IR 05000219/2008005

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January 27, 2009

Mr. Charles Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Rd. Warrenville, IL 60555

SUBJECT: OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2008005

Dear Mr. Pardee:

On December 31, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Generating Station. The enclosed integrated inspection report documents the inspection findings, which were discussed on January 23, 2009, with Mr. P.

Orphanos, Plant Manager, 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.

The report documents one NRC-identified finding and one self revealing finding of very low safety significance (Green). Both of these findings were determined to involve violations of NRC requirements. Additionally, one 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 were entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs) consistent with Section VI.A of the NRC's Enforcement Policy. If you contest these NCVs, 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 accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room). We appreciate your cooperation. Please contact me at (610) 337-5200 if you have any questions regarding this letter.

Sincerely,/RA/ Ronald R. Bellamy, Ph.D., Chief Projects Branch 6 Division of Reactor Projects Docket No. 50-219 License No. DPR-16

Enclosure:

Inspection Report 05000219/2008005

w/Attachment:

Supplemental Information cc w/encl: C. Crane, President and Chief Operating Officer, Exelon Corporation M. Pacilio, Chief Operating Officer, Exelon Nuclear T. Rausch, Site Vice President, Oyster Creek Nuclear Generating Station J. Randich, Plant Manager, Oyster Creek Generating Station J. Kandasamy, Regulatory Assurance Manager, Oyster Creek R. DeGregorio, Senior Vice President, Mid-Atlantic Operations K. Jury, Vice President, Licensing and Regulatory Affairs P. Cowan, Director, Licensing B. Fewell, Associate General Counsel, Exelon Correspondence Control Desk, Exelon Nuclear Mayor of Lacey Township P. Mulligan, Chief, NJ Dept of Environmental Protection R. Shadis, New England Coalition Staff E. Gbur, Chairwoman - Jersey Shore Nuclear Watch E. Zobian, Coordinator - Jersey Shore Anti Nuclear Alliance P. Baldauf, Assistant Director, NJ Radiation Protection Programs

SUMMARY OF FINDINGS

...........................................................................................................3

REPORT DETAILS

.......................................................................................................................5

REACTOR SAFETY

..................................................................................................................6 1R01 Adverse Weather Protection .........................................................................................6 1R04 Equipment Alignment ....................................................................................................6

1R05 Fire Protection .............................................................................................................

.7 1R07 Heat Sink Performance .................................................................................................7 1R08 In-Service Inspection ....................................................................................................8 1R11 Licensed Operator Requalification Program .................................................................9 1R12 Maintenance Effectiveness ...........................................................................................9

1R13 Maintenance Risk Assessments and Emergent Work Control ...................................12

1R15 Operability Evaluations................................................................................................13 1R18

Plant Modifications ......................................................................................................13 1R19 Post-Maintenance Testing ..........................................................................................14 1R20 Refueling and Other Outage Activities ........................................................................14

1R22 Surveillance Testing ...................................................................................................18 1EP2 Alert and Notification System (ANS) Evaluation .........................................................18

1EP3 Emergency Preparedness Organization Staffing and Augmentation System ............19 1EP4 Emergency Action Level (EAL) and Emergency Plan Changes .................................19 1EP5 Correction of Emergency Preparedness Weaknesses ...............................................19

RADIATION SAFETY

..............................................................................................................20 2OS1 Access Control to Radiologically Significant Areas.....................................................20 2OS2 ALARA Planning and Controls ....................................................................................22 2OS3 Radiation Monitoring Instrumentation and Protective Equipment ...............................24

OTHER ACTIVITIES

..............................................................................................................24

4OA1 Performance Indicator (PI) Verification .......................................................................24 4OA2 Identification and Resolution of Problems ..................................................................25 4OA3 Event Follow-up ..........................................................................................................27 4OA5 Other............................................................................................................................29 4OA6 Meetings, Including Exit...............................................................................................31 4OA7 Licensee-Identified Violations......................................................................................31

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

....................................................................................................A-1

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

........................................................A-1

LIST OF DOCUMENTS REVIEWED

........................................................................................A-2

LIST OF ACRONYMS

.............................................................................................................A-11 Enclosure

SUMMAR Y
OF [[]]
FINDIN [[]]

GS IR 05000219/2008005; 10/01/08 - 12/31/2008; Exelon Nuclear, Oyster Creek Generating Station; Maintenance Effectiveness, Refueling and Other Outages.

The report covered a 3-month period of inspection by resident inspectors, a project engineer,

regional reactor inspectors, and an announced inspection by a regional reactor inspector and a senior health physicist. Two Green non-cited violations (NCV) were identified. The significance of most findings is indicated by their color (Green, White, Yellow, or Red) using Inspection Manual Chapter (IMC) 0609, "Significance Determination Process" (SDP). Findings for which

the

SDP does not apply may be Green or be assigned a severity level after
NRC management review. 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.
A. [[]]

NRC-Identified and Self-Revealing Findings Cornerstone: Initiating Events Green. A self-revealing non-cited violation (NCV) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings," occurred when Exelon did not perform an

adequate self-check and did not properly use test equipment during 480 VAC breaker

maintenance on November 7. Specifically, during the maintenance, a human performance error occurred causing a phase to phase fault and an arc flash, and resulted in the loss of safety related equipment and an automatic halon system actuation

in the 480 VAC room. In response, Exelon entered this issue into the corrective action program and implemented actions to address work practice deficiencies. The finding is more than minor because it is associated with the human performance

attribute of the initiating events cornerstone and affected the 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. Using Appendix G, "Shutdown Operations Significance Determination Process," of Manual Chapter 0609, "Significance Determination Process," the finding was determined to have very low safety significance (Green) because it did not increase the likelihood of a loss of reactor coolant system (RCS) inventory, did not affect the licensee's ability to terminate a leak

path or add inventory to the RCS, or degrade the licensee's ability to recover decay heat

removal in the event it was lost. The performance deficiency had a cross-cutting aspect

in the area of human performance because Exelon did not properly implement human error prevention techniques, such as self and peer checking H.2(c). (Section 1R12)

Cornerstone: Barrier Integrity Green. The inspectors identified an

NCV of Technical Specification 3.9.D "Refueling", when Exelon performed core alterations without the required configuration of operable source range monitors (

SRM). Specifically, Exelon installed two fuel assemblies in a reactor quadrant when the required configuration of SRMs was not operable. In response, Exelon entered this issue into the corrective action program and implemented

actions to revise the reactor refueling procedure. Enclosure

The finding is more than minor because it is associated with the configuration control attribute of the barrier integrity cornerstone and affected the cornerstone objective of providing reasonable assurance that physical design barriers protect the public from

radionuclide releases caused by accidents or events. Specifically, during a time of decreased availability of physical barriers (refueling outage), Exelon performed core

alterations without the required configuration of operable SRMs. Using Appendix G,

"Shutdown Operations Significance Determination Process," of Manual Chapter 0609, "Significance Determination Process," the finding was determined to have very low safety significance (Green) because it did not increase the likelihood of a loss of reactor

coolant system (RCS) inventory, did not affect the licensee's ability to terminate a leak

path or add inventory to the RCS, or degrade the licensee's ability to recover decay heat removal in the event it was lost. The performance deficiency had a cross-cutting aspect in the area of human performance, because Exelon did not ensure that the reactor refueling procedures accurately implemented the neutron monitoring requirements

contained in the Technical Specifications H.2(c). (Section 1R20) B. Licensee-Identified Violations A violation of very low safety significance, which was identified by Exelon, has been

reviewed by the inspectors. Corrective actions taken or planned by the licensee have been entered into the Exelon=s corrective action program. This violation and corrective action tracking numbers are listed in Section

4OA 7 of this report. Enclosure
REPORT [[]]

DETAILS Summary of Plant Status At the time of the inspection, AmerGen Energy Company, LLC was the licensee for Oyster

Creek Generating Station. As of January 8, 2009, the Oyster Creek license was transferred to

Exelon Generating Company,

LLC (Exelon) by license amendment No. 271 (

ML083640373). The Oyster Creek Generating Station (Oyster Creek) began the inspection period operating at

98% power due to end-of cycle operations.

On October 6, operators reduced power to 93% and removed the intermediate pressure feedwater heaters from service to support end-of-cycle operations. Operators returned the plant to full (100%) power on October 7, 2008.

On October 18, operators performed an unplanned downpower to 65% to repair a leaking drain

line on the 'C' feedwater regulating valve. Operators returned the plant to full power on October 19, 2008.

On October 24, operators commenced a planned shutdown to begin the 1R22 refueling outage.

The main turbine was removed from service and the reactor was shutdown on October 25,

2008. Oyster Creek was placed in cold shutdown on October 27, 2008.

On November 17, operators commenced a reactor startup following the refueling outage and declared the reactor critical. Operators synchronized the main turbine generator to the grid on

November 18, 2008. The plant reached and was limited to 98.5% power on November 22, 2008

due to a failed feedwater temperature sensing element.

On November 22, operators performed an unplanned downpower to 90% due to a steam leak on the 1-5 drain tank access cover. Later that evening, operators performed a planned

downpower to 80% to perform a rod pattern adjustment. While at reduced power, attempts to

repair the steam leak on the 1-5 drain tank access cover were unsuccessful. Due to the leak,

the second stage reheaters could not be placed in service, which limited power to 98%. The

plant returned to 98% power on November 23, 2008. On November 28, the plant experienced a load reject scram due to an internal fault on the M1A transformer. Exelon reported this event to the

NRC in Event Notification 44688, "Automatic Reactor Scram Due to Main Transformer Fault." Additional information on this event is contained in section 4

OA3 of this report. Exelon commenced a forced outage (1F17) on November 28, 2008 to replace the failed transformer. Exelon personnel performed additional maintenance activities during the outage, which included repairs to the 'A' high pressure

feedwater heater, replacement of the failed feedwater temperature sensor and seal welding of

the 1-5 drain tank access cover. Operators commenced a reactor startup and established the

reactor critical on December 5, and synchronized the main generator to the grid and reached full power on December 6.

Oyster Creek operated at 100% (full) power for the remainder of the inspection period. Enclosure

1.

REACTO R

SAFETY Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity 1R01 Adverse Weather Protection (71111.01) a. Inspection Scope (2 samples) The inspectors performed one adverse weather preparation and one site specific weather-related condition inspection. The inspectors reviewed Exelon's activities associated with seasonal readiness for cold weather conditions. The inspectors reviewed the updated final safety analysis report

(UFSAR) for Oyster Creek to identify risk significant systems that require protection from cold weather conditions. The inspectors assessed the readiness of the service water, emergency service water, and fire protection systems to seasonal susceptibilities (extreme cold weather). The inspectors performed a walkdown of the service water,

emergency service water, and fire protection systems and reviewed applicable corrective action program condition reports to assess their reliability and material condition. The inspectors also reviewed Exelon's cold weather preparation activities to assess their adequacy and to verify they were completed in accordance with procedure

requirements.

The inspectors reviewed Exelon's response to high wind conditions on December 22 thru 24. During that period of time, strong westerly wind gusts had lowered intake levels below normal operating levels. The inspectors verified that operators properly monitored risk-significant plant equipment that could have been affected by the lowering intake

level. The inspectors verified that Exelon had entered appropriate abnormal operating

procedures in response to the lowering intake level. The inspectors performed

walkdowns of the intake structure to assess any adverse equipment effects which may result from the lowering intake level. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. b. Findings No findings of significance were identified. 1R04 Equipment Alignment (71111.04) a. Inspection Scope (3 samples) The inspectors performed three partial equipment alignment inspections. The partial

equipment alignment inspections were completed during conditions when the equipment

was of increased safety significance such as would occur when redundant equipment

was unavailable during maintenance or adverse conditions, or after equipment was

recently returned to service after maintenance. The inspectors performed a partial walkdown of the following systems, and when applicable, the associated electrical distribution components and control room panels, to verify the equipment was aligned to

perform its intended safety functions: Enclosure

  • Containment spray/emergency service water system 2 on October 23; * Standby liquid control system on November 17; and * Emergency diesel generator #2 on November 21. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. b. Findings No findings of significance were identified.

