IR 05000219/2014003
| ML14217A183 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/06/2014 |
| From: | Kevin Mangan NRC/RGN-I/DRP/PB6 |
| To: | Pacilio M Exelon Generation Co, Exelon Nuclear |
| mangan, ka | |
| References | |
| IR-14-001, IR-14-003 | |
| Download: ML14217A183 (27) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ust 6, 2014
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2014003 and NRC INDEPENDENT SPENT FUEL STORAGE INSTALLATION REPORT 07200015/2014001
Dear Mr. Pacilio:
On June 30, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Nuclear Generating Station. The enclosed inspection report documents the inspection results, which were discussed on July 24, 2014, with Mr. G. Stathes, Site Vice President, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one violation of NRC requirements, which was of very low safety significance (Green). However, because of the very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the NCV 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 Nuclear Generating Station. In addition, if you disagree with the cross-cutting aspect assigned to the finding, 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 Nuclear Generating Station. In accordance with Title 10 of the Code of Federal Regulations (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 NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management 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/
Kevin A. Mangan, Chief (Acting)
Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-219, 72-15 License Nos.: DPR-16
Enclosure:
Inspection Report 05000219/2014003 & 0700015/2014001 w/Attachment: Supplementary Information
REGION I==
Docket Nos.: 50-219 License Nos.: DPR-16 Report No.: 05000219/2014003 & 0700015/2014001 Exelon: Exelon Nuclear Facility: Oyster Creek Nuclear Generating Station Location: Forked River, New Jersey Dates: April 1, 2014 - June 30, 2014 Inspectors: J. Kulp, Senior Resident Inspector A. Patel, Resident Inspector S. Hammann, Senior Health Physicist C. Lally, Operations Engineer J. Schoppy, Senior Reactor Inspector P. Kaufman, Senior Reactor Inspector S. Pindale, Senior Reactor Inspector J. M. DAntonio, Senior Operations Engineer Approved By: K. Mangan, Chief (Acting)
Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000219/2014003 & 0700015/2014001; 04/01/2014 - 06/30/2014; Exelon Energy
Company, LLC, Oyster Creek Generating Station; Operability Determinations and Functionality Assessments This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one finding of very low safety significance (Green), which was a 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 finding was 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 5, dated February 2014.
Cornerstone: Mitigating Systems
- Green.
The NRC inspectors identified a Green NCV of 10 CFR 50, Appendix B,
Criterion XVI, Corrective Action, because Exelon did not promptly identify and correct a condition adverse to quality. Specifically, Exelon did not identify and correct a high oil level condition caused by water intrusion in the D emergency service water pump upper motor bearing resulting in an inoperable D emergency service water pump. Following identification of the high level by the inspections, Exelon entered this issue into their corrective action program as issue report 1645010. Exelons corrective action included sealing joints on top of the motor that are susceptible to water intrusion.
The inspectors determined that inadequate identification and resolution of the condition adverse to quality into the corrective action program is a performance deficiency that was within Exelons ability to foresee and correct. This finding is more than minor because it is associated with the configuration control of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency affected the reliability of an emergency service water pump to perform its safety function. This issue was also similar to Example 3j of NRC IMC 0612, Appendix E, Examples of Minor Issues, because the condition resulted in reasonable doubt of the operability of emergency service water system. The inspectors determined that this finding was a deficiency affecting the design or qualification of a mitigating structure, system, or component (SSC), where the SSC maintained its operability or functionality. Therefore, inspectors determined the finding to be of very low safety significance (Green).
The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon did not identify the issue associated with the high oil level in the emergency service water pump upper motor bearing oil in a timely manner in February and April 2014 [P.1]. (Section 1R15)
REPORT DETAILS
Summary of Plant Status
Oyster Creek began the inspection period at 100 percent power and operated at full power throughout the inspection period, except for the following dates. Oyster Creek reduced power on April 4, 2014, to approximately 60 percent power to repair a condenser tube. On May 18 and June 27, 2014, Oyster Creek reduced power to approximately 70 percent power for a rod pattern adjustment.
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 high temperatures. The review focused on the B station emergency battery and the emergency diesel generators. 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 Exelon 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 hot weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems
a. Inspection Scope
The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Exelons procedures affecting these areas and the communications protocols between the transmission system operator and Exelon. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Exelon established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing condition reports and open work orders, and walking down portions of the offsite and AC power systems.
