IR 05000219/2013004

IR 05000219-13-004, July 1, 2013 - September 30, 2013, Oyster Creek, Integrated

ML13318A298
Person / Time
Site:	Oyster Creek
Issue date:	11/14/2013
From:	Hunegs G NRC/RGN-I/DRP/PB6
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
HUNEGS, GK
References
IR-13-004
Download: ML13318A298 (28)

Text

{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION ber 14, 2013

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2013004

Dear Mr. Pacilio:

On September 30, 2013, 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 November 7, 2013 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 NRC-identified finding of very low safety significance (Green). This finding was determined to involve a violation of NRC requirements. However, because of the very low safety significance, and because it was entered into your corrective action program, the NRC is treating this finding as a non-cited violation (NCV), consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest the NCV in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors at Oyster Creek. In addition, if you disagree with the cross-cutting aspect assigned to the finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspectors at Oyster Creek. 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 NRCs Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access Management System (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.htmL (the Public Electronic Reading Room).

Sincerely, /RA/ Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Docket Nos.: 50-219 License Nos.: DPR-16

Enclosure:

Inspection Report 05000219/2013004 w/Attachment: Supplementary Information

REGION I== Docket Nos.: 50-219 License Nos.: DPR-16 Report No.: 05000219/2013004 Exelon: Exelon Nuclear Facility: Oyster Creek Nuclear Generating Station Location: Forked River, New Jersey Dates: July 1, 2013 - September 30, 2013 Inspectors: J. Kulp, Senior Resident Inspector A. Patel, Resident Inspector J. DeMarshall, Operations Engineer B. Dionne, Health Physicist E. Burkett, Emergency Preparedness Inspector J. Laughlin, Emergency Preparedness Inspector Approved By: Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects Enclosure

SUMMARY OF FINDINGS

IR 05000219/2013004; 07/01/2013 - 09/30/2013; Exelon Energy Company, LLC, Oyster Creek

Generating Station; Adverse weather protection.

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 an NCV. The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspect for the finding was 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: Mitigating Systems

Green.

The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, in that, Exelon did not ensure applicable regulatory requirements and design basis for the emergency diesel generators were correctly translated into instructions. Specifically, the inspectors determined that Exelon did not ensure that the design basis for flood control features was maintained and correctly translated into specifications, drawings, procedures and instructions for the installation of a security wall modification around the emergency diesel generator building which affected the probable maximum precipitation flood protection features of the building. Exelon entered this issue into the corrective action program for resolution as IR 1546148 and implemented corrective actions which included removing soil and re-grading the area adjacent to the building to improve the storm water runoff flow patterns.

The performance deficiency was more than minor because the finding affected the protection against external factors attribute of the mitigating systems cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. The inspectors determined this finding involved the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather initiating event; however, it did not involve the assumption that the protected equipment or safety function was completely failed or unavailable, and did not involve the total loss of any safety function, identified by Exelon through a PRA, IPEEE or similar analysis that contributes to external event initiated core damage accident sequences. Therefore, the inspectors determined the finding to be of very low safety significance (Green). This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, because Exelon, beginning in 2009 and as recent as September 2012, did not thoroughly evaluate the problem such that the resolution addressed the cause of an issue that potentially impacted nuclear safety [P.1(c)]. (Section 1R01)

Other Findings

None.

REPORT DETAILS

Summary of Plant Status

Oyster Creek began the inspection period at 100 percent power. Oyster Creek reduced power periodically from July 2, 2013 to July 22, 2013 to comply with New Jersey Department of Environmental Protection thermal discharge permit limitations. On September 1, 2013, operators reduced power to 80% to perform a rod pattern adjustment and returned the reactor to 100% power on September 2, 2013. On September 6, 2013, operators lowered power to 95% to perform repairs on the level controls for a high pressure feed heater and returned the reactor to 100% power. On September 29, 2013, operators reduced power to approximately 25% to perform troubleshooting on the turbine speed control system. On September 30, 2013, operators commenced a planned reactor shutdown and entered the 1M30 planned maintenance outage to perform corrective maintenance on the turbine speed control system.

