IR 05000219/2011004

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

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

Text

UNITED STATESNUCLEAR REGULATORY COMMISSIONREGION I475 ALLENDALE ROADKING OF PRUSSIA. PENNSYLVANIA 19406.1415Nrivember 2, 20llMr, MichaelJ. PacilioSenior Vice President, Exelon Generation Company, LLCPresident and Chief Nuclear Officer, Exelon Nuclear4300 Winfield RoadWarrenville, lL 60555

SUBJECT: OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTIONREPORT 0500021 9t201 1004

Dear Mr. Pacilio:

On September 30, 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 October 17 with Mr. M. Massaro, Site VicePresident, and other 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.Based upon the results of this inspection, no findings were identified.ln accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, itsenclosure, and your response (if any) will be available electronically for public inspection in theNRC Public Document Room or from the Publicly Available Records (PARS) component of theNRC's document system (ADAMS). ADAMS is accessible from the NRC website athtto://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely,Eugene M. DiPaolo, Acting ChiefReactor Projects Branch 6Division of Reactor Projects50-219DPR-16I nspection Report 050002 1 9/2Afi OO4

w/Attachment:

Supplemental I nformationDistribution via ListServDocket No,:License No.:

Enclosure:

cc w/encl:

Mr. Michael

SUMMARY OF FINDINGS

lR 0500021912011004; July 1 - September 30, 2Q11; Oyster Creek Generating Station;Integrated ReportThis report covered a three-month period of inspection by resident inspectors and announcedinspections performed by regional inspectors. The NRC's program for overseeing the safeoperation of commercial nuclear power reactors is described in NUREG-1649, "ReactorOversight Process," Revision 4, dated December 2006.No findings were identified.Enclosure

4

REPORT DETAILS

Summarv of Plant StatusOyster Creek began the inspection period at 100 percent power. Operators performed shortduration unplanned power reductions on July 19, 21 , 22, 23, 24, 25, 26, 27 , and 31 andAugust 1 and 6 to adhere to environmental thermal discharge permit limitations. The operatorsreturned the plant to 100 percent power following each of these power reductions.On July 28, operators performed an unplanned power reduction to 70 percent power due to lossof the B 34.5kV bus which interrupted power to the dilution pumps. Power was subsequentlylowered to 52 percent to adhere to environmental thermal discharge permit limitations.Following restoration of power to the dilution pumps, operators returned the plant to 100 percentpower on July 29.On July 29, operators performed an unplanned power reduction to 70 power due to a loss ofpower to the dilution pumps caused by a lightning strike on the Q121 offsite power line.Following restoration of power to the dilution pumps, operators returned the plant to 100 percentpower on July 30.On August 23, operators performed an unplanned power reduction to 70 percent to performrepairs to the A reactor feedwater pump. The plant returned to 100 percent power onAugust 25.On August 27, operators commenced an unplanned reactor shutdown due to the approach ofHurricane lrene. Cold shutdown was achieved on August 28. After consultation with the Stateof New Jersey and the Federal Emergency Management Agency (FEMA) on August 28,operators commenced a reactor startup and returned the plant to 100 percent power onAugust 30.On August 31, operators reduced power to 70 percent to perform a rod pattern adjustment. Theplant returned to 100 percent power later the same day.On September 21, operators performed an unplanned power reduction to 65 percent power torepair leaking tubes in the B main condenser. The plant returned to 100 percent power onSeptember 22.Oyster Greek remained at or near 100 percent power for the remainder of the inspection period.1. REACTORSAFETYCornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1 R01 Adverse Weather Protection (71111.01 - 1 sample).1 Evaluate Readiness for lmpendinq Adverse Weather Conditionsa. lnspection ScopeThe inspectors reviewed Exelon's preparations and readiness for Hurricane lrene fromAugust 25 through August 28. The inspectors performed walkdowns of the areas thatEnclosure 5could be impacted by hurricane conditions such as the intake structure, emergencydiesel building and transformer yard. The walkdown verified that station personnelsecured loose materials prior to the arrival of high winds and implemented compensatoryactions specified in Exelon severe weather procedures. The inspectors verified thatExelon monitored the approach of the storm and took appropriate actions as required.The inspectors provided continuous onsite coverage starting prior to arrival of the stormon August 27 until the storm passed on August 28. Documents reviewed are listed inthe Attachment.b. FindinosNo findings were identified.

