IR 05000219/2012005
| ML13031A540 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/31/2013 |
| From: | Hunegs G NRC/RGN-I/DRP/PB6 |
| To: | Pacilio M Exelon Generation Co |
| Hunegs G | |
| References | |
| G20130037 IR-12-005 | |
| Download: ML13031A540 (52) | |
Text
UNITED STATES ary 31, 2013
SUBJECT:
OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2012005
Dear Mr. Pacilio:
On December 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Generating Station. The enclosed inspection report documents the inspection results, which were discussed on January 22, 2013 with Russell Peak, Oyster Creek Plant Manager, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding and one self-revealing finding of very low safety significance (Green). These findings were determined to involve violations of NRC requirements. However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.:
Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Oyster Creek Generating Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Oyster Creek Generating Station.
In accordance with 10 CFR 2.390 of the NRCs 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 the NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-219 License Nos.: DPR-16
Enclosure:
Inspection Report 05000219/2012005 w/Attachment: Supplementary Information
REGION I==
Docket No.: 50-219 License No.: DPR-16 Report No.: 05000219/2012005 Licensee: Exelon Nuclear Facility: Oyster Creek Generating Station Location: Forked River, New Jersey Dates: October 1, 2012 - December 31, 2012 Inspectors: J. Kulp, Senior Resident Inspector A. Patel, Resident Inspector J. Schoppy, Senior Reactor Inspector T. Hedigan, Operations Engineer S. Hammann, Senior Health Physicist J. Rady, Reactor Inspector B. Dionne, Health Physicist C. Crisden, Reactor Inspector C. Newport, Operations Engineer P. Kaufman, Senior Reactor Inspector T. OHara, Reactor Inspector T. Fish, Senior Operations Engineer Approved By: Gordon Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000219/2012005, 10/01/2012 - 12/31/2012; Exelon Energy Company, LLC, Oyster Creek
Generating Station; Operability Determinations and Functionality Assessments, Other Activities.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. This report documents one inspector-identified and one self-revealing finding of very low safety significance (Green), both of which are non-cited violations (NCV). The significance of most findings is indicated by their color (Green,
White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspects for the findings were determined using IMC 0310,
Components Within Cross-Cutting Areas. Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green non-cited violation (NCV) of 10 CFR 50,
Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Exelon did not properly implement procedural controls to ensure adequate thread engagement for standby liquid control (SLC) squib valve spool piece flanges. Specifically, SLC squib valve flanges were installed with inadequate thread engagement (stud was not flush with the nut), as required by Exelons maintenance procedures. Exelons corrective actions included declaring the system inoperable, entering the issue into the corrective action program (IR 1444861 and 1444862) and immediately replacing the existing bolts with bolts of an appropriate length such that projection through the nut was at least flush.
The performance deficiency was more than minor because if left uncorrected the inadequate thread engagement would have the potential to lead to a more significant safety concern. Specifically, Exelons evaluation stated that the SLC squib valve spool piece flanges would not have been able to perform their design function under all seismic conditions when the system was required to be operable. In consultation with the Region I senior reactor analyst, the inspectors reviewed this condition using IMC 0609, Attachment G, Shutdown Operations Significance Determination Process. As the condition occurred during the refueling outage and was identified and corrected before Exelon started up the Oyster Creek reactor, and only existed during the outage when SLC was not required to be operable (November 16 - 27, 2012), the issue screened to very low safety significance (Green). This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, Exelon did not take appropriate corrective actions, such as replacing bolts during the refueling outage with longer bolts, after the NRC identified a similar concern on the same SLC squib valve spool piece flanges in September 2012 (IR 1417726). (P.1(d)) (Section 1R15)
Cornerstone: Barrier Integrity
- Green.
A self-revealing NCV of 10 CFR 50, Appendix B, Criterion V, Instructions,
Procedures, and Drawings, was identified because Exelon procedures and work orders were not effective in preventing refueling cavity leakage from overflowing onto the exterior surface of the drywell liner during the refueling outage (1R24) in November 2012. The performance deficiencies that contributed to the finding were inadequate oversight of the contractors applying a strippable coating to the reactor cavity liner and a valve configuration control error on a temporarily installed leakage collection system.
Upon discovery, Exelon took immediate corrective actions to open the leakage collection system filter inlet valve and restore reactor cavity liner leakage flow to the reactor building equipment drain tank.
This finding is associated with the barrier integrity cornerstone and is more than minor because, if left uncorrected, this condition would have the potential to lead to a more significant safety concern. Specifically, the continued wetting of the metallic drywell liner surface could provide an environment conducive to corrosion. This finding is not more than very low safety significance because Exelon performs periodic inspections of drywell liner and exterior surface coating to ensure that liner corrosion is monitored and controlled. The inspectors completed the Phase 1 Initial Screening and Characterization of Findings, of Attachment 0609.04 of Inspection Manual Chapter (IMC) 0609, and screened the finding to Green, very low safety significance. Exelon has entered this condition into the corrective action process under IR 1440116. This finding has a cross-cutting aspect in the area of Human Performance, Work Practices, for not ensuring supervisory and management oversight of work activities, including contractors and plant personnel, such that nuclear safety is supported regarding the application of the strippable coating on the reactor cavity liner. (H.4(c)) (Section 1R08)
REPORT DETAILS
Summary of Plant Status
Oyster Creek began the inspection period at 100 percent power and operated at full power until October 22 when operators commenced a shutdown for a planned refueling and maintenance outage (1R24). Following the completion of refueling and maintenance activities, operators commenced a reactor startup on November 29. Operators returned the unit to 100 percent power on December 4, and remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Seasonal Extreme Weather Conditions
a. Inspection Scope
The inspectors performed a review of Exelons readiness for the onset of seasonal cold temperatures. The review focused on the intake structure and the emergency diesel generators (EDGs). The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications, control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Exelons personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Exelons seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.
b. Findings
No findings were identified.
.2 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors completed one impending adverse weather preparation sample. The inspectors reviewed Exelons preparations for the onset of Superstorm Sandy on October 28, 2012. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during adverse weather conditions.
