IR 05000219/2015003

IR 05000219/2015003, July 1, 2015 September 30, 2015, Integrated Inspection Report; Oyster Creek Nuclear Generating Station

ML15306A416
Person / Time
Site:	Oyster Creek, 05000021
Issue date:	11/02/2015
From:	Kennedy S R NRC/RGN-I/DRP/PB6
To:	Bryan Hanson Exelon Nuclear
KENNEDY, SR
References
IR 2015003
Download: ML15306A416 (27)

Text

November 2, 2015

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION - INTEGRATED INSPECTION REPORT 05000219/2015003

Dear Mr. Hanson:

On September 30, 2015, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Nuclear Generating Station. The enclosed report documents the inspection results, which were discussed on October 15, 2015, with Mr. G. Stathes, Site Vice President, and other members of your staff. NRC inspectors examined activities conducted under your license as they relate to safety and compThe inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. The inspectors documented one finding of very low safety significance (Green) in this report. This finding involved a violation of an NRC requirement. The NRC is treating this violation as non-cited violation (NCV) consistent with Section 2.3.2.a of the 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 U.S. 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 accordance with Title 10 of the Code of Federal Regulations Pand 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/ Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket No. 50-21 License No. DPR-16 Enclosure: Inspection Report 05000219/2015003 w/Attachment: Supplementary Information cc w/encl: Distribution via ListServ

ML15306A416 SUNSI Review Non-Sensitive Sensitive Publicly Available Non-Publicly Available OFFICE RI/DRP RI/DRP RI/DRP NAME APatel/ via email SShaffer/ SWS SKennedy/ SRK DATE 10/ 28 /15 10/28 /15 10/ 29 /15 1 Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION I Docket No: 50-219 License No: DPR-16 Report No: 05000219/2015003 Licensee: Exelon Nuclear Facility: Oyster Creek Nuclear Generating Station Location: Forked River, New Jersey Dates: July 1, 2015 September 30, 2015 Inspectors: A. Patel, Senior Resident Inspector E. Andrews, Resident Inspector B. Lin, Acting Resident Inspector B. Dionne, Health Physicist Approved By: Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects 2

SUMMARY

IR 05000219/2015003; 07/01/2015 09/30/2015; 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 baseline inspections performed by regional inspectors. The Inspectors identified one non-cited violation (NCV) of very low safety significance (Green). The significance of most findings is indicated by their color (i.e., greater than Green, or Green, White, Yellow, Red) and determined using dated April 29, 2015. Cross-cutting aspects are Aspects Within Cross-Cutting Areas dated December 4, 2014. All violations of Nuclear Regulatory Commission (NRC) requirements are dispositioned in accordance with the NRC Enforcement Policy, dated February 4, 2015. power reactors is described in NUREG-5.

Cornerstone: Mitigating Systems

Green.

The inspectors identified an NCV of 10 Code of Federal Regulations (CFR) 50, adequacy of design of the electromatic relief valve (EMRV) voltage drop calculation were inadequate. Specifically, non-conservative temperature inputs were used for the safety related EMRV direct current voltage drop calculation, which reduced the margin of available voltage to the EMRV solenoids. Exelon entered this issue into the corrective action program for resolution as issue report 2522756, and corrective actions included revising the calculation to include the correct temperature values and conduct an extent of condition of other voltage drop calculations that could have similar temperature values. The performance deficiency is more than minor because it is associated with the design 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, lower voltage to the EMRV solenoid at higher temperatures could affect the reliability and capability of the EMRV to perform its design function. In addition, the performance deficiency is determined to be more than minor because it is similar to example 3.j of NRC IMC 0612, Appendix E, Example of Minor Issues, in that as a result of the calculation errors and the magnitude of the decrease of margin, there was a reasonable doubt on the operability of the component. inspectors determined that this finding is a deficiency that affected 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 is not assigned a cross-cutting aspect because it is not reflective of current performance. Specifically, the last time Exelon had an opportunity to evaluate this issue was in 2010 when Exelon identified that the EMRV solenoid voltage had low margin. (Section 1R15)

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REPORT DETAILS

Summary of Plant Status Oyster Creek began the inspection period at 100 percent power. Oyster Creek reduced power periodically from July 17, 2015 to August 18, 2015, to comply with New Jersey Department of Environmental Protection thermal discharge permit limitations and to maintain drywell temperature below the required temperature. On September 18, operators reduced power to 70% to perform a planned rod pattern adjustment. Operators returned the unit to 100 percent power on September 19, and remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

===.1 External Flooding

a. Inspection Scope

During the week of September 15, 2015, the inspectors performed an inspection of the external flood protection measures for Oyster Creek Nuclear Generating Station. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Chapter 2.4.2, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of the emergency diesel generator building to ensure that Exelon erected flood protection measures in accordance with design specifications. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if Exelon planned or established adequate measures to protect against external flooding events. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

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a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Containment spray system II while containment spray system I was out of service on July 6, 2015 Containment spray system I while containment spray system II was out of service on July 16, 2015 Emergency diesel generator No. 1 and standby gas treatment system I while standby gas treatment system II was out of service on July 28, 2015 Emergency service water system II while emergency service water system I was out of service on September 14, 2015 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findings

No findings were identified.

