IR 05000219/2011005

IR 05000219-11-005; 10/01/2011 - 12/31/2011; Oyster Creek Generating Station; Operability Determinations and Functionality Assessments

ML12040A001
Person / Time
Site:	Oyster Creek
Issue date:	02/08/2012
From:	Hunegs G K NRC/RGN-I/DRP/PB6
To:	Pacilio M J Exelon Nuclear Generation Corp
HUNEGS, GK
References
IR-11-005
Download: ML12040A001 (42)

Text

February B, 2OI2Mr. MichaelJ. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer, Exelon Nuclear4300 Winfield RoadWarrenville, fL 60555

SUBJECT: OYSTER CREEK GENEMTING STATION - NRC INTEGRATED INSPECTIONREPORT 0500021 9/201 1 005

Dear Mr. Pacilio:

On December 31 ,2011, the U.S. Nuclear Regulatory Commission (NRC) completed aninspection at your Oyster Creek Generating Station. The enclosed inspection report documentsthe inspection results, which were discussed on January 23,2012 with Mr. M. Massaro andother members of your staff.The inspection examined activities conducted under your license as they relate to safety andcompliance with the Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewedpersonnel.This report documents one NRC-identified finding of very low safety significance (Green) whichwas determined to involve a violation of NRC requirements. However, because of the very lowsafety significance, and because the finding was entered into your corective action program,the NRC is treating this finding as a non-cited violation (NCV), consistent with Section IS.Z otthe NRC Enforcement Policy. lf you contest the NCV in this report, you should provide aresponse within 30 days of the date of this inspection report, with the basis for your denial, tothe Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the RegionalAdministrator, Region l; the Director, Office of Enforcement,United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRCResident Inspector at Oyster Creek Generating Station. ln addition, if you disagree with thecross-cutting aspect assigned to the finding in this report, you should provide a response within30 days of the date of this inspection report, with the basis for your disagreement, to theRegionalAdministrator, Region l, and the NRC Resident Inspector at Oyster Creek GeneratingStation.ln accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in the M. PacilioNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC website athttp://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,Reactor Projects Branch 6Division of Reactor ProjectsDocket No.: 50-219License No.: DPR-16

Enclosure:

Inspection Report0500021912011005M

Attachment:

Supplemental Informationcc Mencl: Distribution via ListServ

SUMMARY OF FINDINGS

lR 0500021912011005, October 1- December 31 ,2011; Oyster Creek Generating Station;Operability Determinations and Functionality Assessments.This report covered a three-month period of inspection by resident inspectors and announcedinspections performed by regional inspectors. lnspectors identified one finding of very lowsafety significance (Green), which was a non-cited violation (NCV). The significance of mostfindings is indicated by their color (Green, White, Yellow, Red) using lnspection Manual Chapter(lMC) 0609, "significance Determination Process" (SDP). The cross-cutting aspects for thefindings were determined using IMC 0310, "Components Within Cross-Cutting Areas." Findingsfor which the SDP does not apply may be Green, or be assigned a severity level after NRCmanagement review. The NRC's program for overseeing the safe operation of commercialnuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4,dated December 2006.

Cornerstone: Mitigating Systems

Green.

The inspectors identified a Green NCV of 10 CFR Part 50.55a, Codes and Standards,because Exelon did not complete an adequate analysis when establishing a new referencevalue for the A containment spray pump in accordance with the American Society ofMechanical Engineer (ASME) Operation and Maintenance (OM) Code Subsection ISTB 4.6.The inspectors determined that Exelon's failure to correctly establish a new reference value forthe A containment spray pump in accordance with the requirements of ASME OM CodeSubsection ISTB 4.6 was a performance deficiency. Exelon entered this issue into thecorrective action program for resolution as lR 1281326.This finding is more than minor because it is similar to IMC 0612, Appendix C, Example 3.j, inthat there was a reasonable doubt that the system met ASME operability requirements due tothe inadequate evaluation. Additionally, the inspectors determined that this issue was morethan minor because it affected the procedure quality attribute of the Mitigating Systemscornerstone objective of ensuring the availability, reliability, and capability of systems thatrespond to initiating events to prevent undesirable consequences (i.e., core damage). Theinspectors determined this finding was not a design qualification deficiency resulting in a loss offunctionality or operability, did not represent an actual loss of safety function of a system ortrain of equipment, and was not potentially risk-significant due to a seismic, fire, flooding, orsevere weather initiating event. Therefore, the finding is considered to be of very low safetysignificance.This finding has a cross-cutting aspect in the area of Mitigating Systems cornerstone objectiveto ensure the availability, reliability, and capability of systems that respond to initiating events toprevent undesirable consequences, because Exelon did not fully follow the ASME requirementsin Subsection ISTB 4.6, New Reference Values. tP.1(c)]. (Section 1R15)

Other Findings

None.Enclosure

4

REPORT DETAILS

Summarv of Plant StatusOyster Creek began the inspection period at 100 percent power. On November 6, operatorsreduced power to approximately 85 percent to perform a rod pattern adjustment, turbine valvetesting and scram time testing. Operators returned the unit to 100 percent on the same day.The unit remained at or near 100 percent power for the remainder of the inspection period.1. REACTORSAFETYGornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01 Adverse Weather Protection (71111.01 - 1 sample).1 Readiness for Seasonal Extreme Weather Conditionsa. Inspection ScopeThe inspectors performed a review of Exelon's readiness for the onset of seasonal coldtemperatures. The review focused on the intake structure and the emergency dieselgenerators (EDGs). The inspectors reviewed the Updated Final Safety Analysis Report(UFSAR), technical specifications, control room logs, and the corrective action programto determine what temperatures or other seasonalweather could challenge thesesystems, and to ensure Exelon's personnel had adequately prepared for thesechallenges. The inspectors reviewed station procedures, including Exelon's seasonalweather preparation procedure and applicable operating procedures. The inspectorsperformed walkdowns of the selected systems to ensure station personnel identifiedissues that could challenge the operability of the systems during cold weatherconditions. Documents reviewed for each section of this inspection report are listed inthe Attachment.b. FindinqsNo findings were identified.

1R04 EquipmentAliqnment

.1 Partial Svstem Walkdowns (71111.04Q - 2 samples)a. lnspection ScopeThe inspectors performed partial walkdowns of the following systems:. Walkdown of containment spray system 2 while containment spray system 1 was outof service for surveillance testing on October 19,2011o Walkdown of core spray system 2 while core spray system 1 was out of service forsurveillance testing on November 16,2011The inspectors selected these systems based on their risk-significance relative to thereactor safety cornerstones at the time they were inspected. The inspectors reviewedEnclosure 5applicable operating procedures, system diagrams, the UFSAR, technical specifications,work orders, condition reports, and the impact of ongoing work activities on redundanttrains of equipment in order to identify conditions that could have impacted systemperformance of their intended safety functions. The inspectors also performed fieldwalkdowns of accessible portions of the systems to verify system components andsupport equipment were aligned correctly and were operable. The inspectors examinedthe material condition of the components and observed operating parameters ofequipment to verify that there were no deficiencies. The inspectors also reviewedwhether Exelon's staff had properly identified equipment issues and entered them intothe corrective action program for resolution with the appropriate significancecharacterization.b. FindinqsNo findings were identified..2 Full Svstem Walkdown (71111.04S - 1 sample)a. Inspection ScopeOn December 1, 2011, the inspectors performed a complete system walkdown ofaccessible portions of the isolation condenser system 'A' to verify the existing equipmentlineup was correct. The inspectors reviewed operating procedures, surveillance tests,drawings, equipment line-up check-off lists, and the UFSAR to verify the system wasaligned to perform its required safety functions. The inspectors also reviewed electricalpower availability, hangar and support functionality, and operability of support systems.The inspectors performed field walkdowns of accessible portions of the systems to verifysystem components and support equipment were aligned correctly and operable. Theinspectors examined the material condition of the components and observed operatingparameters of equipment to verify that there were no deficiencies. Additionally, theinspectors reviewed a sample of related condition reports and work orders to ensureExelon appropriately evaluated and resolved any deficiencies.b. FindinqsNo findings were identified.

1R05 Fire Protection

.1 Resident lnspector Quarterlv Walkdowns (71111.05Q - 4 samples)a. Inspection ScopeThe inspectors conducted tours of the areas listed below to assess the materialcondition and operational status of fire protection features. The inspectors verified thatExelon controlled combustible materials and ignition sources in accordance withadministrative procedures. The inspectors verified that fire protection and suppressionequipment was available for use as specified in the area pre-fire plan, and passive firebarriers were maintained in good material condition. The inspectors also verified thatstation personnel implemented compensatory measures for out of service, degraded, orinoperable fire protection equipment, as applicable, in accordance with procedures.Enclosure

6. 480V Switchgear Room A (OB-FZ-6A) on November 21,2011. 4160V A & B Switchgear Room (TB-FZ-11C) on November 29, 2011. 4160V C Battery Room (TB-FA-26) on November 29,2011. Cable Spreading Room (OB-FZ-4) on December 14,2011b. FindinqsNo findings were identified..2 Fire Protection - Drill Observation (71111.05A - 1 sample)a. Inspection ScopeThe inspeetors observed a fire brigade drill scenario conducted on December 14,2011,that involved a fire in the multiplexer room, in the main office building. The inspectorsevaluated the readiness of the plant fire brigade to fight fires. The inspectors observedthe post-drill debrief and verified that Exelon personnel identified deficiencies, openlydiscussed them in a self-critical manner, and took appropriate corrective actions asrequired. The inspectors evaluated specific attributes as follows:. Proper wearing of turnout gear and self-contained breathing apparatus. Proper use and layout of fire hoses. Employment of appropriate fire-fighting techniques. Sufficient fire-fighting equipment brought to the scene. Effectiveness of command and control. Search for victims and propagation of the fire into other plant areas. Smoke removal operations. Utilization of pre-planned strategieso Adherence to the pre-planned drill scenarioo Drill objectives metThe inspectors also evaluated the fire brigade's actions to determine whether theseactions were in accordance with Exelon's fire-fighting strategies.b. FindinosNo findings were identified.1R1 1 Licensed Operator Requalification Proqram (71111.11 - 1 sample)a. Inspection ScopeThe inspectors observed licensed operator simulator training scenario 2612.CREW.1 1-6.01 on October 5, 2011. The inspectors evaluated operator performance during thesimulated event and verified completion of risk significant operator actions, including theuse of abnormal and emergency operating procedures. The inspectors assessed theclarity and effectiveness of communications, implementation of actions in response toalarms and degrading plant conditions, and the oversight and direction provided by thecontrol room supervisor. The inspectors verified the accuracy and timeliness of theEnclosure

7emergency classification made by the shift manager and the technical specificationaction statements entered by the shift technical advisor. Additionally, the inspectorsassessed the ability of the crew and training staff to identify and document crewperformance problems.b. FindinqsNo findings were identified.

