IR 05000219/2007003
| ML072070141 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 07/24/2007 |
| From: | Ronald Bellamy NRC/RGN-I/DRP/PB6 |
| To: | Crane C AmerGen Energy Co |
| BELLAMY RR | |
| References | |
| IR-07-003 | |
| Download: ML072070141 (41) | |
Text
July 24, 2007
SUBJECT:
OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2007003
Dear Mr. Crane:
On June 30, 2007, the United States 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 July 6, 2007, with Mr. J. Randich, Plant Manager, 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 of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. Additionally, one licensee-identified violation which was determined to be of very low safety significance is listed in the report. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these two 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.
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 6 Division of Reactor Projects Docket No.
50-219 License No.
Enclosure:
Inspection Report 05000219/2007003 w/Attachment: Supplemental Information
REGION I==
Docket No.:
50-219 License No.:
DPR-16 Report No.:
05000219/2007003 Licensee:
AmerGen Energy Company, LLC (AmerGen)
Facility:
Oyster Creek Generating Station Location:
Forked River, New Jersey Dates:
April1, 2007 - June 30, 2007 Inspectors:
M. Ferdas, Senior Resident Inspector R. Treadway, Resident Inspector J. Kulp, Acting Resident Inspector R. Nimitz, Senior Health Physicist J. DAntonio, Senior Operations Engineer G. Malone, Senior Resident Inspector, Hope Creek T. Wingfield, Resident Inspector, Hope Creek B. Haagensen, Operations Engineer J. Bobiak, Reactor Inspector Approved By:
Ronald R. Bellamy, Ph.D., Chief Projects Branch 6 Division of Reactor Projects
ii
SUMMARY OF FINDINGS
IR 05000219/2007003; 04/01/07 - 06/30/07; AmerGen Energy Company, LLC, Oyster Creek
Generating Station; Radioactive Gaseous and Liquid Effluent Treatment & Monitoring Systems The report covered a 3-month period of inspection by resident inspectors, regional inspectors, and an in-office review by a senior operations engineer. One Green non-cited violation (NCV)was identified. The significance of most findings is 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 4, dated December 2006.
NRC-Identified and Self-Revealing Findings
Cornerstone: Public Radiation Safety
- Green.
The inspectors identified that quality assurance test results for effluent monitoring of Sr-89 and Sr-90 in the first quarter of 2006 did not meet test acceptance criteria and AmerGen had not evaluated the condition as of April 27, 2007. This finding was determined to be a non-cited violation of technical specification 6.8.1i, Procedures and Programs. AmerGens corrective actions involved evaluating the test results to understand their potential impact to the public.
The finding was more than minor because it was associated with the effluent measurement quality control attribute of the public radiation 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 operations. In accordance with Inspection Manual Chapter 0609,
Appendix DProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix D" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Public Radiation Safety Significance Determination Process, this finding was determined to be of very low safety significance (Green), the issue was not a radioactive material control issue, it involved the effluent release program, there was no impaired ability to assess dose, and public radiation doses did not exceed 10 CFR 50,
Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low As Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, values. The performance deficiency had a cross cutting aspect in the area of problem identification and resolution because AmerGen did not identify completely, accurately, and in a timely manner that the test results did not meet their acceptance criteria P.1(a). (Section 2PS1)
Licensee-Identified Violations
One violation of very low safety significance was identified by AmerGen and reviewed by the inspectors. Corrective actions taken or planned by AmerGen have been entered into AmerGens corrective action program. This violation and corrective actions are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
The Oyster Creek Generating Station (Oyster Creek) began the inspection period operating at full power.
On April 28, 2007, operators commenced a shutdown in accordance with operating procedures to support a planned maintenance outage. During the planned maintenance outage AmerGen repaired the A and C reactor recirculation pump seals and performed other minor maintenance. Operators established the reactor critical on May 3, 2006 and synchronized the main generator to the grid on May 4, 2007. The plant reached full power on May 5, 2007.
On May 26, 2007, operators performed a planned downpower to 93% in accordance with operating procedures to perform control rod drive mechanism (CRDM) scram testing on rod 26-35 to reduce flange leakage. The plant returned to full power on May 27, 2007.
At the end of this inspection period Oyster Creek was operating at full power.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
a. Inspection Scope
(1 site sample)
The inspectors reviewed AmerGens activities associated with one adverse weather preparation.
The inspectors completed an adverse weather preparation inspection for seasonal readiness to hot weather conditions. The inspectors reviewed the updated final safety analysis report (UFSAR) for Oyster Creek to identify risk significant systems that require protection from hot weather conditions. The inspectors reviewed the feedwater system, emergency service water (ESW), screen wash system, and the 125 volt DC vital power system to assess their readiness for seasonal susceptibilities to hot weather conditions.
The inspectors performed a walkdown of the feedwater pump room, intake area, and the 125 volt DC battery rooms. The inspectors also reviewed applicable corrective action program condition reports to assess the reliability and material condition of these systems. AmerGens hot weather preparation activities were also reviewed to assess their adequacy and to verify they were completed in accordance with procedure requirements.
In addition, the inspectors reviewed AmerGens procedures for grid reliability and protocol between Oyster Creek and First Energy Nuclear Operating Company in response to TI 2515/111, Electrical Distribution System Followup Inspection and Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power. The inspectors also reviewed these procedures to ensure they were kept current and incorporated industry guidance for managing the risk associated with weather related transients affecting grid operability and reliability.
Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findings
No findings of significance were identified.
1R04 Equipment Alignment
a. Inspection Scope
(4 quarterly samples)
The inspectors performed four partial equipment alignment inspections. The partial equipment 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. 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:
- Containment spray/(ESW) system #2 on April 17, 2007;
- Service water system #1 on May 11, 2007;
- Remote shutdown panel on May 15, 2007; and
- Core spray system #1 on May 21, 2007.
