Text

Integrated Inspection Report 05000219-14-002, 01/01/2014 - 03/31/ 2014, Oyster Creek Nuclear Generating Station
	ML14135A013
Person / Time
Site:	Oyster Creek
Issue date:	05/15/2014
From:	Kevin Mangan; NRC/RGN-I/DRP/PB6
To:	Pacilio M; Exelon Generation Co, Exelon Nuclear
	mangan, ka
References
	IR-14-002
	Download: ML14135A013 (34)
	v • d • e

UNITED STATES May 15, 2014

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2014002

Dear Mr. Pacilio:

On March 31, 2014, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Nuclear Generating Station. The enclosed inspection report documents the inspection results, which were discussed on April 24, 2014, 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.

This report documents two violations of NRC requirements, both of 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 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 addition, if you disagree with the cross-cutting aspect assigned to any finding, or a finding not associated with a regulatory requirement 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 Inspector at Oyster Creek Nuclear Generating Station.

Additionally, as we informed you in the most recent NRC integrated inspection report, cross-cutting aspects identified in the last six months of 2013 using the previous terminology were being converted in accordance with the cross-reference in Inspection Manual Chapter 0310.

Section 4OA5 of the enclosed report documents the conversion of these cross-cutting aspects which will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review. If you disagree with the cross-cutting aspect assigned, 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 1, and the NRC Resident Inspector at the Oyster Creek Nuclear Generating Station.

In accordance with Title 10 of the Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access 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/

Kevin A. Mangan, Acting Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-219 License Nos.: DPR-16

Enclosure:

Inspection Report 05000219/2014002 w/Attachment: Supplementary Information

REGION I==

Docket Nos.: 50-219 License Nos.: DPR-16 Report No.: 05000219/2014002 Licensee: Exelon Nuclear Facility: Oyster Creek Nuclear Generating Station Location: Forked River, New Jersey Dates: January 1 to March 31, 2014 Inspectors: J. Kulp, Senior Resident Inspector A. Patel, Resident Inspector B. Bollinger, Reactor Engineer (NSPDP)

P. Kaufman, Senior Reactor Inspector T. Hedigan, Operations Engineer J. Furia, Senior Health Physicist S. Pindale, Senior Reactor Inspector E. Burket, Emergency Preparedness Inspector Approved By: K. Mangan, Acting Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000219/2014002; 01/01/2014 - 03/31/2014; Exelon Energy Company, LLC, Oyster Creek

Generating Station; Risk Assessments, 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 two findings of very low safety significance (Green), both of which are 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). 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 5, dated February 2014.

Cornerstone: Initiating Events

Green.

The inspectors identified a Green non-cited violation of 10 CFR Part 50.65(a)(4),

Requirements for monitoring the effectiveness of maintenance at nuclear power plants, because Exelon did not reassess and manage risk after the grid operator declared a maximum emergency generation action, prior to performing maintenance on the B control rod drive pump on January 30, 2014. The inspectors identified that Exelon assessment of risk was green; however, if the emergency generation action had been included in the assessment, the risk would have been yellow requiring Exelon to perform compensatory actions to limit the risk to the unit. Exelon entered this issue into their corrective action program as issue report 1614625.

The inspectors determined that Exelons failure to assess and manage risk prior to performing maintenance on the B control rod drive pump after the grid operator declared a maximum emergency generation was a performance deficiency that was reasonably within Exelons ability to foresee and correct. This finding is more than minor because it is associated with the configuration control attribute of the Mitigating Systems cornerstone and adversely affected the cornerstone objective to ensure the availability, reliability, and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors used NRC inspection manual chapter 0609, appendix K, flowchart 2, Assessment of Risk Management Actions, to determine the significance of this finding. The inspectors determined that the finding is of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance because operators did not stop when faced with uncertain conditions and evaluate and manage risks before proceeding as scheduled. Specifically, the operators continued maintenance without reassessing risk after the inspectors questioned the rationale for not entering the grid emergency procedure [H.11]. (Section 1R13)

Green.

A self-revealing Green non-cited violation of 10 CFR Part 50, Appendix B,

Criterion XVI, "Corrective Action," was identified when the corrective action to prevent recurrence of a significant condition adverse to quality did not preclude repetition of the event. Specifically, Exelon generated a corrective action to prevent recurrence during a root cause evaluation for a reactor scram caused by spiking on intermediate range monitor nuclear instruments that occurred in May 2004. In October 2013 another scram caused by spiking on the intermediate range nuclear instrument occurred, which Exelon subsequently determined to be a repeat of the May 2004 event. Exelon entered this issue into their corrective action program as issue report 1567196.

