2018011
ML18144A397
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 05/23/2018
From: Racquel Powell
Decommissioning Branch I
To: Halnon G
GPU Nuclear
References
IR 2018011
Download: ML18144A397 (10)


Text

UNITED STATES May 23, 2018

SUBJECT:

GPU NUCLEAR, INC., THREE MILE ISLAND STATION, UNIT 2 - NRC INSPECTION REPORT 05000320/2018011

Dear Mr. Halnon:

On March 26-29, 2018, the U.S. Nuclear Regulatory Commission (NRC) conducted an onsite inspection at the Three Mile Island Station Unit 2 (TMI-2). The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations, and the conditions of your license. The inspection consisted of observations by the inspectors, interviews with personnel, and a review of procedures and records. The results of the inspection were discussed with M. Casey, TMI-2 Project Manager, GPU Nuclear Inc., and E. Callan, Site Vice President, Exelon Generating Company (Exelon),

and other members of Exelon management and staff on March 29, 2018, at the conclusion of the onsite inspection and are described in the enclosed report. No findings of safety significance were identified.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.

Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Katherine Warner (610-337-5389) if you have any questions regarding this matter.

Sincerely,

/RA/

Raymond Powell, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Nuclear Materials Safety Enclosure: Inspection Report No. 05000320/2018011 cc w/encl: Distribution via ListServ

EXECUTIVE SUMMARY

GPU Nuclear, Inc. (GPUN)

Three Mile Island Station, Unit 2 (TMI-2)

NRC Inspection Report No. 05000320/2018011 A routine announced safety inspection was conducted on March 26-29, 2018 at TMI-2.

The inspectors reviewed TMI-2s Post-Defueling Monitored Storage (PDMS) activities related to the safe storage of radioactive material, including site operations, engineering, maintenance, plant support activities, management oversight, and corrective action program (CAP) implementation. The inspection consisted of observations by the inspectors, interviews with the FirstEnergy Corporation/GPUN (FirstEnergy/GPUN) and Exelon personnel, a review of procedures and records, and plant walk-downs. There are currently no ongoing decommissioning activities being conducted at TMI-2. The NRC's program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, "Decommissioning Power Reactor Inspection Program."

Based on the results of this inspection, no findings of safety significance were identified.

REPORT DETAILS

1.0 Background GPUN retains the license for TMI-2 and maintains the facility. GPUN is a wholly-owned subsidiary of FirstEnergy. As part of the sale of TMI-2, GPUN entered into an agreement with AmerGen (now Exelon) to conduct services for TMI-2. Under this agreement, Exelon provides all services, materials, and equipment required to maintain TMI-2 in PDMS status. Services provided by Exelon include maintenance, surveillance testing, and implementation of the activities required in the Safety Analysis Report (SAR), Technical Specification (TS), and the GPUN PDMS Quality Assurance (QA)

Plan.

In December 1993, TMI-2 received a possession-only license from the NRC to enter PDMS. Currently, TMI-2 is in long-term monitored storage. In June 2013, GPUN submitted to the NRC a Post-Shutdown Decommissioning Activities Report (PSDAR)

(ADAMS No. ML13190A366) pursuant to 10 Code of Federal Regulations (CFR)50.82(a)(4). GPUN submitted Revision 1 of their PSDAR in November 2013 (ADAMS No. ML13323A497) and Revision 2 in December 2015 (ML15338A222).

The NRC's program for overseeing the safe operation of a shut-down nuclear power reactor is described in IMC 2561.

2.0 Post-Defueling Monitored Storage Performance and Status Review

a. Inspection Scope

[Inspection Procedures (IPs) 36801, 37801, 40801, 62801, 64704, 71801, 83750, 84750, 86750 A routine announced safety inspection was conducted on March 26-29, 2018 at TMI-2.