1R15 Operabilitv Determinations and Functionalitv Assessments (71111.15 - 5 samples)a. Inspection ScopeThe inspectors reviewed operability determinations for the following degraded or non-conforming conditions:o Unexpected alarm due to low differential pressure in the reactor building on October2,2011 (lR1271279). Chip of porcelain from the bus side insulator emergency service water 1-4 breakercubical on October 11, 2011 (lR 1274871). Containment spray pump 51A flow went above the upper action limit on October 25,2011 (lR 1281326). 2 dieselfire pump start and fire main piping leak during maintenance activity onDecember 12,2011 (lR 1301461)o Unexpected rise in both emergency condenser's shell side level indications onDecember 20,2A11 (lR 1304907)The inspectors selected these issues based on the risk significance of the associatedcomponents and systems. The inspectors evaluated the technical adequacy of theoperability determinations to assess whether technical specification operability wasproperly justified and the subject component or system remained available such that nounrecognized increase in risk occurred. The inspectors compared the operability anddesign criteria in the appropriate sections of the technical specifications and UFSAR toExelon evaluations to determine whether the components or systems were operable.Where compensatory measures were required to maintain operability, the inspectorsdetermined whether the measures in place would function as intended and wereproperly controlled by Exelon. The inspectors determined, where appropriate,compliance with bounding limitations associated with the evaluations.b. FindinqsIntroduction. The inspectors identified a Green NCV of 1OCFR 50.55a, Codes andStandards, when Exelon did not perform an adequate analysis, in accordance with therequirements of the ASME operations and maintenance (OM) Code subsection ISTB4.6, of the A containment spray pump to support establishment of a new inservice test(lST) reference value following the failure of the biennial comprehensive lST.Enclosure

IDescription. On October 19, Exelon performed the biennial comprehensive IST on the Acontainment spray pump. The results of the test determined that the pump flow rate of4400 gpm exceeded the ASME IST upper action limit of 4326 gpm. Exelon declared theA containment spray pump inoperable as required by the ASME OM code and enteredthe issue into the corrective action program as lR 1278683.ASME OC code subsection ISTB 6.2.2, "Action Range," states, in part, "lf the measuredtest parameter values fallwithin the required action range..., the pump shall be declaredinoperable until either the cause of the deviation has been determined and the conditionis corrected, or an analysis of the pump is performed and new reference values areestablished in accordance with subsection ISTB 4.6." Exelon chose to perform ananalysis of the pump and establish a new reference value.ASME OM code subsection ISTB 4.6, "New Reference Values," delineates therequirements for an analysis performed to verify operational readiness of a pump. ISTB4.6 states, in part, "ln cases where the pump's test parameters are within either the alertor required action ranges..., and the pump's continued use at the changed value issupported by an analysis, a new set of reference values may be established. Thisanalysis shall include both a pump level and a system level evaluation of operationalreadiness, the cause of the change in pump performance, and an evaluation of all trendsindicated by all available data. The results of this analysis shall be documented in therecord of tests."Exelon performed an analysis and concluded that establishing a new reference value forthe A containment spray pump was allowable. Their analysis stated, "An analysis ofpump performance was reviewed for the last two years. The pump performance trendindicates that the pump is performing acceptably with flow ranging between 4300 and4400gpm. A review of all maintenance activities since pump replacement shows noactivities have been performed that could impact pump performance. Vibration data forthe pump has been reviewed and it shows no negative trend that could impact reliablepump operation." Using the results of the October 19 test, Exelon selected 4400gpm asthe new reference point and calculated new alert range and required action rangevalues. Exelon performed a comprehensive inservice test on October 20, with resultsmeeting the new acceptance criteria. Exelon declared the A containment spray pumpoperable following review of the test data.The inspectors reviewed Exelon's analysis for the A containment spray pump andidentified that Exelon's analysis did not meet the requirements stated in ASME OM CodeSubsection ISTB 4.6. Specifically, only a partial system level evaluation of readinesswas conducted, the cause of the change in pump performance was not identified and thetrend analysis was conducted using only the last 2 years of data vice all the availabledata.The inspectors notified Exelon of the concern that that the existing analysis did not meetthe requirements of OM code subsection ISTB 4.6 and was inadequate to supportoperability of the A containment spray pump. Exelon entered this issue into thecorrective action program as lR 1281326.In response to the inspectors concerns, Exelon performed further analysis of the issueand identified that B containment spray pump had exhibited the same increase in flow asthe A containment spray pump over the same period of time. Additionally, the detailedEnclosure 10analysis of the A containment spray pump showed that the hydraulic performance of thepump had not appreciatively changed, based upon comparisons of the pump differentialpressure. The analysis concluded that both containment spray pumps were operatingsatisfactorily and that the change in indicated flow rates of both pumps was due tosuspected inaccuracy of the installed flow measuring device, which is common to bothpumps. Exelon has developed and is performing a troubleshooting action plan todetermine the nature of the inaccuracy of the flow measuring and documented the issuein lR 1285841. The flow measuring device is not used by operators as a parameter tocontrol system flow and is primarily used to conduct the quarterly IST test.Analvsis. The inspectors determined that Exelon's failure to perform an adequateanalysis of the A containment spray pump in accordance with the requirements of ASMEOM Code Subsection ISTB 4.6 to demonstrate operability of the pump after it exceededthe upper required action range limit, was a performance deficiency. This finding ismore than minor because it is similar to IMC 06't2 Appendix E Minor Example 3.j in thatthere was a reasonable doubt that the A containment spray pump met ASMErequirements based upon the original evaluation. This finding also affects the MitigatingSystems cornerstone objective to ensure the availability, reliability, and capability ofsystems that respond to initiating events to prevent undesirable consequences.The inspectors evaluated the finding using Phase 1, "lnitial Screening andCharacterization" worksheet in Attachment 4 to IMC 0609, "Significance DeterminationProcess." The inspectors determined this finding was not a design qualificationdeficiency resulting in a loss of functionality or operability, did not represent an actualloss of safety function of a system or train of equipment, and was not potentially risk-significant due to a seismic, fire, flooding, or severe weather initiating event. Therefore,inspectors determined the finding to be of very low safety significance (Green).This finding has a cross-cutting aspect in the area of Problem ldentification andResolution, Corrective Action Program, because Exelon failed to thoroughly evaluateproblems such that the resolutions addressed causes and extent of conditions, asnecessary, which includes evaluating for operability. Specifically, Exelon did not fullyaddress the ASME requirements in ISTB 4.6, "New Reference Values," when performingthe analysis to establish new IST reference values. P.1(c)]Enforcement: 10 CFR 50.55a states in part, that IST Programs verify the operationalreadiness of pumps and valves in compliance with the requirements of the ASME Code.Contrary to the above Exelon failed to adequately analyze pump and systemperformance when establishing new IST reference values in accordance with the ASMECode. Because this violation was of very low safety significance and it was entered intoExelon's CAP as lR 1281326, this violation is being treated as an NCV, consistent withthe Enforcement Policy. (NCV 05000219/2011005-01, Failure to Establish NewReference Values in Accordance with ASME Gode)1R19 Post-Maintenance Testino (71111.19 - 6 samples)a. Inspection ScopeThe inspectors reviewed the post-maintenance tests for the maintenance activities listedbelow to verify that procedures and test activities ensured system operability andfunctional capability. The inspectors reviewed the test procedure to verify that theEnclosure 11procedure adequately tested the safety functions that may have been affected by themaintenance activity, that the acceptance criteria in the procedure was consistent withthe information in the applicable licensing basis and/or design basis documents, and thatthe procedure had been properly reviewed and approved. The inspectors alsowitnessed the test or reviewed test data to verify that the test results adequatelydemonstrated restoration of the affected safety functions.. lsolation condenser relay replacement 6K8A & 6K8B on September 29,2011(R21 1 82121 R2180899). Planned maintenance on the containment spray heat exchangers 1-1 and 1-2 onOctober 19, 2011 (R21 51529). 1-1 fire diesel operability test on October 12, 2011 (R2189620). V-28-28 following manually backseat and torque to the maximum allowable thrustvalue on November 21,2011 (C2026279). V-14-33 post maintenance testing following backseat of the valve on November 21,2011 (C2026279). 1-2fire dieselfollowing unplanned maintenance on December 22,2011 (R2192771)b. FindinosNo findings were identified.