The inspectors determined that Exelons failure to preclude repetition of a significant condition adverse to quality was a performance deficiency that was reasonably within Exelons ability to foresee and correct. This performance deficiency is more than minor because it is associated with the equipment performance attribute of the Initiating Events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The significance of this finding was determined using NRC IMC 0609, appendix A, exhibit 1. This finding screened as very low safety significance (Green), because the finding did not contribute to both the likelihood of a reactor trip and likelihood that mitigation equipment or functions would not be available.

The finding does not have a cross cutting aspect as it is not reflective of current performance because the root cause and associated corrective actions to prevent reoccurrence were from 2004. (Section 4OA2)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Oyster Creek began the inspection period at 100 percent power and operated at full power throughout the inspection period.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

Main article: IP 71111.01

.1 Readiness for Impending Adverse Weather Conditions

a. Inspection Scope

The inspectors reviewed Exelons response to a cold weather alert issued by the grid operator for the period January 3-4, 2014 and a winter storm warning issued by the National Weather Service for the period of January 2-3, 2014. The inspectors verified that Exelon implemented their cold weather procedures and that operators monitored plant equipment that could have been affected by the cold weather conditions. The inspectors performed walkdowns to verify that temperatures equipment and areas in 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.

b. Findings

No findings were identified.

1R04 Equipment Alignment

.1 Partial System Walkdowns

Main article: IP 71111.04Q

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems:

B standby liquid control pump while A standby liquid control pump was out of service for planned maintenance on January 9, 2014 A, B, and D emergency service water pumps while C emergency service water pump was out of service for corrective maintenance on January 30, 2014 Core spray system I while core spray system II was out of service for surveillance testing on February 12, 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.

.2 Full System Walkdown

Main article: IP 71111.04S

Main article: IP 71111.11

Quarterly Review of Licensed Operator Requalification Testing and Training

a. Inspection Scope

The inspectors observed licensed operator simulator training on March 4, 2014, which included a loss of B control rod drive pump and reactor building closed loop cooling water system and subsequent anticipated transient with a failure to scram.

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

Main article: IP 71111.12

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.

Average power range monitor power supply issues on January 30, 2014 Core monitoring system issues on February 18, 2014 Emergency service water pump breaker issues on March 17, 2014

c. Findings

No findings were identified.

1R13 Maintenance Risk Assessments and Emergent Work Control

Main article: IP 71111.13

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 Exelons 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.

A standby liquid control pump and A isolation condenser out of service for planned maintenance on January 9, 2014 Containment spray system II and reactor building closed cooling water pump 1-2 out of service for planned maintenance on January 16, 2014 B combustion turbine, B control rod pump, B battery charger, C emergency service water pump unavailable with declaration of a maximum emergency generation action on January 30, 2014 Reactor building closed cooling water system II and standby gas treatment system II out of service for planned maintenance on March 11, 2014

b. Findings

Introduction:

The inspectors identified a Green, non-cited violation of 10 CFR 50.65 (a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, when Exelon personnel did not assess and manage the increase in risk that resulted from proposed maintenance activities. Specifically, Exelon did not reassess and manage risk after the grid operator declared a maximum emergency generation action, prior to performing maintenance on the B control rod drive pump on January 30, 2014.

Description:

At 0551 on January 30, 2014, PJM Interconnection (PJM is the grid operator for Oyster Creek Generating Station) declared a maximum emergency generation action for the mid-Atlantic and Southern regions of the PJM Regional Transmission Organization. While performing their morning status review, the inspectors determined that the maximum emergency generation action was applicable to Oyster Creek. The inspectors subsequently asked the control room operators for the status of entering Oyster Creeks grid emergency procedure in response to the maximum emergency generation action declaration. Control room operators informed the inspectors that they were told by Exelon power team that the maximum emergency generation action was not applicable to Oyster Creek. The inspectors then asked the control room operators to determine the basis for that determination. Control room operators subsequently consulted with Exelon corporate personnel regarding the resident inspectors concern. At 0859, Exelon determined that maximum emergency generation action was applicable to the site and Oyster Creek entered their grid emergency procedure (ABN-60).

Oyster Creek procedure ABN-60, Grid Emergency states, in part, that for a maximum emergency generation action condition operators must refer to WC-AA-101, Online Work Control Process. This procedure states, ensure a probabilistic risk assessment is performed for the emergent condition, and suspend maintenance, testing, and troubleshooting that may adversely affect electrical generation, or transmission system, as directed by Shift Management and also requires that the risk of the scheduled on-line maintenance activities be continuously evaluated based on conditions such as power grid stability and weather forecast. Exelon risk analysis procedures consider a maximum emergency generation action to be a qualitative risk increase for a loss of offsite power (LOOP) caused by external events.