The inspectors walked down the emergency diesel generators and the intake structure to ensure system availability. The inspectors verified that operator actions defined in Exelons adverse weather procedure maintained the readiness of essential systems.
The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.
b. Findings
No findings were identified.
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Standby gas treatment system (SBGTS) #2 while SBGTS #1 was inoperable for corrective maintenance on October 4, 2012 Emergency service water (ESW) pump 1-1 while ESW pump 1-3 was inoperable for planned maintenance on October 10, 2012 Service water (SW) and ESW systems during Superstorm Sandy on October 29, 2012 Emergency diesel generator (EDG) #1 and EDG #2 during Superstorm Sandy on October 29, 2012 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
From October 10-12, 2012, the inspectors performed a complete system walkdown of accessible portions of the A control rod drive system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
.1 Resident Inspector Quarterly Walkdowns
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Condenser Bay (TB-FZ-11E) on October 23, 2012 Torus Room (RB-FA-2) on November 8, 2012 Drywell (RB-FA-2) on November 20, 2012
b. Findings
No findings were identified.
1R06 Flood Protection Measures
.1 Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the updated final safety analysis report, the site flooding analysis, and plant procedures to assess susceptibilities involving internal flooding. The inspectors also reviewed the corrective action program to determine if Exelon identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors also focused on the control rod drive, core spray and containment spray pump areas to verify the adequacy of internal flooding mitigating strategies and barriers.
b. Findings
No findings were identified.
1R08 In-service Inspection - Oyster Creek
a. Inspection Scope
From November 5, 2012 to November 9, 2012, from November 13, 2012 to November 15, 2012 and from December 11, 2012 to December 13, 2012, the inspectors conducted a review of Exelons implementation of in-service inspection (ISI) program activities for monitoring degradation of the reactor coolant system pressure boundary, risk significant piping and components, and containment systems for the Oyster Greek Generating Station. The sample selection was based on the inspection procedure objectives and risk priority of those pressure retaining components in these systems where degradation would result in a significant increase in risk. The inspectors observed in-process non-destructive examinations (NDE), reviewed documentation, and inter-viewed inspection personnel to verify that the non-destructive examination activities performed as part of Interval 4, Period 3 of the Oyster Creek In-service Inspection during the 1R24 outage were conducted in accordance with the requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code Section XI, 2005 Edition, 2006 Addenda.
Nondestructive Examination and Welding Activities (02.01)
The inspectors performed direct observations of NDE activities in process and reviewed records of nondestructive examinations listed below:
ASME Code Required Examinations Direct field observation of visual examination (VT) of drywell sand bed bay #11 for epoxy coating anomalies and for corrosion. This inspection is part of the IWE containment inspection requirements and is performed to meet a license renewal aging management license requirement.
Inspection documentation review of VT in sand bed bays #1, #3, #5, #7, #9, #13,
- 15, #17, and #19.
Additionally, the inspectors reviewed the results of the ultrasonic (UT) thickness measurements taken in the sand bed bays to determine the extent of corrosion of the drywell wall. The inspectors also reviewed the sand bed coating repair records for repairs carried out during the 1R24 outage inspections.
Record review of NDE examination records of tests performed on reactor vessel nozzle N9 safe-end weld during repair. (See Repair/Replacement Activities below.)
Record review of NDE examination records of tests performed on a leak on reactor head penetration N7B flange weld during repair. (See Repair/Replacement Activities below.)
The inspectors reviewed a sample of certifications for NDE technicians performing examinations and verified that the inspections were performed in accordance with approved procedures and that the results were reviewed and evaluated by certified Level III NDE personnel.
Other Augmented or Industry Initiative Examinations The inspectors reviewed inspection records of visual inspections conducted on reactor vessel internals components. These inspections were carried out in accordance with the industry initiative under the Boiling Water Reactor Vessel and Internals Project (BWRVIP), In Vessel Visual Inspection (IVVI) Program. These inspections monitor and record the condition of the reactor vessel internal components. Specifically, the inspectors reviewed VT examination data records and reviewed the disposition of indications noted by the inspectors. The inspectors verified that the activities were performed in accordance with applicable examination procedures and industry guidance.
All recorded indications were dispositioned by the NDE examiner and Exelon as acceptable for further service.
Review of Originally Rejectable Indications Accepted by Evaluation There were no samples available for review during this inspection that involved examinations with recordable indications that had been accepted for continued service from the previous Oyster Creek outage 1R23.
Repair/Replacement Activities Including Welding Activities During an in-service liquid penetrant (LP) inspection of the nozzle to safe-end weld on reactor vessel control rod drive injection nozzle N9, Exelon identified rejectable surface indications. The inspectors reviewed the LP inspection record and subsequent ultrasonic (UT) examination records conducted on the N9 nozzle to safe-end weld indications. The UT inspection verified that the surface indications were not connected to the inside diameter of the nozzle. Exelon decided to repair the surface indications by installing a full structural weld overlay in accordance with the requirements of ASME Code Case N504-4. The inspectors reviewed the engineering evaluation of the overlay design and the ASME,Section XI repair/replacement plan for the weld overlay. The inspectors reviewed the weld traveler for the overlay and reviewed the pre-service, phased array ultrasonic examination of the completed overlay. Also, the inspectors verified the acceptability of the completed overlay from the successful plant operational pressure test of the nozzle-to safe-end weld. The inspectors verified that the repair, the welding activities and applicable NDE activities were completed successfully in accordance with ASME Code requirements.
During plant startup preparations at the end of the 1R24 outage, a small leak was observed from reactor head penetration N7B flange during the plant operational pressure test. Exelon determined that the leak was the result of a weld defect in a flange to pipe socket weld on the reactor head spray connection. Exelon initiated an ASME,Section XI repair of the defect. The inspectors reviewed the repair replacement program plan, the welding documentation of the repair, the in-process NDE, and the documentation of the final, successful plant operational pressure test of the repair. The leak was repaired in accordance with the ASME Code requirements.
Identification and Resolution of Problems The inspectors reviewed a sample of Oyster Creek action reports (ARs), which identified NDE indications, deficiencies and other nonconforming conditions since the previous
1R23 outage and during the present 1R24 outage. The inspectors verified that
nonconforming conditions were properly identified, characterized, evaluated, corrective actions identified and dispositioned, and appropriately entered into the Oyster Creek corrective action program.