1R05 Fire Protection (71111.05)

a. Inspection Scope (71111.05Q - 4 samples) The inspectors performed a walkdown of four plant areas to assess their vulnerability to fire. During plant walkdowns, the inspectors observed combustible material control, fire

detection and suppression equipment availability, visible fire barrier configuration, and the adequacy of compensatory measures (when applicable). The inspectors reviewed "Oyster Creek Fire Hazards Analysis Report" and "Oyster Creek Pre-Fire Plans" for risk insights and design features credited in these areas. Additionally, the inspectors

reviewed corrective action program condition reports documenting fire protection

deficiencies to verify that identified problems were being evaluated and corrected. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. The following plant areas were inspected: * Northeast Corner Room (RB-FZ-1F4) on October 15; * Northwest Corner Room (RB-FZ-1F3) on October 23; * Motor Generator Set Room (OB-FZ-8A) on December 8; and * Main Transformer Area (MT-FA-12) on December 22. b. Findings No findings of significance were identified. 1R07 Heat Sink Performance (71111.07)

a. Inspection Scope (1 sample) The inspectors verified heat exchanger performance by reviewing the results of one heat

exchanger performance test. The inspectors reviewed the data collected from the

containment spray system #2 heat exchanger performance test on April 23, to verify that the heat exchanger was capable of performing its safety function. In addition, the

inspectors reviewed the test procedure and results to verify that appropriate test controls

were incorporated correctly into the procedure, test acceptance criteria were consistent

with technical specification and

UFS [[]]

AR requirements, and that Exelon identified any

potential heat exchanger deficiencies during testing. Documents reviewed are listed in the Supplemental Information attachment to this report. Enclosure

b. Findings No findings of significance were identified.

1R08 In-Service Inspection (71111.08) a. Inspection Scope (1 Sample) From October 27 thru November 5, the inspectors conducted a review of Exelon's

implementation of in-service inspection (ISI) program activities for monitoring

degradation of the reactor coolant system (RCS) boundary and risk significant piping

system boundaries for Oyster Creek using the criteria specified in the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section

XI , 1995 Edition, with the 1996 Addenda, 10

CFR 50.55a, "Codes and Standards", Boiling Water

Reactor Vessel Internals Program recommendations, and station implementing procedures. The sample selection was based on the inspection procedure objectives

and risk priority of those components and systems where degradation would result in a significant increase in risk of core damage. The inspectors reviewed documentation, observed in-process non-destructive examinations (NDE) and interviewed Exelon personnel to verify that inservice inspection activities were performed in accordance with

the

ASME Boiler and Pressure Vessel Code Section

XI requirements.

The inspectors remotely observed shroud and steam dryer examinations (sampled

VT -1 &

VT-3 examinations), and performed direct field observation of six manual ultrasonic testing examinations. The review was performed to evaluate examiner skills and

performance, to evaluate examination techniques, to assess contractor oversight activities, and to verify licensee and contractor ability to identify and characterize

observed indications. In addition, dye penetrant (PT) examination data records, automated ultrasonic testing data records of the core spray safe-end-to-nozzle (N6A), recirculation safe-end-to-nozzle (N2C), and recirculation outlet nozzle-to-safe-end (N1A)

were reviewed by the inspectors. To verify suitability of materials, welding activities performed, applicable NDE performed,

and

ISI implementing procedures were in accordance with the

ASME code requirements, the inspectors reviewed repair/replacement activities of shutdown cooling loop 'C' outlet isolation motor operated valve V-17-57 per work order C2012002.

Magnetic particle and ultrasonic testing examination data sheets 1R21-240, and 1R21-241 associated with this valve replacement were reviewed.

The inspectors reviewed the In-Vessel-Visual-Inspection (IVVI) program and discussed the scope of examinations being performed with the General Electric (GE) Hitachi examination staff. The inspectors focused on visual examinations being performed on the shroud and steam dryer components and compared the visual inspection results to

the previous outage examinations of these components. The inspectors confirmed that

deficient conditions identified by GE Hitachi were entered into Oyster Creek's corrective action program.

The inspectors discussed operating experience (OE) on reactor vessel nozzle dissimilar

metal weld intergranular stress corrosion cracking (IGSCC) with GE Hitachi personnel

and Exelon staff to verify that they were aware of flaws identified at the Duane Arnold Enclosure

and Hope Creek plants due to

IGSCC. Because of this

OE, the inspectors examined disposition for continued operation, without repair or rework, of non-conforming conditions and indications identified at Oyster Creek during 1R22 ISI activities.

Specifically the inspectors reviewed Exelon's technical evaluation AT 00842492-03 associated with an indication 12 inches long in the circumferential extent and about 0.20

inch deep found in N1A nozzle-to-safe-end dissimilar metal weld NR02 4-565A of the

recirculation piping that exceeds the acceptance standards of

ASME Section
XI ,
IWB -3514.14. Based on

EPRI report IR-2008-340 evaluation of the examination data of this weld, the reported flaw at the N1A nozzle is embedded at the interface between the

stainless steel clad and the ferritic base material and is not exposed to reactor coolant.

The indication is considered a fabrication-induced flaw, not service induced. Mechanical Stress Improvement Process (MSIP) mitigation was performed on this weld during the 1994 refueling outage. Structural Integrity Associates (SIA) performed a flaw evaluation report 0801457.301R3 in accordance with

ASME Section

XI, IWB-3600 to determine

acceptability for continued service. This SIA report concluded that the flaw identified in

weld NR02 4-565A is acceptable for continued service for a period of 2 operating cycles.

A teleconference was held on November 14 between Exelon and the

NRC to discuss the identified flaw, the
SIA flaw report and the
EP [[]]

RI report.

The inspectors also reviewed a sample of issue reports to assess Exelon's effectiveness in problem identification and resolution and determined that they are identifying ISI and

NDE issues at an appropriate threshold and entering them into the corrective action

program. The inspectors sampled condition reports from the current refueling outage 1R22 and from the time period since the last refueling outage 1R21. b. Findings No findings of significance were identified. 1R11 Licensed Operator Requalification Program (71111.11) a. Inspection Scope (71111.11Q - 1 sample) The inspectors observed one simulator training scenario on October 6, to assess operator performance and training effectiveness. The scenario involved an inadvertent

opening of an electromatic relief valve (EMRV), a feedwater heater trip, loss of control

rod drive flow, and an anticipated transient without scram (ATWS). The inspectors

assessed whether the simulator adequately reflected the expected plant's response,

operator performance met Exelon's procedural requirements, and the simulator instructor's critique identified crew performance problems. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. b. Findings No findings of significance were identified. 1R12 Maintenance Effectiveness (71111.12)

a. Inspection Scope (71111.12Q - 2 samples) Enclosure

The inspectors performed two maintenance effectiveness inspection activities. The inspectors reviewed the following degraded equipment issues in order to assess the effectiveness of maintenance performed by Exelon:

  • Conduct of maintenance on
480 VAC system (

IR 842131) on November 7; and * 1-5 moisture separator reheater drain tank leaking from northeast corner of tank (IR 848586) on November 22. The inspectors reviewed completed maintenance work orders and procedures to determine if inadequate maintenance contributed to equipment performance issues. The inspectors also reviewed applicable work orders, corrective action program condition reports and operator narrative logs. Documents reviewed for this inspection

activity are listed in the Supplemental Information attachment to this report. b. Findings Introduction. A self-revealing non-cited violation (NCV) of very low safety significance (Green) of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and

Drawings," occurred when Exelon did not perform an adequate self-check and did not properly use test equipment during the maintenance on a 480 VAC breaker. Specifically, on November 7, during the maintenance activity, a human performance error occurred in

which a phase to phase fault caused an arc flash, and resulted in the loss of safety

related equipment and an automatic halon system actuation. In response, Exelon entered this issue into the corrective action program and implemented action to address

work practice deficiencies. Description. On November 7, at around 3:00 PM, a contractor electrician cross connected electrical phases while attempting to perform a phase rotation check for the

cleanup system pre-coat pump motor. At the time of this error, the plant was in the

refueling mode of operation, with the shutdown cooling and fuel pool cooling systems in service for heat removal. A typical means to verify proper motor/pump rotation associated with maintenance

activities is to "bump" the motor by momentarily initiating a pump start signal and

observing shaft rotation. However, the pre-coat pump had not been returned to service

as expected, and the associated work order was revised to perform an electrical phase rotation check using test equipment. The phase rotation instrument was designed for dual usage. It can either be used for motor rotation with no line voltage present (i.e., equipment not energized), or for 3-phase rotation (i.e., testing the energized part of the circuit; line voltage applied). The test instrument had two groups of three leads, one group for each of the test options. They are marked as motor rotation and 3-phase rotation, respectively. Although the electrician

used the instrument on the energized connections at the associated 480 VAC breaker,

the instrument was configured to be used for motor rotation (no line voltage) conditions. While connecting the test instrument to the three phases of the breaker, the electrician made simultaneous contact with two of the phases, resulting in a phase to phase fault. This caused an arc flash and tripping of the electrical supply to the motor control center

(MCC) 1B21. In addition, as a result of the arc flash, there was a significant amount of Enclosure

smoke generated in the

480 VAC room, which caused an automatic discharge of the halon system. The electrician apparently had the alligator clip fully open while inserting the clip into the energized 480

VAC breaker cubicle. Exelon's subsequent investigation

identified that the worker failed to use the

ST [[]]

AR (Stop, Think, Act, Review) self-

check/human performance tool and failed to recognize that having the alligator clip open

could result in inadvertent contact with two terminal points within the breaker cubicle.

Additionally, the worker was not wearing the required protective safety equipment (e.g., face shield, high voltage gloves, flame retardant outer clothing). As a consequence of not wearing the proper protective safety equipment, the worker received minor burns to

his forearms. The fire brigade responded to the fire alarm and the associated halon system actuation. Within 13 minutes of the halon system actuation, the fire brigade leader confirmed that there was no fire in the 480 VAC room. Exelon reviewed the potentially applicable

emergency action level categories, including those for fire and toxic/flammable gases,

and confirmed that no declaration thresholds were met. The inspectors responded to the control room and the 480 VAC room to assess plant

conditions and licensee response. While the inspectors confirmed that there was no

significant adverse operational or nuclear safety impact due to the electrical transient,

several safety related components became unavailable due to the trip of the MCC

electrical supply, including the 'B' fuel pool cooling pump, remote operation of a

shutdown cooling system cooling water valve, and both core spray system fill pumps. Accordingly, Exelon instituted appropriate contingency actions, which included providing

an alternate means to fulfill the function of the core spray keep-fill system. The inspectors observed Exelon's response to this event, including operator and fire

brigade actions, emergency action level assessment, system and component availability/operability and compliance with technical specifications, implementation of

contingency actions, and additional corrective actions. The inspectors also walked down

the affected

480 VAC room components. The affected

MCCs were subsequently re-

energized at 5:29 AM on November 8. Following the event, station management

instituted an electrical work stoppage/stand down, with discussion of this event focusing

on use of the proper tools for work and recognizing potential hazards and wearing the proper protective safety equipment. The inspectors reviewed Exelon's response for this event, including corrective actions, and found them to be adequate.