1R04 EquipmentAliqnment

.1 Partial Svstem Walkdowns (71111.04Q - 4 samples)a. Inspection ScopeThe inspectors performed partialwalkdowns of the following systems:r Containment spray system 2 with containment spray system 1 unavailable duringsurveillance testing on July 12r A isolation condenser while B isolation condenser was unavailable due to plannedmaintenance on August 11. Core spray system 2 with core spray system 1 unavailable during surveillance testingon September 6o 1-2 Service water pump while 1-1 service water pump was unavailable due toplanned maintenance on September 19The inspectors selected these systems based on their risk-significance relative to thereactor safety cornerstones at the time they were inspected. The inspectors reviewedapplicable 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 staff had properly identified equipment issues and entered them into thecorrective action program for resolution with the appropriate significancecharacterization. Documents reviewed are listed in the Attachment.b. FindinqsNo findings were identified.

1R05 Fire ProtectionEnclosure

6.1 Resident Inspector Quarterlv Walkdowns (71111.05Q - 6 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.Documents reviewed are listed in the Attachment.. New warehouse (NW-FA-23) on July 7o Northeast corner room (RB-FZ-lF ) on July 11o 480V switchgear room B (OB-FZ-68) on August 4r A and B battery room (OB-FZ-9C) on August 11o Turbine operating floor (TB-FZ-114) on August 23. Torus room (RB-FA-2) on September 15b. FindinqsNo findings were identified.

==1R06 Flood Protection Measures (71111.06

• 1 samples)==

.1 Internal Floodinq Reviewa. Inspection ScopeThe inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures toassess susceptibilities involving internalflooding. The inspectors also reviewed thecorrective action program to determine if Exelon identified and corrected floodingproblems and whether operator actions for coping with flooding were adequate. Theinspectors also focused on the southeast corner room of the reactor building/turbinebuilding which contains the containment spray C and D pumps to verify the adequacy ofequipment seals located below the flood line, floor and water penetration seals, commondrain lines and sumps, sump pumps, level alarms, control circuits, and tempo.ary olremovable flood barriers. Documents reviewed are listed in the Attachment.b. FindinosNo findings were identified.

1R11 Licensed Operator Requalification Proqram (71111.11 - l sample)Resident Inspector Quarterlv Reviewa. Inspection ScopeEnclosure

7The inspectors observed licensed operator simulator training scenario 2612.CREW.11-5.01 on August 24. 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 theemergency 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. Documents reviewed are listed in the Attachment.b. FindinqsNo findings were identified.

1R12 Maintenance Effectiveness (71111.12- 2 samples)a. Inspection ScopeThe inspectors reviewed the samples listed below to assess the effectiveness ofmaintenance activities on SSC performance and reliability. The inspectors reviewedsystem health reports, corrective action program documents, maintenance work orders,and maintenance rule basis documents to ensure that Exelon was identifying andproperly evaluating performance problems within the scope of the maintenance rule. Foreach sample selected, the inspectors verified that the SSC was properly scoped into themaintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2)performance r:riteria established by Exelon staff was reasonable. As applicable, forSSCs classified as (a)(1), the inspectors assessed the adequacy of goals and correctiveactions to return these SSCs to (a)(2). Additionally, the inspectors ensured that Exelonstaff was identifying and addressing common cause failures that occurred within andacross maintenance rule system boundaries. Documents reviewed are listed in theAttachment.. Containment spray heat exchangers (lR 1193928) on July 25o lsolation r:ondenser initiation logic relays (lR 1 178900) on August 8b. FindinqsNo findings were identified.1R13 Maintenance Risk Assessments and Emerqent Work Control (71111.13 - 4 samples)a. lnspection ScopeThe inspectors reviewed station evaluation and management of plant risk for themaintenance and emergent work activities listed below to verify that Exelon performedthe appropriate risk assessments prior to removing equipment for work. The inspectorsselected thesel activities based on potential risk significance relative to the reactor safetycornerstones. As applicable for each activity, the inspectors verified that Exelonpersonnel performed risk assessments as required by 10 CFR 50.65(aX4) and that theEnclosure