In addition, the inspectors reviewed AmerGens response to a decrease on the C reactor recirculation pump #2 seal pressure on June 15, 2007. A decrease in seal pressure indicates the #2 seal is degraded. The inspectors monitored reactor recirculation pump seal performance during plant status activities and verified that operations personnel correctly implemented abnormal procedure ABN-2, Recirculation System Failures.
Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findings
No findings of significance were identified.
1R05 Fire Protection
a. Inspection Scope
(10 quarterly samples)
The inspectors performed a walkdown of ten 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 A/B battery room on April 6, 2007; C
Condensate pre-filter modification work in turbine building mezzanine area on April 6, 2007; C
C 4160 volt room on April 12, 2007; C
Condenser bay area on April 29, 2007; C
Main transformer area on May 24, 2007; C
Augmented off gas building on May 30, 2007; C
New RadWaste building on May 30, 2007; C
Condensate transfer pump building on June 7, 2007; C
Reactor building equipment drain tank (RBEDT) room on June 6, 2007; and C
A/B 480 volt room on June 7, 2007.
b. Findings
No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
(1 internal sample)
The inspectors performed one internal flood protection inspection activity. The inspectors performed an internal flood protection inspection activity in the northwest corner room located in the reactor building which contain the A and C core spray pumps. 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 assessed the physical condition of the equipment and components in these rooms. The inspectors reviewed preventive maintenance activities associated with flood protection equipment. The inspectors also reviewed AmerGens procedures related to flooding of the core spray pump rooms. Documents associated with these reviews 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 annual sample)
The inspectors verified acceptable heat exchanger performance by reviewing the results of one heat exchanger performance test. The inspectors reviewed the containment spray system #1 heat exchanger performance test data collected on April 17, 2007 in order to verify that the heat exchanger met performance requirements. In addition, the inspectors reviewed the test procedure and results to verify that appropriate test controls were incorporated correctly into the procedure; test acceptance criteria were consistent with design calculations; and AmerGen appropriately identified potential heat exchanger deficiencies. Documents reviewed 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 Quarterly Sample, 1 Biennial Sample)
The inspectors performed one licensed operator requalification activity observation and one biennial review by regional specialists.
Requalification Activities Reviewed By Resident Staff. The inspectors observed one simulator training scenario on April 24, 2007, to assess operator performance and training effectiveness. The scenario involved a trip of the A high pressure and intermediate pressure heaters, a failed open electromatic relief valve (EMRV), and an anticipated transient without a scram (ATWS) condition with a failure of alternate rod insertion (ARI) requiring operators to initiate standby liquid control (SLC) to shutdown the reactor. The inspectors assessed whether operator performance met AmerGens 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.
Biennial Review by Regional Specialists. The inspectors reviewed documentation of operating history since the last requalification program inspection. Documents reviewed included NRC inspection reports and corrective action program condition reports that involved human performance issues.
The inspectors reviewed two weeks of comprehensive biennial written exams and simulator scenarios and one week of job performance measures (JPM) administered to ensure the quality of these exams met or exceeded the criteria established in NUREG-1021, Rev. 9, Operator Licensing Examination Standards for Power Reactors, and 10 CFR 55.59, Requalification.
The inspectors observed the administration of operating examinations on two operating crews from June 4 through June 8, 2007. The inspectors observed the administration of three simulator scenarios for one operating crew and two scenarios for a second crew.
The inspectors also observed one set of five JPMs administered to one crew. As part of the examination observation, the inspectors assessed the adequacy of AmerGens examination security measures.
The inspectors evaluated the use of feedback in the training program. The inspectors verified that plant and industry events were incorporated into lesson plans used during training. The inspectors also reviewed self assessments and feedback forms.
The inspectors assessed remedial training through reviews of evaluation records for the past two years. The inspectors ensured remediation plans were unique to the individual failures, timely, and effective. The inspectors reviewed the remediation plans for a crew failure and three written exam failures that occurred in this time period.
The inspectors verified that operators were in conformance with their operator license conditions by reviewing the following records:
- (1) attendance records for the last two-year training cycles;
- (2) 10 medical records (approximately 25% of all licensed operators) to confirm all records were complete, that restrictions noted by the doctor were reflected on the individuals license and that the exams were given within 24 months; and
- (3) proficiency watch-standing and reactivation records for all active operator licenses for two quarters.
The inspectors observed simulator performance during the conduct of the examinations.
The inspectors also reviewed simulator performance tests and discrepancy reports to verify compliance with the requirements of 10 CFR 55.46, Simulation Facilities. Oyster Creek is committed to the ANSI 3.5-1985 standard. The inspectors verified simulator configuration control and performance testing was being adequately performed by: (1)interviewing AmerGen personnel; and
- (2) reviewing simulator procedures, open/closed simulator issue reports, maintenance orders, and simulator test results. The inspectors reviewed the following simulator test results:
Normal, Malfunction and Transient tests:
- TTS69 14.8.1 Manual Reactor Trip
- NOT15 14.6.45.6 EMRV Operability Test Core Performance test:
- TQ-AB-303-0101 Rev 2 BWR Core Performance Testing Steady-State test:
- SSP01 100% Steady State Accuracy Test Actual Plant Transient Comparison test:
- OES02 14.8.12 Reactor Isolation Scram
- OES09 14.8.19 Reactor Scram The inspectors noted that the most recent core performance test did not meet acceptance criteria primarily because the rated core power output was greater than 10%
lower than the actual core 100% rated thermal power output. AmerGen had identified this problem and was in the process of upgrading their core model in response to this identified test failure.
