IR 05000219/2012008

IR 05000219/2012008, 08/13/2012-08/31/2012, Oyster Creek Nuclear Generating Station; Biennial Baseline Inspection of Problem Identification and Resolution

ML12272A204
Person / Time
Site:	Oyster Creek
Issue date:	09/28/2012
From:	Hunegs G K NRC/RGN-I/DRP/PB6
To:	Pacilio M J Exelon Generation Co, Exelon Nuclear
References
IR-12-008
Download: ML12272A204 (19)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 2100 RENAISSANCE BOULEVARD, SUITE 100 KING OF PRUSSIA, PENNSYLVANIA 19406-2713 September 28, 2012

Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road

Warrenville, IL 60555

SUBJECT: OYSTER CREEK GENERATING STATION - NRC PROBLEM IDENTIFICATION AND RESOLUTION INSPECTION REPORT 05000219/2012008

Dear Mr. Pacilio:

On August 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 August 31, 2012 with Mr. M. Massaro, Site Vice President, and other members of your staff.

This inspection examined activities conducted under your license as they relate to identification and resolution of problems and compliance with the Commission's rules and regulations and conditions of your license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel.

This report documents one NRC-identified finding of very low safety significance (Green) which involved a violation of NRC requirements. 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 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 Inspectors at Oyster Creek Generating Station. In addition, if you disagree with the cross- cutting aspect assigned to the 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 Inspectors 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 NRC's document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

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 05000219/2012008 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ

ML12272A204 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE lhp RI/DRP RI/DRP RI/DRP NAME SBarber RPowell/cab for GHunegs DATE 09/24/12 09/27/12 09/28/12 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No.: 50-219

License No.: DPR-16

Report No.: 05000219/2012008

Licensee: Exelon Nuclear

Facility: Oyster Creek Generating Station

Location: Forked River, New Jersey

Dates: August 13 - 17, 2012, and August 27 - 31, 2012

Inspectors: S. Barber, Senior Project Engineer, Team Leader A. Patel, Resident Inspector J. Ayala, Project Engineer E. Keighley, Project Engineer

Approved By: Gordon Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects

2 Enclosure

SUMMARY OF FINDINGS

IR 05000219/2012008, 08/13/2012 - 8/31/2012, Oyster Creek Nuclear Generating Station; Biennial Baseline Inspection of Problem Identification and Resolution. The inspectors identified one finding in the area of problem identification and resolution.

This NRC team was performed by three regional in spectors and one resident inspector. The inspectors identified one finding of very low safety significance (Green), which was an 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 NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

Problem Identification and Resolution

The inspectors concluded that Exelon was genera lly effective in identifying, evaluating, and resolving problems. Exelon personnel identified problems, entered them into the corrective action program at a low threshold, and prioritized issues commensurate with their safety significance. In most cases, Exelon appropriately screened issues for operability and reportability, and performed causal analyses that appropriately considered extent of condition, generic issues, and previous occurrences. The inspectors also determined that Exelon typically implemented corrective actions to address the problems identified in the corrective action program in a timely manner. However, the inspectors identified one violation of NRC requirements in the problem identification area.

The inspectors concluded that, in general, Exelon adequately identified, reviewed, and applied relevant industry operating experience to Oyster Creek operations. In addition, based on those items selected for review, the inspectors determined that Exelon's self-assessments and audits were thorough.

Based on the interviews the inspectors conducted over the course of the inspection, observations of plant activities, and reviews of individual corrective action program and employee concerns program issues, the inspectors did not identify any indications that site personnel were unwilling to raise safety issues nor did they identify any conditions that could have had a negative impact on the site's safety conscious work environment.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR 50 Appendix B, Criterion XVI, "Corrective Action," for Exelon's failure to promptly identify and correct a condition adverse to quality. Specifically, Exelon did not promptly identify and correct the impact of increased emergency diesel generator (EDG) loading on the committed three day fuel oil supply. Existing procedural guidance requires load management actions after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> which provides reasonable assurance of EDG operability. Exelon corrective actions include additional load management actions to ensure fuel oil capacity is maintained. This condition has been placed in the Exelon's corrective action program.