8assessments were accurate and complete. When Exelon performed emergent work, theinspectors verified that operations personnel promptly assessed and managed plant risk.The inspectors reviewed the scope of maintenance work and discussed the results ofthe assessment with the station's probabilistic risk analyst to verify plant conditions wereconsistent with the risk assessment. The inspectors also reviewed the technicalspecification requirements and inspected portions of redundant safety systems, whenapplicable, to verify risk analysis assumptions were valid and applicable requirementswere met. Documents reviewed are listed in the Attachment.o Containment spray system 1 unavailable due to surveillance testing during a gridheavy load voltage warning on July 12. Standby gas treatment system 2 unplanned outage for maintenance on August 8. Service water pump 1-1 and A control room ventilation system unavailable due toplanned maintenance on September 19. 1-1 reactor building closed cooling water (RBCCW) heat exchanger unavailable forunplanned corrective maintenance with 1-1 RBCCW pump unavailable due toplanned corrective maintenance on September 27b. FindinqsNo findings were identified.

1R15 Operabilitv Determinations and Functionalitv Assessments (71111.15 - 4 samples)a. Inspection ScopeThe inspectors reviewed operability determinations for the following degraded or non-conform ing conditions:o Low pressure carbon dioxide system on July 12 (lR 1239504). 'B' isolation condenser steam supply valve (V-14-33) stroke time on August 17 (lR1250414). Safety relief valve acoustic monitoring system operability on August 23 (lR 1252766)r CV-305-127\42-19 - Control rod drive outlet scram valve air leak on September 22(]R 1265624)The inspectors selected these issues based on the risk significance of the 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's 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. Documentsreviewed are listed in the Attachment.b. FindinqsEnclosure

9No findings were identified.

1R19 Post-Maintenance Testinq (71111.19 - 5 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 theprocedure 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 andior 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. Documents reviewed arelisted in the Attachment.r B isolation condenser steam inlet valve (V-14-33) on August 11 (C2026219)o 1 diesel fire pump starting battery replacement on August 12 (R2148297)o 2 diesel fire pump following annual preventive maintenance on September 3(R2169826/ R21801 10). #2 emergency diesel generator planned maintenance on September 16 (R2143612). 1-1 service water pump preventive maintenance on September 19 (R21 87785)b. FindinqsNo findings were identified.1R22 Surveillance Testins (71111.22 - 4 samples)a. lnspection 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. Documents reviewed are listed in the Attachment. Theinspectors reviewed the following surveillance tests:r Firewater makeup to isolation condensers inservice test on July 6. Containment spray and emergency service water system 1 pump operability andinservice test on July 12o Standby gas treatment system 1O-hour run - system 1 on August 15. Core spray valve operability and inservice test on September 1b. FindinqsEnclosure

10No findings were identified.Cornerstone: Emergency PreparednesslEPO Drill Evaluation (71114.06 - 1 sample).1 Emerqencv Preparedness Drill Observationa. Inspection ScopeThe inspectors evaluated the conduct of a routine Exelon emergency drill on August 31to identify any weaknesses and deficiencies in the classification, notification, andprotective action recommendation development activities. The inspectors observedemergency response operations in the simulator, technical support center, andemergency operations facility to determine whether the event classification, notifications,and protective action recommendations were performed in accordance with procedures.The inspectors also attended the station drill critique to compare inspector observationswith those identified by Exelon staff in order to evaluate Exelon's critique and to verifywhether the Exelon staff was properly identifying weaknesses and entering them into thecorrective action program. Documents reviewed are listed in the Attachment.b. FindinqsNo findings were identified.2.