.2 Full System Walkdown

a. Inspection Scope

On September 1 and 2, 2015, the inspectors performed a complete system walkdown of accessible portions of the fire protection water system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.

b. Findings

No findings were identified.

1R05 Fire Protection

.1 Resident Inspector Quarterly Walkdowns

a. Inspection Scope

The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.

Intake structure on July 21, 2015 No. 1 emergency diesel generator room on July 21, 2015 No. 2 emergency diesel generator room on July 28, 2015 4160 volt switchgear room on July 28, 2015 Reactor building control rod drive pump room on July 29, 2015 Fire pump house on September 1, 2015

b. Findings

No findings were identified.

.2 Fire Protection Drill Observation

a. Inspection Scope

The inspectors observed a fire brigade drill scenario conducted on August 4, 2015, that involved a fire in the second floor of the site emergency building. The inspectors evaluated the readiness of the plant fire brigade to fight fires. The inspectors verified that Exelon personnel identified deficiencies, openly discussed them in a self-critical manner at the debrief, and took appropriate corrective actions as required. The inspectors evaluated specific attributes as follows: Proper wearing of turnout gear and self-contained breathing apparatus Proper use and layout of fire hoses Employment of appropriate fire-fighting techniques Sufficient fire-fighting equipment brought to the scene Effectiveness of command and control Search for victims and propagation of the fire into other plant areas Smoke removal operations Utilization of pre-planned strategies Adherence to the pre-planned drill scenario Drill objectives met The inspectors also evaluated the fire brigade actions to determine whether these actions were in accordance with fire-fighting strategies.

b. Findings

No findings were identified.

1R11 Licensed Operator Requalification Program

.1 Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on September 8, 2015, which included loss of service water, a recirculation pump trip and an isolation condenser steam leak. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, 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.

1R12 Maintenance Effectiveness

a. Inspection Scope

The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system or 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.

1C 4.16 Kilovolt (kV) protective bus relays on August 4, 2015 EMRV pressure switches on August 14, 2015

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 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.

Containment spray system I and emergency service water system I out of service for planned maintenance on July 6, 2015 Containment spray system II and emergency service water system II out of service for emergent maintenance on July 16, 2015 Core spray system II out of service for planned maintenance on August 9, 2015 Planned maintenance on the hardened vent accumulator check valves on August 17, 2015 Emergency service water system I out of service for corrective maintenance on September 15, 2015

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: EMRVs inadequate temperature values in the EMRV voltage drop calculation on July 1, 2015 No. 1 seal degradation on July 24, 2015 startup transformer degraded cooling on August 2, 2015 1C 4.16kV protective bus relays missed surveillance on August 4, 2015 ore spray pump operability evaluation due to elevated motor vibration on August 6, 2015 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 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 an NCV of 10 CFR 50, Appendix B, Criterion III, of the EMRV voltage drop calculation was inadequate. Specifically, non-conservative temperature inputs were used for the safety related EMRV DC voltage drop calculation, which reduced the margin of available voltage to the EMRV solenoids.

Description.

The Oyster Creek EMRVs are six-inch electrically actuated pressure relief valves manufactured by Dresser Industries. There are five EMRVs on the main steam lines between the reactor pressure vessel and the main steam line isolation valves within the drywell. The EMRVs consist of a main valve assembly, pilot valve assembly, and a solenoid actuator. When energized, the solenoid actuates a plunger, which pushes down the pilot valve operating lever, thereby opening the pilot valve. When the pilot valve opens, pressure under the main valve disc is vented, resulting in an unbalanced steam pressure across the main disc and moving the main disc downward from its seat, opening the main valve. The function of the EMRVs is to depressurize the reactor during a small break loss-of-coolant accident (SBLOCA) to permit the low pressure core spray system to inject water into the reactor core. EMRVs are also available during a loss of offsite power (LOOP) because the solenoid receives power via the 125 volts direct current (VDC) system. The cables from the 125 VDC to the solenoid is routed through various temperature environments which affect the voltage available to the solenoid. Increase in temperature increases conductor resistance, which in turn, C-1302-735-E320-038, Voltage Drop after Modification to 125 VDC igh Pressure Relief Functions, specifies that a minimum voltage of 80 VDC is required in an accident environment to ensure proper operation of the EMRV solenoids.

