IR 05000219/2014005

NRC Integrated Inspection Report 05000219/2014005 and Preliminary White Finding

ML15042A072
Person / Time
Site:	Oyster Creek
Issue date:	02/11/2015
From:	Ho Nieh Division Reactor Projects I
To:	Bryan Hanson Exelon Nuclear Generation Corp
KENNEDY, SR
References
EA-14-186 05000219/2014005, IR 2014005
Download: ML15042A072 (66)

Text

{{#Wiki_filter:UNITED STATES February 11, 2015

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2014005 AND PRELIMINARY WHITE FINDING

Dear Mr. Hanson:

On December 31, 2014, 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 January 29, 2015, with Mr. G. Stathes, Site Vice President, and other members of your staff. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

The enclosed inspection report discusses a finding associated with the failure of Emergency Diesel Generator (EDG) No. 2, which has preliminarily been determined to be White, a finding with low to moderate safety significance. As described in Section 4OA2 of the enclosed report, the finding is associated with an apparent violation of Title 10 of the Code of Federal Regulations (10 CFR) Appendix B, Criterion III, Design Control, because Exelon did not review the suitability of a different maintenance process for tensioning the cooling fan belt on the EDGs. As a result, the new method imposed a stress above the fatigue endurance limit of the shaft material, making the EDG cooling fan shaft susceptible to fatigue and subsequent failure on July 28, 2014. As a consequence, Exelon also violated Technical Specification (TS) 3.7.C, since the EDG No. 2 was determined to be inoperable for greater than the technical specification allowed outage time.

The finding was assessed based on the best available information, using Inspection Manual Chapter (IMC) 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process (SDP) for Findings At-Power, issued June 19, 2012. The basis for the NRCs preliminary significance determination is described in the enclosed report. Because the finding is also an apparent violation of NRC requirements, it is being considered for escalated enforcement action in accordance with the Enforcement Policy, which appears on the NRCs Web site at http://www.nrc.gov/about-nrc/regulatory/ enforcement/enforce-pol.html. The NRC will inform you, in writing, when the final significance has been determined. We intend to complete and issue our final safety significance determination within 90 days from the date of this letter. The NRCs SDP is designed to encourage an open dialogue between your staff and the NRC; however, the dialogue should not affect the timeliness of our final determination.

We believe that we have sufficient information to make a final significance determination.

However, before we make a final decision, we are providing you an opportunity to provide your perspective on this matter, including the significance, causes, and corrective actions, as well as any other information that you believe the NRC should take into consideration. Accordingly, you may notify us of your decision within 10 days to: (1) request a regulatory conference to meet with the NRC and provide your views in person; (2) submit your position on the finding in writing; or, (3) accept the finding as characterized in the enclosed inspection report.

If you choose to request a regulatory conference, the meeting should be held in the NRC Region I office within 30 days of the date of this letter, and will be open for public observation.

The NRC will issue a public meeting notice and a press release to announce the date and time of the conference. We encourage you to submit supporting documentation at least 1 week prior to the conference in an effort to make the conference more efficient and effective. If you choose to provide a written response, it should be sent to the NRC within 30 days of the date of this letter. You should clearly mark the response as Response to Preliminary White Finding in Inspection Report No. 05000219/2014005; EA-14-186, and send it to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, Region I, and a copy to the NRC Senior Resident Inspector at the Oyster Creek Nuclear Generating Station.

You may also elect to accept the finding as characterized in this letter and the inspection report, in which case the NRC will proceed with its regulatory decision. However, if you choose not to request a regulatory conference or to submit a written response, you will not be allowed to appeal the NRCs final significance determination.

Please contact Silas Kennedy at (610) 337-5046 within 10 days from the issue date of this letter to notify the NRC of your intentions. If we have not heard from you within 10 days, we will continue with our significance determination and enforcement decision. Because the NRC has not made a final determination in this matter, no notice of violation is being issued for this inspection finding at this time. In addition, please be advised that the number and characterization of the apparent violation may change based on further NRC review. The final resolution of this matter will be conveyed in separate correspondence.

In addition, the enclosed inspection report documents three violations of NRC requirements which were of very low safety significance (Green). However, because of the very low safety significance and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violations 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, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Oyster Creek Nuclear Generating Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at the Oyster Creek Nuclear 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 component of the NRCs Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely, /RA/ Ho K. Nieh, Director Division of Reactor Projects Docket No.: 50-219 License No.: DPR-16

Enclosure:

Inspection Report 05000219/2014005 Attachment 1: Detailed Risk Significance Evaluation Attachment 2: Supplementary Information