Exelon's failure to promptly identify and correct an inadequate technical evaluation that did not determine the impact of increased EDG loading on the existing three day fuel oil supply was a performance deficiency. Inspectors determined that the finding was more than minor because the performance deficiency was associated with the design control attribute of the Mitigating Systems Cornerstone and the associated cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the technical evaluation stated that #2 EDG loading could be as much as 2735 KW which translates to approximately 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> of fuel capacity with the storage tank at minimum capacity versus the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The EDGs remain operable because they are capable of supplying accident loads with adequate load management actions after eight hours of operation. The inspectors evaluated the finding using IMC 0609, Appendix A, "the Significance Determination Process for Findings for At-Power," and determined that it was of very low safety significance (Green). The finding is not a deficiency affecting the design or qualification of a mitigating structure, system or component (SSC) and the SSC maintains its operability. The finding had a cross-cutting aspect in the area of problem identification and resolution, because Exelon did not thoroughly evaluate problems such that the resolutions address causes and extent of conditions, as necessary.

Specifically, Exelon's technical evaluations 1145338 and 1365452 failed to adequately evaluate the impact of increased loads on the amount of available EDG fuel oil. Therefore, at the increased loads of 2735 KW, the EDG's would have only had 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> of the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of fuel oil capacity. [P.1 (c)] [Section 4OA2.1.c.]

REPORT DETAILS

4OA2 Problem Identification and Resolution

This inspection constitutes one biennial sample of problem identification and resolution as defined by Inspection Procedure 71152. Documents reviewed during this inspection are listed in the attachment to this report.

.1 Assessment of Corrective Action Program Effectiveness

a. Inspection Scope

The inspectors reviewed the procedures that described Exelon's corrective action program at Oyster Creek. To assess the effectiveness of the corrective action program, the inspectors reviewed performance in three primary areas: problem identification, prioritization and evaluation of issues, and corrective action implementation. The inspectors compared performance in thes e areas to the requirements and standards contained in 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," and Exelon's procedure LS-AA-125, "Corrective Action Program." For each of these areas, the inspectors considered risk insights from the station's risk analysis and reviewed issue reports selected across the seven cornerstones of safety in the NRCs Reactor Oversight Process. Additionally, the inspectors attended Station Ownership Committee and Management Review Committee meetings to assess screening and evaluation activities. The inspectors selected items from the following functional areas for review: operations, maintenance, engineering, work control, emergency preparedness, radiation protection, chemistry, physical security, and oversight programs.

1. Effectiveness of Problem Identification In addition to the items described above, the inspectors reviewed system health reports, a sample of completed corrective and preventive maintenance work orders, completed surveillance test procedures, operator logs, and periodic trend reports. The inspectors also completed field walkdowns of various systems on site, such as the emergency diesel generators (EDGs) and core spray systems. Additionally, the inspectors reviewed a sample of issue reports written to document issues identified through internal self-assessments, audits, and the operating experience program. The inspectors completed this review to verify that Exelon entered conditions adverse to quality into their corrective action program, as appropriate.

2. Effectiveness of Prioritization and Evaluation of Issues The inspectors reviewed the evaluation and prioritization of a sample of issue reports issued since the last NRC biennial Problem Identification and Resolution inspection completed in August 2010. The inspectors also reviewed issue reports that were assigned lower levels of significance that did not include formal cause evaluations to ensure that they were properly classified. The inspectors' review included the appropriateness of the assigned significance, the scope and depth of the causal analysis, and the timeliness of resolution. The inspectors assessed whether the evaluations identified likely causes for the issues and developed appropriate corrective 5 Enclosure actions to address the identified causes. Further, the inspectors reviewed equipment operability determinations, reportability assessments, and extent-of-condition reviews for selected problems to verify these processes adequately addressed equipment operability, reporting of issues to the NRC, and the extent of the issues.