During a review of the EMRV voltage drop calculation, the inspectors identified that Exelon used non-conservative temperature values to calculate the voltage drop for a portion of cables in the drywell for four scenarios. The four scenarios of concern are listed as follows: 1. SBLOCA/LOOP with a failure of DC bus D while on the DC battery (scenario 1) 2. SBLOCA/LOOP with a failure of DC bus F while on the DC battery (scenario 2) 3. SBLOCA/LOOP with a failure of DC bus D while on the battery charger (scenario 3) 4. SBLOCA/LOOP with a failure of DC bus F while on the battery charger (scenario 4)

The calculation references temperatures in the drywell could be as high as 138 degrees Celsius. The inspectors identified that the calculation used 65 degrees Celsius instead of 138 degrees Celsius for cables in the drywell therefore non-conservative temperature values were used for the cables for the four different accident scenarios. Specifically, the calculation of record for the available voltages were 80.3 VDC (scenario 1), 81.6 VDC (scenario 2), 94.6 VDC (scenario 3), and 96.7 VDC (scenario 4). As a result of the non-conservative temperatures and the resulted minimal margin (i.e., 80.3 VDC and 81.6 VDC to the required 80 VDC), the inspectors had a reasonable doubt of operability.

Exelon entered the issue into their corrective action program, issue report 2522756, and Exelon recalculated the available voltage which resulted in a decrease of voltage for scenario 1 from 80.3 VDC to 80.1 VDC, scenario 2 from 81.6 VDC to 80.3 VDC, scenario 3 from 94.6 VDC to 93.6 VDC, and scenario 4 from 96.7 VDC to 96.6 VDC.

As a result, for the most limiting scenarios (scenario 1 and 2), the available margin corrective actions include revising the calculation to include the correct temperature values and conduct an extent of condition of other voltage drop calculations that could be affected.

Analysis.

The inspectors determined that non-conservative temperature values for certain cables in the EMRV voltage drop calculation ility to foresee and correct. he performance deficiency is more than minor because it is associated with the design 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, lower voltage to the EMRV solenoid at higher temperatures could affect the reliability and capability of the EMRV to perform its design function. In addition, the performance deficiency is determined to be more than minor because it is similar to example 3.j of NRC IMC 0612, Appendix E, Example of Minor Issues, in that as a result of the calculation errors and the magnitude of the decrease of margin, there was a reasonable doubt on the operability of the component.

inspectors determined that this finding is a deficiency that affected 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).

This finding is not assigned a cross-cutting aspect because the most significant contributor of the finding is the inadequate temperature input into the EMRV voltage drop calculation, which is not reflective of current performance. The last time Exelon had the opportunity to evaluate this issue was in 2010 when Exelon identified that the available EMRV solenoid voltage had low margin (issue report 1128510).

Enforcement.

measures shall be established to provide for verifying the adequacy of design. Contrary adequacy of the design regarding adequate DC voltage to the safety related EMRVs for certain scenarios. Specifically, non-conservative design temperature inputs were used for the EMRV voltage drop calculation.

the calculation to reflect the correct temperature values and conduct an extent of condition of other voltage drop calculations. Because this violation is of very low safety significance (Green) and has been issue report 2522756, this violation is being treated as an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. (NCV 05000219/2015003-01, Non-Conservative Temperature Input in the Electromatic Relief Valve Voltage Drop Calculation)

1R18 Plant Modifications

.1 Permanent Modifications

a. Inspection Scope

The inspectors evaluated a modification to the emergency service water piping by engineering change package 15-piping component 1-4 and 1-The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including replacement of the emergency service water discharge piping segments, 1-3 and 1-4. The inspectors also reviewed revisions to the calculations and interviewed engineering and operations personnel to ensure the modification did not affect the design of the emergency service water system.

b. Findings

No findings were identified.

1R19 Post-Maintenance Testing

a. Inspection Scope

The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.