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:
A, B, C emergency service water pumps while D emergency service water pump out of service on April 9, 2014 Containment spray system I while containment spray system II out of service on April 21, 2014 Core spray system I while core spray system II out of service on May 20, 2014 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.
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.
480 volt switchgear room A on April 22, 2014 480 volt switchgear room B on April 22, 2014 Lower cable spreading room on April 22, 2014 Reactor building isolation condenser area on April 22, 2014 Reactor building refueling elevation on April 22, 2014 Emergency diesel generator fuel storage area on May 8, 2014 Main transformer area on May 8, 2014 Reactor building traversing in-core probe drive area on May 8, 2014 Mechanical vacuum pump room and demineralizer area on May 8, 2014
b. Findings
No findings were identified.
1R06 Flood Protection Measures
.1 Internal Flooding Review
a. Inspection Scope
The inspectors reviewed the UFSAR, 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 new cable spreading room area to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, watertight door seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and temporary or removable flood barriers.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program (71111.11A - 1 Sample,
==71111.11Q - 2 Samples)
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
==
a. Inspection Scope
The inspectors observed licensed operator simulator training on April, 2, 2014, which included a main steam isolation valve closure with an anticipated transient without a scram and the failure of select components to automatically start as required. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, and the appropriate use of abnormal and emergency operating procedures. The inspectors assessed the clarity of communications, implementation 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
The inspectors observed licensed operator performance during a scheduled downpower evolution to set plant conditions for maintenance and a control rod sequence exchange on April 4 and April 5, 2014. The inspectors ensured that infrequently performed test or evolution briefings were performed and met the requirements of Exelon procedure HU-AA-1211, Pre-Job Briefings, Revision 9. Additionally, the inspectors observed control room operator performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
.3 Licensed Operator Requalification
a. Inspection Scope
On June 30, 2014, one NRC region-based inspector conducted an in-office review of results of licensee-administered annual operating tests for 2014 for Oyster Creek Nuclear Generating Station operators. The inspection assessed whether pass rates were consistent with the guidance of NRC IMC 0609, Appendix I, and Operator Requalification Human Performance Significance Determination Process. The review verified that the failure rate (individual or crew) did not exceed 20%.
0 out of 45 operators failed at least one section of the annual exam. The overall individual failure rate was 0 percent.
0 out of 7 crews failed the simulator test. The crew failure rate was 0 percent.
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 structure, system, and component 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 structure, system or component was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff was reasonable. As applicable, for a structure, system or component classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return the structure, system, or component to (a)(2). Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Isolation condenser system level transmitter issues on May 21, 2014 Control rod drive pumps bearing oil level issues on June 19, 2014
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 Exelons 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.
A isolation condenser out of service for planned maintenance on April 3, 2014 D emergency service water pump and A fuel pool cooling out of service for planned maintenance on April 9, 2014 C and D emergency service water pumps and containment spray system II out of service for planned maintenance on April 21, 2014 Emergency diesel generator 1 out of service for planned maintenance on May 12, 2014 Core spray system II out of service for planned maintenance on May 20, 2014 Emergency diesel generator 1 out of service for corrective maintenance on June 16, 2014 A isolation condenser and D emergency service water pump out of service for planned maintenance on June 23, 2014
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:
D emergency service water pump motor due to water intrusion in the upper motor bearing oil reservoir on April 9, 2014 Core spray booster pump NZ03C due to mechanical seal leakage on June 2, 2014 Core spray main pump NZ01C due to low bearing oil level on June 9, 2014 Emergency diesel generator 1 loading with A fuel pool cooling pump breaker not open on June 10, 2014 Emergency diesel generator 2 due to overspeed trip on June 16, 2014 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 NCV of 10 CFR 50, Appendix B, Criterion XVI, Corrective Action, because Exelon did not promptly identify or correct a condition adverse to quality. Specifically, Exelon did not identify and correct a high oil level condition caused by water intrusion in the D emergency service water pump upper motor bearing resulting in an inoperable D emergency service water pump.
Description.
During a system walk down on April 8, 2014, NRC inspectors identified a high oil level condition on the D emergency service water pump upper motor bearing.
