IR 05000219/2006002

IR 05000219-06-002 on 01/01/06 - 03/31/06 for Amergen Energy Company, LLC; Oyster Creek Generating Station; Maintenance Effectiveness, Refueling and Other Outage Activities, and Access Control to Radiologically Significant Areas

ML061280428
Person / Time
Site:	Oyster Creek
Issue date:	05/04/2006
From:	Bellamy R NRC/RGN-I/DRP/PB7
To:	Crane C AmerGen Energy Co
Bellamy R Rgn-I/DRP/Br7/610-337-5200
References
IR-06-002
Download: ML061280428 (41)

Text

SUBJECT:

OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2006002

Dear Mr. Crane:

On March 31, 2006, the US Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Generating Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on April 7, 2006, with Mr. Swenson 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.

The report documents one NRC-identified finding and three self-revealing findings of very low safety significance (Green). Three of these findings were determined to involve a violation of NRC requirements. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these three findings as non-cited violations (NCVs) consistent with Section VI.A of the NRCs Enforcement Policy. If you contest these NCVs, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Oyster Creek Generating Station.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (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 7 Division of Reactor Projects Docket No. 50-219 License No. DPR-16 Enclosure: Inspection Report 05000219/2006002 w/Attachment: Supplemental Information cc w/encl:

Chief Operating Officer, AmerGen Site Vice President, Oyster Creek Nuclear Generating Station, AmerGen Plant Manager, Oyster Creek Generating Station, AmerGen Regulatory Assurance Manager, Oyster Creek, AmerGen Senior Vice President - Nuclear Services, AmerGen Vice President - Mid-Atlantic Operations, AmerGen Vice President - Operations Support, AmerGen Vice President - Licensing and Regulatory Affairs, AmerGen Director Licensing, AmerGen Manager Licensing - Oyster Creek, AmerGen Vice President, General Counsel and Secretary, AmerGen T. O'Neill, Associate General Counsel, Exelon Generation Company J. Fewell, Assistant General Counsel, Exelon Nuclear Correspondence Control Desk, AmerGen J. Matthews, Esquire, Morgan, Lewis & Bockius LLP Mayor of Lacey Township K. Tosch, Chief, Bureau of Nuclear Engineering, NJ Dept of Environmental Protection R. Shadis, New England Coalition Staff N. Cohen, Coordinator - Unplug Salem Campaign W. Costanzo, Technical Advisor - Jersey Shore Nuclear Watch E. Gbur, Chairwoman - Jersey Shore Nuclear Watch E. Zobian, Coordinator - Jersey Shore Anti Nuclear Alliance P. Baldauf, Assistant Director, Radiation Protection and Release Prevention, State of New Jersey

SUMMARY OF FINDINGS

IR 05000219/2006002; 01/01/06 - 03/31/06; AmerGen Energy Company, LLC, Oyster Creek

Generating Station; Maintenance Effectiveness, Refueling and Other Outage Activities, and Access Control to Radiologically Significant Areas.

The report covered a 3-month period of inspection by resident inspectors, regional inspectors, an announced inspection by a regional senior radiation specialist, and in-office inspection by a regional emergency preparedness inspector. Three Green non-cited violation (NCV) and one Green finding were identified. The significance of most findings are indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649,

"Reactor Oversight Process," Revision 3, dated July 2000.

Cornerstone: Initiating Events

Green.

A self-revealing finding was identified regarding untimely corrective actions when packing on the A feedwater regulating valve failed on February 10, 2006, and resulted in an upset of plant stability. This finding was determined not to be a violation of NRC requirements. AmerGens corrective actions involved repairing the valve and replacing the packing.

This finding was more than minor because it was associated with the equipment performance attribute of the initiating events cornerstone and affected the cornerstone objective to limit the likelihood of those events that challenge plant stability during power operation. In accordance with IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Operations, the inspectors conducted a Phase 1 SDP screening and determined the finding to be of very low safety significance (Green). The finding was of very low safety significance because the issue does not contribute to both the likelihood of a reactor trip and unavailability of mitigating equipment. The performance deficiency had a problem identification and resolution cross-cutting aspect. (Section 1R12)

Cornerstone: Mitigating Systems

Green.

A self-revealing finding was identified regarding inadequate procedure quality when the D emergency service water (ESW) pump did not start on December 19, 2005. A preventive maintenance procedure was not adequate to identify a degraded condition associated with a contact in the pumps circuit breaker prior to placing the breaker in service. This finding was determined to be a non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings. AmerGens corrective actions included revising the procedure to ensure that resistance checks are performed on the contacts which could impact proper operation of the ESW pump breakers.

iii

The finding was more than minor because it was associated with the procedure quality attribute of the mitigating systems cornerstone and affected the objective to maintain the reliability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, the inspectors conducted a Phase I SDP screening and determined the finding to be of very low safety significance (Green). The finding was of very low safety significance because the issue was not a design or qualification deficiency that resulted in a loss of function, did not result in an actual loss of safety function for a single train of equipment for greater than allowed by technical specifications, did not result in an actual loss of safety function of non-technical specification equipment considered risk significant in the maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and was not screened as potentially risk significant from external events. The performance deficiency had a human performance cross-cutting aspect. (Section 1R12)

Cornerstone: Occupational Radiation Safety

Green.

The inspectors identified that AmerGen did not properly implement administrative controls for locked high radiation area (HRA) access keys maintained under the control of operations personnel. This finding was determined to be a non-cited violation of technical specification 6.13.2, High Radiation Area. As of the end of this inspection period, AmerGen was determining the appropriate corrective actions for this issue.

The finding was more than minor because it was associated with the program and process attribute of the occupational radiation safety cornerstone and affected the objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The finding was evaluated using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, because it was an exposure control issue. The inspectors determined the finding to be of very low safety significance (Green) because it did not involve an As Low As Reasonably Achievable (ALARA) finding, it did not involve an overexposure, there was no substantial potential for an overexposure, and the ability to assess dose was not compromised. The performance deficiency had a problem identification and resolution cross-cutting aspect.

(Section 2OS1)

Cornerstone: Public Radiation Safety

Green.