The inspection consisted of observations by the inspectors, interviews with FirstEnergy/GPUN and Exelon personnel, a review of procedures and records, and plant walk-downs. The inspectors reviewed the PDMS program as outlined in the PDMS SAR, TS, and PSDAR. The inspectors reviewed PDMS activities related to the safe storage of radioactive material, including site operations, engineering, maintenance, plant support activities, management oversight, material control and accountability, and CAP implementation. The inspectors also assessed the material condition of TMI-2 facilities during plant tours of the reactor building, auxiliary building, radioactive waste building, and fuel handling building.

The inspectors reviewed activities, components, and documentation associated with the following PDMS programs: occupational exposure, fire protection, radioactive effluent control, and site radiological environmental monitoring program (REMP). The inspectors reviewed the offsite dose calculation manual, the radioactive gaseous effluent release permits, the annual REMP report, the groundwater monitoring program, and the annual effluent report, which included a summary of the radioactive waste management and transportation programs.

The inspectors reviewed QA audit documents and CAP reports associated with TMI-2 to determine if issues were being appropriately identified, assessed, and reviewed and that corrective actions were being appropriately implemented.

b. Observations and Findings

The inspectors confirmed that no design changes or plant modifications, as well as no dismantlement or decommissioning activities were performed since the previous inspection. The next reactor building survey will be in 2019. The inspectors confirmed that all required reporting submittals were completed in accordance with TS requirements. The inspectors verified that the maintenance and surveillance program for systems and components had been conducted in accordance with the TS requirements and established procedures. During plant walk-downs the inspectors did not observe any significant water intrusion into buildings and noted that the material condition of structures and components appeared unchanged since the previous inspection.

The annual radiological effluent and REMP reports and supporting analyses demonstrated that all calculated doses were well below regulatory dose criteria of 10 CFR 50, Appendix I. The inspectors noted that one radioactive waste shipment from TMI-2 was shipped offsite during calendar year 2017.

The inspectors determined that scheduled QA audits and self-assessments were conducted timely, and findings or issues identified by these reviews were entered into the stations CAP as Action Reports (AR). Based on the review of ARs, the inspectors noted that required corrective actions were being appropriately and timely implemented.

c. Conclusions

Based on the results of this inspection, no findings of safety significance were identified.

3.0

Exit Meeting Summary

On March 29, 2018, the inspectors debriefed the inspection results to M. Casey, TMI-2 Project Manager, GPU Nuclear Inc., and E. Callan, Site Vice President, Exelon and other members of Exelon management and staff. During that discussion your staff requested to provide additional information for consideration. In-office review of the additional information continued by the NRC, and a telephonic exit meeting was conducted on May 15, 2018, with M. Casey, TMI-2 Project Manager, GPU Nuclear Inc.,

and E. Callan, Site Vice President, Exelon and other members of your staff. The inspectors confirmed that no proprietary information was retained by the inspectors or documented in this report.

PARTIAL LIST OF PERSONS CONTACTED Licensee J. Boyd, TMI-2 Consultant, FirstEnergy D. Brookhart, OCDM Chemist, Exelon E. Callan, Site Vice President, Exelon M. Casey, GPUN TMI-2 Project Manager, FirstEnergy M. Fitzwater, Regulatory Assurance, Exelon J. Goldman, Regulatory Assurance Manager, Exelon E. Hertkorn, PDMS Supervisor, Exelon Generation Company, LLC G. McCarty, Radiation Protection Manager, Exelon R. Myers, Fire Marshal, Exelon J. Shrum, Radiation Protection Supervisor, Exelon J. Sinopoli, Fire Protection Program Engineer, Exelon G. Wright, PDMS Manager, Work Manager, Exelon ITEMS OPEN, CLOSED, AND DISCUSSED None LIST OF

DOCUMENTS REVIEWED

ARs

04034986 04072921 0403032

04070262 04072962 04072947

04072958 04069518 04097965

04072952 04018629 04087083

04035877 04023509 04060047

04027955 04065562 04123534

2444987 04027138 04125083

04082433 04019448

04072059 04072911

04070624 04072530

2301-4.7D, TMI-2 Sampling and Analysis of the Reactor Building Breather System, Revision

