IR 05000219/2011004

IR 05000219-11-004, on 07-01-11 - 09-30-11, Oyster Creek Generating Station - NRC Integrated Inspection Report

ML113060316
Person / Time
Site:	Oyster Creek
Issue date:	11/02/2011
From:	Eugene Dipaolo NRC/RGN-I/DRP/PB6
To:	Pacilio M Exelon Nuclear, Exelon Generation Co
DIPAOLO, EM
References
IR-11-004
Download: ML113060316 (27)

Text

SUBJECT:

OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 0500021 9t201 1004

Dear Mr. Pacilio:

On September 30, 2011, 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 October 17 with Mr. M. Massaro, Site Vice President, and other members of your staff.

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

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

Based upon the results of this inspection, no findings were identified.

ln 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 NRC's document system (ADAMS). ADAMS is accessible from the NRC website at htto://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely, Eugene M. DiPaolo, Acting Chief Reactor Projects Branch 6 Division of Reactor Projects 50-219 DPR-16 I nspection Report 050002 1 9/2Afi OO4 w/Attachment: Supplemental I nformation Distribution via ListServ Docket No,:

License No.:

Enclosure:

cc w/encl:

Mr. Michael

SUMMARY OF FINDINGS

lR 0500021912011004; July 1 - September 30, 2Q11; Oyster Creek Generating Station;

Integrated Report This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

No findings were identified.

REPORT DETAILS

Summarv of Plant Status Oyster Creek began the inspection period at 100 percent power. Operators performed short duration unplanned power reductions on July 19, 21, 22, 23, 24, 25, 26, 27, and 31 and August 1 and 6 to adhere to environmental thermal discharge permit limitations. The operators returned the plant to 100 percent power following each of these power reductions.

On July 28, operators performed an unplanned power reduction to 70 percent power due to loss of the B 34.5kV bus which interrupted power to the dilution pumps. Power was subsequently lowered to 52 percent to adhere to environmental thermal discharge permit limitations.

Following restoration of power to the dilution pumps, operators returned the plant to 100 percent power on July 29.

On July 29, operators performed an unplanned power reduction to 70 power due to a loss of power to the dilution pumps caused by a lightning strike on the Q121 offsite power line.

Following restoration of power to the dilution pumps, operators returned the plant to 100 percent power on July 30.

On August 23, operators performed an unplanned power reduction to 70 percent to perform repairs to the A reactor feedwater pump. The plant returned to 100 percent power on August 25.

On August 27, operators commenced an unplanned reactor shutdown due to the approach of Hurricane lrene. Cold shutdown was achieved on August 28. After consultation with the State of New Jersey and the Federal Emergency Management Agency (FEMA) on August 28, operators commenced a reactor startup and returned the plant to 100 percent power on August 30.

On August 31, operators reduced power to 70 percent to perform a rod pattern adjustment. The plant returned to 100 percent power later the same day.

On September 21, operators performed an unplanned power reduction to 65 percent power to repair leaking tubes in the B main condenser. The plant returned to 100 percent power on September 22.

Oyster Greek remained at or near 100 percent power for the remainder of the inspection period.

1. REACTORSAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1

R01 Adverse Weather Protection

.1 Evaluate Readiness for lmpendinq Adverse Weather Conditions

a. lnspection Scope The inspectors reviewed Exelon's preparations and readiness for Hurricane lrene from August 25 through August 28. The inspectors performed walkdowns of the areas that could be impacted by hurricane conditions such as the intake structure, emergency diesel building and transformer yard. The walkdown verified that station personnel secured loose materials prior to the arrival of high winds and implemented compensatory actions specified in Exelon severe weather procedures. The inspectors verified that Exelon monitored the approach of the storm and took appropriate actions as required.

The inspectors provided continuous onsite coverage starting prior to arrival of the storm on August 27 until the storm passed on August 28. Documents reviewed are listed in the Attachment.

b. Findinos No findings were identified.

==1R04 EquipmentAliqnment

==

.1 Partial Svstem Walkdowns

a. Inspection Scope

The inspectors performed partialwalkdowns of the following systems:

r Containment spray system 2 with containment spray system 1 unavailable during surveillance testing on July 12 r A isolation condenser while B isolation condenser was unavailable due to planned maintenance on August 11

. Core spray system 2 with core spray system 1 unavailable during surveillance testing on September 6 o 1-2 Service water pump while 1-1 service water pump was unavailable due to planned maintenance on September 19 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. Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

==1R05 Fire Protection

==

.1 Resident Inspector Quarterlv Walkdowns

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.