Containment spray system II emergency service water emergent maintenance on July 17, 2015 tandby liquid control pump planned maintenance on August 11, 2015 Emergency diesel generator No. 2 immersion heater relay replacement on August 17, 2015 system temperature thermostat repair on August 25, 2015 Diesel driven fire pump No. 2 solenoid coil replacement on August 29, 2015 Diesel driven fire pump No. 1 pump replacement on August 31, 2015 Emergency service water system I discharge piping replacement on September 16, 2015 on September 21, 2015

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: Containment spray and emergency service water system I pump operability test on July 6, 2015 (in-service test) Containment spray and emergency service water system II pump operability test on August 2, 2015 1C 4.16kV protective bus relay test on August 4, 2015 Hardened vent accumulator check valve leakage testing on August 17, 2015 Main steam isolation valve (NS03B) 10 percent closure test on September 8, 2015 (containment isolation valve test)

b. Findings

No findings were identified. Cornerstone: Emergency Preparedness

1EP6 Drill Evaluation

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Exelon emergency drill on September 29, 2015, to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures. The inspectors also attended the station drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate critique and to verify whether the Exelon staff was properly identifying weaknesses and entering them into the corrective action program.

b. Findings

No findings were identified.

RADIATION SAFETY

===Cornerstone: Public Radiation Safety

2RS7 Radiological Environmental Monitoring Program (REMP)

a. Inspection Scope

The inspectors reviewed the REMP to validate the effectiveness of the radioactive gaseous and liquid effluent release program. The inspectors used the requirements in 10 CFR 20, 40 CFR 190, 10 CFR 50 Appendix I, technical specifications, Offsite Dose Calculation Manual (ODCM), and procedures required by technical specifications as criteria for determining compliance.

Inspection Planning

The inspectors reviewed: 2013 and 2014 Annual Radiological Environmental Operating Reports, REMP program audits, ODCM changes, land use census, and inter-laboratory comparison program results.===

Onsite Inspection The inspectors reviewed and/or observed the following items: Sample collection, monitoring, and dose measurement stations namely, thermoluminescent dosimeters and air monitoring stations Calibration and maintenance records for air sample and dosimetry measurement equipment Environmental sampling of the effluent release pathways specified in the ODCM including surface water, groundwater, drinking water and vegetation Meteorological tower and meteorological data readouts Meteorological instrument operability status and calibration results Missed and anomalous environmental samples identified, resolved, and reported in the annual radioactive environmental monitoring report Positive environmental sample assessment results The groundwater monitoring program as it applies to potential leaking SSCs and early leak detection 10 CFR 50.75(g) records of leaks, spills, and remediation since the previous inspection Changes to the ODCM due to changes to the land use census, long-term meteorological conditions, and modifications to the environmental sample stations Environmental sample laboratory analysis results and measurement detection sensitivities Results of the laboratory quality control program audit, and the inter-and intra-laboratory comparison program results.

Identification and Resolution of Problems The inspectors evaluated whether problems associated with the REMP were identified at an appropriate threshold and properly addressed for resolution in Exeloncorrective action program.

b. Findings

No findings were identified.

4OA1 Performance Indicator Verification

===.1 Reactor Coolant System Specific Activity and Reactor Coolant System Leak Rate (2 samples)

a. Inspection Scope

activity and reactor coolant system leak rate performance indicators for the unit for the period of April 1, 2014 through June 30, 2015. 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-Assessment Performance Indicator GuidelineRevision 7. The inspectors also reviewed reactor coolant system sample analysis and control room logs of daily measurements of reactor coolant system leakage, and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the reactor coolant system identified leakage rate, and chemistry personnel taking and analyzing a reactor coolant system sample. b. Inspection Findings No findings were identified.

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.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

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. The inspectors also confirmed, on a sampling basis, that, as applicable, for identified defects and non-conformances, Exelon performed an evaluation in accordance with 10 CFR Part 21.

b. Findings

No findings were identified.

4OA3 Follow-Up of Events and Notices of Enforcement Discretion

.1 (Closed) Exelon Licensee Event Report (LER) 05000219/2014-005-01:

Secondary Containment Declared Inoperable On September 19, 2014, during refueling outage 1R25 with the unit in cold shutdown, a technician discovered that a previously authorized and installed temporary modification had been removed from a penetration in the outboard main steam isolation valve room (trunnion room). The purpose of the temporary modification is to isolate the penetration from the reactor building to the trunnion room to allow the reactor building trunnion room door to be maintained open during refueling outages. Per Technical Specifications 3.5.B and 4.5.G, in order to maintain secondary containment integrity with the trunnion room door open, four penetrations connecting the trunnion room to the reactor building must be sealed. The trunnion room door was open when the plug was found removed from a six inch equipment drain hub. The plug was immediately reinstalled, restoring the safety function of the secondary containment. Exelon performed an engineering analysis, which determined that the secondary containment system was capable of performing its safety function with the plug removed.