1R22 Surveillance Testinq (71111.22 - 3 samples)a. Inspection ScopeThe inspectors observed performance of surveillance tests and/or reviewed test data ofselected risk-significant SSCs to assess whether test results satisfied technicalspecifications, the UFSAR, and Exelon procedure requirements. The inspectors verifiedthat test acceptance criteria were clear, tests demonstrated operational readiness andwere consistent with design documentation, test instrumentation had current calibrationsand the range and accuracy for the application, tests were performed as written, andapplicable test prerequisites were satisfied. Upon test completion, the inspectorsconsidered whether the test results supported that equipment was capable of performingthe required safety functions. The inspectors reviewed the following surveillance tests:o lsolation condenser auto actuation test on October 3,2011. Containment spray and emergency service water pump system 1 operability andcomprehensive/preservice/ post-maintenance inservice test on October 19,2011(in-service test). Unidentified leak rate surveillance on December 14,2011 (RCS leak rate)b. FindinqsNo findings were identified.Enclosure

1 EP612Gornerstone: Emergency PreparednessDrill Evaluation (71114.06 - 1 sample)Traininq Observations.1a. Insoection ScopeThe inspectors observed a simulator training evolution for licensed operators onOctober 5 which required emergency plan implementation by an operations crew.Exelon planned for this evolution to be evaluated and included in performance indicatordata regarding drill and exercise performance. The inspectors observed eventclassification and notification activities performed by the crew. The inspectors alsoattended the post-evolution critique for the scenario. The focus of the inspectors'activities was to note any weaknesses and deficiencies in the crew's performance andensure that Exelon evaluators noted the same issues and entered them into thecorrective action program.b. FindinqsNo findings were identified.RADIATION SAFETYGornerstone: Occupational Radiation SafetyRSo1 Access Control to Radioloqicallv Siqnificant Areas (71124.01- 1 sample)a. Inspection ScopeThe inspectors reviewed Exelon's performance in assessing workplace radiologicalhazard and implementation of appropriate radiation monitoring and exposure controlmeasures for individual and collective exposure. The review was compared to criteriacontained in 10CFR20, technical specification and applicable corporate and stationprocedures. Specifically, the inspectors' conducted inspection activities in the followingareas:. Radioloqical Hazard Assessment: The inspectors interviewed workers andmanagement to identify significant new radiological hazards on the site. Theinspectors cond ucted walkdowns, performed independent rad iationmeasurement, reviewed radiologically risk-significant work activities, andreviewed air sample survey results to verify that Exelon performed appropriatepre-work surveys and work monitoring to show that their programs were effectivein protecting workers and identifying any changes in radiological hazards.. lnstructions to Workers: The inspectors toured the facility and evaluatedcontainers holding nonexempt licensed radioactive materials that may causeunplanned or inadvertent exposure of workers to verify that they were properlylabeled and controlled. The inspectors reviewed a sample radiation work permitsfor high radiation areas to verify that they contained appropriate stay times,permissible dose allowances and electronic personal dosimeter (EPD) alarmEnclosure 13setpoints. The inspectors reviewed instances where an EPD malfunctioned oralarmed to verify that workers responded property to the off normal condition andthat Exelon entered the event into the corrective action program and performeddose evaluations.Contamination and Radioactive Material Control: The inspectors evaluated theperformance of personnel surveying and releasing potentially contaminatedmaterial at the Radiologically Controlled Area (RCA) access points, to verify thatthe surveys, procedures and equipment were sufficient to control the spread ofcontamination and to prevent unintended release of radioactive materials fromthe site.Radiolooical Hazards Control and Work Coveraqq: The inspectors reviewedExelon procedures to verify that radiological controls, such as surveyrequirements and remote surveillance of jobs in progress were adequate. Theinspectors verified that dosimeters were utilized effectively to monitor and recordradiation worker exposure in the RCA and in high radiation areas. Theinspectors reviewed radiological work permits for work within airborneradioactivity areas to evaluate airborne radioactive controls and monitoring,including potentials for significant airborne levels. The inspectors reviewedphysical and programmatic controls for highly activated or contaminatedmaterials (nonfuel) stored within the spent fuel pool to verify that appropriateadministrative and physical controls were in place.Risk-Sionificant Hiqh Radiation Area (HRA) and Verv Hiqh Radiation Area(VHRA) Controls: The inspectors interviewed the Radiation Protection Managerand supervisors to evaluate Exelon's controls and access procedures for high-risk high and very high radiation areas and any procedural changes since the lastinspection.Radiation Worker Performance: The inspectors observed radiation workers toassess if their performance was commensurate with the level of radiationhazards that were present on the work site. The inspectors reviewed thecorrective action program to identify human performance errors or trends as wellas Exelon's actions to resolve them.Radiation Protection Technician Proficiencv: The inspectors observed theperformance of radiation protection technicians to evaluate if their performancewas consistent with their training and qualifications. The inspectors reviewed thecorrective action program, self assessments and program audits to evaluateExelon's resolution of identified issues.b.FindinqsNo findings were identified.RS02 OccupationalALARA Planninq and Controls (71124.02 - 1 sample)a.Inspection ScopeEnclosure b.a.14The inspectors reviewed Exelon's performance to evaluate the process for maintainingindividual and collective radiation exposure as low as is reasonably achievable (ALARA).The inspectors reviewed plant collective exposure history, current exposure trends,compared dose budgets to actual exposures for work activities, and ongoing or plannedactivities in order to assess current performance and exposure challenges.FindinosNo findings were identified.ln-Plant Airborne Radioactivitv Control and Mitiqation (71124.03 - 1 sample)Inspection ScopeThe inspectors reviewed the updated plant final safety analysis report (UFSAR) toidentify areas of the plant designed as potential airborne radiation areas, theirassociated ventilation systems or airborne monitoring instrumentation. The inspectorsreviewed Exelon's procedures for maintenance, inspection, and use of respiratoryprotection equipment including procedures for air quality maintenance.. Self-Contained Breathinq Apparatus (SCBA) for Emerqency Use: The inspectorsreviewed maintenance and surveillance records and physically inspected, SCBAunits to verify that they were properly maintained and available for emergency use.The inspectors reviewed training and qualification records to verify that operatorsand those assigned emergency duties were adequately trained to use SCBAS.FindinosNo findings were identified.Occupational Dose Assessment (71124.04

• 1 sample)Inspection ScopeThe inspectors reviewed and evaluated the Exelon's occupational dose assessmentprogram to assess the accuracy and effectiveness of the Exelon's ability to measureoccupational dose including internal dose.. External Dosimetry: The inspectors evaluated Exelon's use of personneldosimeters, to verify that they were National Voluntary Laboratory AccreditationProgram (NVLAP) accredited.. Internal Dosimetry: The inspectors reviewed routine bioassay (in vivo) proceduresused to assess dose from internally deposited nuclides using whole body countingequipment.. Shallow Dose Equivalent: The inspectors reviewed dose assessments andmethodology for adequacy.RSO3RSO4b.Enclosure RSO5RSO615FindinqsNo findings were identified.Radiation Monitorinq lnstrumentation (71122.05 - 1 sample)lnspection ScopeThe inspectors evaluated Exelon's radiation monitoring instrumentation ensure theaccuracy and operability of radiation monitoring instruments.. Po'st-Accident Monitorinq lnstrumentation: The inspectors evaluated the calibrationand maintenance records for of high-range effluenVprocess monitors relied on byExelon in its emergency operating procedures.. Calibration and Check Sources: The inspectors reviewed the latest 10 CFR Part 61source term to determine if the calibration sources used were representative of thetypes and energies of radiation encountered in the plant.FindinqsNo findings were identified.Gornerstone: Public Radiation SafetyRadioactive Gaseous and Liquid Effluent Treatment (71124.06 - 1 sample)Inspection ScopeThe inspectors reviewed Exelon's gaseous and liquid effluent control program throughin-office preparation before the inspection to review annual reports and other availabledocumentation.. Groundwater Protection Initiative (GPl) Proqram: The inspectors reviewedreported groundwater monitoring results, remediation efforts, changes to theprogram for identifying and controlling contaminated spills/leaks to groundwaterand walked down the remediation facility.o Procedures. Special Reports & Other Documents: The inspectors reviewedLicensee Event Reports (LERs), event reports, and/or special reports related to theeffluent program to identify any additional focus areas for the inspection based onthe scope/breadth of problems described in these reports.o Walkdowns and Observations: The inspectors reviewed Standby Gas TreatmentSystem (SBGTS) surveillance test data and walked down portions of the system toassess the material condition and to verify that there were no conditions, improperalignment, or system installation issues that would impact the performance of thesystem. The inspectors reviewed the methodology Exelon used to determine theeffluent stack and vent flow rates.a.Enclosure 16Samplinq and Analvses: The inspectors reviewed sampling records to determine ifExelon was routinely relying on the use of compensatory sampling in lieu ofadequate system maintenance.Dose Calculations: The inspectors verified that the calculated monthly, quarterly,and annual doses were within the 10 CFR Part 50, Appendix l, and TechnicalSpecification dose criteria. Additionally, the inspectors reviewed records ofabnormal discharges to ensure that that an evaluation was made of the dischargeto satisfy 10 CFR 20.1501, and account for the source term and projected doses tothe public.b. FindinqsNo findings were identified.RSOTa.RSOSb.a.Radioloqical Environmental Monitorinq Proqram (REMP) (71124.07 - 1 sample)Inspection ScopgThe inspectors reviewed the annual radiological environmental and effluent operatingreports and the results of Exelon assessments since the last inspection, to verify that theREMP was implemented in accordance with the Technical Specification (TS) and theOffsite Dose Calculation Manual (ODCM).. Site Inspection: The inspectors reviewed Exelon's assessment of any positivesample results and the associated radioactive effluent release data that was fromthe source of the released material. The inspectors reviewed any significantchanges made by Exelon to the ODCM. The inspectors reviewed technicaljustifications and verified that Exelon performed reviews required to ensure that thechanges did not adversely affect the ability to monitor the impacts of radioactiveeffluent releases on the environment.FindinosNo findings were identified.Radioactive Solid Waste Processinq and Radioactive Material Handlinq. Storaqe. andTransportation (1 sample)Inspection ScopeThe inspectors reviewed the implementation of the Radioactive Solid Waste Processingand Radioactive Material Handling, Storage, and Transportation Program to verify theeffectiveness of Exelon's programs for processing, handling, storage, and transportationof radioactive material. The review considered requirements contained in 10 CFR Part20,49 CFR, applicable Exelon procedures, including the Process Control Program(PCP), and Technical Specifications.. Radioactive Material Storaqe: The inspectors toured and evaluated facilities,including outdoor storage areas where containers of radioactive waste were stored.Enclosure 17The inspectors evaluated the material condition of the containers and verified thatthe containers and the storage areas were controlled, labeled, and posted inaccordance with all requirements.. Radioactive Material System Walkdown: The inspectors reviewed liquid and solidradioactive waste processing system procedures and viewed recent photographsor walked down accessible portions of systems to verify and assess conditions andconfiguration. The inspectors reviewed non-operational or abandoned radioactivewaste processing equipment to verify establishment of administrative and/orphysical controls of the equipment and reviewed audits and recent photographs ofthe equipment.. Waste Characterization and Classification: The inspectors reviewed radioactivewaste streams and the Quality Assurance (aA) to verify that sample analysisresults, required by 10 CFR Part 61 , were sufficient to support radioactive wasteclassification and characterization.. Shippinq Records: The inspectors selected one non-excepted package shipment(OC-4002-1 1) for record review and verified that the shipping documents containedthe appropriate information and that the shipment was properly labeled.b. FindinwNo findings were identified.4.