Documents reviewed are listed in the Attachment.

.

New warehouse (NW-FA-23) on July 7 o Northeast corner room (RB-FZ-lF ) on July 11 o 480V switchgear room B (OB-FZ-68) on August 4 r

A and B battery room (OB-FZ-9C) on August 11 o Turbine operating floor (TB-FZ-114) on August 23

.

Torus room (RB-FA-2) on September 15 b. Findinqs No findings were identified.

==1R06 Flood Protection Measures (71111.06

• 1 samples)

==

.1 Internal Floodinq Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internalflooding. The inspectors also reviewed the corrective action program to determine if Exelon identified and corrected flooding problems and whether operator actions for coping with flooding were adequate. The inspectors also focused on the southeast corner room of the reactor building/turbine building which contains the containment spray C and D pumps to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and tempo.ary ol removable flood barriers. Documents reviewed are listed in the Attachment.

b. Findinos No findings were identified.

1R11 Licensed Operator Requalification Proqram (71111.11 - l sample) Resident Inspector Quarterlv Review

a. Inspection Scope

The inspectors observed licensed operator simulator training scenario 2612.CREW.11-5.01 on August 24. 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. Documents reviewed are listed in the Attachment.

b. Findinqs 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 SSC 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 SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2)performance r:riteria established by Exelon staff was reasonable. As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs 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. Documents reviewed are listed in the

.

.

Containment spray heat exchangers (lR 1193928) on July 25 o lsolation r:ondenser initiation logic relays (lR 1 178900) on August 8 b. Findinqs No findings were identified.

1R13 Maintenance Risk Assessments and Emerqent Work Control

a. lnspection 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 thesel 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(aX4) 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 the station's probabilistic 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. Documents reviewed are listed in the Attachment.

o Containment spray system 1 unavailable due to surveillance testing during a grid heavy load voltage warning on July 12

.

Standby gas treatment system 2 unplanned outage for maintenance on August 8

.

Service water pump 1-1 and A control room ventilation system unavailable due to planned maintenance on September 19

.

1-1 reactor building closed cooling water (RBCCW) heat exchanger unavailable for unplanned corrective maintenance with 1-1 RBCCW pump unavailable due to planned corrective maintenance on September 27 b. Findinqs No findings were identified.

1R15 Operabilitv Determinations and Functionalitv Assessments

a. Inspection Scope

The inspectors reviewed operability determinations for the following degraded or non-conform ing conditions:

o Low pressure carbon dioxide system on July 12 (lR 1239504)

.

'B' isolation condenser steam supply valve (V-14-33) stroke time on August 17 (lR

===1250414)

.

Safety relief valve acoustic monitoring system operability on August 23 (lR 1252766)r CV-305-127\\42-19 - Control rod drive outlet scram valve air leak on September 22

(]R 1265624)

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 Exelon's 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. Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

1R19 Post-Maintenance Testinq

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 andior 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. Documents reviewed are listed in the Attachment.

r B isolation condenser steam inlet valve (V-14-33) on August 11 (C2026219)o 1 diesel fire pump starting battery replacement on August 12 (R2148297)o 2 diesel fire pump following annual preventive maintenance on September 3 (R2169826/ R21801 10)

.

1. 2 emergency diesel generator planned maintenance on September 16 (R2143612)

.

1-1 service water pump preventive maintenance on September 19 (R21 87785)b. Findinqs No findings were identified.

1R22 Surveillance Testins

a. lnspection Scope The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs 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. Documents reviewed are listed in the Attachment. The inspectors reviewed the following surveillance tests:

r Firewater makeup to isolation condensers inservice test on July 6

.

Containment spray and emergency service water system 1 pump operability and inservice test on July 12 o Standby gas treatment system 1O-hour run - system 1 on August 15

.

Core spray valve operability and inservice test on September 1 b. Findinqs No findings were identified.