RADIATION SAFETY

Cornerstone:

Occupational Radiation Safety [OS]RS07 Radioloqical Environmental Monitorinq Proqram (REMP) (7 1124.07)a. Inspection Scope (1 Sample)The inspectors reviewed Oyster Creek's annual radiological environmental and effluentoperating reports (2009, 2010) and the results of Exelon's assessments to verify that theREMP was implemented in accordance with technical specifications (TS) and the offsitedose calculation manual (ODCM). The inspectors reviewed the report for changes to theODCM with respect to environmental monitoring, commitments in terms of samplinglocations, monitoring and measurement frequencies, land use census, inter-laboratorycomparison program, and analysis of data.The inspectors reviewed the ODCM and associated maps to identify locations ofenvironmental monitoring stations. The inspectors also reviewed the updated finalsafety analysis report (UFSAR) for information regarding the environmental monitoringprogram and meteorological monitoring instrumentation.The inspectors reviewed quality assurance (QA) audit results of the program to assist inselection of samples. The inspectors reviewed available audits and technicalevaluations performed on the vendor's program, as applicable, if used to analyze REMPsamples.Enclosure 11The inspectors reviewed the annual effluent release report and the 10 CFR Part 61 ,"Licensing Requirements for Land Disposal of Radioactive Waste," report, to determine ifExelon was appropriately sampling for the predominant and dose-causing radionuclideslikely to be released in effluents.The inspectors observed the collection and preparation of various environmentalsamples from different environmental media (three particulate and iodine air monitoringstations, one drinking water locations, and one surface water location). Documentsreviewed are listed in the Attachment.Site InspectionThe inspectors walked down and observed sample collection for three air samplingstations (5T-66, ST-72, and ST-73), three thermoluminescent dosimeter (TLD)monitoring stations (5T-66, ST-72, and ST-73), one drinking water station (Station 1 14),and one surface water sample (Station 33) to determine whether the stations werelocated as described in the ODCM. The inspectors also reviewed Exelon gardens (ST66 and ST 35) and reviewed material conditions of monitoring equipment. Consistentwith smart sampling techniques, the inspectors selected air sampling station locationsbased on the locations with the highest X/Q, D/Q wind sectors selected the TLD stationsbased on the most risk-significant locations.The inspectors observed the collection and preparation of various environmentalsamples from different environmental media (three particulate and iodine air monitoringstations, one drinking water locations, and one surface water location). The inspectorsverified that environmental sampling was representative of the release pathways asspecified in the ODCM and that sampling techniques were in accordance with controlledprocedures.For the air samplers and TLDs, the inspectors reviewed the calibration and maintenancerecords/data (orifices, vacuum gauge) to verify that they demonstrate operability of thesecomponents.The inspectors evaluated Exelon's criteria for sampling of other media upon loss of arequired sampling station.Based on direct observation and review of records, the inspectors verified that themeteorological instruments were operable, calibrated, and maintained in accordancewith guidance contained in the FSAR, NRC Regulatory Guide 1.23, "MeteorologicalMonitoring Programs for Nuclear Power Plants," and Exelon procedures. The inspectorsverified that the meteorological data readout and recording instruments in the controlroom and at the tower were operable. The inspectors toured the meteorological towerand reviewed meteorological data readouts, The inspectors compared readouts withcontrol room indications. The inspectors reviewed monthly meteorological monitoringreports.The inspectors verified that missed and or anomalous environmental samples wereidentified and reported in the annual environmental monitoring report. The inspectorsselected events that involved a missed sample, an inoperable sampler, a lost TLD, or ananomalous measurement, and verified that Exelon had identified the cause andimplemented corrective actions. The inspectors reviewed Exelon's assessment of anyEnclosure 12positive sample results (i.e., licensed radioactive material detected above the lower limitsof detection (LLD). The inspectors reviewed the associated radioactive effluent releasedata that was the source of the released material.The inspectors selected structures, systems, or components (SSCs) that involve orcould reasonably involve licensed material for which there is a credible mechanism forlicensed materialto reach groundwater, and verified that Exelon had implemented asampling and monitoring program sufficient to detect leakage of these SSCs togroundwater. The inspectors reviewed the Annual 2010 Radiological Ground WaterProtection Program Report.The inspectors verified that records, as required by 10 CFR 50.75(9), of leaks, spills, andremediation generated since the previous inspection, were being retained in aretrievable manner.The inspectors reviewed any significant changes made by Exelon to the ODCM as theresult of changes to the land use census, long-term meteorological conditions (e.9.,three-year average) or modifications to the sampler stations. The inspectors reviewedtechnicaljustifications for any changed sampling locations. The inspectors verified thatExelon performed the reviews required to ensure that the changes did not affect itsability to monitor the impacts of radioactive effluent releases on the environment.The inspectors verified that appropriate detection sensitivities with respect to TS/ODCMwere used for counting samples (i.e., the samples meet the TS/ODCM required LLDs).The inspectors reviewed quality control charts, as appropriate, for maintaining radiationmeasurement instrument status and actions taken for degrading detector performance,as applicable. For vendor laboratory analysis results for REMP samples, the inspectorsreviewed the results of the vendor's quality control program, including the inter- andintra-laboratory comparison program, to verify the adequacy of the vendor's program.The inspectors reviewed the results of Exelon's inter-laboratory comparison program toverify the adequacy of environmental sample analyses performed by Exelon. Theinspectors verified that the inter-laboratory comparison test included the media/nuclidemix appropriate for the facility. The inspectors reviewed as applicable, Exelon'sdetermination of any bias to the data and the overall effect on the REMP.ldentification and Resolution of ProblemsThe inspectors determined if problems associated with the REMP were being identifiedby Exelon at an appropriate threshold and were properly addressed for resolution in thecorrective action program. In addition to the above, the inspectors verified theappropriateness of the corrective actions for a selected sample of problems documentedby Exelon that involve the REMP.b. FindinqsNo findings were identified.4.