4OA1 Performance Indicator {Pl) Verification

.1 Mitioatinq Svstems Performance lndex (5 - samples)a. Inspection ScopeThe inspectors reviewed Exelon's submittal of the Mitigating Systems PerformanceIndex for the following systems for the period of October 1,2010 through September 30,2011:o Emergency AC Power System. High Pressure Injection Systemr Heat Removal- lsolation Condenserso RHR - Containment Spray. Cooling Water SystemTo determine the accuracy of the performance indicator data reported during thoseperiods, the inspectors used definitions and guidance contained in NEI Document 99-02,"Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectorsalso reviewed Exelon's operator narrative logs, condition reports, mitigating systemsperformance index derivation reports, event reports, and NRC integrated inspectionreports to validate the accuracy of the submittals.Enclosure

.218 b. FindinosNo findings were identified.Occupational Exposure Control Effectiveness (1 - sample)Inspection ScopeThe inspector reviewed implementation of the Occupational Exposure ControlEffectiveness Pl Program. The inspector reviewed corrective action program recordsfor occurrences involving HRAs, VHRAs, and unplanned personnel radiation exposuressince the last inspection in this area. The review was against the applicable criteriaspecified in Nuclear Energy lnstitute (NEl) 99-02, Regulatory Assessment PerformanceIndicator Guideline, Rev. 6. The purpose of this review was to verify that occurrencesthat met NEI criteria were recognized and identified as Performance Indicators.FindinqsNo findings were identified.RETS/ODCM Radioloqical Effluent Occurrences (1 - sample)lnspection ScopeThe inspectors reviewed the implementation of the Radiological Effluents TechnicalSpecification/Offsite Dose Calculation Manual (RETS/ODCM) Pl program. Theinspectors reviewed corrective action program records and projected monthly andquarterly dose assessment results due to radioactive liquid and gaseous effluentreleases for the past four complete quarters. The review was against the applicablecriteria specified in NEI 99-02, Regulatory Assessment Performance Indicator Guideline,Rev. 6. The purpose of this review was to verify that occurrences that met NEI criteriawere recognized and identified as Performance lndicators.As part of this review, the inspectors also reviewed Exelon's evaluations and public doseassessments associated with identification of localized ground water contaminationwithin the restricted area.FindinqsNo findings were identified.Unplanned Power Chanqes per 7000 Critical Hours (1- sample)Inspection Scope (7 1 151)The inspectors reviewed Exelon's submittal for the Unplanned Power Changes per 7000Critical Hours performance indicators for both Unit 1 and Unit 2 for the period of April 1,2010 through March 31, 2011 . To determine the accuracy of the performance indicatordata reported during those periods, the inspectors used definitions and guidancecontained in NEI Document 99-02, "RegulatoryAssessment Performance Indicatorb..3b..4a.Enclosure

4c.A219Guideline," Revision 6. The inspectors reviewed control room logs and plant processcomputer power history data, and compared that information to the data reported by theperformance ind icator.FindinqsNo findings were identified.Problem ldentification and Resolution (71152 - 7 samples)Routine Review of Problem ldentification and Resolution ActivitiesInspection ScopeAs required by Inspection Procedure 71152, "Problem ldentification and Resolution," theinspectors routinely reviewed issues during baseline inspection activities and plantstatus reviews to verify that Exelon entered issues into the corrective action program atan appropriate threshold, gave adequate attention to timely corrective actions, andidentified and addressed adverse trends. In order to assist with the identification ofrepetitive equipment failures and specific human performance issues for follow-up, theinspectors performed a daily screening of items entered into the corrective actionprogram and periodically attended condition report screening meetings.FindinqsNo findings were identified.Semi-Annual Trend Reviewlnspection ScopeThe inspectors performed a semi-annual review of site issues, as required by InspectionProcedure 71152, "Problem ldentification and Resolution," to identify trends that mightindicate the existence of more significant safety issues. In this review, the inspectorsincluded repetitive or closely-related issues that may have been documented by Exelonoutside of the corrective action program, such as trend reports, performance indicators,major equipment problem lists, system health reports, maintenance rule assessments,and maintenance or corrective action program backlogs. The inspectors also reviewedExelon's corrective action program database for the third and fourth quarters of 2011 toassess condition reports written in various subject areas (equipment problems, humanperformance issues, etc.), as well as individual issues identified during the NRCs dailycondition report review (Section 4C.42.1).Findinqs and ObservationsNo findings were identified.The inspectors evaluated a sample of departments and issues to gain insights into anyemerging or adverse trends. This review included a sample of issues and events thatoccurred over the course of the past two quarters, in addition to cause evaluationscompleted during past two quarters, to objectively determine whether issues were.1a.b..2b.Enclosure

.320 appropriately considered or ruled as emerging or adverse trends, and in some cases,verified the appropriate disposition of resolved trends. For example, the inspectorsnoted an increased number of unexpected half scrams. The apparent cause report wasreviewed by the residents for two unexpected half scrams on reactor protection system(RPS) system 2 on August 20 and 21, 2010 (lR 1 104183). The apparent cause reportswere also reviewed for an unexpected half scram on RPS system 1 occurring onSeptember 29,2011 (lR 1269662), a half scram on RPS 2 due to an inoperable APRMcard (lR 1263961), and a half scram due to a LPRM spike (lR 1246795). A number ofthe unexpected half scrams occurred as a result of Nuclear Instrumentation Local PowerRange Monitor (LPRM) failures. Licensee personnel had appropriately identified theNuclear lnstrumentation LPRM failures as a monitored trend with ongoing correctiveactions (lR 1225305) to address this long-standing issue. The inspectors reviewed othermonitoring programs that compliment the trending process, such as system health andperformance indicators, and determined they appropriately identified the LPRM failuresfor further assessment.Annual Sample: Review of the Operator Workaround ProqiamInspection ScopeThe inspectors reviewed the cumulative effects of the existing operator workarounds,operator burdens, existing operator aids and disabled alarms, and open main controlroom deficiencies to identify any effect on the operator's ability to implement abnormal oremergency operating procedure actions, and any negative impact on possible initiatingevents and mitigating systems. The inspectors also evaluated whether station personnelhad identified, assessed, and reviewed operatorworkarounds as specified in Exelon'sprocedure OP-AA-1 02-1 03, Operator Work-Around Program.The inspectors reviewed Exelon's process to identify, prioritize and resolve main controlroom distractions to minimize operator burdens. The inspectors reviewed the systemused to track these operator workarounds and recent Exelon self assessments of theprogram. The inspectors also toured the control room and discussed the currentoperator workarounds with the operators to ensure the items were being addressed ona schedule consistent with their relative safety significance.Findinqs and ObservationsNo findings were identified.The inspectors determined that the issues reviewed did not adversely affect thecapability of the operators to implement abnormal or emergency operating procedures.The inspectors also verified that Exelon entered operator workarounds and burdens intothe corrective action program at an appropriate threshold and planned or implementedcorrective actions commensurate with their safety significance.Annual Sample: ND30-B leakbv discovered durinq A reactor water cleanup (RWCU)filter troubleshootinqlnspection Scopeb..4a.Enclosure