The inspectors determined that Oyster Creek removed the B control rod drive pump from service at 0600 for planned maintenance and that risk for this maintenance had been assessed as part of the work management process. However, the inspectors found that the assessment did not take into account the maximum emergency generation action PJM declared at 0551. Therefore, Exelon did not assess the maintenance risk due to the emergent condition until 0859, three hours after the maximum emergency generation action was declared. Finally, the inspectors determined that the point of contact between the grid operator and the site control room is the Exelon power team. The Exelon power team is to inform the nuclear duty officer of any changes to the status of the grid who then informs the site control room of the change to grid conditions.

Exelons investigation revealed that the Exelon power team was aware of the maximum generation action but did not pass the information regarding the change in grid status to the plant in a timely manner (IR 1614646). This affected Oyster Creeks ability to perform an accurate risk assessment for the planned maintenance on the B control rod drive pump during a maximum emergency generation action. The inspectors noted that Oyster Creek exited the emergency generation action which resulted in plant risk being reduced to green and documented the late notification of a maximum emergency generation action in IR 1614625.

Analysis.

The inspectors determined that Exelons failure to assess and manage risk prior to performing maintenance on the B control rod drive pump after the grid operator declared a maximum emergency generation was a performance deficiency that was reasonably within Exelons ability to foresee and correct. This finding is more than minor because it affected the configuration control 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. Specifically, Exelon did not maximize the availability, reliability and capability mitigating systems prior to removing the control rod drive pump from service during a maximum emergency generation action grid emergency. Additionally, this issue is similar to example 7.f in inspection manual chapter 0612, appendix E, because the overall elevated plant risk placed the plant into a higher licensee-established risk category.

The inspectors evaluated the finding using Phase 1, Initial Screening and Characterization worksheet in Attachment 4 to IMC 0609, Significance Determination Process. For findings within the initiating events, mitigation systems and barriers cornerstones, attachment 4, table 3, paragraph 5.C, directs that if the finding affects the licensees assessment and management of risk associated with performing maintenance activities under all plant operating or shutdown conditions in accordance with Baseline Inspection Procedure (IP) 71111.13, Maintenance Risk Assessment and Emergent Work Control, the inspectors shall use Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, to determine the significance of the finding. The inspectors used flowchart 2, Assessment of Risk Management Actions, to analyze the finding and calculated incremental core damage probability (IDCP) using PARAGON, Exelons risk assessment tool, and found the result to be less than 1E-6. The regional senior reactor analyst confirmed these results using the NRCs risk assessment tool, SAPHIRE. The inspectors determined that because this finding is a 10 CFR 50.65(a)(4) performance issue associated with risk management actions only and the ICDP is not >1E-6, the finding is of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Human Performance because operators did not stop when faced with uncertain conditions and evaluate and manage risks before proceeding as scheduled. Specifically, the operators continued maintenance without reassessing risk after the inspectors questioned the rationale for not entering the grid emergency procedure [H.11].

Enforcement.

10 CFR 50.65 (a)(4), states, in part, that the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities.

Exelon procedure WC-AA-101, Online Work Control Process, that implements the requirements of 10 CFR 50.65 (a)(4), requires Exelon to continuously evaluate the risk of the scheduled on-line maintenance activities based on conditions such as power grid stability. Contrary to the above, on January 30, 2014, between 0600 and 0906, Exelon did not adequately assess the increase in risk of scheduled on-line maintenance activities prior to proposed maintenance activities. Specifically, a risk assessment was not performed after the grid operator declared a maximum emergency generation action prior to removing the B control rod drive pump from service for maintenance.

Compliance to the rule was restored when the action declaration ended. Because this violation was of very low safety significance and it was entered into Exelons corrective action program as IR 1614625, this violation is being treated as a non-cited violation, consistent with the NRC Enforcement Policy. (NCV 05000219/2014002-01, 50.65 a(4)

Risk Evaluation Not Promptly Performed during a Maximum Emergency Generation Action)

1R15 Operability Determinations and Functionality Assessments

Main article: IP 71111.15

a. Inspection Scope

==71114.04 - 1 Sample)

a. Inspection Scope

==

Exelon implemented various changes to the Oyster Creek emergency action levels, emergency plan, and implementing procedures. Exelon had determined that, in accordance with 10 CFR 50.54(q)(3), any change made to the emergency action levels, emergency plan, and its lower-tier implementing procedures had not resulted in any reduction in effectiveness of the plan and the revised plan continued to meet the standards in 50.47(b) and the requirements of 10 CFR 50 Appendix E.