4OA1 Performance lndicator Verification

Enclosure

.113 Reactor Coolant Svstem (RCS) Specific Activitv and RCS Leak Rate (2 samples)Inspection ScopeThe inspectors reviewed Exelon's submittal for the RCS specific activity and RCS leakrate performance indicators for the period of July 1, 2010 and June 30, 2011. Todetermine the accuracy of the performance indicator data reported dudng those periods,the inspectors used definitions and guidance contained in NEI Document 99-02,"Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectorsalso reviewed RCS sample analysis and control room logs of daily measurements forRCS leakage, and compared that information to the data reported by the performanceindicator. Documents reviewed are listed in the Attachment.Inspection FindinqsNo findings were identified.4OA2 Problem ldentification and Resolution (71152 - 1 sample).1 Routine Review of Problem ldentification and Resolution Activitiesa. Inspection ScopeAs required by Inspection Procedure71152, "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.b. FindinqsNo findings were identified.4OA3 Follow-Up of Events (71153 - 3 samples).1 Plant Eventsa. Inspection ScopeFor the plant events listed below, the inspectors reviewed and/or observed plantparameters, reviewed personnel performance, and evaluated performance of mitigatingsystems. The inspectors communicated the plant events to appropriate regionalpersonnel, and compared the event details with criteria contained in IMC 0309, "Reactivelnspection 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 actionsa.b.Enclosure