The apparent cause of the event was determined to be an inadequate signage on the trunnion room door, with a contributing cause that the individual who removed the temporary modification to use the equipment drain hub did not understand the importance of the temporary modification. Exelon has revised the temporary modification to require signage not only on the trunnion room door, but to all the plugs installed as part of the temporary modification.

This LER was revised to include information on the post maintenance test for the temporary modification which revealed that the standby gas treatment system did not achieve the required minimum differential pressure of 1/4 inch of water vacuum on the reactor building. Exelon determined the cause of not achieving the required minimum differential pressure was an improperly latched personnel access hatch on the outer reactor building airlock door. The inspectors reviewed this issue in NRC inspection report 05000219/2015001, (Section 1R19, 4OA3, and 4OA7) and identified two findings. The inspectors did not identify any violations or new issues during the review of Revision 1 of the LER. This LER is closed.

4OA6 Meetings, Including Exit

On October 15, 2015, the inspectors presented the inspection results to Mr. G. Stathes, 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

Exelon Personnel

G. Stathes, Site Vice-President

J. Dostal, Plant Manager

J. Bills, Chemistry Supervisor

P. Bloss, Senior Manager, Plant Engineering

D. Cap, NOS Engineer

T. Cappuccino, Senior Regulatory Assurance Engineer

M. Carter, Security Manager

D. Chernesky, Director, Maintenance

D. DiCello, Director, Work Management

R. Dutes, Regulatory Assurance Engineer

T. Farenga, Radiation Protection Manager

M. Ford, Director, Operations

J. Freeman, Outage Manager

T. Keenan, Manager, Site Security

D. Greiner, NOS Engineer

M. McKenna, Manager, Regulatory Assurance

M. Nixon, Chemistry Specialist

H. Ray, Senior Manager, Design Engineering

J. Renda, Manager, Environmental/Chemistry

J. Stanley, Director, Engineering

E. Swain, Shift Operations Superintendent

C. Symonds, Director, Training

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000219/2015003-01 NCV Non-Conservative Temperature Input in the Electromatic Relief Valve Voltage Drop Calculation (Section 1R15)

Closed

05000219/LER-2014-005-01 LER Secondary Containment Declared Inoperable (Section 4OA3)

Section 1R01: Adverse Weather Protection

Procedures

341, Emergency Diesel Generator Operation, Revision 109

ABN-32, Abnormal Intake Level, Revision 25

Section 1R04: Equipment Alignment

Procedures

310, Containment Spray System Operation, Revision 111 101.2, Oyster Creek Site Fire Protection Program, Revision 73 333, Plant Fire Protection System, Revision 122 SP 5, Fire Water Injection for RPV Water Level Control, Revision 1

SP 61, Fire Water for RPV Flooding, Revision 1

Drawings

GE 148F740, Containment Spray System Flow Diagram, Revision 44

BR 2005, Emergency Service Water System, Revision 86

GE 885D781, Core Spray Flow Diagram, Revision 71 JC19479, Fire Protection Water System, Revision 65

Section 1R05: Fire Protection

Procedures

OP-OC-201-008, Oyster Creek Pre-Fire Plans, Revision 18

OP-OC-201-012-1001, On-Line Fire Risk Management, Revision 3

OP-AA-201-012-1001, Operations On-Line Fire Risk Management, Revision 1

OP-AA-108-117, Protected Equipment Program, Revision 4

WC-AA-101-1006, On-Line Risk Management and Assessment, Revision 1

ER-AA-600-1069, High Risk Fire Area Identification, Revision 1

ER-AA-600-1069, Oyster Creek Site list of High Risk Fire Areas, Revision 0

OP-OC-201-008-1034, Intake Structure, Revision 1

OP-OC-201-008-1038, Fire Water House (Pond Area), Revision 1

OP-OC-201-008-1035, Emergency Diesel Generator Room #1, Revision 2

OP-OC-201-008-1036, Emergency Diesel Generator Room #2, Revision 2

OP-OC-201-008-

OP-OC-201-008-1010, Reactor Building (-

OP-OC-201-008-1043, Site Emergency Building, Revision 0

Miscellaneous

Fire Drill Record, dated August 4, 2015

Section 1R11: Licensed Operator Requalification Program

Condition Reports

2551726 2551924

Section 1R12: Maintenance Effectiveness

Procedures

OP-AA-108-115, Operability Determination, Revision 16

CC-AA-309-101, Engineering Technical Evaluation, Revision 14

ER-AA-310, Implementation of the Maintenance Rule, Revision 9

ER-AA-310-1001, Maintenance Rule

Scoping, Revision 4

ER-AA-310-1003, Maintenance Rule

Performance Criteria Selection, Revision 4

ER-AA-310-1004, Maintenance Rule

Performance Monitoring, Revision 13

ER-AA-600-1012, Risk Management Documentation, Revision 12

ER-AA-600-1045, Risk Assessments of Missed or Deficient Surveillances, Revision 7

