IR 05000219/2014004
| ML14317A041 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 11/13/2014 |
| From: | Silas Kennedy NRC/RGN-I/DRP/PB6 |
| To: | Pacilio M Exelon Nuclear |
| kennedy, sr | |
| References | |
| IR 2014004 | |
| Download: ML14317A041 (41) | |
Text
UNITED STATES ember 13, 2014
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2014004
Dear Mr. Pacilio:
On September 30, 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 October 22, 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 one violation of NRC requirements, which was of very low safety significance (Green). However, because of the very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation, consistent with Section 2.3.2.a of the NRC Enforcement Policy. If you contest the non-cited violation 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 this 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 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 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/
Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket No. 50-219 License No. DPR-16
Enclosure:
Inspection Report 05000219/2014004 w/Attachment: Supplementary Information
REGION I==
Docket No. 50-219 License No. DPR-16 Report No. 05000219/2014004 Licensee: Exelon Nuclear (Exelon)
Facility: Oyster Creek Nuclear Generating Station Location: Forked River, New Jersey Dates: July 1, 2014 through September 30, 2014 Inspectors: J. Kulp, Senior Resident Inspector A. Patel, Resident Inspector P. Kaufman, Senior Reactor Inspector S. Pindale, Senior Reactor Inspector S. Barr, Senior Emergency Preparedness Inspector E. Burket, Emergency Preparedness Inspector B. Dionne, Health Physicist A. Dugandzic, Project Engineer Approved By: Silas R. Kennedy, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY
IR 05000219/2014004; 07/01/2014 - 09/30/2014; Oyster Creek Nuclear Generating Station (Oyster Creek); Maintaining Emergency Preparedness.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one finding of very low safety significance (Green), which was a non-cited violation (NCV). The significance of most findings is indicated by their color (i.e. greater than Green, or Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP), dated June 19, 2012. Cross-cutting aspects are determined using IMC 0310, Aspects Within Cross-Cutting Areas, dated December 19, 2013. 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: Emergency Preparedness
- Green.
The inspectors identified an NCV of Title 10 of the Code of Federal Regulations (10 CFR) 50.54(q)(2), 10 CFR 50.47(b)(10), and 10 CFR Part 50, Appendix E, Section IV.4, for failing to maintain the effectiveness of the Oyster Creek emergency plan as a result of failing to provide the station evacuation time estimate (ETE) to the responsible offsite response organizations (OROs) by the required date. Exelon entered this issue into its corrective action program as issue reports 1525923 and 1578649. Additionally, Exelon re-submitted a new revision of the Oyster Creek ETE to the NRC on April 4, 2014, and the NRCs review of that ETE is documented in Section 1EP4 of this report.
The performance deficiency is more than minor because it is associated with the Emergency Preparedness cornerstone attribute of procedure quality and adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The ETE is an input into the development of protective action strategies prior to an accident and to the protective action recommendation decision making process during an accident. Inadequate ETEs have the potential to reduce the effectiveness of public protective actions implemented by the OROs. The finding is determined to be of very low safety significance (Green) because it is a failure to comply with a non-risk significant portion of 10 CFR 50.47(b)(10). The cause of the finding is related to a cross-cutting aspect of Human Performance, Documentation, because Exelon did not appropriately create and maintain complete, accurate, and up-to-date documentation [H.7]. (Section 1EP5)
REPORT DETAILS
Summary of Plant Status
Oyster Creek began the inspection period at 100 percent power. On July 7, 2014, operators commenced a reactor shutdown and entered a forced outage (1F34) to conduct an inspection of the installed electromagnetic relief valve solenoids. On July 10, 2014, operators commenced a reactor startup following completion of the electromagnetic relief valve solenoid inspections. On July 11, 2014, operators manually scrammed the reactor due to a loss of condenser vacuum and entered a forced outage (1F35) to conduct repairs. Following completion of repairs, operators commenced a reactor startup on July 14, 2014, and achieved full power on July 16, 2014. On July 16, 2014, operators performed a downpower to 75 percent power to conduct a rod for flow swap and returned to full power later the same day. On August 5, 2014, operators performed a downpower to 70 percent power to conduct a control rod pattern adjustment and returned to full power on August 6, 2014. On August 22, 2014, operators performed a downpower to 70 percent power to conduct a control rod pattern adjustment and returned to full power on August 23, 2014. On September 3, 2014, operators performed a downpower to 90 percent power to conduct core spray system surveillances and returned to full power on September 4, 2014. On September 9, 2014, operators performed a downpower to 90 percent power to conduct core spray system surveillances and returned to full power on September 10, 2014. Operators commenced a plant shutdown on September 14, 2014, took the generator offline, and entered the 1R25 refueling outage on September 15, 2014. Oyster Creek remained shutdown and in 1R25 through the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R04 Equipment Alignment
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
Emergency diesel generator No. 1 while emergency diesel generator No. 2 out of service on July 28, 2014 Emergency diesel generator No. 2 while emergency diesel generator No. 1 out of service on August 4, 2014 Emergency diesel generator No. 1 while emergency diesel generator No. 2 out of service on August 25, 2014 Core spray system II while shutdown cooling system inservice for refueling outage (1R25) on September 17, 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 updated final safety analysis report (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. Documents reviewed for each section of this inspection report are listed in the Attachment.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On September 23 and 24, 2014, the inspectors performed a complete system walkdown of accessible portions of the emergency service water system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment line-up check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
1R05 Fire Protection
Resident Inspector Quarterly Walkdowns (71111.05Q - 3 samples)
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Reactor building 23 elevation on August 12, 2014 Reactor building 51 elevation on August 12, 2014 Reactor building 75 elevation on August 12, 2014
b. Findings
No findings were identified.
