IR 05000219/2008004

IR 05000219-08-004; on 07/01/08 - 09/30/2008; Amergen Energy Company, LLC, Oyster Creek Generating Station; Operability Evaluations

ML083030193
Person / Time
Site:	Oyster Creek
Issue date:	10/29/2008
From:	Bellamy R NRC/RGN-I/DRP/PB6
To:	Pardee C AmerGen Energy Co, Exelon Nuclear
BELLAMY RR
References
IR-08-004
Download: ML083030193 (37)

Text

UNITED STATES ber 29, 2008

SUBJECT:

OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2008004

Dear Mr. Pardee:

On September 30, 2008, the U. S. 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 October 10, 2008, with Mr. T.

Rausch, Site Vice-President, 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 this report. However, because of the very low safety significance and because they were entered into your corrective action program, the NRC is treating these 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. DPR-16 Enclosure: Inspection Report 05000219/2008004 w/Attachment: Supplemental Information cc w/encl:

C. Crane, President and Chief Operating Officer, Exelon Corporation M. Pacilio, Chief Operating Officer, Exelon Nuclear T. Rausch, Site Vice President, Oyster Creek Nuclear Generating Station J. Randich, Plant Manager, Oyster Creek Generating Station J. Kandasamy, Regulatory Assurance Manager, Oyster Creek R. DeGregorio, Senior Vice President, Mid-Atlantic Operations K. Jury, Vice President, Licensing and Regulatory Affairs P. Cowan, Director, Licensing B. Fewell, Associate General Counsel, Exelon Correspondence Control Desk, AmerGen Mayor of Lacey Township P. Mulligan, Chief, NJ Dept of Environmental Protection R. Shadis, New England Coalition Staff E. Gbur, Chairwoman, Jersey Shore Nuclear Watch E. Zobian, Coordinator, Jersey Shore Anti Nuclear Alliance P. Baldauf, Assistant Director, NJ Radiation Protection Programs

SUMMARY OF FINDINGS

IR 05000219/2008004; 07/01/08 - 09/30/2008; AmerGen Energy Company, LLC, Oyster Creek

Generating Station; Operability Evaluations The report covered a 3-month period of inspection by resident inspectors and regional reactor inspectors, and an announced inspection by a senior health physicist. In addition, an in-office review of pass/fail results for licensed operator requalification exams was conducted by a region-based 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.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a non-cited violation (NCV) of 10 CFR 50, Appendix B,

Criterion V, Instructions, Procedures, and Drawings, because AmerGen did not properly implement scaffolding control procedural requirements on August 11, 2008.

Specifically, AmerGen did not perform engineering evaluations for scaffolding constructed within the minimum allowed distance of safety-related equipment to determine its acceptability. AmerGens corrective actions included modifying or removing scaffold, conducting a briefing on this issue to all scaffold builders and supervisors, and scheduling a second brief for scaffold builders who arrive at Oyster Creek prior to the upcoming refueling outage.

This finding was more than minor because it was associated with the external factors attribute of the mitigating systems cornerstone and affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding was also similar to example 4.a in NRC Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, because AmerGen routinely did not perform evaluations for scaffolds constructed within the minimum allowed distance of safety related equipment. In accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to be of very low safety significance because it was not a design or qualification deficiency which resulted in a loss of operability or functionality, did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its technical specification allowed outage time, did not represent an actual loss of safety function of one or more non-technical specification trains of equipment designated as risk-significant 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 potentially risk significant due to a seismic, flooding or severe weather initiating event. The performance deficiency had a cross-cutting aspect in the area of human performance because AmerGen did not follow procedures and obtain engineering evaluations for scaffold that did not meet the requirements contained in procedures for scaffold installation in the plant H.4(b).

(Section 1R15)

Licensee-Identified Violations

A violation of very low safety significance, which was identified by AmerGen has been reviewed by the inspectors. Corrective actions taken or planned by AmerGen have been entered into AmerGens corrective action program. This violation and the 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 several occasions during the summer months (July 12, 19, 20, 21, 22, 23, and September 5 2008) operators performed unplanned power reductions in accordance with operating procedures for several hours to maintain the plants circulating water discharge temperatures below Oyster Creeks environmental discharge permit requirements.

Operators performed planned power reductions to 85% for rod pattern adjustments on July 12, August 2, and August 23, 2008.

Oyster Creek ended the inspection period at 98% due to end-of-cycle operations.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

a.

Inspection Scope (1 sample)

The inspectors performed one site specific weather-related condition inspection. The inspectors reviewed AmerGens preparations for Hurricane/Tropical Storm Hanna from September 3 thru September 5, 2008, which was expected to produce heavy rain and high wind conditions. The inspectors verified that AmerGen personnel effectively implemented severe weather preparation procedures. The inspectors performed walk downs of areas that could be potentially impacted by the anticipated weather conditions such as the intake, the transformer area, the diesel generator building, turbine building roof and exposed areas in the protected area. The inspectors reviewed corrective action program condition reports and the status of ongoing maintenance activities to ensure the readiness of safety and support systems. The inspectors observed hurricane preparedness meetings and verified that required briefings were conducted with operations personnel. The inspectors monitored the status of the plant through periodic communications with operations personnel during the period of adverse weather.