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R01 Adverse Weather Protection

.1 External Flooding

a. Inspection Scope

During the week of July 24, 2013 and on August 13, 2013, the inspectors performed an inspection of the external flood protection measures for the Oyster Creek Nuclear Generating Station. The inspectors reviewed the UFSAR, Chapter 2.4.2, which depicted the design flood levels and protection areas containing safety-related equipment to identify areas that may be affected by external flooding. The inspectors conducted a general site walkdown of the emergency diesel generator building to ensure that Exelon erected flood protection measures in accordance with design specifications. The inspectors also reviewed operating procedures for mitigating external flooding during severe weather to determine if Exelon planned or established adequate measures to protect against external flooding events.

b. Findings

Introduction.

The inspectors identified a Green, non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion III, Design Control, in that, Exelon did not ensure applicable regulatory requirements and design basis for the emergency diesel generators were correctly translated into instructions. Specifically, Exelon did not ensure the design basis for the emergency diesel generator building probable maximum precipitation flood control features was maintained and correctly translated into instructions for installation of a security wall around the emergency diesel generator building.

Description.

As described in the update final safety analysis report (UFSAR), Section 2.4.2.3, the probable maximum precipitation level is 23.5 feet above mean sea level (MSL). As stated in the Oyster Creek Individual Plant Examination for External Events (IPEEE), section 5.2.3, the emergency diesel generator building is at an elevation of 23.0 feet above MSL, therefore a six inch high asphalt dike was constructed to prevent water entry into the emergency diesel generator building. Additionally, AmerGen (previous owner of Oyster Creek Nuclear Generation Station) letter, Reply to a Request for Additional Information on IPEEE, dated August 17, 2000, Section III, states, The ground surface is even with the top of the ramp at the Emergency Diesel Generator Building at Elevation 23.5 feet, and slopes down to the road at the north end of the building and the south side of the site to the south of the building. Precipitation will thus flow away from the entry without ponding.

On August 13, 2013, the inspectors performed a walk down of the emergency diesel generator building during a heavy rainstorm to determine if the flood protection features listed in the UFSAR for protection against external flooding of the building during a probable maximum precipitation event were adequate. The inspectors observed that rainwater was accumulating and flowing over the flood protection features into the emergency diesel generator building. The inspectors determined that the design features were not protecting the building against external flooding. Exelon entered the issue into their corrective action program as IR 1546148. As an immediate temporary corrective action, Exelon installed sandbags at the entrance of the emergency diesel generator building to mitigate the amount of water that would enter the building during a PMP event. Long term corrective actions were completed to re-grade the area such that water would not accumulate and enter the emergency diesel generator building.

The inspectors review noted that in 2009, Exelon made several modifications throughout the site to improve security. One of the modifications was to install a solid security wall around the emergency diesel generator building. Modification design package, OC 09-00549, for the security wall was generated using Exelon procedure CC-AA-103, Configuration Change Control for Permanent Physical Plant Changes.

CC-AA-103, step 4.1.4, states: Identify potential impacts of the change to the facility from a flooding perspective especially any change to the topography and assure that all affected analyses are updated and the impacts understood before allowing installation to begin. Additionally, CC-AA-103 directs the use of procedure CC-AA-102, Design Input and Configuration Change Impact Screening, to determine applicable design considerations and impacts of the modification. CC-AA-102 provides a comprehensive listing of configuration change considerations that could impact the design basis of the system, structures and components.

CC-AA-102, step 4.1.38, identifies civil and structural requirements that must be addressed during the configuration change process. Sub-step 4.1.38.6 determines if the configuration change adversely affects the external and internal flooding analysis.

Exelons response to step 4.1.38 addressed other effects concerning civil and structural considerations but did not identify any effects on the flooding analysis. Further, CC-AA-102, step 4.1.14, determines changes to environmental conditions and resultant adverse environmental impacts of the modification. Environmental conditions include changes to floor drains, storm drains, ditches and swales. Exelons response to step 4.1.14 identified that the installed security wall had the potential to increase water retention in the area between the wall and the emergency diesel generator building.