The inspectors specifically focused on several corrective action reports written in response to the leakage of reactor refueling cavity (pool) water into the drywell sand bed area.
b. Findings
Introduction:
A self-revealing non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings, was identified when reactor refueling cavity leakage was not adequately controlled (incorrect strippable coating application and failure to control the position of valve V-18-131) allowing water to contact the exterior surface of the drywell shell in the sand bed areas.
Description:
During the refueling outage (1R24), a strippable coating was applied to the refueling cavity liner as a radiological contamination prevention measure which had a secondary benefit of minimizing reactor pool leakage. During installation of the coating, the contractor did not properly follow the work order instructions, resulting in parts of the pool liner not being properly coated. This deficiency of not coating the liner contributed to an increase in the refueling pool leakage when the refuel pool was filled for refueling operations on November 2, 2012. The increased pool leakage continued until November 20, 2012 when refueling operations were completed and the refuel pool was drained.
A temporary system had been installed to capture the refueling pool leakage and direct it to the reactor building equipment drain tank (RBEDT) for processing. The leakage was directed via an overflow drain trough, through a filter with isolation valves, to the RBEDT.
After a short period of operation, the filter became clogged, reducing the flow to the RBEDT. The clogged filter caused the refuel pool drain trough to overflow and water flowed over the exterior surface of the drywell shell into the sand beds and onto the torus room floor. The leakage on the torus room floor was diverted to the reactor building drain system and collected in the normal plant liquid radiological waste disposal system.
To address the clogged filter, Exelon revised work order R2076388, to close the filter inlet valve and removed the filter cartridge. However, the work order failed to appropriately direct operators to return the filter inlet valve (V-18-131) to the open position. As a result, for a period of approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, the leakage continued.
Analysis:
Exelon did not provide adequate instructions, procedures and drawings to properly apply the strippable coating to the refueling cavity liner to minimize known liner leakage and to control the position of the leakage collection system filter inlet valve. The two issues are being grouped together in accordance with the guidance provided in NRC IMC 0612, Appendix B, Block 2, Item (3). These issues are performance deficiencies because providing appropriate instructions was within Exelons ability to foresee and correct and should have prevented water leakage onto the exterior of the drywell liner.
This finding is more than minor because, if left uncorrected, this condition would have the potential to lead to a more significant safety concern. Specifically, the continued wetting of the metallic drywell liner surface could provide an environment conducive to corrosion in the sand bed areas.
This finding affects the barrier integrity cornerstone and the inspectors completed the Phase 1 Initial Screening and Characterization of Findings, of Table 2 and Table 3 of 0609.04 of Inspection Manual Chapter (IMC) 0609. The inspectors completed the screening of Exhibit 3, of IMC 0609, Appendix A and screened the finding to Green, very low safety significance, because the finding does not represent an actual open pathway in the physical integrity of the reactor containment , and, ... the finding does not involve an actual reduction in function of hydrogen igniters in the reactor containment. This finding is not more than very low safety significance because Exelon removed the sand from the sand bed areas and coated the liner exterior with an epoxy coating in 1992, to further reduce the likelihood of liner corrosion. Additionally, Exelon performs periodic inspections of the drywell liner and exterior surface coating to ensure that liner corrosion is monitored and controlled.
This issue is of very low safety significance because Exelon completed significant corrective actions to reduce the corrosion of the drywell liner in the sand bed bays in 1992 when the sand was removed from the sand beds. Also, the drywell liner in the sand bed bays was coated with an epoxy coating in 1992, to further prevent the likelihood of corrosion.
The inspectors determined that the finding has a cross-cutting aspect in the area of Human Performance, Work Practices, H.4(c) for not ensuring supervisory and management oversight of work activities, including contractors and plant personnel, such that nuclear safety is supported regarding the application of the strippable coating on the reactor cavity liner.
Enforcement:
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures and Drawings requires, in part, that, Activities affecting quality shall be prescribed by documented instructions, procedures and drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings. Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished. Contrary to the above, Exelon did not implement effective instructions, procedures, or drawings to ensure that leaking portions of the refueling cavity liner were coated with a strippable coating to minimize leakage and did not provide effective procedures to preclude water from contacting the exterior surface for the drywell liner during refueling outage 1R24, in November 2012. This condition resulted in an environment that was conducive to an increased potential for drywell liner corrosion. Upon discovery, Exelon took immediate corrective actions to open the filter inlet valve and restore reactor cavity liner leakage flow to the reactor building equipment drain tank and entered this condition into the corrective action process under IR 1440116. This violation is being treated as an NCV, consistent with Section 2.3.2. of the Enforcement Policy because it was of very low significance and was documented in Exelons corrective action program. (NCV 05000219/2012005-02, Inadequate Application of Strippable Coating to the Refueling Cavity Liner and the Failure to Configure a Valve in the Leakage Collection System Resulting in Increased Potential for Corrosion on the Exterior of the Drywell Liner Surface in the Sand Beds)
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed licensed operator simulator on October 3, 2012 and just in time training for unit startup on December 3, 2012. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures.
The inspectors assessed the clarity and effectiveness of communications, implemen-tation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by the shift technical advisor.
Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance problems.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
On October 21, 2012, the inspectors observed the control room operators shutdown the unit for refueling outage 24 and turbine overspeed trip test. The inspectors observed the pre-evolution brief and reviewed the post-evolution critique to ensure that the crew was ready to perform the evolution and were self-critical in their appraisal of their perfor-mance. Additionally, the inspectors observed the crew during the evolution to verify that procedure use, crew communications, and coordination of activities in the control room met established expectations and standards.
b. Findings
No findings were identified.
.3 Licensed Operator Requalification Program
a. Inspection Scope
On August 2, 2012, region-based inspectors conducted an in-office review of results of the licensee-administered annual operating tests (comprehensive written exams were previously administered in May and June 2011). The inspection assessed whether pass rates were consistent with the guidance of NRC Manual Chapter 0609, Appendix I, Operator Requalification Human Performance Significance Determination Process (SDP). The inspectors verified that:
Crew pass rate was greater than 80 percent. (Pass rate was 100 percent.)
