IR 05000219/2010002
| ML101200165 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/30/2010 |
| From: | Bellamy R NRC/RGN-I/DRP/PB6 |
| To: | Pardee C Exelon Generation Co, Exelon Nuclear |
| BELLAMY RR | |
| References | |
| 1-2009-044 IR-10-002 | |
| Download: ML101200165 (33) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
415 ALLENDALE ROAD KING OF PRUSSIA, PENNSYLVANIA 19406*1415 April 30. 2010 Mr. Charles Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUBJECT: OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2010002 AND NRC OFFICE OF INVESTIGATIONS REPORT 1-2009-044
Dear Mr. Pardee:
On March 31, 2010, 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 April 29, 2010, with Mr. M. Massaro, 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 Commission's rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This inspection also reviewed your actions for a Rod Worth Minimizer operability event that occurred on July 15, 2009, and led to a violation of NRC regulatory requirements. In response to this event, the NRC Office of Investigations (01) initated an investigation on August 12, 2009, to determine if there were wiflful aspects that contributed to this violation of Technical Specifications. Based upon the evidence developed during the investigation, the NRC concluded that while a violation of NRC requirements did occur, there was insufficient evidence to substantiate that employees at Oyster Creek deliberately violated technical specifications during the reactor startup from the July 15 event.
Please note that final NRC documents, such as the 01 report described above, may be made available to the public under the Freedom of Information Act (FOIA) subject to redaction of information appropriate under FOIA. Requests under FOIA should be made in accordance with 10 CFR 9.23, Request for Records.
The report documents two NRC-identified findings of very low safety significance (Green).
Both of these findings were determined to involve violations of NRC requirements. However, because of the very low safety Significance and because they are entered into your corrective action program. the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A.1 of the NRC Enforcement Policy. lif you contest any NCV, 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, ATIN.: Document Control Desk, Washington DC 20555 0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Oyster Creek Generating Station. In addition, if you disagree with the characterization of any finding in this report, you should provide a response within 30 days of the date of this inspection report with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Oyster Creek Generating Station.
The information you provide will be considered in accordance with Inspection Manual Chapter 0305.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's 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,
~Q.~
Ronald R. Bellamy, Ph.D., Chief Projects Branch 6 Division of Reactor Projects Docket No. 50-219 Ucense No. DPR-16
Enclosure:
Inspection Report 05000219/2010002 w/Attachment: Supplemental Information
REGION I II Docket No.: 50-219 I!
License No.: DPR-16 I
Report No.: 05000219/2010002 I Licensee: Exelon Nuclear Facility: Oyster Creek Generating Station Location: Forked River, New Jersey Dates: January 1, 2010- March 31, 2010 Inspectors: J. Kulp, Senior Resident Inspector J. Ambrosini, Resident Inspector W. Schmidt, Senior Reactor Analyst Approved By: Ronald R. Bellamy, Ph.D., Chief Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000219/2009002; 01/01/2010 - 03/3112010; Exelon Energy Company, LLC, Oyster Creek
Generating Statiqn; Maintenance Effectiveness, Operability Evaluations.
The report covered a 3-month period of inspection by resident inspectors and a senior reactor analyst. Two Green non-cited violations (NCV) were 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" (SOP). The cross-cutting aspects were determined using IMC 0310, "Components Within the Cross Component Areas." Findings for which the SDP does not apply may be Green or be assigned a severity level after NRC management review. The NRC's 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: Barrier Integrity
- Green.
The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65(a}(3), requirements for monitoring the effectiveness of maintenance at nuclear power plants (maintenance rule), because EXE;lon did not make adjustments to established performance and condition monitoring goals to ensure that unavailability and reliability of structures, systems and components (SSC) were appropriately balanced.
Specifically, Exelon did not ensure that corrective actions identified in a 2006-2007 (a)(3)evaluation to update performance criteria sheets for maintenance rule systems were adequately implemented. Exelon entered this issue into their corrective action system as IR 1053237.
This finding is not similar to any of the IMC 0612 Appendix E minor examples, but is more than minor because if left uncorrected it wOl:lld have the potential to lead to a more significant safety concern. Specifically, the failure to implement revised performance criteria could prevent the screening of safety significant systems that have exceeded their performance criteria through a maintenance rule expert panel and prevent Exelon from monitoring degraded components against established goals in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions, This finding is not suitable for evaluation using the Significance Determination Process (SOP) because the performance deficiency did not cause the degraded equipment performance. Findings for which the SOP does not apply may be Green or assigned a severity level after NRC management review. Per the guidance provided in NRC inspection procedure 71111.12, this issu*e is considered to be a Category 11 finding and thus, per NRC management review, is consid.ered to be
- Green.
This finding has a cross~cutting aspect in the area of problem identification and resolution (P.3(c>>.
Specifically, Exelon did not ensure that actions identified in the 2006-2007 (a)(3)assessment to update performance criteria sheets for maintenance rule systems were completed and implemented. (Section 1R12)
Cornerstone: Barrier Integrity
- Green.