On June 25, 2007, a senior operations engineer conducted an in-office review of AmerGens requalification exam results for Oyster Creek. The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP). The inspectors verified that:
- Crew failure rate on the dynamic simulator was less than 20% (Actual Results:
Failure rate was 0%);
- Individual failure rate on the dynamic simulator test was less than or equal to 20% (Actual Results: Failure rate was 0%);
- Individual failure rate on the walkthrough test (JPMs) was less than or equal to 20% (Actual Results: Failure rate was 0%);
- Individual failure rate on the comprehensive biennial written exam was less than or equal to 20% (Actual Results: Failure rate was 0%); and
- More than 75% of the individuals passed all portions of the exam (Actual Results: 100% of the individuals passed all portions of the exam).
b. Findings
No findings of significance were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
(3 quarterly samples)
The inspectors performed three maintenance effectiveness inspection activities. The inspectors reviewed the following degraded equipment issues in order to assess the effectiveness of maintenance by AmerGen:
C C/D service air dryer purge exhaust valve (V-6-3293) failed open on February 18, 2007 (IR 592859);
C Standby gas treatment (SBGT) system #1 exhaust fan control switch mechanically locked in manual position on May 6, 2007 (IR 626109); and C
Northeast corner room 1-7' sump pump breaker issue on June 4, 2007 (IR
===634350).
The inspectors verified that the systems or components were monitored in accordance with AmerGens maintenance rule program requirements. The inspectors compared documented maintenance preventable functional failure (MPFF) determinations and unavailable hours to those being tracked by AmerGen to evaluate the effectiveness of AmerGens condition 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.
b. Findings
No findings of significance were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
=
The inspectors reviewed six on-line risk management evaluations through direct observation and document reviews for the following plant configurations:
C 34.5 KV offsite power line (Q-121) unavailable due to emergent maintenance on April 9, 2007; C
Torus nitrogen purge valve (V-23-15), containment spray/ESW system #2, unavailable due to scheduled maintenance, and 34.5 KV offsite power line (Z-52)unavailable due to emergent maintenance on April 24, 2007; C
Service water pump 1-2' and SBGT system #2 unavailable due to scheduled maintenance on May 11, 2007; C
Bank 6 start-up transformer unavailable due to scheduled maintenance on May 12, 2007; C
Containment spray system #1 unavailable due to scheduled maintenance and the presence of an external event (offsite forest fire) that had the potential to affect offsite power sources on May 16, 2007; and C
A and B isolation condenser available due to compensatory actions during scheduled maintenance on automatic initiation logic relay 6K12 on May 22, 2007.
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 procedures.
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 (Paragon) to gain insights into the risk associated with these plant configurations. Additionally, the inspectors reviewed corrective action program 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.
1R15 Operability Evaluations
a.
Inspection Scope (4 samples)
The inspectors reviewed four operability evaluations for degraded or non-conforming conditions associated with:
C 1-3' ESW pump upper motor bearing oil sample contained elevated wear particles on April 4, 2007 (IR 613061);
C Elevated temperatures on control rod drive 18-07' on April 16, 2007 (IR 617868);
C Turbine control valve actuator support structure on May 1, 2007 (IR 623614);and C
Degraded response time on 6K12 relay for A and B isolation condenser automatic initiation on May 25, 2007 (IR 635065).
The inspectors reviewed the technical adequacy of the operability evaluations to ensure the conclusions were technically justified. The inspectors also walked down accessible portions of equipment to corroborate the adequacy of AmerGens operability evaluations. 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 or reviewed the results of seven post-maintenance tests for the following equipment:
- SBGT system #1 exhaust fan and roughing filter (F-28-8) on April 4, 2007 (WO R2096300 and C2013299);
- Containment spray system #1 heat exchangers on May 16, 2007 (WO A2165943);
- Service water pump #2 on May 22, 2007 (WO A2157012);
- Emergency diesel generator (EDG) #2 on June 5, 2007 (WO A2115619);
- Service water pump #1 discharge pressure gauge on June 18, 2007 (WO R2101094);
- Isolation condenser 6K12 relay on June 22, 2007 (WO C2015317); and
The inspectors verified that the post-maintenance tests conducted were adequate for the scope of the maintenance performed and the tests verified functional capability of the system after maintenance. 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 one outage activity.
Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
On April 28, 2007, operators initiated a plant shutdown to support a planned maintenance outage. The inspectors observed portions of the shutdown from the control room, and reviewed plant logs to verify that technical specification requirements were met for placing the reactor in hot shutdown and cold shutdown. 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 April 29, 2007, and the condenser bay on April 30, 2007, to verify there was no evidence of leakage or visual damage to passive systems contained in these areas.
During the walkdown of the drywell the inspectors observed that the drywell trenches discussed in PNO-1-06-012, Preliminary Notification of Event of Unusual Occurrence dated November 9, 2006 (Accession Number: ML063130424), did not contain water.
The inspectors documented their observations with pictures of the trenches which can be found in the NRCs Agencywide Documents Access and Management System (ADAMS) (Accession Number: ML071240314).
The inspectors monitored AmerGens controls over outage activities to determine whether they were in accordance with procedures and applicable technical specification requirements. 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 verified that the decay heat removal function was maintained through monitoring shutdown cooling parameters during plant status and by performing a walkdown of the system on April 30, 2007. The inspectors determined whether offsite and electrical power sources were being maintained in accordance with technical specification requirements and consistent with the outage risk assessment. Periodic walkdowns of portions of the onsite electrical buses and the EDGs were conducted. The inspectors also observed Oyster Creeks plant onsite review committee (PORC) startup affirmations on May 2, 2007.
The inspectors performed an inspection and walkdown of portions of the drywell prior to containment closure on May 2, 2007, to verify there was no evidence of leakage or visual damage to passive systems and to determine whether debris was left which could affect drywell suppression pool performance during postulated accident conditions. The inspectors monitored restart activities that began on May 3, 2007, to ensure that required equipment was available for operational condition changes, including verifying technical specification requirements, license conditions, and procedural requirements.
Portions of the startup activities were observed from the control room to assess operator performance including the reactor going critical on May 3, 2007, as well as taking the mode switch to run and synchronization of the main turbine generator to the grid on May 4, 2007. The inspectors also verified that unidentified leakage and identified leakage rate values were within expected values and within technical specification requirements after startup.
b. Findings
No findings of significance were identified.