Individual pass rate on the dynamic simulator test was greater than 80 percent.
(Pass rate was 96 percent.)
Individual pass rate on the job performance measures (JPMs) of the operating exam was greater than 80 percent. (Pass rate was 100 percent.)
More than 75 percent of the individuals passed all portions of the operating exam.
(Pass rate was 96 percent.)
The facility staff previously administered the comprehensive written exams in May and June 2011.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on system, structure and component (SSC) performance and reliability. The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65. Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Secondary containment building low pressure (IR 1425935) on October 13, 2012 Forked River combustion turbine #2 failure to start (IR 1439089) on October 29, 2012
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.
The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
Standby gas treatment system #1 unavailable for corrective maintenance on October 4, 2012 Containment spray and emergency service water system 2 out for planned maintenance on October 10, 2012 Red shutdown risk after loss of offsite power on October 29, 2012 Orange shutdown risk due to one offsite power source being unavailable on October 30, 2012
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Service water system operability during high intake water levels on October 29, 2012 Emergency service water system operability during high intake water levels on October 30, 2012 Standby liquid control pump operability due to inadequate thread engagement on pump discharge flanges on November 28, 2012 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to Exelons evaluations to determine whether the components or systems were operable.
Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
Introduction:
The inspectors identified a Green, non-cited violation of 10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, because Exelon did not properly implement procedural controls to ensure adequate threaded fastener engagement when reinstalling the standby liquid control (SLC) squib valve spool piece following squib valve replacement. Specifically, the SLC squib valve spool pieces were installed with inadequate thread engagement (studs were not flush with the nuts), as required by station maintenance procedures.
Description:
On November 27, 2012, during a walkdown of the SLC system, the inspectors identified that following the replacement of both squib valves, all the fasteners securing the squib valve spool pieces to the system piping were two to three threads short of being flush with the nut and were not in compliance with Exelon procedure 2400-GMM-3900.52, Inspection and Torquing of Bolted Connections. Specifically, 2400-GMM-3900.52, precaution step 3.1.2 states, in part, minimum projection of a bolt through a nut shall be flush. Contrary to this procedure, the inspectors identified the spool piece flange fasteners for both SLC systems, each having four studs per flange, did not project any stud flush with the fastening nuts.
Exelon reviewed the as-found condition and determined that there was not a reasonable assurance that the fasteners for the spool pieces would be able to perform their design function under all seismic conditions, and determined SLC to be inoperable. At the time of identification, technical specification actions did not apply because SLC was not required to operable because Oyster Creek was in a refueling outage (reactor temperature < 212 F). Additionally, Exelon determined that the condition concerning the flange fasteners that were installed did not exist when SLC was required to operable because the spool pieces were removed and reinstalled during the refueling outage on November 16, 2012. Exelons corrective actions included entering the issue into the corrective action program (IR 1444861 and 1444862) and immediately replacing the inadequate studs with studs of an appropriate length, such that projection through the nut was at least flush.
The inspectors also identified previous thread engagement issues with the SLC spool piece flange fasteners in September 2012. The inspectors observed at that time two of the discharge flange bolts were one thread short of being flush with the nut. Exelons corrective actions included entering that issue into the corrective action program (IR 1417726) and determined the as-found condition had no impact on the operability of SLC because enough thread engagement was maintained by other 2 fasteners and engineering evaluation stated the 2 fasteners short of being flush had adequate thread engagement to maintain structural integrity. The inspectors also observed that the corrective actions for IR 1417726 determined longer bolts were required but was not implemented during the removal and reinstallation during the refueling on November 16, 2012.
Analysis:
The inspectors determined that Exelons failure to control adequate thread engagement of the SLC squib valve spool piece flanges in accordance with the prescribed procedure was a performance deficiency that was reasonably within Exelons ability to foresee and prevent. This performance deficiency was associated with the Mitigating Systems cornerstone. The performance deficiency was more than minor because if left uncorrected the inadequate thread engagement would have the potential to lead to a more significant safety concern. Specifically, Exelons evaluation stated that the SLC squib valve spool piece flanges would not have been able to perform their design function under all seismic conditions when the system was required to be operable. In consultation with the Region I senior reactor analyst, the inspectors reviewed this condition using IMC 0609, Attachment G, Shutdown Operations Significance Determination Process. As the condition occurred during the refueling outage and was identified and corrected before Exelon started up the Oyster Creek reactor, and only existed during the outage when SLC was not required to be operable (November 16 - 27, 2012), the issue screened to very low safety significance (Green).