An NRC identified NCV of Technic:al Specification (TS) 6.8.1, Procedures and Programs, was identified when Exelon did not declare the rod worth minimizer (RWM) inoperable prior to completing the withdrawal of the twelfth rod during a reactor startup on July 15, 2009. During the startup, the RWM exhibited difficulty following the movement of control rods, had difficulty following which control rod was selected, and generated a total of 3 rod blocks even though the physical configuration of the control rod positions was in accordance with the control rod withdrawal sequence. Although operations personnel were aware of these malfunctions of the RWM, they believed that the rod blocks being generated were conservative and did not consider the operability criteria contained in the RWM operating procedure. At the beginning of the withdrawal of the twelfth control rod, the RWM generated an improper rod block and began tracking a control rod that had not been selected or withdrawn. The operators were able to clear the rod block and fully withdraw the rod. The operators declared the RWM inoperable based upon the improper rod block that occurred at the beginning of the withdrawal of the twelfth rod, but entered the TS action statement baseel upon the time that the operability decision was made, which was after the rod was fully withdrawn. Because of this concluSion, the wrong TS action statement was entered and all actions and limitations associated with the correct TS were not completed. This issue has been entered into Exelon's corrective action program.
The finding was more than minor because it was similar to example 2.g of IMC 0612 Appendix E. Additionally, the finding was more than minor because it was associated with the Design Control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. In accordance with IMC 0609.04 (Table 4a), "Phase 1 -Initial Screening and Characterization of Findings," the finding was determined to be of very low safety significance (Green)because the finding affected the barrier integrity cornerstone and was a fuel barrier issue. The performance deficiency had a cross-cutting aspect in the area of human performance, decision making H.1(a}, because Exelon did not make a safety significant decision using a systematic process when faced with uncertain or unexpected plant conditions. Specifically. Exelon did not consider the operability criteria in procedure 409, "Operation of the Rod Worth Minimizer," when faced with a malfunctioning RWM during the reactor startup on July 15, 2009. (Section 1R15)
REPORT DETAILS
Summary of Plant Status
The Oyster Creek Generating Station (Oyster Creek) began the inspection period operating at full power.
On February 28, operators performed a planned downpower to 85 1% to recover control rods following hydraulic control unit maintenance. Oyster Creek returned to full power later the same day.
.
On March 21. operators performed a planned downpower to 60% for performance of a control rod pattern adjustment, turbine valve testing and non-destructive evaluation of piping in the condenser bay in preparation for temporary repairs. Oyster Creek returned to full power later the same day.
Oyster Creek operated at full power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
a.
Inspection Scoge (5 samples)
The inspectors performed five site specific weather-related condition inspections.
The inspectors reviewed Exelon's response to the following adverse weather conditions:
cold weather conditions on January 4; a severe thunderstorm warning from the National Weather Service (NWS) on January 25; a blizzard warning from the NWS on February 5; a winter storm warning from the NWS on February 9; and a high wind warning on March 12. The inspectors verified that operators properly monitored important plant equipment that could have been affected by the cold weather, snow accumUlation and the high winds from the storms. The inspectors ensured that temperatures for equipment and areas in the plant were maintained within procedural limits, access to eqUipment was maintained. and when necessary, compensatory actions (Le., additional heating or increased monitoring frequency) were properly implemented in accordance with procedures. The inspectors performed walkdowns of areas that could be potentially impacted by the cold weather conditions, such as the intake structure, the fire protection system, and the emergency diesel generators.. The inspectors performed walkdowns of the site and intake structure following the storms to ensure that there was no damage caused by debris from the storms.
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 Equjpment 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 safety significance such as would occur when redundant equipment was unavailable during maintenance or adverse conditions, or after equipment was recently returned to service after maintenance. The inspectors performed a partial walkdown of the following systems, and when applicable, the associated electrical distribution components and control room panels, to verify the equipment was aligned to perform its intended safety functions;
- Containment spray system #2 when containment spray system #1 was unavailable due to planned surveillance testing on January 19;
- 'A' control rod drive (CRD) system when 'B' CRD system was unavailable due to planned maintenance on March 10; and
- Core spray system #2 when core spray system #1 was out for planned surveillance testing on March 29.
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 5 samples)
The inspectors performed a walkdown of five 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 Reporf' and "Oyster Creek Pre-Fire Plans" for risk insights and design features credited in these areC;is. 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:
- CRD pump room (RB-FZ-1 F3) on January 5;
- Portable emergency pump an~a on January 13;
- Feedwater pump area (TB-FZ-11 F) on January 21;
- 4160V C and D vaults CrB-FA-3A) on February 22; and
- New warehouse (NW-FA-23) on February 23.
b, Findings No findings of significance were identified.
1R06 Flood Protection Measures
a. Inspection Scope
(1 samplel The inspectors performed one internal flood protection inspection activity.