1R22 Surveillance Testing
a. Inspection Scope
(6 samples - 2 IST, 3 routine surveillance tests, and 1 RCS leakage)
The inspectors observed portions of or reviewed the results of six surveillance tests:
- Drywell purge valve (V-27-4) functional test on April 5, 2007;
- B isolation condenser functional test on April 9, 2007;
- Turbine building radioactive gaseous effluent monitor (RAGEMS) high radiation monitor surveillance test on April 14, 2007;
- Unidentified leak rate technical specification calculation on May 17, 2007;
- Core spray system #2 inservice test (IST) on May 22, 2007; and
- B standby liquid control pump IST on June 18, 2007.
The inspectors reviewed completed test procedures to verify test data was complete and met procedural requirements to demonstrate that systems and components were capable of performing their intended function. 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.
RADIATION SAFETY
Cornerstone: Public Radiation Safety
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01) a.
Inspection Scope (10 Samples)
The inspectors reviewed activities and associated documentation in the area of radioactive gaseous and liquid effluent treatment and monitoring.
The inspectors as part of their inspection planning and in-office inspection reviewed the 2003, 2004, 2005 and 2006 Radiological Effluent Release and Radiological Dose Assessment reports for Oyster Creek to verify that AmerGen was adequately implementing the program as described in Oyster Creeks Radiological Effluents Technical Specifications (RETS) and Offsite Dose Calculation Manual (ODCM). The inspectors reviewed the ODCM to identify recent changes to radioactive waste system design and operation at Oyster Creek. The inspectors determined whether changes to the ODCM were technically justified and documented appropriately.
The inspectors evaluated AmerGens analysis on additional discharge pathways from the plant as a result of liquid or gaseous discharges from normal operations and unexpected discharges from spills or leaks, which may have occurred since the previous inspection. The inspectors verified that AmerGen had records on sampling locations, type of monitoring, and frequency of sampling to meet 10 CFR 20.1501, General, requirements.
The inspectors determined whether modifications made to radioactive waste system design and operation could result in changes to the dose consequence to the public.
The inspectors verified that technical and/or 10 CFR 50.59, Changes, Test, and Experiments,reviews were performed, when needed. The inspectors determined whether radioactive liquid and gaseous effluent radiation monitor setpoint calculation methodology changed since the previous inspection. The inspectors also verified that AmerGen had set and adjusted its radioactive effluent alarm setpoints in accordance with the methodology and parameters specified within the current ODCM.
The inspectors determined if anomalous results, reported in the current Radiological Effluent Release and Radiological Dose Assessment reports, were adequately resolved. The inspectors also reviewed AmerGens actions to resolve out-of-specification intra-laboratory and inter-laboratory cross-check analysis data for the effluent monitoring program, and to assess the adequacy of AmerGens corrective actions for the out-of-specification data.
The inspectors reviewed the UFSAR, RETS and the ODCM to identify radioactive gaseous and liquid processing systems, effluent radiation monitoring systems, and applicable flow measurement devices. The inspectors reviewed the RETS and ODCM to identify the programs for identifying potential contaminated spills and leakage and AmerGens process for control and assessment. The inspectors determined if any AmerGen procedures and/or surveillance activities address the ability to identify onsite spills/leaks of contaminated fluids.
The inspectors also reviewed AmerGens self-assessments, audits, and corrective action program condition reports to determine if unanticipated offsite releases of radioactive material had occurred since the previous inspection and how they would impact the performance indicators.
The inspector walked down accessible portions of Oyster Creeks gaseous and liquid release systems, including radiation and flow monitors, filters, tanks, and vessels. The walkdowns were performed to determine if the systems were consistent with descriptions provided in the UFSAR and to evaluate material condition of the systems and components. The inspectors also verified that system components were as described in the ODCM and were used for reduction of activity levels in accordance with the RETS and ODCM. During plant tours, the inspectors looked for potential unmonitored radioactive gaseous and/or liquid release pathways.
The inspectors observed routine effluent sample collections from the main stack and the augmented off gas (AOG) building vent and observed laboratory analysis of these effluent samples (particulate filters and charcoal cartridges). The inspectors verified that radioactive gaseous effluent treatment equipment was being used in accordance with RETS and ODCM requirements. The inspectors reviewed the status of any radioactive liquid waste release plans because Oyster Creek does not routinely release liquid radioactive effluents.
The inspectors reviewed records of gaseous releases made when effluent radiation monitors were out-of-service to ensure an adequate defense-in-depth was maintained against an unmonitored, unanticipated release of radioactive material to the environment. The inspectors verified that compensatory sampling and radiological analyses was conducted as required by the RETS and ODCM when effluent monitors were declared out-of-service on the service water monitor. The inspectors also determined if AmerGen had placed information on leaks or spills into its 10 CFR 50.75(g), Reporting and Record Keeping for Decommissioning Planning, decommissioning file.
The inspectors assessed AmerGens understanding of the location and construction of underground pipes and tanks, and storage pools that contain radioactive contaminated liquids. The inspectors evaluated if AmerGen may have potential unmonitored leakage of contaminated fluids to the groundwater as a result of degrading material conditions or aging of facilities. The inspectors evaluated AmerGens capabilities (such as monitoring wells) of detecting spills or leaks and their ability to identify groundwater radiological contamination both onsite and beyond the owner controlled area. The inspectors reviewed AmerGens technical bases for their onsite groundwater monitoring and efforts to finalize a routine long-term sample program. The inspectors reviewed ground and surface water sample results. The inspectors discussed with AmerGen personnel their understanding of groundwater flow patterns for the site and, in the event of a spill or leak of radioactive material, how AmerGen personnel would estimate the pathway of a plume of contaminated fluid both onsite and beyond the owner controlled area. The inspectors also reviewed the Oyster Creek Station Hydro-Geologic Investigation Report, Revision 1, dated September 1, 2006. The inspectors also reviewed Oyster Creeks Annual Radiological Groundwater Protection Program Report, dated May 2007.