21The inspectors performed an in-depth review of Exelon's prompt investigation andcorrective actions associated with condition report 1278033, ND30-B leakby discoveredduring A RWCU (reactor water cleanup) filter TSAP (trouble shooting action plan).Specifically, while cycling filter isolation valves during troubleshooting on the A RWCUfilter, leakby on the B filter isolation valves caused the B filter to isolate, which caused areactor water level transient and a power excursion which exceeded the licensedthermal power limit.The inspectors assessed Exelon's prompt investigation, operator actions, and theprioritization and timeliness of Exelon's corrective actions to determine whether Exelonwas appropriately identifying, characterizing, and correcting problems associated withthis issue and whether the planned or completed corrective actions were appropriate.The inspectors compared the actions taken to the requirements of Exelon's correctiveaction program and 10 CFR 50, Appendix B. In addition, the inspectors performedmaintenance history reviews and interviewed engineering, chemistry and operationspersonnel to assess the effectiveness of Exelon's actions.b. Findinqs and ObservationsNo findings were identified.Exelon determined the cause of this event was backflow through the ND30B valve(precoat pump discharge valve to the B RWCU filter), which shares a common headerwith the ND30A valve (precoat pump discharge valve to the A RWCU filter). Exelondetermined that there was undetected degradation of the valve which would not bereadily apparent since the common header between A and B RWCU filters was isolatedduring normal operations and could not cause a system transient if there was leakby ofeither valve. When ND30A was opened during the troubleshooting procedure, leakby ofND30B became evident and caused the system transient.The licensed operators responded appropriately by promptly lowering power when theynoticed that thermal power was rising. Reactor thermal power peaked at 1946 MW, witha maximum licensed power limit of 1930 MW, and was above the licensed limit for lessthan one minute. Although the thermal power limit was exceeded, the inspectorsdetermined that there was no regulatory violation of the licensed thermal power limitbased upon guidance in NRC Regulatory lssue Summary 2007-21, Adherence toLicensed Power Limits. Specifically, the pre-planned evolution was not expected toincrease power, the reactor power was below the licensed thermal limit at the start of theevolution and the operators monitoring power levels took prompt action to lower powerbelow the licensed limit when power was noted to be above licensed limit.The inspectors reviewed the maintenance history for ND30-B. This valve wasoverhauled in 1996 (C0505108). During post maintenance testing, Exelon noted that theposition indicator stayed in the open position when the valve was shut. Exelongenerated job order A0772599 to adjust the valve position limit switch to match theclosed position of the valve. The inspectors noted that in the closure remarks for theoverhaul work order, that maintenance personnel stated that the numerous punch markson the valves made it difficult to match parts and valves during overhaul and installation.The inspectors observed that the potential existed that ND30-B was actually partiallyEnclosure 22open due to confusion created by the numerous matchmarks on the valve duringreassembly and that the limit switch for valve position may have been adjusted toerrantly indicate closed.The inspectors noted that the A reactor water cleanup filter has not been available foruse since 1996 and only the B filter has been in service. The A filter was not consideredabandoned equipment as described in Exelon procedure CC-AA-109, EquipmentAbandoned Via Operational Configuration Change, and fell under the classification of"spare equipment." Abandoned equipment is returned to service through theEngineering Change Request process. Spare equipment being returned to servicefollows no formal process besides normal startup and operating procedures. Theinspectors observed that due to the length of time that the A filter had been idle, formalabandonment of the filter should have been considered. Although Exelon was using acomplex troubleshooting plan to evaluate the condition of the A filter and associatedequipment in order to return the filter to service, the engineering change request processmay have provided a stronger framework to evaluate the state of all the affectedcomponents and identify the leakby of ND30-B.The inspectors reviewed the classification of this event in accordance with Exelonprocedure OP-AA-300-1540, Reactivity Management Administration. Exelon classifiedthis event as a Level 4 Reactivity Management Precursor as the operators performed adownpower of greater than or equal to 0.5% due to an emergent issue, when theylowered power due to the power excursion. The inspectors observed that Exelon did notevaluate the rise in power when classifying this event. The inspectors observed that thepeak powe r (1948 MW thermal) during the excursion prior to operators taking remedialaction to lower power met the requirements for a Level 2 Major Reactivity ManagementEvent for violation of a core thermal power license limit. Additionally, the power changecaused by this event was approximately 0.9% and met the definition for a Level 3 MinorReactivity Management Event for a change in reactor power of greater than or equal to0.5% directly caused by equipment problems. Reactivity management events feed intocorporate reactivity management performance indicators and are not part of the NRCregulatory performance indicators. The inspectors evaluated this as a record keepingissue of low significance and determined it as being a minor issue..5 Annual Sample: D reactor recirculation pump return to servicea. Inspection ScopeThe inspectors performed an in-depth review of Exelon's apparent cause analysis andcorrective actions associated with condition report 1262779, Power Change During DRecirc Pump Placed in Service. Specifically, an unplanned power excursion occurredwhen placing the D recirculation pump in service after scheduled maintenance.The inspectors assessed Exelon's problem identification threshold, cause analyses,extent of condition reviews, compensatory actions, and the prioritization and timelinessof Exelon's corrective actions to determine whether Exelon was appropriately identifying,characterizing, and correcting problems associated with this issue and whether theplanned or completed corrective actions were appropriate. The inspectors compared theactions taken to the requirements of Exelon's corrective action program and 10 CFR 50,Appendix B.Enclosure b.23Findinqs and ObservationsNo findings were identified.Exelon determined the most probable cause was due to less than adequate proceduralguidance. Procedure 301.2, Reactor Recirculation System, did not provide explicitguidance to ensure operators would not exceed core thermal limits. Exelon determinedthat a contributing cause was not conducting just-in-time training prior to this evolution.Corrective actions for this event included a procedure change to give the operators moremargin to the thermal power limits when manipulating reactor recirculation flow andactions to review the work schedule while specifically looking for opportunities for just-in-time training for operators.The licensed operators responded appropriately by promptly lowering power when theynoticed that thermal power was rising. Reactor thermal power rose above 1950 MW,with a maximum licensed power limit of 1930 MW, and was above the licensed limit forless than one minute. Although the thermal power limit was exceeded, the inspectorsdetermined that there was no regulatory violation of the licensed thermal power limitbased upon guidance in NRC Regulatory lssue Summary 2007-21, Adherence toLicensed Power Limits. Specifically, the pre-planned evolution was not expected toincrease power above the licensed power limit, the reactor power was below thelicensed thermal limit at the start of the evolution and the operators monitoring powerlevels took prompt action to lower power below the licensed limit when power was notedto be above licensed limit.The inspectors reviewed the classification of this event in accordance with Exelonprocedure OP-AA-300-1540, Reactivity Management Administration. Exelon classifiedthis event as a Level 3 Reactivity Management Precursor for a change in reactor powerof greater than or equal to 0.5% directly caused by equipment problems. The inspectorsobserved that Exelon did not appropriately evaluate the rise in power when classifyingthis event. The inspectors observed that the peak power (greater than 1950 MWthermal) during the excursion prior to operators taking remedial action to lower powermet the requirements for a Level 2 Major Reactivity Management Event for violation of acore thermal power license limit. Reactivity management events feed into corporatereactivity management performance indicators but are not part of the NRC regulatoryperformance indicators. The inspectors evaluated this as a record keeping issue of lowsignificance and determined it as being a minor issue.The inspectors determined Exelon's overall response to the issue was commensuratewith the safety significance, was timely, and included appropriate compensatory actions.The inspectors determined that the actions taken were reasonable to resolve both theimmediate power excursion and the knowledge gap which led to the potential to exceedcore thermal limits.Annual Sample: Torus pinslnsoection ScopeThe inspectors reviewed the evidence of degradation of the structure supporting thetorus sway bar struts generally referred to as a stanchion. The inspectors visuallyexamined every stanchion looking for the degree of oxide exfoliation (.i.e., flakes-of-rust)Enclosure.6 24that filled the stanchion. The inspectors noted the presence of water in somestanchions, collateral evidence of degradation, captured in the open rectangular boxformed by the thick stanchion membranes. The inspectors paid close attention to thecondition of the six inch diameter pin, inserted between opposite walls of the openrectangular box that supports the vertical strut and allows for strut movement during anevent. The inspectors reviewed the management of the aging effects to determine if theattributes of preventive actions, monitoring, detection, trending, acceptance criteria,corrective actions, confirmation, administrative controls, and operating experience wereaddressed.In addition to a complete visual examination of all the stanchions, the inspectorsreviewed various related documents and interviewed station personnel involved in themanagement of structural integrity. The inspectors compared the documented recordand results of interviews with the corrective action's identification of root and contributingcauses of the problem. The inspectors determined if the documented information wasreported to appropriate levels of management. The inspectors reviewed the correctiveaction to determine if the corrective action was appropriately focused to correct theproblem (and to address the root and contributing causes for significant conditionsadverse to quality).The inspectors reviewed the Exelon process to identify, prioritize and resolve theobserved degradation. The inspectors reviewed the analysis, performed by Exelon, todetermine the operability of the pins and performed an independent calculation to verifythe conclusions. The corrective actions and planned actions were reviewed for rigor ofevaluation and disposition of operability and reportability issues, consideration of extentof condition and cause, generic implications, common cause, and previous occurrences.The corrective actions were further reviewed to determine if the classification andprioritization of the problem's resolution was commensurate with the safety significance.The inspectors further determined if the completion of corrective actions was in a timelymanner commensurate with the safety significance of the issue. The inspectorsconsidered if any delays in implementation were justified based on the safetysignificance of the issue. The inspectors considered if any permanent corrective actionsrequired significant time to implement and if interim corrective actions and/orcompensatory actions were identified and implemented to minimize the problem and/ormitigate its effects until the permanent action could be implemented.Because Oyster Creek is operating with a renewed operating license, the inspectorscompared the actions taken to the requirements of the Exelon corrective action programand 10 CFR Part 50, Appendix B, and NUREG 1800, Rev 2, "Standard Review Plan forReview of License Renewal Applications for Nuclear Power Plants," Appendix A.1,"Aging Management Review - Generic (Branch Technical Position RLSB-1)," in order todeiermine if the corrective actions, and proposed future actions met the standard for anappropriate aging management program.b. Findinqs and ObservationsNo findings were identified.The inspectors noted the amount of exfoliation contained in the stanchion did not visuallycorrespond to the amount of material degraded from the pin. In many cases, theEnclosure