The inspectors performed an internal flood protection inspection activity in the turbine building basement which contains the service air compressors, instrume'nt air dryers and the turbine building closed cooling water 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 to assess the physical condition of the equipment and components in the turbine building basement. The inspectors reviewed preventive maintenance activities associated with flood protection equipment.
The inspectors also reviewed Exelon's procedures related to flooding of the turbine building basement.
Documents associated with 1hese 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 sample)
Annual Review. The inspectors verified acceptable heat exchanger performance by reViewing Exe!on's technical evaluation of the 'A' spent fuel pool heat exchanger following inspection and corrective maintenance (tube plugging). 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 sample)
The inspectors observed one simulator training scenario to assess operator performance and training effectiveness on March 2. The inspectors assessed whether the simulator adequately reflected the expected plant response, operator performance met Exelon's procedural requirements, and the simulator instructor's critique identified crew performance problems. Documents revil;;wed for this inspection activity are listed in the Supplemental Information attachment tc, this report.
b. Findings
No findings of significance were identified.
1R 12 Maintenance Effectiveness (71111.12) a.
Inspection Scope (2 samples)
The inspectors performed two maintenance effectiveness inspection activities. The inspectors reviewed the following degraded equipment issues in order to assess the effectiveness of maintenance by Exelon:
- Standby gas treatment system (SGTS) #2 (IR 1022923) on January 27 and;
- Nuclear instrument (NI) system (IR 853335, 903303, 947291) on March 18.
The inspectors also verified that the systems or components were being monitored in accordance with Exelon's maintenance rule program requirements. The inspectors compared documented functional failure determinations and unavailability hours to those being tracked by Exelon. The inspectors reviElwed 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
Introduction The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50.65(a)(3),requirements for monitoring the effectiveness of maintenance at nuclear power plants (maintenance rule), because Exelon did not make adjustments to established performance and condition monitoring goals to ensure that unavailability and reliability of structures, systems and components (SSC) were appropriately balanced. Specifically, Exelon did not ensure that corrective actions identified in a 2006~2007 (a)(3) evaluation to update performance criteria sheets for maintenance rule systems were adequately implemented.
Description The inspectors determined that Exelon did not adequately update various maintenance rule performance goals after review of a previous evaluation. Specifically, Exelon documented a required periodic evaluation of performance and condition monitoring activities and associated goals and preventive maintenance in "Oyster Creek Generating Station Maintenance Rule Periodic (a)(3) Assessment, dated January 1. 2006 - June 30, 2007." Exelon used the corrective action program (lR 601473) to manage the various tasks required to complete the assessment. In section 5.3.4 of the assessment, Exelon recommended that all system managers develop new performance criteria sheets for all maintenance rule systems. The task was placed in the corrective action program I
I (IR 601473, action 37) as an action item and was documented as complete on October 12,2007. Exelon developed additional action items in IR 601473, tasking each I
system manager to review the existing performance monitoring criteria and ensure it was updated in accordance with ER-AA-31 0-1003, "Maintenance Rule - Performance Criteria Selection." These assigned actions were taken to complete between 2007 and 2009. Exelon did not have an action in IR 601473 to implement the updated I
performance criteria and therefore. did not load the revised criteria into the maintenance rule tracking software. Since the revised criteria were not implemented, systems managers were using outdated and technically unjustifiable data to evaluate performance and condition monitoring activities for some systems.
An illustrative example concerns the performance and condition monitoring activities related to the nuclear instrument (Nl) system. The NI system consists of the source range monitors and neutron monitoring system, which monitor core power and protect against fuel damage through the generation 01' rod blocks and reactor trip setpoints.
During the periodiC evaluation conducted in 2006-2007, the system manager determined that the performance criteria needed to be revised from "no repeat MPFF~ (maintenance preventable functional failures) to "2 MPFF per 24 month period." The specific action in IR 601473 to review and update the reliability criteria for the NI system was completed I on June 21,2007. On three occasions (December 19. 2008 IR 853335, May 7,2009 ).
IR 903303, and July 29, 2009 - IR 947291), trle NI system experienced spiking of average power range monitoring (APRM) channels and generated unintended half scram signals. The system manager determined that each of these events constituted a MPFF
!
I
[
of the NI system. The three recorded MPFFs within an 8 month time period exceeded the NI system's updated reliability criteria but not* the outdated criteria since the spikes I, occurred on different APRM channels. For a system that exceeds its reliability criteria, Exelon T&RM (Training and Reference Manu::ll) ER~AA-310-1005, "Maintenance Rule Dispositioning Between (a)(1) and (a)(2)" requires the system manager to review the MPFF and make a proposal to be reviewed by Exelon's maintenance rule expert panel.
to determine if the NI system should be placed in 10 CFR 50.65(a)(1) status where it would be subject to additional monitoring and corrective actions. Because the revised performance criteria were not implemented and the system manager was using the outdated criteria to evaluate system performance. the nuclear instrument (NI) system was not evaluated by the maintenance rule expert panel for transitioning to (a)(1) status.