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 (3 samples)

The inspectors performed three partial equipment alignment inspections. The partial equipment alignment inspections were completed during conditions when the equipment was of increased risk 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 functions:

• Service Water System, on July 2, 2008;

• Containment Spray System #2 on July 8, 2008; and

• 1-1 and 1-2 diesel driven fire pumps on August 14-15, 2008.

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

(71111.05Q - 4 samples)

The inspectors performed a walkdown of four 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 Creek Fire Hazards Analysis Report and Oyster Creek Pre-Fire Plans 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. The following plant areas were inspected:

• Turbine building basement (south) on August 11, 2008;

• Emergency diesel generator fuel oil storage area on August 13, 2008;

• Reactor building (23 elevation) on August 14, 2008; and

• C Battery room on August 25, 2008.

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

b. Findings

No findings of significance were identified.

1R06 Flood Protection Measures

a. Inspection Scope

(2 samples)

The inspectors performed two internal flood protection inspection activities. The inspectors reviewed the flood protection measures contained in the upper cable spreading room in the turbine building and the northwest corner room of the reactor building (contains the A and C core spray pumps and control rod drive 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 the areas.

The inspectors reviewed preventative maintenance activities associated with flood protection equipment. The inspectors also reviewed AmerGens procedures related to flooding of these areas. Documents associated with these reviews 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

(71111.11B - 1 sample &

==71111.11Q - 1 sample) The inspectors performed one region-based review of the 2008 Oyster Creek licensed

==

operator requalification examination results and one simulator training observation.

On August 25, 2008, a region-based inspector conducted an in-office review of the 2008 licensee-administered annual operating test and comprehensive written exam results.

The inspectors assessed whether pass rates were consistent with the guidance of NRC Inspection Manual Chapter (IMC) 0609, Appendix I, AOperator Requalification Human Performance Significance Determination Process (SDP).@ The inspectors verified that:

• Crew failure rate was less than 20%. (Crew failure rate was 0%)

• Individual failure rate on the dynamic simulator test was less than or equal to 20%.

(Individual failure rate was 0%)

• Individual failure rate on the walk-through test was less than or equal to 20%.

(Individual failure rate was 0%)

• Individual failure rate on the comprehensive written exam was less than or equal to 20%. (Individual failure rate was 0%)

• Overall pass rate among individuals for all portions of the exam was greater than or equal to 75%. (Overall pass rate was 100%)

The inspectors observed a simulator training scenario to assess operator performance and training effectiveness on August 4, 2008. The inspectors observed training scenarios OBE 08-5.1 and OBE 08-5.2. The inspectors assessed whether the simulator adequately reflected the expected plants response, 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.

b. Findings

No findings of significance were identified.

1R12 Maintenance Effectiveness

a. Inspection Scope

(1 sample)

The inspectors performed one maintenance effectiveness inspection activity. The inspectors reviewed the following degraded equipment issue in order to assess the effectiveness of maintenance by AmerGen:

• C emergency service water (ESW) pump packing failure on July 7, 2008 (IR

===796449).

The inspectors verified that the component was being 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. The inspectors reviewed completed maintenance work orders and procedures to determine if inadequate maintenance contributed to equipment performance issues. The inspectors also reviewed applicable work orders, corrective action program condition reports, operator narrative logs, and vendor manuals.

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

b. Findings

No findings of significance were identified.

=

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

• A isolation condenser (IC) unavailable due to planned maintenance (testing), B IC in manual, and severe thunderstorms in the area on July 23, 2008;

• 1-2 condensate transfer pump and 1-3 station air compressor unavailable due to planned maintenance during main steam isolation valve closure testing on August 11, 2008;

• 1-1 condensate transfer pump and redundant fire pump unavailable due to planned maintenance; and containment spray system #1 unavailable for planned surveillance testing on August 18, 2008;

• Core spray system #2 and the redundant fire pump unavailable due to planned maintenance during maintenance activities in the switchyard on August 25, 2008;

• Core spray system #2 and redundant fire pump unavailable due to planned maintenance; and the B 125VDC battery charger (rotary) unavailable due to unplanned maintenance to repair an electrical ground on August 28, 2008; and

• B control rod drive pump, B control room heating ventilation and air conditioning (HVAC), and B IC unavailable due to planned maintenance on August 23, 2008.