The NRC inspectors informed the unit supervisor regarding the oil level in the sight glass; however, no issue report (IR) was written. On April 9, 2014, the NRC inspectors determined high oil level is not recommended by the motor vendor manual.
Subsequently, Exelon lowered the oil level to the normal band and performed an analysis on the oil that was removed. The oil appeared cloudy and there was visible water in the oil. Per Exelon procedure, MA-AA-716-230-1001, Oil Analysis Interpretation Guidance, visible water signifies greater than 10,000 ppm of water in oil (water content >
1000 ppm constitutes an Alert level; water content > 2000 ppm constitutes a Fault level).
Exelon defines Alert level in MA-AA-716-230-1001, Data Interpretation, Alert: Adverse trend or deviation from normal operating conditions. However, there is a low probability of damage or failure of equipment. Additional monitoring or analysis may be required.
Exelon defines Fault level in MA-AA-716-230-1001, Data Interpretation, Fault: Serious deviation from normal operating condition has been detected. Damage or equipment failure may occur. Subsequently, as a result of the oil level reaching the fault level, Exelon declared the D emergency service water pump inoperable and drained the oil and refilled the oil reservoir (IR 1645010).
Exelon conducted an apparent cause evaluation and determined an IR was not written for this degraded condition although it had been identified by equipment operators.
Specifically on February 17, 2014, an equipment operator noticed the high oil level on the emergency service water pump upper bearing. The equipment operator communicated to the field supervisor who informally investigated the issue. The field supervisor annotated it on the Operations Senior Reactor Operator turnover sheet, but an IR was not submitted in their corrective action program. Exelons PI-AA-120, IRs are defined as a common process through which personnel at Exelon Nuclear Facilities can identify and gain assignment for resolution of identified issues. Exelons human performance apparent cause evaluation for this issue noted that IRs are required as the first step in identifying, analyzing and resolving problems. Exelon procedure PI-AA-120, Issue Identification and Screening Process requires, in part, that issues be entered into the corrective action program via computer or a handwritten issue reporting form.
Exelon determined that the apparent cause for the water intrusion into the upper motor bearing is that the preventive maintenance work order, procedure or instruction lacks the procedural guidance to inspect the upper motor gaskets and did not address sealing the joints on the motor. Exelons corrective action included sealing joints on top of the motor that are susceptible to water intrusion. The inspectors reviewed the corrective actions to restore the motor and determined them to be reasonable.
Analysis.
The inspectors determined that inadequate identification and resolution of a condition adverse to quality was a performance deficiency that was within Exelons ability to foresee and correct. The performance deficiency was more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency affected the reliability of an emergency service water pump to perform its safety function due to the upper motor bearing oil containing water. This issue was also similar to Example 3j of NRC IMC 0612, Appendix E, Examples of Minor Issues, because the condition resulted in reasonable doubt of the operability of emergency service water system II and additional analysis was necessary to verify operability.
The inspectors evaluated the finding using exhibit 2, Mitigating System Screening Questions in Appendix A to IMC 0609, Significance Determination Process. The inspectors determined that this finding was a deficiency affecting the design or qualification of a mitigating SSC, where the SSC maintained its operability or functionality. Therefore, inspectors determined the finding to be of very low safety significance (Green). The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon did not identify the issue associated with the high oil level in the emergency service water pump upper motor bearing oil in a timely manner in February and April 2014 [P.1].
Enforcement.
10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as, deficiencies, deviations, and nonconformances are promptly identified and corrected. Exelon procedure PI-AA-120, Issue identification and screening process requires, in part, that issues be entered into the corrective action program via computer or a handwritten issue reporting form. Contrary to the above, Exelon did not identify and correct a condition adverse to quality. Specifically, between February 17 and April 19, 2014, Exelon operations personnel noted a high oil level in the D emergency service water pump upper motor bearing oil; however, the adverse condition was not entered into the corrective action program. As a result, the condition adverse to quality, unacceptable water content in the upper motor bearing oil, was not promptly corrected.
Because this issue is of very low safety significance (Green) and Exelon entered this issue into their corrective action program as IR 1645010, this finding is being treated as an NCV consistent with the NRC Enforcement Policy. (NCV 05000219/2014003-01, Failure to Identify and Correct High Oil Level in D Emergency Service Water Pump Upper Motor Bearing)
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed the temporary modifications listed below to determine whether the modifications adversely affected the safety functions of systems that are important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
TCC-1405-736, Temporary power to 24V battery charger per R2150504 on May 19, 2014
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.