3. Effectiveness of Corrective Actions The inspectors reviewed Exelon's completed corrective actions through documentation review and, in some cases, field walk downs to determine whether the actions addressed the identified causes of the problems. The inspectors also reviewed issue reports for adverse trends and repetitive problems to determine whether corrective actions were effective in addressing the broader issues. The inspectors reviewed Exelon's timeliness in implementing corrective actions and effectiveness in precluding recurrence for significant conditions adverse to quality. The inspectors also reviewed a sample of issue reports associated with selected NCVs and findings to verify that Exelon personnel properly evaluated and resolved these issues. In addition, the inspectors expanded the corrective action review to five years to evaluate Exelon actions related to EDG deficiencies and aspects of the work control system.

b. Assessment 1. Effectiveness of Problem Identification Based on the selected samples, plant walkdowns, and interviews of site personnel in multiple functional areas, the inspectors determined that Exelon identified problems and entered them into the corrective action program at a low threshold. Exelon staff at Oyster Creek initiated approximately 17,000 issue reports between August 2010 and August 2012. The inspectors observed supervisors and managers at the Station Ownership Committee and Management Review Committee meetings appropriately questioning and challenging issue reports to ensure adequate clarification and completion of the issues identified in issue reports. Based on the samples reviewed, the inspectors determined that Exelon trended equipment and programmatic issues, and appropriately identified problems in issue reports. The inspectors verified that conditions adverse to quality identified through this review were entered into the corrective action program, as appropriate. Additionally, inspectors concluded that personnel were identifying trends at low levels. In response to several questions and minor equipment observations identified by the inspectors during plant walkdowns, Exelon personnel promptly initiated issue reports and/or took immediate action to address the issues. The inspectors identified one example of more than minor significance where Exelon personnel were not effective in identifying a condition adverse to quality. This finding is documented in Section 4OA2.1.c.

2. Effectiveness of Prioritization and Evaluation of Issues The inspectors determined that, in general, Exelon appropriately prioritized and evaluated issues commensurate with the safety significance of the identified problem. Exelon screened issue reports for operability and reportability, categorized the issue reports by significance, and assigned actions to the appropriate department for evaluation and resolution.

6 Enclosure The issue report screening process considered human performance issues, radiological safety concerns, repetitiveness, adverse trends, and potential impact on the safety conscious work environment.

Based on the sample of issue reports reviewed, the inspectors noted that the guidance provided by Exelon corrective action program implementing procedures appeared sufficient to ensure consistency in categorization of issues. Operability and reportability determinations were generally performed when conditions warranted and in most cases, the evaluations supported the conclusion. Causal analyses appropriately considered the extent of condition or problem, generic issues, and previous occurrences of the issue. However, the inspectors did observe one instance of an inadequate extent of condition review:

Core Spray System II Pump Discharge Check Valve Flange Inadequate Thread Engagement The inspectors identified an issue with the bolting of a core spray system booster pump discharge check valve. Exelon's procedure, 2400-GMM-3900.52, "Inspection and Torquing of Bolted Connections," states, in part, "minimum projection of a bolt through a nut shall be flush with a recommended projection of one or more threads." Previously, on April 11, 2011, Exelon identified that the core spray system I booster pump discharge check valve flange had two bolts which did not have adequate thread engagement because the two bolts were below flush with the nut (Issue Report 01201063).

Subsequently, Exelon completed an operability evaluation and determined that structural integrity was maintained with the two bolts recessed because the other 12 bolts had adequate thread engagement. During their extent of condition review, Exelon conducted walkdowns of other similar flanges within core spray system I and core spray system II.

Issue report 01201063 stated that the walkdowns did not identify any other bolts with inadequate thread engagement. However, during the August 15, 2012 walkdown, the inspectors identified that the core spray system II booster pump discharge check valve had a bolt that did not have adequate thread engagement. It was recessed approximately two threads below flush. The remaining bolts were verified to have adequate thread engagement. Exelon entered the issue into the CAP (Issue Report 01401476) and determined that structural integrity was maintained with the one bolt recessed because the other 13 bolts had adequate thread engagement.