The inspectors reviewed changes to the ODCM as well as to the liquid or gaseous radioactive waste system design, procedures, or operation since the last inspection. For each system modification, and each ODCM revision that impacted effluent monitoring or release controls, the inspectors reviewed AmerGens technical justification to determine whether the changes affected AmerGens ability to maintain effluents as low as reasonably achievable (ALARA) and whether changes made to monitoring instrumentation resulted in a non-representative monitoring of effluents.
For significant changes to dose values reported in the 2006 Oyster Creek Radiological Effluent Release report vice the 2005 report, the inspectors evaluated the factors which may have resulted in the change. The inspectors also determined if the change was influenced by an operational issue (e.g., fuel integrity, extended outage, or major decontamination efforts).
The inspectors reviewed a selection of 2004, 2005, and 2006 monthly, quarterly, and annual dose calculations to ensure that AmerGen properly calculated the offsite dose (both cumulative and projected) from radiological effluent releases and direct radiation to determine if any annual RETS or ODCM values were exceeded. The inspectors evaluated the source term used by Oyster Creek to ensure all applicable radionuclides discharged, within detectability standards, were included. The inspectors also performed conservative calculations, based on ODCM methodology, to validate projected doses.
The inspectors reviewed air cleaning system surveillance test results on the standby gas treatment system to ensure that system operations were within applicable acceptance criteria specified in the Oyster Creek technical specifications. The inspectors also reviewed surveillance test results and methodology the licensee used to determine the stack and vent flow rates.
The inspectors reviewed records of effluent monitor instrument calibrations for each point of discharge. The inspectors reviewed recently completed system modification, and current effluent radiation monitor alarm setpoint values to ensure they were in agreement with RETS and ODCM requirements.
The inspectors reviewed calibration records of radiation measurement instrumentation in the laboratory counting room that is used for effluent monitoring and release activities.
The inspectors reviewed quality control records for the radiation measurement instruments and looked for indications of degraded instrument performance.
The inspectors reviewed the results of the intra-laboratory and inter-laboratory comparison program to verify the quality of radioactive effluent sample analyses performed by AmerGen. The inspectors reviewed AmerGens quality control evaluation of the inter-laboratory comparison test data and associated corrective actions for any deficiencies identified. The inspectors also reviewed AmerGens assessment of any identified bias in the sample analysis results and the overall effect on calculated projected doses to members of the public.
The inspectors reviewed the results from AmerGens nuclear oversight department audits to determine whether the licensee met the requirements of the RETS and the ODCM.
b. Findings
Introduction.
The inspectors identified that quality assurance test results for effluent monitoring of Sr-89 and Sr-90 in the first quarter of 2006 did not meet test acceptance criteria and AmerGen had not evaluated the condition as of April 27, 2007. This finding was of very low safety significance and determined to be a non-cited violation (NCV) of technical specification 6.8.1i, Procedures and Programs.
Description.
AmerGen established an inter-laboratory cross-check program that provides known quantity radionuclide cross-check samples to its principle contract laboratory responsible for quantification of radioactivity analyses for its gaseous effluent program. In the first quarter of 2006, AmerGen provided, to its contract laboratory, a particulate effluent filter (Sample A20298-79) with a known spiked quantity of radioactivity (Sr-89 and Sr-90) for blind analysis. The laboratory results, for analysis and inter-comparison, were available the second quarter of 2006. The testing is used to validate quantification of Sr-89 and Sr-90 releases by the plant.
On April 27, 2007, the inspectors reviewed the inter-comparison analysis results and noted that the sample results did not meet their acceptance criteria. The inspectors notified chemistry personnel of this issue and identified that AmerGen personnel were not aware of these test results because they were not reviewed after the laboratory completed their analysis. This issue was documented by AmerGen in corrective action program condition report IR 622978.
AmerGen evaluated this issue and identified that its contract laboratory had satisfactorily quantified multiple other similar samples, from other facilities in 2006 with agreement in inter-comparison results. AmerGen reviewed its historical releases of these radionuclides and conducted an evaluation of projected radiation doses to members of the public for 2006 and concluded that no doses in excess of 10 CFR 50, Appendix I, had occurred. AmerGen did not identify any indication of increased or abnormal releases.
The inspectors also noted that Oyster Creek technical specification, section 6.8.1, requires that written procedures for quality assurance of effluent monitoring be established, implemented, and maintained covering quality assurance for effluent and environmental monitoring using the guidance in Regulatory Guide 4.15, revision 1, Quality Assurance for Radiological Monitoring Programs (Normal Operations)-Effluent Streams and Environmental Monitoring. Regulatory Guide 4.15 provides the NRCs regulatory position on an acceptable quality assurance program. The regulatory guide identifies the need for quality assurance procedures for timely review and analysis of data and that provisions be made for investigation and correction of recognized deficiencies including documentation of these actions.
Analysis.
The performance deficiency associated with this finding involved not performing a timely review and identifying that quality assurance test results for effluent monitoring did not meet acceptance criteria. A failure to implement adequate quality assurance for radioactive effluents could cause inaccurate quantification of effluents released and associated public dose projections. AmerGens corrective actions involved evaluating the test results to understand their potential impact to the public.
The finding was more than minor because it was associated with the effluent measurement quality control attribute of the public radiation 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 operations. In accordance with inspection Manual Chapter 0609, Appendix D, Public Radiation Safety Significance Determination Process, this finding was determined to be of very low safety significance (Green) the issue was not a radioactive material control issue, it involved the effluent release program, there was no impaired ability to assess dose, and public radiation doses did not exceed 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low As Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents, values.