This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program because Exelon did not take appropriate corrective actions to address safety issues and adverse trends in a timely manner, commensurate with their safety significance and complexity. Specifically, Exelon did not take appropriate corrective actions, such as replacing bolts during the refueling outage with longer bolts, after the NRC identified a similar concern on the same SLC squib valve spool piece flanges in September 2012 (IR 1417726). (P.1(d))
Enforcement:
10 CFR 50, Appendix B, Criterion V, Instructions, Procedures, and Drawings, requires, in part, that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings. Contrary to the above, Exelon did not adequately implement procedure 2400-GMM-3900.52, Inspection and Torquing of Bolted Connections, for adequate thread engagement of the standby liquid control squib valve spool piece flanges on November 16, 2012. Specifically, the SLC squib valve spool piece flange bolts were two to three threads from being flush with the nut, therefore it did not meet thread engagement requirements specified in the procedure and engineering did not have reasonably assurance that SLC would have performed its design function in a seismic event. Because this violation was of very low safety significance (Green) and has been entered into Exelons CAP as issue reports 1444861 and 1444862, this violation is being treated as a non-cited violation, consistent with the NRC Enforcement Policy. (NCV 05000219/2012005-01, Failure to Follow Inspection and Torquing of Bolted Connection Procedure)
1R18 Plant Modifications
.1 Permanent Modifications
a. Inspection Scope
The inspectors evaluated a procedure change to ABN-32, Abnormal Intake Level. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change and performed a walk down of the system and intake structure to ensure the procedure change was reasonable and could be reasonably performed.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
Containment spray system #2 after V-21-13 preventive maintenance (R2116444)on October 11, 2012 Emergency service water (ESW) pump 1-3 after ESW pump motor cable replacement (R2208902) on October 15, 2012 Main steam isolation valve (MSIV) mechanical snubbers 211-0058A, 211-0025A, 411-0004, and 411-0026 after snubber replacements (C2028734) from November 7-11, 2012 Inboard MSIV, V-1-7, after valve stem repacking (C2027126) on November 10, 2012 ESW system 2 after discharge piping replacement (C2026522) on November 14, 2012 C electromatic relief valve after pilot valve replacement (R2136093) on November 15, 2012 Outboard MSIV, V-1-9, after valve rebuild (C2028595) on November 15, 2012
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors reviewed Exelons work schedule and outage risk plan for the maintenance and refueling outage (1R24), which was conducted from October 22, 2012 through December 3, 2012. The inspectors reviewed Exelons development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:
Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable technical specifications when taking equipment out of service Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing Installation and configuration of reactor coolant pressure, level, and temperature instruments to provide accurate indication and instrument error accounting Status and configuration of electrical systems and switchyard activities to ensure that technical specifications were met Monitoring of decay heat removal operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by technical specifications Refueling activities, including fuel handling and fuel receipt inspections Fatigue management Identification and resolution of problems related to refueling outage activities
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant systems, structures and components to assess whether test results satisfied technical specifications, the UFSAR, and Exelon procedure require-ments. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
Main steam isolation valve, V-1-7, closure test on October 22, 2012 Automatic depressurization system actuation circuit test on November 13, 2012 Emergency diesel generator #2 loss of offsite power and loss of coolant accident test on November 16, 2012 Core spray system #1 in-service test on November 16, 2012
b. Findings
No findings were identified.
Cornerstones: Emergency Preparedness (EP) 1EP2 Alert and Notification System Evaluation
a. Inspection Scope
(71114.02 - 1 Sample)
An onsite review was conducted to assess the maintenance and testing of the Alert and Notification System (ANS). During this inspection, the inspectors conducted a review of the ANS testing and maintenance programs. The inspectors reviewed the associated ANS procedure and the Federal Emergency Management Agency (FEMA) approved ANS Design Report to ensure compliance with design report commitments for system maintenance and testing. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 2. Title 10 of the Code of Federal Regulations (10 CFR) 50.47(b)(5) and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
(71114.03 - 1 Sample)
The inspectors conducted a review of the Oyster Creek Emergency Response Organization (ERO) augmentation staffing requirements and the process for notifying and augmenting the ERO. The review was performed to verify the readiness of key Exelon staff to respond to an emergency event and to verify Exelons ability to activate their emergency response facilities (ERF) in a timely manner. The inspectors reviewed the Exelon Nuclear Standardized Emergency Plan and the Oyster Creek Emergency Plan Annex for ERF activation and ERO staffing requirements, the ERO duty roster, applicable station procedures, augmentation test reports, the most recent drive-in drill report, and condition reports (CR) related to this inspection area. The inspectors also reviewed a sample of ERO responder training records to verify training and qualifications were up to date. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 3. Title 10 CFR 50.47(b)(2) and related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP5 Maintaining Emergency Preparedness
a. Inspection Scope
(71114.05 - 1 Sample)
The inspectors reviewed a number of activities to evaluate the efficacy of Exelons efforts to maintain the Oyster Creek emergency preparedness program. The inspectors reviewed: Letters of Agreement and/or Memorandums of Understanding with offsite agencies; the 10 CFR 50.54(q) Emergency Plan change process and practice; licensee maintenance of equipment important to EP; records of evacuation time estimate population evaluation; and provisions for, and implementation of, primary, backup, and alternate emergency response facility (ERF) maintenance. The inspectors also verified Exelons compliance at Oyster Creek with new NRC EP regulations regarding:
emergency action levels for hostile action events and protective actions for on-site personnel during events.
The inspectors further evaluated Exelons ability to maintain their EP program through their identification and correction of EP weaknesses, by reviewing a sample of drill reports, actual event reports, self-assessments, 10 CFR 50.54(t) audits, and EP-related CRs. The inspectors reviewed a sample of EP-related CRs initiated at Oyster Creek from July 2010 through October 2012. The inspection was conducted in accordance with NRC Inspection Procedure 71114.05. Title 10 CFR 50.47(b) and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
Cornerstones: Public Radiation Safety and Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
The inspectors reviewed radiation measurement devices, area radiation surveys, radiation work permits, contamination and radiation material controls, high and very high radiation areas, radiation worker performance, and radiation protection personnel qualifications. These areas were inspected to review and evaluate Exelons performance in assessing the radiological hazards in the workplace associated with licensed activities and the implementation of appropriate radiation monitoring and exposure control measures for both individual and collective exposures. The inspectors evaluated whether problems associated with radiation monitoring and exposure control were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in Exelons corrective action program.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
The inspectors reviewed the as low as is reasonable achievable (ALARA) work activity evaluations, exposure estimates, exposure reduction requirements and measures taken by Exelon to track, trend and reduce occupational doses for ongoing work activities to assess performance with respect to maintaining individual and collective radiation exposures ALARA. The inspectors also reviewed Exelons records to determine the historical trends and current status of plant source term known to contribute to elevated facility collective exposure. The inspectors observed the performance of radiation workers and radiation protection technicians during refueling outage activities in radiation areas, airborne radioactivity areas, and high radiation areas. The inspectors verified Exelons ALARA program, including administrative, operational, and engineering controls, is effectively maintaining occupational exposure ALARA. The inspectors evaluated whether problems associated with ALARA planning and controls are being identified by Exelon at an appropriate threshold and were properly addressed for resolution in Exelons corrective action program.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors reviewed the updated final safety analysis report, technical specification, air sample test results, equipment maintenance and test records, inspection and maintenance procedures, and system operational procedures. The inspectors reviewed procedural guidance for use of installed plant systems to reduce dose and assessed whether the systems are used, to the extent practicable, during high-risk activities. The inspectors reviewed instrument setpoints to verify that in-plant airborne concentrations are being controlled consistent with ALARA to the extent necessary to validate plant operations as reported by the performance indicators and to verify that the practices and use of respiratory protection devices on site do not pose an undue risk to the wearer.