Cornerstone: Emergency Preparedness

lEPO Drill Evaluation (71114.06 - 1 sample)

.1 Emerqencv Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Exelon emergency drill on August 31 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities. The inspectors observed emergency response operations in the simulator, technical support center, and emergency operations facility 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 Exelon's critique and to verify whether the Exelon staff was properly identifying weaknesses and entering them into the corrective action program. Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

RADIATION SAFETY

Cornerstone: Occupational Radiation Safety [OS]

RS07 Radioloqical Environmental Monitorinq Proqram (REMP) (7 1124.07)

=

The inspectors reviewed Oyster Creek's annual radiological environmental and effluent operating reports (2009, 2010) and the results of Exelon's assessments to verify that the REMP was implemented in accordance with technical specifications (TS) and the offsite dose calculation manual (ODCM). The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and analysis of data.

The inspectors reviewed the ODCM and associated maps to identify locations of environmental monitoring stations. The inspectors also reviewed the updated final safety analysis report (UFSAR) for information regarding the environmental monitoring program and meteorological monitoring instrumentation.

The inspectors reviewed quality assurance (QA) audit results of the program to assist in selection of samples. The inspectors reviewed available audits and technical evaluations performed on the vendor's program, as applicable, if used to analyze REMP samples.

The inspectors reviewed the annual effluent release report and the 10 CFR Part 61,

"Licensing Requirements for Land Disposal of Radioactive Waste," report, to determine if Exelon was appropriately sampling for the predominant and dose-causing radionuclides likely to be released in effluents.

The inspectors observed the collection and preparation of various environmental samples from different environmental media (three particulate and iodine air monitoring stations, one drinking water locations, and one surface water location). Documents reviewed are listed in the Attachment.

Site Inspection The inspectors walked down and observed sample collection for three air sampling stations (5T-66, ST-72, and ST-73), three thermoluminescent dosimeter (TLD)monitoring stations (5T-66, ST-72, and ST-73), one drinking water station (Station 1 14),and one surface water sample (Station 33) to determine whether the stations were located as described in the ODCM. The inspectors also reviewed Exelon gardens (ST 66 and ST 35) and reviewed material conditions of monitoring equipment. Consistent with smart sampling techniques, the inspectors selected air sampling station locations based on the locations with the highest X/Q, D/Q wind sectors selected the TLD stations based on the most risk-significant locations.

The inspectors observed the collection and preparation of various environmental samples from different environmental media (three particulate and iodine air monitoring stations, one drinking water locations, and one surface water location). The inspectors verified that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with controlled procedures.

For the air samplers and TLDs, the inspectors reviewed the calibration and maintenance records/data (orifices, vacuum gauge) to verify that they demonstrate operability of these components.

The inspectors evaluated Exelon's criteria for sampling of other media upon loss of a required sampling station.

Based on direct observation and review of records, the inspectors verified that the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the FSAR, NRC Regulatory Guide 1.23, "Meteorological Monitoring Programs for Nuclear Power Plants," and Exelon procedures. The inspectors verified that the meteorological data readout and recording instruments in the control room and at the tower were operable. The inspectors toured the meteorological tower and reviewed meteorological data readouts, The inspectors compared readouts with control room indications. The inspectors reviewed monthly meteorological monitoring reports.

The inspectors verified that missed and or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors selected events that involved a missed sample, an inoperable sampler, a lost TLD, or an anomalous measurement, and verified that Exelon had identified the cause and implemented corrective actions. The inspectors reviewed Exelon's assessment of any positive sample results (i.e., licensed radioactive material detected above the lower limits of detection (LLD). The inspectors reviewed the associated radioactive effluent release data that was the source of the released material.

The inspectors selected structures, systems, or components (SSCs) that involve or could reasonably involve licensed material for which there is a credible mechanism for licensed materialto reach groundwater, and verified that Exelon had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to groundwater. The inspectors reviewed the Annual 2010 Radiological Ground Water Protection Program Report.

The inspectors verified that records, as required by 10 CFR 50.75(9), of leaks, spills, and remediation generated since the previous inspection, were being retained in a retrievable manner.

The inspectors reviewed any significant changes made by Exelon to the ODCM as the result of changes to the land use census, long-term meteorological conditions (e.9.,

three-year average) or modifications to the sampler stations. The inspectors reviewed technicaljustifications for any changed sampling locations. The inspectors verified that Exelon performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.

The inspectors verified that appropriate detection sensitivities with respect to TS/ODCM were used for counting samples (i.e., the samples meet the TS/ODCM required LLDs).

