IR 05000219/2012009

IR 05000219-12-009; 11/13/2012 - 11/27/2012; Oyster Creek Generating Station (Ocgs); Inspection Procedure 93812, Special Inspection

ML13010A470
Person / Time
Site:	Oyster Creek
Issue date:	01/10/2013
From:	Hunegs G NRC/RGN-I/DRP/PB6
To:	Pacilio M Exelon Generation Co
HUNEGS, GK
References
IR-12-009
Download: ML13010A470 (25)

Text

January 10, 2013

SUBJECT:

OYSTER CREEK GENERATING STATION - NRC SPECIAL INSPECTION REPORT 05000219/2012009

Dear Mr. Pacilio:

On November 27, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed a special inspection at your Oyster Creek Generating Station (OCGS). The inspection was conducted to evaluate the emergency preparedness program performance and organizational decision-making associated with Oyster Creeks response to Hurricane Sandy on October 29 and 30, 2012. Although ancillary aspects of the OCGS response to Hurricane Sandy were assessed, the primary focus of the Special Inspection Team (SIT) was to determine if the Alert declaration and notification was timely and accurate. This inspection was conducted to expand on the inspection activities performed by the resident and regional inspectors who provided the real time hurricane response coverage. The NRCs initial evaluation of this event satisfied the criteria in NRC Inspection Manual Chapter (IMC) 0309, Reactive Inspection Decision Basis for Reactors, for conducting a special inspection. The decision to conduct this special inspection was based on deterministic-only criteria involving emergency preparedness program implementation during an actual event, specifically, initial concerns that OCGS may not have met the planning standards associated with the classification and notification of an event. The SIT Charter (Attachment 2 of the enclosed report) provides the basis and additional details concerning the scope of the inspection. The enclosed inspection report documents the inspection results, which were discussed on November 27, 2012, with Mr. Massaro, Site Vice President, and other members of your staff.

The SIT examined activities conducted under your license as they relate to safety and compliance with Commission rules and regulations and with the conditions of your license.

The SIT reviewed selected procedures and records, observed activities, and interviewed personnel. The SIT concluded that OCGS performance was acceptable and that emergency action level declarations were timely. However, the SIT observed several licensee practices where plant performance could be improved. These areas were related to equipment and organization performance. These observations were determined to be of minor significance and therefore no enforcement action is being taken. No NRC-identified or self-revealing findings were identified during this inspection. However, a licensee-identified violation which was determined to be of very low safety significance is listed in this report. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy. If you contest this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, 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 OCGS.

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 NRCs Public Document Room or from the Publicly Available Records (PARS) component of NRCs Agencywide Documents Access and 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/

Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket No. 50-219 License No. DPR-16

Enclosure:

Inspection Report 05000219/2012009 w/Attachments:

Supplemental Information (Attachment 1)

Special Inspection Team Charter (Attachment 2)

Detailed Sequence of Events (Attachment 3)

REGION I==

Docket No.: 50-219 License No.: DPR-16 Report No.: 05000219/2012009 Licensee: Exelon Nuclear Facility: Oyster Creek Generating Station (OCGS)

Location: Forked River, New Jersey Dates: November 13, 2012 - November 27, 2012 Team Leader: F. Bower, Senior Resident Inspector, Division of Reactor Projects Team: S. Barr, Senior Emergency Preparedness Inspector, Division of Reactor Safety T. Hedigan, Operations Engineer, Division of Reactor Safety Approved By: Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000219/2012009; 11/13/2012 - 11/27/2012; Oyster Creek Generating Station (OCGS);

Inspection Procedure 93812, Special Inspection.

This report covers a 15-day period of onsite inspection and offsite review from November 13, 2012, through November 27, 2012. A three-person NRC team, comprised of two regional inspectors and one resident inspector, conducted this Special Inspection. 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 200

NRC Identified and Self Revealing Findings

None

Other Findings

A violation of very low safety significance (Green) that was identified by OCGS was reviewed by the inspectors. Corrective actions taken or planned by OCGS have been entered into OCGSs corrective action program. This violation and corrective action tracking number are listed in Section 4OA7 of this report.

REPORT DETAILS

1. Background and Description of Event

In accordance with the Special Inspection Team (SIT) Charter (Attachment 2), the inspection team conducted a detailed review of the emergency preparedness program performance and organizational decision-making associated with Oyster Creeks response to Hurricane Sandy on October 29 and 30, 2012. The SIT gathered information from the control room operators narrative logs and intake level monitoring logs, interviewed station personnel, and reviewed procedures, emergency response organization records, and various technical documents to develop a detailed timeline of the event (Attachment 3).