The inspectors reviewed a sample of training and medical records to verify that employees were properly qualified to use respiratory protection devices. The inspectors monitored several employees as they demonstrated the use of respiratory protection devices. The inspectors spot check several respiratory protection devices and verified that they were in acceptable material condition and maintained properly.
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors reviewed Exelons procedures associated with dosimetry operations, including issuance/use of external dosimetry, assessment of internal dose, and evaluation of and dose assessment for radiological incidents. The inspectors evaluated whether Exelon had established procedural requirements for determining when external dosimetry and internal dose assessments are required. The inspectors walked down and evaluated the onsite storage of dosimeters before issuance, during use, and before processing/reading. The inspectors also reviewed the guidance provided to radiation workers with respect to care and storage of dosimeters. The inspectors reviewed dosimetry occurrence reports or corrective action program documents for adverse trends related to electronic pocket dosimeters. The inspectors reviewed procedures used to assess the dose from internally deposited radionuclides using whole body counting equipment. The inspectors reviewed the documentation for two individuals who had declared pregnancy during the current assessment period and evaluated whether Exelons radiological monitoring program (internal and external) for declared pregnant workers is technically adequate to assess the dose to the embryo/fetus. The inspectors reviewed exposure results and monitoring controls implemented by Exelon. The inspectors evaluated Exelons neutron dosimetry program, including dosimeter types and/or radiation survey instrumentation.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Mitigating Systems Performance Index (5 samples)
a. Inspection Scope
The inspectors reviewed Exelons submittal of the Mitigating Systems Performance Index for the following systems for the period of October 1, 2011 through September 30, 2012:
Emergency AC Power System High Pressure Injection System Heat Removal - Isolation Condensers RHR - Containment Spray Cooling Water System To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 6. The inspectors also reviewed Exelons operator narrative logs, condition reports, mitigating systems performance index derivation reports, event reports, and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 EP Performance Indicators (PI) (3 samples)
a. Inspection Scope
The inspectors reviewed data for the three EP Performance Indicators (PI), which are:
- (1) Drill and Exercise Performance;
- (2) ERO Drill Participation; and,
- (3) ANS Reliability.
The last NRC EP inspection at Oyster Creek was conducted in the third calendar quarter of 2011. Therefore, the inspectors reviewed supporting documentation from EP drills and equipment tests from the third calendar quarter of 2011 through the third calendar quarter of 2012 to verify the accuracy of the reported PI data. The review of the PIs was conducted in accordance with NRC Inspection Procedure 71151. The acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 6, was used as reference criteria.
b. Findings
No findings were identified.
.3 Occupational Exposure Control Effectiveness (1 - sample)
a. Inspection Scope
The inspectors reviewed implementation of the Occupational Exposure Control Effectiveness PI Program. 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 review was against the applicable criteria specified in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 6. The purpose of this review was to verify that occurrences that met NEI criteria were recognized and identified as Performance Indicators.
b. Findings
No findings were identified.
.4 RETS/ODCM Radiological Effluent Occurrences (1 - sample)
a. Inspection Scope
The inspectors reviewed the implementation of the Radiological Effluents Technical Specification/Offsite Dose Calculation Manual (RETS/ODCM) PI program. 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 review was against the applicable criteria specified in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 6. 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 Exelons evaluations and public dose assessments associated with identification of localized ground water contamination within the restricted area.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening meetings.
b. Findings
No findings were identified.
.2 Semi-Annual Trend Review
a. Inspection Scope
The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, "Problem Identification and Resolution," to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors included repetitive or closely-related issues that may have been documented by Exelon outside of the corrective action program, such as trend reports, performance indicators, major equipment problem lists, system health reports, maintenance rule assessments, and maintenance or corrective action program backlogs. The inspectors also reviewed Exelon's corrective action program database for the first and second quarters of 2012 to assess condition reports written in various subject areas (equipment problems, human performance issues, etc.), as well as individual issues identified during the NRCs daily condition report review (Section 4OA2.1).
a. Findings and Observations
No findings were identified.
The inspectors evaluated a sample of equipment material condition improvement lists.
This review included a sample of condition reports of those systems on the list to determine equipment availability, reliability and operability. The inspectors also verified the appropriate disposition of equipment material condition trends and that they were addressed within the scope of the corrective action program and documented in condition reports.
Examples of systems in Exelons equipment material condition improvement list include electrical penetrations, fuel pool cooling heat exchangers, and standby gas treatment systems. The inspectors determined that Exelon appropriately identified equipment material conditions improvements and appropriately documented those systems in the corrective action program. The inspectors concluded that Exelon was implementing appropriate actions to address any adverse trend in equipment material condition.
.3 Annual Sample: Review of the Operator Workaround Program
a. Inspection Scope
The inspectors reviewed the cumulative effects of the existing operator workarounds, operator burdens, existing operator aids and disabled alarms, and open main control room deficiencies to identify any effect on emergency operating procedure operator actions, and any impact on possible initiating events and mitigating systems. The inspectors evaluated whether station personnel had identified, assessed, and reviewed operator workarounds as specified in Exelon procedure OP-AA-102-103, Operator Work-Around Program.
The inspectors reviewed Exelons process to identify, prioritize and resolve main control room distractions to minimize operator burdens. The inspectors reviewed the system used to track these operator workarounds and recent Exelon self assessments of the program. The inspectors also toured the control room and discussed the current operator workarounds with the operators to ensure the items were being addressed on a schedule consistent with their relative safety significance.
b. Findings and Observations
No findings were identified.
The inspectors determined that the issues reviewed did not adversely affect the capability of the operators to implement abnormal or emergency operating procedures.
The inspectors also verified that Exelon entered operator workarounds and burdens into the corrective action program at an appropriate threshold and planned or implemented corrective actions commensurate with their safety significance.