The inspectors reviewed quality control charts, as appropriate, for maintaining radiation measurement instrument status and actions taken for degrading detector performance, as applicable. For vendor laboratory analysis results for REMP samples, the inspectors reviewed the results of the vendor's quality control program, including the inter-and intra-laboratory comparison program, to verify the adequacy of the vendor's program.

The inspectors reviewed the results of Exelon's inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed by Exelon. The inspectors verified that the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility. The inspectors reviewed as applicable, Exelon's determination of any bias to the data and the overall effect on the REMP.

ldentification and Resolution of Problems The inspectors determined if problems associated with the REMP were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the corrective action program. In addition to the above, the inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by Exelon that involve the REMP.

b.

Findinqs No findings were identified.

4OA1 Performance lndicator Verification

.1 Reactor Coolant Svstem (RCS) Specific Activitv and RCS Leak Rate (2 samples)

Inspection Scope The inspectors reviewed Exelon's submittal for the RCS specific activity and RCS leak rate performance indicators for the period of July 1, 2010 and June 30, 2011. To determine the accuracy of the performance indicator data reported dudng those periods, the inspectors used definitions and guidance contained in NEI Document 99-02, "Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements for RCS leakage, and compared that information to the data reported by the performance indicator. Documents reviewed are listed in the Attachment.

Inspection Findinqs No findings were identified.

4OA2 Problem ldentification and Resolution

.1 Routine Review of Problem ldentification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure71152, "Problem ldentification 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. Findinqs No findings were identified.

4OA3 Follow-Up of Events

.1 Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, "Reactive lnspection 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 Exelon's follow-up actions related to the events to assure that Exelon implemented appropriate corrective actions a.

b.

b.

commensurate with their safety significance. Documents reviewed are listed in the

.

.

Loss of the B 34.5kV electrical bus on July 28

.

Declaration of Unusual Event due to seismic activity on August 23

.

Response to Hurricane lrene during the period August 25-28 Findinqs No findings were identified.

Other Activities

Follow-up On Traditional Enforcement Actions (lP 92702) (1 sample)

Inspection Scope The U.S. Nuclear regulatory Commission Office of Investigations completed an investigation at Oyster Creek Nuclear Generating Station (OCNGS) on January 14,2010 which confirmed that a contract employee, who had unescorted access to vital areas of the plant, deliberately failed to report an arrest while employed for Bartlett at OCNGS.

The contract employee's action caused Exelon to be in violation of License Condition 2.C.(4) of the OCNGS operating license and Section 9.1 of the OCNGS Physical Security Plan. A severity level lV non-cited violation was issued in investigation report l-2009-047 (ML092580013) on April 12,2Q10. The inspectors reviewed Exelon's corrective actions, ensured that any generic implications were addressed, and verified that Exelon's programs and practices are adequate to prevent recurrence. No inadequacies were noted. Documents reviewed are listed in the Attachment.

Findinqs No findings were identified.

Independent Spent Fuel Storase Installation (lSFSl) (60855.1)40A5

,1 b.

.2 a. lnspection Scope (1 Sample)

The inspector reviewed routine operational surveillance data, including radiological surveillance, for the ISFSI facility. The inspector toured the facility, reviewed TLD monitoring data, and made independent radiation measurements. Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

.3 (Closed) NRC Temporarv Instruction 2515/177 - Manaoinq Gas Accumulation in

Emerqencv Core Coolinq. Decav Heat Removal and Containment Sprav Svstems

a. Inspection Scope

The inspectors performed the inspection in accordance with Temporary Instruction (Tl) 25151177, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." The NRC staff developed Tl 25151177 to support the NRC's confirmatory review of Exelon's responses to NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." Based on a review of Exelon's GL 2008-01 response letters, the Office of Nuclear Reactor Regulation (NRR) staff provided additional plant specific guidance on inspection scope to the regional inspectors. The inspectors used this inspection guidance along with the Tl to verify that Exelon implemented or was in the process of acceptably implementing the commitments, modifications, and programmatically controlled actions described in their GL 2008-01 response. The inspectors verified that the plantspecific information (including licensing basis documents and design information) was consistent with the information that Exelon submitted to the NRC in response to GL 2008-01.

