IR 05000219/2012002
| ML12123A655 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/02/2012 |
| From: | Hunegs G NRC/RGN-I/DRP/PB6 |
| To: | Pacilio M Exelon Nuclear, Exelon Generation Co |
| HUNEGS, GK | |
| References | |
| IR-12-002 | |
| Download: ML12123A655 (36) | |
Text
{{#Wiki_filter:UNITED STATES May 2, 2012
SUBJECT:
OYSTER CREEK NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2012002
Dear Mr. Pacilio:
On March 31, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Generating Station. The enclosed inspection report documents the inspection results, which were discussed on April 16, 2012 with Mr. M. Massaro 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 Severity Level IV non-cited violation (NCV) and three NRC-identified finding of very low safety significance (Green). These findings were determined to involve violations of NRC requirements. Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report. 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 NCVs, consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspector at Oyster Creek Generating Station. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspector at Oyster Creek Generating Station. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely, /RA/ Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-219 License Nos.: DPR-16
Enclosure:
Inspection Report 05000219/2012002 w/Attachment: Supplementary Information
REGION I== Docket No.: 50-219 License No.: DPR-16 Report No.: 05000219/2012002 Licensee: Exelon Nuclear Facility: Oyster Creek Generating Station Location: Forked River, New Jersey Dates: January 1, 2012 - March 31, 2012 Inspectors: J. Kulp, Senior Resident Inspector J. Ambrosini, Resident Inspector L. Kern, Project Engineer P. Kaufman, Senior Reactor Inspector J. Tomlinson, Operations Engineer Approved By: Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000219/2012002, 01/01/2012 - 03/31/2012; Exelon Energy Company, LLC, Oyster
Creek Generating Station; Licensed Operator Requalification Program, Maintenance Risk Assessments and Emergent Work, Control, Problem Identification and Resolution.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one Severity Level IV non-cited violation (NCV) and three findings of very low safety significance (Green), which were also NCVs. The significance of most findings is indicated by their color (Green, White, Yellow, Red)using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, Components Within Cross-Cutting Areas. Findings for which the SDP does not apply may be Green, or be assigned a severity level after NRC management review. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.
Cornerstone: Initiating Events
- Green.
The inspectors identified a Green NCV of Technical Specification (TS) 6.8.1a, Procedures and Programs, for improperly implementing technical specifications requirements into abnormal operation procedures for the reactor recirculation system. The inspectors determined this procedural inadequacy was a performance deficiency that was within Exelons ability to foresee and correct. Exelons revised the abnormal operating procedure for the reactor recirculation system to restore compliance as a corrective action.
Exelon entered this issue into the corrective action program for resolution as IR 1323171.
There were no similar examples in Appendix E to Inspection Manual Chapter (IMC) 0612, but the inspectors determined this finding was more than minor because this performance deficiency could be reasonably viewed as a precursor to a significant event and if left uncorrected, this performance deficiency would have the potential to lead to a more significant safety concern. Specifically, if the recirculation loop was returned to service after being isolated while the reactor was at power, then a significant cold water transient could occur which could result in a reactor trip as described in UFSAR Section 15.4.4. This finding affects the configuration control attribute of the Initiating Events cornerstone objective of limiting the likelihood of those events that upset plant stability and challenge critical safety functions during shutdown as well as power operations. The inspectors determined that this finding was a transient initiator that did not contribute to both the likelihood of a reactor trip and the likelihood that mitigation equipment or functions would not be available. Therefore, the inspectors determined the finding to be of very low safety significance (Green).
The inspectors determined that it was not appropriate to assign a cross-cutting aspect to this finding as the performance deficiency had existed since the original issue of the procedure in 2000 and was not indicative of current performance. (Section 1R11)
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green NCV of 10 CFR 50.65(a)(4), Requirements for monitoring the effectiveness of maintenance at nuclear power plants, when Exelon did not implement risk management actions to manage the risk associated with the performance of surveillance activities on containment spray system 1. The inspectors determined that not implementing risk management actions to mitigate an increased overall maintenance risk was a performance deficiency that was within Exelons ability to foresee and correct.
Exelons immediate corrective actions included resetting the crew clock and briefing the remaining operating crews on the details of this event. Exelon entered this issue into the corrective action program for resolution as IR 1324575.
The inspectors determined that this issue is more than minor because it is similar to example 7.g in Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues in that key safety functions were significantly degraded without sufficient compensation. The inspectors determined that this finding affected both the Mitigating Systems and Barriers Integrity cornerstones. The inspectors used Inspection Manual Chapter 0609, Appendix K, Maintenance Risk Assessment and Risk Management Significance Determination Process, flowchart 2, Assessment of Risk Management Actions, to analyze the finding. As 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 inspectors determined that the finding is of very low safety significance (Green).
This finding has a crosscutting aspect in the area of Human Performance, Work Practices, because Exelons supervisory oversight of work activities did not support nuclear safety.
[H.4.(c)] (Section 1R13)
Cornerstone: Barrier Integrity
- Green.