.4 Annual Sample: Failure of Agastat Relays in the Isolation Condenser System (ICS)
a. Inspection Scope
The inspectors performed an in-depth review of Exelons failure analysis and corrective actions associated with condition report CR 01350115 that documented occurrences where Agastat electro-pneumatic time delay relay contacts within the isolation condenser system (ICS) failed to change state when the relay de-energized. The relay de-energized as expected during the surveillance testing procedure when the direct current (DC) circuit was opened by simulating a high Reactor Pressure Vessel (RPV)pressure condition. However, relay contacts did not actuate to reposition the B isolation condenser condensate return valves. There has been a high frequency of failures of these Agastat electro-pneumatic time delay relays within the ICS. Most of the failures have been identified during surveillance activities that simulated high RPV pressure or low-low RPV water level conditions into the ICS logic to verify that the ICS actuation signals initiated.
The inspectors assessed Exelons problem identification threshold, causal analyses, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions to determine whether Exelon was appropriately identifying, characterizing, and correcting problems associated with this issue. The inspectors compared the actions taken to the requirements of Exelons corrective action program and Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Appendix B, Criterion XVI, Corrective Action. In addition, the inspectors reviewed documentation associated with this issue, including condition and failure analysis reports, and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions and the actions planned to complete full resolution of the issue.
b. Findings and Observations
No findings were identified.
Because of repetitive failures of the Agastat electro-pneumatic time delay relays over the last several years within the ICS, Exelon implemented ECR OC 12-00438 to replace the existing Agastat relays with Allen-Bradley electronic time delay relays. Exelon also uses this type of Allen-Bradley relay within the ICS High Energy Line Break circuitry and these relays have been very reliable. Also, an Electric Power Research Institute (EPRI)
Control Relays Aging Management Guideline Technical Report was published in 2011 that acknowledged the high failure frequency for this type of Agastat relay and provided a suitable replacement relay. Exelon used this guidance to install the recommended replacement relay into the ICS during their 2012 refueling outage.
The inspectors determined that Exelons overall response to the issue was commensurate with the safety significance, was timely, and the actions taken and planned were reasonable to resolve the relay failures within the ICS.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 Plant Events
a. Inspection Scope
For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. The inspectors verified that Exelon properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the event to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.
Oyster Creek declared alert due to high intake level during Superstorm Sandy on October 29, 2012 Inspectors were stationed onsite for Superstorm Sandy from Sunday, October 28, 2012 through Tuesday, October 30, 2012. While onsite, inspectors provided continuous monitoring and evaluation of environmental conditions and Exelons actions in response to the storm. The inspectors responded to the control room as warranted to provide event response and to monitor operator response to rising intake levels and restoration of equipment following a loss of offsite power. During the loss of offsite power, both of Exelons self-contained air cooled emergency diesel generators, which are not cooled by service water, started as designed and provided power to vital equipment. At the height of the storm, a total of 39 of Oyster Creeks 42 emergency sirens were rendered inoperable due to power outages and storm damage. During the time that the sirens were not available, the route alerting method of emergency notification was available, if necessary. The inspectors noted that Exelon has committed to the State of New Jersey, to install new sirens with battery backup capability by June 1, 2013. Following testing and acceptance by the Federal Emergency Management Agency (FEMA), the sirens will be placed in service and the old sirens will be removed. Located at approximately 23 feet above sea level, the independent spent fuel storage facility was unaffected by the 7.4 foot storm surge. Reports and observations from the inspectors were a factor in the decision to dispatch a special inspection team to review Exelons response to Superstorm Sandy. The special inspection was conducted from November 13 to 27, 2012. The results of the inspection are documented in Inspection Report 05000219/2012009 (ML13010A47).
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Temporary Instruction 2515/187 - Inspection of Near-Term Task Force
Recommendation 2.3 - Flooding Walkdowns
a. Inspection Scope
The inspectors verified that Exelons walkdown packages contained the elements as specified in NEI 12-07 Walkdown Guidance document:
The inspectors accompanied Exelon on their walkdown of the turbine building basement and condenser bay and verified that Exelon confirmed the following flood protection features:
Visual inspection of the wall penetrations Available Physical margin Flood protection feature functionality was determined using visual observation The inspectors independently performed their walkdown and verified that the following flood protection feature was in place:
Emergency diesel generator building asphalt dike The inspectors verified that noncompliances with current licensing requirements, and issues identified in accordance with the 10 CFR 50.54(f) letter, Item 2.g of Enclosure 4, were entered into Exelons corrective action program. In addition issues identified in response to Item 2.g that could challenge risk significant equipment and Exelons ability to mitigate the consequences will be subject to additional NRC evaluation.
b. Findings
No findings or self-revealing findings were identified.
.2 Temporary Instruction 2515/188 - Inspection of Near-Term Task Force
Recommendation 2.3 - Seismic Walkdowns
a. Inspection Scope
The inspectors accompanied Exelon on their seismic walkdowns of the 23 ft and 45 ft level of the Drywell on November 5, 2012 and verified that Exelon confirmed that the following seismic features associated with the inboard main steam isolation valve (V-1-7)and A, C, and E electromatic relief valves were free of potential adverse seismic conditions (list the applicable seismic features which were verified):
Anchorage was free of bent, broken, missing or loose hardware Anchorage was free of corrosion that is more than mild surface oxidation Anchorage was free of visible cracks in the concrete near the anchors Anchorage configuration was consistent with plant documentation SSCs will not be damaged from impact by nearby equipment or structures Overhead equipment, distribution systems, ceiling tiles and lighting, and masonry block walls are secure and not likely to collapse onto the equipment Attached lines have adequate flexibility to avoid damage The area appears to be free of potentially adverse seismic interactions that could cause flooding or spray in the area The area appears to be free of potentially adverse seismic interactions that could cause a fire in the area The area appears to be free of potentially adverse seismic interactions associated with housekeeping practices, storage of portable equipment, and temporary installations (e.g., scaffolding, lead shielding)
The inspectors independently performed their walkdown and verified that the following SSCs were free of potential adverse seismic conditions:
A isolation condenser on August 22, 2012 Standby liquid control tank on August 22, 2012 Observations made during the walkdown that could not be determined to be acceptable were entered into Exelons corrective action program for evaluation.