A self-revealing finding was identified regarding inadequate procedure adherence when work activities on the main condenser during a forced maintenance outage resulted in an unauthorized, unmonitored effluent discharge to the environment between January 31 and February 2, 2006. This finding was determined to be a non-cited violation of technical specification 6.8.1a, Procedures and Programs. As of the end of this inspection period, AmerGen was determining the appropriate corrective actions for this issue.

iv

The finding was more than minor because it was associated with the program and process attribute of the public radiation safety cornerstone and affected the objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. This finding was evaluated using IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process, because it was a radioactive effluent release program issue. The inspectors determined the finding to be of very low safety significance (Green) because AmerGen was able to assess the dose from the release of the radioactive effluent and the radiological release associated with the event was not greater than 10 CFR 50 Appendix I, Numerical Guides for Design Objectives for Operation to Meet the Criterion As Low As Is Reasonably Achievable for Radioactive Material in Light -Water-Cooled Nuclear Power Reactor Effluents or 10 CFR 20.1301(d), Dose Limits for Individual Members of the Public, regulatory limits. The performance deficiency had a human performance cross-cutting aspect. (Section 1R20)

Licensee-Identified Violations

None.

v

REPORT DETAILS

Summary of Plant Status

The Oyster Creek Generating Station (Oyster Creek) began the inspection period operating at full power.

On January 25, 2006, operators performed an unplanned downpower to approximately fifty-three

(53) percent in accordance with abnormal procedures due to a trip of the B reactor recirculation pump when the A reactor recirculation pump was out-of-service.

On January 28, 2006, operators commenced a planned shutdown to investigate the cause of the B reactor recirculation pump trip. Oyster Creek was placed in cold shutdown on January 29, 2006. AmerGen personnel entered the drywell to investigate the cause of the B reactor recirculation pump trip and identified a failed pump motor. AmerGen replaced the B reactor recirculation pump motor with a refurbished spare, replaced the A reactor recirculation pump seal, and repaired a tube leak on the 1C-3 high pressure feedwater heater during the outage. Prior to startup an oil leak was identified on the B reactor recirculation pump motor. AmerGen personnel were unable to repair the motor and the B reactor recirculation pump was tagged out-of-service. Operators started the plant with four operable reactor recirculation pumps; established the reactor critical on February 4, 2006 and synchronized the main generator to the grid on February 5, 2006. During the startup, operators were unable to start the A feedwater pump and in accordance with operating procedures operators maintained power at 70% until repairs were completed on the A feedwater pump ground sensing circuit. The plant reached full power on February 8, 2006.

On February 10, 2006, operators performed an unplanned downpower to seventy

(70) percent in accordance with operating procedures after identifying a significant packing leak on the A feedwater pump regulating valve. Operators removed the A feedwater string from service and maintenance personnel replaced the packing on the valve. The plant returned to full power on February 12, 2006.

On February 26, 2006, Oyster Creek experienced an unplanned reactor power excursion to approximately one hundred and one (101) percent due to a failure of the speed controller for the D reactor recirculation pump motor generator. Operators immediately reduced reactor power below 100 percent by lowering the speed on the A, C and E reactor recirculation pumps with the master flow controller. The speed controller for the D reactor recirculation pump was locked in place in accordance with operating procedures. Oyster Creek implemented a temporary standing order which directed operations to take manual-local control of the motor generator to reduce pump speed when a power reduction is necessary. The D reactor recirculation pump motor generator is scheduled to be repaired during Oyster Creeks next refueling outage.

On March 12, 2006, while operators were performing control rod exercising in accordance with technical specification 4.2.D, Reactivity Control, control rod 06-43 was given a withdraw signal, but inserted. In accordance with abnormal and operating procedures, operators returned control rod 06-43 to its proper position. Oyster Creek personnel performed troubleshooting and minor maintenance on the reactor manual control system because it was determined to be the cause of the problem. On March 13, 2006, operators resumed control rod exercising, however control rod 06-35 responded in a similar manner as control rod 06-43.

Oyster Creek personnel performed additional troubleshooting and identified a problem with the reactor manual control system timer sequencer. In order to complete the technical specification surveillance test within its specified time period, AmerGen revised the surveillance test procedure to allow operators to insert all one hundred and thirty seven (137) control rods one notch to verify operability of the control rods and complete the surveillance test. Performing the surveillance test in this manner resulted in an unplanned power reduction to approximately ninety-three

(93) percent power. After successful completion of the surveillance test, maintenance personnel replaced the timer sequencer for the reactor manual control system, and operators withdrew all control rods to their normal position. Oyster Creek returned to full power on March 14, 2006.

On March 26, 2006, while operators were performing control rod exercising in accordance with technical specification 4.2.D, Reactivity Control, control rod 38-41 was given an insert signal, but withdrew. In accordance with abnormal and operating procedures operators returned control rod 38-41 to its proper position. The unexpected control rod response caused a power excursion to approximately one hundred and two (102) percent for a two minute period. The remainder of the control rod exercising was performed by using the revised surveillance test procedure developed by AmerGen during a similar issue on March 12, 2006 when control rods were given a withdraw signal, but inserted. Oyster Creek personnel performed additional troubleshooting and identified a problem with the reactor manual control logic circuitry.

On March 29, 2006, operators performed an unplanned downpower to sixty

(60) percent in accordance with operating procedures to repair a leak on the C reactor feedpump casing drain line. AmerGen personnel were monitoring the leak since February 19, 2006 when the leak was first identified. On March 28, 2006, leakage increased and AmerGen management directed operations personnel to remove the C reactor feedpump from service to perform repairs.

Maintenance personnel removed a portion of the drain line and installed a cap. The plant returned to full power on March 30, 2006.

Oyster Creek operated at full power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a.

Inspection Scope (1 sample)

The inspectors reviewed AmerGens response to one site specific weather-related condition. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

The inspectors reviewed AmerGens response to winter storm conditions which involved cold temperatures, high winds, and heavy rain on January 18, 2006. Operators entered abnormal procedures ABN-31, High Winds, and ABN-32, Abnormal Intake Level during the adverse weather condition due to high winds and low levels in the intake canal. The inspectors verified that procedures were properly implemented and that actions taken were appropriate for the weather conditions. Additionally, during the storm, the inspectors performed a walkdown of the intake structure (including the ESW and service water pumps) and other outdoor safety system equipment (including standby gas treatment (SBGT) fans) to verify that any issues noted were appropriately identified and dispositioned by AmerGen.

b. Findings

No findings of significance were identified.

1R04 Equipment Alignment

a. Inspection Scope

(4 samples)

The inspectors performed three partial and one complete equipment alignment inspections. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

Partial System Walkdown. The inspectors performed three partial equipment alignment inspections. The partial alignment inspections were completed during conditions when the equipment was of increased safety significance such as would occur when redundant equipment was unavailable during maintenance or adverse conditions; or after equipment was recently returned to service after maintenance. The inspectors performed a partial walkdown of the following systems, and when applicable, the associated electrical distribution components and control room panels, to verify the equipment was aligned to perform its intended safety functions:

• B isolation condenser on January 10, 2006;

• 1' emergency diesel generator (EDG) on January 24, 2006; and

• Diesel driven fire pump fuel oil transfer system on March 6, 2006.