The inspectors independently evaluated this issue for significance in accordance with IMC 0612, Appendix B, "Issue Screening," and IMC 0612, Appendix E, "Examples of Minor Issues." The inspectors determined that the failure to identify and correct the inadequate thread engagement of a bolt on the core spray system II booster pump discharge check valve flange was a performance deficiency. Although the core spray system II booster pump discharge check va lve flange bolt did not meet adequate thread engagement per Exelon procedure 2400-GMM-3900.52, Exelon determined structural integrity and operability was maintained by the other 13 bolts. As operability was maintained and this was not considered to be a programmatic concern, the inspectors determined this issue to be of minor significance, and, as a result, it is not subject to enforcement action in accordance with the NRC's Enforcement Policy. Exelon documented this issue in issue report 01401476.

7 Enclosure 3. Effectiveness of Corrective Actions The inspectors concluded that corrective actions for identified deficiencies were generally timely and adequately implemented. For significant conditions adverse to quality, Exelon identified actions to prevent recurrence. The inspectors concluded that corrective actions to address the sample of NRC NCVs and findings since the last problem identification and resolution inspection were generally timely and effective.

However, the inspectors did have some observations related to Exelon's corrective action implementation.

Issue Report Closure Documentation During review of closed issue reports, the inspectors identified that some reports did not include the appropriate documentation for closure. LS-AA-125 specifies that "closure documentation should stand alone and be clear enough to identify that the corrective action, as intended, was completed satisfactorily." The inspectors independently evaluated this issue for significance in accordance with IMC 0612, Appendix B, "Issue Screening," and IMC 0612, Appendix E, "Examples of Minor Issues." Although there was a procedural violation in three identified cases (Issue Reports 1029623, 1164296, 1105414), the licensee was able to provide other documentation to show that all of the intended actions had been completed. Thus, the inspectors determined this issue to be of minor significance, and, as a result, it is not subject to enforcement action in accordance with the NRC's Enforcement Policy. Exelon generated issue report 1401973 to document this deficiency.

c. Findings

Introduction.

The inspectors identified a Green NCV of 10 CFR 50 Appendix B, Criterion XVI, "Corrective Action," for Exelon's failure to promptly identify and correct a condition adverse to quality. Specifically, Exelon did not promptly identify and correct the impact of increased emergency diesel generator (EDG) loading on the committed three day fuel oil supply. Existing procedural guidance requires load management actions after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> which provides reasonable assurance of EDG operability. Exelon corrective actions include additional load management actions to ensure fuel oil capacity is maintained. This condition has been placed in the Exelon's corrective action program.

Description.

Oyster Creek has a 15,150 gallon EDG fuel oil storage tank which was designed to provide three days of fuel supply. Technical Specification 3.7.C.4.A requires that at least 14,000 gallons of fuel oil be available in the EDG fuel oil storage tank. This requirement supports the design basis in the Updated Final Safety Analysis Report (UFSAR), Section 9.5.4.1, which states, in part, the "Diesel Generator Fuel Storage Tank was sized to provide three days of fuel supply." Calculation C-1302-862-5360-002, evaluated the tank's capacity and the usable volume and specified 14,393.2 gallons of fuel oil be available to meet this commitment because 393.2 gallons is considered unusable volume. This calculation indicates that there will be sufficient fuel oil for three days of operation assuming a diesel loading of 2500 KW.

On November 12 and 24, 2010, Exelon conducted Loss of Offsite Power/Loss of Coolant Accident (LOOP/LOCA) testing of the #2 EDG and #1 EDG, respectively. The test results indicated certain electrical breakers did not trip as designed or that the breakers were not tested. As a result, Exelon completed a technical evaluation, 1145338, 8 Enclosure "Molded Case Circuit Breaker with Undervoltage Fitted Device Electrical Loading Evaluation," to document the impact of these loads on EDG loading. The inspectors identified Exelon's evaluation appropriately documented the impact on EDG loading, but did not identify the impact of increased loading on EDG fuel oil consumption. In response to the inspectors' observations, Exelon initiated issue report 1406825 and recalculated the EDG fuel oil consumption. This recalculation determined that 15,338 gallons of fuel oil would be needed to account for the operation of #2 EDG at the new elevated loading of 2735KW. As a result, the minimum fuel oil volume would only provide 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> operation instead of the required three day (72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />) supply. The EDGs remain operable because emergency procedures require load management actions after eight hours of operation.