1R06 Flood Protection Measures
Annual Review of Cables Located in Underground Bunkers/Manholes
a. Inspection Scope
The inspectors conducted an inspection of underground bunkers/manholes subject to flooding that contain cables whose failure could disable risk-significant equipment. The inspectors performed visual observations of risk-significant areas with assistance from a camera, including the SBO3 (MH-743-3) and SBO4 (MH-743-4), containing 13.8kV cables from the combustion turbine, and to verify that the cables were not submerged in water, that cables and/or splices appeared intact, and to observe the condition of cable support structures. An additional manhole sample included was the start-up transformer A&B (MH-724-1), containing 34.5kV cables from the start-up transformers. The inspectors also ensured that drainage was provided and functioning properly in areas where dewatering devices were not installed. The inspectors also verified that Exelon took action to keep the cables dry and assess cable degradation in accordance with Exelons aging management program for inaccessible power cables.
b. Findings
No findings were identified.
1R07 Heat Sink Performance (711111.07A - 1 sample)
a. Inspection Scope
The inspectors reviewed the containment spray system I heat exchangers to determine their readiness and availability to perform their safety function. The inspectors reviewed the design basis for the components and verified Exelons commitments to NRC Generic Letter 89-13. The inspectors reviewed the results of previous inspections of the containment spray system 1 heat exchangers. The inspectors discussed the results of the most recent inspection with engineering staff including the as-found and as-left conditions. The inspectors verified that Exelon initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum number allowed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
Quarterly Review of Licensed Operator Performance in the Main Control Room (71111.11 - 2 samples)
a. Inspection Scope
The inspectors observed licensed operator performance during a plant startup from a forced outage (1F35) on July 14, 2014. The inspectors also observed licensed operator performance response during an unplanned low instrument air pressure condition on August 6, 2014. The inspectors observed infrequently performed test or evolution briefings that were performed and met the requirements of Exelon procedure HU-AA-1211, Pre-Job Briefings, Revision 9. Additionally, the inspectors observed control room operator performance to verify that procedure use, crew communications, and coordination of activities between work groups similarly met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on structure, system, or component performance and reliability.
The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For each sample selected, the inspectors verified that the structure, system or component was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff was reasonable. As applicable, for a structure, system, or component classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return the structure, system or component to (a)(2). Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
Forked River combustion turbine No. 2 on August 14, 2014 Electromatic relief valves on September 22, 2014
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.
The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with 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.
Emergency diesel generator No. 2 out of service on July 28, 2014 Emergency diesel generator No. 1 and containment spray system I out of service on August 4, 2014 Emergency diesel generator No. 2 out of service on August 25, 2014 Core spray system I out of service on September 4, 2014 Refueling outage yellow shutdown risk due to decay heat removal on September 16, 2014
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
Electromatic relief valve solenoids degraded condition on September 17, 2014 Emergency diesel generator No. 1 due to common cause evaluation for the emergency diesel generator No. 2 cooling fan shaft failure on July 28, 2014 Emergency diesel generator No. 2 governor with low oil level on August 4, 2014 Emergency diesel generator No. 2 following engine overspeed trip on August 25, 2014 Emergency diesel generator No. 2 following water found in lube oil system on August 28, 2014 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to Exelons evaluations to determine whether the components or systems were operable.
Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
No findings were identified.