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 (when applicable) 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

(9 samples)

The inspectors reviewed nine operability evaluations for degraded or non-conforming conditions associated with:

• Service water pipe leak on flange connection to chlorination pipe on July 17, 2008 (IR 797406);

• Reactor building ventilation exhaust isolation valve/damper V-28-22 closed indication did not illuminate on July 29, 2008 (IR 801408);

• B control room HVAC unplanned shutdown on August 6, 2008 (IR 804233);

• Installation of scaffolding around safety related equipment not in accordance with Oyster Creek procedures on August 14, 2008 (IR 807796)

• Reactor building ventilation exhaust isolation valve/damper V-28-22 not fully closed on August 20, 2008 (IR 808623);

• Core spray system #2 reduction in flow on August 26, 2008 (IR 811067);

• B 125V DC electrical ground indication on August 27, 2008 (IR 811498);

• Service water pump 1-1 and 1-2 do not meet surveillance test criteria on September 16 and September 22, 2008 (IR 818629 and IR 820732); and

• Automatic depressurization system downcomer vacuum breaker surveillance on September 22, 2008 (IR 820935).

The inspectors reviewed 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 (when applicable).

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

b. Findings

Introduction.

The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because AmerGen did not properly implement scaffolding control procedural requirements on August 11, 2008. Specifically, AmerGen did not perform engineering evaluations for scaffolding constructed within the minimum allowed distance of safety-related equipment to determine its acceptability. AmerGens corrective actions included modifying or removing scaffold, conducting a briefing on this issue to all scaffold builders and supervisors, and scheduling a second brief for scaffold builders who arrive at Oyster Creek prior to the upcoming refueling outage.

Description.

On August 11, 2008, during a plant status walk down in the reactor building, the inspectors noted that scaffold constructed in the vicinity of the D core spray booster pump and control rod hydraulic control units were not in accordance with procedure MA-796-024-1001, Scaffolding Criteria for the Mid Atlantic Stations.

Specifically, the scaffolds had runners, diagonal bracing, and railings that were within the minimum allowed distance of safety related equipment as specified in the procedure.

The inspectors discussed this issue with engineering and operations personnel, and AmerGen reviewed the inspectors concerns. AmerGen concluded that the scaffold was not built in accordance with procedure MA-796-024-1001 and was corrected by maintenance personnel.

On August 15, 2008, AmerGen performed an extent of condition review of the installed scaffolds within the plant. AmerGen identified ten scaffolds that were within the minimum allowed distance to safety related equipment (scram discharge header, hydraulic control units, core spray booster pumps, electrical cable trays, containment spray system piping, and 125 VDC motor control center) which had not been evaluated by engineering personnel to determine the acceptability of these as-built configurations per procedure MA-796-024-1001. AmerGen documented the concern and the results of the extent of condition review in corrective action program condition report IR 807796.

Engineering personnel evaluated the scaffolds in accordance with the procedure and determined that the scaffolds were acceptable and would not significantly impact safety related equipment during a seismic event. Engineering personnel also determined that several of the scaffolds required minor modifications.

The inspectors noted an additional example of a scaffold built in close proximity to safety related equipment (B IC drain line) on September 29, 2008, during routine plant status walk downs. The inspectors determined that the scaffold was not constructed per the requirements of MA-AA-796-024-1001; and that an engineering evaluation had not been requested or completed to evaluate the acceptability of this scaffold. AmerGen documented the inspectors concerns in corrective action condition report IR 826505 and an engineering evaluation was completed.

AmerGen performed an evaluation (IR 807796) of this issue and determined that maintenance personnel did not properly implement the scaffold control procedural requirements. Specifically, AmerGen personnel responsible for building scaffold did not request (through the work management system) engineering evaluations for acceptability of scaffolding that could not be built in accordance with the requirements of procedure MA-AA-796-024-1001. AmerGens corrective actions included modifying or removing scaffold, conducting a briefing on this issue to all scaffold builders and supervisors, and scheduling a second brief for scaffold builders who arrive at Oyster Creek prior to the upcoming refueling outage.

The performance deficiency associated with this finding involved AmerGen not properly implementing scaffolding control requirements contained in procedure MA-AA-796-024-1001. On several occasions AmerGen did not perform engineering evaluations for scaffolding constructed within the minimum allowed distance of safety-related equipment to determine its acceptability.

Analysis.

This finding was more than minor because it was associated with the external factors attribute of the mitigating systems cornerstone and affected the objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. This finding was also similar to example 4.a in NRC Inspection Manual Chapter (IMC) 0612, Power Reactor Inspection Reports, Appendix E, Examples of Minor Issues, because AmerGen routinely did not perform evaluations for scaffolds constructed within the minimum allowed distance of safety related equipment.

In accordance with IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, the finding was determined to be of very low safety significance because it was not a design or qualification deficiency which resulted in a loss of operability or functionality, did not represent a loss of system safety function, did not represent an actual loss of safety function of a single train for greater than its technical specification allowed outage time, did not represent an actual loss of safety function of one or more non-technical specification trains of equipment designated as risk-significant 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 potentially risk significant due to a seismic, flooding or severe weather initiating event.

The performance deficiency had a cross-cutting aspect in the area of human performance because AmerGen did not follow procedures and obtain engineering evaluations for scaffold that did not meet the requirements contained in procedures for scaffold installation in the plant H.4(b).

