IR 05000219/2010005
| ML110390509 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 02/08/2011 |
| From: | Bellamy R NRC/RGN-I/DRP/PB6 |
| To: | Pacilio M Exelon Nuclear |
| BELLAMY RR | |
| References | |
| IR-10-005 | |
| Download: ML110390509 (64) | |
Text
UNITED STATES N UCLEAR REGULATORY COMMISSION
REGION I
475 ALLENDALE ROAD KING OF PRUSSIA. PA 19406.1415 February B, 20II Mr. Michael pacilio Chief Nuclear Officer and Senior Vice president Exelon Nuclear 4300 Winfield Road Warrenville, lL 6ObS5 SUBJECT: OYSTER CREEK GENERATING STATIoN - NRc INTEGRATED INSPEcTIoN REPORT 0500021 9/201 0oo5
Dear Mr. Pacilio:
on December 31 ,2010, the u. S. Nuclear Regulatory commission (NRC) compteted an inspection at your oyster creek Generating siation. rne enctosed integrated inspection report documents the inspectio.n findings, which ilere oiscu.r"o on January 26,2011, with Mr. Michael Massaro, site vice president, aid'other members of youi staff.
The inspection examined activities conducted under your ficense as they refate to safety and compliance with the commission's rules and regulations ano with the conoltions of your license.
The inspectors reviewed selected procedures personnel.
aid records, observed activities, and interviewed This report documents one NRC-identified finding and two setf-revealing findings of very low safety significance (Green) which involved violati-ons of NRC requirements. However, because of the very fow safety signiffcance and oecause in"v entereo into your program, the NRC is treating these findings "i" viotations 6.rbVsl corrective nonj.it"o consistent action with section 2'3'2 ot the NRc Enforcement Po'licy ". tf to; ;;;bst any NCv, you shoutd provide response within 30 days of the date of tnis^ irisleition a refort, witn the oalis ror your denial, to the Nuclear Regufatory c-ommission, ATTN.: oo.rm"ni-Controf Desk, washington DC 205ss-0001; with copies to the Regional Administrator, nejion I ine oirector, office of Enforcement, united states NuclearRegu-latory commission, washington, DC 20555-0001; and the NRC Resident Inspector at oysier creek Generating station.-ln 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 baiis for your'oirrgr"ement, Administrator, Region l, and the NRC Resident lnsdectoi to the Regional a1 oyster creek Generating Station.
you provide will be considered in iccoroance witn Inspection Manuat chapter I$;:"ttation
M. Pacilio 2 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:i/wwl.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
We appreciate your cooperation. Please contact me at (610) 337-5232 if you have any questions regarding this letter.
Sincerely, Ronald R. Bellamy, Ph.D., Chief Projects Branch 6 Division of Reactor Projects Docket No. 50-219 License No. DPR-16 Enclosure: Inspection Report05000219/20'10005 w/Attachment: Supplemental Information cc w/encls: Distribution via ListServ
SUMMARY OF FINDINGS
lR 05000219/2010005;101112010 - 1213112010; Exelon Energy Company, LLC, Oyster Creek
Generating Station; Maintenance Effectiveness, Event Followup.
The report covered a 3-month period of inspection by resident inspectors, a regional project engineer, and regional specialist inspectors. Three 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 (lMC) 0609, "Significance Determination Process" (SDP). The cross-cutting aspects were determined using tMC 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.
Gornerstone: Initiating Event Green: A Green, self-revealing NCV of Technical Specification (TS) 6.8.1.a occurred when Exelon did not adequately implement plant startup procedures which resulted in an automatic reactor scram. lmmediate corrective actions included just in time training with all reactor operators, increased management oversight during the subsequent startup, and procedural changes to list all alarms by name that must be cleared prior to raising reactor pressure above 500 psig. Exelon is performing a full root cause evaluation on the event (lR 1 155520).
The inspectors determined that the performance deficiency was similar to the "not minor if'statement contained in example 4b of IMC 0612, Appendix E, "Examples of Minor lssues," because the performance issue resulted in a manual reactor scram. The finding was more than minor in accordance with IMC 0612, Appendix B, "lssue Screening," because it was associated with the equipment performance attribute of the initiating events cornerstone and atfected the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operation. In accordance with IMC 0609.04 (Table 4a), "Phase 1 - Initial Screen and Characterization of Findings," the finding was determined to be of very low safety significance (Green)because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. This finding has a cross-cutting aspect in the area of human performance, work practices (H.4(b)), where personnef work practices support human performance, specifically, Exelon defines and etfectively communicates expectations regarding procedural compliance and personnel follow procedures. On December 23, operators did not verify that condenser vacuum was adequate prior to raising reactor pressure above 500 psig, contrary to established procedural guidance. (Section 4OA3)
Gornerstone: Mitigating Systems Green: AGreen, inspectoridentifiedNCVof TS4.5.M.1.f, "SnubberServiceLife Monitoring", was identified while inspecting four snubber testing failures that occurred during refueling outage 1R23. Specifically, Exelon's snubber testing program, contained in SP-1302-52-O4S, "Requirements for Functional Testing of Snubbers", does not evaluate snubber maintenance and test records to identify common cause failures of snubbers due to environmental (temperature, vibration, humidity) conditions and adjust snubber service life expectations accordingly, such that snubber service life reviews can be accomplished effectively without service life affecting reactor operations. Exelon took immediate corrective action to repair or replace the failed snubbers, performed an analysis to ensure the snubber failures had no impact on system operation, and entered this issue into their corrective action program (1R1138622, lR1139897, lR1143332, rR1143829)
There are no similar examples in IMC 0612, Appendix E, "Examples of Minor lssues".
This finding is more than minor because it affects the equipment performance attribute of the mitigating systems cornerstone to ensure the availability, reliability and capability of system that respond to initiating events to prevent undesirable consequences, specifically the safety related piping systems in containment. ln accordance with Table 4a of IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," the finding was determined to be of very low safety significance (Green) because it was a qualification deficiency confirmed not to result in loss of operability or functionality. This finding has a cross-cutting aspect in the area of problem identification and resolution (P.1(c)) because Exelon did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions. Additionally, Exelon did not conduct effectiveness reviews of corrective actions to ensure that the problems are resolved.
(Section 1R12)
Cornerstone: Public Radiation Safety
Green: A Green, self-revealing NCV of TS 6.8.4 occurred due to Exelon's failure to maintain continuous, representative monitoring and sampling of plant stack gaseous effluents, as required by the Offsite Dose Calculation Manual. The cause was degradation of sample line integrity over the period March 2006 through March 2010.
Exelon reported the issue, initiated compensatory monitoring, repaired the stack sample tubing, conducted bounding dose calculations, and entered this issue, including the evaluation of extent-of-condition, into the conective action program (lR 01053577).
This finding is more than minor because the performance deficiency adversely impacted the Public Cornerstone objective of ensuring adequate protection of public health and safety in that effluent releases were not fully monitored in accordance with applicable requirements to ensure proper quantification and characterization of radioactive releases. This finding was assessed for significance using IMC 0609, Appendix D, and determined to be of very low safety significance because: Exelon was able to re-assess the radioactive effluent using alternative radiation monitoring instrumentation and programs, therefore Exelon had data by which to assess dose to a member of the public, determine the dose impact to the public, and conclude that the doses were less than the dose values in Appendix I to 10 CFR Part 50 and/or 10 CFR 20J301(e). This finding has a cross-cutting aspect in the area of Human Performance, Resources (H.2(c))
because procedures were not sufficiently robust for review of reasonableness and consistency of data from samples to support identification of the issue in a timely manner. (Section 4OA3)
REPORT DETAILS
Summarv of Plant Status The Oyster Creek Generating Station (Oyster Creek) began the inspection period operating at full power.
On October 31, operators commenced a planned shutdown and started the 1R23 refueling outage. The plant returned to power generation on December 1.
On December 2, operators performed an unplanned downpower from 35% to 2oo/o reaclor power due to indications of an internal fault on the M1B transformer. Operators took the generator of1ine and started the 1F23 forced outage to electrically disconnect the M1B power on iransformer. The operators placed the generator online and returned to 50%
December 4 after disconnecting the M1B transformer.
power, took the On December 9th, operators performed a planned downpower to 20o/o reactor generator offline and' started in" fzqforced outage to replace the M1B transformer with an to 50% power on 6nsite spare. The operators placed the generator online and returned December 12, after placing the spare M1B transformer on its storage pad.
power, took the On December 15, operators performed a planned downpower to 20% reactor generator offline and started ine t rzs forced outage to electrically reconnect the M1B transformer with an onsite spare. The operators placed the generator online and returned to full power on December 17.
pump wlt_ch On December 18, operators responded to a trip of the "A" reactor recirculation resulted in an unplanned downpower. Exelon chose to remain at 55% power while 2 of reactor recirculation pumps were unavailable.
On December 19, operators commenced an unplanned shutdown and started the 1F26 forced commenced a outage to repair the "8" reactor recirculation pump mechanical seal. Operators an
,ercior startup on Decemb er 23. While heating up the plant following reactor startup, automatic scram occurred. The automatic scrim ls discussed in detail in section 4OA3 of this on December 24 and returned to full power report. Operators performed another reactor startup on December 25.
period' Oyster Creek operated at 100% (full) power for the remainder of the inspection
REACTOR SAFEW Gornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
a.
lnspection ScoPe (1 samPle)
The inspectors peformed one adverse weather preparation inspection' The inspectors reviewed Exelon's activities associated with seasonal readiness for cold weather conditions. The inspectors reviewed the updated final safety analysis report (UFSAR) to identify risk significant systems that require protection from cold weather conditions. The inspectors performed a walkdown of the intake structure, the heat tracing of outdoor components including temporary water storage tanks, and the emergency diesel generators. The inspectors reviewed Exelon's cold weather preparation activities to assess their adequacy and to verify they were completed in accordance with procedural requirements. The inspectors also reviewed applicable corrective action program condition reports to assess their reliability and material condition of their systems.
Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findinqs No findings were identified.
1R04 EquipmentAlignment
a. Inspection Scope
(4 samples)
The inspectors performed 3 partial and 1 complete equipment alignment inspections.
The partialequipment 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:
r 'A' Containment Spray system on November 29 and November 30 after the system was returned to service following the 1R23 refueling outage;
.
'A' and 'B' lsolation Condenser system on December 6 after the equipment was returned to service following the 1R23 refueling outage; and o 'A' control rod drive system on December 30 following planned maintenance on the B control rod drive system.
The inspectors performed a complete system alignment inspection on the standby liquid control (SLC) system on November 29 and 30 after it was returned to service following the 1R23 refueling outage to determine whether the system was aligned and capable of providing a backup method of shutting down the reactor in accordance with design basis requirements. The inspectors reviewed operating procedures, the surveillance test procedure, piping and instrument drawings, and the applicable equipment lineup list, to determine if the equipment was aligned to perform its safety function upon actuation.
Documents reviewed for this inspection activity are listed in the Supplemental lnformation attachment to this report.
b.
Findinos No findings were identified.
R05 Fire Protection
a.
lnspection Scope (71111.05Q - 3 samples)
The inspectors performed a walkdown of three 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.
Documents reviewed for this inspection activity are listed in the Supplemental lnformation attachment to this report. The following plant areas were inspected:
.
Demineralizer Tanks and Steam Jet Air Ejector Area (TB-FZ-11H) on November 16; o Emergency Diesel Generator Room #1 (DG-FA-15) on November 18; and o Emergency Diesel Generator Room #2 (DG-FA-17) on November 18.
b.