Complete System Walkdown. The inspectors performed a complete system alignment inspection on the reactor building closed cooling water (RBCCW) system to determine whether the system was aligned and capable of providing cooling water in accordance with design basis requirements. The inspectors reviewed operating procedures, surveillance test procedures, pipe and instrument drawings, and applicable equipment lineup lists to determine if the equipment was aligned to perform its design function upon actuation. The inspectors also performed a walkdown of the system to assess material condition and operational performance.

b. Findings

No findings of significance were identified.

1R05 Fire Protection

a. Inspection Scope

(9 samples)

The inspectors performed a walkdown of nine plant areas to assess their vulnerability to fire. During plant walkdowns, the inspectors observed combustible material control, fire detection and suppression equipment availability, visible fire barrier configuration, and the adequacy of compensatory measures (when applicable). The inspectors reviewed Oyster Creeks Fire Hazards Analysis Report and Individual Plant Examination for External Events (IPEEE) for risk insights and design features credited in these areas.

Additionally, the inspectors reviewed corrective action program condition reports documenting fire protection deficiencies to verify that identified problems were being evaluated and corrected. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. The following plant areas were inspected:

C Standby liquid control (SLC) area on January 5, 2006; C 1 EDG on January 9, 2006; C 2 EDG on January 9, 2006; C EDG fuel oil storage tank room on January 10, 2006; C RBCCW heat exchanger area on January 17, 2006; C Shutdown cooling (SDC) pump room on January 30, 2006; C Diesel driven fire pump house on February 28, 2006; C A/B 125 volt battery room on March 1, 2006; and C A 480 Volt safety related breaker room on March 2, 2006.

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

(1 sample)

The inspectors performed one internal flood protection inspection activity in the reactor feedwater pump room located in the turbine building. The inspectors performed a walkdown of the flood barriers, floor drains, and floor sumps. The inspectors evaluated these items to determine if internal flood vulnerabilities existed and to assess the physical condition of the equipment and components in the reactor feed pump room.

The inspectors also reviewed AmerGens procedures related to flooding of the reactor feed pump room. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified

1R07 Heat Sink Performance

a. Inspection Scope

(1 sample)

The inspectors verified acceptable heat exchanger performance by reviewing the results of one heat exchanger maintenance activity. The inspectors observed AmerGens inspection and cleaning activities associated with the 1-1' RBCCW heat exchanger on March 6, 2006. The inspectors assessed the state of cleanliness and material condition of the heat exchanger by verifying the extent of corrosion, fouling and silting within the heat exchanger. After maintenance was complete, the inspectors performed a walk down of the 1-1' RBCCW heat exchanger and reviewed its operational data (flow, temperatures, and pressures) to assess the effectiveness of the cleaning activities.

Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

1R11 Licensed Operator Requalification Program

a. Inspection Scope

(1 sample)

The inspectors observed one simulator training scenario on February 13, 2006, to assess operator performance and training effectiveness. The scenario involved a partial loss of reactor water level indication which resulted in a half scram, a stuck open electromagnetic relief valve (EMRV), and an anticipated transient without scram (ATWS)event. The inspectors assessed whether the simulator adequately reflected the plants response, operator performance met AmerGen procedural requirements, and the simulator instructors critique identified crew performance problems. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

(3 samples)

The inspectors performed three maintenance effectiveness inspection activities. The inspectors reviewed AmerGens performance monitoring of the control rod drive (CRD)system to determine whether AmerGen was adequately monitoring equipment performance in accordance with the Maintenance Rule to ensure that maintenance was effective. The inspectors also reviewed the following degraded component issues in order to assess the effectiveness of maintenance by AmerGen:

• Containment spray system #1flow circuit failure on January 21, 2006 (IR 444410); and

• A feedwater regulating valve packing leak on February 10, 2006 (IR 452708).

The inspectors verified that the systems or components were monitored in accordance with AmerGens maintenance rule program requirements. The inspectors compared documented functional failure determinations and unavailable hours to those being tracked by AmerGen to evaluate the effectiveness of AmerGens monitoring activities and determine whether performance goals were being met. The inspectors reviewed completed maintenance work orders and procedures to determine if inadequate maintenance contributed to equipment performance issues. The inspectors reviewed applicable work orders, corrective action program condition reports, preventive maintenance tasks, vendor manuals, and system health reports. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

Additionally, the inspectors completed their review of AmerGens apparent cause evaluation (IR 435168) associated with the failure of the D ESW pump to start on December 19, 2005. This issue was identified as an unresolved item (URI)

===05000219/2005005-02 in NRC Inspection Report 05000219/2005005, dated January 25, 2006. The inspectors reviewed AmerGens evaluation and the maintenance history on the D ESW pump and its associated 4160 Volt breaker.

b. Findings

Containment Spray System 1' Flow Instrumentation Failure An URI was identified to review AmerGens corrective action program evaluation (IR 444410) regarding the failure of the containment spray system 1' flow instrumentation on January 21, 2006. The inspectors plan to review this evaluation after it is completed, which had not occurred by the end of this inspection period.

(URI 05000219/2006002-01, Containment Spray System #1 Flow Instrumentation Failure)

A Feedwater Regulating Valve Packing Leak

Introduction.

A self-revealing finding was identified regarding untimely corrective actions when packing on the A feedwater regulating valve failed on February 10, 2006, and resulted in an upset of plant stability. The finding was determined not to be a violation of NRC requirements.

Description.

On February 10, 2006, the plant performed an unscheduled downpower to less than seventy

(70) percent reactor power to correct a packing leak on the A feedwater regulating valve. The packing leak was identified on February 5, 2005, and was left uncorrected until February 10, 2006, when a four

(4) foot steam plume (approximately three

(3) gallon per minute leak) from the A feedwater regulating valve was identified by an operator during turbine building rounds. Operators commenced a downpower in accordance with plant operating procedures to support isolation of the A feedwater piping, in order for maintenance personnel to repack the valve. Oyster Creek returned to full power operation on February 12, 2006.

The inspectors noted that AmerGens corrective action program identified the deficiency in work order A2107900 on February 5, 2005. The work request initially required no immediate maintenance to correct the deficiency. On September 25, 2005, the work request was updated to reflect leakage from the valve had increased and stated that a valve repack should be considered during a maintenance outage. A catch basin was installed under the A feedwater regulating valve on October 8, 2005, when leakage had increased to sixty

(60) drops per minute. The work request was updated on October 21, 2005, to annotate that the leakage had increased to a pencil size stream. On November 28, 2005, during a forced outage preparation meeting, engineering personnel requested that operators provide an update on the leakage in order to determine if maintenance should be performed on the valve during a forced maintenance outage.