1R18 Plant Modifications
Permanent Modifications
a. Inspection Scope
The inspectors evaluated a modification to the change the material of electromatic relief valve solenoid internal components. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the material change, including replacement of electromatic relief valve solenoid actuator internal components. The inspectors also reviewed revisions to the purchase orders to ensure the materials were changed.
The inspectors also evaluated a modification of the design of the electromatic relief valve solenoid actuators. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification.
In addition, the inspectors reviewed modification documents associated with the design change, including replacement of electromatic relief valve solenoid actuators and relocation of vibration susceptible internal components of the actuators. The inspectors also reviewed revisions to the maintenance refurbishment procedure and interviewed engineering and maintenance personnel to ensure the procedure could be reasonably performed.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
Electromatic relief valves following electromatic relief valve solenoid refurbishment on July 10, 2014 Emergency diesel generator No. 2 following cooling fan shaft replacement on July 30, 2014 Emergency diesel generator No. 1 following cooling fan shaft inspections on August 4, 2014 Emergency diesel generator following crankcase pressure detector replacement on August 28, 2014 V-31-5, reactor head cooling inlet valve, replacement on September 23, 2014 Electromatic relief valves replacement following electromatic relief valve solenoid actuator internal components design change on September 30, 2014
b. Findings
No findings were identified.
1R20 Refueling and Other Outage Activities
a. Inspection Scope
The inspectors reviewed the stations work schedule and outage risk plan for the Oyster Creek forced outage 1F34, on July 7, 2014. On July 10, 2014, Oyster Creek commenced startup and subsequently manually scrammed the reactor on July 11, 2014, due to low vacuum conditions in the condenser.
The inspectors also reviewed the stations work schedule and outage risk plan for the Oyster Creek forced outage 1F35 on July 11, 2014, following a manual scram in response to a low condenser vacuum condition. On July 14, 2014, Oyster Creek commenced startup and returned to full power on July 16, 2014.
The inspectors also reviewed the stations work schedule and outage risk plan for the Oyster Creek maintenance and refueling outage (1R25), which started on September 15, 2014, and ongoing at the end of the inspection period. The completion of this sample will be documented in the 4th quarter integrated inspection report.
The inspectors reviewed Exelons development and implementation of outage plans and schedules to verify that risk, industry experience, previous site-specific problems, and defense-in-depth were considered. During the outage, the inspectors observed portions of the shutdown and cooldown processes and monitored controls associated with the following outage activities:
Configuration management, including maintenance of defense-in-depth, commensurate with the outage plan for the key safety functions and compliance with the applicable technical specifications when taking equipment out of service Implementation of clearance activities and confirmation that tags were properly hung and that equipment was appropriately configured to safely support the associated work or testing Status and configuration of electrical systems and switchyard activities to ensure that technical specifications were met Monitoring of decay heat removal operations Impact of outage work on the ability of the operators to operate the spent fuel pool cooling system Reactor water inventory controls, including flow paths, configurations, alternative means for inventory additions, and controls to prevent inventory loss Activities that could affect reactivity Maintenance of secondary containment as required by technical specifications Refueling activities, including fuel handling and fuel receipt inspections Identification and resolution of problems related to refueling outage activities
b. Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant structures, systems, and components to assess whether test results satisfied technical specifications, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
Unidentified reactor coolant system (RCS) leak rate verification on August 1, 2014 Core spray system I valve operability and in-service test on September 9, 2014 Core spray system I pump operability and in-service test on September 10, 2014 V-31-5, reactor head cooling inlet valve, local leak rate test on September 20, 2014
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP2 Alert and Notification System Evaluation
a. Inspection Scope
An onsite review was conducted to assess the maintenance and testing of the alert and notification system (ANS). During this inspection, the inspectors conducted a review of the ANS testing and maintenance programs. The inspectors reviewed the associated ANS procedures and the Federal Emergency Management Agency approved ANS Design Report to ensure compliance with design report commitments for system maintenance and testing. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 2. 10 CFR 50.47(b)(5) and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP3 Emergency Response Organization Staffing and Augmentation System
a. Inspection Scope
The inspectors conducted a review of the Oyster Creek Emergency Response Organization (ERO) augmentation staffing requirements and the process for notifying and augmenting the ERO. The review was performed to verify the readiness of key Exelon staff to respond to an emergency event and to verify Exelons ability to activate their emergency response facilities (ERF) in a timely manner. The inspectors reviewed the Oyster Creek Emergency Plan for ERF activation and ERO staffing requirements, the ERO duty roster, applicable station procedures, augmentation test reports, the most recent drive-in drill reports, and corrective action reports related to this inspection area.