On October 29, 2012, Hurricane Sandy, a Category 1 hurricane, was expected to make landfall in the vicinity of the OCGS. OCGS was shutdown on October 22 for a scheduled refueling outage and partially defueled (approximately 10 bundles had been moved to the spent fuel pool) with a time to boil of 28 hours3.240741e-4 days <br />0.00778 hours <br />4.62963e-5 weeks <br />1.0654e-5 months <br /> for the core and spent fuel pool. Decay heat removal was via shutdown cooling and spent fuel pool cooling. The reactor vessel head was removed and secondary containment was intact.

At approximately 9:20 a.m. on October 29, 2012, control room operators entered the abnormal operating procedure ABN-32, Abnormal Intake Level, when intake level downstream of the traveling water screens rose above three feet and the operators began monitoring intake level every four hours. At 1:46 p.m., operators entered ABN-31, High Winds, due to wind gusts greater than 58 miles per hour.

At 6:47 p.m., due to the combination of the storm surge and the high tidal cycle associated with a full moon, the intake level was measured at 4.65 feet (point 23) and 4.50 feet (point 24) on control room recorder CR-423-11. Control room operators recognized that intake level had reached the Notice of Unusual Event (NOUE) threshold condition of greater than 4.5 feet. At 6:55 p.m., the Operations Shift Manager declared an NOUE HU-4. This declaration was accurate and timely. The state and local notifications were completed within the required timeframe at 7:03 p.m.. However, these notifications were inaccurate because the wind direction provided in the notification was from the wrong level of the sites meteorological tower. This issue is discussed further in report section 4OA7.

At 7:54 p.m., offsite power line R144 tripped and caused a resulting trip of the fuel pool cooling system. Operators entered ABN-16, Loss of Fuel Pool Cooling. At 8:08 p.m.,

the modem that was relaying intake level data to the control room recorder (points 23 and 24) failed and rendered the primary means of measuring intake level unavailable.

Operators that had been stationed at the intake structure were also relaying intake level readings to the control room from two local pressure indicators (PI-533-1173 and PI-533-1172). At this time, the intake levels were 4.6 psig (5.3 feet) and 4.5 psig (5.1 feet) on pressure indicators 1173 and 1172, respectively. Control room operators had to rely on these secondary indicators to make emergency action level decisions.

Offsite power to OCGS was lost at 8:18 p.m., and operators entered ABN-36, Loss of Offsite Power. The loss of offsite power caused a trip of the shutdown cooling sytem.

Subsequently, the senior reactor operator (field supervisor) overseeing equipment operators at the intake structure reported to the emergency diesel generators (EDGs)to facilitate post-start checks of the EDGs that automatically started on the loss of offsite power. The EDGs were automatically aligned to restore power to the emergency busses.

When the field supervisor returned to the intake structure at approximately 8:29 p.m., he reported to the control room that intake level was 4.9 psig (6.0 feet) on both of the local pressure indicators. The Shift Manager reviewed the Alert emergency action level threshold of greater than 6.0 feet intake level and determined that it had not been met, and he requested another intake level reading from the operators at the intake structure.

At 8:32 p.m., the field supervisor reported that he could no longer safely monitor the local pressure indicators (PI-533-1173 and PI-533-1172) to determine intake level due to the rising water level. The inspectors noted that this is consistent with caution statements in ABN-32 because the intake structure deck is at a height of six feet mean sea level and electrically energized motor control centers are mounted on the deck. The field supervisor also reported that intake level was 6.25 feet and rising on a staff gauge located on the intake structure upstream of the traveling screens. The intake staff gauge was an alternate method of monitoring intake level when the primary and secondary level indicators are unavailable.

At 8:44 p.m., the operations Shift Manager declared an Alert (HA-4) in response to the report that intake level was greater than 6.0 feet on the intake staff gauge. State and local notifications for the Alert were completed at 8:51 p.m.. The SIT determined that these notifications were accurate and timely. The shutdown cooling and fuel pool cooling systems were returned to service at 8:50 p.m. and 9:19 p.m., respectively.

At 11:11 p.m., intake level on the staff gauge was 7.0 feet (Note: the staff gauge is not available above 7 feet). At approximately 12:18 a.m. on October 30, 2012, the maximum intake level of 7.4 feet was reached as determined by water level measurements above the base of the service water pumps. Water levels remained below the service water pump motors and well below the design basis flood height of greater than 22 feet that is documented in UFSAR section 2.4.5.4.