The inspectors performed an in-office review of all emergency action level and emergency plan changes submitted by Exelon as required by 10 CFR 50.54(q)(5),including the changes to lower-tier emergency plan implementing procedures, to evaluate for any potential reductions in effectiveness of the emergency plan. This review by the inspectors was not documented in an NRC safety evaluation report and does not constitute formal NRC approval of the changes. Therefore, these changes remain subject to future NRC inspection in their entirety. The requirements in 10 CFR 50.54(q) were used as reference criteria.

b. Findings

No findings were identified.

1EP6 Drill Evaluation

Main article: IP 71114.06

.1 Emergency Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine quarterly Exelon emergency drill on February 3, 2014 to identify any weaknesses or deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator and technical support center 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 Exelons 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 and Occupational Radiation Safety

2RS8 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and

Transportation (71124.08 - 1 sample)

a. Inspection Scope

During the week of February 3-7, 2014, the inspectors verified the effectiveness of Exelons programs for processing, handling, storage, and transportation of radioactive material. The inspectors used the requirements of 10 CFR Parts 20, 61, and 71; 10 CFR 50, Appendix A, Criterion 63, Monitoring Fuel and Waste Storage; and licensee procedures required by the Technical Specifications/Process Control Program, as criteria for determining compliance. The inspectors reviewed the solid radioactive waste system description in the updated final safety analysis report, the process control program, and the recent radiological effluent release report for information on the types, amounts, and processing of radioactive waste.

The inspectors reviewed the scope and results, to assess adequacy of Exelons corrective actions of quality assurance audits performed for this area since the last inspection.

Radioactive Material Storage The inspectors inspected areas where containers of radioactive waste were stored to determine if the radioactive materials storage areas were controlled and posted as appropriate.

The inspectors verified that the licensee had established a process for monitoring the impact of long-term storage (e.g., buildup of any gases produced by waste decomposition, chemical reactions, container deformation, loss of container integrity, or re-release of free-flowing water). The inspectors verified that there were no signs of swelling, leakage, or deformation.

Radioactive Waste System Walkdown The inspectors walked down accessible portions of liquid and solid radioactive waste processing systems to verify and assess that the current system configuration and operation agree with the descriptions in the updated final safety analysis report, offsite dose calculation manual, and process control program.

During the walkdown, the inspectors identified radioactive waste processing equipment that was not operational and/or was abandoned in place and verified that Exelon had established administrative and/or physical controls for the protection of personnel from unnecessary personnel exposure.

The inspectors reviewed the adequacy of any changes made to the radioactive waste processing systems since the last inspection. The inspectors verified that changes from what was described in the updated final safety analysis report were reviewed and documented.

The inspectors identified processes for transferring radioactive waste resin and/or sludge discharges into shipping/disposal containers. The inspectors verified that the waste stream mixing, sampling procedures and methodology for waste concentration averaging were consistent with the process control program and provided representative samples of the waste product for the purposes of waste classification. For those systems that provide tank recirculation, the inspectors verified that the tank recirculation procedure provided sufficient mixing. Finally, the inspectors verified that the Exelon process control program correctly described the current methods and procedures for dewatering waste.

Waste Characterization and Classification The inspectors identified radioactive waste streams and verified that Exelons radiochemical sample analysis results were sufficient to support radioactive waste characterization. The inspectors verified that Exelons use of scaling factors and calculations to account for difficult-to-measure radionuclides was technically sound and based on current analyses. The inspectors assessed that changes to plant operational parameters were taken into account to maintain the validity of the waste stream composition data between the annual or biennial sample analysis update and when Exelon determined if waste shipments met applicable requirements. Finally, the inspectors verified that Exelon had established and maintained an adequate quality assurance program to ensure compliance with applicable waste classification and characterization requirements.

Shipment Preparation The inspectors reviewed the records of shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and Exelon documents for verification of shipment readiness to verify the requirements of any applicable transport cask certificate of compliance had been met. The inspectors assessed that the receiving licensee was authorized to receive the shipment packages. The inspectors evaluated if the shippers were knowledgeable of the shipping regulations and that shipping personnel demonstrated adequate skills to accomplish the package preparation requirements for public transport. Finally, the inspectors verified that Exelons training program provided training to personnel responsible for the conduct of radioactive waste processing and radioactive material shipment preparation activities.