The inspectors also reviewed a sample of ERO responder training records to verify training and qualifications were up to date. The inspection was conducted in accordance with NRC Inspection Procedure 71114, Attachment 3. 10 CFR 50.47(b)
- (2) and related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
No findings were identified.
1EP4 Emergency Action Level and Emergency Plan Changes
a. Inspection Scope
Staff from the Office of Nuclear Security and Incident Response (NSIR) performed an in-office review of the latest revision to the ETE Analysis for Oyster Creek located under ADAMS accession number ML14101A164, as listed in the Attachment.
The staff performed a review using the guidance provided in NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies. The Updated ETE was found to be complete in accordance with 10 CFR Part 50, Appendix E.IV.3. The NRC review was only intended to verify consistent application of the ETE guidance contained in NUREG/CR-7002; and therefore remains subject to future NRC inspection in its entirety.
b. Findings
No findings were identified.
1EP5 Maintaining Emergency Preparedness
a. Inspection Scope
The inspectors reviewed a number of activities to evaluate the efficacy of Exelons efforts to maintain the Oyster Creek emergency preparedness (EP) program. The inspectors reviewed: memorandums of agreement with offsite agencies; the 10 CFR 50.54(q) Emergency Plan change process and practice; Oyster Creeks maintenance of equipment important to EP; records of ETE population evaluation; and provisions for, and implementation of, primary, backup, and alternate ERF maintenance. The inspectors also verified Exelons compliance at Oyster Creek with new NRC EP regulations regarding: emergency action levels for hostile action events; protective actions for on-site personnel during events; emergency declaration timeliness; ERO augmentation and alternate facility capability; ETE updates; on-shift ERO staffing analysis; and ANS back-up means.
Additionally, NRC EP rulemaking, which became effective on December 23, 2011, added a new regulation which required licensees to develop an ETE analysis and submit it to the NRC by December 23, 2012. This inspection included a follow-up of issues identified by the NSIR staff during its review of the Exelon submittal of the ETEs for the ten sites that it operated at the time. The NSIR staff related those issues to Exelon, which provided responses through 2013 and into 2014. During this inspection period, regional EP inspectors reviewed applicable Exelon documents, conducted discussions with Exelon personnel, and provided assessment of the Exelon response.
The inspectors further evaluated Exelons ability to maintain Oyster Creeks EP program through their identification and correction of EP weaknesses, and by reviewing a sample of drill reports, actual event reports, self-assessments, and 10 CFR 50.54(t) reviews.
Also, the inspectors reviewed a sample of EP-related condition reports initiated at Oyster Creek from October 2012 through September 2014. The inspection was conducted in accordance with NRC Inspection Procedure 71114.05. 10 CFR 50.47(b) and the related requirements of 10 CFR Part 50, Appendix E, were used as reference criteria.
b. Findings
Introduction:
The inspectors identified a Green NCV of 10 CFR 50.54(q)(2) for failing to maintain the effectiveness of the Oyster Creek emergency plan. Specifically, Exelon failed to provide the station ETE to responsible OROs and failed to update its site-specific protective action strategies as outlined in the requirements listed in 10 CFR 50.47(b)(10), and Section IV, Paragraph 4, of Appendix E to 10 CFR Part 50.
Description:
On November 23, 2011, the NRC issued final new and amended EP regulations (76 Federal Register 72560) that required all licensees to update the ETE on a periodic basis. This rulemaking became effective on December 23, 2011. The rulemaking also added a new regulation, 10 CFR Part 50, Appendix E, Section IV.4, which required licensees to develop an ETE analysis using the most recent decennial census data and submit it to the NRC within 365 days of December 23, 2011.
Concurrently, with the issuance of the rulemaking, the NRC published a new report entitled Criteria for Development of Evacuation Time Estimate Studies, NUREG/CR-7002. The Statements of Consideration for the rulemaking (76 Federal Register 72580)identified that the NRC staff would review the submitted ETEs for completeness using that document. The Statements also provided that the guidance of NUREG/CR-2002 was an acceptable template to meet the requirements and licensees should use the guidance or an appropriate alternative.
By individual letters dated December 12, 2012, Exelon submitted the ETEs for the sites for which it held the operating licenses, including Oyster Creek. By letter dated January 23, 2013, Exelon submitted the NUREG/CR-7002 checklists for the ETEs that identified where a particular criterion was addressed in the ETEs, facilitating the NRC review.