The performance deficiency had a cross cutting aspect in the area of problem identification and resolution because AmerGen did not identify completely, accurately, and in a timely manner that the test results did not meet their acceptance criteria
Enforcement.
Technical Specification 6.8.1i, Procedures and Programs, requires that procedures for quality assurance of effluent monitoring be established, implemented, and maintained. Contrary to the above, AmerGen did not properly implement quality assurance effluent monitoring procedures which resulted in not identifying their first quarter 2006 test results for inter-laboratory blind cross-check samples of Sr-89 and Sr-90 on April 27, 2007 did not meet acceptance criteria. However, because the finding was of very low safety significance (Green) and has been entered in their corrective action program (IR
===622978), this violation is being treated as a NCV consistent with Section VI.A of the NRC Enforcement Policy, NUREG-1600. (NCV 05000219/2007003-01, Identification of Quality Assurance Test Results for Effluent Monitoring Not Meeting Acceptance Criteria)2PS3 Radiological Environmental Monitoring Program
a. Inspection Scope
=
The inspectors reviewed activities and documentation associated with the Radiological Environmental Monitoring Program (REMP) at Oyster Creek. The inspectors evaluated AmerGens performance against criteria contained in the Oyster Creek technical specifications, Amergens procedures, the REMP program requirements outlined in the ODCM, and NRC Branch Technical Position, Revision 1, An Acceptable Radiological Environmental Monitoring Program.
The inspectors reviewed the 2005 and 2006 Annual Environmental Monitoring Reports and Amergens assessment results to verify that the REMP was implemented as required by technical specifications and the ODCM. The inspectors reviewed the reports for changes to the ODCM with respect to environmental monitoring and commitments for sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and analysis of data. The inspectors also reviewed the UFSAR for information regarding the Oyster Creek environmental monitoring program and meteorological monitoring instrumentation; and the ODCM to identify environmental monitoring stations. The inspectors also reviewed AmerGens self-assessments, audits, licensee event reports, and interlaboratory comparison program results.
The inspectors walked down three air sampling stations (66, 71, 73) and four thermoluminescent dosimeter (TLD) monitoring stations (51, 66, 71, 73) to determine whether they are located as described in the ODCM and to assess the material condition of the equipment.
The inspectors observed the collection of two particulate and iodine samples from environmental monitoring stations (71, 73), the collection of groundwater (drinking water) from station 37, and surface water from station 33 to verify that the environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with applicable procedures.
The inspectors reviewed calibration testing records for the meteorological tower to verify that meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the UFSAR, NRC Regulatory Guide 1.23 Meteorological Monitoring Programs for Nuclear Power Plants, and AmerGen procedures. The inspectors compared meteorological instrument readouts in the control room (plant process computer) and at the tower for operability and evaluated readout data to identify if there were line loss differences between the control room and meteorological towers.
The inspectors reviewed each event documented in the Annual Environmental Monitoring Report that involved a missed sample, inoperable sampler, lost TLD, or anomalous measurement to determine the cause and AmerGens corrective actions.
The inspectors conducted a review of AmerGens assessment of positive sample results (i.e., licensed radioactive material detected above the lower limits of detection (LLDs)).
The inspector reviewed the associated radioactive effluent release data that was the likely source of the released material.
The inspectors reviewed any significant changes made by AmerGen to the ODCM as the result of changes to the land use census or sampler station modifications since the last inspection. The inspectors reviewed technical justifications for any changed sampling locations. The inspectors verified that the changes did not affect AmerGens ability to monitor the impacts of radioactive effluent releases on the environment. The inspectors also reviewed the calibration and maintenance records for selected air samplers.
The inspectors reviewed the results of REMP samples and AmerGens vendor laboratorys quality control program, including inter-laboratory comparison program, to verify the adequacy of the vendors program.
The inspectors reviewed audits and technical evaluations performed on the vendors program. The inspectors reviewed the results of the inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed and the quality control evaluation of the inter-laboratory comparison program and the corrective actions for any deficiencies. When applicable, the inspectors reviewed determination of any bias to the data and the overall effect on the REMP. The inspectors reviewed quality assurance audit results of the program to determine whether AmerGen met applicable technical specification and ODCM requirements.
The inspectors reviewed special reports, audits, and self assessments related to REMP, to determine if identified problems were entered into the corrective action program for resolution.
b. Findings
No findings of significance were identified
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Verification
a.
Inspection Scope (4 samples)
The inspectors reviewed AmerGens program to gather, evaluate, and report information on four performance indicators (PIs) associated with the initiating events and mitigating systems cornerstone. The inspectors used the guidance provided in Nuclear Energy Institute (NEI) 99-02, Revision 4, Regulatory Assessment Performance Indicator Guideline to assess the accuracy of AmerGens collection and reporting of PI data.
The inspectors reviewed operating logs, license event reports (LER), and corrective action program condition reports.
The inspectors verified the accuracy and completeness of the reported data between April 1, 2006 through March 30, 2007 for the following PIs:
- Unplanned Scrams per 7000 Critical Hours;
- Scrams with Loss of Normal Heat Sink;
- Unplanned Power Changes per 7000 Critical Hours; and
- Safety System Functional Failures - Boiling Water Reactor (BWR).
b. Findings
No findings of significance were identified.
4OA2 Identification and Resolution of Problems
.1 Review of Items Entered Into the Corrective Action Program
The inspectors performed a daily screening of items entered into AmerGens corrective action program to identify repetitive equipment failures or specific human performance issues for follow-up. This was accomplished by reviewing hard copies of each condition report, attending daily screening meetings, and/or accessing AmerGens computerized database.
.2 Semi-Annual Review to Identify Trends
Inspection Scope (1 sample)
The inspectors performed one semi-annual trend review. The inspectors reviewed AmerGens corrective action program documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors also performed a walkdown of equipment important to safety to ensure issues were being properly identified and tracked in the corrective action program. The review was focused on repetitive equipment problems, human performance issues, and program implementation issues. The results of the trend review by the inspectors were compared with the results of normal baseline inspections. The review included issues documented outside the normal corrective action system, such as in system health reports, nuclear oversight reports, and Oyster Creek monthly management reports.