Additionally, inspectors verified that items that could allow the spent fuel pool to drain down rapidly were added to the seismic walkdown equipment list (SWEL) and these items were walked down by Exelon.
b. Findings
No findings were identified.
.3 Followup Inspection for Three or More Severity Level IV Traditional Enforcement
Violations in the Same Area in a 12-Month Period (IP 92723)
a. Inspection Scope
The inspectors performed a follow-up inspection for three Severity Level (SL) IV Traditional Enforcement violations in the area of Impeding Regulatory Process that occurred in 2011. Two of the violations involved Operator Licensing medical issues and the third violation involved improper implementation of an Emergency Action Level bases change.
The objectives of the inspection were to determine whether Exelon:
Provided assurance that the causes of the SL IV Traditional Enforcement violations were understood; Provided assurance that the extent of condition and extent of cause of the SL IV Traditional Enforcement violations were identified; and Provided assurance that corrective actions for the SL IV Traditional Enforcement violations were sufficient to address the causes.
The inspectors reviewed Exelons collective Common Cause Analysis evaluation for the violations, related condition reports, procedures, and relevant references. The inspectors also interviewed management and staff personnel who were familiar with the violations and participated in the evaluation or corrective actions.
Documents reviewed during the inspection are listed in the Attachment.
b. Findings and Observations
No findings were identified.
The inspectors concluded that Exelon completed an adequate Common Cause Analysis that used a systematic method to identify the causes of the Traditional Enforcement violations. Exelon considered the primary common cause to be inadequate individual accountability and questioning attitude associated with regulatory sensitive issues.
Exelons evaluation also considered two additional Traditional Enforcement violations that occurred outside of the 12-month period assessed by the inspection.
The inspectors determined that the station adequately assessed the extent of condition and extent of cause of the violations. The inspectors concluded that Exelons corrective actions were sufficient to address the identified common cause and that the completed and planned corrective actions addressed the causes described in the evaluation.
.4 Operation of an ISFSI at Operating Plants (IP 60855)
a. Inspection Scope
The inspectors evaluated Exelons activities related to long-term operation and monitoring of their Independent Spent Fuel Storage Installation (ISFSI), and verified that activities were being performed in accordance with the Certificate of Compliance (CoC),technical specifications (TS), regulations, and Exelon procedures.
The inspectors performed tours of the ISFSI pad to assess the material condition of the pad and the loaded horizontal storage modules (HSMs). The inspectors also verified that transient combustibles were not being stored on the ISFSI pad or in the vicinity of the HSMs. The inspectors confirmed vehicle entry onto the ISFSI pad was controlled in accordance with Exelons procedures and verified that Exelon was appropriately performing daily HSM surveillances in accordance with TS requirements.
The inspectors interviewed reactor engineering personnel and reviewed Exelons program associated with fuel characterization and selection for storage from the last ISFSI loading campaign in April/May 2012. The inspectors verified that the criteria meets the conditions for cask and canister use as specified in the CoC. The inspectors also confirmed that physical inventories were conducted annually and were maintained as required by the regulations.
The inspectors reviewed radiological records from the last ISFSI loading campaign to confirm that radiation and contamination levels measured on the casks were within limits specified by TS and consistent with values specified in the updated final safety analysis report (UFSAR). The inspectors reviewed radiation protection procedures and radiation work permits (RWPs) associated with ISFSI operations. The inspectors also reviewed annual environmental reports to verify that areas around the ISFSI pad and the ISFSI site boundary were within limits specified in 10 CFR Part 20 and 10 CFR Part 72.104.
The inspectors reviewed corrective action program condition reports (ARs), and the associated follow-up actions that were generated since Exelons last loading campaign to ensure that issues were entered into the corrective action program, prioritized, and evaluated commensurate with their safety significance. The inspectors also reviewed Exelons 10 CFR 72.48 screenings.
b. Findings
No findings were identified.
.5 Institute of Nuclear Power Operations (INPO) Report Review
a. Inspection Scope
The inspectors reviewed the final report for the INPO plant assessment of Oyster Creek Nuclear Generating Station conducted in March 2012. The inspectors reviewed these reports to ensure that any issues identified were consistent with NRC perspectives of Exelon performance and to determine if INPO identified any significant safety issues that required further NRC follow-up.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On January 22, 2013, the inspectors presented the inspection results to Russell Peak, Oyster Creek Plant Manager, and other members of the Oyster Creek Nuclear Generating Station staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
4OA7 Licensee-Identified Violations
None ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- G. Stathes, Site Vice-President
- M. Massaro, Site Vice-President
- R. Peak, Plant Manager
- M. Ford, Director, Operations
- B. Baker, Site Manager Reactor Services, Limerick
- G. Young, Operations Training
- C. Holtzapple, SNM Coordinator
- G. Malone, Director, Engineering
- J. Dostal, Director, Maintenance
- C. Symonds, Director, Training
- D. DiCello, Director, Work Management
- J. Barstow, Manager, Regulatory Assurance
- T. Farenga, Radiation Protection Manager
- R. Larzo, Engineering Manager
- J. Murphy, Rad Engineering Manager
- J. McCarthy, Senior Radiation Protection Analyst
- D. Chernesky, Manager, Environmental/Chemistry
- T. Keenan, Manager, Site Security
- W. Trombley, Senior Manager, Plant Engineering
- H. Ray, Senior Manager, Design Engineering
- G. Flesher, Shift Operations Superintendent
- J. Chrisley, Regulatory Assurance Specialist
- D. Moore, Regulatory Assurance Specialist
- J. Kerr, Regulatory Assurance Specialist
- S. Schwartz, Senior Staff Engineer
- P. Procacci, Electrical Design Engineer
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000219/2012005-01 NCV Failure to Follow Inspection and Torquing of Bolted Connection Procedure (Section 1R15)
- 05000219/2012005-02 NCV Inadequate Application of Strippable Coating to the Refueling Cavity Liner and the Failure to Configure a Valve in the Leakage Collection System Resulting in Increased Potential for Corrosion on the Exterior of the Drywell Liner Surface in the Sand Beds (Section 1R08)
A- 2