As provided in the Statements of Consideration, the NRC staff performed a completeness review using the checklists and found the ETEs (including the ETEs for Oyster Creek) to be incomplete due to common and site-specific deficiencies. The staff discussed its concerns regarding the completeness of the ETEs, in a teleconference with Exelon conducted on June 10, 2013. On September 5, 2013, Exelon resubmitted the ETEs and the associated checklists for its sites. The NRC staff performed another completeness review and again found the ETEs to be incomplete. Examples of information missing from the submittal included: peak and average attendance were not stated (NUREG/CR-7002 Criteria Item 2.1.2.a); the ETE used a value based on campsite and hotel capacity, vice an average value (2.1.2.b); basis for speed and capacity reduction factors due to weather was not provided (3.4.b); snow removal was not addressed (3.4.c); no bus routes or plans were included in the ETE analysis (4.1.2.a); and no discussion on the means of evacuating ambulatory and non-ambulatory residents was included (4.1.2.b). The staff communicated the various ETE issues to Exelon through several telephone conference calls. Upon identification, Exelon entered this issue into its corrective action program as issue reports 1525923 and 1578649.
Exelon submitted a third ETE for Oyster Creek on April 4, 2014, and the NRCs review of that ETE is documented in Section 1EP4 of this report.
Analysis:
The inspectors determined that the failure to submit a complete updated ETE for Oyster Creek by December 23, 2012, is a performance deficiency because Exelon failed to meet a regulatory requirement that was reasonably within its ability to foresee and correct, and should have been prevented, for both the December 12, 2012, and September 5, 2013, submittals.
Using IMC 0612, Appendix B, Issue Screening, the inspectors determined that the performance deficiency is associated with the Emergency Preparedness cornerstone attribute of procedure quality and is more than minor because it adversely affected the cornerstone objective of ensuring that the licensee is capable of implementing adequate measures to protect the health and safety of the public in the event of a radiological emergency. The ETE is an input into the development of protective action strategies prior to an accident and to the protective action recommendation decision making process during an accident. Inadequate ETEs had the potential to reduce the effectiveness of public protective actions implemented by the OROs.
The inspectors utilized IMC 0609, Appendix B, Emergency Preparedness Significance Determination Process (SDP), to determine the significance of the performance deficiency. The performance deficiency was associated with planning standard 10 CFR 50.47(b)(10). EP SDP Table 5.10-1, Significance Examples §50.47(b)(10), provides two Green significance examples: ETEs and updates to the ETEs were not provided to responsible OROs, and The current public protective action strategies documented in emergency preparedness implementing procedures (EPIPs) are not consistent with the current ETE. The inspectors concluded that, because the performance deficiency delayed the NRCs approval of the Oyster Creek ETE, the ETE was not provided to the site OROs nor was it used to inform the site EPIPs as required by 10 CFR 50.47(b)(10),and Section IV, Paragraph 4 of Appendix E to 10 CFR Part 50. Therefore, in accordance with EP SDP Table 5.10-1, this was determined to be a finding of very low safety significance (Green).
The cause of the finding had a cross-cutting aspect in the area of Human Performance, Documentation, because Exelon personnel did not create and maintain complete, accurate and, up-to-date documentation. Specifically, the EP organization did not develop the Oyster Creek ETE as required by the new regulation introduced by the NRCs EP Rule [H.7].
Enforcement:
10 CFR 50.54(q)(2) states, in part, that a licensee shall follow and maintain in effective emergency plans which meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to this part. 10 CFR 50.47(b)(10), states, in part, that licensees shall develop an evacuation time estimate and update it on a periodic basis.
10 CFR Part 50 Appendix E, Section IV.4, states that within 365 days of December 23, 2011, nuclear power reactor licensees shall develop an ETE analysis and submit it under § 50.4.
Contrary to the above, the ETEs submitted by Exelon on December 12, 2012, and on September 5, 2013, for Oyster Creek were found to be inadequate. Upon identification, Exelon implemented immediate corrective actions by entering this issue into its corrective action program as issue reports 1525923 and 1578649, and revising the ETE to satisfy NRC requirements. Because this finding is of very low safety significance (Green) and was entered into Exelons corrective action program, this issue is being treated as an NCV consistent with Section 2.3.2.a of the Enforcement Policy. (NCV 05000219/2014004-01: Inadequate Evacuation Time Estimate Submittals)
RADIATION SAFETY
Cornerstone: Occupational Radiation Safety
2RS1 Radiological Hazard Assessment and Exposure Controls
a. Inspection Scope
During the period of August 11-14, 2014, and September 22-26, 2014, the inspectors reviewed Exelon performance in assessing the radiological hazards and exposure control in the workplace. The inspectors used the requirements in 10 CFR Part 20 and guidance in Regulatory Guide (RG) 8.38, Control of Access to High and Very High Radiation Areas for Nuclear Plants, technical specifications, and the Exelon procedures required by technical specifications as criteria for determining compliance.