Had the new reliability criteria been implemented, the NI system would have been evaluated for transition to (a)(1) status and a detailed maintenance plan of action would have been generated to restore the reliability of the system.
Analysis Exelon's failure to make adjustments, where necessary, to goals and monitoring to ensure that unavailability and reliability are balanced is a performance deficiency. This finding is not similar to any of the IMe 0612 Appendix E minor examples, but is more than minor because if left uncorrected it would have the potential to lead to a more significant safety concern. Specifically, the failure to implement revised performance criteria could prevent the screening of safety significant systems that have exceeded their performance criteria through a maintenance rule expert panel and prevent Exelon from monitoring degraded components against established goals in a manner sufficient to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions.
This finding is not suitable for evaluation using the Significance Determination Process (SDP) because the performance deficiency did not cause the degraded equipment performance. Findings for which the SOP does not apply may be Green or assigned a severity level after NRC management revi.ew. Per the guidance provided in inspection procedure 71111.12, this issue is considered t() be a Category II finding and thus, per NRC management review, is considered to be Green.
This finding has a cross-cutting aspect in the area of problem identification and resolution (P.3(c>>. Specifically, Exelon did not ensure that actions identified in the 2006 2007 (a)(3) assessment to update performance criteria sheets for maintenance rule systems were completed and implemented.
Enforcement 10 CFR 50.65{a)(3) states, in part, that adjustments shall be made to performance monitoring activities where necessary to ensure that the objective of preventing failures of systems, structures and components (SSe) through maintenance is appropriately balanced against the objective of minimizing unavailability.
Contrary to the above, the licensee failed to implement adjustments to maintenance rule performance monitoring criteria as recommended in the 2006-2007 (a)(3) evaluation. As a result of not completing adjustments to the goals, system managers were using technically unjustifiable criteria to monitor and evaluate system performance for some maintenance rule systems.
Because this finding was of very low safety Significance and was entered into Exelon's corrective action program as IR 1053237, this violation is being treated as an NeV, consistent with the NRC Enforcement Policy. (NCV 04000219/201002*01, Adjustments to Maintenance Rule System Peiformance Criteria not made after Biannual Evaluation).
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
{5 samples}
The inspectors reviewed five on-line risk management evaluations through direct observation and documented reviews for the following plant configurations:
- 'A' isolation condenser and containment spray system #1 unavailable due to planned maintenance on January 4;
- STGS #1, IN isolation condenser, and 'B' 125V battery charger unavailable due to planned maintenance on January 5;
- STGS #2 and containment spray system #2 unavailable due to planned maintenance on January 11;
- Capacitor bank #2 unavailable due to unplanned maintenance on January 14; and
- Unplanned inoperability and entry into a limited condition for operation (LCD) for 'A' core spray booster pump on March 29.
The inspectors reviewed the applicable risk evaluations, work schedules, and control room logs for these configurations to verify the risk was assessed correctly and II .
I reassessed for emergent conditions in accordance with Exelon's procedures. Exelon's actions to manage risk from maintenance and testing were reviewed during shift turnover meetings, control room tours, and plant walkdowns. The inspectors also used Exelon's 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 (6 samples)
The inspectors reviewed six operability evaluations for degraded or non-conforming conditions associated with:
- Containment spray recirculation fan breaker on January 4 OR 1010428);
- V-28:-39 limit switch broken on January 5 (IR 1012511);
- V-28-28, STGS #2 orifice inlet valve failed to close on January 27 (IR 1022923);
- '00' breaker low temperature alarm on February 18 (IR 1030141);
- Torus 02 analyzer reading off scale low locally on March 3 OR 1037327); and
- Rod worth minimizer (RWM) inoperability due to inconsistent rod tracking and generation of improper rod blocks on July 15, 2009.
The inspectors reviewed the technical adequacy of the operability evaluations to ensure the conclusions were technically justified. ThEl inspectors also walked down accessible portions of equipment to corroborate the adequacy of Exelon's operability evaluations.
Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findings
Introduction A Green NRC identified Non-Cited Violation (NCV) of TS 6.8.1, Procedures and Programs, was identified when Exelon did not declare the rod worth minimizer (RWM)inoperable prior to completing the withdrawal of the twelfth rod during a reactor startup on July 15. 2009. The RWM exhibited difficulty tracking control rod position, generated inappropriate rod blocks and did not meet the loperability criteria listed in procedure 409, "Operation of the Rod Worth Minimizer."
Description At 1820 on July 15, 2009, a reactor startup was commenced to return Oyster Creek to power operation following a reactor scram on July 12. During the startup, the RWM exhibited difficulty following the movement of control rods, had difficulty following which control rod was selected, and generated a total of 3 rod blocks even though the physIcal configuratIon of the control rod positions was in accordance with the control rod withdrawal sequence. Although operations personnel were aware of these malfunctions of the RWM, they believed that the rod blocks being generated were conservative.