On October 30, 2012, intake levels receded below the Alert and NOUE threshold levels at 6:29 a.m. and 5:45 p.m., respectively. OCGS began to restore offsite power on October 30, 2012, and had offsite power fully restored to the plant by 3:46 a.m. on October 31, 2012. At 3:52 a.m. on October 31, 2012, OCGS terminated the Alert.

.1 Emergency Action Level (EAL) Declarations

a. Inspection Scope

On October 29, the impact of the storm on the OCGS required Exelon to declare two emergency events due to the rising water level at the station intake structure. The two applicable OCGS Emergency Plan emergency action levels (EALs) specified thresholds of intake water level greater than 4.5 feet for the declaration of an NOUE and of intake water level greater than 6.0 feet for the declaration of an Alert. The OCGS Emergency Plan and 10 CFR 50, Appendix E, require that an emergency event be declared within 15 minutes of an EAL threshold being exceeded. Additionally, the licensee must notify applicable offsite response organizations within 15 minutes of the event declaration.

The inspectors reviewed Exelons performance related to the event declarations and the subsequent offsite notifications. Specifically the review was conducted to determine if the declarations and notifications had been made both accurately and timely. This review was accomplished through the review of: the OCGS Emergency Plan; applicable Emergency Plan implementing procedures; control room operating logs; the Shift Emergency Director Checklist; the completed offsite notification forms; and, associated issue reports. The inspectors also interviewed the control room operating crew that was on shift at the time of both event declarations and both notifications.

b. Findings and Observations

No findings were identified. However, Exelon identified that the NOUE offsite notification was inaccurate because the required meteorological information provided in the notification had a wind direction error. This licensee-identified violation of very low safety significance (Green) is further described in Section 4OA7 of this report.

In their attempt to understand the operating crews actions and to assess the crew performance, the inspectors encountered challenges with control room log keeping clarity. Additionally, the timeliness of control room log corrections made it difficult for the inspectors to determine whether the NOUE and Alert declarations and notifications were completed accurately and timely. Many of the control room log entries were not documented concurrent with activities and decisions made by the control room operating crew. It was necessary for the inspectors to conduct interviews and review unofficial logs and notes, to assess operating crew performance. Nonetheless, the inspectors determined that OCGS operators had made the NOUE declaration in an accurate and timely manner. The Alert declaration and notification were also accurate and timely.

The inspectors concluded that OCGS had properly anticipated which EALs would most likely be exceeded during the storm and had, to the extent possible, prepared the offsite notification forms before the storm arrived at the station.

Overall, the emergency preparedness performance was good; however, the inspectors observed some areas where performance could be improved. Specifically, the inspectors noted that determining the Alert EAL threshold for high intake level can be a challenge when the remote intake level recorder in the control room (primary instrument)is not available. This condition occurred on October 29, due to power fluctuations experienced during the hurricane. The challenge arose because, in accordance with the abnormal procedure for rising intake level (ABN-32), the bubblers at the intake structure (local, secondary instruments) are not safe to access at intake levels greater than 6 feet mean sea level (MSL). However, intake level must be measured to determine when water level is greater than 6 feet for the Alert EAL threshold to be met. The inspectors determined that the equipment operator assigned to report bubbler level indication could not access the indications to positively confirm that the water level had exceeded 6 feet.

The inspectors also determined that the control room crew that was receiving the reports from the equipment operator at the intake structure did not have a clear understanding of the intake level required to satisfy the EAL; some operators believed the Alert occurred when the water level reached 6 feet, while others correctly knew that it was when the level was greater than 6 feet.

The inspectors concluded that the above challenges did not prevent the crew from making the Alert declaration in a timely manner. However, if the remote level indications were more accessible, and the control room crew had been briefed on the specific level needed to satisfy the EAL, the emergency preparedness performance would have been improved, easier to verify as appropriate, and better documented.

.2 Emergency Response Organization (ERO) Activation

a. Inspection Scope

In accordance with the OCGS Emergency Plan, Exelon was required to augment the on-shift emergency response organization (ERO) and activate emergency response facilities (ERFs) when the Alert declaration was made. The inspectors assessed Exelons performance, specifically to determine if the Oyster Creek ERO was augmented timely and completely and if the required ERFs were properly activated.

The inspectors reviewed ERO checklists, logs applicable to emergency plan imple-menting procedures; interviewed the OCGS emergency preparedness staff, ERO responders, and the Corporate Emergency Director (CED); and, reviewed various issue reports initiated by OCGS.

b. Findings and Observations

No findings were identified. The inspectors concluded that Exelon had taken prudent measures to prepare for ERO activation before the storm arrived. The inspectors also concluded that OCGS had complied with all station procedures and regulations in the augmenting of the station ERO and in the activation of the site ERFs; however, the inspectors identified some performance issues.