V-14-30, A isolation condenser steam inlet valve after valve motor preventive maintenance on April 1, 2014 B isolation condenser after isolation condenser condensate return valve preventive maintenance on April 7, 2014 D emergency service water pump after drain and refill of the upper motor bearing oil on April 11, 2014 Containment spray system II after preventive maintenance on April 22, 2014 Emergency diesel generator 1 after preventive maintenance on May 19, 2014 Core spray system II after preventive maintenance on May 21, 2014 Emergency diesel generator 2 after overspeed trip limit switch replacement on June 17, 2014 D emergency service water pump after motor replacement on June 25, 2014
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 SSCs to assess whether test results satisfied technical specifications, the UFSAR, and Exelon procedure requirements. 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:
A isolation condenser isolation test and calibration on April 2, 2014 Containment spray and emergency service water system I pump operability and quarterly in-service test on April 16, 2014 Standby gas treatment system 10-hour run - system II on May 25, 2014 Torus to drywell vacuum breaker operability test on June 19, 2014 Unidentified leak rate verification on May 29, 2014
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP6 Drill Evaluation
.1 Training Observations
a. Inspection Scope
The inspectors observed a simulator training evolution for licensed operators on April 2, 2014, which required emergency plan implementation by an operations crew. Exelon planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that Exelon evaluators identified the same issues and entered them into the corrective action program.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Unplanned Scrams with Complications (1 sample)
a. Inspection Scope
The inspectors reviewed Exelons submittal for the Unplanned Scrams with Complications performance indicator for the period April 1, 2013 through March 31, 2014. 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 7. The inspectors reviewed control room logs, NRC integrated inspection reports and plant process computer data, and compared that information to the data reported by Exelon to validate the accuracy of the submittal.
b. Findings
No findings were identified.
.2 Unplanned Scrams per 7000 Critical Hours (1 sample)
a. Inspection Scope
The inspectors reviewed Exelons submittal for the Unplanned Scrams per 7000 Critical Hours performance indicator for the period April 1, 2013 through March 31, 2014. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed control room logs, NRC integrated inspection reports and plant process computer data, and compared that information to the data reported by Exelon to validate the accuracy of the submittal.
b. Findings
No findings were identified.
.3 Unplanned Power Changes per 7000 Critical Hours (1 sample)
a. Inspection Scope
The inspectors reviewed Exelons submittal for the Unplanned Power Changes performance indicator for the period April 1, 2013 through March 31, 2014. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed control room logs, NRC integrated inspection reports and plant process computer data, and compared that information to the data reported by Exelon to validate the accuracy of the submittal.
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 Annual Sample: Operator Actions during a Reactor Scram on December 14, 2013 and
Subsequent Startup Reactor Scram Signal
a. Inspection Scope
The inspector reviewed Exelons evaluation and corrective actions associated with the operator performance aspects of a reactor scram on December 14, 2013, (IR 1597041)and the subsequent startup reactor scram signal (IR 1598442). The inspector reviewed the root cause evaluations, associated issue reports, and interviewed personnel related to these issues to ensure appropriate corrective actions have been identified and appear effective.
b. Findings and Observations
No findings were identified.
In regard to IR 1597041, the inspector evaluated the specific issues of reactor vessel level control following the reactor scram on December 13, 2013, and a fourteen hour delay in resetting the scram. The inspectors noted that emergency operating procedure (EOP) EMG-3200.01A, RPV Control - No ATWS, directs operators to control level between 138 to 175. Review of the post event level plots show that the isolation condensers, used for pressure control, were initiated three times in the first hour following the scram with reactor vessel level at approximately 138-140. Per water physics, this creates a level swell of up to 20 inches. This resulted in a cooldown such that when the isolation condensers were secured, level dropped below 138 due to shrink, by approximately 10-15 inches.
The inspector interviewed the shift manager for this event concerning why level was not maintained above 138. The crew was concerned on not exceeding the upper level limit due to the potential 20 swell when initiating the isolation condensers. This upper limit is based on potential flooding of the isolation condenser steam lines which could cause a water hammer. Due to this concern, the crew kept level at the low end of the EOP band and considered compliant with the EOP criteria because level was trending up whenever the isolation condensers were secured.