REGION I== Docket Nos.: 50-219 License Nos.: DPR-16 Report No.: 05000219/2014005 Licensee: Exelon Nuclear Facility: Oyster Creek Nuclear Generating Station Location: Forked River, New Jersey Dates: October 1, 2014 - December 31, 2014 Inspectors: J. Kulp, Senior Resident Inspector A. Patel, Resident Inspector J. Schoppy, Senior Reactor Inspector P. Kaufman, Senior Reactor Inspector B. Fuller, Senior Operations Engineer R. Deese, Senior Reactor Analyst J. Viera, Operations Engineer E. Burkett, Emergency Preparedness Inspector B. Dionne, Health Physicist N. Floyd, Reactor Inspector M. Orr, Reactor Inspector J. Deboer, Reactor Engineer Approved By: Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY

IR 05000219/2014005; 10/01/2014 - 12/31/2014; Exelon Energy Company, LLC, Oyster Creek

Nuclear Generating Station; Inservice Inspection Activities; Problem Identification and Resolution.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one apparent violation of with preliminary low to moderate safety significance (White) and three findings of very low safety significance (Green), which were also non-cited violations. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC)0609, Significance Determination Process (SDP), dated June 2, 2011. The cross-cutting aspects for the findings were determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 4, 2014. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated July 9, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 5.

Cornerstone: Mitigating Systems

Preliminary

White.

The inspectors identified a preliminary White finding and an associated apparent violation of 10 CFR 50, Appendix B, Criterion III, Design Control, because Exelon staff did not review the suitability of the application of a different maintenance process at Oyster Creek that was essential to a safety-related function of the emergency diesel generators (EDG). Specifically, in May 2005, Exelon staff changed the method for tensioning the cooling fan belt on the EDG from measuring belt deflection to belt frequency and did not verify the adequacy of the acceptance criteria stated for the new method. As a result, Exelon staff did not identify that the specified belt frequency imposed a stress above the fatigue endurance limit of the shaft material, making the EDG cooling fan shaft susceptible to fatigue and subsequent failure on July 28, 2014. As a consequence, Exelon also violated Technical Specification 3.7.C, because the EDG No. 2 was determined to be inoperable for greater than the technical specification allowed outage time. Exelons immediate corrective actions included entering the issue into their corrective action program as issue report (IR) 1686101, replacing the EDG No. 2 fan shaft, examining the EDG No.1 fan shaft for extent of condition, and performing a failure analysis to determine the causes of the broken shaft.

This finding is more than minor because it is associated with the equipment performance attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences (i.e., core damage). In accordance with IMC 0609.04, Initial Characterization of Findings, and Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, issued June 19, 2012, the inspectors screened the finding for safety significance and determined that a detailed risk evaluation was required because the finding represented an actual loss of function of a single train for greater than its technical specification allowed outage time. The detailed risk evaluation concluded that the increase in core damage frequency was 5.1E-6, or White (low to moderate safety significance). This finding does not have an associated cross-cutting aspect because the performance deficiency occurred in 2005 and is not reflective of present performance. (Section 4OA2.4)

Green.

The inspectors identified a non-cited violation (NCV) of Technical Specification 6.8.1, Procedures and Programs, because Exelon did not adequately establish and maintain the plant shutdown procedure. Specifically, the procedure was not adequate in that it did not contain precautions concerning rod insertion when reactor power is below the point of adding heat; operational limitations on plant cooldown when power is below the point of adding heat; and contingency actions for re-criticality during shutdown. Exelon entered this issue into their corrective action program as IR 2412093 and conducted a root cause analysis.

This finding is more than minor because it affected the procedure quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating events. Specifically, the plant shutdown procedure did not contain precautions to continuously insert control rods when reactor power is less than the point of adding heat, did not define operational considerations for limiting reactor cooldown, and did not contain contingency actions for return to criticality during shutdown. The inspectors screened this issue using IMC 0609.04, Initial Characterization of Findings, Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria. Inspectors determined this finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Documentation, because Exelon did not ensure that the shutdown procedure contained adequate controls for soft shutdown. [H.7] (Section 4OA2.5)

Green.

The inspectors identified an NCV of Technical Specification 6.8.1, Procedures and Programs, because Oyster Creek operators did not adequately implement procedures when performing a plant shutdown. Specifically, the operators did not ensure that all personnel on shift had received Just-in-Time-Training for their role in the shutdown; operators did not perform a reactivity Heightened Level Awareness brief for the shutdown, and did not insert source range monitors (SRMs) in accordance with procedure. These performance deficiencies contributed to two unanticipated criticalities during the shutdown.

Exelon entered this issue into their corrective action program as IR 2412093 and conducted a root cause analysis.