This condition was not previously identified by Exelon. The inspectors determined that there were previous opportunities available for Exelon to identify and correct the impact of the increased EDG loading on fuel oil consumption from 2010 to 2012. Specifically, the referenced technical evaluation was reviewed and revised by engineers on four separate occasions (Issue Reports 1139345, 1140832, 1145338, and 1365452) during this time period. The effect of the increased loading on fuel oil consumption was not identified in any of these instances.

Exelon's corrective actions for this issue include developing a work group evaluation to determine the reason why the technical evaluation did not include the impact of increased loading on the EDG fuel oil consumption; revising plant procedures to ensure the effects of the additional EDG load are appropriately considered after eight hours of EDG operation; and developing lessons learned for this issue.

Analysis.

Exelon's failure to promptly identify and correct an inadequate technical evaluation that did not determine the impact of increased EDG loading on the existing three day fuel oil supply was a performance deficiency. Inspectors determined that the finding was more than minor because the performance deficiency was associated with the design control attribute of the Mitigating Systems Cornerstone and the associated cornerstone objective of ensuring the capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the technical evaluation stated that #2 EDG loading could be as much as 2735 KW which translates to approximately 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> of fuel capacity with the storage tank at minimum capacity versus the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The EDGs remain operable because they are capable of supplying accident loads with adequate load management actions after eight hours of operation.

The inspectors evaluated the finding using IMC 0609, Appendix A, "the Significance Determination Process for Findings for At-Power," and determined that it was of very low safety significance (Green). The finding is not a deficiency affecting the design or qualification of a mitigating structure, system or component (SSC) and the SSC maintains its operability.

The finding had a cross-cutting aspect in the area of problem identification and resolution, because Exelon did not thoroughly evaluate the problem such that the resolution addressed causes and extent of conditions, as necessary. Specifically, Exelon's technical evaluations 1145338 and 1365452 failed to evaluate the impact of increased loads on the amount of available EDG fuel oil. Therefore, at the increased loads of 2735 KW, the EDG's would have only had 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> of the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of fuel oil capacity. [P.1 (c)]

Enforcement.

10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, 9 Enclosure such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and non-conformances are promptly identified and corrected. Contrary to the above, on November 28, 2010, Exelon failed to adequately evaluate the impact of increased EDG loading on the three day fuel oil supply. As a result, the #2 EDG's fuel storage tank only had 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> of fuel capacity at the increased loads specified in the technical evaluation (2735KW). Since this finding was determined to be of very low safety significance (Green) and has been entered into Exelon corrective action program (Issue Report 1406825) it is being treated as an NCV, consistent with the Enforcement

Policy. (NCV 05000219/2012008-01, Failure to Adequately Evaluate the impact of Increased Emergency Diesel Generators Loading on the Volume of Available Fuel

Oil )

.2 Assessment of the Use of Operating Experience

a. Inspection Scope

The inspectors reviewed a sample of issue reports associated with review of industry operating experience to determine whether Exelon appropriately evaluated the operating

experience information for applicability to Oyster Creek and had taken appropriate actions, when warranted. The inspectors also reviewed evaluations of operating experience documents associated with a sample of NRC generic communications to ensure that Exelon adequately considered the underlying problems associated with the issues for resolution via their corrective action program. In addition, the inspectors observed various plant activities to determine if the station considered industry operating experience during the performance of routine and infrequently performed activities.

b. Assessment The inspectors determined that Exelon appropriately considered industry operating

experience information for applicability, and used the information for corrective and preventive actions to identify and prevent similar issues when appropriate. The inspectors determined that operating experience was appropriately applied and lessons learned were communicated and incorporated into plant operations and procedures when applicable. The inspectors also observed that industry operating experience was routinely discussed and considered during the conduct of Plan-of-the-Day meetings and pre-job briefs.

c. Findings

No findings were identified.