Subsequent to the forced outage meeting in November 2005, no update was provided by operations personnel. On January 28, 2006, Oyster Creek entered into an eight (8)day forced maintenance outage to replace the B reactor recirculation pump. Oyster Creek did not perform repairs on the A feedwater regulating valve during the forced maintenance outage. The valve packing subsequently failed shortly after Oyster Creek achieved full power on February 8, 2006, and required a reduction in reactor power to seventy

(70) percent to repair.

Analysis.

The performance deficiency associated with this self-revealing equipment problem involved untimely corrective actions. AmerGen did not perform corrective actions in a timely manner to ensure the reliability of the A feedwater regulating valve.

The performance deficiency had a problem identification and resolution cross-cutting aspect because it involved untimely corrective actions. AmerGens corrective actions involved repairing the valve.

This finding was more than minor because it was associated with the equipment performance attribute of the initiating events cornerstone and affected the cornerstone objective to limit the likelihood of those events that challenge plant stability during power operation. In accordance with Inspection Manual Chapter (IMC) 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Operations, the inspectors conducted a Phase 1 SDP screening and determined the finding to be of very low safety significance (Green). The finding was of very low safety significance because the issue does not contribute to both the likelihood of a reactor trip and unavailability of mitigating equipment.

Enforcement.

The A feedwater regulating valve is not a safety related component, and therefore no violation of regulatory requirements occurred. Nonetheless, because the finding was of very low safety significance and AmerGen has entered this issue into their corrective action program in condition report 452708, this is identified as a finding.

(FIN 05000219/2006002-02, Untimely Corrective Actions Causes Unplanned Power Reduction Due to A Feedwater Packing Leakage.)

D ESW Pump Start Failure

Introduction.

A self-revealing finding was identified regarding inadequate procedure guidance when the D ESW pump did not start on December 19, 2005. A preventive maintenance procedure was not adequate to identify a degraded condition associated with a contact in the pumps circuit breaker prior to placing the breaker in service. This finding was of very low safety significance (Green) and determined to be a non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings.

Description.

On October 20, 2005, the installed D ESW pump General Electric (GE)

Magne-Blast 4160 Volt circuit breaker was replaced with a spare breaker (S/N 0196A2853-029) under preventive maintenance work order R0806287. The work order required that maintenance personnel verify that portions of maintenance procedure 2400-SME-3915.03, 4160 Volt Breaker Preventive Maintenance, had been performed prior to installing the breaker. Specifically, the work order required that maintenance personnel verify that maintenance procedure 2400-SME-3915.03, exhibit 2, Data Sheet, was completed satisfactorily for the breaker to be installed. Exhibit 2 of the maintenance procedure for the breaker to be installed was completed on November 19, 2004. The spare breaker was installed into the D ESW pumps breaker cubicle, the pump motor was successfully started, and the pump was placed in a standby condition on October 20, 2005. Subsequently, the D ESW pump was successfully started on November 19, 2005.

On December 19, 2005, the D ESW pump did not start when operators attempted to place the pump in service during its monthly operational start. Maintenance personnel investigated this issue and identified that one of the four 52Y anti-pump relay contacts had a high resistance reading due to excessive oxidation on its contact surface.

Maintenance personnel cleaned (burnished) the contact and measured its resistance to ensure it was adequately cleaned. The pump was successfully started and placed in standby on December 19, 2005.

The 52Y relay is a auxiliary control device mounted on the GE 4160 Volt Magne-Blast circuit breaker. The 52Y contacts are normally closed and in series with the 52X closing coil. Since the contact resistance was high, the relay operated as if it was open, and the start signal was not passed to the closing coil, which resulted in the D ESW pump not starting.

AmerGens evaluation (IR 435168) into the cause of the pump failure identified that maintenance procedure 2400-SME-3915.03 was not adequate to identify a potentially degraded condition with one of the 52Y relay contacts. The procedure did not ensure resistance measurements on the four 52Y relay contacts were taken when the procedure was performed; therefore it was not adequate to determine the reliability (i.e., increased resistance) of the contacts. Specifically, the procedure did not list the four 52Y relay contacts which needed to be measured and did not contain a space for maintenance personnel to record the contact resistance of each 52Y relay contact after it was measured. Additionally, AmerGen determined that the preventive maintenance task should be re-performed prior to installing a spare breaker if it has been greater than ninety days since it was last performed.

Analysis.

The performance deficiency associated with this self-revealing equipment problem involved inadequate procedure guidance. AmerGen did not maintain an adequate procedure to ensure each 52Y relay contact was measured in order to determine the reliability of the contacts. The performance deficiency had a human performance cross-cutting aspect because it involved a procedure quality issue.

AmerGens corrective action included revising the preventive maintenance procedure to ensure all 52Y contacts are measured, the contact resistance acceptance value was changed to a lower value, and required measurements of the contact resistance to be taken if it has been greater than ninety days since the performance of the preventive maintenance task.

The finding was more than minor because it was associated with the procedure quality attribute of the mitigating systems cornerstone and affected the objective to maintain the reliability of systems that respond to initiating events to prevent undesirable consequences. In accordance with IMC 0609, Appendix A, Significance Determination of Reactor Inspection Findings for At-Power Situations, the inspectors conducted a Phase I SDP screening and determined the finding to be of very low safety significance (Green). The finding was of very low safety significance because the issue was not a design or qualification deficiency that resulted in a loss of function, did not result in an actual loss of safety function for a single train of equipment for greater than allowed by technical specifications, did not result in an actual loss of safety function of non-technical specification equipment considered risk significant in the maintenance rule program for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and was not screened as potentially risk significant from external events.

Enforcement.

10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstance. Contrary to the above, on November 19, 2004, AmerGens procedure 2400-SME-3915.03 did not provide adequate guidance to ensure that resistance measurements on all the 52Y relay contacts in the GE Magne-Blast 4160 Volt circuit breaker were measured to assess the reliability of the contacts. However, because the finding was of very low safety significance and has been entered into the AmerGens corrective action program in condition report 435168, this violation is being treated as a non-cited violation, consistent with Section VI.A of the NRC Enforcement Policy. URI 05000219/2005005-02 is closed. (NCV 05000219/2006002-03,D ESW Pump Start Failure)

=

The inspectors reviewed five on-line risk management evaluations through direct observation and document reviews for the following plant configurations:

C Control Rod 30-15 unavailable due to a leak on accumulator charging block valve V-305-111 on January 12, 2006; C 2' EDG unavailable during scheduled maintenance on January 23, 2006; C 1' core spray system and 1' combustion turbine unavailable during scheduled maintenance on February 28, 2006; C 1-1' RBCCW system unavailable during heat exchanger cleaning and inspection on March 6, 2006; and C 1' SBGTsystem unavailable during scheduled maintenance on March 14, 2006.

The inspectors reviewed the applicable risk evaluations, work schedules, and control room logs for these configurations to verify the risk was assessed correctly and reassessed for emergent conditions in accordance with AmerGens procedure guidance.