.725 inspectors noted the amount of exfoliation present in the stanchion could not beexplained by the evidence of a smooth coating of light rust on the pin. This observationsupports the licensee's plan to disassemble, clean, and inspect two strut supports withevidence of the most amount of degradation in order to determine conclusively the rootcause of the exfoliation.ln summary, there was no indication of a potentially safety significant issue related to thepreservation of design margins under the current licensing basis and aging managementover the period of extended operation. Further, no trends were noted by the inspectors,in the examples and analysis selected from this specific corrective action for detailedreview. The inspectors observed that Exelon staff implemented their corrective actionprocess, following the stipulated program requirements regarding the initial discovery ofthe reviewed issue along with managing the effects of aging. The corrective actions forthe identified degradation included developing a plan to verify the root cause of thedegradation. The corrective action documentation, relative to the proceduralrequirements, was complete and included implemented and planned future correctiveactions. In addition, the elements contained in the corrective action documentationconsisted of detailed and thorough information. Interim corrective actions, such asperforming ongoing system monitoring and trending, were structured to minimizepotential failures pending system repair.Annual Sample: Review of root cause evaluation of procedure qualitv issueslnspection Scope (71152 - 1 sample)The inspectors reviewed Exelon's evaluation and corrective actions associated with lR01205903 "Root Cause Evaluation: Procedure Quality lssues That Resulted in Five NRCFindings With the Common Cross-Cutting Aspect of Human Performance - ResourceDocumentation (H.2(c))." The inspectors reviewed the Root Cause Evaluation,procedures, CRs, and interviewed personnel related to the issue to ensure that thefull extent of the issue was identified, appropriate evaluations were performed, andcorrective actions were specified, prioritized and effective. The inspectors discussed thisissue with station management.FindinqsNo findings were identified.The inspectors determined that the Root Cause Evaluation appropriately identified theroot and contributing causes of the issue and that the corrective actions associated withthe root and contributing causes were adequate, effective, and commensurate with thesignificance of the identified issues.Fof low-Up of Events and Notices of Enforcement Discretion (71153 - 1 sample)Plant EventsInspection ScopeFor the plant events listed below, the inspectors reviewed and/or observed plantparameters, reviewed personnel performance, and evaluated performance of mitigatingEnclosurea.b.40A3.1a.

40A5.126systems. The inspectors communicated the plant events to appropriate regionalpersonnel, and compared the event details with criteria contained in IMC 0309, "ReactiveInspection Decision Basis for Reactors," for consideration of potential reactive inspectionactivities. As applicable, the inspectors verified that Exelon made appropriateemergency classification assessments and properly reported the event in accordancewith 10 CFR Parts 50.72 and 50.73. The inspectors reviewed Exelon's follow-up actionsrelated to the events to assure that Exelon implemented appropriate corrective actionscommensurate with their safety significance.o High hydrogen alarm in the C battery room on December 21,2011FindinosNo findings were identified.Other Activities(Closed) Unresolved ltem (URl) 05000219/2011-003-03: Difficultv in drawino a maincondenser vacuum durinq olant startup due to water in 48 inch holdup lineln December 2010, Oyster Creek experienced an automatic reactor scram due to lowcondenser vacuum during startup from the 1F26 forced outage. Exelon performed aroot cause analysis focused on operator performance issues related to the scram. Theinspectors reviewed the root cause analysis and documented a finding and observationin section

4OA2 of resident quarterly inspection report 500021912011002. Theinspectors noted that the root cause did not identify some contributors to the scram;specifically, that condenser vacuum did not respond as expected when a second set ofair ejectors was placed in operation, and that an additional step in the startup procedure,which would have verified that there was adequate vacuum to secure the mechanicalvacuum pump, had been signed off as complete when vacuum was actually below therequired value. Exelon entered these observations into the corrective action program asassignment 2 of lR 1 1931 10. The inspectors further observed that a similar eventoccurred in 2006 (lR 556890) where Oyster Creek experienced difficulty in drawing acondenser vacuum during startup and pedormed an equipment apparent causeevaluation (EACE). Due to the similarity of the 2006 and 201 1 events, the inspectorsreviewed the effectiveness of the corrective actions listed in lR 556890 in considerationof the reactor scram documented in lR 1193110.The action items generated in lR 556890 included developing a preventive maintenancetask for periodic replacement of V-7-29, a solenoid operated drain valve for the off gassystem holdup line, and modification of the air extraction and off gas system startupprocedure to include a flush of the holdup line drain line. The replacement of V-7-29was determined to be required on a 4 year periodicity based upon the environmentalconditions that the valve is subject to and the service life of the valve. The inspectorsverified that this valve was last replaced in April 2007. The inspectors noted that thepreventive maintenance task that causes the valve replacement was issued in April 2008and the first scheduled replacement of the valve was scheduled for 4 years from thatdate instead of 4 years from the actual date of last replacement. The inspector notifiedwork control personnel, who corrected the due date to April 2011 and documented theiractions in lR 1227974. However Exelon was unable to replace the valve by that dateand the next replacement is now scheduled for the upcoming 1R24 refueling outage,Enclosure

.227 which is approximately 5.5 years after the last replacement. Although this exceeds the 4year replacement criteria specified in the preventive maintenance task, the valve wasverified to be working correctly after it was found submerged in November 2010 asdocumented in lR 1140316. The inspectors reviewed several reactor startups andverified that the drain line was flushed in accordance with the modified startupprocedure, including the startup from 1F26.The inspectors reviewed vacuum system response during several startups since 2006.Although some vacuum anomalies were noted, the system response since the scram inDecember 2010 has been as expected. The inspectors interviewed the system engineerconcerning maintenance practices, inspections and performance of the mechanicalvacuum pump and steam jet air ejectors. The inspectors reviewed completed workpackages and inspection results on the air ejectors and found that the last inspectionshowed them to be within tolerances. Exelon compared work procedures for themechanical vacuum pump with those in the vendor's manual, reviewed the maintenancehistory, found no discrepancies and documented the results of their review in lR1267198. The inspectors found that Exelon's actions were adequate.The inspectors did not identify any violations of NRC requirements. This unresolveditem is closed.(Closed ) Non-cited Violation (NCV) 05002 1 9/201 1 503-0 1 /Findinq (FlN)05000219/201 1503-02: Chanqes to EAL Basis Decreased the Effectiveness of the Planwithout Prior NRC AoprovalInspection ScopeOn September 12,2011, the NRC transmitted a non-cited violation (NCV-EA-11-128)and a Green finding to Exelon related to a change Exelon made to the emergency actionlevel (EAL) basis for EAL HU6, which introduced a decrease in effectiveness to OysterCreek's Emergency Plan and resulted in a violation of the requirements stipulated in10 CFR 50.5a(q). Specifically, the licensee modified the EAL Basis in EAL HU6,Revision 0, which extended the start of the 15-minute emergency classification clockbeyond a credible notification that a fire is occurring or indication of a valid fire detectionsystem alarm. This change decreased the effectiveness of the Emergency Plan byreducing the capability to perform a risk significant planning function in a timely manner.The NCV and finding were described in detail in NRC Inspection Report No.0500021912011503.In response to the NCV and finding, Exelon entered the issue into their corrective actionprogram as lR 01 184333 and subsequently implemented Revision 3 of the Oyster CreekEmergency Plan, which restored the EAL HU6 Basis to the Revision 10 (of the pre-Exelon Revision 0 Emergency Plan) guidance, thereby removing the decrease ineffectiveness. The inspectors reviewed lR 01 184333 and the revised version of the HU6Basis, and discussed the corrective actions with the Oyster Creek EmergencyPreparedness staff.Findinqs and ObservationsNo findings were identified. The inspectors determined that Exelon's response andcorrective actions were reasonable and appropriate to address the NCV and finding, andtheir underlying performance deficiency. The NRC considers the issue to be closed.a.b.Enclosure

284OAO Meetinqs. Includinq ExitOn January 23,2012 the inspectors presented the inspection results to M. Massaro, SiteVice President and other members of the Oyster Creek staff. The inspectors verifiedthat no proprietary information was retained by the inspectors or documented in thisreport.4C.AT Licensee-ldentified ViolationsNone.ATTACHM ENT:

SUPPLEMENTARY INFORMATION

Enclosure

A-1SUPPLEM ENTARY INFORMATIONKEY POINTS OF CONTAGT

Licensee Personnel

M. Massaro, Site Vice-President

R. Peak, Plant Manager

M. McKenna, Director, Operations

G. Malone, Director, Engineering

J. Dostal, Director, Maintenance

C. Symonds, Director, Training

D. DiCello, Director, Work Management

J. Barstow, Manager, Regulatory Assurance

T. Farenga, Radiation Protection Manager

M. Ford, Manager, Environmental/Chemistry

T. Keenan, Manager, Site Security

R. Skelsky, Senior Manager, Plant Engineering

H. Ray, Senior Manager, Design Engineering

G. Flesher, Shift Operations Superintendent

J. Chrisley, Regulatory Assurance Specialist

D. Moore, Regulatory Assurance Specialist

J. Kerr, Regulatory Assurance Specialist

M. Nixon, Effluents Chemist

J. Raby, Radiation Protection Supervisor

J. Renda, Manager, Performance lmprovement

E. Tucker, Nuclear Oversight, Audits

K. Wolf, Radiation Protection Technical ManagerL Abelev, Standby Gas Treatment System Manager

J. Bills, Environmental, Radioactive Waste Supervisor

D. Chernesky, Assistant Maintenance Director

J. Chrisman, Radioactive Waste Shipper

P. Deckman, Maintenance Manager

T. DiTaranto, Radioactive Waste Chemist

J. McCarthy, Senior Technical Specialist, Radiation Protection

J. Murphy, Radiological Engineering ManagerOthers:

K. Tuccillo, Supervisor, Nuclear Environmental Engineering Section (NEES), New JerseyDepartment of Environmental Protection (NJDEP) - Bureau of Nuclear Engineering(BNE)