Exelon reviewed the potential to increase water retention and determined the wall will not exacerbate the problem and may serve to limit water retention because the configuration of the wall is expected to redirect the rainfall runoff around and/or away from the emergency diesel generator building. As a result, the inspectors observed that no instructions were provided to the installation crew to grade the ground or to provide any improvements to address the interruption of stormwater runoff patterns described in licensing basis documents caused by installation of the solid security wall.

The inspectors determined evaluations to assess impacts on the emergency diesel generator as a result of the security modification were inadequate as evidenced when heavy rainstorm water entered the emergency diesel generator building. The inspectors also identified continuing opportunities for Exelon to re-evaluate or affirm the design of the security wall installation and its potential impact on the emergency diesel generators.

In September 2012, the inspectors questioned the effect of the installation of the security wall and the apparent grading of the ground on the stormwater runoff patterns in the vicinity of the emergency diesel generator building. Specifically, the inspectors questioned the impact of not having the grading around the emergency diesel generator building sloped away from the emergency diesel generator building. Exelon entered this question into the corrective action program as IR 1410069. Exelons response to IR 1410069 stated, in part, the ground around the emergency diesel generator consists of a thin layer of coarse gravel and sand, which allow for faster infiltration of water into the ground therefore this should mitigate the effects of water retention. No additional action, further evaluations or design reviews of the wall installation were performed.

Analysis.

The inspectors determined that Exelon did not ensure the design basis for flood control features were correctly translated into instructions for the installation of a security wall around the emergency diesel generator building. The performance deficiency was more than minor because the finding affected the protection against external factors attribute of the mitigating systems cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, installation of the security wall changed the surface water runoff patterns and the grade of the ground which affected the flood protection of the emergency diesel generator during a probable maximum precipitation event.

The inspectors determined that this finding affected the external event mitigation systems portion of the Mitigating Systems cornerstone through the use of Table 2 of attachment 0609.04, Initial Characterization of Findings. The inspectors evaluated the finding using Exhibit 2 - Mitigating Systems Screening Questions and Exhibit 4 - External Events Screening Questions of inspection manual chapter 0609, Appendix A.

The inspectors determined this finding involved the loss or degradation of equipment or function specifically designed to mitigate a seismic, flooding or severe weather initiating event; however, it did not involve the assumption that the protected equipment or safety function was completely failed or unavailable, and did not involve the total loss of any safety function, identified by Exelon through a PRA, IPEEE or similar analysis that contributes to external event initiated core damage accident sequences. Therefore, the inspectors determined the finding to be of very low safety significance (Green).

This finding has a cross-cutting aspect in the area of Problem Identification and Resolution, because Exelon did not thoroughly evaluate a problem such that the resolution addressed the cause of an issue that potentially impacted nuclear safety.

Specifically, since 2009 and as recent as September 2012, Exelons evaluation was not adequate to evaluate the potential adverse impact of the security wall on the flood protection features of the emergency diesel generator building. (P.1(c))

Enforcement.

10 CFR 50 Appendix B, Criterion III, states, in part, that measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. Contrary to the above, between September 2009 and August 2013, Exelon did not properly translate the regulatory requirements of flood control measures into instructions for installation of a security wall which resulted in the flood control features of the emergency diesel generator building during a PMP to be inadequate. Because this violation was of very low safety significance and it was entered into Exelons corrective action program as IR 1546148, this violation is being treated as an NCV, consistent with the Enforcement Policy. (NCV 05000219/2013004-01, Physical Change To Security Feature Causes Flood Control Feature To Be Ineffective). ==1R04 Equipment Alignment

.1 Partial System Walkdowns

==

a. Inspection Scope

The inspectors performed partial walkdowns of the following systems: Containment spray system II while containment spray system I was out-of-service on July 8, 2013 Emergency diesel generator I while emergency diesel generator II was out-of-service on September 9, 2013 A isolation condenser while B isolation condenser was out-of-service on September 24, 2013 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