Shipping Records The inspectors identified non-excepted package shipment records and verified that the shipping documents indicate the proper shipper name; emergency response information; a 24-hour contact telephone number; accurate curie content and volume of material; and appropriate waste classification, transport index, and international shipping identification number. The inspectors verified that the shipment placarding was consistent with the information in the shipping documentation.

Identification and Resolution of Problems The inspectors verified that problems associated with radioactive waste processing, handling, storage and transportation were being identified by Exelon at an appropriate threshold, were properly characterized and corrective actions for a selected sample of problems were appropriate.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA2 Problem Identification and Resolution

Main article: IP 71152

.1 Routine Review of Problem Identification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure 71152, Problem Identification and Resolution, the 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, performed 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.

b. Findings

No findings were identified.

.2 Semi-Annual Trend Review

a. Inspection Scope

The inspectors performed a semi-annual review of site issues, as required by Inspection Procedure 71152, Problem Identification and Resolution, to identify trends that might indicate the existence of more significant safety issues. In this review, the inspectors evaluated Exelons technical specification surveillance frequency control program. The inspectors reviewed Exelons corrective action program database to assess condition reports written in the subject area as well completed surveillance frequency changes as permitted by the program. The inspectors also reviewed the specific condition reports to verify that Exelon was appropriately evaluating and trending potential adverse conditions in accordance with applicable procedures. Finally, the inspectors reviewed Exelons technical specification surveillance frequency control program and associated implementing procedures to determine whether the program was consistent with industry standards.

b. Findings and Observations

No findings were identified.

The inspectors reviewed a surveillance test interval change screening form associated with the control rod drive scram discharge instrument volume, which changed the scram discharge volume level instrument test from quarterly to annually. The inspectors noted the change properly considered prior test performance and associated results, vendor-specified maintenance, operating experience, and risk insights; and the inspectors concluded that the change was acceptable and in accordance with procedures. The inspectors also reviewed condition reports associated with surveillance frequencies and the governing administrative program and determined that there were no adverse trends in this area.

.3 Annual Sample: Loss of Vacuum Scram

a. Inspection Scope

A problem identification and resolution sample inspection was conducted for evaluation of an approximate one inch hole identifed on the B main condenser steam inlet stainless steel expansion joint bellows which caused a rapid loss of condenser vacuum during unit startup from a maintenance outage. Operators initiated the scram due to the rapid loss of condenser vacuum on October 6, 2013.

The inspectors assessed problem identification threshold, apparent cause analyses, extent of condition reviews, and timeliness of corrective actions. The inspectors performed reviews of the documents listed in the Attachment to this report and interviewed engineering personnel to assess the effectiveness of the planned, scheduled, and completed corrective actions to resolve the identified component deficiency.

Finally, the inspectors reviewed issue reports, system health reports, work orders, purchase orders, drawings, photographs, and procedures to determine if the nonconforming condition was appropriately identified, documented, characterized and entered into Exelons corrective action process and in compliance with 10 CFR Part 50, Appendix B requirements.

b. Findings and Observations

No findings were identified.

Exelon determined that the hole identifed on the B main condenser steam inlet expansion joint bellows was most likely caused by fatigue cracking of the stainless steel expansion bellows and also identified a contributing cause as impact damage at the hole location. The inspectors consider the cause to be plausible based on a review of photographs taken of the stainless steel steam inlet expansion bellows failure location.

The inspectors determined that Exelon took acceptable immediate corrective action to perform a temporary leak repair of the expansion bellows to resolve the vacuum leak until a permanent replacement bellows could be procured and installed. Additionally Exelon, as part of the extent of condition reviews, inspected all similar expansion joint bellows with no deficiencies identified. The inspectors determined the planned replacement of the bellows is being appropriately tracked in Exelons corrective action program, refueling outage scope change request process, and work order process. The inspectors concluded that the corrective actions taken and planned should adequately resolve the main condenser expansion bellows issue.

.4 Annual Sample: Automatic Reactor Scram Caused By An Invalid Intermediate Range

Monitor Signal

a. Inspection Scope

A problem identification and resolution sample inspection was conducted for evaluation of the root cause analysis that Exelon performed due to an automatic reactor scram on October 3, 2013. The scram was caused by an invalid intermediate range monitor scram signal.

The inspectors performed an in-depth review of the root cause evaluation and assessed the following attributes: operability of the intermediate range monitors, identification of the root and contributing causes, extent of condition reviews, and previous operating experience. The inspectors also assessed the timeliness of corrective actions and whether they will preclude repetition of the event. The inspectors performed reviews of the documents noted in the Attachment to this report and interviewed engineering personnel to assess the effectiveness of the planned, scheduled, and completed corrective actions to resolve the identified deficiencies.

b. Findings and Observations

Introduction.