Operations personnel determined that the rod block that was generated was proper based upon the control rod position that the RWM indicated, even though the control rod position indicated was different than the true position. The operators were able to clear the improper rod blocks and continue with the startup.
The withdrawal of the twelfth control rod (rod 46-27) commenced at 1923. The rod was moved out one notch to position two on its way to position forty-eight. At 1926, the RWM lost track that rod 46-27 was selected, identified it as being out of sequence and generated a rod block. This rod block was improper as rod 46-27 was physically in the correct position in regards to the withdrawal sequence. The RWM generated several "relatch requests" which verified that rod 46-2-;7 was in the proper sequence and the rod block cleared. At 1929, the operators recommenced rod withdrawal but the RWM was not tracking control rod movement and generated additional relatch requests and identified one or more withdrawal errors ("relaIch warnings"). At this time, the RWM identified rod 14-27, a rod that had not been selected or withdrawn, as being at position twenty-eight and generated a rod block. At 1930, operators performed a RWM "demand scan", which refreshed the RWM with the current rod positions, and cleared the erroneous rod block for rod 14-27. The operators were then able to complete the withdrawal of the twelfth rod. At 1940. the operators declared the RWM inoperable due to generating an improper rod block, which occurred at 1929 during the withdrawal of the twelfth control rod. The operators entered Technical SpeCification (TS) 3.2.B.2(a}, which addresses RWM inoperability after the first twelve rods are withdrawn. At 1942, the RWM was bypassed and the startup was continued.
The criteria for operability of the RWM is contained in procedure 409, "Operation of the Rod Worth Minimizer," which states, "The RWM will be considered operable if the RWM can track CRD positions, and develop rod blocks when the rod positions do not match the loaded sequence. Per the procedure, failures of individual rod position indications will not cause the RWM to be inoperable if actual rod position can be substituted into the RWM and the RWM can generate appropriate rod blocks with the substituted rod position."
The inspectors noted that during the withdrawal of the first twelve rods, there were 3 inappropriate rod blocks generated and numerous instances where the RWM lost track of control rod position as evidenced by the generation of "relatch requests," "relatch warnings," and repetitive selections of individual control rods. Although the operability call was made at 1940, the event that the operability call was based upon occurred at 1929. Based upon the time that the final improper rod block occurred, the previous instances of the RWM not accurately tracking rod position, and the operability criteria contained in procedure 409, the inspectors concluded that the operators should have declared the RWM inoperable prior to the withdrawal of the twelfth control rod and entered TS 3.2.B.2(b). This TS requires the submission of a 30 day report to the NRC detailing why the RWM failed, the actions and schedule required to repair it, and limits the licensee to one reactor startup per calendar year in this condition. Additionally. this TS requires the stationing of a second licensed operator and an engineer from the Core Engineering group to verify that the rod program is being followed.
Exelon documented this malfunction by addinfl it to an existing action request related to troubleshooting and repair of the RWM. Exelon documented the entrance into the wrong technical specification in IR 1062747.
Analysis Exelon's failure to declare the RWM inoperable in accordance with the operability criteria contained in procedure 409 "Operation of the Rod Worth Minimizer," is a performance deficiency.
The finding was more than minor because it was similar to example 2.g of IMC 612, Appendix E. Exelon conducted a portion of tht3 reactor startup with a malfunctioning RWM and did not declare the RWM inoperable until after the twelfth control rod had been withdrawn. Exelon did not enter the appropriate TS action statement and did not perform the required TS actions. Additionally, the finding was more than minor because it was associated with the Design Control attribute of the Barrier Integrity cornerstone objective to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events.
In accordance with IMC 0609.04 (Table 4a), "Phase 1 - Initial Screening and Characterization of Findings," the finding was determined to be of very low safety significance (Green) because the finding affected the barrier integrity cornerstone and was a fuel barrier issue.
The performance deficiency had a cross-cutting aspect in the area of human performance, decision making [H.1 (a)], because Exelon did not make a safety significant decision using a systematic process when faced with uncertain or unexpected plant conditions. SpeCifically, Exelon did not consider the operability criteria in procedure 409.
"Operation of the Rod Worth Minimizer," when faced with a malfunctioning RWM during the reactor startup on July 15, 2009.
Enforcement Oyster Creek Nuclear Generating Station Technical Specification 6.8.1, "Procedures and Programs" states, in part, that written procedures shall be established, implemented, and maintained covering the items referenced in Appendix itA" of Regulatory Guide (RG)1.33, of which operation of the rod worth monitor system is one of the items mentioned.