Findinos No findings were identified.
1R08 Inservice Inspection (lSl) Activities
a.
Inspection 9cope (71 11 1.08 - 1 Sample)
The inspectors selected samples for inspection based upon the guidance in lnspection Procedure 71111.08 and the risk priority of those components and systems where degradation could result in a significant increase in the risk of core damage. The observations and documentation reviews were conducted to verify that inspection activities are being performed in accordance with the American Society of Mechanical Engineers (ASME) Boiler, and Pressure Vessel Code requirements.
Drvwell Sandbed Bav Visual (W) and Ultrasonic (UT) Inspections The inspectors reviewed the Exelon procedures for performing drywell ultrasonic (UT)wall thickness measurements and for performing visual inspection (VT) of the drywell protective coating in the sandbed regions. The inspectors observed Exelon perform these inspections in sandbed bays #1, #3 and #11. The inspectors also reviewed the completed inspection reports (both UT and W) for sandbed bays #1, #3, #5, #7 , #9,
- 11, #13, #15, #17 and #19. The inspectors verified that Exelon successfully completed the planned inspections, documented the observed conditions, analyzed and evaluated the conditions identified and entered all conditions into the corrective action process for follow up and resolution.
I Dissimilar Metal Weld lnspections During this refueling outage, the inspectors reviewed Exelon's conduct of automated, phased-array, ultrasonic examinations of four reactor vessel nozzle dissimilar metal welds in accordance with Boiling Water Reactor Vessel Internals Project (BWRVIP)inspection requirements. The inspectors determined that Exelon had conducted a detailed review of pre-1R23 performance demonstration initiative (PDl) ultrasonic inspection data to determine whether any significant weld indications had existed that were undetected by prior inspections. The inspectors verified that Exelon's detailed review, conducted in 2008, did not reveal any significant defect indications.
The inspectors verified that the inspections completed during the November 2010 refueling outage met the requirements of the ASME Boiler and Pressure Vessel Code, Section Xl, Amendment lll, Supplement 10. The inspectors reviewed the procedures used in these inspections, verified the process qualification documentation, and remotely observed the collection of inspection data by Exelon personnel. Upon completion of these inspections, the inspectors reviewed a sample of the inspection data sheets.
Additional Non-Destructive Examination (NDE) Samples The inspectors verified that NDE activities were performed in accordance with the ASME Boiler and Pressure Vessel Code, Section Xl, by reviewing inspection procedures, personnel NDE documentation, and by direct observation and data report reviews. The inspectors reviewed the completed inspection reports (data sheets) from six primary system ultrasonic weld inspections, one dye penetrant examination, and 1 radiographic examination of a core spray piping weld replacement.
The inspectors reviewed a sample of the in-reactor vessel visual inspection (lwl)indications recorded from Exelon's visual inspection of the reactor steam dryer. The inspectors verified that Exelon's inspection results documented no change in the prior steam dryer indications during the past operating cycle. The inspectors reviewed condition reports which reported indications discovered as a result of visual inspection of the steam dryer and evaluated the reported conditions as acceptable for use "as-is" for continued operation with re-inspection during the next refueling outage. The inspectors assessed Exelon's evaluation and disposition for continued service without repair of these non-conforming conditions identified during lSl activities.
The inspectors reviewed a sample of the ultrasonic examination personnel certifications and reviewed the NDE qualifications for the technicians responsible for the data collection, review and interpretation of the inspection results. This review was conducted to confirm that the examiner skill, the test equipment capabilities, the examination techniques used, and the examination procedures enabled the performance of the ultrasonic and visual examination of the selected components. The inspectors verified that the manual and automatic remote ultrasonic examinations met the requirements of ASME Section Xl.
ASME. Section Xl Repair Replacement Samples The inspectors reviewed work order (WO) C2023465, which controlled the replacement of the internals of valve V-2-73 as specified by engineering change request (ECR) 09-
===00499. The inspectors verified that the work and the post repair NDE (VT-3 of the valve I
body and W-1 of all bolting materials) were completed in accordance with ASME Code Case N-416-3, The inspectors also reviewed WO C2023712 which accomplished the replacement of a section of core spray piping. With respect to this work order, the inspectors reviewed:
AR01076164, which reported two areas of core spray pipe wall thinning which was eroded below minimum wallthickness; inspection results reported via NER-NC-09-035Y; and the technical evaluation (AR01076164-03) which recommended replacement of the affected piping during the November 2010 refueling outage. The inspectors reviewed the welding process for the replacement of the core spray pipe and the NDE (magnetic particle testing (MT) during the welding process and radiographic testing (RT) of the completed weld) used to inspect the repair. The final RT was accomplished with eight RT films. One of the films showed evidence of incomplete weld fusion. The inspectors reviewed the issue report (lR 1144878) which evaluated this condition and specified excavation of the affected area and re-welding and post-repair RT. Upon repair of the weld, the inspectors verified acceptable RT results. The inspectors verified the completion of this replacement after reviewing the acceptance by Exelon and the Authorized Nuclear Inspector.
b. Findinqs No findings were identified.
1R1 1 Licensed Operator Requalificatig! Prooram (71111.11)a. Inspection Scops ===
The inspectors observed one simulator training scenario on October 6 to assess operator performance and training effectiveness. The inspectors observed training scenario 2612.CREW10-6.01. 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 reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findinqs No findings were identified.
1R12 Maintenance Effectiveness (71111
.12 )
a.
lnspection 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:
o Main steam isolation valves (lR 1 1 37357 and 1 138356) on November 10; and
.
Adverse trend on snubbers (lR 1139909) on December 29.
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 functionalfailure determinations and unavailable hours to those being tracked by Exelon. 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. Findinqs lntroduction: The inspectors identified a Green NCV of TS 4.5.M.1.f, "Snubber Service Life Monitoring", while inspecting 4 snubber testing failures that occurred during 1R23.
Specifically, Exelon's snubber testing program, contained in SP-1302-52-045, "Requirements for Functional Testing of Snubbers", does not evaluate snubber maintenance and test records to identify common cause failures of snubbers due to environmental (temperature, vibration, humidity) conditions and adjust snubber service life expectations accordingly so snubber service life reviews can be accomplished effectively without service life affecting reactor operations.
Description:
During 1R23, Exelon experienced functional failures on a total of four safety related mechanical snubbers during the TS required functional tests, specifically, the running drag test. The four snubber functional failures were entered into the corrective action program in lRs 1138622,1139897, 1143332 and 1143829. TS 4.5.M.1.c, "Functional Tests", states that at least every 24 months, a representative sample (defined as 10o/o of the total of each type of snubber in use at the plant) shall be functionally tested either in place or in a bench test. TS 4.5.M.1.c further states: for each snubber that does not meet the functional test criteria, an additional 10% of that type of snubber shall be functionally tested. In accordance with TS 4.5.M.1.c, the four functional failures cause Exelon to expand their inspection scope and an additional 40o/o of the installed mechanical snubbers be tested. The apparent cause of the failures for all four snubbers was either hardened or missing grease. The snubbers were either repaired or replaced with new snubbers and reinstalled into the appropriate piping supports. For each failed snubber, Exelon performed engineering evaluations to determine if the failed snubber had adverse affects on the attached piping systems. No adverse effects were identified that would have affected reactor operations.
TS 4.5.M.1.f, "snubber Service Life Monitoring", states, in part, that records of the service life of each snubber shall be maintained, to include the date at which the designated service life commences, the date of installation, and the maintenance records on which the designated service life is based. TS 4.5.M.1.f also requires that the installation and maintenance records be reviewed on a 24 month basis to verify that the indicated service life of the snubbers will not be exceeded prior to the next review.
The TS also specifies that service life shall not at any time affect reactor operations.
ln 1977, Exelon installed mechanical snubbers on safety related systems within containment. The snubbers were built by Pacific Scientific (PSA) and have a design service life of 40 years. Exelon has assigned each snubber a service life of 40 years from time of installation.
ln 2004, PSA issued technical bulletin DR-19, "Mechanical Shock Arrestor Standard Design Specification." In this technical bulletin, PSA modified the design service life as "40 years effective service life with appropriate maintenance and operation within the rated load and environmental limits." ln 2006, PSA issued technical bulletin DR-20, "Mechanical Shock Arrestor Service Life Extension Program & Preventive Maintenance Recommendations." In this technical bulletin, PSA provided guidance for a preventive maintenance program based upon a graduated response to snubbers found degraded or failed. The program includes failure analysis, increased monitoring and preventive maintenance. The preventive maintenance program in this bulletin is being considered but has not been implemented at Oyster Creek.
In 1994, the NRC issued information notice (lN)94-048, "Snubber Lubricant Degradation in High-Temperature Environments", which alerted licensees to possible degradation of the lubricant used in mechanical snubbers manufactured by PSA when the snubber is used in a high temperature environment. The lN describes failure of the grease by mechanisms of hardening and loss of viscosity in PSA mechanical snubbers when exposed to high temperatures. The NRC issued lN 94-048 for licensees to review and for consideration of appropriate actions to avoid similar problems but did not require any regulatory action.
Oyster Creek's snubber testing program is contained in SP-1302-52-045, "Requirements for Functional Testing of Snubbers". This procedure defines the requirements and acceptance criteria for functional testing of PSA mechanical snubbers, as well as the test and acceptance criteria required by technical specifications.
The inspector reviewed available maintenance records for the four failed snubbers identified in 1R23. These snubbers had failed or were found degraded and had to be replaced at a time-in-service ranging from 6 to 17 years despite having a designated service life of 40 years. The four failed snubbers had a history of repetitive failures.
Three of the snubbers were found to be failed or degraded three times including the failure identified in 1R23. The remaining snubber failed for the second time in 1R23.
Despite the maintenance and testing history of these snubbers, no change to the designated 40 year service life was made. The testing requirements in TS 4.5.M.1.c (10% every 24 months) ensure that each snubber will be tested once every 20 years.
The demonstrated service lives of snubbers that were identified as failed during 1R23 are much shorter than the time between TS required testing intervals. SP-1302-52-045, "Requirements for Functional Testing of Snubbers", does not have any provisions to update service life of snubbers after they are found degraded or failed, which inhibits Exelon's ability to meet TS 4.5.M.1.f to conduct a review of snubber records to verify that indicated service life will not exceeded until the next service life review. Additionally, the discovery of a failed snubber requires that engineering perform an evaluation to show that the failed snubber had no adverse effects on the piping. This does not meet the requirement contained in TS 4.5.M.1.f stating that the service life of a snubber shall not at any time affect reactor operation, but instead provides a reactive means to review past operability.
The inspectors noted that Exelon has two corporate procedures, ER-AA-330-010 "snubber Functional Testing" and ER-AA-330-011 "Snubber Service Life Monitoring" that serve as guidance for individual sites to test and monitor seryice life of snubbers.
These procedures have not been implemented at Oyster Creek.
Analvsis: Exelon's failure to take into account the maintenance and testing history of snubbers when determining designated service life so that a review of the snubber testing plan to ensure that service life is not exceeded prior to the scheduled snubber service life review is a performance deficiency.
There are no similar examples in IMC 0612, Appendix E, "Examples of Minor lssues".
This flnding is more than minor because it affects the equipment performance attribute of the mitigating systems cornerstone to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences, specifically the safety related piping systems in containment.
ln accordance with table 4a of IMC 0609.04, "Phase 1 - lnitial Screening and Characterization of Findings," the finding was determined to be of very low safety significance (Green) because it was a qualification deficiency confirmed not to result in loss of operability or functionality.