Enforcement.

10 CFR Part 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures. Exelons maintenance procedure MA-MA-796-024-1001 is a procedure affecting quality that establishes the minimum clearance between scaffolds and plant equipment. This procedure states, in part, that if a scaffold cannot be built in accordance with the guidelines, engineering approval per an (work management action request) evaluation shall be obtained. Contrary to the above, prior to August 11, 2008 and on September 29, 2008, AmerGen did not request or evaluate scaffolding constructed within the minimum allowed distance of safety-related equipment. Because this issue is of very low safety significance (Green) and AmerGen entered this issue into their corrective action program in condition report IR 807796 and 826505, this violation is being treated as an NCV consistent with Section VI.A.1 of the NRC Enforcement Policy.

(NCV 05000219/2008004-01: Scaffold Installation Procedure Not Properly Implemented)

1R18 Plant Modifications

a. Inspection Scope

(1 sample)

The inspectors reviewed one permanent plant modification that was installed when Oyster Creek was on line. The permanent modification involved installation of an alternate cooling water supply to the shutdown cooling (SDC) system (ECR-OC-07-

===00766-001). Specifically, the reactor building closed cooling water (RBCCW) system and the turbine building closed cooling water (TBCCW) system was modified to allow the TBCCW system to provide cooling water to the SDC system during an outage instead of the RBCCW system.

The inspectors reviewed the engineering change package, design basis and licensing basis documentation to ensure that the SDC system could operate as designed when cooling water was supplied by the TBCCW system during outage conditions and that the functions of the RBCCW system were not affected during normal operations. The inspectors walked down portions of the systems while the modification was being installed. The inspectors ensured that revisions to licensing and design documents and operating procedures were being made and would support operations when the modification was completed. The inspectors also reviewed AmerGens 10 CFR 50.59 screening for the modification. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

=

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

• C ESW pump on July 15, 2008 (WO C2016038);

• B condensate transfer pump on August 14, 2008 (WO R2091031);

• 1-2 diesel driven fire pump on August 1, 2008 (WO M2202273); and

• Reactor building ventilation exhaust isolation valve/damper V-28-22 on August 20, 2008 (WO C2018757).

The inspectors verified that the post-maintenance tests 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.

1R22 Surveillance Testing

a. Inspection Scope

(5 samples - 2 IST, 2 Routine Surveillance, and 1 RCS)

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

• Containment spray and ESW system #1 in-service test (IST) on July 8, 2008;

• Reactor coolant system (RCS) leakage detection (unidentified leakage) on July 10, 2008;

• #1 diesel driven fire pump operability test on August 1, 2008;

• Main steam line high flow test and calibration on September 3, 2008; and

• 1-1 service water pump comprehensive IST on September 16, 2008.

The inspectors verified that test data was complete and met procedural requirements to demonstrate the 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.

Cornerstone: Emergency Preparedness [EP]

EP 6 Drill Evaluation (71114.06)

a. Inspection Scope

(1 sample)

The inspectors observed one operator requalification activity on August 12, 2008, that counted as input into the NRCs emergency response drill and exercise performance indicator (PI). The inspectors observed AmerGens critique of the training activity to verify that weaknesses and deficiencies were adequately identified. The inspectors 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 [OS]

2OS1 Access Control to Radiologically Significant Areas (71121.01) a.

Inspection Scope (3 samples)

The inspectors reviewed activities and associated documentation in the area of access control to radiologically significant areas. The inspectors evaluated AmerGens performance against criteria contained in 10 CFR 19 (Notices, Instructions, and Reports to Workers: Inspection and Investigation), 10 CFR 20 (Standards For Protection Against Radiation), AmerGen procedures, and Oyster Creek Technical Specifications.

The inspectors, as part of their inspection planning, reviewed NRC PI data associated with the Occupational Exposure Cornerstone. The inspectors reviewed internal dose assessments for 2008 to identify apparent occupational internal doses greater than 50 millirem committed effective dose equivalent (CEDE). The inspectors also reviewed AmerGen airborne radioactivity controls and the program which monitors potential intakes associated with hard-to-detect radionuclides (e.g., transuranics).

The inspectors reviewed AmerGens performance in the area of external occupational exposure control including instances of personnel contamination (when applicable). The inspectors also reviewed how AmerGen uses effective dose equivalent for external exposure control.

The inspectors conducted plant tours and observed work activities to assess radiation worker performance and the technical proficiency of radiation protection technicians.

The inspectors also reviewed corrective action program condition reports associated with radiation worker and radiation protection technician errors to ensure problems in this area were being properly characterized, prioritized, and resolved (including review of corrective actions). The inspectors also assessed the technical proficiency of radiation protection workers during discussions and observations of radiation protection workers.