2303-11.20A, Operability Check of the TMI-2 Equipment Hatch Personnel Airlock Doors,

Revision 5

2303-11.20B, Operability Check of the TMI-2 Ante Room Personnel Airlock Doors, Revision 5

2303-11.20A, Operability Check of the TMI-2 Equipment Hatch Personnel Airlock Doors,

Revision 6

2303-11.20B, Operability Check of the TMI-2 Ante Room Personnel Airlock Doors, Revision 6

2303-11.20A, Operability Check of the TMI-2 Equipment Hatch Personnel Airlock Doors,

Revision 6A

2303-11.20B, Operability Check of the TMI-2 Ante Room Personnel Airlock Doors, Revision

6A

990-3017, Three Mile Island Unit No. 2 Fire Protection Program Evaluation, Revision 11

LIST OF DOCUMENTS REVIEWED (Contd)

AP-1038, TMI - Unit 1 Administrative Procedure, Revision 84 (Administrative Controls - Fire

Protection Program)

Combined 2016 Annual Radioactive Effluent Release Report, dated April 28, 2017

NOSA-TMI-17-12, TMI-2 Post Defueling Monitored Storage (PDMS) Audit Report, dated

November 17, 2017

Nuclear Electric Insurance Limited Property Loss Control Comprehensive Evaluation Report,

dated March 2017

OP-AA-201-001, Fire Marshal Tours, Revision 6

Post-Defueling Monitored Storage Safety Analysis Report, dated August 24, 2017

Post-Shutdown Decommissioning Activities Report, Revision 2, dated December 2015

Radiation Work Permit TM-2-18-00201, Revision 01

Radiation Work Permit TM-2-18-00202, Revision 01

Radiation Work Permit TM-2-18-00203, Revision 00

Radiation Work Permit TM-2-18-00204, Revision 00

Radiation Work Permit TM-2-18-00205, Revision 00

Radiation Work Permit TM-2-18-00209, Revision 00

RP-AA-401, Operational ALARA Planning and Controls, Revision 22

RS-17-060-II, Uniform Low-Level Radioactive Waste Manifest, dated July 6, 2017

RS-17-165-II, Uniform Low-Level Radioactive Waste Manifest, dated December 4, 2017

Survey TMI-M-20180119-6

Survey TMI-M-20180126-5

Survey TMI-M-20180126-8

Survey TMI-M-20180126-11

Technical Specifications for PDMS - Amendment 63 for License 50-320 issued May 1, 2009

TMI-17-040, 2016 Annual Radiological Environmental Operating Report, dated April 28, 2017

TMI-C-17-04-28, TMI-2 Post-Defueling Monitored Storage (PDMS) QA Activity Audit, dated April

2017

TMI-17-S-0053

TMI-17-S-0030

TMI-17-S-0013

TMI-15-S-0147

TMI-17-S-0101

TMI-17-S-0097

TMI-17-S-0042

TMI-17-S-0117

Work Orders

R2244705 R2231910 R2209213

R2242156 R2240495 R2235926

R2257601 R2088105 R2209213

R2231909 R2235927

R2242561 R2088104

LIST OF ACRONYMS USED

AR Action Report

CAP Corrective Action Program

CFR Code of Federal Regulations

Exelon Exelon Generating Company

FirstEnergy FirstEnergy Corp.

GPUN GPU Nuclear, Inc.

IMC Inspection Manual Chapter

IP Inspection Procedure

NRC Nuclear Regulatory Commission

PDMS Post-Defueling Monitored Storage

PSDAR Post-Shutdown Decommissioning Activities Report

QA Quality Assurance

REMP Radiological Environmental Monitoring Program

SAR Safety Analysis Report

TMI-2 Three Mile Island Station, Unit 2

TS Technical Specifications

Attachment