Contrary to the above, during a reactor startup on July 15, 2009, Exelon personnel did not evaluate malfunctions of the RWM, which occurred during the withdrawal of the first twelve control rods, against the criteria for operability contained in Procedure 409, "Operation of the Rod Worth Minimizer", did not declare the RWM inoperable at the time of the malfunctions, and did not enter the corn~ct teChnical specification action statement and ensure that all the required actions were completed.
Because the finding was of very low safety significance (Green) and was entered into Exelon'$ corrective action program in condition report IR 1062747, this violation is being treated as an NeV, consistent with section IV.A of the NRC Enforcement Policy. (NCV
===04000219/201002-02, Failure To Declare The Rod Worth Minimizer Inoperable At The Time Operability Criteria Was Not Met And Enter The Correct Technical Specification Action Statement).
1R18 Plant Modifications
a.
Inspection Sco12e (1 temporary modification sample)
The inspectors reviewed one temporary plant modification that was implemented by Exelon personnel at Oyster Creek. The inspectors reviewed the following modification:
- Dilution Plant Powered from Q121 Line (temporary modification SP-10-01);
The inspectors reviewed the engineering/proc,edure change packages, design basis, and licensing basis documents associated with each of the modifications to ensure that the systems associated with each of the modifications would not be adversely impacted by the change. The inspectors reviewed the modifications to ensure they were performed in accordance with Exelon's modification process. The inspectors also ensured that revisions to licensing/design basis documents and operating procedures were properly revised to support implementation of the modification. The inspectors also reviewed Exelon's 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.
1R19 Post-Maintenance Testing
a. Inspection Scope
=
The inspectors observed portions of and/or reviewed the results of five post-maintenance tests for the following equipment:
- SGTS #1 following corrective maintenance on January 6 (C2021781);
- SGTS #2 exhaust fan EF 1-9 on January 28 (C2022347);
- Core spray system #2 following pump aliginment on February 9 (R2134924):
- Turbine building closed cooling water '1-2' heat exchanger following cleaning on February 24 (R2140574); and
- CRD pump 'B' following oit sample on March 10 (R2155020).
The inspectors verified that the post-maintenance tests conducted were adequate for the scope of the maintenance performed and that they ensured component functional capability. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findings
No findings of significance were identified.
1
R22 Surveillance Testing
a.
Inspection ScoRe (4 In-service Test (1ST) samples and 3 Routine Surveillance samples)
The inspectors observed portions of and/or reviewed the results of seven surveillance and 1ST tests:
- 'A' standby liquid control pump and valve operability and in-service test (1ST) on January 5;
- Containment sprayfESW system #2 operability and 1ST on January 11;
- SGTS #2 charcoal filter in place leak test on January 26;
- Technical Support Center ventilation surveillance on January 27,
- 'A' and 'B' CRD Pump operability and 1ST on February 3;
- Core spray system #2 valve operability and 1ST on February 9;
- Emergency diesel generator #2 load test surveillance on March 9.
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]
1EP6 Drill Evaluation
a.
Inspection Scope (2 samples)
The inspectors observed one site EP drill and one operator requalification activity.
The inspectors observed the EP drill from the control room simulator, the technical support center (TSC), operations support center (OSC) and the emergency operations facility (EO F) on February 17. The inspectors evaluated the conduct of the drill, facility equipment issues, and Exelon personnel performance related to developing classification, notification, and protective action recommendations. The inspectors observed Exelon's drill critique of the TSC ancl EOF facilities to ensure Exelon appropriately identified performance issues.
The inspectors also observed an operator requalification activity on January 28, which counted as an input into the NRC's emergency response drill and exercise performance indicator (PI). The inspectors observed Exelon's critique of the training activity to verify that weaknesses and deficiencies were adequately identified. The inspectors specifically focused on ensuring Exelon identified operator performance issues associated with event claSSification, notification, and protective action recommendations.
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
lOA] 40A2 Identification and Resolution of Problems (71152)
.1 Review of Items Entered Into the Corrective Action Program
The Inspectors performed a daily screening of items entered into Exelon's corrective action program to identify repetitive equipment failures or specific human performance issues for foUowwup. This was accomplished by reviewing hard copies of each condition report, attending daily screening meetings, or accessing Exelon's computerized database .
.2 Annual Sample Reviews (2 annual samples)
The inspectors reviewed Exelon's evaluations and corrective actions associated with the following issues. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
Reactor recirculation syStem flow oscillations a.
Insl2ection Scope The inspectors reviewed Exelon's evaluation and corrective actions associated with a small power transient resulting from a change in the '0' recirculation pump flow rate (IR
===1009804). The inspectors reviewed relevant corrective action program condition reports to ensure that the full extent of the issue was identified, appropriate evaluations were performed, and corrective actions were specified and prioritized commensurate with the significance of the issue. The inspectors discussed this issue with operations and engineering personnel. The inspectors reviewed industry and NRC guidance on adherence to licensed power limits and Oyster Creek procedure 202.1, "Power Operations," to verify the licensee's compliance with operating license limits and to
. ensure that the issue was prioritized correctly.
b. Findings and Observations
No findings of significance were identified.