The inspectors identified a Green NCV of TS 6.8.1a for not maintaining operating procedures in accordance with NRC and industry standards which required prudent, conservative lowering of reactor power prior to performing evolutions which had the potential to affect reactivity. The inspectors determined this procedural inadequacy was a performance deficiency that was within Exelons ability to foresee and correct. Exelon has documented no immediate corrective actions but has entered this issue into the corrective action program for resolution as IR 1355895.
There were no similar examples in Inspection Manual Chapter (IMC) 0612, Appendix E, Examples of Minor Issues, but the inspectors determined this finding was more than minor because it affected the configuration control aspect of the Barrier Integrity cornerstone.
Specifically, reactivity control and reactor manipulations are used to preserve the integrity of the fuel cladding in order to provide reasonable assurance that physical design barriers protect the public from radionuclide releases caused by accidents or events. The inspectors used IMC 0609.04, Attachment 1, Phase 1 - Initial Screening and Characterization of Findings and determined the finding to be of very low safety significance (Green) because it did not affect the RCS barrier or the fuel barrier.
This finding has a cross-cutting aspect in the area of Human Performance, Decision Making, where the licensee uses conservative assumptions in decision making and adopts a requirement to demonstrate that the proposed action is safe in order to proceed rather than a requirement to demonstrate that it is unsafe in order to disapprove the action. [H.1.(b)]
(Section 4OA2)
Severity Level IV. The inspector identified a Severity Level IV non-cited violation of 10 CFR 55.21, Medical Examination, for two licensed reactor operators failing to have a medical examination by a physician every two years. This violation was identified by an NRC inspector May 25, 2011 and Exelon entered it into their corrective action program and performed the medical examinations on the two reactor operators.
The inspectors determined that the failure to perform the biennial medical examinations for two licensed reactor operators in accordance with 10 CFR 55.21 was a performance deficiency that was reasonably within Exelons ability to foresee and correct. Because the issue impacted the regulatory process, in that the medical conditions of two licensed operators were not reviewed and reported to the NRC, thereby delaying the NRCs opportunity to review the matter, the inspectors evaluated this performance deficiency in accordance with the traditional enforcement process. Using example 6.4.d.1 from the NRC Enforcement Policy, the inspector determined that the violation was a SL IV (more than minor concern that resulted in no or relatively inappreciable potential safety or security consequence) violation, because Exelon personnel did not perform the medical examinations required by 10 CFR 55.21. The finding was of very low safety significance because during the time period when the physicals were required to be performed, neither operator had stood watch, and when the physicals were administered on June 2, 2011, all requirements were met. No changes to the conditions on either operators license were necessary following their physicals. In accordance with Inspection Manual chapter (IMC)0612, Appendix B, traditional enforcement issues are not assigned cross-cutting aspects.
(Section AOA3).
Other Findings
A violation of very low safety significance that was identified by Exelon was reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program. This violation and corrective action tracking number are listed in section 4OA7.
REPORT DETAILS
Summary of Plant Status
Oyster Creek began the inspection period at 100 percent power. On January 11, 2012, operators reduced power to approximately 90 percent due to indications of a leaking condenser tube in the C north waterbox. Later that day, operators returned the plant to 100 percent power on following isolation of the waterbox.
On January 20, 2012, operators performed a planned power reduction to 60 percent to identify and repair leaking tubes in the C north waterbox. Operators returned the plant to 100 percent power on January 21, 2012 following repairs.
On January 23, 2012, operators reduced power to 90 percent to perform a rod for flow swap.
Operators returned the plant to 100 percent power on January 24, 2012.
On February 3, 2012, operators reduced power to 90 percent to return C reactor recirculation loop to service following completion of maintenance on the motor generator set. Operators returned the plant to 100 percent on February 4, 2012.
On February 13, 2012, operators reduced power to 94 percent to perform surveillance testing on core spray system 2. Operators returned to plant to 100 percent power on February 15, 2012.
On February 21, 2012, operators reduced power to 96 percent to perform surveillance testing on core spray system 1. Operators returned the plant to 100 percent power on February 24, 2012.
On February 25, 2012, operators reduced power to 95 percent to perform a rod pattern adjustment. Operators returned the plant to 100 percent power on February 25, 2012.
On March 21, 2012, operators reduced power to 95 percent to remove the B reactor recirculation pump (RRP) from operation to perform maintenance on the B motor generator set.
Operators returned the plant to 100 percent power on March 21, 2012. Later that day, operators reduced power to 90 percent to restart the B RRP. Attempts to start the pump were unsuccessful and operators returned the plant to 100 percent power on March 22, 2012. Later in the day on March 22, 2012, operators reduced power to 90 percent, successfully restarted the B RRP and returned the plant to 100 percent power.
The unit remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
==1R04 Equipment Alignment Partial System Walkdowns (71111.04Q - 3 samples)
==
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
- Containment spray system 1 while containment spray system 2 was out for planned maintenance on January 19, 2012
- Emergency diesel generator (EDG) 2 while EDG 1 was out for planned maintenance on February 6, 2012
- Core spray system 1 while core spray system 2 was out for planned maintenance on February 13, 2012 The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the UFSAR, technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findings
No findings were identified. ==1R05 Fire Protection