The performance deficiency associated with this finding involved Exelon not properly

implementing the requirements contained in procedure

MA -
AA [[-1000, "Conduct of Maintenance Manual." Specifically, the contractor electrician did not perform an adequate self-check of his work and did not properly use test equipment. Further, the electrician did not properly utilize personal protective equipment as required by]]
MA -
AA -1000, "Conduct of Maintenance Manual." Analysis The inspectors determined that Exelon personnel did not implement the requirements of procedure
MA -

AA-1000, "Conduct of Maintenance Manual." The finding

was more than minor because it was associated with the human performance attribute of

the Initiating Events Cornerstone and affected the 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. This finding was also similar to example Enclosure

4.b in

NRC Inspection Manual Chapter (

IMC) 0612, "Power Reactor Inspection Reports, " Appendix E, "Examples of Minor Issues," in that Exelon did not adequately self-check to ensure the instrument alligator clip was properly connected to the appropriate breaker

leads. In accordance with NRC Inspection Manual Chapter 0609, Appendix G, Attachment 1,

"Shutdown Operations Significance Determination Process Phase 1 Operational Checklists for Both

PWR [[s [Pressurized Water Reactors] and]]

BWRs [Boiling Water Reactors]," the inspectors evaluated the significance of this finding. The inspectors

determined that Checklist 7,

BWR [[Refueling Operation with Reactor Coolant System Level > 23 feet," was applicable. The finding was determined to have very low safety significance (Green) because it did not increase the likelihood of a loss of reactor coolant system (]]

RCS) inventory, did not affect the licensee's ability to terminate a leak path or add inventory to the RCS, or degrade the licensee's ability to recover decay heat

removal in the event it was lost.

The performance deficiency had a cross-cutting aspect in the area of human performance because Exelon personnel did not properly implement human error prevention techniques, such as self and peer checking H.4(a). Enforcement. 10 CFR Part 50, Appendix B, Criterion V, "Instructions, Procedures, and drawings," requires, in part, that activities affecting quality shall be prescribed by

documented procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures. Exelon maintenance procedure

MA -

AA-1000 is a procedure affecting quality that establishes the maintenance standards

of performance. This procedure states, in part, that self-check shall be used for

equipment manipulation, tools and test equipment shall be used properly, and required

protective safety equipment shall be worn. Contrary to the above, on November 7, a contractor electrician did not perform an adequate self-check and did not properly use test equipment during maintenance, resulting in a phase to phase fault, halon system

actuation, and a loss of safety related equipment. In addition, the worker did not wear the required protective safety equipment during the work activity. Because this issue was of very low safety significance (Green) and Exelon has entered this issue into their

corrective action program in condition report

IR 842131, this violation is being treated as an
NCV consistent with Section
VI.A. 1 of the

NRC Enforcement Policy. (NCV 05000219/2008005-01: Conduct of Maintenance Procedure Not Properly Implemented) 1R13 Maintenance Risk Assessments and Emergent Work Control (71111.13)

a. Inspection Scope (71111.13 - 4 samples) The inspectors reviewed four on-line risk management evaluations through direct

observation and document reviews for the following plant configurations:

  • Containment spray system 1, 'A' control rod drive pump and 'B' motor generator set unavailable due to planned maintenance on October 16; * Core spray system 2 unavailable due to planned maintenance and '1-3' station air compressor unavailable due to unplanned maintenance on December 15; Enclosure
  • Turbine building closed cooling water system heat exchanger 1 unavailable due to planned maintenance, '1-3' station air compressor unavailable due to unplanned maintenance and elevated temperatures on B Isolation Condenser Shell on December 18; and * #2 air compressor trip due to inlet flow restriction on December 26. The inspectors reviewed the applicable risk evaluations, work schedules, and control

room logs for these configurations to verify the risk was assessed correctly and

reassessed for emergent conditions in accordance with Exelon's procedures. Exelon's

actions to manage risk from maintenance and testing were reviewed during shift turnover meetings, control room tours, and plant walkdowns. The inspectors also used Exelon's on-line risk monitor (Paragon) to gain insights into the risk associated with

these plant configurations. Additionally, the inspectors reviewed corrective action

program condition reports documenting problems associated with risk assessments and emergent work evaluations. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings No findings of significance were identified. 1R15 Operability Evaluations (71111.15) a. Inspection Scope (2 samples) The inspectors reviewed two operability evaluations for degraded or non-conforming conditions associated with: *

GEMAC wide range reactor vessel level instrument on November 6 (

IR 836518); and * Source range monitor (SRM) 21 on November 26 (IR 841602). The inspectors reviewed the technical adequacy of the operability evaluations to ensure the conclusions were technically justified. The inspectors also walked down accessible portions of equipment to corroborate the adequacy of Exelon's operability evaluations. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. b. Findings No findings of significance were identified. 1R18 Plant Modifications (71111.18) a. Inspection Scope (2 samples) The inspectors reviewed one permanent plant modification and one temporary plant modification that was installed when Oyster Creek was on line. Enclosure

The permanent modification involved the replacement of check valve V-5-165 due to a failed local leak rate test (LLRT). Specifically, after failing its local leak rate test, Exelon replaced V-5-165 with a suitable replacement and retested the valve satisfactorily. The inspectors reviewed the engineering change package, design and licensing basis

documentation to ensure that the changes implemented by Exelon were in accordance

with plant procedures and NRC regulations. The inspectors ensured that appropriate

revisions to licensing and design documents and operating procedures were being made and would support operations when the modifications were completed. The temporary modification involved the installation of a temporary filter in the control rod drive (CRD) system during refueling outage 1R22. The inspectors reviewed the engineering change package, design and licensing basis documentation to ensure that the changes implemented by Exelon were in accordance with plant procedures and NRC regulations. The inspectors walked down portions of the systems while the temporary

modification was being removed.

The inspectors also reviewed Exelon's 10 CFR 50.59 screening for the modifications. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. b. Findings No findings of significance were identified.

1R19 Post-Maintenance Testing (71111.19)

a. Inspection Scope (4 samples) The inspectors observed portions of and reviewed the results of four post-maintenance tests for the following equipment: * '1-1' emergency service water pump replacement on October 16 (WO R2126593); *

LLRT of check valve V-5-165 on December 2 (A2184770); * Post installation testing of the M1A main transformer deluge system on December 12 (

WO C2002155); and

  • Replacement of hydraulic control unit 50-35 hydraulic accumulator on December 12 (WO C2017578). The inspectors verified that the post-maintenance tests conducted were adequate for the scope of the maintenance performed and that they ensured component functional capability. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings No findings of significance were identified.

1R20 Refueling and Other Outage Activities (71111.20)

a. Inspection Scope (2 samples) Enclosure

The inspectors monitored Exelon=s activities associated with one refueling and one other outage activity. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. Refueling Outage (1R22) On October 24, operators initiated a plant shutdown to support the 1R22 refueling outage. The inspectors observed portions of the shutdown from the control room, and

reviewed plant logs to determine that technical specification (TS) requirements were met for placing the reactor in Ahot shutdown@ and Acold shutdown.@ The inspectors also monitored Exelon=s controls over outage activities to determine whether they were in accordance with procedures and applicable

TS requirements. The inspectors verified that cooldown rates during the plant shutdown were within

TS requirements. The inspectors performed a walkdown of portions of the drywell in

conjunction with Exelon's initial inspection of the drywell (primary containment) immediately following reactor shutdown on October 25. The inspectors performed additional walkdowns of portions of the drywell on October 28, November 3, November

5, and November 17; and the condenser bay and the main steam tunnel on October 30,

to verify there was no evidence of leakage or visual damage to passive systems

contained in these areas. During the walk down of the drywell the inspectors observed

that the drywell trenches discussed in

PNO -1-06-012, "Preliminary Notification of Event of Unusual Occurrence," dated November 9, 2006 (

ADAMS Accession Number: ML063130424), did not contain water upon initial entry on October 25 or on November 5.

During final drywell closeout on November 17, a trace amount of water was identified in

the Bay 5 trench. The likely source of the water was from recently completed

maintenance that occurred in its vicinity. The water was removed by Exelon personnel prior to the drywell being locked (IR 846240). The inspectors verified that Exelon assessed and managed the outage risk. The

inspectors confirmed on a sampling basis that tagged equipment was properly controlled

and equipment configured to safely support maintenance work. During control room tours, the inspectors verified that operators maintained reactor vessel level and temperature within the procedurally required ranges for the operating condition. The

inspectors also verified that the decay heat removal function was maintained through

monitoring shutdown cooling (SDC) system parameters during plant status and

performing a walkdown of the system on October 25. The inspectors observed Oyster Creek=s plant onsite review committee (PORC) startup affirmations from November 14 through November 16. The inspectors determined that offsite and onsite electrical power sources were maintained in accordance with TS requirements and consistent with the outage risk assessment. Periodic walkdowns of portions of the onsite electrical buses and the

emergency diesel generators were conducted during risk significant electrical

configurations to confirm the equipment alignment met requirements. The inspectors

verified through routine plant status activities that decay heat removal safety function was maintained with appropriate redundancy as required by TS and consistent with Exelon=s outage risk assessment. The inspectors verified that flow paths, configurations, and alternative means for inventory control were consistent with the outage risk assessment. Enclosure

The inspectors performed walkdowns of the poly bottles in the torus room to

determine if water was accumulating in the drywell sand bed drains on October 27 and

November 10. The poly bottles did not contain or show evidence of water on those

dates. The inspectors performed an inspection and walkdowns of portions of the drywell prior to

containment closure on November 17, to verify there was no evidence of leakage or

visual damage to passive systems and to determine whether debris was present which

could affect drywell suppression pool performance during postulated accident conditions. The inspectors monitored restart activities that began on November 17, to ensure that required equipment was available for operational condition changes, including verifying TS requirements, license conditions, and procedural requirements. Portions of the

startup activities were observed from the control room to assess operator performance

including achievement of reactor criticality on November 17, placing the mode switch to

run and synchronization of the main turbine generator to the grid on November 18. The inspectors further verified that unidentified leakage and identified leakage rate values were within expected values and within technical specification requirements.

Other Outage Activity - Forced Outage due to Main Transformer Failure (1F17). On November 28, an automatic load reject scram occurred due to a failure of the M1A Main

Transformer. Details of the scram and operator response to the scram are provided in section 4OA3. The inspectors responded to the control room and observed portions of the post-scram recovery and plant cooldown. The inspectors verified that cooldown

rates during the plant shutdown were within TS requirements. The drywell remained

closed and inerted throughout the outage.

The inspectors verified that Exelon assessed and managed the outage risk. The inspectors confirmed on a sampling basis that tagged equipment was properly controlled

and equipment configured to safely support maintenance work. During control room tours, the inspectors verified that operators maintained reactor vessel level and temperature within the procedurally required ranges for the operating condition. The

inspectors also verified that the decay heat removal function was maintained through monitoring shutdown cooling (SDC) system parameters during plant status and performing a walkdown of the system on December 1. The inspectors observed Oyster Creek=s

PO [[]]

RC startup affirmations on December 3 and December 4. Operators commenced a reactor startup and established the reactor critical on

December 5, and synchronized the main generator to the grid and reached full power

on December 6. b. Findings Introduction. The inspectors identified an

NCV of

TS 3.9.D, "Refueling", when Exelon performed core alterations without the required configuration of operable source range monitors (SRM). Specifically, Exelon installed two fuel assemblies in a quadrant when

the required configuration of SRMs was not operable. In response, Exelon entered this issue into the corrective action program and implemented actions to revise the reactor refueling procedure. Enclosure

Description. On November 7, during plant status review, the inspectors identified that

SRM 21 was listed as out of service at 9:24
PM on November 6 and declared inoperable at 11:53
PM. Exelon had commenced the second phase of refueling at 10:30

PM on

November 6. After reviewing the technical specifications and refueling procedure fuel

move sheets, the inspectors identified that two fuel assemblies were installed in reactor

quadrant one at 10:52

PM and 11:23
PM , during which time
SRM 21 was inoperable. Technical Specification 3.D.9 requires

SRM 21 and either SRM 22 or 24 to be operable when performing core alterations in reactor quadrant one. The inspectors engaged the

Shift Manager and were told that the guidance contained in Exelon procedure 205.0,

"Reactor Refueling" allowed monitoring of the two fuel movements in question with either

SRM 21 or

SRM 22 operable. The inspectors brought the discrepancy between the guidance contained in the refueling procedure and the requirements contained in TS to the attention of Exelon licensing staff, who verified that the procedure did conflict with

the requirements contained in the TS and entered the issue into the corrective action

program as

IR 844470.