AmerGens actions to manage risk from maintenance and testing were reviewed during shift turnover meetings, control room tours, and plant walkdowns. The inspectors also used AmerGens on-line risk monitor (ORAM-Sentinal) to gain insights into the risk associated with these plant configurations. Additionally, the inspectors reviewed corrective action condition reports documenting problems associated with risk assessments and emergent work evaluations. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

1R14 Operator Performance During Non-Routine Evolutions and Events

a. Inspection Scope

(4 samples)

The inspectors evaluated AmerGens performance and response during four non-routine evolutions to determine whether operator response was consistent with applicable procedures, training, and AmerGens expectations. The inspectors observed control room activities and/or reviewed control room logs and applicable operating procedures to assess operator performance. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

Turbine Building Closed Cooling Water Heat Exchanger Fouling. On January 16, 2006, operators received a stator cooling water trouble alarm due to degraded turbine building closed cooling water (TBCCW) heat exchanger performance during elevated grassing conditions. The inspectors verified that operators appropriately implemented abnormal procedure ABN-32, Abnormal Intake, and operating procedure 309.1, Turbine Building Closed Cooling Water System. The inspectors also performed a walkdown of the intake structure and TBCCW system after operators implemented actions to mitigate the impact of macro fouling on the TBCCW heat exchangers.

B Reactor Recirculation Pump Trip. On January 25, 2006, operators experienced a trip of the B reactor recirculation pump. The inspectors responded to the control room when they became aware of the condition and verified operators appropriately implemented abnormal procedure ABN-2, Recirculation System Failures, and operating procedure 301.2, Reactor Recirculation System. The inspectors also reviewed technical specification requirements to ensure that Oyster Creek was operated in accordance with its operating license. Please refer to section 4OA3 of this report for additional details.

Augmented Offgas (AOG) System Hydrogen Detonation. On February 13, 2006, operators responded to a hydrogen detonation in the B train of the AOG system.

Operators received offgas isolation alarms and two loud bangs were heard originating from the AOG building. The detonation caused a high pressure spike in the offgas holdup line causing offgas to isolate. The inspectors verified that operators appropriately implemented abnormal procedure ABN-25, "Off-Gas Explosion," and were able to reset the offgas isolation and restore offgas flow to the stack. The inspectors reviewed technical specification requirements to ensure that Oyster Creek was operated in accordance with its operating license. The inspectors also reviewed 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, to determine if this condition was reportable. Please refer to section 4OA3 of this report for additional details.

D Reactor Recirculation Pump Speed Controller Failure. On February 26, 2006, operators experienced an unplanned reactor power excursion to approximately one hundred and one (101) percent due to a failure of the speed controller for the D reactor recirculation pump motor generator. The inspectors verified that operators appropriately implemented abnormal procedure ABN-2, Recirculation System Failures, and operating procedure 301.2, Reactor Recirculation System. The inspectors reviewed AmerGens prompt investigation (IR 459041) to assess the impact on the other in-service reactor recirculation pumps. In addition, the inspectors reviewed implementation of standing order 95, Reactor Recirculation Pump/System Operation 4 Loop with D Pump in Local-Manual Control, which directed operations to take manual-local control of the motor generator to reduce pump speed when a power reduction is necessary. The inspectors reviewed technical specifications requirements to ensure that Oyster Creek was operated in accordance with its operating license. The inspectors also reviewed 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, to determine if this condition was reportable.

b. Findings

No findings of significance were identified.

1R15 Operability Evaluations

a. Inspection Scope

(5 samples)

The inspectors reviewed five operability determinations for degraded or non-conforming conditions associated with:

C Core spray vent valves found out of position on January 5, 2006 (IR 439243);

C RBCCW heat exchanger 1-2' experiencing high differential pressure on January 19, 2006 (IR 442848);

• Reactor building 119 foot elevation supply damper solenoid leak on January 23, 2006 (IR 445065);

• A isolation condenser condensate return valve leakage on February 7, 2006 (IR 450749); and

• Control rod 06-43 did not withdraw during weekly control rod exercise testing on March 13, 2006 (IR 465287).

The inspectors reviewed the technical adequacy of the operability determinations to ensure the conclusions were technically justified. The inspectors also walked down accessible equipment to corroborate the adequacy of AmerGens operability determinations. Additionally, the inspectors reviewed other AmerGen identified equipment deficiencies during this report period and assessed the adequacy of their operability conclusions. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

(7 samples)

The inspectors observed portions of and/or reviewed the results of six post-maintenance tests on the following equipment:

• 2' SBGT system on February 14, 2006;

• 1' diesel driven fire pump on February 14, 2006;

• A spent fuel pool pump on February 15, 2006;

• 1-1' RBCCW heat exchanger on March 6, 2006;

• 480 Volt safety related switchgear room supply fan 21' on March 10, 2006;

• ESW keep-fill valve V-3-133 on March 9, 2006; and

• A SDC pump on March 22, 2006.

The inspectors verified that the post-maintenance tests conducted were adequate for the scope of the maintenance performed and that they ensured component functional capability. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

1R20 Refueling and Other Outage Activities

a. Inspection Scope

(1 sample)

The inspectors monitored AmerGens activities associated with the outage activities described below. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

On January 28, 2006, operators initiated and completed a plant shutdown to support a forced maintenance outage to repair the failed motor on the B reactor recirculation pump. The inspectors observed portions of the shutdown from the control room, and reviewed plant logs to determine that technical specification requirements were met for placing the reactor in hot shutdown and cold shutdown. The inspectors also monitored AmerGens controls over outage activities to determine whether they were in accordance with procedures and applicable technical specification requirements.

The inspectors verified that cooldown rates during the plant shutdown were within technical specification requirements. The inspectors performed a walkdown of portions of the drywell (primary containment) on January 29, 2006, condenser bay on January 30, 2006, and torus room on February 2, 2006, to verify there was no evidence of leakage or visual damage to passive systems contained in those areas. The inspectors verified that AmerGen assessed and managed the outage risk. The inspectors confirmed on a sampling basis that tagged equipment was properly controlled and equipment configured to safely support maintenance work. During control room tours, the inspectors verified that operators maintained reactor vessel level and temperature within the procedurally required ranges for the operating condition. The inspectors also verified that the decay heat removal function was maintained through monitoring SDC parameters and performing a walkdown of the system on January 30, 2006. The inspectors observed Oyster Creeks plant onsite review committee (PORC) startup affirmations on February 2, 2006.

The inspectors performed an inspection and walkdown of portions of the drywell prior to containment closure on February 3, 2006, to verify there was no evidence of leakage or visual damage to passive systems and determine that debris was not left which could affect drywell suppression pool performance during postulated accident conditions. The inspectors monitored restart activities that began on February 4, 2006, to ensure that required equipment was available for operational condition changes, including verifying technical specification requirements, license conditions, and procedural requirements.