The inspector reviewed self-assessments and audits related to access control to radiological areas to determine if identified problems were entered into the corrective action program for resolution. The inspectors reviewed corrective action program condition reports to determine if repetitive issues were occurring that could lead to more significant problems. The review also included an evaluation of corrective action program condition reports to determine if any problems involved NRC PI events with dose rates greater that 25 R/hr at 30 centimeters, greater than 500 R/hr at 1 meter, and unintended exposures greater than 100 millirem total effective dose equivalent (TEDE),or 5 rem shallow dose equivalent (SDE), or 1.5 rem lens dose equivalent (LDE).

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

b. Findings

No findings of significance were identified.

2OS2 ALARA Planning and Controls (71121.02) a.

Inspection Scope (2 samples)

The inspectors reviewed activities and documentation associated with radiological planning and controls to determine if AmerGen was implementing operational, engineering, and administrative controls to maintain personnel occupational radiation exposure as low as is reasonably achievable (ALARA). The review evaluated AmerGens performance against criteria contained in 10 CFR 19, 10 CFR 20, AmerGen procedures, and applicable industry standards.

The inspectors, as part of their inspection planning, reviewed information regarding Oyster Creeks collective dose history, current exposure trends, and ongoing and planned activities in order to assess current exposure performance and potential challenges. The inspectors evaluated Oyster Creeks collective exposure (using NUREG-0713 and plant historical data) and source-term (average contact dose rate with reactor coolant piping) measurements. The inspector reviewed AmerGens procedures associated with maintaining occupational exposures ALARA, and the process used to estimate and track work activity radiation exposures.

The inspectors reviewed AmerGens planning and preparation for the upcoming refueling outage to determine if AmerGen had established procedures, engineering controls, and work controls, based on sound radiation protection principles, to achieve occupational exposures that were ALARA. For planning purposes, the inspectors selected work activities likely to result in the highest personnel collective exposures and reviewed the planning and preparation for those work activities to determine if ALARA requirements were integrated into work orders and radiation work permit documents.

Specifically, the inspectors reviewed work activities associated with under vessel work/control rod drive change-out, insulation activities, in-service inspections, scaffolding activities, shielding activities, valve work activities, and radiological controls coverage.

The inspectors also reviewed AmerGens dose goals for the upcoming refueling outage.

The inspectors reviewed and evaluated how source term controls were being maintained by operations, radiation protection, and other work groups. Specifically, the inspectors reviewed AmerGens plans and evaluations associated with source term and measured drywell radiation base-point measurements. The inspectors reviewed how AmerGen was utilizing shielding and other techniques (e.g., decontamination) to reduce worker exposure during work activities. The inspectors reviewed recent Oyster Creek ALARA Committee meeting minutes. The inspector also reviewed Oyster Creeks five year exposure reduction plan.

The inspector reviewed self-assessments and audits related to ALARA planning and control to determine if identified problems were being entered into the corrective action program for resolution.

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

b. Findings

No findings of significance were identified.

2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)

a. Inspection Scope

(1 sample)

The inspectors reviewed activities and documentation associated with radiation monitoring instrumentation and protective equipment. The review evaluated AmerGens performance against criteria contained in 10 CFR 20, AmerGen procedures, and Oyster Creek Technical Specifications.

The inspectors reviewed corrective action program condition reports associated with radiation monitoring instrumentation and protective equipment to ensure problems in this area were being properly characterized, prioritized, and resolved (including review of corrective actions). Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings

No findings of significance were identified.

OTHER ACTIVITIES

[OA]

4OA1 Performance Indicator Verification

a. Inspection Scope

(2 samples)

The inspectors reviewed data associated with two PIs. The inspectors used the guidance provided in Nuclear Energy Institute (NEI) 99-02, Regulatory Assessment Performance Indicator Guideline to assess the accuracy and completeness of the PI data. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

The inspectors reviewed AmerGens reported July 1, 2007 through June 30, 2008 data for the following PIs:

• Reactor Coolant Activity; and

• Reactor Coolant System Leakage.

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, or accessing AmerGens computerized database.

.2 Annual Sample Review

a. Inspection Scope

(1 Annual samples)

The inspectors reviewed AmerGens evaluation and corrective actions associated with the following issue. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

Heavy Load Handling Activities. The inspectors reviewed AmerGens activities and corrective actions associated with the implementation of NUREG-00612 and NUREG-

===00554 for the lifting of heavy loads (IR 685675 & 754875). The inspectors reviewed procedures applicable to the use of overhead cranes, lifting requirements and load paths, and crane operator qualifications. The inspectors also reviewed training and qualification records for personnel who perform crane operations. The inspectors reviewed corrective action program condition reports for the previous two years associated with crane issues to ensure the issues were properly evaluated and corrective actions were specified and prioritized. The inspectors interviewed engineering personnel and toured the refuel floor and heater bay roof to observe safe load paths and lay down areas.

b. Findings and Observations

No findings of significance were identified.

Heavy Load Handling Activities. The inspectors determined that, corrective actions taken to address IR 685675 and 754875 were reasonable and adequate. The inspectors noted that AmerGen demonstrated in-depth review of closure response to condition report IR 754075.