SRM 21 was repaired and returned to service at 6:55 PM on

November 8. The performance deficiency associated with this finding involved Exelon not properly

implementing the requirements of

TS 3.9.D and moved fuel without the required

SRMs

to monitor the fuel movements.

Analysis. The inspectors determined that Exelon personnel did not properly implement the requirements of TS 3.9.D. The finding is more than minor because it affects the

configuration control attribute of the barrier integrity cornerstone objective of providing

reasonable assurance that physical design barriers protect the public from radionuclide

releases caused by accidents or events. Specifically, during a time of decreased

availability of physical barriers (refueling outage), Exelon performed fuel movements without the required configuration of operable source range monitors.

Using Appendix G, "Shutdown Operations Significance Determination Process," of

Manual Chapter 0609, "Significance Determination Process," the finding was determined

to have very low safety significance (Green) because it did not increase the likelihood of

a loss of reactor coolant system (RCS) inventory, did not affect the licensee's ability to terminate a leak path or add inventory to the RCS, or degrade the licensee's ability to recover decay heat removal in the event it was lost. The performance deficiency had a cross-cutting aspect in the area of human

performance, because Exelon did not ensure that the reactor refueling procedures accurately implemented the neutron monitoring requirements contained in the Technical Specifications H.2(c).

Enforcement.

TS 3.9.D states that at least two
SRM channels shall be operable during core alterations. Additionally,
TS 3.9.D requires that one of the operable

SRM channels

shall be located in the core quadrant where core alterations are being performed, and the other shall be in an adjacent quadrant. Contrary to the above, on November 6, 2008, the licensee performed core alterations (installed 2 new fuel assemblies) in

quadrant one of the reactor while SRM channel 21 was inoperable. Because this issue

is of very low safety significance (Green) and Exelon entered this issue into their

corrective action program (IR 844470), this violation is being treated as an NCV, Enclosure

consistent with Section

VI.A. 1 of the

NRC Enforcement Policy. (NCV 05000219/2008005-02, "Core Alterations Performed Without the Required Configuration of Source Range Nuclear Monitors.") 1R22 Surveillance Testing (71111.22)

a. Inspection Scope (4 samples - 1 In-Service Testing, 1 Routine Surveillance, and

2 LL [[]]

RT) The inspectors observed portions of and reviewed the results of four surveillance tests:

  • Standby liquid control in-service test on September 30; * Main steam isolation valve local leak rate test on October 30; * Isolation condenser vent valve (V-14-1) local leak rate test on October 31; and * Emergency diesel generator #1 loss of offsite power testing on November 3. The inspectors verified that test data was complete and met procedural requirements to demonstrate that the systems and components were capable of performing their intended function. The inspectors also reviewed corrective action program condition

reports that documented deficiencies identified during these surveillance tests.

Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings No findings of significance were identified. Cornerstone: Emergency Preparedness [EP]

1EP 2 Alert and Notification System (

ANS) Evaluation (71114.02)

a. Inspection Scope (1 Sample) An onsite review was conducted to assess the maintenance and testing of the Oyster

Creek

ANS. During this inspection, the inspectors interviewed the

ANS Manager who is

responsible for implementation of the ANS testing and maintenance program. The

inspectors further discussed with the

ANS manager the performance of the

ANS siren

system from February 2007 through September 2008. The inspectors reviewed the

ANS procedures and the

ANS design report to ensure compliance with those commitments for system maintenance and testing. Additionally, the inspectors reviewed changes to

the design report and how these changes are captured. The inspection was conducted

in accordance with

NRC Inspection Procedure 71114, Attachment 2. Planning standard,
CFR 50.47(b) (5) and the related requirements of 10

CFR 50, Appendix E were used as reference criteria. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings No findings of significance were identified. Enclosure

1EP 3 Emergency Preparedness Organization Staffing and Augmentation System (71114.03) a. Inspection Scope (1 Sample) A review of Oyster Creek's Emergency Response Organization (

ERO) augmentation

staffing requirements and the process for notifying the ERO was conducted. This was performed to ensure the readiness of key staff for responding to an event and to ensure timely facility activation. The inspectors reviewed procedures and condition reports

associated with the ERO notification system and drills, and reviewed records from call-in

drills from February 2007 through September 2008. The inspectors interviewed

personnel responsible for testing the

ERO augmentation process, and reviewed the training records for a sampling of
ERO responders to ensure training and qualifications were up to date. The inspectors reviewed procedures for
ERO administration and training, and verified a sampling of

ERO responders who participated in exercises in 2007 and 2008. The inspectors also reviewed records of offsite agency training. The

inspection was conducted in accordance with

NRC Inspection Procedure 71114, Attachment 3. Planning standard, 10

CFR 50.47(b) (2) and related requirements of 10 CFR 50 Appendix E were used as reference criteria. Documents reviewed for this

inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings No findings of significance were identified.

1EP 4 Emergency Action Level (

EAL) and Emergency Plan Changes (71114.04) a. Inspection Scope (1 Sample) The inspectors conducted a review of Oyster Creek's 10 CFR 50.54(q) screenings for all

the changes made to the EALs and all of the changes made to the Emergency Plan from

June 2006 through September 2008 that could potentially result in a decrease in

effectiveness. This review of the

EAL and Emergency Plan changes did not constitute
NRC approval of the changes and, as such, the changes remain subject to future
NRC inspection. The inspection was conducted in accordance with
NRC Inspection Procedure 71114, Attachment 4. The requirements of 10

CFR 50.54(q) were used as

reference criteria. Documents reviewed for this inspection activity are listed in the

Supplemental Information attachment to this report.

b. Findings No findings of significance were identified.

1EP5 Correction of Emergency Preparedness Weaknesses (71114.05)

a. Inspection Scope (1 Sample) The inspectors reviewed a sampling of self-assessment procedures and reports to

assess Oyster's Creek's ability to evaluate their performance and programs. The

inspectors reviewed a sampling of condition reports from January 2007 through Enclosure

September 2008 initiated by Oyster Creek from drills, self-assessments and audits. Additionally, the inspectors reviewed audits for 2007 and 2008 that were required by

10 CFR 50.54(t). This inspection was conducted in accordance with

NRC Inspection

Procedure 71114, Attachment 5. Planning standard, 10 CFR 50.47(b) (14) and the

related requirements of 10 CFR 50 Appendix E were used as reference criteria.

Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report.

b. Findings No findings of significance were identified.

2.

RADIAT [[]]
ION [[]]
SAFETY [[Cornerstone: Occupational Radiation Safety []]
OS [[]]]
2OS 1 Access Control to Radiologically Significant Areas (71121.01) a. Inspection Scope (17 samples) The inspectors reviewed external and internal occupational dose assessments relative to applicable performance indicators (

PIs). (See Section 4OA1) The inspectors identified exposure significant work areas during station tours and walked

down selected radiological controlled areas and conducted independent radiation

surveys. The inspectors observed and evaluated housekeeping, material conditions,

posting, barricading, and access controls to determine if radiological controls were

acceptable. The inspectors determined that prescribed radiation work permit (RWP), procedure, and engineering controls were in place. The inspectors attended job briefings and evaluated Exelon's use of approved respiratory protective equipment. The

inspectors conducted independent radiation surveys with a survey instrument to evaluate ambient conditions and adequacy of applied radiological controls. The inspectors toured outage work areas and reviewed on-going radiologically significant work activities in the drywell, reactor building, turbine building, and refueling floor. The inspectors conducted direct observation and review of on-going outage work

activities such as reactor disassembly, reactor refueling, in-vessel inspection, turbine

blade repairs, turbine control and stop valve repairs, turbine component sand blasting,

condenser bay valve repair, replacement of electromatic relief and safety valves, and repairs to 'C' reactor recirculation pump. The inspectors reviewed the Exelon's radiation protection refuel outage readiness checklists. The inspectors reviewed Exelon's

implementation of TS high radiation area controls. The review included evaluation of the

adequacy of applied radiological controls, including RWPs, procedure adherence,

radiological surveys, system breach surveys, airborne radioactivity sampling, contamination controls, and barrier integrity and associated engineering control performance. The inspectors evaluated the adequacy of personnel monitoring in areas of potential dose rate gradients. The inspectors reviewed use of electronic dosimeters

(ED) including the adequacy of ED setpoints, verified that workers knew actions to take

upon receipt of an

ED alarm and compared of

ED exposure results with

thermoluminescent dosimeter exposure results. Enclosure

The inspectors reviewed internal dose assessments for 2008 to identify apparent occupational internal doses greater than 50 millirem committed effective dose equivalent

(CEDE). The review included evaluation of the adequacy of selected dose assessments

and review of the program for evaluation of potential intakes associated with hard-to-

detect radionuclides (e.g., transuranics). The inspectors reviewed applicable

10 CFR Part 61 waste stream analysis and scaling factor reports. The inspectors attended an Oyster Creek
ALA [[]]

RA Committee meeting held to discuss

outage performance, including personnel contamination frequency and internal

exposures status. The inspectors reviewed physical and programmatic controls for highly activated or

contaminated non-fuel items stored within spent fuel or other storage pools. The inspectors conducted post-outage station tours and walked down radiological

controlled areas to evaluate post-outage housekeeping, material conditions, posting, barricading, and access controls. The inspectors reviewed self-assessments and audits to determine if identified problems were entered into the corrective action program for resolution. The inspectors evaluated

the database for repetitive deficiencies or significant individual deficiencies to determine

if self-assessment activities were identifying and addressing deficiencies at an appropriate threshold. The review included evaluation of data to determine if any deficiencies involved PI events with dose rates greater that 25 R/hr at 30 centimeters,

greater than 500 R/hr at 1 meter or unintended exposures greater than 100 millirem total

effective dose equivalent (TEDE), 5 rem shallow dose equivalent (SDE), or 1.5 rem lens

dose equivalent (LDE). The inspection included a review of condition reports which involved potential radiation

worker or radiation protection personnel errors to determine if there was an observable

pattern traceable to a similar cause and an evaluation of corrective actions. In addition, the inspectors reviewed outage radiological oversight activities.

The inspectors discussed high radiation area (HRA) access control procedure changes implemented since the last inspection with the Radiation Protection Manager and selected supervisors to determine if the changes resulted in a reduction in the

effectiveness and level of worker protection. During station tours, the inspectors

reviewed implementation of

HRA and very high radiation area (
VHRA ) controls and discussed
HRA controls with in-field, lead radiological controls personnel. The inspectors reviewed posting, barricading, and locking of

HRAs. The inspectors

discussed controls established for special areas that had the potential to become Very

High Radiation Areas. The inspectors conducted a locked HRA key inventory to validate

proper control and issuance of locked HRA access keys.

During station tours, the inspectors observed radiation worker performance with respect to stated

RWP requirements. The inspectors questioned workers to determine if they were aware of the significant radiological conditions in their workplace, the

RWP

controls/limits in place, and if their work performance took into consideration the level of

radiological hazards present. The inspectors questioned workers in various areas of the Enclosure

radiological controlled area to determine their knowledge of ambient radiological conditions. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. b. Findings

No findings of significance were identified.