.3 Assessment of Self-Assessments and Audits

a. Inspection Scope

The inspectors reviewed a sample of audits, including the most recent audit of the corrective action program, departmental self-assessments, and assessments performed by independent organizations. Inspectors performed these reviews to determine if Exelon entered problems identified through these assessments into the corrective action program, when appropriate, and whether Exelon initiated corrective actions to address identified deficiencies. The inspectors evaluated the effectiveness of the audits and 10 Enclosure assessments by comparing audit and assessment results against self-revealing and NRC-identified observations made during the inspection.

b. Assessment The inspectors concluded that self-assessments, audits, and other internal Exelon assessments were generally critical, thorough, and effective in identifying issues. The inspectors observed that Exelon personnel knowledgeable in the subject completed these audits and self-assessments in a methodical manner. Exelon completed these audits and self-assessments to a sufficient depth to identify issues which were then entered into the corrective action program for evaluation. In general, the station implemented corrective actions associated with the identified issues commensurate with their safety significance.

c. Findings

No findings were identified.

.4 Assessment of Safety Conscious Work Environment

a. Inspection Scope

During interviews with station personnel, the inspectors assessed the safety conscious work environment at Oyster Creek. Specifically, the inspectors interviewed personnel to determine whether they were hesitant to raise safety concerns to their management and/or the NRC. The inspectors also interviewed the station Employee Concerns Program coordinator to determine what actions are implemented to ensure employees were aware of the program and its availability with regards to raising safety concerns.

The inspectors reviewed the Employee Concerns Program files to ensure that Exelon entered issues into the corrective action program when appropriate, and that concerns that impacted plant safety were adequately investigated.

b. Assessment During interviews, Oyster Creek staff expressed a willingness to use the corrective action program to identify plant issues and deficiencies and stated that they were willing to raise safety issues. The inspectors noted that no one interviewed stated that they personally experienced or were aware of a situation in which an individual had been retaliated against for raising a safety issue. All persons interviewed demonstrated an adequate knowledge of the corrective action program and the Employee Concerns Program. Based on these limited interviews, the inspectors concluded that there was no evidence of an unacceptable safety conscious work environment and no significant challenges to the free flow of information.

c. Findings

No findings were identified.

11 Enclosure

4OA6 Meetings, Including Exit

On August 31, 2012, the inspectors presented the inspection results to M. Massaro, Site Vice President, and other members of the Oyster Creek 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

Licensee Personnel

M. Massaro, Site Vice-President

R. Peak, Plant Manager

G. Malone, Director, Engineering

J. Barstow, Manager, Regulatory Assurance

W. Lopkoff, Manager, Training Support

G. Flesher, Shift Operations Superintendent

J. Correll, Operations Shift Supervisor

P. Olivieri, Supervisor, Operational Chemistry

J. Graveman, Supervisor, Mechanical Maintenance

H. Tritt, Supervisor, Electrical Design Engineering

M. Sullivan, Work Management Pre-Defined Coordinator

F. Meyer, Work Management Pre-Defined Coordinator

J. Fleury, Sr. Operations Training Instructor

J. Chrisley, Sr. Regulatory Specialist

D. Moore, Regulatory Specialist

M. Seeloff, Regulatory Specialist

C. Holtzapple, Reactor Engineer

K. Paez, Regulatory Specialist

M. Mura, Chemist

M. Basti, Engineering Analyst

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened and Closed

05000219/2012008-01 NCV Failure to Adequately Evaluate the impact of Increased Emergency Diesel Generators Loading

on the Volume of Available Fuel Oil

Attachment

Section 4OA2: Problem Identification and Resolution

Audits and Self-Assessments

LS-AA-126-1005,

OC 2012 Qualifications Check-In Assessment, February 16, 2012

LS-AA-126-1005, M&T Departments Qualificat ion Verification, September 9. 2011

1182407, Emergency Preparedness Audit Report, April 27, 2011.

