IR 05000219/2012003

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IR 05000219-12-003, 04/01/2012 - 06/30/2012; Exelon Energy Company, LLC, Oyster Creek Nuclear Generating Station; Operability Determinations and Functionality Assessments
ML12213A536
Person / Time
Site: Oyster Creek
Issue date: 07/31/2012
From: Hunegs G
NRC/RGN-I/DRP/PB6
To: Pacilio M
Exelon Nuclear, Exelon Generation Co
HUNEGS, GK
References
IR-12-003
Download: ML12213A536 (38)


Text

{{#Wiki_filter:UNITED STATES uly 31, 2012

SUBJECT:

OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2012003

Dear Mr. Pacilio:

On June 30, 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 July 17, 2012 with Mr. M. Massaro, Site Vice President, and other members of your staff.

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

The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

This report documents two NRC-identified findings of very low safety significance (Green). One of the findings was determined to involve 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 an NCV, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs 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 any 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 NRCs 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 05000219/2012003 w/Attachment: Supplementary Information

REGION I== Docket No.: 50-219 License No.: DPR-16 Report No.: 05000219/2012003 Licensee: Exelon Nuclear Facility: Oyster Creek Generating Station Location: Forked River, New Jersey Dates: April 1, 2012 - June 30, 2012 Inspectors: J. Kulp, Senior Resident Inspector J. Ambrosini, Resident Inspector S. Barr, Senior Emergency Preparedness Inspector A. Patel, Resident Inspector J. Furia, Senior Health Physicist J. Laughlin, Emergency Preparedness Inspector J. Tomlinson, Operations Engineer T. OHara, Reactor Inspector C. Newport, Operations Engineer B. Dionne, Health Physicist D. Spindler, Senior Resident Inspector Approved By: Gordon Hunegs, Branch Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000219/2012003, 04/01/2012 - 06/30/2012; Exelon Energy Company, LLC, Oyster Creek

Nuclear Generating Station; Operability Determinations and Functionality Assessments.

This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified two findings of very low safety significance (Green), one of 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 NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

Cornerstone: Initiating Events

Green.

The inspectors identified a Green finding when Exelon did not perform an adequate operability determination of Average Power Range Monitor (APRM) 7 prior to restoring it to operation on March 24, 2012, after it was declared inoperable on February 2, 2012.

Specifically, Exelon declared APRM 7 operable on March 24, 2102 without a documented technical basis or successful completion of a surveillance test to demonstrate operability, and operated APRM 7 through April 3, 2012, when it failed in the same manner and was again declared inoperable. Exelon entered this issue into their corrective action program as IR 1389340 to track resolution of this issue.

The inspectors determined that the failure to perform an operability evaluation to demonstrate that APRM-7 was operable as directed by OP-AA-108-115, Operability Determinations, is a performance deficiency that was within Exelons ability to foresee and correct. The inspectors determined this finding was more than minor because if left uncorrected it could become a more significant safety concern. Specifically, degraded technical specification required and safety related equipment require a full operability screening to ensure Exelon identifies and characterizes the equipment performance issues, develops all needed compensatory measures and does not restore inoperable equipment to operable status. The inspectors determined the finding to be of very low safety significance (Green) because it affected the initiating events cornerstone and does not contribute to both the likelihood of a reactor trip and the likelihood that mitigating equipment or functions will not be available.

This finding has a cross cutting aspect in the area of Human Performance, Decision Making, where the licensee makes safety-significant or risk-significant decisions using a systematic process, especially when faced with uncertain or unexpected plant conditions, to ensure safety is maintained [H.1(a)]. (Section 1R15)

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of Technical Specification 3.8.D, "Isolation Condenser," when Exelon did not enter the correct technical specification and take the required actions when both isolation condensers were made inoperable in order to perform corrective maintenance. Specifically, Exelon incorrectly entered general Technical Specification 3.0.A for conditions in excess of those addressed in the technical specifications instead of the more specific technical specification (3.8.D) for when both isolation condensers are inoperable. Entry into the appropriate technical specification would have required the initiation of an immediate shutdown instead of allowing 30 hours to reach cold shutdown. Exelon entered this issue into their corrective action program as IR 1386020 to track resolution of this issue.