2OS 2

ALARA Planning and Controls (71121.02) Inspection Scope (8 samples) The inspectors performed the following samples to determine if Exelon was implementing operational, engineering, and administrative controls to maintain personnel

occupational radiation exposure as low as is reasonably achievable (ALARA). The

review was based upon the criteria contained in 10 CFR 20, applicable industry

standards and Oyster Creek procedures. The inspectors reviewed pertinent information regarding station collective dose history,

current exposure trends, and ongoing or planned activities in order to assess current

performance and exposure challenges. The inspectors determined the site specific trends in collective exposures (using

NUR [[]]

EG-0713 and plant historical data), source-term (average contact dose rate with reactor coolant piping) measurements and the plant=s three-year rolling average collective exposure. The inspectors reviewed site specific procedures associated with

maintaining occupational exposures

ALA [[]]

RA. The inspectors also reviewed the processes used to estimate and track activity specific exposures. The inspectors reviewed planning and preparation for the refueling outage to determine

if Exelon had established procedures, engineering and work controls, based upon sound radiation protection principles, to achieve occupational exposures that were

ALA [[]]

RA. The inspectors selected work activities likely to result in the highest collective personnel radiation exposures and reviewed the planning and preparation for those work activities

to determine if

ALARA requirements were integrated into work procedure and

RWP

documents. Specifically, the work activities reviewed by the inspectors were under vessel work (control rod drive change-out), in-service inspection, scaffolding activities,

various valve work activities, refueling activities, and radiological controls coverage. The inspectors compared the results achieved (dose and dose rate reductions, person-

rem expended) with the estimated occupational doses established in the initial

ALA [[]]

RA plans for selected work activities conducted during the fall 2008 refueling outage. The inspectors reviewed implementation of program requirements for re-evaluation of dose

estimates including re-review of work plans by the Oyster Creek

ALA [[]]

RA Committee. The inspectors also reviewed exposure tracking for ongoing outage activities.

The inspectors reviewed under vessel work/control rod drive change-out, in-service inspection, scaffolding activities, various valve work activities, refueling activities, and radiological controls coverage. The inspectors evaluated the use of

ALA [[]]

RA controls for Enclosure

these work activities by reviewing use of engineering controls, implementation of

ALA [[]]

RA procedures and controls, and use of shielding. The inspectors observed workers to determine if workers were utilizing low dose waiting areas and to determine if workers received appropriate on-the-job supervision to ensure

the

ALA [[]]

RA requirements were met. The inspectors also reviewed job supervisor

oversight to ensure the work activities were conducted in a dose efficient manner (e.g., work crew size minimized, workers properly trained, proper tools and equipment). The inspectors attended worker briefings to evaluate the adequacy of radiological controls

briefings and reviewed exposures of individuals from selected work groups. The inspectors reviewed Exelon=s evaluations and efforts in the area of source term controls. Areas reviewed included shielding, chemical controls, shutdown methodology,

flood-up strategy, and clean-up strategies. The inspectors also reviewed radiation

measurements on primary system piping, including trends and current status. The inspectors also discussed longer term source term reduction plans and efforts with

Oyster Creek managers. The inspectors made independent radiation measurements during tours to validate efforts. The inspectors observed radiation worker and radiation protection technician

performance during work activities being performed in radiation areas, airborne radioactivity areas, and high radiation areas. The inspectors observed activities that presented the greatest radiological risk to workers (e.g., under vessel work, reactor

refueling pool work). The inspectors evaluated observed work practices to determine if

workers demonstrated the

ALA [[]]

RA philosophy in practice (e.g., were workers familiar

with the work activity scope and tools to be used, were workers utilizing

ALA [[]]

RA low dose waiting areas) and whether there were any procedure compliance issues (e.g., were work activity controls followed). The inspectors observed worker/technician performance to determine if performance was consistent with expectations considering

potential radiological hazards and the work involved.

The inspectors reviewed the exposure and monitoring controls employed by Exelon for declared pregnant workers with respect to

10 CFR 20 requirements. The inspectors reviewed self-assessments, audits, and special reports related to the

ALARA program to determine if identified problems were entered into the corrective

action program for resolution. The inspectors reviewed dose significant post-job (work activity) reviews and post-outage

ALA [[]]

RA report critiques of exposure performance to determine if identified problems were properly characterized, prioritized, and resolved in

an expeditious manner.

The inspectors reviewed overall

ALA [[]]

RA performance for 2008 including the refueling outage. The inspectors compared accrued occupational dose for various work tasks, relative to initial task estimates. Outage tasks reviewed, relative to initial estimates,

included under vessel work/control rod drive change-out, in-service inspection,

scaffolding activities, shielding activities, various valve work activities, recirculation system pump and motor work, and various refueling activities including reactor

disassembly and reassembly. Enclosure

The inspectors evaluated assumptions and bases for current annual collective exposure estimates and reviewed the dose rate and person-hour estimates (versus actual sustained) for accuracy, for the tasks reviewed. The inspectors reviewed procedures and methods used to adjust exposure estimates

(e.g., work-in-progress reviews) or modifying existing work packages, caused when

unexpected changes in scope or emergent work are encountered. The inspectors also reviewed the level of tracking detail, exposure report timeliness, and exposure report distribution. Documents reviewed for this inspection activity are listed in the

Supplemental Information attachment to this report. b. Findings No findings of significance were identified.

2OS 3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03) a. Inspection Scope (2 samples) The inspectors reviewed the radiological source term, based on 10

CFR Part 61 data, to identify potential changes in radiation types and energies that could impact instrument

calibrations and/or analyses. The inspectors reviewed calibration records and

operability determination documentation for selected instruments used for job coverage. The inspectors reviewed audits and self-assessments in the area of radiation monitoring equipment and protective equipment to determine if identified issues in this area were

entered into the corrective action program. The inspectors reviewed condition reports and action requests to evaluate Exelon=s threshold for identifying, evaluating, and resolving problems in this area. Documents reviewed for this inspection activity are listed in the Supplemental Information attachment to this report. b. Findings

No findings of significance were identified.

4.

OTHER [[]]
ACTIVI [[TIES [OA]]]
4OA 1 Performance Indicator (

PI) Verification (71151) a. Inspection Scope (10 samples) The inspectors reviewed Exelon's program to gather, evaluate, and report information on five performance indicators (PIs) associated with the mitigating systems performance index (MSPI). The inspectors used the guidance provided in Nuclear Energy Institute (NEI) 99-02, Revision 5, "Regulatory Assessment Performance Indicator Guideline" to

assess the accuracy of Exelon's collection and reporting of PI data. The inspectors

reviewed operating logs and corrective action program condition reports. The inspectors

verified the accuracy and completeness of the reported data from October 1, 2007 through September 30, 2008 for the following PIs: Enclosure

  • Emergency AC Power System; * High Pressure Injection System; * Heat Removal System; * Residual Heat Removal System; and * Cooling Water Systems. The inspectors reviewed Exelon's program to gather, evaluate, and report information on

three performance indicators (PIs) associated with the Emergency Plan. The inspectors reviewed supporting documentation from drills and tests for July 1, 2007 through

September 30, 2008, to verify the accuracy of the reported data. The acceptance criteria used for the review were

10 CFR 50.9 and
NEI 99-02, Revision 5, "Regulatory Assessment Performance Indicator Guidelines." The
PI s included: * Drill and Exercise Performance (
DEP ); *
ERO Drill Participation; and *

ANS Reliability. The inspectors reviewed Exelon's Occupational Exposure Control Effectiveness

Performance Indicator (PI) Program. The inspectors reviewed corrective action program

records for occurrences involving High Radiation Areas, Very High Radiation Areas, and

unplanned personnel radiation exposures since the last inspection in this area. The

acceptance criteria used for the review was that specified in

NEI 99-02, Regulatory Assessment Performance Indicator Guideline, Rev. 5. The purpose of this review was to verify that occurrences that met

NEI criteria were recognized and identified as

Performance Indicators. Documents reviewed for this inspection activity are listed in the

Supplemental Information attachment to this report. b. Findings No findings of significance were identified.

4OA2 Identification and Resolution of Problems (71152) .1 Review of Items Entered Into the Corrective Action Program a. Inspection Scope (1 sample) The inspectors performed a daily screening of items entered into Exelon's corrective action program to identify repetitive equipment failures or specific human performance issues for follow-up. This was accomplished by reviewing hard copies of each condition report, attending daily screening meetings, or accessing Exelon's computerized database.

b. Findings

No findings of significance were identified.

.2 Semi-Annual Review to Identify Trends a. Inspection Scope (1 sample) Enclosure

The inspectors performed one semi-annual trend review. The inspectors reviewed Exelon's corrective action program documents to identify trends that could indicate the existence of a more significant safety issue. The inspectors also performed a walkdown

of equipment important to safety to ensure issues were being properly identified and

corrected in the corrective action program. The review was focused on repetitive

equipment problems, human performance issues, and program implementation issues. The results of the trend review by the inspectors were compared with the results of normal baseline inspections. The review included issues documented outside the normal corrective action system, such as in system health reports and Oyster Creek

monthly management reports. The review considered a six-month period of June 1,

2008 through December 18, 2008. b. Assessment and Observations No findings of significance were identified.

The inspectors reviewed corrective action program condition reports for five high risk maintenance rule systems (core spray, containment spray, emergency service water,

isolation condenser and electromatic relief valves) and did not identify any adverse

trends. The inspectors also reviewed corrective action program conditions reports

associated with human performance issues and program implementation and did not identify any significant adverse trends. .3 Annual Sample Review (2 samples) Operator Work-Arounds

a. Inspection Scope The inspectors reviewed equipment issues that were identified by Exelon as operator work-arounds (OWAs) and operator challenges. The inspectors verified that the OWAs

were being properly controlled as specified by

OP -

AA-102-103, "Operator Work-Around

Program." The inspectors assessed the cumulative impact of the identified OWAs,

operator challenges, and control room deficiencies by performing a detailed document review and interviewing operations personnel during the week of December 23, 2008. In addition, the inspectors conducted a walkdown of the main control room and risk

significant plant areas to determine if these deficiencies adversely affected the ability of

operations personnel to implement emergency operating procedures or respond to plant transients. b. Findings and Observations No findings of significance were identified. The inspectors verified that

OWA s were being identified at an appropriate threshold, entered into the corrective action program, tracked for resolution, and the cumulative effects of

OWAs for mitigating systems were evaluated to determine the overall impact on the affected systems. Review of Stack Radiation Monitor System a. Inspection Scope Enclosure

The inspectors reviewed the availability and operation of the station's stack radiation monitor system (corrective action program condition reports

IR 661532 and

IR 658467). Exelon had been experiencing difficulty with the system's auto-filter changer apparatus. The inspectors discussed the status of the system with chemistry personnel responsible

for effluent sampling and also discussed system operation with the system engineer.

The inspectors also reviewed corrective action documentation associated with the

operation and availability of the system.

b. Findings and Observations

Introduction. An unresolved item (URI) was identified because additional information and a review of system sampling capabilities is required to determine if there are any impacts to Oyster Creek's emergency plan and to determine if any performance deficiency exists. The inspectors plan to review the additional information after it is complied by Exelon, which had not occurred by the end of this inspection period. Description. As a result of the difficulties experienced with the in-line auto filter change apparatus, Exelon has initiated action to replace the system with an updated model. In

the interim, the installed conventional direct in-line particulate and iodine sampling

system was placed in service to implement the sampling provisions of Oyster Creek's

Offsite Dose Calculation Manual (ODCM). The sampling system continues to auto-

adjust flow rates to ensure proper collection of isokinetic samples. A separate sampling

apparatus provides for sampling of tritium. A review of the availability of the system indicates the system has met requirements for sampling in accordance with the

OD [[]]

CM

and has maintained high reliability. At the time of this inspection, the inspectors had not

completed a review of potential emergency response implications associated with

collection and analysis of particulate and iodine samples during accident conditions, relative to the changes in sample collection methodology (i.e., inability to use the auto-filter change-out capability). Exelon is providing additional information regarding collecting samples using the installed in-line particulate and iodine sampling system. Inspectors will review the additional information against the requirements of the

emergency plan to determine if a performance deficiency exists. (URI 05000219/2008005-03: Stack Radiation Monitoring System Sampling Capabilities)

4OA 3 Event Follow-up (71153) (3 samples) The inspectors performed three event follow-up inspection activities. Documents reviewed for this inspection activity are listed in the Supplemental Information attached to this report. .1 Fire in 480
VAC Junction Box a. Inspection Scope On October 23, operations personnel in the control room responded to a
480 VAC junction box fire in the vicinity of the breathing air compressor building (

IR 835031). The

fire had no effect on plant operations but did interrupt power to the Breathing Air

Compressor Building and the Monitor and Control Facility (MAC). Enclosure

The inspectors arrived on site after being informed of the event on October 23. The inspectors performed a walkdown of the control room and discussed the issue with Exelon personnel in order to understand the effects of a loss of power to the MAC facility

and the breathing air system on plant operations. The inspectors also reviewed operator

logs, plant process computer (PPC) data, and system drawings to verify that there was

no effect on plant operations. b. Findings No findings of significance were identified. .2 Arc Flash / Smoke in 480 VAC Switchgear Room

a. Inspection Scope On November 7, operations personnel in the control room responded to alarms that indicated a fire in the

480 VAC room. Coincidentally, in-field personnel reported the presence of heavy smoke in the 480

VAC room. The inspectors responded to the control room after being informed of the event. The inspectors performed a walkdown of

the control room and discussed the associated event details with Exelon personnel in

order to understand the extent of the issues with the 480 VAC system, and any potential

impact to the plant. The inspectors also reviewed operator logs, PPC data, and system

drawings to understand the plant's response. The inspectors also interviewed engineering and maintenance personnel to understand the circumstances surrounding the work activity that was being performed in the

480 VAC room, during which the arc flash occurred. Subsequent to the initial recovery of the 480

VAC system, the inspectors

ensured no additional issues were observed with the 480 VAC system. The

maintenance effectiveness issues are discussed in Section 1R12 of this report.

b. Findings

No findings of significance were identified.