Portions of startup activities were observed from the control room to assess operator performance. The inspectors further verified that unidentified leakage and identified leakage rate values were within expected values and within technical specification requirements.

b. Findings

Introduction.

A self-revealing finding was identified regarding inadequate procedure adherence when work activities on the main condenser during a forced maintenance outage resulted in an unauthorized, unmonitored effluent discharge to the environment between January 31 and February 2, 2006. This finding was of very low safety significance (Green) and determined to be a non-cited violation of technical specification 6.8.1a, Procedures and Programs.

Description.

During a forced maintenance outage, AmerGen conducted A main condenser tube cleaning between January 31 and February 2, 2006. This activity was performed under work order C2010694 by contractor personnel. After completion of the work activity, the brushes used to perform the tube cleaning caused an alarm in a small article monitor (SAM) while AmerGen personnel attempted to remove the brushes from the radiologically controlled area. Radiation protection personnel performed additional surveys on the brushes, and radioactive isotopes (Cr-51, MN-54, Co-58, Co-60, and Zn-65) were identified. The condenser water boxes are maintained as a radiologically clean area during power and maintenance activities.

Upon discovery of the contaminated brushes, AmerGen performed an investigation (IR 449393) to determine the preliminary cause of the contamination. AmerGen determined that contractor personnel changed the water supply connection from the non-contaminated demineralized water system to the contaminated condensate transfer system. The contractor changed the water supply connection because insufficient water pressure was available from the demineralized water system to perform an adequate tube cleaning.

AmerGens investigation identified that the contractor personnel assumed the condensate transfer system water station was acceptable and did not review guidance contained in maintenance procedure 2400-SMM-3302.01, Main Condenser Cleaning, Inspection, and Tube Testing. Maintenance procedure 2400-SMM-3302.01 requires the use of demineralized water as the water source for condenser tube cleaning.

Additionally, AmerGen personnel responsible for oversight of the activity did not identify the change in water supply connection.

AmerGen personnel performed a dose projection by utilizing the results obtained from calculations which determine the amount of water released to the discharged canal during the cleaning activities and results of isotopic analysis of water samples.

AmerGen estimated approximately eleven thousand (11,000) gallons of condensate transfer water were released to the Oyster Creek discharge canal. Isotopic analysis was performed on water samples obtained from the condensate transfer system hose connection, A main condenser water box, and main condenser discharge. AmerGens public dose projections determined the release resulted in an exposure to the public that was less than 0.005% of the applicable quarterly limits specified in the Oyster Creek Offsite Dose Calculation Manual (ODCM). Additionally, AmerGen performed direct and indirect bioassay on workers who performed the maintenance activity and calculated an exposure of less than 1 millirem. AmerGens dose projections and bioassay results did not identify a significant public or occupational dose consequence. The inspectors, with assistance from a regional radiation specialist, reviewed AmerGens calculations, sample results, and dose projections associated with this unmonitored release.

AmerGens was in the process of performing a root cause evaluation (IR 449393) to determine appropriate corrective actions for this issue. The evaluation had not been completed as of the end of this inspection period.

Analysis.

The performance deficiency associated with this self-revealing finding involved inadequate procedure compliance. An AmerGen contractor did not use demineralized water to perform main condenser tube cleaning in accordance with maintenance procedures, and this resulted in an unauthorized, unmonitored radioactive release to the environment. The performance deficiency had a human performance cross-cutting aspect because it involved procedure compliance. As of the end of this inspection period, AmerGen was determining the appropriate corrective actions for this issue.

The finding was more than minor because it was associated with the program and process attribute of the public radiation safety cornerstone and affected the objective to ensure adequate protection of public health and safety from exposure to radioactive materials released into the public domain as a result of routine civilian nuclear reactor operation. This finding was evaluated using IMC 0609, Appendix D, Public Radiation Safety Significance Determination Process, because it was a radioactive effluent release program issue. The inspectors determined the finding to be of very low safety significance (Green) because AmerGen was able to assess the dose from the release of the radioactive effluent and the radiological release associated with the event was not greater than 10 CFR 50 Appendix I, Numerical Guides for Design Objectives for Operation to Meet the Criterion As Low As Is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents or 10 CFR 20.1301(d),

Dose Limits for Individual Members of the Public, regulatory limits.

Enforcement.

Technical specification 6.8.1a, requires, in part, that written procedures recommended in Appendix A of Regulatory Guide 1.33, Quality Assurance Requirements, shall be established, implemented, and maintained. Regulatory Guide 1.33 section 9e states that general procedures for the control of maintenance, repair, replacement, and modification work should be prepared. Contrary to the above, from January 31 thru February 2, 2006, AmerGen did not properly implement maintenance procedure 2400-SMM-3302.01, Main Condenser Cleaning, Inspection, and Tube Testing. A water source contrary to that specified in the maintenance procedure was used during A main condenser tube cleaning which resulted in an unauthorized, unmonitored effluent discharge to the environment. However, because the finding was of very low safety significance and has been entered into AmerGens corrective action program in condition report 449393, this violation is being treated as a non-cited violation, consistent with Section VI.A of the NRC Enforcement Policy.

(NCV 05000219/2006002-04, Unauthorized Unmonitored Effluent Discharge to the Environment)

1R22 Surveillance Testing

a. Inspection Scope

(7 samples)

The inspectors observed portions of and/or reviewed the results of seven surveillance tests:

• B SLC pump in-service test (IST) on January 5, 2006;

• A isolation condenser valve IST on January 10, 2006;

• Primary containment isolation valve IST on January 10, 2006;

• A and B CRD pump surveillance test on January 11, 2006;

• A spent fuel pool pump functional test on February 14, 2006;

• 2' SBGT system functional test on February 15, 2006; and

• Control rod surveillance test on March 13, 2006.

The inspectors evaluated the test procedures to verify that applicable system requirements for operability were adequately incorporated into the procedures and that test acceptance criteria were consistent with Oyster Creek technical specification requirements and the updated final safety analysis report (UFSAR). The inspectors also verified that test data was complete, verified, and met procedural requirements to demonstrate that systems and components were capable of performing their intended functioned. The inspectors also reviewed corrective action program condition reports that documented deficiencies identified during these surveillance tests. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

1R23 Temporary Plant Modifications

a. Inspection Scope

(2 sample)

The inspectors reviewed the following two temporary plant modifications installed by AmerGen at Oyster Creek in 2005:

• A feedwater pump ground sensing setpoint change (ECR 06-00110); and

• Bypass of the D reactor recirculation pump speed control signal (C2012233-01).