A self-revealing Green non-cited violation of 10 CFR Part 50, Appendix B, Criterion XVI, "Corrective Action," was identified because corrective actions to prevent recurrence of a significant condition adverse to quality did not preclude repetition of the event. Specifically, Exelon generated corrective actions to prevent recurrence, following a root cause evaluation, for a May 2004 reactor scram that was caused by spiking on intermediate range monitor nuclear instruments. A similar event occurred in October 2013 which was determined to be a repeat of the May 2004 event.

Description.

The inspectors identified that in May 2004, Oyster Creek experienced a reactor scram during a planned plant shutdown at approximately 2 percent power. The scram occurred when the reactor protection system (RPS) processed a reactor scram signal from the intermediate range monitor channels. The scram signal occurred when operators moved the source range monitor detectors into the core. During subsequent troubleshooting activities, Exelon determined that excessive electrical noise spiking appeared on intermediate range monitor channels which caused the RPS scram signal.

Exelon performed a root cause evaluation of the event, documenting their conclusions in a root cause evaluation. The root cause of the event was determined to be spiking on the intermediate range monitor channels which was caused by electronic noise generated from the source range monitor center conductors. Exelon found that the noise was detected by the intermediate range monitors due to low insulation resistance to ground measurements on the intermediate range monitor cables. They determined this was caused by a combination of moisture intrusion and degradation of the cable connections. Exelon identified two corrective actions to prevent recurrence. The first corrective action was to provide training to electricians and instrument and control technicians on electrically induced noise. The second corrective action was to develop and perform a preventive maintenance action to test the nuclear instrument cabling for degradation prior to every controlled startup and shutdown. The inspectors determined that subsequent to the completion of the root cause evaluation, the system manager modified this corrective action by implementing a preventive maintenance action to test the nuclear instrument cabling only before shutting down for refueling outage and during start up after a refueling outage.

In NO-AA-10, Quality Assurance Topical Report, Revision 72, Paragraph 2.116, Exelon defines a Significant Condition Adverse to Quality as, in part, events as described in the plant Technical Specifications. In Oyster Creek Nuclear Generating Station Technical Specification 1.30, a reportable event is defined as follows: A REPORTABLE EVENT shall be any of those conditions specified in Section 50.73 to 10 CFR Part 50. This plant scram was reported to the NRC under 10 CFR Section 50.73(a)(2)(iv)(A) in Licensee Event Report (LER) ER 2004-003-00/01. The inspectors concluded that since the 2004 scram met the technical specification definition of a reportable event, it also met Exelons definition of a significant condition adverse to quality. The inspectors then concluded that the corrective actions to prevent recurrence that were developed by the root cause analysis were meant to prevent recurrence of the root cause of the scram.

The inspectors noted that in October 2013 Oyster Creek experienced a reactor scram during a planned startup from maintenance outage 1M30. The reactor protection system processed a scram signal on intermediate range monitor channels while withdrawing the source range monitor detectors out of the core. During subsequent troubleshooting activities, Exelon determined that excessive electrical noise spiking appeared on intermediate range monitor channels when operators were moving source range monitor detector 22 into and out of the core. Exelon subsequently entered the issue into their corrective action program (Issue Report 1567196) and performed a root cause evaluation of the event which is documented in root cause evaluation 1567196-08, Intermediate Range Monitor Erratic Behavior Causes Full Reactor Scram during 1M30 Start-up. Exelon determined the root cause of the event was that the previous corrective actions to address the noise susceptibility of the intermediate range monitor channels have been less than adequate. Exelon immediate corrective actions were to repair the source range instrument in order to remove the noise source. The inspectors reviewed the root cause evaluation and determined it to be reasonable.

Analysis.

The inspectors determined that not precluding repetition of a significant condition adverse to quality was a performance deficiency that was within Exelons ability to foresee and correct. Specifically, the corrective actions to prevent recurrence of the May 2004 event were ineffective to preclude repetition of and resulted in a repeat event in October 2013. The inspectors determined that the performance deficiency is more than minor because it is associated with the equipment performance attribute of the initiating events cornerstone and adversely affected the cornerstone objective to limit the likelihood of events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. Using IMC 0609 Appendix A, The Significance Determination Process for Findings At-Power, Exhibit 1, Initiating Events Screening Questions, the inspectors determined that this violation was a transient initiator because it caused a reactor scram. Because the failure to properly ground the intermediate range monitors did not contribute to both the likelihood of a reactor trip and likelihood that mitigation equipment or functions would not be available, the violation screened as very low safety significance (Green),

This finding does not have a cross cutting aspect due to it is not reflective of current performance. The decision to not test intermediate range monitors prior to every reactor startup was made in 2004.