.3 Scram due to failure of M1A Transformer

a. Inspection Scope On November 28, operating personnel in the control room responded to an automatic load reject scram caused by the failure of the M1A transformer.

The inspectors responded to the control room following the notification of the scram and observed the response of Exelon personnel to the event, including operator actions in

the control room. At the time of the event, the inspectors verified that conditions did not

meet the entry criteria for an emergency action level (EAL) as described in the Oyster

Creek

EAL matrix. In addition, the inspectors reviewed 10
CFR 50.72, "Immediate Notification Requirements for Operating Nuclear Power Reactors," to verify that Exelon properly notified the
NRC during the event. The inspectors also reviewed

TS requirements to ensure that Oyster Creek operated in accordance with its operating

license. Enclosure

The inspectors reviewed PPC data, control room logs, and discussed the event with Exelon personnel to gain an understanding of how operations personnel and plant equipment responded during the event. The inspectors evaluated Exelon's program and process associated with event response to ensure they adequately implemented station

procedures

OP -
AA -108-114, "Post Transient Review" and
OP -

AA-106-101-1001, "Event

Response Guidelines." The inspectors observed the

PO [[]]

RC meeting prior to plant startup to evaluate whether Exelon understood the cause of the event and appropriately resolved issues identified during the event. The inspectors reviewed Exelon's prompt investigation and post-trip

review reports, both documented in

IR [[850348, to gain additional information pertaining to the event, and ensure that human performance and equipment issues were properly evaluated and understood prior to plant startup. b. Findings Introduction. An unresolved item was identified to review Exelon's root cause assessment and licensee event report (]]

LER) regarding the failure of the M1A main

transformer and subsequent load reject scram to determine whether a performance

deficiency existed which contributed to the transformer failure. The inspectors plan to

review Exelon's evaluation after it is completed, which had not occurred by the end of

this inspection period. Description. At 2101, November 28, Oyster Creek experienced a generator trip due to an A-phase and B-phase differential relay actuation, which resulted in a reactor shutdown due to a load reject scram. All safety systems operated as expected during the scram. The grid disturbance report provided by Jersey Central Power & Light,

combined with information from the Oyster Creek Digital Protective Relay System, differential voltage and current indication data, and dissolved gas in oil analysis indicated that the fault occurred on the B phase of the M1A Main Power Transformer. Exelon

entered this issue into their corrective action program in condition report

IR 850348. (

URI 05000219/2008005-04: Failure of M1A Transformer Causes an Automatic Load Reject Scram) 4OA5 Other .1 Quarterly Resident Inspectors Observations of Security Personnel and Activities

a. Inspection Scope

During the inspection period, the inspectors conducted the following observations of security force personnel and activities to ensure that the activities were consistent with

Exelon security procedures and regulatory requirements relating to nuclear plant

security. These observations took place during both normal plant working hours and

backshift hours. Specifically, the inspectors: * Observed operations within the central and secondary security alarm stations; * Toured selected security towers and security officer response posts; * Observed security force shift turnover activities; and * Observed security officers on compensatory posts. Enclosure

These quarterly resident inspectors' observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of inspectors' normal plant status review and inspection

activities.

.2 Independent Spent Fuel Storage Installation (ISFSI) Radiological Controls a. Inspection Scope The inspectors reviewed operational surveillance data for the

ISF [[]]

SI facility. The inspectors toured the facility and observed and evaluated implementation of radiological

controls, including

RWP s and postings, and discussed the controls with technicians and supervisory staff. Radiological control activities for

ISFSI areas were evaluated against 10 CFR Part(s) 20 and 50, and applicable licensee procedures and Certificate of

Compliance.

b. Findings No findings of significance were identified.

.3 (Closed) URI 05000219/2008004-02. Water with Tritium Identified in Excavation Area within the Protected Area. The inspectors reviewed Exelon's investigation results associated with the identification,

on September 8, of apparent tritium activity in a water puddle collected in an excavation,

within the Protected Area, for a new water storage tank. This issue was documented in

condition report 815415. Exelon conducted sampling of the water prior to pumping it

out. During the review, the inspectors walked down the excavation area, reviewed sample data including groundwater sample analysis results, inter-compared sample results with confirmatory samples, evaluated the likelihood of spillage or leakage, toured

the chemistry laboratory, and discussed the results with licensee personnel. This matter was initially reviewed during

NRC Inspection 05000219/2008004, dated October 29 and documented as

URI 05000219/2008004-02. The inspectors reviewed the circumstances

surrounding the identification of the sample, reporting of information, and conformance with the station=s

TS and associated

ODCM. Exelon developed a comprehensive list of possible causes for the apparent indication of tritium. Exelon concluded that the source of the water in the excavation was from passage of a rain storm. Exelon also concluded the cause of the indication of apparent

tritium in the water sample was attributable to an isolated instance of inadvertent cross-

contamination of the sample during sample processing within the onsite chemistry

laboratory. Exelon's review did not identify any credible means for the water sample, taken from a puddle from within the excavation, to reflect the levels of tritium indicated. Confirmatory sampling and analysis did not identify comparable tritium levels for

additional water samples collected from the excavation and water removed from the

excavation that had been drummed. Exelon also collected and analyzed groundwater

monitoring well water samples, from various wells surrounding the area, and did not

identify tritium in these well sample results. Consequently, the review did not identify any credible public or occupational doses associated with the issue. No reporting criteria were identified including reporting under the voluntary industry groundwater Enclosure

reporting criteria. Exelon suspended analysis of samples, enhanced analysis protocols, and tested the protocols via traceable radioactive standards, prior to resumption of routine analyses. Exelon resumed onsite analysis of tritium samples on November 14.

This unresolved item is closed.

b. Findings No findings of significance were identified.

.4 (Closed)

NRC Temporary Instruction (
TI ) 2515/175, Emergency Response Organization, Drill/Exercise Performance Indicator, Program Review. a. Inspection Scope The inspectors performed
NRC Temporary Instruction (
TI ) 2515/175, ensured the completeness of the
TI 's Attachment 1, and then forwarded that data to

NRC, HQ.

b. Findings No findings of significance were identified.

4OA6 Meetings, Including Exit Resident Inspectors Exit Meeting. On January 23, 2009, the inspectors presented the inspection results to Mr. P. Orphanos, Plant Manager, and other members of the Exelon

Staff, who acknowledged the conclusions and observations presented. The inspectors

confirmed that proprietary information reviewed during the inspection period was

returned to Exelon.

Regional Administrator Site Visit. On October 9, a site visit was conducted by Mr.

S. Collins, Regional Administrator, for the

NRC Region 1 office. During Mr. Collins' visit, he

toured the plant and met with Exelon personnel.

Director - Division of Reactor Projects Site Visit. On October 28, a site visit was conducted by Mr.

D. Lew, Director of the Division of Reactor Projects for the

NRC

Region 1 Office. During Mr. Lew's visit, he toured the plant (including a primary

containment entry) and met with Exelon personnel.

Executive Director of Operations Site Visit. On December 16, a site visit was conducted by Mr. W. Borchardt, Executive Director of Operations for the Nuclear Regulatory

Commission. During Mr. Borchardt's visit, he toured the plant and met with Exelon

managers. Mr.

D. Lew, Director of the Division of Reactor Projects for the

NRC Region

office, accompanied Mr. Borchardt on his visit.

4OA7 Licensee-Identified Violations The following violation of very low safety significance (Green) was identified by the

licensee and is a violation of

NRC requirements which meet the criteria of Section

VI of

the

NRC Enforcement Policy,

NUREG-1600, for being dispositioned as an NCV. Enclosure

Enclosure * TS 6.8.1, "Procedures and Programs", requires that written procedures be established and implemented covering the applicable procedures recommended in Appendix "A" of Regulatory Guide 1.33 as referenced in the Quality Assurance

Topical Report (QATR). Regulatory Guide 1.33, Rev.2, as referenced in the

QA [[]]

TR, recommends procedures for chemical and radiochemical control including

validity of calibration techniques and adequacy of analyses. Contrary to this, the

licensee modified its tritium analysis method to achieve an improved environmental lower limit of detection and did not follow its method development process outlined in station procedure

CY -

AA-130-200, Rev. Section 4.1, for

analysis of tritium using the method described in procedure

CY -

OC-130-530,

Rev.4, including completion of Attachment 6 of the procedure. This was

identified in the licensee's corrective action program as IR 832750. This finding is of very low safety significance because it involves the area of environmental monitoring and the radiological environmental monitoring program did not identify

unexpected conditions in the environment.

ATTACH [[]]
MENT [[:]]
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION [[]]
SUPPLE [[]]
MENTAL [[]]
INFORM [[]]
ATION [[]]
KEY [[]]
POINTS [[]]
OF [[]]

CONTACT Licensee Personnel

M. Chandra, Oyster Creek Emergency Preparedness Specialist

J. Dent, Director, Work Management

J. Dostal, Director, Operations S. Dupont, Regulatory Assurance Specialist A. Farenga, Oyster Creek Emergency Preparedness Manager
G. Harttraft,

ISI Program Manager, Oyster Creek

J. Kandasamy, Manager, Regulatory Assurance
T. Keenan, Manager Security G. Ludlam, Director, Training J. Makar, Senior Manager System Engineering G. McAllister,
ANS Manager
M. McAllister

NDE Level III Examiner, Oyster Creek

J. McCarthy, Manager, Technical Support M. McKenna, Shift Operations, Superintendent J. Murphy, Manager, Radiological Engineer

P. Orphanos, Plant Manager

R. Peak, Director, Engineering

D. Peiffer, Manager Nuclear Oversight

T. Rausch, Site Vice-President H. Ray, Senior Manager Design Engineering J. Renda, Manager Radiation Protection

T. Sexsmith, Manager Corrective Action Program

J. Vaccaro, Director, Maintenance

R. Wiebenga, Manager Environmental/Chemistry Manager

Others: P. Schwartz, State of New Jersey, Bureau of Nuclear Engineering

GE Hitachi Personnel T. Romano, Inservice Inspection Coordinator
LIST [[]]
OF [[]]
ITEMS [[]]
OPENED ,
CLOSED ,
AND [[]]
DISCUS [[]]

SED Opened/Closed 05000219/2008005-01 NCV Conduct of Maintenance Procedure Not Properly Implemented (Section 1R12)05000219/2008005-02 NCV Core Alterations Performed Without the Required Configuration of Source Range Nuclear Monitors.