Compliance with license condition 2.B.17, "Biological Opinion" a.
Inspection ScoRe The inspectors reviewed Exelon's implementation of the terms and conditions associated with license condition 2.B.17 "Biological Opinion," associated corrective action program documents and the reporting requirements contained in the biological opinion and in technical specifications. The inspectors reviewed relevant corrective action program condition reports to ensure that the full extent of the issue was identified, that appropriate evaluations were performed, that reports were submitted to the National Marine Fisheries Service (NMFS) and the NRC as required by the operating license and environmental technical specifications, and corrective actions were specified and prioritized. In general, Exelon met the programmatic and reporting requirements of TSs and the biological opinion. The inspectors identified several issues with the implementation of the requirements contained in the biological opinion:
- The information recorded and submitted in conjunction with an incidental intake of a sea turtle was not in the format contained in the biological opinion and did not contain a/l the requested information.
- The biological opinion requires that rescue equipment and spot lights be staged at both the dilution and circulating system intakes. Exelon stages this equipment only during turtle season {June 1 through October 31}.
- The posted procedure for sea turtle resuscitation is not the current version specified in the biological opinion and is not posted at the operating stations for the intake and dilution plant trash rakes.
- The required annual summary report does not meet the reporting requirements contained in the biological opinion as it does not contain all the requested information.
The inspectors reviewed the issues with NRC and NMFS biologists on March 29 and determined that due to their administrative nature, these issues represented minor violations of license condition 2.B.17. The inspectors discussed this issue with Oyster Creek environmental and regulatory affairs personnel and reviewed intake and dilution plant raking and sea turtle handling procedures. Issues identified by the inspectors were entered into Exelon's corrective action program as IR 1046066.
.
b. Findings and Observations
No findings of significance were identified.
40A3 Event Followup (71153) ===
The inspectors performed one event followup inspection activity. Documents reviewed for this inspection activity are listed in the Supplemental Information attached to this report.
.1 Capacitor bank #2 feeder breaker did not open on demand.
a. Inspection Scope
On January OB, control room operators noted that the feeder breaker for the #2 capacitor bank did not open upon demand by the grid system operator. Attempts by the control operators to open the breaker from the Oyster Creek control room were unsuccessful.
Jersey Central Power and Light (JCP&L) maintenance technicians were dispatched to the switchyard and were unsuccessful in opening the breaker locally.
The inspectors monitored Exelon's interactions with JCP&L and actions in developing a course of action to deenergize #2 capacitor bank safely while maintaining power to the dilution plant to prevent adverse environmental effects for aquatic life living in the discharge canal. The inspectors verified that Exelon responded in accordance with their procedures and managed risk by reviewing the control room narrative logs, corrective action program condition reports, and through interviews of engineering and operations personnel. The inspectors also reviewed TS r<i3quirements to ensure that Oyster Creek was operated in accordance with its operating license. Exelon successfully deenergized
- 2 capacitor bank on February 1, allowing JCP&L to commence repairs to the #2 capacitor bank feeder breaker. The failure of the capacitor bank feeder breaker is described and evaluated in corrective action program condition report IR 1014371.
b. Findings
No findings of significance were identified .
.2 {Closed) URI 05000219/2009009-01, Review Exelon's Root Cause Analysis for the
Q121 Circuit Breaker Failure to Open on July -12,2009 and LER 05000219/2009-005-00 and -01, Reactor Scram following a Transmission Line Lightning Strike
a. Inspection Scope
The inspectors reviewed the unreSOlved item (URI) pending issues which included reviewing Exelon's root cause report for the faHure of the Q121 circuit breaker to open to isolate a fault within its designed time on July 12, 2009 and to review the licensee's applicability of that failure and a previously unknown failure of the same circuit breaker in June 2009, to the Oyster Creek Maintenance Rule Program. The inspectors also reviewed the associated licensee event report (LER) and the corrective action program documentation.
The LER and root cause analysis concluded that the circuit breaker did not open as deSigned because the trip linkage latch ban bearing had degraded due to lack of lubrication. Exelon's root cause analysis included the results of a laboratory examination of the breaker trip latch ball bearing by JCP&L, who owns and maintains all the circuit breakers in the Oyster Creek switchyards. Upon removal of this double shielded ball bearing, it was stiff and hard to tum. After disassembly of the bearing, it appeared that the grease had lost it lubrication ability, potentlally due to contamination with a spray lubricant.
In reviewing the JCP&L digital faull recorder (DFR) information provided after the July 12, 2009 scram, Exelon identified that the 0121 breaker had not responded properly following a June 2009 line lightning strike. In the June 2009 event, it opened in about 20 seconds after it was first demanded. The lightning strike was near the Whiting substation at the other end of the line and did not result in the actuation of the secondary protection relays in the Oyster Creek switchyard. When the breaker opened in June 2009, the control room (CR) operator closed it as directed by JCP&L to repower the line.