The inspectors noted that the reactor building crane had been used when degraded conditions existed. The Oyster Creek reactor building crane is a single failure proof crane, and operating it with degraded condition, could challenge the cranes defense in depth. Specifically, since June 2008 during operation of the crane, the brakes locked twice preventing crane movement. AmerGen was aware of deficiencies that could have potentially impacted the operations of the crane, however corrective actions were not prioritized in a manner to resolve the issues prior to the cranes next scheduled use. This issue was determined to be minor because there was no condition where loss of control of a load was present. See Section 4OA3.3 for additional information on this issue.

The inspectors also noted that wording in procedures, MA-OC-205-001, Reactor Pressure Vessel Disassembly and MA-OC-205-002, Reactor Pressure Vessel Reassembly, would have allowed the lead maintenance technician to determine new lay down areas or new load paths without an engineering analysis. AmerGen documented this observation in corrective action program condition report IR 821880 to evaluate the need to revise the procedures to preclude this from occurring.

In addition, the inspectors identified some differences between Oyster Creeks crane operator qualification procedure, 2400-ADM-3891.01, Crane Operator Qualifications, and the corporate implementation of the program for non-site employees. Specifically, the procedure requires reactor building crane operators to complete N-OC-2674.920.0.0006, Reactor Building Crane Training, in addition to the N-TO-MM-252.00, Cranes, Operate Overhead, qualification while the corporate implementation of the program requires procedure N-TO-MM-252.00 and a pre-job brief on the reactor building crane. AmerGen documented the observation in corrective action program condition report IR 822679 to evaluate the need to revise the corporate procedure.

=

The inspectors performed five event followup inspection activities. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

.1 Loss of Emergency Communication Capability

a. Inspection Scope

On July 3, 2008, Oyster Creek experienced a loss of offsite communication capability.

Specifically, the conventional phones and the EP notification phone lines were not functional. Operations personnel had the ability to communicate with local and state authorities with cell phones. AmerGen restored all EP communication capability within two hours of identifying the problem. AmerGen reported this event to the NRC in Event Notification 44334, Loss of Commercial Telephone and Dedicated EP Landlines.

On September 29, 2008, Oyster Creek experienced another loss of offsite communication capability. Specifically, the on-site phone system and the NRC emergency notification system (ENS) were not functional. Operations personnel established communication capability with the NRC through the use of cell phones, and verified that EP notification phone lines to the state and local authorities were not impacted. AmerGen reported this event to the NRC in Event Notification 44526, Loss of Internal Phone System.

The inspectors verified that operations personnel responded in accordance with procedures and communications were properly re-established. At the time of the events the inspectors verified that conditions did not meet the criteria for an emergency action level (EAL) declaration as described in the Oyster Creek EAL matrix. In addition, the inspectors reviewed 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors to verify that AmerGen properly notified the NRC of the events.

The inspectors also reviewed control room narrative logs and discussed the issue with operation and regulatory assurance personnel.

AmerGen documented these issues in corrective action program condition reports IR 793184 and 823902.

b. Findings

No findings of significance were identified.

.2 Reactor Building Crane Stopped During Cask Lift

a. Inspection Scope

On July 15, 2008, the reactor building crane at Oyster Creek stopped moving during a lift of a cask from the spent fuel pool. The cask remained suspended approximately 20 ft off the bottom of the pool and approximately 5 ft underwater during troubleshooting by AmerGen personnel. The cask contained processed control rod blades and used nuclear instrumentation.

The inspectors arrived on site after being informed of the issue and remained onsite to monitor AmerGens response to this issue. The cask was safely placed on the spent fuel floor on July 16, 2008 after AmerGen personnel identified a gear limit switch on the cranes hoist that needed to be adjusted. The inspectors performed a walkdown of the spent fuel pool area and discussed the issue with AmerGen personnel in order to understand the extent of the issue and the actions taken. The inspectors reviewed control narrative logs and system drawings to understand the issue. The inspectors also monitored radiation dose rates in the spent fuel pool area to ensure that dose rates were within anticipated values.

AmerGen documented this issue in corrective action program condition report IR 796853. NRC inspection report 05000219/2008009 contains additional information on this issue.

b. Findings

No findings of significance were identified.

.3 Service Water Pipe Leak

a. Inspection Scope

On July 17, 2008, operations personnel identified a 600 gpm leak on a flange connection from the chlorination system to the service water system. The leak was located on a portion of piping that is located below the intake structure. Based on the location of the leak, the leakage discharged directly into the intake. Operations personnel implemented ABN-18, Service Water Failure Response, and monitored equipment performance and plant parameters to assess the impact of the reduced service water flow. AmerGen personnel also removed the chlorination system from service to ensure the leak would not result in an impact to the environment. On July 19, 2008, AmerGen determined that they would not repair the leak until their next refueling outage because access to the location was extremely limited with the plant operating. AmerGen also reestablished chlorination to the ESW and RBCCW systems by installing a temporary modification which created a new chlorination injection point. AmerGen personnel also performed additional monitoring and developed an operability determination which concluded that the system remained functional but degraded.