Enforcement.

10 CFR 50, Appendix B, Criterion XVI, Corrective Action states, in part, In the case of significant conditions adverse to quality, the measure shall assure that the cause of the condition is determined and corrective action taken to preclude repetition.

Contrary to the above, Exelons corrective action to prevent recurrence for the May 2004 event did not preclude repetition of the event as evidenced by a repeat event occurring in October 2013. Exelon immediate corrective actions were to repair the source range instrument in order to prevent recurrence. Because this issue is of very low safety significance (Green) and Exelon entered this issue into their corrective action program (Issue Report 1567196) this finding is being treated as an NCV consistent with the NRC Enforcement Policy. (NCV 05000336/2014002-02, Corrective Action to Prevent Recurrence Ineffective to Preclude Repetition of a Significant Condition Adverse to Quality)

Observations The inspectors determined that the root cause evaluation for the October 2013 event was thorough and included considerations for extent of condition. The inspectors reviewed Exelons corrective actions and determined that overall they were appropriate to adequately address the identified deficiencies. The inspectors noted the planned repairs of the intermediate range monitor cables are being appropriately tracked in Exelons corrective action program and work management process and repair activities are planned during the 1R25 refueling outage.

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

Main article: IP 71153

.1 (Closed) Licensee Event Report (LER) 05000219/2013-001-00/01: Automatic Reactor

SCRAM due to an Invalid Intermediate Range Monitor (IRM) SCRAM Signal On October 3, 2013, during a plant startup with the reactor critical and power in the intermediate range, an automatic reactor scram occurred due to an invalid (noise)intermediate range monitor scram signal processed on both reactor protection system trip systems. The scram was caused by both reactor protection system channels receiving simultaneous IRM Hi-Hi signals on intermediate range monitor channels 12, 13, 14, 17, and 18.

The root cause of the event was identified as the susceptibility of the intermediate range monitor channels to electrical noise due to low shield to ground insulation resistance.

Contributing to the event was an internal fault of the source range monitor channel 22 detector which created a significant amount of noise which propagated onto the intermediate range monitor channels resulting in spiking. The source range monitor 22 detector was replaced in a subsequent maintenance outage on November 20, 2013.

The root cause identified corrective actions to repair the intermediate range monitor insulation resistance.

The inspectors did not identify any new issues during the review of the LER. One violation was identified and discussed in Section 4OA2.4 of this report. This LER is closed.

.2 (Closed) Licensee Event Report (LER) 05000219/2013-003-00: Secondary Containment

Integrity Momentarily Declared Inoperable On November 17, 2013, while transiting into the reactor building through the northwest air lock, an Exelon employee opened the outer door to enter the air lock before another employee, who was in the air lock, had finished closing the inner door. This resulted in both the inner and outer air lock doors being open at the same time during power operation. The employees reset the door interlock pin and shut the door, restoring secondary containment integrity after a period of approximately 10 seconds. Exelon entered this issue into their corrective action program and determined that secondary containment was inoperable. Exelon subsequently entered and exited the limiting condition for operation action statement for the period of time that both doors were open, as technical specification definition 1.14 and technical specification 3.5.B.1 require.

Exelon subsequently replaced the door interlock mechanism and performed an extent of condition inspection on the other air lock doors.

The inspectors noted that technical specification 3.5.B.2 states, in part, that upon accidental loss of secondary containment integrity, restore secondary containment integrity within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The inspectors determined that the inadvertent opening of both doors in this scenario was accidental in nature and that secondary containment integrity was restored within the time restrictions imposed by technical specification 3.5.B.2. The inspectors determined that Exelon complied with their technical specifications and no violation of technical specification exists. The inspectors did not identify any violations new issues during the review of the LER. This LER is closed.

.3 (Closed) Licensee Event Report (LER) 05000219/2013-002-00: Manual Scram Due to

Lowering Vacuum On October 6, 2013, during a plant startup from maintenance outage and reactor power ascension at approximately 20% of rated thermal power, main condenser vacuum began to lower. As a result of degrading condenser vacuum operators inserted a manual reactor scram.

Operations and maintenance personnel identified an approximate 1 inch hole on the B condenser steam inlet expansion joint bellows on the south side of B condenser. Exelon confirmed the hole to be an active leak and subsequently the source of condenser vacuum degradation. A temporary leak repair was performed on the expansion joint bellows.