Inspection Planning The inspectors reviewed 2013 and 2014 performance indicators for the occupational exposure cornerstone for Oyster Creek. The inspectors reviewed the results of radiological protection (RP) program audits. The inspectors reviewed any reports of operational occurrences related to occupational radiation safety since the last inspection.
Radiological Hazard Assessment The inspectors reviewed changes to plant operations since the last inspection that represent a significant new radiological hazard for onsite workers or members of the public. The inspectors evaluated whether Exelon assessed the potential impact and has implemented appropriate controls.
The inspectors reviewed the following documents:
Radiological surveys associated with the following radiation work permits (RWPs):
o RWP OC 14-01700 Torus Vacuum Breaker Surveillance; o RWP 14-00406, 1R25 Refueling Floor Activities; o RWP 14-00508, 1R25 Drywell Scaffolding; o RWP 14-00511, 1R25 Drywell Control Rod Drive (CRD) Exchange Activities and Support; o RWP 14-00519, 1R25 Drywell In-service Inspection (ISI), Intergranular Stress Corrosion Cracking (IGSCC), Flow-Accelerated Corrosion (FAC) Inspection.
Drywell air sample locations and the use of continuous air monitors Loose contamination monitoring Radiological surveys from the Torus and Spent Fuel Pool heat exchangers Instructions to Workers The inspectors selected five radioactive material containers and assessed whether the containers were labeled and controlled in accordance with 10 CFR Part 20 requirements. The inspectors reviewed RWPs used to access high radiation areas (HRA) and evaluated if the specified work control instructions and control barriers were consistent with technical specification requirements for HRA.
Contamination and Radioactive Material Control The inspectors observed five locations where Exelon monitors potentially contaminated material leaving the radiological control area and inspected the methods used for control, survey, and release of these materials from these areas. The inspectors observed the performance of personnel surveying and releasing material for unrestricted use and evaluated whether the work was performed in accordance with plant procedures. The inspectors assessed whether the radiation monitoring instrumentation used for equipment release and personnel contamination surveys had appropriate sensitivity for the type(s) of radiation present.
The inspectors evaluated whether any recent transactions involving nationally tracked sources were reported in accordance with10 CFR Part 20 requirements.
Radiological Hazards Control and Work Coverage The inspectors evaluated ambient radiological conditions and performed independent radiation measurements during walk-downs of the facility. The inspectors assessed whether the conditions were consistent with applicable posted surveys, RWPs, and associated worker briefings.
The inspectors examined Exelon physical and programmatic controls for highly activated and contaminated materials stored within the spent fuel. The inspectors assessed whether appropriate controls were in place to preclude inadvertent removal of these materials from the pool.
The inspectors examined the posting and physical controls for selected HRAs and Locked High Radiation Areas (LHRAs) to verify conformance with the occupational performance indicator.
The inspector evaluated the radiological controls, exposure monitoring, and radiation protection job coverage for the RWPs listed above.
Risk-Significant HRAs and LHRAs Controls The inspectors discussed with the Radiation Protection Manager the controls and procedures for high-risk HRAs and LHRAs. The inspectors discussed with first-line health physics supervisors the controls in place for areas that have the potential to become LHRAs during certain plant operations. The inspectors assessed whether plant operations required communication beforehand with the health physics group, so as to allow timely actions to post, control, and monitor the radiation hazards.
Radiation Worker Performance The inspectors observed the performance of radiation workers with respect to stated RP work requirements. The inspectors assessed whether workers were aware of the radiological conditions in their workplace and the RWP controls/limits in place, and whether their behavior reflected the level of radiological hazards present. The inspector reviewed radiological problem reports since the last inspection that attributed the cause of the event to human performance errors.
RP Technician Proficiency The inspectors observed the performance of the RP technicians with respect to controlling radiation work. The inspectors evaluated whether technicians were aware of the radiological conditions in their workplace and the RWP controls/limits, and whether their behavior was consistent with their training and qualifications with respect to the radiological hazards and work activities.
b. Findings
No findings were identified.