P. Schwartz, Nuclear Engineer, NEES, NJDEP, BNEAttachment

A-2LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATEDOpened/Closed0500219/2011-005-01 NCV Failure to Establish New Reference Valuesln Accordance with ASME CodeClosed0500219/201 1-003-03 URI Difficulty in drawing a main condenser vacuumduring plant startup due to water in 48 inch holdupline (Section 4OA5)050021912011503-01 NCV (Traditional Enforcement) Changes to EAL BasisDecreased the Effectiveness of the Plan withoutPrior NRC Approval (4OA5)050021 912011503-02 FIN Changes to EAL Basis Decreased theEffectiveness of the Plan without Prior NRCApproval (4OA5)LIST OF DOCUMENTS REVIEWEDSection 1R01: Adverse Weather ProtectionProceduresOP-OC-108-109-1001 , Preparation for Severe Weather T&RM for Oyster Creek, Revision 12OP-AA-108-1 11-1001, Severe Weather and Natural Disaster Guidelines, Revision 6WC-AA-107, Seasonal Readiness, Revision 9OP-OC-108-109-1002, Cold Weather Freeze Inspection, Revision 4ABN-31, High Winds, Revision 16ABN-32, Abnormal Intake Level, Revision 18Condition Report (lR)1169462 1148348 1249177 1281142Maintenance Orders (AR)A2268453 C2A2046 A2266608 A2283781 A2289303MiscellaneousWinter Readiness Work (lnitial Cut) 2011Section 1R04: Equipment AliqnmentProcedures308, Emergency Core Cooling System Operation, Revision 90307, lsolation CondenserSystem, Revision 116Attachment

A-3Condition Report (lR)861950 902105 906896Maintenance Orders (AR)R2151529 A2215767Drawinos9583789775001210116BR 2005, Emergency Service Water System Flow DiagramGE 148F740, Containment Spray System Flow DiagramGE 885D781, Core Spray System Flow DiagramGE 148F262, Emergency Condenser Flow DiagramMiscellaneousOyster Creek Generating Station UFSAR 6.3.1.3, Core Spray SystemOyster Creek Generating Station UFSAR 6.3.1 .1 , lsolation Condenser SystemTechnical Specification 3.8, lsolation CondenserVM-OC-5001, Care and Operation of lsolation CondensersSection 1R05: Fire ProtectionProceduresABN-29, Plant Fires, Revision 26101.2, Oyster Creek Site Fire Protection Program, Revision 67CC-AA-21 1, Fire Protection Program, Revision 4333, Plant Fire Protection System, Revision 106Condition Reports (lR)1266418 1302888Work Orders (AR)R2182583MiscellaneousOyster Creek Generating Station Pre-Fire Plan: OB-FZ-6A,480V Switchgear Room "A"Oyster Creek Generating Station Pre-Fire Plan: TB-FZ-11C,4160V "A" & "8" Switchgear Room,Oyster Creek Generating Station Pre-Fire Plan: TB-FA-26, "C" Battery RoomOyster Creek Generating Station Pre-Fire Plan: OB-FZ-A,Turbine Bldg. - Cable SpreadingRoom (Old)Oyster Creek Generating Station Pre-Fire Plan: OB-FA-9, Main Office BuildingFiie Drill Scenario, Control Room Annex North Side Cable Room, dated December 14,2011Fire Drill Record, dated December 15,2011Section 1Rl1: Licensed Operator Requalification ProqramMiscellaneousScenario 26 1 2.CREW. 1 1 -6.01Attachment

A-4Section 1 R12: Maintenance EffectivenesgProceduresER-AA-3'10, lmplementation of Maintenance Rule, Revision 8ER-AA-310-1005, Maintenance Rule - Disposition Between (aX1) andLS- AA-125-1003, Apparent Cause Evaluation Manual, Revision 10ER-AA-310-1001, Maintenance Rule - Scoping, Revision 4Condition Reports(a)(2), Revision 61209785 12563231212538 12051171 290803MiscellaneousNEI 93-01, lndustry Guideline for Monitoring the EffectivenessPlantsMaintenance Rule Scoping Document for System 641, Reactor Protection SystemMaintenance Rule Scoping Document for System 621, Core Monitoring SystemMaintenance Rule Expert Panel Meeting Minutes, October 6,2011Oyster Creek Generating Station Maintenance Rule Periodic (aX3) Assessment, July 1,2009 -June 30, 201 1Section 1R13: Maintenance Risk Assessments and Emergent Work GontrolProcedures101.2, Oyster Creek Site Fire Protection Program, Revision 67WC-OC-101-1001, On-Line Risk Management and Assessment, Revision 61 2639611 16880212655841 1658651246795126966212212471225305Condition Reports1301461 1301745MiscellaneousOyster Creek Spar ModelCondition Report (lR)1271279 12748711301581 13019331285841Maintenance OrdersAtVork OrdersR2189616 R2192771 A2292045of Maintenance at Nuclear Power1301581 1301933 1301514 1302134Event and Condition Assessment, dated December 13,20111281326 1274974 1301461 13017451301514 1302134 1304907 1278683Section 1 R1 5: Operabilitv EvaluationsProcedures329, Reactor Building Heating, Cooling and Ventilation System, Revision 62101.2, Oyster Creek Site Fire Protection Program, Revision 67645.4.036, Fire Pump #2 Operability Test, Revision 18607.4.004, Containment Spray and Emergency Service Water Pump System 1 Operability andCom prehensive/Preservice/Post-Maintenance I nservice Test, Revision 75R2152668 C2026778 A2287794Attachment

A-5MiscellaneousOyster Creek Generating Station UFSAR, Table 9.4-1, Reactor Building Heating and VentilationSystemOC-201 1 -OE-0007, Operability EvaluationASME OMa Code-1995 with the 1996 Addendum, Subsection ISTB, lnservice Testing of Pumpin Light-Water Reactor Power Plants725751-15, IST Pump Evaluation Form, dated October 19,20111231326, NRC question regarding IST evaluation, dated November 3,20111231326, NRC question regarding IST evaluation, dated November 15,2011VM-OC-0003, LN Pumps - Instruction Manual and Parts ListJersey Central Power & Light Company letter, Oyster Creek Nuclear Generating Station DocketNo. 50-219 Fire Protection Program, dated October 3,1977Flowserve Letter, Request Approval of Performance Test Containment Spray Pumps - model8LN18, dated September 24,2004Branch Technical Position APCSB 9.5-1, Guidelines for Fire Protection for Nuclear PowerPlants Docketed Prior to July 1 , 1976Oyster Creek Generating Station UFSAR, 6.3.1.'1, lsolation Condenser SystemTechnical Specification 3.8, lsolation CondenserASME OM Code 1995 with 1996 Addenda, Subsection ISTB, Inservice Testing of Pumps inLight-Water Reactor Power PlantsPerformance Trend Data for P-21-1A, dated October 25,2011NUREG-1482, Guidelines for lnservice Testing at Nuclear Power Plants, Revision 1Section 1 R19: Post-Maintenance TestinqProcedures609.3.023, B lsolation Condenser lsolation Test and Calibration- B1 Sensors First, Revision 0645.4.001, Fire Pump #1 Operability Test, Revision 65609.4.001, lsolation Condenser valve Operability and ln Service Test, Revision 72312.9, Primary Containment Control, Revision 53330, Standby Gas Treatment System, Revision 531 16, Surveillance Testing Program, Revision 88651.4.001, "standby Gas Treatment Auto Actuation Test", Revision 64Condition Report (lR)1270059 1281670 1275740 12757911280520 1226484 936805 10133811226484 1244702 1288845 12477221250909 12852911022923 104243912269352151529 M2287941 M2284181 C2026279A2279541 C2025943 R2149264Maintenance Orders (AR)2118212 2180899R219223 A2287516MiscellaneousECR OC-11-00556, B lC Steam Inlet Valve V-14-33 Packing LeakDrawing GU 3E-822-21-1000, Standby Gas Treatment Flow DiagramRegulatory Guide 1.52, Design, Inspection, and Testing Criteria for Air Filtration and AdsorptionUnits of Post-Accident Engineered-safety-Feature Atmosphere Cleanup Systems inLight-Water-Cooled Nuclear Power PlantsOyster Creek Generating Station UFSAR 6.5, Fission Product Removal and Control SystemsSDBD-OC-822, System Design Basis Document for Reactor Building Ventilation SystemC-1302-822-5360-045, SGTS Cooling Air Flow RequirementAttachment

A-6Section 1 R22: Surveillance TestinqProcedures609.3.113, lsolation Condenser Automatic Actuation Bistable Calibration and Test, Revision 21607.4.004, Containment Spray and Emergency Service Water Pump System 1 Operability andComprehensive/ Prese rvice/ Post-Maintenance lnservice Test, Revision 75312.9, Primary Containment Control, Revision 53ER-AB-331-1006, BWR Reactor Coolant System Leakage Monitoring and Action Plan, Revision2Condition Report (lR)1271676 1278683 1278795 1296997 1217663 12393351266282 1272246 1290256 1281326Work Orders (AR)R2184316 R2152668 R2152668MiscellaneousTPC-20111019-01, Temporary Procedure Change for, Containment Spray and EmergencyService Water Pump System 1 Operability and Comprehensive/ Preservice/ Post-Maintenance Inservice Test, Revision 75ASME OM Code-1995 with the 1996 Addendum, Subsection ISTB, Inservice Testing of Pumpsin Light-Water Reactor Power Plants725752-15, IST Pump Evaluation Form for P-21-1A, dated October 19,2011NUREG-1482, Guidelines for lnservice Testing at Nuclear Power Plants, Revision 1VM-OC-O145, Rosemount Model 1151 Alpine Pressure TransmittersSection 1EP6: Drill EvaluationMiscellaneousScenario 26 1 2.CREW .1 1 -6.0 1Section RS01: Access Gontrol to Radiolosicallv Sionificant AreasProceduresRP-AB-460, TIP Area Access Control, Revision 1RP nn-460, Controls for High and Locked High Radiation Areas, Revision 20RP-AA-460-001, Control for Very High Radiation Areas, Revision 2RP-AA-460-002, Additional High Radiation Area Control, Revision 0RP-AA-460-003, Access to HRA/LHRA/VHRAS In Response to a Potential or ActualEmergency, Revision 1RP-AA-461, Radiological Control for Contaminated Water Diving Operations, Revision 2RP-AA-870-1002, Use of Vacuums in Radiological Controlled Areas, Revision 2RP-OC-301-1001, Air Sample Collection and Analysis TRM, Revision 5RP-AA-503, Unconditional Release Survey Method, Revision 5233.2, DrywellAccess and Control During Fuel Movement, Revision 12MiscellaneousRadiation Work Permits - RWP 721,731,732,740High Radiation Area key control status- quarterly inventory, boundary validation, daily checksRadiation Protection Audit Report NOSA-OYS-1 1-06Attachment