The review considered a six-month period of January through June 2007.
Assessment and Observations No findings of significance were identified.
A substantive cross-cutting issue in the area of human performance at Oyster Creek was continued in the NRCs 2006 annual assessment letter, dated March 2, 2007.
Specifically, in 2006 AmerGen did not demonstrate consistent performance in the human performance cross-cutting aspect of procedure adherence. Oyster Creek continued its implementation of corrective actions and its excellence plan to improve plant performance in this area. AmerGen completed site-wide training on procedure use and adherence in the first quarter of 2007. The inspectors have noted improved and consistent performance in the area of procedure use and adherence in 2007 by Oyster Creek personnel. This was demonstrated by no inspection findings in the first and second quarter of 2007 due to procedure use and adherence issues, AmerGens performance indicators and trending, and self assessments performed by AmerGen during the past six months (corrective action program condition report IR 543262 and
===499162).
The NRC also identified in the 2006 annual assessment letter a human performance cross-cutting theme in human error prevention techniques (corrective action program condition report IR 577111). AmerGen completed site-wide training on human performance fundamentals in the second quarter 2007. The inspectors have also noted improvement in this area which is demonstrated by no inspection findings in the first six months of 2007 due to AmerGen personnel not properly implementing human error prevention techniques. As of the end of the inspection period, Oyster Creek is on track to perform fewer investigations into events/issues compared to 2006, which indicates an improvement in human performance.
The inspectors identified two potential low level adverse trends. AmerGen was is in the process of evaluating these issues and determining appropriate corrective actions. The first issue involves less than adequate problem identification of low level issues by engineering and operations personnel. The second issue deals with not ensuring up-to-date copies of procedures and operator aids were being maintained in the plant.
AmerGen documented these two issues in corrective action program condition reports IR 638389 and IR644373, respectively.
.3 Annual Sample Review
a. Inspection Scope
=
The inspectors reviewed AmerGens evaluation and corrective actions associated with the following issue.
Trunnion Room Fan Failure. The inspectors reviewed AmerGens evaluation and corrective actions associated with the unavailability of the 1-7' trunnion room recirculation fan due to a failure of overload relays in the breaker (motor control center)for the fan on November 23, 2006. The trunnion room contains the outboard main steam isolation valves and piping. The inspectors reviewed corrective action program condition report IR 561571 and the associated apparent cause evaluation against the requirements of AmerGens corrective action program to ensure that the full extent of the issue was identified, appropriate evaluations were performed, and corrective actions were specified and prioritized. The inspectors interviewed AmerGen personnel and reviewed work orders and procedures used to replace and maintain the overload relays.
The inspector reviewed the maintenance and replacement history of the overload relays on the 1-7' and the redundant 1-6' trunnion room recirculation fan to ensure its overload relays were not susceptible to a similar failure.
b. Findings and Observations
No findings of significance were identified. The apparent cause evaluation adequately determined the causes and extent of condition of the issue. The inspectors noted that AmerGen had relied on training (skill of the craft) of maintenance personnel during the November 2006 relay maintenance and calibration, which led to the relay failure and subsequent unavailability of the fan. The maintenance procedure has been updated to be more explicit in the calibration and replacement process of the overload relays. The inspector determined that the overall short term and proposed longer term corrective actions associated with the overload relays were reasonable and adequately prioritized.
4OA3 Event Followup
(1 sample)
.1 Forest Fire in Vicinity of Plant
a. Inspection Scope
On May 15, 2007, operations personnel were informed that a forest fire was identified approximately 10 miles southwest of the plant. The cause of the fire was attributed to an errant flare from a military aircraft during a training session over a section of the Pine Barrens in Ocean County, New Jersey. The fire was declared contained on May 18, 2007, after burning over 17,000 acres.
The inspectors observed the response of AmerGen personnel and reviewed AmerGens contingency plans and site preparations related to potential impact of the fire on the plant. The inspectors monitored offsite power parameters and verified offsite power requirements were being maintained in accordance with the Oyster Creek technical specifications. The inspectors monitored offsite emergency preparedness siren availability. The inspectors also reviewed 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors, to determine if this condition was reportable.
Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findings
No findings of significance were identified.
4OA5 Other
.1 (CLOSED) URI 05000219/2006005-05, Identification of Cesium 137 on AmerGens
Owner Controlled Property
a. Inspection Scope
On December 6, 2006, AmerGen received analytical results on environmental samples (soil and tree leaf) which were collected in August and September 2006 on portions of the owner controlled property that indicated detectable levels of Cesium (Cs)-137. The gamma spectroscopy analysis did not identify other radionuclides that would indicate plant related origin. The samples were supplemental samples taken in support of the REMP after the normal garden used for environmental sampling was unavailable because the garden crops had been eaten by wildlife.
The NRC initially reviewed and discussed this issue in NRC inspection report 05000219/2006005, dated January 18, 2007 (ADAMS Ascension No. ML070190461).
During that inspection the inspectors walk down areas of indicated elevated activity, collected and analyzed split samples with AmerGen and the State of New Jersey, and reviewed AmerGens initial evaluation of the issue. AmerGen concluded that there was no significant credible public or occupational doses associated with the identification of detectable levels of Cs-137 within the owner controlled area and that projected public doses were below 10 CFR 50 Appendix I and ODCM ALARA dose guidelines assuming continuos occupancy.
The inspectors conducted additional reviews of this issue and discussed the inspection results in NRC inspection report 05000219/2007002, dated May 7, 2007 (ADAMS Ascension No. ML070190461). During this inspection the inspectors did not identify any credible dose to members of the public due to the contamination. AmerGen concluded the contamination was associated with previous fallout associated with non-Oyster Creek sources (e.g., above grounds weapons testing). The inspectors continued to review data results at the conclusion of this inspection.