The inspectors verified the modifications were consistent with the design and licensing bases of the affected system, and the performance capability of the system was not degraded by the modification. The inspectors reviewed the modifications to verify applicable technical specification and operability requirements were met during installation. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

1EP4 Emergency Action Level and Emergency Plan Changes

c. Inspection Scope

(1 Sample)

During the period of September 2005 and February 2006, the NRC received changes made to AmerGens emergency plan (E-Plan) in accordance with 10 CFR 50.54(q),

Conditions of Licenses. AmerGen determined the changes did not decrease the effectiveness of the E-Plan; and the E-Plan continued to meet the requirements of 10 CFR 50.47(b), Emergency Plans, and 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities. A selected sample of E-Plan changes were reviewed in-office by a regional emergency preparedness inspector. This review does not constitute approval of the changes and, as such, the changes and the associated 10 CFR 50.54(q) reviews are subject to future NRC inspection.

d. Findings

No findings of significance were identified.

1EP6 Drill Evaluation

a. Inspection Scope

(1 sample)

The inspectors observed one licensed operator requalification training activity that was included as an input into the NRCs emergency drill and exercise performance indicator.

This observation was made in the simulator on March 10, 2006. The inspectors observed AmerGens critique of the training activity to verify that weaknesses and deficiencies were adequately identified. The inspectors specifically focused on ensuring AmerGen identified operator performance problems with event classification and notification activities. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety

2OS1 Access Control to Radiologically Significant Areas (71121.01)

a. Inspection Scope

(2 samples)

The inspectors reviewed activities, and associated documentation, in the area of access control to radiological significant areas. The inspectors evaluated AmerGens performance against criteria contained within 10 CFR 20 (Standards for Protection Against Radiation), applicable technical specification requirements, and AmerGen procedures.

The inspectors reviewed performance indicators (PIs) for the occupational exposure cornerstone. The inspectors toured Oyster Creek, reviewed radiological controls, and performed independent radiation surveys during the tours. The inspectors reviewed housekeeping, material condition, radiological postings, barricades, and access controls to determine if radiological controls were acceptable. The inspectors assessed the adequacy and effectiveness of radiological controls on work associated with installation of level instrumentation on the sludge tanks and replacement of B reactor recirculation pump seal.

The inspectors reviewed AmerGens implementation of high radiation area (HRA)access controls at Oyster Creek, including administrative controls and inventory of locked HRA access keys maintained by operations and radiation protection.

The inspectors reviewed self-assessments and audits performed by Amergen to determine if problems were being entered into the corrective action program for resolution. The inspectors evaluated the database for repetitive deficiencies or significant individual deficiencies to determine if self assessment activities were identifying and addressing issues. The inspectors evaluated data associated with PI events with dose rates greater that 25 R/hr at 30 centimeters, greater than 500 R/hr at 1 meter; unintended exposures greater than 100 millirem total effective dose equivalent, 5 rem shallow dose equivalent, and 1.5 rem lens dose equivalent. The inspectors also reviewed corrective action program condition reports to evaluate AmerGens threshold for identifying, evaluating, and resolving problems in the area of access control to radiologically significant areas. Documents reviewed for this inspection activity are listed in the Supplemental Information attached to this report.

b. Findings

Introduction.

The inspectors identified that AmerGen did not properly implement administrative controls for locked HRA access keys maintained under the control of operations personnel. This finding was of very low safety significance (Green) and determined to be a non-cited violation of technical specification 6.13.2, High Radiation Area.

Description.

On March 14, 2006, the inspectors conducted an inventory of locked HRA keys maintained in the control room by operations and reviewed the results of audits performed in November and December 2005. The inspectors reviewed AmerGen procedure OP-OC-108-103-1002, Operations Controlled Keys, to identify the process of maintaining administrative control of HRA keys. AmerGens procedure stated that the controlled key inventory be kept up-to-date, and that the key inventory be audited.

The inspectors identified that the key inventory, as depicted in Attachment 1 to procedure OP-OC-108-103-1002, was not up-to-date as required. Specifically, the inspectors identified that the control room maintained four

(4) HRA keys for the tag 5 location. However, the procedure stated that there should be five

(5) keys for that location and in the event of a lost key the operations personnel should notify radiation protection personnel. The inspectors could not identify any efforts to correct the key inventory or notify radiation protection personnel associated with the apparent lost key following the audits conducted on November 4, 2005 and December 11, 2005. The inspectors also identified that at least five

(5) required weekly audits were not conducted or documented between the time period of November 4, 2005 and December 11, 2005, as required by the procedure. In addition, the inspector identified that operations personnel had signed off on the key audits as acceptable on these dates despite inconsistencies in the key inventory. The inspectors noted that the procedure was subsequently revised on December 14, 2005, to change audit frequency from weekly to quarterly. Notwithstanding, when reviewed by the inspector on March 14, the inventory depicted in Attachment 1 of the procedure, had not been updated. The inspectors discussed these observations with radiation and operation personnel. AmerGen investigated this issue and determined that the procedure contained multiple administrative errors such as incorrect key identification numbers or amount discrepancies and documented this in corrective action program condition report

===466231. AmerGens investigation did not identify missing HRA keys.

Analysis.

The performance deficiency involved inadequate procedure adherence.

AmerGen did not maintain administrative controls for locked HRA keys in accordance with technical specification requirements and AmerGen procedures. The performance deficiency had a problem identification and resolution cross-cutting aspect because it involved inadequate corrective actions to previously identified administrative control issues associated with HRA keys (O2004-0752 and IR 431915). As of the end of the inspection period, AmerGen was determining the appropriate corrective actions for this issue.

The finding was more than minor because it was associated with the program and process attribute of the occupational radiation safety cornerstone and affected the objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The finding was evaluated using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, because it was an exposure control issue. The inspectors determined the finding to be of very low safety significance (Green) because it did not involve an ALARA finding, it did not involve an overexposure, there was no substantial potential for an overexposure, and the ability to assess dose was not compromised.

Enforcement.

Technical Specification 6.13.2, High Radiation Area, requires, in part, that keys to areas with radiation dose rates in excess of 1000 millirem/hr (at 30 centimeters), but less than 500 rads in one hour (at 1 meter), be maintained under the administrative control of operations and/or radiation protection supervision on duty to prevent unauthorized entry. Contrary to this requirement, AmerGen did not properly implement procedure OP-OC-108-103-1002, which specifies the administrative controls for locked HRA keys being maintained by operations personnel, between November 4, and December 11, 2005. However, because the finding was of very low safety significance, and has been entered into AmerGens corrective action program in condition report 466231, this violation is being treated as a non-cited violation consistent with Section VI.A of the NRC Enforcement Policy, NUREG-1600 (NCV 05000219/2006002-05, Inadequate Administrative Control of High Radiation Area Keys).