ABN-2, Recirculation System Failures, Revision 24 635.2.001, 4160 Switchgear Buses (A, B, C, D) and Circulating Water Pump Protective Relay

Surveillance, Revision 69

Condition Reports

2531793

2532095

2534463

2535167

2537535

Maintenance Orders/Work Orders A2384384 A2283092 A2273674 R2217699 R2217746

A2325745 A2325826 A2142392

Vendor/Technical Manuals

VM-OC-0025, Barksdale Pressure Switches, Revision 5

Miscellaneous

OC-SURV-03, Risk Analysis for Missed Surveillance, Failure to Perform Calibration of Loss of

Voltage/Degraded Voltage Instrumentation for 1C Bus, dated August 4, 2015, Revision 0

Calculations

C-1302-731-E320-017, OCNGS: 4160V Under Voltage (Degraded) Relay Setpoint Uncertainty,

Revision 1

C-1302-731-E320-009, OCNGS: 4.16KV Bus C7D Undervoltage Relay 27-11TD, 12TD, 13TD

Stability Calculation, Revision 2

Section 1R13: Maintenance Risk Assessments and Emergent Work Control

Procedures

WC-AA-101, Online Work Control Process, Revision 24

WC-AA-101-1001, Online Risk Management and Assessment, Revision 18

ER-AA-600-1042, Online Risk Management, Revision 9

OP-AA-108-117, Protected Equipment Program, Revision 4 310, Containment Spray System, Revision 111 610.4.003, Core Spray System 2 Valve Operating and Inservice Test, Revision 44

Condition Reports

2450524

2451796

1573470

1620802

2514042

Maintenance Orders/Work Orders R2228514 R2183985 A0703679

Miscellaneous

BR 2005 Sheet 4, Emergency Service Water System Flow Diagram, Revision 86

Section 1R15: Operability Determinations and Functionality Assessments

Procedures

ABN-2, Recirculation System Failures, Revision 24

ER-AA-600-1045, Risk Assessments of Missed or Deficient Surveillances, Revision 7

ER-AA-600-1012, Risk Management Documentation, Revision 12 635.2.001, 4160 Switchgear Buses (A, B, C, D) and Circulating Water Pump Protective Relay

Surveillance, Revision 69

Condition Reports

2531793

2532095

1314970

959034

2532305

1310171

2537535

2536453

Maintenance Orders/Work Orders A2384384 A2283092 A2273674

C2034861

Miscellaneous

Technical Evaluation for Environmental Qualification Extension of Pressure Switches, dated

August 14, 2015 Prompt Investigation 1C 4160V BUS Protective Relay Surveillances Missed, dated August 4, 2015

OC-2012-OE-0001, Operability Evaluation for Core Spray System Pump Motor, Revision 0

OC-SURV-03, Risk Analysis for Missed Surveillance, Failure to Perform Calibration of Loss of

Voltage/Degraded Voltage Instrumentation for 1C Bus, dated August 4, 2015, Revision 0

OC-2015-OE-0001, Operability Evaluation Failed Cooling on Startup Transformer SA, Revision 0

Calculations

C-1302-731-E320-017, OCNGS: 4160V Under Voltage (Degraded) Relay Setpoint Uncertainty,

Revision 1

C-1302-731-E320-009, OCNGS: 4.16KV Bus C7D Undervoltage Relay 27-11TD, 12TD, 13TD

Stability Calculation, Revision 2

C-1302-741-5350-001, OCNG: Loading of Emergency Diesel Generators, Unit Substations, and

4.16 kV Buses 1A & 1B

Licensing and Design Basis Documentation Oyster Creek Updated Final Safety Analysis Report, Revision 18

Section 1R18: Plant Modifications

Procedures

LS-AA-104-1000, 50.59 Resource Manual, Revision 9

LS-AA-104, Exelon 50.59 Review Process, Revision 10

LS-AA-104-1003, 50.59 Screening Form, Revision 4

Calculations

C-1302-532-E540-047, OC NSR Pipe Analysis Emergency Service Water Pump Outlets to Yard, Revision 01G

Condition Reports

1445987

1490523

Drawings

BR 2120, Composite Piping Plans and Sections Intake Structure, Revision 10 GU 3B-532-24-001, Emergency Service Water (ESW) Pipe Support Location, Revision 1