In the second quarter (April thru June) of 2007 the inspectors reviewed AmerGens evaluation into the likely sources of the contamination, the levels and specific radionuclides detected, and AmerGens effluent release deposition studies. The inspectors also reviewed the sample results including statistical analyses and minimum detection capabilities, radionuclides identified, and inter-comparison of sample analysis results verse up-wind control station sample analysis results. The inspectors review included the results of independent NRC split samples collected and analyzed by its contract laboratory, Oak Ridge Institute for Science and Education. The sample results can be found in the NRCs ADAMS and are dated January 12, 2007 (Accession Number: ML071830219); February 2, 2007 ( Accession Number: ML071830228); and May 4, 2007 (Accession Number: ML071830233)
b. Findings
No findings of significance were identified. This URI is closed.
AmerGens investigation concluded the source of the soil activity was due to fallout associated with deposition from sources not associated with Oyster Creek operations.
AmerGen further concluded that the variability of the analysis results was due to various environmental factors such as soil types, vegetation types, and differences in bio-accumulation. The inspectors did not identify Oyster Creek as the likely source of the levels of environmental radioactivity detected on its owner controlled area as a result of collection of alternate samples of broadleaf vegetation and supplemental soil samples.
The sample results identified were comparable to those expected associated with historical, non-plant related fallout.
4OA6 Meetings, Including Exit
Public Meeting. The NRC conducted a meeting with AmerGen on May 23, 2007, to discuss NRCs assessment of safety performance at Oyster Creek for the calendar year 2006. During the meeting Mr. S. Collins, Regional Administrator for the NRC Region 1 office, discussed Oyster Creeks performance with members of AmerGens management lead by Mr. T. Rausch, Station Vice President. The meeting was open for public observation. A copy of the slide presentation and a summary of the meeting can be found in ADAMS under accession numbers ML071510055 and ML071520436 Regional Administrator Site Visit. On May 24, 2007, a site visit was conducted by Mr.
S. Collins. During Mr. Collins visit, he toured the plant and met with AmerGen managers.
Division of Reactor Projects (DRP) Division Director Site Visit. On June 7, 2007, a site visit was conducted by Mr. D. Lew, DRP Division Director for the Region 1 office.
During Mr. Lews visit, he toured the plant and met with AmerGen managers.
Resident Inspector Exit Meeting. On July 6, 2007, the inspectors presented their overall findings to members of AmerGens management led by Mr. J. Randich and other members of his staff who acknowledged the findings. The inspectors confirmed that proprietary information reviewed during the inspection period was returned to AmerGen.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (green) was identified by AmerGen and is a violation of NRC requirements which meets the criteria of Section VI of the NRC Enforcement Policy, NUREG-1600, for being dispositioned as an NCV.
- 10CFR55.59(c) states, in part, that a facility licensee shall have a requalification program reviewed and approved by the Commission, and that this program must include comprehensive requalification written examinations and annual operating tests. The AmerGen procedure TQ-AA-106-0304 LORT Exam Development Job Aid, section 4.7.1.3.H.1, requires that each section of the operating exam shall be at least 50% unique when compared to all previous operating exams administered during the same annual operating test (i.e. 50% or less of the scenarios or JPMs selected for a specific exam have appeared on previous exams developed for the same annual operating test). In addition, section 4.7.2.A.6 requires that the exam developer verify that each scenario set includes 5 to 8 crew critical tasks. Contrary to the above, on February 2, 2007, AmerGen identified that four of seven exam sets for the 2006 annual operating test were less than 50% unique; and on May 31,2007 AmerGen identified that 5 of 43 operators evaluated in 2006 had been administered scenario sets which did not have at least 5 predetermined crew critical tasks.
The violation was of very low safety significance (Green) because after review of the 2006 operating test results, there was no indication that the exam was compromised or a reduction in discrimination validity occurred. This issue is described in corrective action program condition report IR 634123 and IR 634150. Amergens corrective actions involved verification of adequate operator performance on training exams subsequent to the last annual examination, and revision of the 2007 exam to include zero repeat of scenarios and to ensure adequate scenario set critical task content.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- R. Artz, Senior Chemist
- N. Boulware, Simulator Coordinator
- J. Costic, Operations Training Manager
- L. Craine, Radiological Engineer
- J. Dent, Director, Work Management
- J. Dostal, Shift Operations, Superintendent
- S. Dupont, Regulatory Assurance Specialist
- M. Filippone, System Engineer
- M. Godknecht, Programs Engineer
- S. Hutchins, Senior Manager Design Engineering
- T. Keenan, Manager Security
- D. Kettering, Director, Engineering
- J. Kandasamy, Manager, Regulatory Assurance
- G. Ludlam, Director, Training
- J. Magee, Director, Maintenance
- J. Makar, Senior Manager System Engineering
- J. Murphy, Radiological Protection Technical Manager
- P. Orphanos, Director, Operations
- D. Peiffer, Manager Nuclear Oversight
- M. Pruskowski, Environmental Engineer
- J. Randich, Plant Manager
- T. Rausch, Site Vice President
- J. Renda, Manager Radiation Protection
- T. Schuster, Manager Environmental/Chemistry Manager
- S. Schwartz, System Engineer
- T. Sexsmith, Manager Corrective Action Program
Others
- P. Schwartz, State of New Jersey, Bureau of Nuclear Engineering
- K. Toucillo, State of New Jersey, Bureau of Nuclear Engineering
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed
- 05000219/2007003-01 NCV Inadequate Identification of Unacceptable Quality Assurance Test Results for Effluent Monitoring (Section 2PS1)
Closed
- 05000219/2006005-05 URI Identification of Cesium 137 on AmerGens Owner Controlled Property (Section 4OA5)