The offsite Emergency Operations Facility (EOF) was staffed prior to the arrival of the storm, in the morning of October 29. For the on-site ERFs (the Operations Support Center and the Technical Support Center), Exelon verified that the normal work crews and shift personnel contained the adequate ERO members to activate those on-site ERFs without requiring personnel to travel to the site during the storm. The inspectors concluded that once the Alert had been declared, the ERO was adequately augmented and the ERFs were activated in accordance with station procedures. The ERO was maintained and the ERFs were activated until the station terminated from the Alert early in the morning of October 31.

Due to the local loss of electrical power, the EOF was initially ready to be activated with the facilitys emergency generator supplying electrical power to the building. Shortly thereafter, that generator began to trip off line, and with no power to the building, the CED did not activate the EOF. The EOF staff diagnosed the generators tripping as a result of a mechanical fault in the EOFs air conditioner. Once the EOF staff opened the air conditioners circuit breaker, the generator successfully and consistently supplied power to the building. At that point, the CED activated the EOF and assumed command and control.

The inspectors concluded that the ERO personnel lacked some information regarding EOF equipment and the EOF facility which contributed to delayed EOF activation. The EOF personnel had adequate equipment and resources to help relieve the burden from the control room crew dealing with the emergency event. Exelon initiated an issue report to review the EOF performance and to determine what improvements in performance could be realized through procedure and training enhancement. The SIT determined that the EOF activation delays associated with the loss of the facilitys emergency generator were minor and did not violate NRC emergency preparedness program requirements.

.1 Hurricane Preparations and Contingency Plans

a. Inspection Scope

The inspectors reviewed and assessed OCGSs hurricane preparations that included the implementation of OP-AA-108-11-1001, Severe Weather and Natural Disaster Guidelines, and OP-OC-108-109-1001, Severe Weather Preparation. The inspectors also reviewed action items and contingency plans that OCGS created in support of their hurricane preparations. The contingency plans reviewed included Offsite Power, and Intake Debris/Grassing Readiness and Contingencies.

b. Findings and Observations

No findings were identified.

OCGS created a customized list of action items to ensure that outage related activities and personnel were properly prepared for Hurricane Sandy. The list included approximately eighty items, which included, but were not limited to, confirming the availability of all electrical busses (full defense-in-depth), promulgating a duty roster, and pre-staging a duty team of emergency response personnel.

.2 Procedure Adequacy

a. Inspection Scope

The inspectors reviewed the following abnormal operating procedures (ABNs) and system operating procedures (SOPs) that were implemented during Hurricane Sandy on October 29 and 30, 2012. The inspectors assessed the operators procedure use and adherence during and following the storm through a review of plant logs and personnel interviews. The documents reviewed included the following:

• Operator logs;

• ABN-32, Abnormal Intake Level;

• ABN-31, High Winds;

• ABN-36, Loss of Offsite Power;

• SOP-311, Fuel Pool Cooling System;

• SOP -324, Thermal Dilution Pumps; and

• SOP- 344, Screen Wash System Evolutions.

The inspectors conducted a review of procedures that OCGS was prepared to use as a contingency, if equipment at the intake structure was lost as a result of high water level during Hurricane Sandy. The review was conducted to assess whether OCGS had adequate procedures available to effectively mitigate a loss of the service water system and to provide decay heat removal. The following abnormal operating procedures were reviewed:

• ABN-3, Loss of Shutdown Cooling;

• ABN-16, Loss of Fuel Pool Cooling;

• ABN-18, Service Water Failure Response; and

• ABN-19, RBCCW Failure Response.

b. Findings and Observations

No findings were identified.

Based on a review of abnormal procedures implemented during Hurricane Sandy, interviews of OCGS personnel, and discussion with NRC inspectors that were monitoring operations onsite on October 29, 2012, the inspectors observed that a change to ABN-32 for increasing the intake level that would require securing the service water pumps was not preplanned. The inspectors noted that revision 18 of ABN-32 directed operators to secure all of the service water pumps when the intake level reached seven feet MSL. However, the day shift operating crew identified that the bottom of the service water pump motors was located at approximately 10 feet MSL.

Therefore, approximately three feet of available margin existed before the service water pump motors would be impacted. The normal method of decay heat removal from the shutdown cooling and fuel pool cooling systems would therefore remain available. The day shift operating crew discussed revising ABN-32, but did not communicate this contingency plan to the Outage Command Center (OCC) and the procedure change was not pursued further during the day shift.