Maintenance Orders/Work Orders

C2033516 A2318853 A2210238

Miscellaneous

ECR

OC 15-00087-001, Replacement of ESW Piping Component ESW 1-4 and ESW 1-3, Revision 1

Section 1R19: Post-Maintenance Testing

Procedures

OP-AA-106-101, Significant Event Reporting, Revision 17

MA-AA-716-012, Post Maintenance Testing, Revision 20

WC-AA-101, On-Line Work Control Process, Revision 24

MA-AA-716-011, Work Execution & Close Out, Revision 19 310, Containment Spray System Operation, Revision 110 331.1, Control Room and Old Cable Spreading Room Heating, Ventilation and Air Conditioning System, Revision 40 101.2, Oyster Creek Site Fire Protection Program, Revision 73 645.4.036, Fire Pump #2 Operability Test, Revision 26 645.4.012, Fire Pump Functional Test, Revision 13 636.4.013, Diesel Generator #2 Load Test, Revision 45

RAP-T6F, EDG 2 Eng Temp High, Revision 0 606.4.016, Containment Spray and Emergency Service Water System 1 Pump Operability and Quarterly Inservice Test, Revision 39 310, Containment Spray System Operation, Revision 111 645.4.012, Fire Pump Functional Test, Revision 13 645.4.036, Fire Pump #2 Operability Test, Revision 26 604.3.026, Suppression Pool Temperature Monitoring System Channel Calibration, Revision 10

Condition Reports

2529028

2528626

2547023

2548275

2548558

2542321

2457579

2557031

2557965

2518474

Drawings

BR 2005, Emergency Service Water System, Revision 86

GE 148F740, Containment Spray System Flow Diagram, Revision 44

JC 19479, Fire Protection Water System, Revision 65

Calculations

C-1302-822-E150-066, Secondary Containment Integrity Calculation, Revision 2

Maintenance Orders/Work Orders

C2034807 R2189971 M2383837

R2196280 A2383054 M2383054

A2386349 M2386540

C2034982

C2034921 A2382518 R2190217

Miscellaneous

Oyster Creek Nuclear Generating Station Updated Final Safety Analysis Report Section 6.2, Containment Systems, Revision 18 Oyster Creek Nuclear Generating Station Technical Specifications Section 3.4, Emergency Cooling, Amendment 247 Prompt Investigation report for the #2 Fire Diesel Engine Failure to Start

Section 1R22: Surveillance Testing

Procedures

ER-AA-600-1045, Risk Assessments of Missed or Deficient Surveillances, Revision 7

MA-AA-716-012, Post Maintenance Testing, Revision 20

CY-OC-120-530, Liquid Poison System Sampling, Revision 5 607.4.016, Containment Spray and Emergency Service Water System I Pump Operability and Quarterly Inservice Test, Revision 39 607.4.017, Containment Spray and Emergency Service Water System 2 Pump Operability and Quarterly Inservice Test, Revision 40

635.2.001, 4160 Switchgear Buses (A, B, C, D) and Circulating Water Pump Protective Relay

Surveillance, Revision 69 612.4.001, Standby Liquid Control Pump and Valve Operability and In-Service Test, Revision 49

Calculations

C-1302-532-E540-036, ESW System Performance with Keepfill Line Failure, Revision 1

C-1302-241-E310-111, Factor of Safety Against Failure for the Containment Spray Pumps 1-1 and 1-2, Revision 0

C-1302-241-5360-004, Containment Spray/Emergency Service Water System Performance, Revision 0

C-1302-731-E320-017, OCNGS: 4160V Under Voltage (Degraded) Relay Setpoint Uncertainty,

Revision 1

C-1302-731-E320-009, OCNGS: 4.16KV Bus C7D Undervoltage Relay 27-11TD, 12TD, 13TD

Stability Calculation, Revision 2

Condition Reports

2524505

2523621

2450524

2451796

1573470

1620802

2514042

2537535

Drawings

GE148F740, Containment Spray System Flow Diagram, Revision 44

Maintenance Orders/Work Orders R2257974

R2228514 R2183985 R2257972 A0703679 A2380768 R2196280

A2296738

Section 1EP6: Drill Evaluation

Procedures

ABN 1, Reactor Scram, Revision 13

ABN 29, Plant Fires, Revision 30

ABN 36, Loss of Off Site Power and Station Blackout (Plant Control), Revision 28

ABN 41, Security Event, Revision 36

EMG-SP5, Fire Water Injection for RPV Water Level Control, Revision 1

Section 2RS7 Radiological Environmental Monitoring Program

Procedures

CY-AA-170-000, Radioactive Effluent and Environmental Monitoring Program, Revision 5