Subsequently, when JCP&L asked the CR operator to reopen the 0121 breaker to allow line work following the June event, it did not open from the CR. The circuit breaker was successfully opened from the circuit breaker relay house to isolate the line. The operators initiated an issue report (lR 930778) documenting the problem, which was attributed to a previously identified issue concerning a problem in the wiring between the CR switch and the circuit breaker rather than any actual circuit breaker operational issue.
Absent the DFR information from JCP&L, Exelon did not know that 0121 had experienced a failure to operate as designed.
The Q121 circuit breaker is not safety-related, but is included as part of the switchyard system in the Oyster Creek maintenance rule program, along with the other offsite power and generator output circuit breakers (which included the 230 KV and 34.5 KV switchyards) in the Oyster Creek maintenance rule system program. Prior to the July 12, 2009, reactor scram, the switchyard system was in maintenance rule category a(2}, and Exelon was not aware of any recent problems with the 0121 breaker ability to open if required to isolate a fault. The only known issue concerned the ability to open the breaker using the control room switch. Following the Ju!y
.12 , 2009 scram and the
identification of the June 2009 failure to operat,e as deSigned, the switchyard system was appropriately placed in the a(1} status, with corrective actions underway to return it to a(2) status, including a review of JCP&L preventive maintenance and periodic testing activities.
The other corrective actions documented in IR 940992 appeared adequate to prevent recurrence, including a review of the past performance of the similar circuit breakers in the 34.5KV switchyard. Exelon identified that it had not been the practice of asking JCP&L to inform Exelon of circuit breaker timing issues if there was not a direct impact on offsite power availability and took additional actions to improve the interface and transmittal of information concerning the operation of components within the scope of the maintenance rule.
b. Findings
No findings of significance were identified .
.3 {Closed) LER 05000219/2009-006-00 and ~01, EDG #1 Inoperable due to Failure of its
Output Breaker to Close
a. Inspection Scope
This LER discusses the #1 EDG output circuit breaker not automatically closing as designed during routine testing on August 5, 2009, due to the failure of contacts to properly actuate in the generator breaker close- (GBC) relay. NRC Special Inspection Report 05000219/2009-009 reviewed and dispositioned this issue. Exelon issued Revision 1 of this LER to report a GBC Agastat relay manufacturing defect under 10 CFR Part 21, Reporting of Defects and Non-compliances. Review of this LER identified no new issues.
b. Findings
No findings of significance were identified.
40A6 Meetings, Including Exit Resident Inspector Exit Meeting. On April 29, 2010, the inspectors presented their overall findings to members of Exelon's management led by Mr. P. Orphanos. Plant Manager, and other members of his staff who acknowledged the findings. The inspectors confirmed that proprietary information reviewed during the inspection period was returned to Exelon.
40A7 Licensee-Identified Violations None.
AITACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Massaro, Site Vice-President
- P. Orphanos, Plant Manager
- D. Dicello, Director, Work Management
- J. Dostal, Director, Operations
- R. Peak, Director, Engineering
- R. Reiner, Director, Training
- J. Vaccaro, Director, Maintenance
- J. Barstow, Manager, Regulatory Assurance
- T. Keenan, Manager, Security
- R. Wiebenga, Senior Manager, System Engineering
- H. Ray, Senior Manager, Design Engineering
- M. McKenna, Shift Operations Superintendent
- D. Peiffer, Manager, Nuclear Oversight
- J. Kerr, Manager. Corrective Action Program
- J. Kandasamy, Manager, Environmental/Chemistry Manager
- J. Renda. Manager, Radiation Protection
- C. Barnes, Regulatory Assurance Specialist
Others:
State of New Jersey, Bureau of Nuclear Engineering
LIST OF ITEMS
OPENED. CLOSED, AND DISCUSSED
Opened/Closed
- 05000219/2010002-01 NCV Adjustments to Maintenance Rule System Performance Criteria not made after Biannual Evaluation (Section 1 R12)
- 05000219/2010002-02 NCV Failure To Declare The Rod Worth Minimizer Inoperable At The Time Operability Criteria Was Not Met And Enter The Correct Technical Specification Action Statement (Section 1R 15)
Closed
- 05000219/2009-005-00 LER Reactor Scram Following a Transmission Line Lightning Strike (Section 40A3)
- 05000219/2009-005-01 LER Reactor Scram Following a Transmission Line Lightning Strike (Section 40A3)
- 05000219/2009-006-00 LER EDG #1 Inoperable due to Failure of its Output Breaker to Close (Section 40A3)
- 05000219/2009*006-01 LER EDG #1 Inoperable due to Failure of its Output Breaker to Close (Section 40A3)
- 05000219/2009009-01 URI Review Exelon's Root Cause Analysis for the 0121 Circuit Breaker Failure to Open on July 12, 2009 (Section 40A3)