As intake level rose towards seven feet MSL, the night shift operating crew coordinated with the OCC to have ABN-32 revised to raise the required intake level for securing the service water pumps. Revision 19 to ABN-32 was completed shortly before the intake level reached seven feet MSL. Although intake level rose to approximately 7.4 feet MSL, the intake level did not approach the new higher ABN-32 required limit for securing the service water pumps. OCGS documented this issue in issue report 1438850. The inspectors considered this issue minor because the delay in revising the procedure did not affect the availability, reliability or capability of the shutdown cooling or fuel pool cooling water systems.

.3 Operator Training

a. Inspection Scope

The inspectors interviewed operations personnel regarding the training and procedure reviews/walkthroughs that were performed in accordance with the action item list for hurricane preparations. Through these interviews, the inspectors verified that OCGS conducted just-in-time training for each operating crew by having the crews brief and perform walkthroughs of all system operating and abnormal procedures that were anticipated to be used during the storm.

b. Findings

No findings were identified.

.4 Post- Event Problem Identification

a. Inspection Scope

The inspectors interviewed personnel, reviewed various procedures, logs, critiques and corrective action program documents to assess whether equipment, human performance and programmatic issues related to EAL event declarations, the activation of OCGSs ERO and OCGSs preparedness for the hurricane were appropriately identified and entered into the corrective action program.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

Exit Meeting Summary

On November 27, 2012, the inspection team discussed the inspection results with Mr. M. Massaro, Site Vice President, and members of his staff. The inspection team confirmed that proprietary information reviewed during the inspection period was returned to Exelon.

4OA7 Licensee-Identified Violations

The following violation of very low safety significance (Green) was identified by OCGS and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.

• 10 CFR 50.47(b)(5) requires, in part, that procedures have been established for notification, by the licensee, of state and local response organizations and for notification of emergency personnel by all organizations, and that the content of initial and follow-up messages to response organizations and the public has been established. Exelon procedure EP-MA-114-100, Mid-Atlantic State/Local Notifications, Step 4.4, provides the directions for completing the State/Local notification form. Step 4.4.7 of EP-MA-114-100 states, in part, that the meteorological tower indicator to use in the case of a no-release condition is the Met Tower 380 indicator. During the events of October 29, 2012, there was no release in progress. Therefore, the OCGS staff should have used the meteorological data from the Met Tower 380 indicator. Contrary to the above, for the state and local notification of the Unusual Event declaration, the OCGS staff used the Met Tower 33 indicator. At the time of the Unusual Event notification, the wind direction that should have been reported from the 380 indicator was 63.7 degrees. The State/Local notification form, however, was completed with the Met Tower 33 wind direction indication, which was 55.7 degrees. The inspectors evaluated the finding using IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process.

Specifically, Attachment 1, Failure to Implement (Actual Event) Significance Logic, indicates that any failure by the licensee to properly implement their emergency plan during an actual Unusual Event condition is of very low safety significance (Green).

Exelon documented the issue in issue report 1438003 and issue report 1443552.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Exelon Personnel

M. Massaro, Site Vice President

R. Peak, Plant Manager

M. Ford, Operations Director

A. Zuchowski., Shift Manager

A. Krukowski, Field Supervisor

M. Baratta, Reactor Operator

C. Wade, Equipment Operator

G. Malone, Engineering Director

J. Dostal, Maintenance Director

D. DiCello, Work Management Director

J. Vaccaro, Projects Manager

J. Barstow, Regulatory Assurance Manager

D. Chemesky, Chemistry Manager

T. Farenua, RP Manager

J. Renda, PI Manager

T. Keenan, Site Security Manager

J. McDaniel, NOS Manager

J. Chrisley, Regulatory Assurance

M. Jesse, Corporate Director Licensing

J. Armstrong, PB Regulatory Assurance Manager

N. Dennin, Operations

D. Moore, Regulatory Assurance

K. Aleshire, Corporate Director EP

M. Chanda, EP Manager

NRC Personnel

D. Roberts, Director, Division of Reactor Projects

G. Hunegs, Chief, Reactor Projects Branch 6

J. Kulp, Senior Resident Inspector, Oyster Creek

A. Patel, Resident Inspector, Oyster Creek

P. Kaufman, Senior Reactor Inspector

J. Schoppy, Senior Reactor Inspector

State of New Jersey Personnel

R. Pinney, Supervisor, NJ Department of Environmental Protection

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed and

Discussed

None