2RS2 Occupational ALARA Planning and Controls
The inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors used the requirements in 10 CFR Part 20, RG 8.8, RG 8.10, technical specifications, and Exelon procedures required by technical specifications as criteria for determining compliance.
a. Inspection Scope
The inspectors reviewed information regarding Oyster Creek collective dose history, current exposure trends, ongoing and planned activities in order to assess current performance and exposure challenges. The inspectors reviewed the plants three year rolling average collective exposure. The inspectors compared the site-specific trends in collective exposures against the industry average values and those values from similar vintage reactors. In addition, the inspectors reviewed any changes in the radioactive source term by reviewing the trend in average contact dose rate with recirculation piping.
The inspectors reviewed site-specific procedures associated with maintaining occupational exposures ALARA, which included a review of processes used to estimate and track exposures from specific work activities.
The inspectors reviewed the ALARA work activity evaluations, exposure estimates, and exposure reduction requirements. The inspectors assessed whether Exelon planning identified appropriate dose reduction techniques; considered alternate dose reduction features; and estimated reasonable dose goals. The inspectors determined whether Exelon work planning considered the use of remote technologies as a means to reduce dose and the use of dose reduction insights from industry operating experience and plant-specific lessons learned. The inspectors assessed the integration of ALARA requirements into work procedure and RWP documents.
The inspectors reviewed the assumptions and basis for the current annual collective dose estimate for accuracy. The inspectors reviewed applicable procedures to determine the methodology for estimating exposures from specific work activities and for department and station collective dose goals. The inspectors evaluated Exelons method of adjusting exposure estimates, or re-planning work, when unexpected changes in scope or emergent work were encountered.
The inspectors used Exelon records to determine the historical trends and current status of plant source term known to contribute to elevated facility collective dose. The inspectors assessed whether Exelon had made allowances or developed contingency plans for expected changes in the source term as the result of changes in plant fuel performance issues or changes in plant primary chemistry.
The inspectors observed radiation worker and RP technician performance during work activities being performed in radiation areas, airborne radioactivity areas, and HRAs.
The inspectors evaluated whether workers demonstrated the ALARA philosophy in practice and whether there were any procedure or RWP compliance issues.
ALARA Work Planning The inspectors reviewed ALARA planning estimates and results achieved for the following RWPs:
RWP 14-00406, 1R25 Refueling Floor Activities; RWP 14-00508, 1R25 Drywell Scaffolding; RWP 14-00511, 1R25 Drywell CRD Exchange Activities and Support; RWP 14-00519, 1R25 Drywell ISI, IGSSC, FAC Inspection.
Source Term Reduction and Control The inspectors reviewed records of source term trends and current status of plant source term reduction plans and contingency plans for changes in source term.
b. Findings
No findings were identified.
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The inspectors verified in-plant airborne concentrations are being controlled consistent with ALARA principles and the use of respiratory protection devices. The inspectors used the requirements in 10 CFR Part 20, the guidance in RG 8.15, RG 8.25, NUREG-0041, technical specifications, and procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the following:
UFSAR to identify areas with ventilation systems or airborne monitoring instrumentation The respiratory protection program Procedures for maintenance, inspection, use of respiratory protection equipment, and air quality maintenance Engineering Controls The inspectors reviewed the following:
Procedures for use of installed plant ventilation systems Observed two temporary ventilation system setups Observed two installed ventilation systems including the alarm setpoints Threshold criteria for evaluating levels of airborne beta-emitting and alpha-emitting radionuclides Use of Respiratory Protection Devices The inspectors reviewed the following:
Two work activities where respiratory protection devices were used The use of respirator protection factors Respiratory protection devices were certified for use Two individual respirator use qualifications
b. Findings
No findings were identified.
2RS4 Occupational Dose Assessment
a. Inspection Scope
The inspectors verified that occupational dose is appropriately monitored, assessed, and reported. The inspectors used the requirements in 10 CFR Part 20, RG 8.13, RG 8.36, RG 8.40, technical specifications, and procedures required by technical specifications as criteria for determining compliance.
Inspection Planning
The inspectors reviewed the following:
RP program audit National Voluntary Laboratory Accreditation Program dosimetry report procedures associated with dosimetry operations and dose assessments External Dosimetry The inspectors reviewed the following:
Onsite storage of dosimeters Use of electronic personal dosimeters Eight dosimetry occurrence reports or corrective action program documents Routine Bioassay (In Vivo)
The inspectors reviewed the following:
Procedures used to assess internal dose The whole body count measurement process Portal radiation monitor use as a passive monitoring system Inclusion of hard-to-detect radionuclides in internal dose assessments, if applicable
Internal Dose Assessment - Airborne Monitoring
The inspectors reviewed the dose assessment procedures based on airborne monitoring.