CY-AA-170-100, Radiological Environmental Monitoring Program, Revision 2CY-AA-170-1000, Radiological Environmental Monitoring Program and Meteorological Program Implementation, Revision 8

CY-AA-130-200, Quality Control, Revision 12

CY-AA-130-201, Radiochemistry Quality Control, Revision 2

CY-AA-170-100, Radiological Environmental Monitoring Program, Revision 2

CY-AA-170-1000, Radiological Environmental Monitoring Program and Meteorological Program Implementation, Revision 7

CY-AA-170-1100, Quality Assurance for Radiological Monitoring Program, Revision 1

CY-OC-120-1200, REMP Sample Collection - Well Water, Revision 1

CY-AA-120-420, Domestic Water Sample Collection, Revision 10

CY-AA-120-703, Radwaste System and Tritium Remediation Liquid Composite Sample Preparation, Revision 2

CY-OC-408-4001, RGPP Onsite and Offsite Sample Results Comparison, Revision 0

EN-AA-408, Radiological Ground Water Protection Program, Revision 0

EN-AA-408-4000, Radiological Ground Water Protection Program Implementation, Revision 0

EN-OC-408-4160, RGPP Reference Material for Oyster Creek. Revision 1

RP-AA-228, 10CFR 50.75(g) and 10CFR 72.30 (d), Revision 1 Murray and Trettel, Inc, P1009 Procedure Manual Met Monitoring Program Equipment Servicing and Data Recovery Procedures Manual, Revision 29 Normandeau Associates, Inc.

Procedure, Collection of Groundwater Samples for Radiological Analysis (Radiological Groundwater Protection Program), Revision 3 Normandeau Associates, Inc. Procedure

ER-OCGS-02, Collection/Exchange of Field Dosimeters for Radiological Analysis (OCGS), Revision 4 Normandeau Associates, Inc. Procedure

ER-OCGS-03, Collection of Aquatic Sediment Samples for Radiological Analysis (OCGS), Revision 3 Normandeau Associates, Inc. Procedure

ER-OCGS-04, Collection of Food Products and Broad Leaf Vegetation Samples for Radioactive Analysis (OCGS), Revision 4 Normandeau Associates, Inc. Procedure

ER-OCGS-05, Collection of Air Iodine and Air Particulate Samples for Radiological Analysis (OCGS), Revision 6 Normandeau Associates, Inc. Procedure

ER-OCGS-06, Collection of Water Samples for Radiological Analysis (OCGS), Revision 5 Normandeau Associates, Inc. Procedure

ER-OCGS-07, Performance of Annual Land Use Census (OCGS), Revision 2 Normandeau Associates, Inc. Procedure

ER-OCGS-08 Collection of Precipitation Samples for Radiological Analysis, Revision 1 Normandeau Associates, Inc. Oyster Creek 2014 Annual Land Use Census, December 10, 2014Orifice Calibration data

2693421(A/P # 73) Calibrated March 20, 2014,

2693413 (A/P #66) Calibrated March 20, 2014, and

2693416 (A/P #20) Calibrated March 20, 2014. All three calibrated orifices were installed February 25, 2015 Air Particulate Pump Vacuum Gauge #

0002812118 Calibrated April 15, 2015

Section 4OA1: Performance Indicator Verification

Procedures

ER-AB-331-1006, BWR Reactor Coolant System Leakage Monitoring and Action Plan,

Revision 2

Condition Reports

2545749

2475490

Miscellaneous

NUREG 1022, Reporting Requirements, Revision 3

Various Operator Logs from April 1, 2014 to June 30, 2015

NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7

Section 4OA2: Problem Identification and Resolution

Procedures

PI-AA-125, Corrective Action Program (CAP) Procedure, Revision 2

Section 4OA3: Follow-up of Events and Notices of Enforcement Discretion

Condition Reports

2383852

2440641

2440643

Miscellaneous

LER 2014-005-01, Secondary Containment Declared Inoperable, dated August 11, 2015

LIST OF ACRONYMS

ADAMS Agencywide Documents Access and Management System

CFR Code of Federal Regulations

DC Direct Current

EMRV Electromatic Relief Valve

IMC Inspection Manual Chapter kV Kilovolt

LER Licensee Event Report

LOOP Loss of Offsite Power

NCV Non-Cited Violation

NRC Nuclear Regulatory Commission

ODCM Offsite Dose Calculation Manual

REMP Radiological Environmental Monitoring Program

SBLOCA Small Break Loss-of-Coolant Accident

SSC Structure, System, or Component

UFSAR Updated Final Safety Analysis Report VDC Volts Direct Current