This finding has a cross-cutting aspect in the area of problem identification and resolution because Exelon did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions. Additionally, Exelon did not conduct effectiveness reviews of corrective actions to ensure that the problems are resolved. (P.1(c)).
Enforcement:
TS 4.5.M.1.f requires that installation and maintenance records for each snubber be reviewed to verify that the indicated service life has not been exceeded or will not be exceeded prior to the next schedule snubber service life review. Contrary to the above, Exelon failed to consider snubber maintenance history when evaluating designated service life values and conducting snubber service life reviews required by TS. Because this violation was of very low safety significance and it was entered into Exelon's corrective action program as lR 1170026, this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV 05000219/2010-005-01, Snubber Maintenance History Not Taken Into Account When Conducting Service Life Reviews).
1R13 Maintenance Risk Assessments and Emersent Work Control
a. lnspection Scope (4 samples)
The inspectors reviewed four on-line risk management evaluations through direct observation and document reviews for the following plant configurations:
.
Bank 6 startup transformer, 'B'battery charger, and 'B'control rod drive system unavailable due to planned maintenance on October 20;
.
Core spray system #2 planned unavailability and reactor water inventory management during refueling outage on November 22; o 'A' control rod drive system and main transformer M1B unavailable due to planned maintenance on December 6; and o Both station blackout combustion turbines unavailable due to adverse weather conditions, and #1 EDG unavailable due to a battery charger failure on December 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 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 lnformation attachment to this report.
b. Findinqs No findings were identified.
1R15 Operabilitv Evaluations
a. Inspection Scope
(5 samples)
The inspectors reviewed five operability evaluations for degraded or non-conforming conditions associated with:
o fnoperable core spray snubber on October 1 (lR 1120002);o lP20B power supply failure on October 18 (lR 1123503);o Degraded weld on embedded plate in torus bay 9 on November 16 (lR 1138764);e Emergency diesel generator after discrepancies following loss of offsite power test on November 29 (lR 1145338); and
.
Torus to drywell vacuum breakers on November 30 (lR 1145393).
The inspectors reviewed the technical adequacy of the operability evaluations to ensure the conclusions were technically justified. The inspectors also walked down accessible portions of equipment to corroborate the adequacy of Exelon's operability evaluations.
Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findinqs No findings were identified.
1R18 Plant Modifications (7 1 1 1 1
.18 )
a. Inspection Scope
(1 temporary and 1 permanent modification samples)
The inspectors reviewed one temporary and one permanent plant modification that were implemented by Exelon personnel at Oyster Creek. The inspectors reviewed the following modifications:
.
Bypass valve opening jack circuitry (temporary modification 10-00601); and
.
Deluge system modification for M1B transformer replacement (permanent modification 09-00573);
The inspectors reviewed the engineering/procedure 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 walked down portions of the systems associated with the modification when applicable and prudent. 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 each of the modifications. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b.
Findinqs No findings were identified.
1R19 Post-Maintenance Teetinq
a. Inspection ScEre (5 samples)
The inspectors observed portions of and/or reviewed the results of five post-maintenance tests for the following equipment:
Containment spray and emergency service water (ESW) system 2 following inspection of keepfill checkvalve V-3-131 on October 6 (R2162788);
Main steam isolation valve (MSIV) V-1-9 leak rate test following completion of valve maintenance on November 22 (42263426);
MSIV V-1-8 leak rate test following completion of valve maintenance on November 23 (R213%a$;
lnservice test baseline after core spray NZO1B motor replacement on November 17 (R2138066); and
.
M1B Hyundai main transformer replacement with Utah transformer on December 16 (c20246e4).
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.
Findinqs No findings were identified.
1R20 Refuelinq and OthelOutaqe Activities
a.
lnspection Scope (3 samples)
The inspectors monitored Exelon's activities associated with the outage activities described below. Documents reviewed for this inspection activity are listed in the Supplemental lnformation attachment to this report.
Refuelinq Outaqe (1 R23)
On October 31, operators initiated a plant shutdown to support the 1R23 refueling outage. The inspectors observed portions of the shutdown from the control room, and reviewed plant logs to ensure that technical specification requirements were met for placing the reactor in "hot shutdown" and "cold shutdown." The inspectors also monitored Exelon's controls over outage activities to determine whether they were in accordance with procedures and applicable TS requirements.
The inspectors verified that cool down rates during the plant shutdown were within TS requirements. The inspectors performed a walkdown of accessible portions of the drywell (primary containment) on November 2, and the condenser bay and the main steam tunnel on November 3, to verify that sources of leakage were identified and that there was no evidence of visual damage to passive systems contained in these areas.
The inspectors noted the presence of a small amount of water in the bay 5 drywell trench. The bay 17 drywelltrench was dry. The inspectors verified that Exelon assessed and managed outage risk. The inspectors confirmed, on a sampling basis, that tagged equipment was properly controlled and equipment configured to safely support maintenance and plant operations. During control room tours, the inspectors verified that operators maintained reactor vessel level and temperature within the procedurally required ranges for the operating condition. The inspectors also verified that the decay heat removal function was maintained by performing a walkdown of the system on November 7 and by periodically monitoring shutdown cooling (SDC)parameters throughout the outage. The inspectors observed Oyster Creek's plant onsite review committee (PORC) startup affirmations on November 29.
The inspectors performed an inspection and walkdown of portions of the drywell prior to containment closure on November 29, to verify there was no evidence of leakage or visual damage to passive systems and to verify that debris was not left which could affect drywell suppression pool performance during postulated accident conditions. The inspectors monitored restart activities that began on November 30. The inspectors ensured that, through verification of technical specification requirements, license conditions, and procedural requirements, required equipment was available to support operational condition changes. Portions of the startup activities were observed from the control room to assess operator and equipment performance. The inspectors further verified that unidentified leakage and identified leakage rate values were within expected values and within technical specification requirements.
During startup activities on December 1, control room operators responded to indications of an unidentified leak rate of approximately 17 GPM. The operators isolated the 'B' recirculation loop due to indications that the leakage was from the 'B' recirculation pump mechanical seal, which stopped the leak. Operators then declared an Unusual Event per Emergency Action Level (EAL) guidance. This event is described in detail in section 4OA3 of this report. After this event, Exelon commenced startup on 4 recirculation loops instead of the typical five loop operation.
Other Outaoe Activitv - Forced Outaqe due to Main Transformer Failure and Reolacement (1F23. 24. 25)ln December, operators reduced power and took the turbine offline three times to support a planned maintenance outage due to a failure of the M1B main transformer.
Exelon replaced both the M1A and M1B main transformers with new transformers during refueling outage 1R23 in November. During power ascension following 1R23, online oil monitoring equipment on the M1B main transformer indicated the increasing presence of acetylene and other gases, which was indicative of an internal fault. As a result, Exelon decided to remove the newly installed Hyundai transformer and replace it with the previously installed Utah transformer. On December 2, operators reduced power and took the generator offline to electrically disconnect Hyundai transformer (1F23). Exelon placed the generator online and returned to 50% power on December 4. On December 9, operators reduced power and took the generator offline to move the Hyunda, transformer from the transformer pad to a storage area and moved the spare Utah transformer from the storage area to the transformer pad (1F24). Exelon placed the generator online and returned to 50% power on December 12. On December 15, operators reduced power and took the generator offline to electrically connect the Utah transformer (1F25). The plant returned to 100% power on December 17.
Other Outaqe Activitv - Forced Outaqe due to Recirculation Pump Trip (1F26)
On December 19, operators initiated and completed an unplanned plant shutdown to support a forced outage to repair the 'B' reactor recirculation pump mechanical seal and to perform electrical troubleshooting on the 'A' reactor recirculation pump, which had tripped on December 18 and is described in section 4OA3 of this report. The inspectors observed portions of the shutdown from the control room, and reviewed plant logs to ensure that TS requirements were met for placing the reactor in "hot shutdown" and "cold shutdown." The inspectors also monitored Exelon's controls over outage activities to determine whether they were in accordance with procedures and applicable TS requirements.
The inspectors verified that cool down rates during the plant shutdown were within TS requirements. The inspectors performed a walkdown of portions of the drywell on December 21. The inspectors noted the presence of standing water in the bay 5 and 17 drywell trenches, which Exelon placed in the corrective action program (lR 1 155037).
The inspectors verified that Exelon assessed and managed outage risk. The inspectors confirmed on a sampling basis that tagged equipment was properly controlled and equipment configured to safely support maintenance and plant operations. During control room tours, the inspectors verified that operators maintained reactor vessel level and temperature within the procedurally required ranges for the operating condition. The inspectors also verified that the decay heat removal function was maintained through monitoring SDC parameters. The inspectors observed Oyster Creek's PORC startup affirmations on December 22.
The inspectors performed an inspection and walkdown of portions of the drywell prior to final containment closure on December 22, to verify that any observed leakage was documented, that there was no visual damage to passive systems and to determine that debris was not left which could affect drywell suppression pool performance during postulated accident conditions. The inspectors again noted the presence of standing water in the bay 5 and 17 drywelltrenches, which Exelon placed in the corrective action program (lR 1155422). The inspectors monitored restart activities that began on December 23, to ensure that required equipment was available for operational condition changes, including verifying TS requirements, license conditions, and procedural requirements. Portions of the startup activities were observed from the control room to assess operator and equipment performance. During the plant startup, an automatic scram occurred and is described in section 4OA3 of this report. The inspectors monitored portions of the subsequent startup that began on December 24 to ensure that required equipment was available for operational condition changes, including verifying TS requirements, license conditions, and procedural requirements. Oyster Creek synchronized the main generator to the grid and achieved full power on December 25.
The inspectors verified that unidentified leakage and identified leakage rate values were within expected values and within TS requirements following return to power operations.
b. Findinos No findings were identified.
1R22 Surveillance Testinq (7 1111
.22 )
a. Inspection Scope
(1 In-Service Testing sample, 1 lsolation valve sample and 3 routine surveillance samples)
The inspectors observed portions of and/or reviewed the results of 5 surveillance tests:
o Fire deluge system #10 surveillance test on October 14 (R2135571);
.
Core spray 'D' check valve surveillance test on November 8 (R2026637);
.
- 2 emergency dieselgenerator LOCA/LOOP surveillance test on October 13 (R2133261);o Main steam isolation valve V-1-9 closure and IST test on November 29 and 30 (A2263426); and
.
Reactor protection system output breaker trip test on December 28 (R2168175).
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. Findinos No findings were identified.
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety (OS)
RS01 Access Control to Radiolooicallv Siqnificant Areas (71124.01)a. lnspection Scope (1 sample)
The inspectors reviewed licensee activities and associated documentation to inspect Exelon's performance in the inspection areas listed below. The evaluation of Exelon's performance was against criteria contained in 10 CFR 20, TSs, and applicable station procedures.
lnspection Plannino The inspectors reviewed Performance Indicators (Pls) for the Occupational Exposure Cornerstone. The inspectors also reviewed the results of recent radiation protection program audits and assessments and any reports of operational occurrences related to occupational radiation safety since the last inspection. (See Section 4OA1)
Radiological Hazard Assessmenl The inspectors discussed plant operations to identify any significant new radiological hazards for onsite workers or members of the public. The inspectors assessed the potential impact of the changes and monitoring to detect and quantify the radiological hazard.
The inspectors toured radiological controlled areas and reviewed radiological surveys of plant areas (e.g., refueling floor, reactor cavity, reactor building, turbine building, condenser bay, drywell, and the torus), and outdoor areas to verify that the thoroughness and frequency of the surveys were appropriate for the given radiological hazard.