(Section 1R20)

Opened 05000219/2008005-03

URI Stack Radiation Monitoring System Sampling Capabilities (Section 4

OA2)05000219/2008005-04

URI Failure of M1A Transformer Causes an Automatic Load Reject Scram (Section 4

OA3)

Closed

05000219/2008004-02

URI Water with Tritium Identified in Excavation Area within the Protected Area (Section 4
OA 5)
LIST [[]]
OF [[]]
DOCUME [[]]
NTS [[]]
REVIEW [[]]
ED In addition to the documents identified in the body of this report, the inspectors reviewed the following documents and records. Section 1R01: Adverse Weather Protection Procedures
OP -
OC -108-109-1001, "Preparation for Severe Weather
T& [[]]
RM for Oyster Creek"
OP -
AA -108-111-1001, "Severe Weather and Natural Disaster Guidelines"
WC -
AA -107, "Seasonal Readiness"
OP -
OC -108-1001, "Preparation for Severe Weather
T& [[]]
RN for Oyster Creek"
OP -
OC -108-109-1002, "Cold Weather Freeze Inspections"
OP -
OC -108-109-1003, "Winter Readiness"
ABN 32, "Abnormal Intake Level"

EP-AA-1010, "Radiological Emergency Plan Annex for Oyster Creek Station"

Work Orders R2130844 M216809

Condition Reports (IR) 815001 846770 848613 859525 859559 859583

Section 1R04: Equipment Alignment Procedures 304, Standby Liquid Control System Operation

310, "Containment Spray System Operation"

341, "Emergency Diesel Generator Operation"

Condition Reports (IR) 624925 824421 824420 842685 789733 792279 Other Documents GE 148F723, Liquid Poison System, Sheet 1

GE 148F740, "Containment Spray System", Sheet 1 Attachment

Section 1R05: Fire Protection Procedures

ABN -29, "Plant Fires" 101.2, "Oyster Creek Site Fire Protection Program"
CC -

AA-211, "Fire Protection Program"

333, "Plant Fire Protection System"

OP -
AA -201-009, "Control of Transient Combustible Material" Other Documents
OP -
OC -201-208 Attachment 1, "Oyster Creek Nuclear Generating Station Pre-Fire Plan - Reactor Building (-19' Elevation)
CRD Pump Room (
RB -FZ-1F3)
OP -
OC -201-208 Attachment 1, "Oyster Creek Nuclear Generating Station Pre-Fire Plan - Reactor Building (-19' Elevation) Northeast Corner Room (RB-FZ-1F4)
OP -
OC -201-208 Attachment 1, "Oyster Creek Nuclear Generating Station Pre-Fire Plan -
MG Set Room (
OB -FZ-8A)
OP -

OC-201-208 Attachment 1, "Oyster Creek Nuclear Generating Station Pre-Fire Plan - Main Transformer Area (MT-FA-12) 990-1746, "Oyster Creek Nuclear Generating Station Fire Hazards Analysis Report"

Section 1R07: Heat Sink Performance Procedures 607.4.005, "Containment Spray and Emergency Service Water Pump System 2 Operability and Comprehensive/Preservice/Post-Maintenance Inservice Test" Condition Reports (IR) A0703678

Other Documents Calculation C-1302-241-E120-085

UFS [[]]
AR Section 6.22, "Containment Heat Removal Systems"
UFS [[]]
AR Table 6.2-7, "Containment Spray Heat Exchangers"
UFSAR Table 6.2-15, "Containment Response to Minimum Containment Spray and Emergency Service Water System Flows" Section 1R08: In-Service Inspection
NDT Examination Reports Liquid Penetrant Examination Report
APR -003, Sheet
PT -002, weld
NR 02 2-565C (N2C) Recirc Safe End to Nozzle, completed 11/1/2008 Automated Ultrasonic Testing Data/Scan Parameter Sheet,
APR -003, weld
NR 02 2-565C (N2C) Recirc Safe End to Nozzle, Sheets
APD -003,
APD -004, and

APD-005, completed

11/5/2008 Liquid Penetrant Examination Report

APR -004, Sheet
PT -001, weld
NR 02 1-567A (N6A) Core Spray Safe End to Nozzle, completed 11/1/2008 Automated Ultrasonic Testing Data/Scan Parameter Sheet,
APR -004, weld
NR 02 1-567A (N6A) Core Spray Safe End to Nozzle, Sheets
APD -001 and
APD -002, completed 11/3/2008 Manual
UT Examination Report Number
OC 1R22-149, Sheets D-024, D-025, and D-026, Pipe to Valve V-20-0015, Weld

NZ-3-0004, completed 10/30/2008 Attachment

Manual

UT Examination Report Number
OC 1R22-081, Sheet D-052, Elbow to Pipe Weld
ND -1-0004, completed 11/3/2008 Manual
UT Examination Report Number
OC 1R22-084, Sheet D-050, Pipe to Pipe Weld
ND -1-0004C, completed 11/3/2008 Manual
UT Examination Report Number
OC 1R22-080, Sheet D-047, Pipe to Elbow Weld
ND -1-0003, completed 11/3/2008 Manual
UT Examination Report Number
OC 1R22-082, Sheet D-048 and D-049, Pipe to Valve V-16-0133, Weld
ND -1-0004A, completed 11/3/2008 Manual
UT Examination Report Number
OC 1R22-083, Sheet D-053 and D-054, Valve V-16-0133 to Pipe Weld
ND -1-0004B, completed 11/3/2008
UT Examination Summary Sheet Number
APR -001,
NR 02 4-565A (N1A) Recirc Outlet Nozzle to Safe End, 11/18/08, 30 pages Engineering Technical Evaluations
AT 00842492, Engineering Evaluation for the Acceptability of
UT Indication in weld
NR 02 4-565A, 11/14/08 Document Number
AM [[-2008-020, Revision 0, 11/13/08, Oyster Creek Reactor Recirculation Nozzle N1A Degradation Mechanism Review Structural Integrity Associates Calculation File No. 0801457.301, Flaw Evaluation of Oyster Creek N1A Suction (RPV Outlet) Nozzle-to-Safe End Weld, Revision 3, 11/12/08 Repair/Replacement Work Order C2012002, Replacement of Shutdown Cooling Loop 'C' Outlet Isolation Motor Operated Valve V-17-57, Form]]
NIS -2, dated 2/8/2007 Magnetic Particle Testing Examination Data Record 1R21-240, completed 11/5/2006 Magnetic Particle Testing Examination Data Record 1R21-241, completed 11/5/2006 Ultrasonic Testing Examination Sheet 1R21-240,

NU-2-17-X, Elbow to Valve Weld, Data Sheet D-314 and D-316, completed 11/5/2006 Ultrasonic Testing Examination Sheet 1R21-241, NU-2-18-X, Valve to Pipe Weld, Data Sheet D-317, D-318, and D-319, completed 11/5/2006

Procedures

ER -
AA -330, Conduct of In-service Inspection Activities, Rev. 7
ER -
AA -330-001, Section XI Pressure Testing, Rev. 8
ER -
AA -330-002, In-service Inspection of Section XI Welds and Components, Rev. 7
ER -
AA -330-009,
ASME Section
XI Repair/Replacement Program, Rev.
5 ER -
OC -330-1001,
ISI Program Plan Document, Fourth Ten-Year Inspection Interval, Oyster Creek Generating Station, Rev. 5
ER -OC-330-1002,
IGSCC Inspection Program, Fourth 10-Year Inspection Interval, Rev. 2 Other Documents Surveillance and Test Program Audit
NOSA -OYS-08-07 Oyster Creek September 22, 2008 to October 3, 2008 Program Health Report Oyster Creek Inservice Inspection (ISI) Program, 3rd Quarter 2008
RPV and Internals Program (
IVVI )/BWRVIP) Oyster Creek Generating Station
ER -
AB -331, 3rd Quarter
2008 ASME Code Case N-568 Alternative Examination Requirements for Class 1, 2 and 3 Piping, Components and Supports

EPRI Evaluation of Dissimilar Metal Weld Examinations Performed at Oyster Creek during Refueling Outage 22 (1R22), IR-2008-340, dated 11/2008 Attachment

IRs 550305 744982 836642 842492

Section 1R11: Licensed Operator Requalification Program

Procedures

ABN -1, "Reactor Scram"
ABN -40, "Stuck Open
EMRV "
EMG -3200.01B, "
RPV Control w/
ATWS " Support Procedure 16, "Bypassing
MSIV Lo-Lo Level Isolation Interlocks and the
RBCCW Interlocks" Support Procedure 17, "Termination and Prevention of Injection" Support Procedure 25, "Initiation of Containment Spray System in the Torus Cooling Mode" Other Documents
EOP User's Guide (2000-BAS-3200.02) Section 1R12: Maintenance Effectiveness Procedures
ER -
AA -310, "Implementation of Maintenance Rule"
ER -
AA -310-1005, "Maintenance Rule - Disposition Between (a)(1) and (a)(2)"
LS -
AA -125-1003, "Apparent Cause Evaluation Manual"
MA -

AA-1000, "Conduct of Maintenance Manual"

Condition Reports (IR) 848586 842131

Work Order R2094262 Other Documents

NEI 93-01, "Industry Guideline for monitoring the Effectiveness of Maintenance at Nuclear Power Plants" Section 1R13: Maintenance Risk Assessments and Emergent Work Control Procedures
ER -AA-600-1042, "On-line Risk Management"
ER -
AA -600-1021, "Risk Management Application Methodologies"
ER -
AA -600-1014, "Risk Management Configuration Control"
ER -
AA -600-1011, "Risk Management Program"
WC -

OC-101-1001, "On-line Risk Management and Assessment" 334, "Instrument and Service Air System"

309.1, "Turbine Building Closed Cooling Water"

Condition Report (IR) 857633 860216

Other Documents

EXOC 011-

CALC-001, "Isolation Condenser Heat Capacity" Attachment

Section 1R15: Operability Evaluations Procedures

OP -

AA-108-115, "Operability Determination"

209.95.0, "Reactor Flood-up/Drain-down"

Drawings GE 148F444, "Cleanup Demineralizer System Flow Diagram"

Condition Reports (IR) 836518 841602 850390

Other Documents NRC Inspection Manual - Part 9900 Technical Guidance, "Operability Determinations & Functionality Assessments for Resolution of Degraded or Nonconforming Conditions

Adverse to Quality or Safety Oyster Creek Nuclear Generating Station Operations Plant Manual Figure 55-1: "Cold Reference Leg Level Instrument" Oyster Creek Nuclear Generating Station Operations Plant Manual Figure 55-4: Reactor Water Level Instrument Ranges" 2611-PGD-2621, Nuclear Plant Operator Training Module "RX Vessel Instrumentation" Technical Specifications

3.D. 9, "Refueling"
UFSAR Table 7.6-1, "Summary of Reactor Vessel Water Level Instruments"

RO/STA 98-1, Lesson Plan: "Vessel Instruments - Level" Section 1R18: Plant Modifications

Procedures

CC -
AA -103, "Configuration Change Control for Permanent, Physical Plant Changes" 665.5.006, "Local Leak Rate Tests"
CC -
AA -112, "Temporary Configuration Changes"
CC -
MA -112-1001, "Temporary Configuration Change Packages (TCCP)"
LS -
AA -104-1000, "Exelon 50.59 Resource Manual"
LS -

AA-104, "Exelon 50.59 Review Process"

Work Order (AR) A2184770 A217646

Other Documents

ATI 841005-02
ECR 08-1004, "Replacement of check valve V-5-165 due to
LLRT failure"
OC -2008-S-0170, 50:59 Screening: "
CRD Pump Filter Tie In" Section 1R19: Post-Maintenance Testing Procedures
MA -
AA -716-012, "Post Maintenance Testing"
OP -

MA-109-101, "Clearance and Tagging" 607.4.004, "Containment Spray and Emergency Service Water Pump System 1 Operability and Comprehensive/Preservice/Post-Maintenance Inservice Test", dated October 16, 2008 Attachment