The inspectors reviewed a sample of isometric drawings, and piping and instrument diagrams, and conducted selected system piping walkdowns to verify that Exelon's drawings reflected the subject system configurations and Updated Final Safety Analysis Report (UFSAR) descriptions. Specifically, the inspectors verified the following related to a sample of isometric drawings for the core spray, containment spray, isolation condenser and shutdown cooling systems:

.

High point vents were identified;

.

High points that did not have vents were recognized and evaluated with respect to their potential for gas buildup;

.

Other areas where gas could accumulate and potentially impact subject system operability, such as orifices in horizontal pipes, isolated branch lines, heat exchangers, improperly sloped piping, and under closed valves, were acceptably evaluated in engineering reviews or had ultrasonic testing (UT) points which would reasonably detect void formation; and, o For piping segments reviewed, branch lines and fittings were clearly shown.

The inspectors conducted walkdowns of portions of the above systems to evaluate the acceptability of Exelon's drawings utilized during their review of GL 2008-01. The inspectors verified that Exelon conducted walkdowns of the applicable systems to confirm that the combination of system orientation, vents, instructions and procedures, tests, and training, would ensure that each system was sufficiently full of water to ensure operability, The inspectors reviewed Exelon's methodology used to determine system piping high points, identification of negative sloped piping, and calculations of void sizes based on UT equipment readings, to ensure the methods were reasonable. The inspectors also reviewed engineering analyses associated with the development of acceptance criteria for as-found voids. The review included engineering assumptions for void transport and acceptability of void fractions at the suction and discharge piping of the applicable system pumps. In addition, the inspectors verified that Exelon's review included all emergency core cooling systems, along with supporting systems, within scope of the GL.

The inspectors reviewed a sample of Exelon's procedures used for filling and venting the associated GL 2008-01 systems to verify that the procedures were effective in venting or reducing voiding to acceptable levels. The inspectors reviewed a sample of system venting and UT surveillance results to ensure proper implementation of the surveillance program.

The inspectors reviewed corrective action program (CAP) documents to verify that selected actions described in Exelon's nine month and supplemental submittals were acceptably documented including completed actions, and implementation schedule for incomplete actions. The inspectors also verified that the NRC commitments in Exelon's submittals were included in the CAP. Additionally, the inspectors reviewed evaluations and corrective actions for various issues Exelon identified during their GL 2008-01 review. The inspectors performed this review to ensure Exelon appropriately evaluated and adequately addressed any gas voiding concerns. Finally, the inspectors reviewed Exelon's training associated with gas accumulation to assess if appropriate training had been provided to the operations and engineering support staff to ensure appropriate awareness of the effects of gas voiding. Documents reviewed are listed in the

.

b. Findinqs No findings were identified. This completes the inspection requirements for Tl 25151177.

4OAO Meetinqs. Includinq Exit On October 17, the inspectors presented the inspection results to Mr. M. Massaro, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report 4C.A7 Licensee-ldentified Violations None ATTACHMENT: SUPPLEM ENTARY INFORMATION

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Massaro, Site Vice-President

R. Peak, Plant Manager

D. Dicello, Director, Work Management

M. McKenna, Director, Operations

G. Malone, Director, Engineering

C. Symonds, Director, Training

J. Dostal, Director, Maintenance

J. Barstow, Manager, Regulatory Assurance

T. Keenan, Manager, Security

M. Ford, Manager, Environmental/Chemistry

J. Renda, Manager, Site Radiation Protection

A. Farenga, Manager, Radiological Engineering

D. Chernesky, Assistant Director, Maintenance

R. Skelsky, Senior Manager, Systems Engineering

H. Ray, Senior Manager, Design Engineering

G. Flesher, Shift Operations Superintendent

J. McDaniel, Manager, Nuclear Oversight

M. Rossi, RequalTraining Lead

M. Seeloff, Manager, Corrective Action Program

J. Chrisley, Regulatory Assurance Specialist

J. Kerr, Regulatory Assurance Specialist

K. Wolf, Radiation Protection Support Manager

M. Nixon, Chemistry Supervisor

D. Moore, Regulatory Assurance Specialist

J. McCarthy, Radiological Engineer

K. Martin, Project Manager, lFSl

S. Schwartz, Design Engineer

Others:

State of New Jersey, Bureau of Nuclear Engineering

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

None

Opened

None

Closed

None