The inspectors conducted walkdowns of the facility, including the dry-active waste storage buildings and outdoor storage areas, to evaluate material conditions and potential radiological conditions. The inspectors made independent radiation measurements to verify condition.
The inspectors selected various radiological risk significant work activities (reactor cavity, in vessel work activities, drywell work activities, condenser bay work, turbine work and iorus diving activities) that involved exposure to radiation to verify that appropriate pre-work surveys were performed to identify and quantify the radiological hazard and to establish adequate protective measures. The review included identification of discrete particles, the presence of alpha emitters, the potential for airborne radioactive materials, potential changes in radiological conditions, and non-uniform exposures of the body.
The inspectors reviewed and discussed air sample survey records associated with various work activities to verify that samples were representative of breathing zone and collected and counted in accordance with procedures. The inspectors reviewed the use and operation of continuous air monitors during plant tours. The inspectors reviewed consideration of potential airborne radioactivity generation in areas of loose surface contamination.
lnstructions to Workers The inspectors toured radiologically controlled areas, including outage work areas, and reviewed labeling of containers of radioactive materials to verify that container labeling was consistent with requirements and was informative to workers' The inspectors reviewed a sample of radiation work permits (RWP), ALARA reviews, and radiological surveys used to access high radiation areas (HRA). The purpose of the review was to verify that work control instructions, specified control barriers, stay times or permissible dose limits, and electronic personal dosimeter (EPD) alarm set-points were in conformance with survey indications. Areas reviewed included the drywell, turbine work areas, refueling floor, and the condenser bay. The inspectors evaluated Exelon's changes to setpoints for specified conditions and subsequent updating of radiation work permits. The inspectors reviewed ongoing remote monitoring via teledosimetry.
The inspectors reviewed ongoing work activities in the radiological controlled area to evaluate methods used by Exelon to update workers on changes in radiologicalwork conditions.
Contamination and Radioactive Material Control The inspectors observed locations where Exelon monitors potentially contaminated material leaving the radiologically controlled area (RCA), and inspected the methods used for control, survey, and release from the RCA. The inspectors observed the performance of personnel surveying and releasing materialfor unrestricted use to verify that the work was performed in accordance with plant procedures. The inspectors reviewed the procedures to ensure that they were sufficient to control the spread of contamination and prevent unintended release of radioactive materials from the site.
The inspectors evaluated the radiation monitoring instrumentation sensitivity to verify that it was adequate for the types of radiation present.
The inspectors reviewed Exelon's criteria for the survey and release of potentially contaminated material. The inspectors verified that there was guidance on how to respond to an alarm that indicates the presence of radioactive material.
The inspectors reviewed procedures and records to verify that the radiation detection instrumentation was used at an appropriate sensitivity level based on observed background parameters in the counting area. The inspectors ensured that application of alarm setpoints was based on the instrument's sensitivity. The inspectors also discussed alarm setpoints and typical detection capabilities with licensee personnel.
The inspectors selected a sample of sealed sources, those presenting the greatest radiological risk, from Exelon's inventory records and verified that the sources were accounted for and have been verified to be intact. The inspectors discussed any transactions involving nationally tracked sources to evaluate reporting in accordance with 10 CFR20.2207.
Radiolooical Hazards Control and Work Coveraqe The inspectors toured the facility and reviewed ongoing work and evaluated ambient radiological conditions (e.9., actual or potential radiation levels or airborne radioactivity levels). The inspectors verified the existing conditions were consistent with posted surveys, RWPs, and worker briefings.
The inspectors observed ongoing work activities and verified the adequacy of radiological controls, such as required surveys (including system breach radiation, contamination, and airborne surveys), radiation protection job coverage (including audio and visual surveillance for remote job coverage), and contamination controls. The inspectors evaluated Exelon's use of electronic personnel dosimeters (EPDs) in high noise areas as HRA monitoring devices (e.9., use of teledosimetry).
The inspectors verified that radiation monitoring devices (thermoluminescent dosimeters (TLD))were placed on the monitored individual's body consistent with the method that Exelon was employing, to monitor dose from external radiation sources. The inspectors verified, by direct observation, that the dosimeters were placed in the location of highest expected dose. As part of this review, the inspectors reviewed the use of dosimetry to effectively monitor exposure to personnel in high-radiation work areas with significant dose rate gradients.
The inspectors reviewed three radiation work permits for work within potential airborne radioactivity areas with the potentialfor individual worker internal exposures. The inspectors evaluated airborne radioactive controls and monitoring, including potentials for significant airborne levels (e.9., grinding, grit blasting, system breaches, entry into tanks, cubicles, reactor cavities). The inspectors reviewed system breech activities including use of local ventilation system and respiratory protection equipment to minimize airborne radioactive exposure.
The inspectors observed ongoing work activities within flooded pools and examined Exelon's physical and programmatic controls for highly activated or contaminated materials (nonfuel) stored within storage pools. The inspectors verified that appropriate controls (i.e., administrative and physical controls) were in place to preclude inadvertent removal of these materials from the pool.
The inspectors conducted inspection of posting and physical controls for HRAs and Very High Radiation Areas (VHRA), to the extent necessary to verify conformance with the Occupational Pl. The inspectors evaluated reduction in controls of areas (e.9., changing posting of areas from HRAs to Radiation Areas).
Risk-Sionificant Hioh Radiation Area and Verv Hiqh Radiation Area Controls The inspectors discussed with the Radiation Protection Manager (RPM), the controls and procedures for high-risk HRAs and VHRAs and any procedural changes since the last inspection. The inspectors discussed methods employed by Exelon to provide stricter control of VHRA access including potential reduction in the effectiveness and level of worker protection (e.9., use of lock boxes).
The inspectors discussed with health physics supervisors, controls for special areas that had the potential to become VHRAs during certain plant operations including controls to ensure that an individualwas not able to gain unauthorized access to the VHRA.
Radiation Worker Performance The inspectors observed radiation worker performance with respect to stated radiation protection work requirements to determine if performance reflected the level of radiological hazards present. The inspectors interviewed numerous workers conducting work activities in the radiological controlled area to determine if workers were aware of the radiological conditions in their workplace and the RWP controls/limits in place.
The inspectors reviewed at least ten radiological problem reports since the last inspection to identify human performance errors and determine if there were any observable patterns. The inspectors discussed corrective actions for identified concerns with licensee personnel.
Radiation Protection Technician Proficiencv The inspectors observed the performance of radiation protection technicians with respect to radiation protection work requirements to determine if technicians were aware of the radiological conditions in their workplace and the RWP controls/limits and if their performance was consistent with their training and qualifications with respect to the radiological hazards and work activities.
The inspectors reviewed outage radiological problem reports to identify those that indicate the cause of the event to be radiation protection technician error and to evaluate the corrective action approach taken by Exelon to resolve the reported problems.
b. Findinqs No findings were identified.
RSO2 Occupational ALARA Planninq and Controls (71124.02)a. lnspection Scope The inspectors reviewed Exelon's performance, in the below identified areas, with respect to maintaining individual and collective radiation exposure ALARA.
lnspection Planninq The inspectors reviewed pertinent information regarding plant collective exposure history, current exposure trends, and ongoing or planned activities in order to assess current performance and exposure challenges. The inspectors determined the plant's 3-year rolling average collective exposure.
The inspectors determined the site-specific trends in collective exposures using various methods such as plant historical data, including outage work dose based on task, evaluation of ALAM data, and licensee source term data.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA including the processes used to estimate and track exposures from specific work activities.
Radioloqical Work Planning The inspectors obtained from Exelon a list of work activities ranked by actual or estimated exposure that were planned or in progress and selected work activities of the highest exposure significance. These included reactor disassembly, control rod drive work, scaffolding, torus diving, and valve work.
The inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure mitigation requirements. The inspectors determined if Exelon reasonably grouped the radiologicalwork into work activities, based on historical precedence, industry norms, and/or special circumstances.
The inspectors determined if Exelon's planning identified appropriate dose mitigation features; considered, commensurate with the risk of the work activity, alternate mitigation features; and defined reasonable dose goals. As applicable, the inspectors verified that Exelon's ALARA assessment had taken into account decreased worker efficiency from use of respiratory protective devices.
The inspectors determined if Exelon's work planning considered the use of remote technologies (such as teledosimetry, remote visual monitoring, or robotics) as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors verified the integration of ALARA requirements into work procedure and radiation work permit (RWP) documents.
The inspectors compared accrued results achieved (person-rem), with the intended dose established in Exelon's ALARA planning for work activities that exceeded 5 person-rem aggregate dose. The inspectors determined the reasons for any inconsistencies between intended and actualwork activity doses, as accrued. The inspectors discussed aggregate exposure sustained during the 1R23 outage as compared to established pre-outage goals.
Verification of Dose Estimates and Exposure Trackinq Svstems The inspectors selected at least five ALARA work packages and reviewed the assumptions and bases for the collective exposure estimate for reasonable accuracy.
The inspectors reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and the intended dose outcome. The inspectors also reviewed approvals by the station ALARA committee.
The inspectors verified, for the selected work activities, that Exelon established measures to track, trend, and if necessary to reduce, occupational doses for ongoing work activities including criteria to prompt additional reviews and/or controls.
The inspectors evaluated the adequacy of Exelon's method of adjusting exposure estimates when unexpected changes in scope or emergent work are encountered.
Source Term Reduction and Control The inspectors used licensee records to determine the historical trends and current status of significant tracked plant source terms known to contribute to elevated facility aggregate exposure. The inspectors discussed source term mitigation with licensee staff and reviewed the stations Five-Year ALARA plan. The inspectors discussed contingency plans for potential changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.
Radiation Worker and Radiation Protection Technician Performance The inspectors observed both radiation worker and radiation protection technician performance during work activities being performed in radiation areas, airborne radioactivity areas, or high radiation areas. The inspectors determined if workers demonstrated the ALARA philosophy in practice and whether there were any procedure compliance issues. The inspectors observed performance to determine whether the training and skill level were sufficient with respect to the radiological hazards and the work involved.
b. Findinqs No findings were identified.
RSO3 ln-Plant Airborne Radioactivitv Control and Mitiqation (71 124.03)
a. Inspection Scope
The inspectors assessed Exelon's performance associated with efforts to limit generation and minimization of occupational intake of airborne radioactive material.
Inspection Planninq The inspectors reviewed the UFSAR to identify areas of the plant designed as potential airborne radiation areas and any associated ventilation systems or airborne monitoring instrumentation. The inspectors also reviewed the UFSAR for overview of respiratory protection program and a description of the types of devices used.
The inspectors reviewed Exelon's procedures for maintenance, inspection, and use of respiratory protection equipment including procedures for air quality maintenance. The inspectors directly observed and evaluated the use of respiratory protection equipment during ongoing work activities.
The inspectors reviewed the reported Occupational Performance lndicators to identify any related to unintended dose resulting from intakes of radioactive materials.
Enqineerino Controls The inspectors evaluated Exelon's use of ventilation systems as part of its engineering controls to control airborne radioactivity. The inspectors discussed procedural guidance for use of installed plant systems to verify system use, to the extent practicable, during high-risk activities. The inspectors discussed verification of plant ventilation systems during reactor cavity work.
The inspectors reviewed installed ventilation systems used to mitigate the potentialfor airborne radioactivity. The inspectors discussed use of installed systems during work activities associated with reactor cavity work.
The inspectors selected two temporary ventilation system setups (high efficiency particulate absolute) filters to support work in contaminated areas. The inspectors discussed the use of these systems with respect to procedural guidance and ALARA.