Review of the EOP basis documents shows that the only basis for the 138 low level is that this is a scram setpoint, so the scram cannot be reset until level is stable above that value. The inspector determined that excessive concern over the potential for water hammer and failure to anticipate the effect of cooldown from the isolation condensers is a knowledge and training issue, rather than a failure to comply with the EOP. Exelon captured this issue as IR 1599446 and IR 161771.
The delay in resetting the scram resulted initially from the fact that level was repeatedly dropping below the 138 scram setpoint. The inspector reviewed Exelon procedure, ABN-1, Reactor Scram, and noted that there is no specified time frame or urgency about resetting the scram. There is one valve which must be closed if the scram will not be reset for an extended period of time; the crew took that action.
The facility wrote IR 1599446 to address RPV level control, and IR 161771 to evaluate an expanded level band for isolation condenser operation in EOPs and other issues.
In regards to IR 1598442, the inspector determined that the evaluation and corrective actions for the error that resulted in a scram signal while shutdown was thorough and appropriate. The inspector also evaluated the issue of whether fitness for duty and/or fatigue testing should have been performed. Exelon procedure SY-AA-102-202, Testing for Cause, lists conditions requiring either for cause testing. The only aspect of this event that potentially required for cause testing was an event that resulted in a station event free clock reset. OP-AA-101-113-001, Station Event Free Clock Program, Attachment 1, Station Clock Reset Criteria, item 5.c includes regulatory reporting per 10 CFR 50.72 and 10 CFR 50.73 as a reason for a clock reset. This event was reported per 10 CFR 50.72(b)(3)(iv)(A) and 10 CFR 50.73(a)(2)(iv)(B). Exelon determined this was not an item requiring a reset because the reset is discretionary.
The inspector interviewed the Human Performance Improvement Manager, and determined the event would have been a station clock reset if the event had happened with the plant online. As result, for the event that did not occur online, no for cause fitness for duty test was discretionarily not required.
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. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and 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 events to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.
Unusual Event due to release of chlorinated water on May 28, 2014
b. Findings
No findings were identified.
4OA5 Other Activities
.1 Operation of an Independent Spent Fuel Storage Installation (ISFSI) at Operating Plants
a. Inspection Scope
The inspectors evaluated Exelons activities related to long-term operation and monitoring of their ISFSI, and verified that activities were being performed in accordance with the Certificate of Compliance (CoC), technical specifications (TS), regulations, and site 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 the site procedures and verified that Exelon was 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 the TS and consistent with values specified in the final safety analysis report (FSAR). The inspectors reviewed radiation protection procedures and radiation work permits 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, and the associated follow-up actions associated with ISFSI operations to ensure that issues were entered into the corrective action program, prioritized, and evaluated commensurate with their safety significance.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On July 24, 2014, the inspectors presented the inspection results to Mr. G. Stathes, Site Vice President 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.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Exelon Personnel
- G. Stathes, Site Vice-President
- R. Peak, Plant Manager
- M. Ford, Director, Operations
- G. Malone, Director, Engineering
- J. Dostal, Director, Maintenance
- C. Symonds, Director, Training
- M. Rossi, Operations Training Lead
- B. Egan, Shift Manager
- D. DiCello, Director, Work Management
- M. McKenna, Manager, Regulatory Assurance
- D. Moore, Licensing
- M. Caldeira, HPIP Manager
- T. Farenga, Radiation Protection Manager
- J. Renda, Manager, Environmental/Chemistry
- T. Keenan, Manager, Site Security
- P. Bloss, Senior Manager, Plant Engineering
- H. Ray, Senior Manager, Design Engineering
- E. Swain, Shift Operations Superintendent
- J. Chrisley, Regulatory Assurance Specialist
- D. Moore, Regulatory Assurance Specialist
- K. Paez, Regulatory Assurance Specialist
- J. Dougherty, Exelon Corporate ISFSI Program Engineer
- C. Holtzapple, SNM Coordinator
- K. Zadroga, Radiation Protection Supervisor
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000219/2014003-01 NCV Failure to Identify and Correct High Oil Level in D Emergency Service Water Pump Upper Motor Bearing (Section 1R15)