1212559, In Storage Maintenance Program

1235178, Engineering Design Control Audit Report, September 21, 2011

279521, Clearance & Tagging Check-In Assessment

1315558, Chemical Control Check

1315598, KT&R Radiological Engineering

1315602, JITT - CI (Station Selected) (Ops/M&TT)

1315601, OJT/TPE FASA (Station Selected) (Ops/M&TT)

1341751, Engineering Programs and Station Blackout Audit Report, May 2, 2012

1344283, Emergency Preparedness Audit Report, May 2, 2012

Issue reports

(* indicates that condition report was generated as a result of this inspection)

683987

1045825

1085315

1125834

1160774

688610

1047802

1085542

1130724

1163877

688613

1051127

1085866

1130859

1164296

739881

1051786

1086887

1131227

1166198

751681

1053577

1088269

1133436

1166315

845515

1053820

1088325

1134008

1166475

948779

1054877

1089124

1134238

1170026

955503

1056720

1092319

1134331

1172382

964740

1057368

1093272

1134729

1173959

1011285

1059263

1095258

1136793

1181133

1011287

1059398

1095685

1136887

1181834

1012042

1062800

1097180

1137357

1182369

1012511

1065678

1097579

1139345

1183261

1012554

1067367

1098064

1139393

1184339

1014226

1067437

1101332

1140086

1187591

1017212

1068606

1101718

1140109

1188679

1018631

1071480

1102251

1144569

1188695

1019733

1072608

1105219

1145140

1189144

1022215

1072730

1105225

1145155

1194023

1023265

1073539

1105414

1145343

1197321

1025003

1077866

1105417

1146145

1197586

1025131

1078841

1106187

1147583

1201117

1025765

1080349

1106206

1149067

1203140

1026410

1081571

1109244

1150432

1205823

1029623

1081724

1111911

1150622

1210400

1029644

1082800

1117537

1151350

1211042

1037616

1085156

1123363

1152003

1212659

Attachment

1044622

1085267

1125247

1155520

1219542

1221224

1277464

1331134

1367285

1383888

1223661

1282463

1331696

1367294

1384447

1224333

1286245

1333192

1367667

1388381

1225305

1290133

1334230

1368052

1389116

1226021

1290865

1334251

1368876

1389713

1226484

1292381

1336082

1371366

1395653

1241090

1293873

1337486

1372109

1397147

1241738

1295834

1338421

1372834

1397329

1242808

1308834

1341796

1373302

1397331

1242816

1308916

1342833

1375107

1397342

1245293

1313742

1344710

1375960

1397986

1248493

1314808

1344714

1377283

1399768

1249322

1316459

1348904

1377490

1400244

1251308

1318874

1352346

1378159

1400301

1256585

1318924

1352558

1379667

1405731

1258912

1319033

1352980

1379844

1406837

1259123

1323291

1355138

1380349

1401111*

1259656

1323387

1357414

1380403

1401408*

1262828

1326042

1358319

1382377

1401455*

1263568

1326186

1359010

1382717

1401476*

1270558

1326635

1359612

1383268

1401973*

1274119

1326654

1361943

1383318

1405877*

1274974

1326993

1362255

1383388

1406822*

1275859

1328090

1365699

1383510

1406825*

1276686

1328199

1367272

1383604

Operating Experience

1054877, Browns Ferry OE: RBCCW Red Brass Piping Failure in Drywell

1056720, Electrical Fire, Scram, SI, and Alert Notification

1065678, Dual Unit Scram with Equipment Complications (Calvert Cliffs Event)

1071480, Containment Isolation Valve Backseat Gasket Failure (Flowserve Model 1878

Globe Valve)

1078841, ISI/IST Requirements of Dynamic Restraints (Snubbers)

1089124, Scram, SI, Fires, Equipment Damage and Alert

1109244, 4kv Breaker Failure Due to Improper Lubrication

1130859, Standby Liquid Control System Dilution Flow

1172382,

1182369,

1221224, Operator Performance Issues Involving Reactivity Management at Nuclear Power Plants

1201117, NRC Concerns on Parameters Used to Maintain Reactor Power (Palisades),

1314808, Technical Specification Interpretation and Operability Determination,

28199, Inappropriate Temporary Connection of Non-Seismic Systems/Components to Seismically Qualified Systems

1355138, Engineering Evaluation Needed for RF Bridge Shielding

Attachment

NCVs and Findings

05000219/2010007-01, Inadequate Corrective Actions Associated With the Reactor Building to

Torus Vacuum Breaker Trip Valve Failures05000219/2010008-01, Scaffold Installation Procedure Not Properly Implemented

05000219/2010008-02, EDG Low Voltage Control Cable Submergence

05000219/2010008-03, 1A2 and 1B2 480 V Load Center Transformer Cooling Fan Testing