The inspectors selected installed systems to monitor and warn of changing airborne concentrations in the plant. The inspectors evaluated the alarms and setpoints to prompt licensee/worker action to ensure that doses are maintained within the limits of 10 CFR Part2Q and ALAM. The inspectors observed monitoring of ambient conditions.
The inspectors evaluated that licensee's use of trigger points for evaluating levels of hard{o detect airborne radionuclides.
Use of Respiratorv Protection Devices The inspectors evaluated Exelon's use of respiratory protection devices to maintain occupational doses ALARA. The inspectors selected work activities where respiratory protection devices were used (e.9., control rod drive removal, grit blasting) to limit the intake of radioactive materials, and evaluated the use of respirators. The inspectors evaluated Exelon's means to verify that the level of protection (protection factor)provided by the respiratory protection devices during use was at least as good as that assumed in Exelon's work controls and dose assessment.
The inspectors evaluated the use of certified equipment (respiratory protection devices)to limit the intake of radioactive materials and evaluated that the devices were used consistent with their NIOSH/MSHA certification or any conditions of their NRC approval.
The inspectors reviewed records of air testing for supplied-air devices to verify that air used in these devices meets or exceeded appropriate quality. The inspectors evaluated the breathing air supply systems against the minimum pressure and airflow requirements for the devices in use.
The inspectors selected individuals qualified to use respiratory protection devices, and verified that they have been deemed qualified to use the devices.
The inspectors observed individuals assigned to wear a respiratory protection device and observed them donning and functionally checking the device as appropriate. The inspectors discussed their use of the devices including how to properly respond to any device malfunction or unusual occurrence.
b. Findinqs No findings were identified.
RS04 Occupational Dose Assessment (71124.04)
a. Inspection Scope
The inspectors evaluated Exelon's occupational dose assessment program to assess the accuracy and effectiveness of Exelon's ability to measure occupational dose, including internal dose.
Inspection Plannino The inspectors reviewed the results of available radiation protection program audits related to internal and external dosimetry to gain insights into overall licensee performance in the area of dose assessment.
The inspectors reviewed Exelon's current National Voluntary Laboratory Accreditation Program (NVLAP) accreditation report for Exelon personnel dosimetry.
The inspectors reviewed licensee procedures associated with dosimetry operations, including issuance/use of external dosimetry (routine, multi-badging, extremity, neutron, etc.), and assessment of internal dose. The inspectors evaluated procedure guidance for personnel monitoring.
External Dosimetrv The inspectors evaluated the use of Exelon's personnel dosimeters that require processing, to determine if they were NVLAP accredited. The inspectors determined if Exelon uses a "correction facto/'to address the response of the electronic dosimeter (ED) as compared to its TLD for situations when the ED must be used to assign dose.
Intern?l Dosimetrv The inspectors reviewed routine bioassay (in vivo) procedures used to assess dose from internally deposited nuclides using whole body counting equipment. The inspectors determined if the procedures address methods for determining if an individual is internally or externally contaminated, the release of contaminated individuals, the determination of entry route (ingestion, inhalation), and assignment of dose.
The inspectors evaluated the minimum detectable activity (MDA) of Exelon's instrumentation used for passive whole body counting to determine if the MDA was adequate to determine the potential for internally deposited radionuclides sufficient to prompt additional investigation.
Special Dosimetric Situations The inspectors reviewed Exelon's program to inform workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy.
The inspectors reviewed Exelon's methodology for monitoring external dose in situations in which non-uniform fields are expected or large dose gradients could exist (e.9,, diving activities, valve work) to verify that Exelon established criteria for determining when alternate monitoring techniques (i.e., use of multi-badging or determination of effective
' dose equivalent for external exposures using an approved method) were to be implemented.
b. Findinqs No findings were identified.
RS05 Radiation Monitorinq Instrumentation (71 122.05)a. lnspection Scope The inspectors evaluated Exelon's radiation monitoring instrumentation to assess the performance of Exelon in ensuring the accuracy and operability of radiation monitoring instruments.
Inspection Planninq The inspectors reviewed the UFSAR to identify radiation instruments associated with monitoring area radiological conditions including airborne radioactivity, process streams, effluents, materials/articles, and workers.
The inspectors obtained a listing of in-service survey instrumentation including air samplers and small article monitors (SAMs), along with instruments used for detecting and analyzing workers'external contamination (personnel contamination monitors (PCMs)) and workers' internal contamination (portal monitors (PMs), whole body counters (WBCs)), including neutron monitoring instrumentation to determine whether an adequate number and type of instruments are available to support operations.
The inspectors obtained and reviewed copies of licensee and third-party (independent)evaluation reports of the radiation monitoring program since the last inspection, including audits of Exelon's offsite calibration facility and reviewed the reports for insights into Exelon's program.
The inspectors reviewed procedures that govern instrument source checks and calibrations. The inspectors review the calibration and source check procedures for adequacy. The inspectors reviewed calibration records and source checks for contamination monitoring instruments.
Walkdowns and Observations The inspectors walked down the stack monitoring system, to verify that effluenUprocess monitor configurations align with ODCM descriptions. The inspectors looked for monitor degradation and/or out-of-service tags.
The inspectors selected at least five portable survey instruments in use or available for issuance and checked calibration and source check stickers for currency, and to assess instrument material condition and operability. The inspectors evaluated instrumentation in use within the radiological controlled area to validate current calibration and source checking. The inspectors reviewed source checking of different types of portable survey instruments.
The inspectors walked down five area radiation monitors, including portable area monitors, and continuous air monitors (CAMs) to determine whether they were appropriately positioned relative to the radiation source or area they were intended to monitor. The inspectors compared monitor response (via local or remote indication) with actual area conditions for consistency. The inspectors evaluated instrumentation in-place on the refueling bridge and work platforms.
The inspectors selected PCMs, PMs, and SAMs and verified that the periodic source checks were performed in accordance with licensee procedures. The inspectors reviewed alarm set-point data for various personnel and equipment monitors at three radiological controlled area exits to verify that the alarm set-point values were reasonable under the circumstances to ensure that licensed material was not released from the radiological controlled area.
Calibration and Check Sources
The inspectors reviewed Exelon's latest 10 CFR Part 61 source term to determine if the calibration sources used were representative of the types and energies of radiation encountered in the plant.
b. Findinos No findings were identified.
Cornerstone: Public Radiation Safety (PS)
RSO6 Radioactive Gaseous and Liquid Effluent Treatment (71124.06)
Inspection Scope The inspectors reviewed aspects of Exelon's gaseous and liquid effluent control program in the below listed areas.
(Note: Exelon identified operability issues with the Plant Stack Monitor in April 2010.
This issue was previously reviewed and discussed in NRC Inspection Report
===05000219/2010003, dated August 9,2010 (ADAMS ML102210111). See Section 4OA5 for a discussion of this issue.)
Event Report and Effluent Report Reviews The inspector's reviewed the 2006, 2007,2008, and 2009 Annual Radiological Effluent Release Reports. The inspectors determined if the reports were submitted as required by the ODCM/Technical Specifications. The inspectors reviewed the reports for anomalous results, unexpected trends or abnormal releases identified by Exelon for further inspection to determine if they were evaluated, were entered in the corrective action program, and were adequately resolved.
The inspectors reviewed the Radiological Effluent Release reports to ldentify radioactive effluent monitor operability issues reported by Exelon as provided in effluent release reports. The inspectors reviewed these issues during the onsite inspection, as warranted, given their relative significance. The inspectors determined if the issues were entered into the corrective action program and adequately resolved.
ODCM and UFSAR Reviews The inspectors reviewed the UFSAR descriptions of the radioactive effluent monitoring systems, treatment systems, and effluent flow paths during inspection walk-downs.
The inspectors reviewed changes to the ODCM made by Exelon since the last inspection, to review the technical basis or evaluations of the change and to determine whether they were technically justified and maintained effluent releases ALARA.
Groundwater Protection Initiative (GPl) Prooram The inspectors reviewed reported groundwater monitoring results, and changes to the program for identifying and controlling contaminated spills/leaks to groundwater.
The inspectors reviewed Exelon's evaluations and program to provide for release of tritiated groundwater associated with its remediation of tritium groundwater. The inspectors reviewed changes made to the ODCM to support this activity. The inspectors reviewed projected dose calculations with respect to guidance contained in NRC Regulatory Guide 1
.109 . As part of this review, the inspectors walked-down the
pumping system at the intake, used for the groundwater remediation effort.
Procedures. Special Reports & Other Documents The inspectors reviewed LERs, event reports and special reports related to the effluent program issued since the previous inspection. The inspectors reviewed these documents to identify any additional focus areas for the inspection based on the scope/breadth of problems described in these reports.
Walkdowns and Observations The inspectors determined if Exelon made any significant changes to its effluent release points, e.9., changes subject to a 10 CFR 50.59 review or requiring NRC approval of alternate discharge points.
Samplinq and Analvses The inspectors determined if Exelon was routinely relying on the use of compensatory sampling in lieu of adequate system maintenance.
Effluent Flow Measurinq lnstruments The inspectors reviewed the methodology used to determine the effluent stack and plant vent flow rates.
Problem ldentification and Resolution The inspectors reviewed problems associated with the effluent monitoring and control program to determine if they were identified by Exelon at an appropriate threshold and were properly addressed for resolution in the corrective action program. (See Section 4c.A2)b. Findinqs No findings were identified.
4. OTHER ACTTVTTTES [OA]
4OA1 Performance lndicator Verification
a. Inspection Scope
=
.1 Occupational Exposure Control Effectiveness (1 Sample)
a. Inspection Scope
(71 151)
The inspectors reviewed Exelon's program to gather, evaluate, and report information on the occupational exposure control effectiveness performance indicator (Pl). The inspectors used the guidance provided in Nuclear Energy Institute (NEl) 99-02, Revision 6, "Regulatory Assessment Performance Indicator Guideline" to assess the accuracy of Exelon's collection and reporting of Pl data. The inspectors reviewed corrective action program records for occurrences involving High Radiation Areas, Very High Radiation Areas, and unplanned personnel radiation exposures since the last inspection in this area. The purpose of this review was to verify that occurrences that met NEI criteria were recognized and identified as Performance Indicators.
b. Findinqs No findings were identified.
RETS/ODCM Radioloqical Effluent Occurrences (1 Sample)
a. Inspection Scope
(71 1 51 )
The inspectors reviewed Exelon's program to gather, evaluate, and report information on the radiological effluents technical specification/offsite dose calculation manual (RETSiODCM) Pl. The inspectors used the guidance provided in NEI 99-02 to assess the accuracy of Exelon's collection and reporting of Pl data. The inspectors reviewed corrective action program records and projected monthly and quarterly dose assessment results due to radioactive liquid and gaseous effluent releases for the past four complete quarters. The purpose of this review was to verify that occurrences that met NEI criteria were recognized and identified as Performance Indicators. As part of this review, the inspectors also reviewed Exelon's evaluations and public dose assessments associated with identification of localized ground water contamination within the restricted area.
b. Findinos No findings were identified.
Mitiqatino Svstems Performance Indicators (5 samples)
The inspectors reviewed Exelon's program to gather, evaluate, and report information on five Pls associated with the mitigating systems performance index (MSPI). The inspectors used the guidance provided in NEI 99-02 to assess the accuracy of Exelon's collection and reporting of Pl data. The inspectors reviewed operating logs and corrective action program condition reports. The inspectors verified the accuracy and completeness of the reported data from October 1,2009 through September 30, 2010 for the following Pls:
o Emergency AC power system;
.
High pressure injection system;
.