The inspectors responded to the control room following site announcement of the service water leak and observed the response of AmerGen personnel to the event, including operator actions in the control room. The inspectors also reviewed technical specification requirements to ensure that Oyster Creek operated in accordance with its operating license. The inspectors reviewed process plant computer (PPC) data, control room logs, walked down the service water system, and discussed the issue with AmerGen personnel to gain an understanding of how operations personnel and plant equipment responded. The inspectors also reviewed the operability determination that was performed (per section 1R15 in this report).

AmerGen documented this issue in corrective action program condition reports IR 797406 and 797641.

b. Findings

No findings of significance were identified.

.4 Elevated Unidentified Leakage

a. Inspection Scope

In September 2008, AmerGen performed an evaluation (IR 811541) per procedure OP-AA-106-101-1006, Operational and Technical Decision Making Process, to determine the potential sources and if additional actions should be taken at Oyster Creek based on an increasing trend in unidentified leakage in the drywell. AmerGens evaluation determined that several control rod drive mechanisms (CRDMs) and the C reactor recirculation pump seal were the likely sources of the leakage. The evaluation also identified several actions for operations personnel to perform in order to reduce the unidentified leakage rate. In September 2008, AmerGen took the following actions which resulted in a significant reduction in the unidentified leakage value: isolated cooling water to CRDM 30-35; inserted control rod 26-35; and isolated C reactor recirculation pump.

The inspectors monitored unidentified leakage and AmerGens actions in accordance with IMC 2515, Appendix D, Plant Status. The inspectors ensured that Oyster Creek was being operated in accordance with technical specifications requirements, and that operations and engineering personnel were appropriately monitoring changes in the unidentified and identified leak rates in accordance with procedures and instructions.

The inspectors, with assistance from regional inspectors and NRR technical staff, independently reviewed AmerGens evaluation, which included reviewing trend data associated with drywell sump chemistry analysis, unidentified drywell leakage, identified drywell leakage, recirculation pump seal pressure, and drywell temperature, pressure, air particulate, and radiation levels. The inspectors also observed Oyster Creeks plant onsite review committee (PORC) which discussed the conclusions and actions contained in evaluation IR 811541.

b. Findings

No findings of significance were identified.

.5 Water with Tritium Identified in Excavation Area Within the Protected Area

a. Inspection Scope

On September 8, 2008, AmerGen conducted radiological analysis of surface water (puddle) that was identified in a shallow excavation area created to support installation of a new clean water storage tank. The water had collected in the area, and AmerGen attributed the water to a rain storm that had occurred between September 6 and 7, 2008.

AmerGen sampled the water and the analysis identified levels of tritium that were below the Environmental Protection Agencys drinking water standards in the sample.

AmerGen took immediate actions to collect and drum the residual water and initiated an investigation to determine the source of the tritium. AmerGen documented this issue in corrective action program condition report IR 815415.

The inspectors performed a visual inspection of the excavation area and reviewed the results of AmerGens analyses of the surface water samples. The inspectors observed follow-up well sampling that was performed by AmerGen and discussed this issue with AmerGen personnel. The inspectors also evaluated potential sources of the tritium including recent pipe cutting, in the excavation, of a Torus Water Storage Tank (TWST)line. In addition, the inspectors reviewed AmerGen procedures (developed in support of the Nuclear Energy Institute (NEI) groundwater protection initiative) to verify that AmerGen properly reported this event. The inspectors also reviewed sample results and discussed with AmerGen personnel their preliminary conclusions on the source of the tritium in the samples.

b. Findings

& Observations No findings of significance were identified. An unresolved item (URI) was identified to review AmerGens corrective action program evaluation (IR 815415) regarding the identification of tritium in a September 8, 2008 surface water sample from a puddle of water in an excavation area within the protected area.

Based on preliminary reviews and observations, the inspectors did not identify an immediate public health and safety concern. In addition, no indication of contamination of drinking water aquifers was identified by the inspectors.

AmerGen performed an initial evaluation to determine the potential source of the tritium in the samples collected. The evaluation included a review of potential active or historical leakage in the area; potential occurrence of a water spill associated with cutting of the torus water storage tank piping located in the excavation area; problems with water sampling (including sample collection, preparation, and counting); and potential washout of tritium from station effluents. To support their evaluation, AmerGen collected groundwater samples from various wells surrounding the area and collected multiple soil samples along the length of the TWST piping, including the location of the puddle.

AmerGens evaluation, which continued at the conclusion of this inspection period, indicated the likely cause of the indication of tritium in the water sample was due to an inadvertent cross-contamination of the sample from the use of glassware in the chemistry laboratory. The evaluation also initially concluded that the indication of tritium was not due to a past spill or an active pipe leak, that water had not spilled during cutting of piping in the excavation area, or that rain water washout caused tritium to appear in the sample of the water puddle. AmerGen initiated corrective actions to improve sample preparation and counting, including detection of potential sample cross-contamination.