617.4.003, "Control Rod Scram Insertion Time Test and Valve

IST Test", dated December 12, 2008 2400-
GMM -3225.52, "Control Rod Drive Hydraulic Control Unit"
MA -

AA-716-008, "Foreign Material Exclusion" 645.6.011, "Deluge and Sprinkler System Inspection"

645.6.010, "Fire Protection Deluge Valve Functional Test"

101.2, "Fire Protection Program"

Condition Report (IR) 831507 831503 831491 832013 834399 833488

Work Order R2120883 R2060728 C2017578 A2008192 C2002155 A2184770

R2126593 Other Documents

VM -

OC-0226, "Hydraulic Control Unit (237E18G1-G5)"

Section 1R20: Refueling and Outage Activities Procedures 201, "Plant Startup"

203, "Plant Shutdown"

205.0, "Reactor Refueling"

205.94.0 "Reactor Pressure Vessel Flood-Up Using Core Spray" 205.95.0, "Reactor Flood-up / Drain-Down" 305, "Shutdown Cooling System Operation"

306, "Reactor Vessel Head Cooling System Operation"

OP -
AA -108-108, "Unit Restart Review"
OP -

AA-108-1001, "Drywell/Containment Closeout" Condition Report (IR) 844470 845597 840457 830890 836125 841602

2349 837767 845240 845553 845402 844348

853928 768064 840425 845710 845890 845699

835930 835929 836622 846752 846750 846456 846784 846785 846829 846873 846881 846719 846761 846278 846729 846267 846248 846246

846209 846237 846240 842544 836613 837464

837868 836642 836622 836664 836125 835982

837057 844763 839088 703097 840560 837797 838342 838369 848547 848788 848783 848754 848723 848662 848586 848077 768233 843243

843244 843433 843349 835027 835031 832616 833992

Other Documents

NF -
AA -310, Fuel Move Sheet "1R22 Load SRM 21"
NF -

AA-310, Fuel Move Sheet "1R22 Reload 2A5 Contingency Part 1"

Technical Specifications 3.9.D, "Refueling"

Technical Specification 3.5.B, "Secondary Containment" Attachment

Oyster Creek Generating Station 1R22 Refueling Outage Shutdown Safety Plan, dated October 9, 2008 Section 1R22: Surveillance Testing

Procedures

SA -
AA -129, "Electrical Safety"
MA -

AA-1000, "Conduct of Maintenance"

665.5.006, "Local Leak Rate Tests" 636.4.001, "No. 1 Diesel Generator Automatic Actuation Test" 612.4.001, "Standby Liquid Control Pump and Valve Operability and In-Service Test"

341, "Emergency Diesel Generator Operation"

304, "Standby Liquid Control Operation"

Condition Reports (IR) 827682 833194 839492 839552 839293 827682 824420 824421

Work Orders (AR) R2095488 A2156628 A2203632 C2015162

Other Documents NRC Inspection Manual Part 9900 Technical Guidance, "Maintenance- Preconditioning of

Structures, Systems, and Components Before Determining Operability"

ECD C 208466
GL 96-01 "Testing of Safety-Related Logic Circuits" Section
1EP 2: Alert and Notification System (
ANS ) Evaluation Other Documents Nuclear Standardized Radiological Emergency Plan,
EP -
AA -1000, Rev. 19 Nuclear Radiological Emergency Plan Annex for Oyster Creek Station,
EP -

AA-1010, Rev. 1 Oyster Creek Nuclear Plant Upgraded Public Alert and Notification System Report, March 2005

East Alert Notification System Program,

EP -

MA-121-1002, Rev. 5

East

ANS Preventive Maintenance Program,
EP -MA-121-1005, Rev. 3 East
ANS Siren Monitoring, Troubleshooting, and Testing,

EP-MA-121-1006, Rev.5 Maintenance and testing records for February 2007 - September 2008

Section

1EP 3: Emergency Response Organization (

ERO) Staffing and Augmentation System Condition Reports (IR) 697247 708924 807768 817140 752173 706900 619806 682808 676706 697251 817103 819611

790610 790590 697250 807477

Other Documents

ERO Training and Qualification,
TQ -AA-113, Rev. 12 Mid-Atlantic
ERO Notification or Augmentation,
EP -AA-112-100-F-07, Rev. E
ERO Fundamentals,
EP -AA-1102, Rev. 5 Attachment
ERO Augmentation drill results for March 2007 - September 2008
ERO call-in augmentation drill results for April 2007 - September 2008
ERO roster and drive times
ERO training module plans (sampling) Section
1EP 4: Emergency Action Level (

EAL) and Emergency Plan Changes Condition Reports (IR) 581301

Other Documents Standardized Radiological Emergency Plan 07-82, Rev. 0

Emergency Plan for Oyster Creek Station 07-83, Rev. 0

Radiological E Plan Annex for Oyster Creek 08-14, Rev. 1 Section

1EP 5: Correction of Emergency Preparedness Weaknesses Condition Reports (

IR) 767502 767277 622256 664768 675307 593516 609972 703429 699926

Other Documents

FA [[]]

SA Self-Assessment Report - Emergency Preparedness, 7-23-08

Emergency Preparedness Audit

NOSA -
OYS -08-03, Oyster Creek, 4-30-08 Check-In Self-Assessment Report - Emergency Preparedness, 4-18-08 Emergency Preparedness Audit
NOSA -

OYS-07-04, Oyster Creek, 5-2-07

Drill reports 1st quarter 2007 - 3rd quarter 2008 Section 2OS1: Access Control to Radiological Significant Areas Other Documents Annual Radiological Operating Report, 2007

Monthly, Quarterly, and Cumulative Effluent Dose reports (October 2007 to present)

Horizontal Storage Module Temperature Profiles

Module Temperature Monitoring Data and Results

IFSI 10
CFR 72.212 Evaluation Section
2OS 2:
ALARA Planning and Controls Other Documents
ALA [[]]

RA Work in Progress Reviews and Post-Job Interviews

Outage

ALA [[]]

RA Plan Results Tracking Data

Bioassay Results and Intake Investigation Results - various Section 2SO3: Radiation Monitoring Instrumentation and Protective Equipment Other Documents Outage Air Sample Results, 1R22 Electronic Dosimeter Alarm Response forms - various

Section

4OA 1: Performance Indicator Verification Other Documents Oyster Creek Limiting Condition for Operation (

LCO) Log, 12/1/2007 through 11/30/2008

Oyster Creek Out of Service (OOS) Log, 12/1/2007 through 11/30/2008

Oyster Creek Operations Narrative Log, 12/1/2007 through 11/30/2008

Oyster Creek Corrective Action Program Log, 12/1/2007 through 11/30/2008

ER -
AA -2008, Mitigating Systems Performance Index (MSPI) Failure Determination Evaluation
ER -
AA -600-1047, Mitigating Systems Performance Index Basis Document
NEI 99-02 Rev 5, Regulatory Assessment Performance Indicator Guideline
OC -2006-01, Oyster Creek
MS [[]]

PI Basis Document

Section 4OA2: Identification and Resolution of Problems

Procedures

OP -
AA -102-103, "Operator Work-Around Program"
OP -

AA-108-101, "Control of Equipment and System Status"

Condition Reports (IR) 833493 846045 833858 835952 835982 842358 840233 854727 854814 854818 832749 832750

2753 832745 832755 835816 835817 836134

837169 838391 838394 838756 839590 853405

838691 854727 840233 Work Orders (AR) A833493

Section 4OA3: Event Followup Procedures 645.6.013, "Fire Suppression System Halon Functional Test"

ABN -29, "Plant Fires"
ABN -48, "Loss of
USS 1B2"
OP -
OC -201-008, "Oyster Creek Nuclear Generating Station Pre-Fire Plan"
LS -
AA -106, "Plant Operations Review Committee"
OP -

AA-108-108, "Unit Restart Review"

2.3.014, "EMRV Pressure Sensor/Pilot Valve Control Relay - Test and Calibrate (PS-IA0083)" 602.3.004, "Electromatic Relief Valve Pressure Sensor Test and Calibration"

OP -
AA -108-114, "Post Transient Review"
CC -
AA -5001, "Post Transient or
SCR [[]]

AM Walkdown"

Condition Reports (IR) 842102 842131 857308 857399 850585 850391 850395 850348 850838 850841 850856 851022 851040 852390 851906 850613 850390 842259 839150 768233 835031 835027 835031

Other Documents

NUREG -1022, "Event Reporting Guidelines 10
CFR 50.72 and 50.73" Event Notice 44688, "Automatic Reactor Scram Due to Main Transformer Fault" Exelon Letter, "Oyster Creek Nuclear Generating Station;
NJPDES Permit
NJ 0005550 5-Day Follow-up Report and Assertion of Affirmative Defense under
NJ Administrative Code and

NJ Statues, Incident Identification Number 297279, Communications Center

Number 08-11-29-0009-48", dated December 3, 2008 C-1302-622-E510-060, "PS-IA-0083

EMRV High Pressure Relief Calibration and Instrument Loop Error", Rev. 0
NUREG -0737, "Clarification of TMI Action Plan Requirements"
GPU Nuclear Corporation Letter, "Technical Specification Change Request (
TSCR ) No. 216.
RE [[:]]
LIMITI NG
SAFETY [[]]
SYSTEM [[]]
SETTIN [[]]

GS; Technical Specification 2.3.D, "Reactor High Pressure, Relief Valve Initiation" Limiting Safety System Setpoint Change", dated

June 15, 1994 Topical Report 101, "Considerations Associated with Changing Electromatic Relief Valve (EMRV) Setpoints", Rev.

0 ES 0800016, "
OPL -3 Parameters for Oyster Creek Unit 1 Cycle 22"
LIST [[]]
OF [[]]
ACRONY [[]]
MS ABN Abnormal Procedure
ADAMS Agency-wide Documents Access and Management System
ALARA As Low As Reasonably Achievable
ANS Alert and Notification System
ASME American Society of Mechanical Engineers
AT [[]]

WS Anticipated Transient Without Scram

BWR Boiling Water Reactor
CE [[]]
DE Committed Effective Dose Equivalent
CFR Code of Federal Regulations

CRD Control Rod Drive EAL Emergency Action Level

ED Electronic Dosimeter
EMRV Electromatic Relief Valve
EPRI Electric Power Research Institute
ERO Emergency Response Organization Exelon Exelon Energy Company,
LLC GE General Electric
GEM [[]]

AC General Electric Measurement and Control

HRA High Radiation Area
IGSCC Intergranular stress corrosion cracking
IR Issue or Condition Report
ISI In-service Inspection
IMC Inspection Manual Chapter
IV [[]]

VI In-vessel visual inspection

LDE Lens Dose Equivalent
LER License Event Report
LLC Limited Liability Company
LL [[]]

RT Local Leak Rate Test

MAC Monitoring and Control Facility

MCC Motor Control Center Attachment

Attachment

MSIP Mechanical stress improvement process
MSPI Mitigating Systems Performance Index
NEI Nuclear Energy Institute

NCV Non-cited Violation NDE Non-destructive examination

NRC Nuclear Regulatory Commission
NUREG [[]]
NRC Technical Report Designation
OD [[]]
CM Offsite Dose Calculation Manual
OE Operating experience
OWA Operator Workarounds Oyster Creek Oyster Creek Generating Station
PI Performance Indicator
PORC Plant Onsite Review Committee
PPC Process Plant Computer
PT Dye Penetrant Test PWR Pressurized Water Reactor
QA [[]]

TR Quality Assurance Topical Report

RCS Reactor Coolant System
RWP Radiological Work Permit
SDC Shutdown Cooling SDE Shallow Dose Equivalent
SDP Significance Determination Process
SIA Structural Integrity Associates
ST [[]]
AR Stop, Think, Act, Review
SRM Source Range Monitor
TEDE Total Effective Dose Equivalent
TI Temporary Instruction

UFSAR Updated Final Safety Analysis Report

URI Unresolved Item
VAC Voltage, Alternating Current
VHRA Very High Radiation Area VT Visual Test