05000219/2010008-04, Failure to identify catch containment drain tube interfered with drain function in RB corner room

05000219/2011002-04, No procedure existed for loss of annunciators causing a delay in implementation of compensatory actions05000219/2011007-01, B' 480 Volt Switchgear room

05000219/2010005-02, Failure to Conduct Representative Sampling of Stack Effluents

05000219/2010007-02, Failure to Follow Preventive Maintenance Procedure Leading to

Incomplete Fire Diesel Maintenance 05000219/2011001-03, Failure to Implement Procedures Resulting in Reactor Scram

05000219/2011003-01, Failure to Perform Acceptance Inspection of Contractor Work Results in Damage to Safety Related Instrument Cable

Procedures

201, Plant Startup, Revision 79

203, Plant Shutdown, Revision 64

2400-GMM-3900.52, Inspection and Torquing of Bolted Connections, Revision 7

2.2, Control Rod Drive Manual Control System, Revision 50 341, Emergency Diesel Generator Operation, Revision 96 681.4.004, Technical Specification Log Sheet, Revision 24 and 25

636.4.013, Diesel Generator #2 Load Test, Revision 32

636.4.003, Diesel Generator #1 Load Test, Revision 91

ABN-36, Loss of Off-Site Power, Revision 13

EI-AA-1, Safety Conscious Work Environment Policy Statement, Revision 3

EI-AA-101, Employee Concerns Program, Revision 10

EI-AA-101-1001, Employee Concerns Program Process, Revision 11

EI-AA-101-1002, Employee Issues Trending, Revision 7

EI-AA-102, Differing Professional Opinion, Revision 0

ER-AA-310-1004, Functional Failure Cause Determination Evaluation, Rev. 6

LS-AA-1012, Safety Culture Monitoring, Revision 0

LS-AA-115, Operating Experience Program, Revision 15

LS-AA-115-1001, Processing of Level 1 OPEX Evaluations, Revision 5

LS-AA-115-1002, Processing of Level 2 OPEX Evaluations, Revision 3

LS-AA-115-1003, Processing of Level 3 OPEX Evaluations, Revision 2

LS-AA-115-1004, Processing of NERs, NNOEs, and Root Cause Report Transmittals, Rev. 2

NNOMA-AA-716-234, FIN Team Process, Revision 7

LS-AA-120, Issue Identification and Screening Process, Revision 14

LS-AA-125, Corrective Action Program, Revision 14

OP-AA-108-115-1002, Supplemental Consideration for On-Shift Immediate Operability Determinations, Revision 2

OP-AB-300-1001, BWR Control Rod Movement Requirements, Revision 63

WC-AA-101-1002, On Line Scheduling Process, Revision 11

Attachment

Work Orders

A2172983 A2269369 A2302858 A2303905

C2021264

C2024970

C2026796 M2256254 R2017873 R2107272 R2133195 R2153559

R2159219 R2163946

Miscellaneous

Calculation

C-1302-862-5360-002, EDG Fuel Oil Consumption Calculation eSOMS Control

OC-2010-OE-0005, Emergency Diesel Generators (Issue Report 01093272), November 14, 2010

Room Logs 5/31/12-6/1/12, 8/1/12-8/26/12

Technical Evaluation

1139345-02, EDG Loading Calculation

SDD-OC-732-A, 480 V Unit Substation 1A2 & 1B2 Transformer Cooling Fans, Rev. 1

System Health Report for EDGs, 2008-2012

Calculation

C-1302-862-5360-002, Diesel Generator Fuel Requirements, Usable Tank Volume and Pump NPSH, Revision 5

LIST OF ACRONYMS

ADAMS Agency-wide Documents Access and Management System

CAP Corrective Actions Program

CFR Code of Federal Regulations

EDG Emergency Diesel Generator

IMC Inspection Manual Chapter

LLC Liability Limited Corporation

NCV Non-Cited Violation

NRC Nuclear Regulatory Commission

PARS Publicly Available Records System

PCM Performance Centered Maintenance

RF Refueling

SDP Significance Determination Process

TS Technical Specifications