The inspectors plan to review this evaluation after it is completed. (URI 05000219/2008004-02, Water with Tritium Identified in Excavation Area within the Protected Area)

4OA5 Other

.1 Quarterly Resident Inspector Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted the following observations of security force personnel and activities to ensure that the activities were consistent with AmerGen security procedures and regulatory requirements relating to nuclear plant security. These observations took place during normal plant working hours. Specifically, the inspectors:

• Observed operations within the central and secondary security alarm stations;

• Toured selected security towers and security officer response posts;

• Observed security force shift turnover activities;

• Observed security equipment testing;

• Observed security officers on compensatory posts; and

• Reviewed corrective action program condition reports associated with security related issues.

The inspectors also reviewed a report of the results of a survey of the site security organization relative to its safety conscious work environment (SCWE). The inspectors considered whether the surveys were conducted in a manner that encouraged candid and honest feedback. The results were reviewed to determine whether adequate number of staff responded to the survey. The inspectors also reviewed Exelons self-assessment (IR 807160) of the survey results and verified that any issues or areas for improvement were entered into the corrective action program for resolution.

These quarterly resident inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of inspectors normal plant status review and inspection activities.

.2 Implementation of Temporary Instruction (TI) 2515/176 - Emergency Diesel Generator

Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing

a. Inspection Scope

The objective of TI 2515/176, Emergency Diesel Generator Technical Specification Surveillance Requirements Regarding Endurance and Margin Testing, is to gather information to assess the adequacy of nuclear power plant emergency diesel generator endurance and margin testing as prescribed in plant-specific technical specifications.

The inspectors reviewed emergency diesel generator ratings, design basis event load calculations, surveillance testing requirements, and emergency diesel generator vendors specifications and gathered information in accordance with TI 2515/176.

The inspectors assessment and information gathered while completing this TI was discussed with AmerGen personnel. This information was forwarded on to the NRCs Office of Nuclear Reactor Regulation for further review and evaluation.

b. Findings

No findings of significance were identified.

4OA6 Meetings, Including Exit

Resident Inspector Exit Meeting. On October 10, 2008, the inspectors presented their overall findings to members of AmerGens management led by Mr. T. Rausch, Site Vice-President, 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.

Director - Division of Reactor Projects Site Visit. On September 9, 2008, a site visit was conducted by Mr. D. Lew, (Division of Reactor Projects, Director), for the NRCs Region I Office. During Mr. Lews visit, he met with AmerGen managers and observed the Emergency Preparedness Hostile Action Based Drill.

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.

• 10 CFR 50.55a, Codes and Standards, requires that systems and components of boiling and pressurized water-cooled nuclear power reactors shall meet the requirements of the ASME Boiler and Pressure Vessel Code. Contrary to this, AmerGen did not perform an accelerated IST of the 1-1 service water pump in August 2008, as required by the ASME code when the pumps performance was evaluated to be in the alert range during its quarterly IST on June 19, 2008. The following quarterly IST on September 16, 2008 showed the pumps performance to be in the action range. The increased frequency testing was not performed because the work order to perform the testing was not properly coded in the work management system. AmerGen performed a technical evaluation and determined that the cause of the degradation in the pumps performance was due to a system degradation, specifically system leakage, and verified that the pump was operating satisfactorily and was not degraded. The violation was of very low safety significance because the deficiency was a qualification issue that did not result in the loss of operability of the system or component. The issue is described in corrective action program condition reports IR 820700 and CR 787909. Corrective actions involved AmerGen performing an extent of condition review on work orders involving surveillance testing and ISTs to ensure they were properly coded and scheduled correctly.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

J. Dent, Director, Work Management

J. Dostal, Shift Operations, Superintendent

S. DuPont, Regulatory Assurance Specialist

D. Hinchliffe, System Engineer

T. Keenan, Manager Security

J. Kandasamy, Manager, Regulatory Assurance

G. Ludlam, Director, Training

J. Makar, Senior Manager System Engineering

P. Orphanos, Director, Operations

R. Peak, Director, Engineering

D. Peiffer, Manager Nuclear Oversight

J. Randich, Plant Manager

T. Rausch, Site Vice-President

H. Ray, Senior Manager Design Engineering

J. Renda, Manager Radiation Protection

T. Sexsmith, Manager Corrective Action Program

J. Vaccaro, Director, Maintenance

R. Wiebenga, Manager Environmental/Chemistry Manager

Others:

R. Penny, State of New Jersey Bureau of Nuclear Engineering

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened/Closed

05000219/2008004-01 NCV Scaffold Installation Procedure Not Properly Implemented (Section 1R15)

Opened

05000219/2008004-02 URI Water with Tritium Identified in Excavation Area within the Protected Area (Section 4OA3)