Declared Pregnant Workers The inspectors reviewed Exelons means of communication to workers of the risks of radiation exposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and the specific process to be used for (voluntarily) declaring a pregnancy.
Exelon had no declarations of pregnancy or internal dose assessments for declared pregnant workers during this inspection period.
Shallow Dose Equivalent Exelon had no documented dose assessments for shallow dose equivalent during this inspection period.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA1 Performance Indicator Verification
.1 Safety System Functional Failures (IE05) (1 sample)
a. Inspection Scope
The inspectors sampled Exelons submittals for the Safety System Functional Failures performance indicator for Oyster Creek for the period of April 1, 2013 through March 31, 2014. To determine the accuracy of the performance indicator data reported during those periods, inspectors used definitions and guidance contained in the Nuclear Energy Institute (NEI) Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7, and NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 10 CFR 50.73." The inspectors reviewed Exelons operator narrative logs, operability assessments, maintenance rule records, maintenance work orders, condition reports, event reports and NRC integrated inspection reports to validate the accuracy of the submittals.
b. Findings
No findings were identified.
.2 Unplanned Power Changes (IE03) (1 sample)
a. Inspection Scope
The inspectors reviewed Exelons submittal for the Unplanned Power Changes performance indicator for the period April 1, 2013 through March 31, 2014. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors reviewed control room logs, NRC integrated inspection reports, and plant process computer data, and compared that information to the data reported by Exelon to validate the accuracy of the submittal.
b. Findings
No findings were identified.
.3 RCS Specific Activity and RCS Leak Rate (2 samples)
a. Inspection Scope
The inspectors reviewed Exelons submittal for the RCS specific activity and RCS leak rate performance indicators for the period of April 1, 2013 through June 30, 2014. To determine the accuracy of the performance indicator data reported during those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, Regulatory Assessment Performance Indicator Guideline, Revision 7. The inspectors also reviewed RCS sample analysis logs and control room logs of daily measurements for RCS leakage, and compared that information to the data reported by the performance indicator. Additionally, the inspectors observed surveillance activities that determined the RCS identified leakage rate.
b. Findings
No findings were identified.
.4 Performance Indicator Verification
a. Inspection Scope
The inspectors reviewed data for the following three EP Performance Indicators:
- (1) drill and exercise performance;
- (2) ERO drill participation; and
- (3) ANS reliability. The last NRC EP inspection at Oyster Creek was conducted in the fourth calendar quarter of 2013. Therefore, the inspectors reviewed supporting documentation from EP drills and equipment tests from the fourth calendar quarter of 2013 through the second calendar quarter of 2014 to verify the accuracy of the reported performance indicator data. The review of the performance indicators was conducted in accordance with NRC Inspection Procedure 71151. The acceptance criteria documented in NEI 99-02, Regulatory Assessment Performance Indicator Guidelines, Revision 7, was used as reference criteria.
b. Findings
No findings were identified.
4OA2 Problem Identification and Resolution
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, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening meetings.
b. Findings
No findings were identified.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
Plant Events
a. Inspection Scope
For the plant event listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant event to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, Reactive Inspection Decision Basis for Reactors, for consideration of potential reactive inspection activities. As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelons follow-up actions related to the events to assure that Exelon implemented appropriate corrective actions commensurate with their safety significance.
Loss of vacuum scram during startup from a forced outage (1F34) on July 11, 2014
b. Findings
No findings were identified.
4OA5 Other Activities
Institute of Nuclear Power Operations (INPO) Report Review
a. Inspection Scope
The inspectors reviewed the final report for the INPO plant assessment of Oyster Creek conducted in February 2014. The inspectors reviewed these reports to ensure that any issues identified were consistent with NRC perspectives of Exelon performance and to determine if INPO identified any significant safety issues that required further NRC follow-up.
b. Findings
No findings were identified.
4OA6 Meetings, Including Exit
On October 22, 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
- J. Dostal, Plant Manager
- M. Ford, Director, Operations
- G. Malone, Director, Engineering
- D. Chernesky, Acting Director, Maintenance
- C. Symonds, Director, Training
- D. DiCello, Director, Work Management
- M. Chanda, Oyster Creek Emergency Preparedness Manager
- 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
- D. Moore, Regulatory Assurance Specialist
- K. Paez, Regulatory Assurance Specialist
- K. Aleshire, Exelon Corporate Emergency Preparedness Manager
- V. Cwietniewicz, Mid-Atlantic Corporate Emergency Preparedness Manager
- M. Jesse, Regulatory Assurance Manager
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000219/2014004-01 NCV Inadequate Evacuation Time Estimate Submittals (Section 1EP5)