This finding is more than minor because it affected the procedure quality attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the reliability and capability of systems that respond to initiating events. Specifically, Exelon did not implement procedures during the plant shutdown which contributed to two unanticipated returns to criticality which required operator action to mitigate. The inspectors screened this issue using IMC 0609.04, Initial Characterization of Findings, Exhibit 2 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and IMC 0609 Appendix M, Significance Determination Process Using Qualitative Criteria. Inspectors determined this finding was of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Human Performance, Procedure Adherence, because licensed operators did not implement processes, procedures and work instructions during the plant shutdown. [H.8] (Section 4OA2.5)

Cornerstone: Initiating Events

Green.

The inspectors identified an NCV of 10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, because Exelon did not promptly correct a condition adverse to quality associated with the reactor head cooling (RHC) spray line 2-inch upper flange which was installed in a configuration that exceeded the allowable acceptance criteria. Specifically, Exelon staff identified a misaligned flange condition in IR 845395 but did not correct the deficiency by evaluation, repair or replacement during the 1R22 refueling outage in 2008 or subsequently during the 1R23 and 1R24 refueling outages. Exelon staff completed corrective actions to replace the flange during the 1R25 refueling outage after the NRC inspector questioned the acceptability of this condition. Exelon staff entered this issue into their corrective action program as IR 2385501.

The finding is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and affected the cornerstone objective to limit the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Specifically, misalignment of the RHC spray line flange was greater than that provided in Oyster Creek pipe specifications and resulted in additional stresses in the flange weld. This condition was identified by Exelon staff as a possible contributor to the occurrence of a through wall crack and leak in the N7B upper flange socket weld joint that was identified and repaired in November 2012, but the misalignment was not corrected at that time. The inspectors screened this issue using IMC 0609.04, Phase 1 - Initial Screening and Characterization of Findings, and Exhibit 1 of IMC 0609, Appendix A, The Significance Determination Process for Findings At-Power, and determined this finding was of very low safety significance (Green). The inspectors determined that this finding had a Problem Identification and Resolution cross-cutting aspect because Exelon did not evaluate and take timely corrective actions to address the long-standing repetitive flange alignment issue of the reactor head cooling spray piping flange connection to reactor pressure vessel head N7B nozzle [P.2]. (Section 1R08)

REPORT DETAILS

Summary of Plant Status

Oyster Creek began the inspection period with the reactor shut down for the 1R25 refueling outage. Operators commenced a startup of the reactor on October 11, 2014. On October 12, 2014, an automatic scram occurred at approximately 1 percent power due to a human performance error which occurred during troubleshooting of the main generator automatic voltage regulator. Following repairs, Oyster Creek operators commenced startup on October 13, 2014, and the unit achieved 100 percent power on October 17, 2014. Operators briefly lowered power to 90 percent to perform rod pattern adjustments on October 18, 2014, October 24, 2014 and November 10, 2014. Operators lowered power to 95 percent on November 21, 2014 to perform turbine surveillances and returned to full power later the same day. The unit remained at or near 100 percent power for the remainder of the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 Readiness for Seasonal Extreme Weather Conditions

a. Inspection Scope

The inspectors performed a review of Exelons readiness for the onset of seasonal cold temperatures. The review focused on the intake structure and the EDGs. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), technical specifications, control room logs, and the corrective action program to determine what temperatures or other seasonal weather could challenge these systems, and to ensure Exelon personnel had adequately prepared for these challenges. The inspectors reviewed station procedures, including Exelons seasonal weather preparation procedure and applicable operating procedures. The inspectors performed walkdowns of the selected systems to ensure station personnel identified issues that could challenge the operability of the systems during cold weather conditions.

b. Findings

No findings were identified.

.2 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Exelons response to a tornado warning issued by the National Weather Service on November 8, 2014. The inspectors verified that Exelon implemented their adverse weather procedures and that operators monitored plant equipment that could have been affected by the adverse weather conditions. The inspectors performed walkdowns to verify that equipment in areas around the plant were maintained within procedural limits, and when necessary, compensatory actions were properly implemented in accordance with procedures. The inspectors also verified that Exelon properly implemented its adverse weather procedures and that operators reviewed applicable emergency procedure. The inspectors performed independent walkdowns of the site to verify the site was ready for the onset of adverse weather.

a. Findings

No findings were identified.

.3 External Flooding

a. Inspection Scope

During the week of October 22, 2014, the inspectors performed an inspection of the external flood protection measures for Oyster Creek Nuclear Generating Station. The inspectors reviewed the 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 EDG 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.

b. Findings

No findings were identified. ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Core spray system II during planned maintenance for core spray system I on November 12, 2014 Containment spray system I during planned maintenance for containment spray system II on November 19, 2014 1-2 service water pump and both trains of emergency service water during planned maintenance on the 1-1 service water pump on December 8, 2014 1-2 and 1-3 turbine building closed cooling water pumps and both EDGs during planned maintenance on the 1-1 turbine building closed cooling water pump on December 9, 2014 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findings

No findings were identified. ==1R05 Fire Protection