A-7Focused Area Self-assessment 1 134322-0320 1 I P eriodic Alpha CharacterizationSection RS02: OccupationalALARA Planninq and ControlsMiscellaneousGeneral Source Term dataRadiation Work permits and ALARA plans - RWP 721 ,731,732,740Section RS03: ln-Plant Airborne Radioactivitv Gontrol and MitiqationProceduresRP-OC-826, Inspection of MSA Firehawk Mask Mounted Regulator SCBAs, Revision 5RP-OC-827, Flow Testing of MSA Firehawk (MMR) SCBAS, Revision 2MiscellaneousBreathing Air Certification Test DataEmergency Equipment SCBA Check-offSCBA test data- packs 21, 27,26, and 1710 CFR 61 Waste Stream Analysis ReportSection RS04: Occupational Dose AssessmentMiscellaneousExposure Control and Dose RecordsGeneral Source Term dataPersonnel Contamination Event DataPersonnel Intake InvestigationsSection RS05: Radiation Monitorinq lnstrumentationMiscellaneousGeneral Source Term dataHigh Range Effluent Monitor Set-point BasesSection RS06: Radioactive Gaseous ancl Liquiol Effluent TreatmentProceduresEN-OC-408-4160, RGPP Reference Material for Oyster Creek Generating Station, Revision 4CY-OC-120-900, Stack Effluent Sampling and Analysis, Revision 18CY-OC-120-910, Turbine Building ventilation System Sampling, Revision 7CYY-OC-120-920, AOG Building Effluent and Process Gas Sampling and Analysis, Revision 12621.3.023, Stack RAGEMS Sample and Effluent Flow Calibration, Revision 23621.3.034, Turbine Building RAGEMS and Effluent Flow Calibration, Revision 15651.3.002, SBGTS Particulate Filter leak test, Revision, Revision 25651.1.006, SBGTS Charcoal radioactive Methyl lodine Removal test, Revision 20651.2.004, SBGTS Electrical Test - Heater, Revision 12MiscellaneousAnnual Effluent Release and Environmental ReportsOffsite Dose Calculation Manual (Rev. 5) and changesAttachment

A-8Teledyne Brown 2nd Quarter Quality Assurance Report (January- June 201 1)Chemistry Quality Assurance Laboratory Cross Check fourth quarter 2010Radiochemistry Cross Check Program results - second quarter 2009Service Water Radiation Monitor Set-point Calculation (OCG3-007)SBGTS test data10 CFR 61 Waste Stream Analysis Report 2011lE Bulletin 80-10 System List and Sample PlanReports (various) - Routine Ground WaterReport- Hydrogeology Investigation ReportGeneral Source Term DataSection RS07: Radioloqical Environmental Monitorinq Prosram (REMP)ProceduresCY-AA-170-210, Potentially Contaminated System Controls program, Revision 0CY-OC-120-1105, Chemical Addition System Sample and Analysis Schedule, Revision 9CY-AA-1 30-201, Radiochemistry Quality Control, Revision 0CY-AA-1 70- 1 000, Rad iolog ical Environmental Monitoring Program and MeteorologicalProgram lmplementation, Revision 5RW-AA-100, Process Control Program for Radioactive Wastes, Revision 7MiscellaneousAnnual Effluent Release and Environmental ReportsEnvironmentalTLD Calibration Data - Calibration RecordsEnvironmental TLD Read-out DataGlobal Dosimeter Fade VerificationNUPIC Audit SA1 0-017, Mirion TechnologiesISOLOC Sampler cycle dataMirion Technologies NPP Supplier Audit Report SA10-07Section RS08: Radioactive Solid Waste Processinq and Radioactive Material Handlinq.Storaqe. and TransportationProcedures351.4, Solid Radioactive Waste Operating Procedure, Revision 6MiscellaneousRadioactive Waste Facility Material Condition reports10 CFR 61 Waste Stream Analysis Report - 2011Radioactive Waste Shipment Data - OC-4002-11Section 4OAl : Performance lndicator VerificationProceduresLS-AA-2001, Collecting and Reporting of NRC Performance Indicator Data, Revision 14LS-AA-2200, Mitigating System Performance Index Data Acquisition and Reporting, Revision 3MiscellaneousNEI 99-02, Rev. 6, Regulatory Assessment Performance Indicator GuidelineAnnual Radiological Environmental, Effluent Release Report- 20102010-2011 Public Dose ProjectionsAttachment

A-9Offsite Dose Calculation Manual and changesRadiologicalWork Doses Greater than 100 milliremOyster Creek MSPI Basis DocumentlE-03-Unplanned Power Changes per 7000 Critical Hours Frequently Asked Question, datedFebruary 2011Oyster Creek Unit 1 - 4Q2011 - Pl Data Elements (QR) Change File, dated January 19,2012Section 4OA2: Problem ldentification and ResolutionProcedures202.1, Power Operation, Revision 124CC-AA-109, Equipment Abandoned Via Operational Configuration Change, Revision 5OP-AA-300 -1540, Reactivity Management Administration, Revision IMA-AA-716-004, Conduct of Troubleshooting, Revision 10OP-AA-108-105, Equipment Return to Service, Revision 4OP-AA-300, Reactivity Management, Revision 5OP-OC-300-1000, Reactivity Management Threat Management, Revision 1WC-AA-106, Work Screening and Processing, Revision 13AD-AA-101-1002, Writer's Guide for Procedures and T&RM, Revision 15AD-AA-101, Processing of Procedures and T&RMs, Revision 23303, Reactor Cleanup Demineralizer System, Revision 126WC-AA-104, Integrated Risk Management, Revision 17OP-AA-108-110, Evaluation of Special Tests or Evolutions, Revision 2OP-AA-102-103, Operator Work-around Program, Revision 3OP-AA-102-103-1001, Operator Burden and Plant Significant Decisions lmpact AssessmentProgram, Revision 4301.2, Reactor Recirculation System, Revision 74OP-AA-100, Exelon Nuclear Conduct of Operations Manual, Revision 0ER-OC-450, Structures Monitoring Program, Revision 2Condition Reports1278033 1256951 1262193 1037619 1022511 10535771164020 1175089 1205823 1205903 1260868 12609161261018 1261657 1261681 1262324 1262379 12553091255312 1255329 1255201 1255196 1255198 12553571255377 1255376 1255186 1255187 1255403 12551921255341 1255206 1240319 1240326 1240330 12403311240347 1241299 1118826 1262779 12ffi6}0 556002839033 1225305Work Orders (AR)c5050108 c0061033 c2022135 A2285007 A2112538 A2275763A2246733 PM99904 R2128839 R2132651 A2147360DrawinosGE 148F444, Clean Up Demineralizer System Flow Diagram, Revision 88MiscellaneousNR- Regulatory lssue Summary 2007-21, Adherence to Licensed Power Limits, Revision 1Safety Evaluation, NEI Guidance Document to Licensees on Complying with the LicensedPower Limit. dated October 8, 2008Attachment

A-10NEI Position Statement, Guidance to Licensees on Complying with the Licensed Power Limit,dated June 12, 2008VM-OC-0155, Clean Up Filtration System Components ManualOyster Creek Generating Station UFSAR 5.4.8, Reactor Water Cleanup System1 OCFR50.2, DefinitionsReactor Water Cleanup System, Revision 15Operations Department Logs, dated October 18,2011Operator Burden Aggregate Assessment Form, Revision 0Operators Challenge and Operator Work-around Plan of Day ReportNOSA-OYS-1 1 -06, Radiation Protection Audit Report1 134322-03, Focused Area Self-assessmentForm #187-008 "RB Floor Elevation (-) 19"-6" - "Torus Outer Support Baseplate Pins", datedJuly 8, 2011ER-OC-450 Revision 0, Attachment 8, Form #R209138-01-04,"Structures and ComponentsMonitoring Report", "Area - Torus Room and Corner Rooms below El.23'-6"", datedOctober 29,2006AR 00556002 Report, "structural Monitoring Deficiencies in Torus Supports", datedNovember 10,2006R2132651, "lnspect Containment lnternal Structures", dated November 30, 2010AR 00839033, "(1R22 lsl) Tours Sway Brace Rust and Bolt Conditions", dated November 1,2008A2147360-03 "Verification of Torus Outer Support Baseplate Pin Capacity", dated August 4,2011Section 4OA3: Followup of Events and Notices of Enforcement DiscretionProceduresRAP-U7f, C Bat H2 Hl, Revision 3ABN-33, Toxic or Flammable Gas Release, Revision 8EP-AA-1010, Radiological Emergency Plan Annex for Oyster Creek Station, Revision 3Condition Report (lR)1305669 1305713MiscellaneousOyster Creek Generating Station Operations Log, dated December 21,2011Section 4OA5: Other ActivitiesProcedures325, Air Extraction and Off Gas System, Revision 66201, PlanI Startup, Revision 71Condition Reoorts (lR)556890 835872 1267198 1155520 1193110 578204985777 993508 1062796 1197337 495114 11403161267198 1227974Attachment

A-11Work Orders (AR)R2121215 R2182478 R2131041 A2207565 R2118340 A2211728R2098257 R0800766 R2192716MiscellaneousComponent History Work Order Closure for V-7-29, dated March 31, 2011Component History Work Order Closure for V-12-317, dated March 31,2011Attachment