The inspectors determined that not entering the correct technical specification and invoking the associated action requirement was a performance deficiency that was reasonably within Exelon's ability to foresee and correct, and should have been prevented. This finding is more than minor because it is similar to example 2.a in IMC 0612, Appendix E. Specifically, by not entering TS 3.8.D, Exelon did not meet the technical specification requirement to start shutting down the plant immediately when both isolation condensers were made inoperable.

Additionally, this finding also affects the Mitigating Systems cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined this finding was not a design qualification deficiency resulting in a loss of functionality or operability, did not represent an actual loss of safety function of a system or train of equipment, and was not potentially risk-significant due to a seismic, fire, flooding, or severe weather initiating event.

Therefore, inspectors determined the finding to be of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance, Resources, because Exelon's training of personnel not sufficient to preclude entry into a non-conservative technical specification. [H.2(b)] (Section 1R15)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Oyster Creek began the inspection period at 100 percent power. On April 6, 2012, operators reduced power to 90 percent, started the E reactor recirculation pump following motor generator set maintenance and returned to the plant to full power. On April 27, operators reduced power to 80 percent to perform a rod sequence exchange and returned the plant to full power on April 28. On April 29, operators reduced power to 95 percent to perform a control rod pattern adjustment and returned the plant to full power later that day. On May 2, operators reduced power to restart the A reactor recirculation pump following motor generator set maintenance.

The restart was unsuccessful and the plant was returned to full power later the same day. On May 3, following repairs to the motor generator set, operators reduced power to 90 percent, successfully started the A reactor recirculation pump and returned the plant to full power. On May 18, operators reduced power to 75 percent to perform quarterly turbine valve testing and returned the plant to full power on May 19. On May 19, operators reduced power to 80 percent to perform a rod pattern adjustment and returned the plant to full power on May 20. On June 23, operators lowered power to 80 percent to perform a rod pattern adjustment and returned the plant to full power on June 24. Oyster Creek 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 high temperatures. The review focused on the emergency service water (ESW) system and the emergency diesel generators (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 hot weather conditions. Documents reviewed for each section of this inspection report are listed in the Attachment.

b. Findings

No findings were identified.

.2 Summer Readiness of Offsite and Alternate Alternating Current (AC) Power Systems

a. Inspection Scope

The inspectors performed a review of plant features and procedures for the operation and continued availability of the offsite and alternate AC power system to evaluate readiness of the systems prior to seasonal high grid loading. The inspectors reviewed Exelons procedures affecting these areas and the communications protocols between the transmission system operator and Exelon. This review focused on changes to the established program and material condition of the offsite and alternate AC power equipment. The inspectors assessed whether Exelon established and implemented appropriate procedures and protocols to monitor and maintain availability and reliability of both the offsite AC power system and the onsite alternate AC power system. The inspectors evaluated the material condition of the associated equipment by interviewing the responsible system manager, reviewing condition reports and open work orders, and walking down portions of the offsite and AC power systems including the 230 KV switchyard.

b. Findings

No findings were identified.

.3 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors completed one impending adverse weather preparation sample. The inspectors reviewed Exelons preparations for the onset of hot weather on June 20, 2012. The inspectors reviewed the implementation of adverse weather preparation procedures before the onset of and during adverse weather conditions. The inspectors walked down the EDGs and the ESW system to ensure system availability. The inspectors verified that operator actions defined in Exelons adverse weather procedure maintained the readiness of essential systems. The inspectors discussed readiness and staff availability for adverse weather response with operations and work control personnel.

b. Findings

No findings were identified.

.4 External Flooding

a. Inspection Scope

The inspectors performed an inspection of the external flood protection measures for Oyster Creek Nuclear Generating Station on April 17, 2012. The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Chapter 2.4.8, 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 all external areas of the plant, including the turbine building, reactor building, intake and discharge canals, intake structure and the diesel generator building to ensure that Exelons flood protection measures were 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: Containment spray system 2 while system 1 was unavailable for planned maintenance on April 17, 2012 Core spray system 1 while system 2 was unavailable for planned maintenance and surveillance testing on May 21, 2012 Control rod drive system while the A pump was unavailable for planned maintenance on May 29, 2012 Isolation condenser B while isolation condenser A was unavailable for surveillance testing on June 25, 2012 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.

b. Findings

No findings were identified. ==1R05 Fire Protection

.1 Resident Inspectors Quarterly Walkdowns