Exelon Power Labs determined that the hole was most likely caused by fatigue cracking of the stainless steel expansion joint bellows and a contributing cause was impact damage at the hole location.

The inspectors did not identify any violations or new issues during the review of the LER. This LER is closed.

4OA5 Other Activities

.1 The table below provides a cross-reference from the 2013 and earlier findings and

associated cross-cutting aspects to the new cross-cutting aspects resulting from the common language initiative. These aspects and any others identified since January 2014 will be evaluated for cross-cutting themes and potential substantive cross-cutting issues in accordance with IMC 0305 starting with the 2014 mid-cycle assessment review.

Finding Old Cross-Cutting Aspect New Cross-Cutting Aspect 05000219/2013004-01 P.1(c) P.2

.2 (Closed) URI 05000219/2013003-03, Difference In Interpretation Of Guidance Contained

NEI 99-02 Submitted Into The Frequently Asked Question Process.

a. Inspection Scope

The inspectors identified that Exelons performance indicator submittal (3rd Quarter 2012) for Unplanned Power Changes per 7000 Critical Hours performance indicator excluded a downpower which the inspectors believed should have been reported as an unplanned downpower based on the inspectors interpretation of the guidance in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, revision 6.

NEI 99-02, Chapter 1, General Reporting Guidance, states that if the NRC staff and the licensee cannot resolve an issue of interpretation or implementation of the guidance contained in NEI 99-02 the issue should be escalated to appropriate industry and NRC management using the frequently asked question (FAQ) process. As a result, the NRC opened an unresolved item (URI) to allow the issue to be addressed through the FAQ process and to determine whether a performance deficiency exists in Exelons reporting of the performance indicator data for Unplanned Power Changes per 7000 Critical Hours.

On April 2, 2014, the FAQ was resolved by the NRC Reactor Oversight Process Working Group and Nuclear Energy Institute Reactor Oversight Process Task Force which determined that the downpower should have been reported under the Unplanned Power Changes per 7000 Critical Hours performance indicator for the 3rd quarter of 2012. The downpower is no longer relevant to the performance indicator calculation because the indicator only considers downpowers occurring in the previous four quarters.

Additionally, the inspectors reviewed the relevant four quarters for which the downpower would have been considered and determined that counting this downpower would not have made the Unplanned Power Changes per 7000 Critical Hours performance indicator change from Green to White.

The inspectors concluded that Exelons submission of inaccurate performance indicator data for the 3rd quarter of 2012 constitutes a violation of 10CFR50.9, Completeness and accuracy of information.

However because this issue did not cause the Unplanned Power Changes per 7000 Critical Hours performance indicator to change from green to white, the violation is considered to be minor. This closes URI 05000219/2013003-03.

b. Findings

No findings were identified.

4OA6 Meetings, Including Exit

On April 24, 2014, 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

R. Peak, Plant Manager

M. Ford, Director, Operations

G. Malone, Director, Engineering

J. Dostal, Director, Maintenance

C. Symonds, Director, Training

M. Chanda, Emergency Preparedness Manager

D. DiCello, Director, Work Management

M. McKenna, Manager, Regulatory Assurance

T. Farenga, Radiation Protection Manager

J. Renda, Manager, Environmental/Chemistry

T. Keenan, Manager, Site Security

P. Bloss, Senior Manager, Plant Engineering

H. Ray, Senior Manager, Design Engineering

E. Swain, Shift Operations Superintendent

J. Chrisley, Regulatory Assurance Specialist

D. Moore, Regulatory Assurance Specialist

K. Paez, Regulatory Assurance Specialist

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

05000219/2014002-01 NCV Untimely Performance of a 50.65 a(4) Risk Evaluation during a Maximum Emergency Generation Action (Section 1R13)

05000219/2014002-02 NCV Corrective Action to Prevent Recurrence Ineffective to Preclude Repetition of a Significant Condition Adverse to Quality (Section 4OA2)

Closed

05000219/2013-001-00/01 LER Automatic Reactor SCRAM due to an Invalid Intermediate Range Monitor (IRM) SCRAM Signal

05000219/2013-002-00 LER Manual Scram Due to Lowering Vacuum (Section 4OA3)

05000219/2013-003-00 LER Secondary Containment Integrity Momentarily Declared Inoperable (Section 4OA3)

05000219/2013003-03 URI Difference In Interpretation Of Guidance Contained NEI 99-02 Submitted Into The Frequently Asked Question Process (Section 4OA5)

LIST OF DOCUMENTS REVIEWED