2OS2 ALARA Planning and Controls (71121.02)

=

The inspectors reviewed activities, and associated documentation in the area of operational, engineering, and administrative controls to maintain personnel occupational radiation exposure ALARA. The inspectors evaluated AmerGens performance against criteria contained in 10 CFR 20 (Standards for Protection Against Radiation) and applicable industry standards and AmerGen procedures.

The inspectors reviewed documents associated with station collective dose history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspectors reviewed AmerGens plans in the area of source term controls. Specifically, the inspectors reviewed AmerGens Cobalt-60 source term control efforts as described in the AmerGen business plan. The inspectors also reviewed system radiation base-point measurement results.

The inspectors reviewed self-assessments, audits, and special reports performed by Amergen to determine if problems were being entered into the corrective action program for resolution. The inspectors also reviewed dose significant post-job reviews and post-outage ALARA report critiques of exposure performance to evaluate AmerGens threshold for identifying, evaluating, and resolving problems. Documents reviewed for this inspection activity are listed in the Supplemental Information attached to this report.

b. Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

(2 samples)

The inspectors reviewed activities and associated documentation in the area of radiation monitoring instrumentation and protective equipment. The inspectors evaluated AmerGens performance against criteria contained within 10 CFR 20 (Standards for Protection Against Radiation), applicable technical specification requirements, and AmerGen procedures.

The inspectors reviewed the calibrations and operability checks for portable radiological control instrumentation (including hand-held instrumentation and laboratory instrumentation): RO-20-077643, RO-2A-075840, RO-2-072356, RO-7-073525, ASP1-700118, Gillian-075932, RAS1-701861, AMS3-700030.

The inspectors reviewed self-assessments and audits performed by AmerGen to determine if problems were being entered into the corrective action program for resolution. The inspectors also reviewed corrective action program condition reports to evaluate AmerGens threshold for identifying, evaluating, and resolving problems.

Documents reviewed for this inspection activity are listed in the Supplemental Information attached to this report.

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered Into the Corrective Action Program

To identify repetitive equipment failures or specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into AmerGens corrective action program. This was accomplished by reviewing hard copies of each condition report, attending daily screening meetings, and/or accessing AmerGens computerized database.

4OA3 Event Followup

(2 samples)

.1 Trip of the B Reactor Recirculation Pump

On January 25, 2006, operators experienced a trip of the B reactor recirculation pump.

Prior to the event, the plant was operating with four reactor recirculation pumps in service and the A reactor recirculation pump out-of-service due to a failed seal.

Operators stabilized the plant at approximately fifty-three

(53) percent, in accordance with procedures.

The inspectors responded to the control room after hearing the site announcement that the B reactor recirculation pump had tripped. The inspectors observed the response of AmerGen personnel, including operator actions in the control room. The inspectors verified that operators responded in accordance with procedures and equipment responded as intended. The inspectors further reviewed technical specification requirements to ensure that Oyster Creek was operated in accordance with its operating license.

AmerGen initiated an investigation and performed troubleshooting to determine the cause of the pump trip. AmerGen determined the pump tripped due to a ground in the pump motor. The inspectors reviewed AmerGens extent of condition reviews on the other in-service reactor recirculation pumps to determine if the other pumps were susceptible to the same type of failure. AmerGen performed a plant shutdown on January 28, 2006, in order to replace the B reactor recirculation pump motor.

The trip of the B reactor recirculation pump was described and evaluated in corrective action program condition report IR 452708.

.2 AOG System Hydrogen Detonation

Early in the evening on February 13, 2006, the inspectors were informed that the Oyster Creek AOG system isolated due to a hydrogen detonation. Operators received offgas isolation alarms and two loud bangs were heard originating from the AOG building.

The detonation caused a high pressure spike in the offgas holdup line, causing offgas to isolate. Operators implemented abnormal procedure ABN-25, "Off-Gas Explosion," and were able to reset the offgas isolation and restore offgas flow to the stack via the offgas system. Operations and engineering personnel performed plant walkdowns in the mechanical vacuum pump room, steam jet air ejector room, high/low conductivity room, feedpump room, AOG building, and the base of the stack. The walkdowns did not identify visible damage to components or structures.

The inspectors responded to the site to verify that the detonation and offgas flow isolation did not impact safety-related or plant support systems needed to safely operate Oyster Creek.

The inspectors verified the condition did not meet the entry criteria for an emergency action level (EAL) as described in the Oyster Creek EAL matrix. The inspectors also reviewed technical specification requirements to ensure that Oyster Creek was operated in accordance with its operating license. The inspectors also reviewed 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, to determine if this condition was reportable.

The inspectors also performed walkdowns of the areas inspected by operations and engineering, and did not identify damage to structures or components caused by the detonation.

The detonation in the AOG system was described and evaluated in corrective action program condition report IR 453495. AmerGen attributed the cause of the detonation to be catalyst (palladium particulates) carryover from the B recombiner bed to the blower.

AmerGen determine the catalyst bed was replaced in October 2005, and was not rinsed properly to prevent particulate carryover.

4OA6 Meetings, Including Exit

Exit Meeting Summary. On April 7, 2006, the inspectors presented the inspection results to Mr. Swenson and other members of his staff, who acknowledged the findings.

The inspectors asked AmerGen whether any of the material examined during the inspection should be considered proprietary. No proprietary information was identified.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee personnel

R. Artz, Chemist

M. Button, Director, Engineering

J. Derby, Radiological Engineer

K. Drieher, Security Manager

J. Dostal, Shift Operations, Superintendent

A. Judson, Radiological Engineer

J. Kandasamy, Manager, Regulatory Assurance

R. Larzo, Engineering

J. Magee, Director, Maintenance

J. Murphy, Radiological Engineering Manager

J. ORourke, Assistant Engineering Director

T. Powell, Engineering Programs Manager

J. Randich, Plant Manager

J. Renda, Radiation Protection Manager

C. Swenson, Site Vice President

J. Vaccaro, Director, Training

M. Wagner, CAP Coordinator

R. Zacholski, Director, Operations

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened

05000219/2006002-01 URI Containment Spray System 1' Flow Instrumentation Failure (Section 1R12)

Opened/Closed

05000219/2006002-02 FIN Untimely Corrective Actions Causes Unplanned Power Reduction Due to A Feedwater Packing Leakage (Section 1R12)

05000219/2006002-03 NCV D ESW Pump Start Failure (Section 1R12)

05000219/2006002-04, NCV Unauthorized Unmonitored Effluent Discharge to the Environment (1R20)

05000219/2006002-05 NCV Inadequate Administrative Control of High Radiation Area Keys (2OS1)

Closed

05000219/2005005-02 URI D ESW Pump Start Failure (Section 1R12)