Heat removal system;
.
Residual heat removal system; and r Cooling water systems.
Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.
b. Findinqs No findings were identified.
4c.42 ldentification and Resolution of Problems (71152)
,1 Review of ltems Entered Into the Corrective Action Proqram 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 follow-up. The screening was accomplished by reviewing hard copies of condition reports, attending daily screening meetings, or accessing Exelon's computerized database.
,2 Semi-Annual Review to ldentifv Trends
Inspection Scope (1 sample)
The inspectors performed one semi-annualtrend review. The inspectors reviewed Exelon's corrective action program documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors also performed a walkdown of equipment important to safety to ensure issues were being properly identified and corrected in the corrective action program. The inspectors review was focused on repetitive equipment problems, human performance issues, and program implementation issues. The results of the trend review by the inspectors were compared with the results of normal baseline inspections. The review included issues documented outside the normal corrective action system, such as in system health reports and Oyster Creek monthly management reports. The review considered a six-month period of June through December 2010.
b.
Assessment and Observations No findings were identified.
.3 Annual Sample Review
a. Inspection Scope
(1 Operator Work Around and 1 annual sample)
The inspectors reviewed Exelon's evaluation and corrective actions associated with the following two issues. Documents reviewed for these inspection activities are listed in the Supplemental Information attachment to this report.
Operator Work-Arounds (Cumulative Review). The inspectors reviewed equipment issues that Exelon identified as operator work-arounds (OWA) or operator challenges.
The inspectors verified that the OWAs were being properly controlled as specified by OP-AA-102-103, "Operator Work-Around Program." The inspectors assessed the cumulative impact of the identified OWAs, operator challenges, and control room deficiencies by performing a detailed document review and interviewing operations personnel during the week of December 15. In addition, the inspectors conducted a walkdown of the main control room and risk significant plant areas to determine if these deficiencies adversely affected the ability of operations personnel to implement emergency operating procedures or respond to plant transients.
Torus Vacuum Breaker V-26-18 O-Rinq Missinq. The inspectors reviewed Exelon's evaluation and corrective actions associated with the torus vacuum breaker V-26-18 actuator o-ring missing (lR 1142958). Exelon noted an air leak on the piston actuator for the reactor building to torus vacuum breaker air actuator during the last run cycle. When Exelon performed corrective maintenance on the actuator during the 1R23 outage, maintenance personnel noted the o-ring was missing on the cylinder flange. Exelon rebuilt the actuator with a correctly installed o-ring under work order C2024491. 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.
b. Findinqs and Observations No findings were identified.
,4 Problem ldentification and Resolution for Inservice Inspection (71111.08)
a. Inspection Scope
The inspectors reviewed a sample of corrective action reports that identified nonconforming conditions discovered during the most recent and previous refueling outages. The inspectors verified that flaws and other nonconforming conditions identified during nondestructive testing were reported, characterized, evaluated and appropriately dispositioned for continued operation or for repair or replacement.
b. Findinqs No findings were identified.
.5 Problem ldentification and Resolution for Radiation Protection Inspections (71 153.
7 1 1 24.01 . 7 1 1 24.02. 7 1 1 24.03. 7 1 1 24.04. 7 1 1 24.05. 7 1 1 24.06. 60855.1\
a. Inspection Scope
The inspectors reviewed a sample of corrective action documents to determine if identified problems were entered into the corrective action program for resolution and to evaluate Exelon's threshold for entering issues into the program. The review included a check for possible repetitive issues, such as radiation worker or radiation protection technician errors. The inspectors also reviewed recent audits and assessments to ensure that identified issues were entered into the corrective action program.
b. Findinos No findings were identified.
40A3 Event Followup (71 153) (7 samples)
The inspectors performed seven event followup inspection activities. Documents reviewed for this inspection activity are listed in the Supplemental Information attached to this report.
.1 Ground Water (Pipe Vault #1)
a. lnspection Scope (71 153. 71 124.06)
On May 14,2010 Exelon notified the NRC and the State of New Jersey of the identification of tritiated water, measuring about 18,000 pCi/l, in pipe vault #1. The estimated quantity of water was approximately 2,000 to 3,000 gallons which was pumped into a tank for processing. The pipe vault is located on the southeast corner of the Reactor Building and was being entered and inspected as part of Exelon's buried pipe remediation program. This issue was initially discussed in NRC quarterly inspection report 05000219/2010003, dated August 9, 2010 (ADAMS Mt1022101 1 1).
As part of the review at that time, the inspectors performed walkdowns of the area and entered the vault to review material conditions. The inspectors confirmed that, prior to the 2008 outage, the isolation condensers (lC)were filled from the condensate storage tank, which contains tritiated water. During the 2008 refueling outage, Exelon installed a demineralized water system to provide a non{ritiated water source for the lCs and serves as the preferred source of filling the lCs to maintain system water levels.
Although the condensate storage tank and fire main continue to be the credited sources of lC shell side fill water for the licensing basis, Exelon's preferential use of the demineralized water system will minimize future tritium releases during use of the lCs.
The inspectors conducted a follow-up review as to the source of the tritium in pipe vault
- 1. The inspectors interviewed Exelon personnel and evaluated the likely causes of tritium. The inspectors walked down the area near the vault to identify likely sources.
The inspectors reviewed the following items:
Latest radiological data, including well samples from newly installed wells; Efforts to radiological characterizalion of area; Exelon's failure modes analysis (FMA);
Inspection results of potential piping sources in the area including determination of likely sources; Assessments as to the source of the tritium; Records of the site characterization of geology and hydrology; Systems, structures, and/or components that contain or could contain licensed material in the area; Evaluations of work practices that involved licensed material for which there is a credible mechanism for the licensed material to reach the groundwater at that location; lmplementation of the onsite groundwater monitoring program; Records of leaks and spills; Dose projections available; Disposition of water; and Reporting and notification records.
Exelon's evaluation determined that the source of the tritium identified in the water found in pipe vault #1 was from local tritiated steam condensate deposition associated with actuation of the lCs in July 2007. No other credible source of the tritium was identified through the Exelon's failure modes analysis, evaluation and inspection of the condition of underground piping, or evaluation of well sample results for the wells surrounding and in the vicinity of pipe vault #1. The evaluation of well data included that from new wells installed in the vicinity of pipe vault #1. Exelon conducted dose projections associated with the releases and did not identify any significant public or occupational dose impact.
b. Findinqs No findings were identified.
RAGEMS Monitorinq Inspection Scope (71 153. 71 124.06)
On April 7, Exelon technicians ascending the plant ventilation stack identified that the stack radioactive effluent sample line of the radioactive gaseous etfluent monitoring system (RAGEMS) was disconnected at a pipe union at about the 260 foot elevation of the stack. The sample line was found to be displaced laterally resulting in the interruption of the sample flow path. The stack sample line is used to deliver a continuous sample of stack effluents to the RAGEMS located in the RAGEMS Building at the base of the stack. The technician who discovered the piping discontinuity reconnected the fitting. Subsequent Exelon investigation identified that three sample line unions had failed in the line to varying degrees. Two were found disconnected and the third was loose. The RAGEMS system had been declared inoperable on April 7, to support the flow transmitter work. Exelon evaluated reportability and subsequently made a 10 CFR 50.72 notification (ENS 45824) on April 8.
The inspectors reviewed the circumstances surrounding the issue, the duration of the condition, and public dose projection implications of the condition. The inspectors reviewed Exelon's root cause investigation as well as bounding dose reconstruction.
The review was with respect to 10 CFR 20,10 CFR 50, the station TSs, and the ODCM.
(Note: This issue was initially reviewed and discussed in NRC quarterly inspection report
===05000219/2010003, dated August 9, 2010 (ADAMS ML102210111). Both the reportability aspects of this issue as well as the emergency preparedness (EP) aspects were reviewed and evaluated during that NRC inspection. Preliminary assessment of the public dose impact of this issue was also reviewed during that inspection which indicated no public doses in excess of 10 CFR 50, Appendix l, ALARA design specifications were exceeded. )
During this inspection, the inspectors reviewed Exelon's dose assessment in regards to the maximum projected doses during the time period that the RAGEMS was in a degraded condition. The inspectors also reviewed secondary effluent controls contained within the Radioactive Effluents Control Program, including monitoring systems, sampling, coolant monitoring, and environmental monitoring to provide secondary controls on radioactive effluents and control of doses to the public. The inspectors also reviewed bounding dose calculations associated with effluent release conditions considering secondary controls and/or monitoring systems.
As part of this review, the inspectors evaluated: potential release paths, projected source terms, projected doses, bounding sources terms and controls, to determine if during the time period of degraded monitor performance, with the existing source term, 10 CFR 50, Appendix I doses were exceed or likely exceeded. The inspectors also evaluated potential projected doses, assuming a less favorable source term and use of secondary controls, to limit doses to the public to 10 CFR 50, Appendix I ALAM design specifications.
The inspectors also confirmed that Exelon conformed to the requirements of TSs related to the protective instrumentation specifications pertaining to the off-gas system radiation monitoring functions.
Findinqs
Introduction:
A Green, self-revealing NCV of Technical Specification 6.8.4 occurred when Exelon failed to maintain continuous representative sampling of plant stack radioactive gaseous effluents. Specifically, Exelon did not fully conduct monitoring and sampling of stack gaseous effluents in accordance with the methodology in the ODCM, as required by TS 6.8.4.
Description:
Effluents from the plant stack are principally monitored and sampled by the installed stack radioactive gaseous effluent monitoring system (RAGEMS). This monitoring system is described in the UFSAR and the system provides for on-line noble gas monitoring as well as continuous particulate and iodine sampling and the collection of tritium samples. The RAGEMS system provides for monitoring and sampling of combined ventilation system inputs from various plant ventilated spaces including the reactor building, off-gas system, turbine building, and radwaste facilities. The stack effluent sample line runs down the stack and is used to deliver a sample to the stack RAGEMS sample and monitoring system located in the RAGEMS Building at the base of the stack. The station has secondary controls in-place (e.9., off-gas monitoring, source term analysis and monitoring, in-plant monitoring, bounding analyses and controls) to alert plant staff to changes in release rates and source term. In addition, the station's environmental monitoring program provides secondary checks of the efficacy of the effluents program.
Exelon's root cause analysis identified that the stack monitoring system showed very slight declining performance beginning as early as March 2006. This declining performance was evidenced by a very gradual decline in live-time radioactivity count rate for the stack gas channel. Further, the stack monitor gas channel computer trace showed decreasing gas channel count rates associated with occasional off-gas system outages as compared to earlier traces. Exelon's post identification review concluded that its secondary effluent program monitoring capabilities provided for sufficient detection of changes in source term and release rates to ensure conformance with 10 CFR 50 Appendix I ALARA design values.
TS 6.8.4 requires that Exelon conduct, in-part, monitoring and sampling of radioactive gaseous effluent in accordance with the methodology and parameters in the ODCM.
The ODCM specifies in section 4.11.2, that the effluent doses shall be determined by obtaining representative samples. The ODCM also specifies in section 4.11.2 that noble gas radionuclides in gaseous effluents may be identified by taking a grab sample and analyzing it using criteria specified. Table 4.11.2.1.2-1 requires that the sampling be continuous and that the noble gases be monitored continuously with a noble gas monitor. Since the same sample line also provides the stack effluent sample for grab sampling, this capability atso degraded over time and was eventually lost due to loss of line integrity.
Exelon's root cause analysis indicated the MGEMS stack effluent system did not collect a fully representative sample of the effluents due to the sample line integrity issue.
Based on data analysis, Exelon concluded the initial degradation of integrity occurred in or about March 2006.
Exelon conducted a multi-faceted re-analysis of projected releases and offsite doses.
Exelon conducted bounding dose analyses to estimate potential public dose consequences during the period of sample line degradation, evaluated reactor coolant history, and normalized stack releases using post-system restoration data. Exelon also reviewed environmentalsample data, including ambient radiation levels and particulate and iodine environmental sample station data and did not identify any indication that elevated releases occurred during periods of potential degradation of the sampling capability. Exelon evaluated in-plant work activities during the period to identify any potential airborne events. Exelon also evaluated fuel integrity, coolant concentrations, leak rates, and dose consequences associated with potential changes thereto. Exelon concluded that the degradation of the stack effluent sample line did not result nor was likely to result in any member of the public exceeding applicable 10 CFR 50, Appendix l, ALAM design specifications.
Exelon's failure analysis indicated the degradation of sample line integrity was due to improper line connection assembly in conjunction with with sample line weight stress.
Exelon repaired the connections and installed tube supports to support the sample line and to prevent wind induced motion of the line causing stress at the fittings. Exelon declared the stack RAGEMS system (including the sample line) operable on April 20, after conducting a satisfactory leak check of the sample line.
Exelon's root cause analysis identified that procedures for conduct of review of data from actual samples and quality control activities for reasonableness and consistency were not sufficient to critically review and evaluate the stack sample data. The need for such data reviews is specified in Regulatory Guide 4.15, Rev. 1, which is incorporated by reference into the TS for effluent monitoring.
Analvsis: Exelon did not fully monitor or collect representative samples of plant stack effluents, as required by TS 6.8.4 and the ODCM during the period between March 2006 and March 2010 as a result of sample line integrity issues. The failure to monitor or collect representative samples of the plant stack effluent was reasonably within Exelon's ability to foresee and should have been prevented.
This finding was not willful and did not involve a violation that impacted the regulatory process or contribute to an actual safety consequence. The finding is more than minor because it is associated with the plant facilities, equipment, and instrumentation attribute of the Public Radiation Safety Cornerstone and adversely impacted the objective of ensuring adequate protection of public health and safety from exposure to radioactive materials released into the public domain. Specifically, during the period March 2006 through at least March 2A1A, stack monitoring and sampling degraded over time due to sample line integrity issues. Following identification, Exelon initiated an enhanced compensatory monitoring program, repaired the cause of the non-representative sampling, and entered this issue, including the evaluation of extent-of-condition, into the corrective action program. This finding was assessed using IMC 0609, Appendix D, and determined to be of very low safety significance (Green) because: the issue was contrary to Exelon's TSs and is a radioactive effluent release program deficiency; there was no spill; secondary radioactive effluent monitoring and control program elements provided for control of effluents releases. In addition, Exelon was able to assess the dose to members of the public from routine releases and determined that projected doses did not nor were likely to exceed applicable limits including ALAM design specifications of 10 CFR 50, Appendix l. Exelon's review of environmental radiation monitoring data, during the period of sample line degradation, did not identify any adverse effect or delectable activity in the environment attributable to the condition.
The inspectors' independent review of Exelon's data, assessment, dose projections, and source term, indicated that both pre-and post correction assessment public doses were a small fraction of the 10 CFR 50, Appendix I ALARA dose specifications. The inspectors identified that during the period, fuel integrity remained high, there were no abnormal releases, principal radioactive effluent reduction equipment (e.9., augmented off-gas system) were maintained operable to reduce effluents, and secondary controls contained in Exelon's effluent program and source term monitoring provided for characterization and control of effluents to ensure conformance with 10 CFR 50 Appendix l. Exelon plans to provide updated effluent release and dose reports, as necessary, to reflect revised analyses.
The cause of this finding is related to the crosscutting area of human performance, resources aspect (H.2(c)) because procedures for conduct of review of data from actual samples and quality control activities for reasonableness and consistency were not sufficient to recognize deficiencies (e.9., detect degradation of sampling capabilities).
Enforcement:
TS 6.8.4 requires Exelon to conduct, in-part, monitoring and sampling of radioactive gaseous effluent in accordance with the methodology and parameters in the ODCM. The ODCM specifies in Section 4.11.2 that, for purposes of determining public dose rates to be within the limits specified therein, the doses due to iodine-131 , iodine-133, tritium, and all radionuclides, in particulate form, with half-lives greater than 8 days in gaseous effluents shall be determined by obtaining representative samples. The ODCM also specifies in section 4.11.2 that noble gas radionuclides in gaseous effluents may be identified by taking a grab sample and analyzing it using criteria specified therein. ln addition, section 2.4 of the ODCM specifies that the quantity of noble gases released will be determined from the continuous noble gas monitor and periodic isotopic analyses.
Contrary to these requirements, Exelon failed to conduct representative monitoring and sampling of noble gasses, iodine, particulates, and tritium during the period March 2006 through at least March 2010, due to degradation in stack effluent sampling line integrity.
Exelon initiated compensatory monitoring, repaired the cause of the non-representative sampling, and entered this issue, including the evaluation of extent-of-condition, into the corrective action program (lR 01053577). Because this finding is of very low safety significance, and because it was entered into Exelon's corrective action program (lR 01A$577), this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV 05000219/2010005.02, Failure to Conduct Representative Sampling of Stack Effluents)
.3 Loss of4160V 1D Bus
Inspection Scope On October 7, Exelon personnelwere performing procedure 632.2.002,"Grid Undervoltage Channel FunctionalTest" when the 1D 4160V breaker tripped. As designed, the#2 emergency dieselgenerator (EDG) received a fast start signal, its output breaker closed, and the diesel powered the load from the 1D 4160V bus. Exelon later determined that the cause of the failure was a fault in the test equipment.
The inspectors verified that operations personnel responded in accordance with procedures and equipment responded as intended by reviewing the completed procedures, control room narrative logs, corrective action program condition reports, and through interviews of operations personnel. The inspectors also reviewed TS requirements to ensure that Oyster Creek was operated in accordance with its operating license. The inspectors performed a walkdown of the main control room panels and indications to verify equipment status and plant parameters. Exelon notified the NRC with an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report (ENS 46315) and submitted a licensee event report (LER 0500021 912010-001-00) for this event. The loss of the 4160V 1D bus is described and evaluated in corrective action program condition report lR 1123363.
.4 Unusual Event declared to Unidentified Leak Rate qreater than 10 GPM
Inspection Scope On December 1, control room operators responded to indications of an unidentified leak rate of approximately 17 GPM. The operators isolated the "B" recirculation loop due to indications that the leakage was from the "B" recirculation pump mechanical seal, which stopped the leak.
The inspectors responded to the control room following site announcement declaring an Unusual Event due to an Unidentified Leak Rate in excess of 10 GPM and observed the response of Exelon personnel to the event, including operator actions in the control room. At the time of the event, the inspectors verified that conditions met the entry criteria for an emergency action level (EAL) as described in the Oyster Creek EAL matrix. ln addition, the inspectors reviewed 10 CFR 50.72, "lmmediate Notification Requirements for Operating Nuclear Power Reactors," to verify that Exelon properly notified the NRC during the event. The inspectors also reviewed TS requirements to ensure that Oyster Creek operated in accordance with its operating license.
The inspectors reviewed plant process computer (PPC) data, control room logs, and discussed the event with Exelon personnel to gain an understanding of how operations personnel and plant equipment responded during the event. The inspectors evaluated Exelon's program and process associated with event response to ensure they adequately implemented station procedure OP-M-106-101-1001, "Event Response Guidelines."
The Unusual Event is described and evaluated in corrective action program condition report lR 1147123.
b. Findinos No findings were identified.
'A' Reactor Recirculation Pump Trip on December 18
a. Inspection Scope
On December 18, Oyster Creek experienced a trip of the 'A' recirculation pump. At the time, Oyster Creek was in four loop operation due to the previous failure of the "B" recirculation pump mechanical seal. Control room operators responded to several recirculation pump and motor generator set alarms and confirmed that the "A" recirculation pump had tripped. Oyster Creek performed simple troubleshooting and determined the pump tripped due to an electricalfault in the system, but could not isolate the location of the fault while at power. Exelon chose to remain at 55 percent power during initial troubleshooting while two of the recirculation loops were unavailable.
At the time of the event, the inspectors verified that conditions did not meet the entry criteria for an EAL as described in the Oyster Creek EAL matrix. In addition, the inspectors reviewed 10 CFR 50.72, "lmmediate Notification Requirements for Operating Nuclear Power Reactors," to verify that Exelon properly notified the NRC during the event. The inspectors also reviewed TS requirements to ensure that Oyster Creek operated in accordance with its operating license.
The inspectors reviewed PPC data, control room logs, and discussed the event with Exelon personnel to gain an understanding of how operations personneland plant equipment responded during the event. The inspectors evaluated Exelon's program and process associated with event response to ensure they adequately implemented station procedures OP-AA-108-114, "Post Transient Review" and OP-M-106-101-1001, "Event Response Guidelines."
Exelon initiated an unplanned plant shutdown on December 19 to support a forced outage (1F26) to repair the "8" reactor recirculation pump mechanical seal and to continue electrical troubleshooting on the "A" reactor recirculation pump. This forced outage is described in detail in section 1R20.
b. Findinos No findings were identified.
.6 Automatic reactor scram durinq critical plant heatup on December 23
a. Inspection Scope
On December 23, operating personnel in control room responded to an automatic reactor scram.
The inspectors responded to the site after being informed of the event on December 23.
At the time of the event, the inspectors verified that conditions did not meet the entry criteria for an EAL as described in the Oyster Creek EAL matrix. In addition, the inspectors reviewed 10 CFR 50.72, "lmmediate Notification Requirements for Operating Nuclear Power Reactors," to verify that Exelon properly notified the NRC during the event. The inspectors also reviewed TS requirements to ensure that Oyster Creek operated in accordance with its operating license.
The inspectors reviewed PPC data, control room logs, and discussed the event with Exelon personnel to gain an understanding of how operations personnel and plant equipment responded during the event. The inspectors evaluated Exelon's program and process associated with event response to ensure they adequately implemented station procedures OP-AA-108-1 14, "Post Transient Review" and OP-AA-106-101-1001 , "Event Response Guidelines."
The inspectors observed the plant onsite review committee (PORC) meeting prior to plant startup to ensure Exelon identified the cause of the event and appropriately resolved issues identified during the event. The inspectors reviewed Exelon's prompt investigation (lR 1 155520) to gain additional information pertaining to the event, and ensure that human performance and equipment issues were properly evaluated and understood prior to plant startup.
b. Findinqs lntroduction. A Green, self-revealing NCV of Technical Specification 6.8.1.a occurred when Exelon did not adequately implement plant startup procedures which resulted in an automatic reactor scram.
Description.
On December 23, Exelon operators were performing a reactor startup following forced outage 1F26. The mode switch was in startup with the reactor power in range 9 of the intermediate range monitor (lRM) nuclear instrumentation. Reactor pressure was approximately 570 psig with main condenser vacuum at 24 inches Hg when both reactor protection systems (RPS) activated and the reactor received an automatic scram signal on low condenser vacuum.
The condenser low vacuum trip relay setpoint is 22 inches Hg while reactor pressure is above 600 psig. The automatic reset for the low vacuum trip relay is between 25 and 26 inches Hg. ln order to ensure the low vacuum trip relay has reset, procedure 201, "Plant Startup", step 5.44.2, directs the operators to confirm that "all main condenser vacuum trips have cleared and all main condenser alarms have cleared prio/'to exceeding 500 psig reactor pressure. Operators did not verify that condenser vacuum was adequate or that all main condenser vacuum trips had cleared, prior to raising reactor pressure above 500 psig.
Exelon's preliminary evaluation (lR 1 155520) determined that operators had verified that the low vacuum turbine trips were reset, but did not verify that the main condenser low vacuum alarm and the RPS main condenser low vacuum alarms were clear prior to raising reactor pressure above 500 psig. lmmediate corrective actions included just in time training with all reactor operators, increased management oversight during the startup, and procedural changes to list all alarms by name that must be cleared prior to raising reactor pressure above 500 psig. Exelon is performing a full root cause evaluation on the event (lR 1 155520).
Analvsis. Exelon's failure to implement procedure 201, "Plant Startup," is a performance deficiency that was reasonably within Exelon's ability to foresee and prevent. The inspectors determined that the performance deficiency was similar to example 4b in IMC 0612, Appendix E, "Examples of Minor lssues," and is more than minor because the performance deficiency resulted in a plant transient.
Additionally, the finding was more than minor in accordance with IMC 0612, Appendix B, "lssue Screening," because it was associated with the equipment performance attribute of the initiating events cornerstone and affected the objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during power operation. ln accordance with IMC 0609.04 (Table 4a), "Phase 1 - Initial Screen and Characterization of Findings," the finding was determined to be of very low safety significance (Green) because the finding did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available.
This finding has a cross-cutting aspect in the area of human performance, work practices (H.4(b)), where personnelwork practices support human performance.
Specifically, Exelon defines and effectively communicates expectations regarding procedural compliance and that personnelfollow procedures. On December 23, operators did not verify that condenser vacuum was adequate nor that all main condenser vacuum trips had cleared prior to raising reactor pressure above 500 psig contrary to established procedural guidance.
Enforcement.
TS 6.8.1a states, in part, that written procedures shall be established, implemented, and maintained as recommended in Regulatory Guide 1.33. Contrary to the above, Exelon failed to implement procedure 201, "Plant Startup," in a manner that would have prevented the automatic scram which occurred on December 23. Because this violation was of very low safety significance and it was entered into Exelon's corrective action program as lR 1155520, this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV 05000219/2011-01-03, Failure to lmplement Procedures Resulting in Reactor Scram).
.7 (Closed) LER 0500021 9/201 0-001 -00,
Inspection Scope This LER discussed an automatic start of the # 2 emergency diesel generator due to an unexpected trip of the 1D bus normal feeder breaker caused by a fault in a piece of test equipment during a surveillance test on October 7. The inspectors reviewed this LER and no new issues were identified. This LER is closed.
The inspectors noted that this LER was submitted on December 17, which was 10 days later than the requirement of 60 days following the discovery of the event as required in 1O CFR 50.73(a). Exelon made a timely I hour report (ENS 46315) following the event on October 7. The inspectors evaluated that the issue of the timely submission of the LER was a minor violation, as it did not meet the examples of a severity level lV violation provided in section 6.9.d of the NRC Enforcement Policy.
b. Findinos No findings were identified.
4OA5 Other
.1 lndependent Spent Fuel Storaqe Installation (lSFSl) (60855.1)
a. Inspection Scope
=
The inspectors reviewed routine operational surveillance data, including radiological surveillance, for the ISFSI facility. The inspectors toured the facility and made independent radiation measurements of the facility. The data was evaluated against 10 CFR Part20 and applicable Exelon procedures.
b. Findinqs No findings were identified.
Post-Approval Site Inspection for License Renewal (71003)
a. Inspection Scope
(1 Sample)
The inspectors reviewed Exelon's plans to comply with license condition (2XcX1 1) for the inspection of the drywell sand bed region. The inspectors compared Exelon's plans against the requirement to perform full scope inspections (as defined in Appendix A of the license renewal safety evaluation report dated March 20, 2007 , and summarized in the UFSAR) of the drywell sand bed region every other refueling outage beginning in the refueling outage prior to April 9, 2009. The inspectors also compared Exelon plans against commitment
- (4) in Appendix A of the license renewal safety evaluation report which states the Inservice Inspection Program will be enhanced to require inspection of 100Yo of the epoxy coating. The inspectors further reviewed Exelon's inspection plans to determine if the inspections were performed in accordance with ASME section Xl, subsection IWE and if the inspections met the scheduler requirements of the note to commitment 4 to inspect all 10 bays every other refueling outage, in accordance with item 21of the IWE inspection program.
The inspectors reviewed Exelon'compliance with license condition (2)(c)(13) which requires Exelon perform an engineering study prior to April 9, 2009 to identify options to eliminate or reduce the leakage in the facility cavity liner. The inspectors also determined if Exelon was continuing to monitor for leakage of the refueling cavity liner and other water sources associated with the drywell and if they had implemented plans to eliminate routine leakage in order to provide increased protection against further degradation as stated in the Safety Evaluation Report (SER) at 5-5. The inspectors reviewed Exelon's response to their choice to install a flow indicating device on the refueling drain and the subsequent failure of the device due to clogging. The inspectors reviewed the impact of the resultant water flowing down the containment vessel gap and into the sandbeds. The inspectors reviewed photographs of the moisture in the sandbed regions caused by the failure of the flow indicating device and the evidence that the water did not appear to impinge on the containment vessel wall but flowed down the vertical concrete wall of the sandbed.
The inspectors reviewed changes made to commitments prior, and subsequent to, the period of extended operation. The inspectors compared the process and consequence of changes to update a vessel inspection program commitment, change the period of replacement for the diesel fire pump day tank, modify the buried pipe program procedure, and modify a commitment related to fire pump surveillance. The change process was compared with the expectations in NRR Office Letter No. 807 "Controlof Licensing Bases for Operating Reactors", NEI 99-04 "Guidelines for Managing NRC Commitment Changes," and NRC Regulatory lssue Summary 2000-17 "Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff."
The inspectors reviewed results of the mitigation of the buried piping degradation program, including the methodology used to identify vulnerable piping. This review compared Exelon's progress against the SER, Appendix A, Commitment 26, which included the provisions to enhance the program to include inspection of buried piping within ten years of entering the period of extended operation, unless an opportunistic inspection occurs within this ten year period. The inspectors reviewed Exelon's actions in order to determine if the inspections included at least one carbon steel, one aluminum and one cast iron pipe or component and if the locations selected for inspection included at least one location where the previously replaced or recoated. Because Exelon chose to pface piping, whose failure would result in significant consequences, inside a vault or secondary barrier, the inspectors discussed the progress of the remediation program with the program owners.
The inspectors reviewed the process, procedures, and results of compliance with 10 CFR 54.37 (b). The inspectors compared this against the UFSAR update required by 10 CFR 50.71(e) which must include any systems, structures, and components newly identified that would have been subject to an aging management review or evaluation of time-limited aging analyses in accordance with S 54.21. The inspectors verified if the Oyster Creek UFSAR update described how the effects of aging will be managed such that the intended functions in S 54.a(b) will be effectively maintained during the period of extended operation.
The inspectors reviewed the results of all one{ime inspections and the plans for one-time inspections during and after the current outage to determine compliance with commitment24 of appendix A of the SER. The standard of evaluation was if the program provided reasonable assurance that during the extended period operation an aging effect is not occurring, or that the aging effect is occurring slowly enough to not affect the component or structure intended function during the period of extended operation, and therefore will not require additional aging management. The inspectors ascertained if the commitment to include two stainless steel pipe sections in a stagnant br low flow area in the reactor water cleanup system, and two stainless steel pipe sections in a stagnant or low flow area in the isolation condenser system were included in the one-time inspection samples.
b. Findinqq No findings were identified.
.2 (Closed) URI 05000219/2010004-01 : EDG Pillow-Block Bearinq
a. Inspection Scope
Ouring tfre routine overhaul and inspection of the #1 emergency diesel generator (EDG)on June 8, maintenance personnel identified damage to the cooling fan shaft pillow-block bearing. Exelon removed the bearing for further analysis by an offsite lab and replaced the bearing and shaft with new components on June 9. Exelon entered this issue into the corrective action program as lR 1078312 and lR 1103610 and performed an equipment apparent cause evaluation (EACE) to review the offsite lab report to determine the cause of the failure and any additional corrective actions. This EACE was not complete at the conclusion of the third quarter 2010 inspection period, so the inspectors opened a URI to follow the issue. The inspectors reviewed the offsite lab report and Exelon's EACE and discussed the results with regional specialist inspectors.
b. Findinqs No findings were identified.
40A6 Meetinqs. Includinq Exit Resident Inspector Exit Meetinq. On January 26, the inspectors presented their overall findings to members of Exelon's management led by Mr. Michael Massaro, 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 Exelon.
Radiation Protection Exit Meetinq. The inspectors presented the inspection findings to members of Exelon management on October 8, November 12, and December 10, 2010.
Exelon personnel acknowledged the inspection findings. No proprietary material is included in this inspection report.
Inservice Inspection Exit Meetinq. The inspectors presented the inspection findings to members of Exelon management on December 13, 2010. Exelon personnel acknowledged the inspection findings. No proprietary material is included in this inspection report.
Post-Approval Site Inspection for License Renewal Exit Meetinq. The inspectors presented the inspection findings to members of Exelon management on December 13, 2010. Exelon personnel acknowledged the inspection findings. No proprietary material is included in this inspection report.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- M. Massaro, Site Vice-President
- P. Orphanos, Plant Manager
- R. Peak, Plant Manager
- D. Dicello, Director, Work Management
- M. McKenna, Director, Operations
- G. Malone, Acting Director, Engineering
- C. Symonds, Acting Director, Training
- J. Dostal, Director, Maintenance
- J. Barstow, Manager, Regulatory Assurance
- T. Keenan, Manager, Security
- R. Skelsky, Senior Manager, Systems Engineering
- H. Ray, Senior Manager, Design Engineering
- G. Flesher, Acting Shift Operations Superintendent
- J. McDaniel, Manager, Nuclear Oversight
- M. Seeloff, Manager, Corrective Action Program
- M. Ford, Manager, EnvironmentaliChemistry
- A. Farenga, Manager, Radiation Protection
- J. Chrisley, Regulatory Assurance Specialist
- J. Kerr, Regulatory Assurance Specialist
- Z. Demeke, Engineering
- G. Harttraft, Engineering
- M. McAllister, NDE Senior Site Specialist
- P. Tamburo, Senior Staff Engineer
- S. Schwartz, Senior Staff Engineer
- P. Bloss, Work Management Director
- R. Heffner, Radiation Protection Supervisor
- Z. Karpe, Corporate Environmental Manager
- K. Leonard, Program Owner, Buried Pipe
- M. Nelson, Project Manager
- S. Sklenar, Environmental Manager, Mid-Atlantic
- C. Taylor, Licensing Engineer
Others:
State of New Jersey, Bureau of Nuclear Engineering
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened/Closed
0500021 9/201 0005-01 NCV Snubber Maintenance History Not Taken Into Account When Conducting Service Life Reviews (Section 1R12)
- 05000219/2010005.02 NCV Failure to Conduct Representative Sampling of Stack Effluents (Section 4OA3)
0500021 9/201 0005-03 NCV Failure to lmplement Procedures Resulting in Reactor Scram (Section 4OA3)
Closed
- 05000219/2010-001-00 LER Automatic start of emergency diesel generator due to unexpected trip of the 1D bus normal feeder breaker (Section 4OA3)
0500021 9/201 0004-01 URI EDG Pillow-Block Bearing (Section 4OA5)