b.14commensurate with their safety significance. Documents reviewed are listed in theAttachment.. Loss of the B 34.5kV electrical bus on July 28. Declaration of Unusual Event due to seismic activity on August 23. Response to Hurricane lrene during the period August 25-28FindinqsNo findings were identified.Other ActivitiesFollow-up On Traditional Enforcement Actions (lP 92702) (1 sample)Inspection ScopeThe U.S. Nuclear regulatory Commission Office of Investigations completed aninvestigation at Oyster Creek Nuclear Generating Station (OCNGS) on January 14,2010which confirmed that a contract employee, who had unescorted access to vital areas ofthe plant, deliberately failed to report an arrest while employed for Bartlett at OCNGS.The contract employee's action caused Exelon to be in violation of License Condition2.C.(4) of the OCNGS operating license and Section 9.1 of the OCNGS PhysicalSecurity Plan. A severity level lV non-cited violation was issued in investigation report l-2009-047 (ML092580013) on April 12,2Q10. The inspectors reviewed Exelon'scorrective actions, ensured that any generic implications were addressed, and verifiedthat Exelon's programs and practices are adequate to prevent recurrence. Noinadequacies were noted. Documents reviewed are listed in the Attachment.FindinqsNo findings were identified.Independent Spent Fuel Storase Installation (lSFSl) (60855.1)40A5,1b..2a. lnspection Scope (1 Sample)The inspector reviewed routine operational surveillance data, including radiologicalsurveillance, for the ISFSI facility. The inspector toured the facility, reviewed TLDmonitoring data, and made independent radiation measurements. Documents reviewedare listed in the Attachment.b. FindinqsNo findings were identified..3 (Closed) NRC Temporarv Instruction 2515/177 - Manaoinq Gas Accumulation inEmerqencv Core Coolinq. Decav Heat Removal and Containment Sprav Svstemsa. Inspection ScopeEnclosure 15The inspectors performed the inspection in accordance with Temporary Instruction(Tl) 25151177, "Managing Gas Accumulation in Emergency Core Cooling, Decay HeatRemoval and Containment Spray Systems." The NRC staff developed Tl 25151177 tosupport the NRC's confirmatory review of Exelon's responses to NRC Generic Letter(GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay HeatRemoval and Containment Spray Systems." Based on a review of Exelon's GL 2008-01response letters, the Office of Nuclear Reactor Regulation (NRR) staff providedadditional plant specific guidance on inspection scope to the regional inspectors. Theinspectors used this inspection guidance along with the Tl to verify that Exelonimplemented or was in the process of acceptably implementing the commitments,modifications, and programmatically controlled actions described in their GL 2008-01response. The inspectors verified that the plantspecific information (including licensingbasis documents and design information) was consistent with the information thatExelon submitted to the NRC in response to GL 2008-01.The inspectors reviewed a sample of isometric drawings, and piping and instrumentdiagrams, and conducted selected system piping walkdowns to verify that Exelon'sdrawings reflected the subject system configurations and Updated Final Safety AnalysisReport (UFSAR) descriptions. Specifically, the inspectors verified the following relatedto a sample of isometric drawings for the core spray, containment spray, isolationcondenser and shutdown cooling systems:. High point vents were identified;. High points that did not have vents were recognized and evaluated with respect totheir potential for gas buildup;. Other areas where gas could accumulate and potentially impact subject systemoperability, such as orifices in horizontal pipes, isolated branch lines, heatexchangers, improperly sloped piping, and under closed valves, were acceptablyevaluated in engineering reviews or had ultrasonic testing (UT) points which wouldreasonably detect void formation; and,o For piping segments reviewed, branch lines and fittings were clearly shown.The inspectors conducted walkdowns of portions of the above systems to evaluate theacceptability of Exelon's drawings utilized during their review of GL 2008-01. Theinspectors verified that Exelon conducted walkdowns of the applicable systems toconfirm that the combination of system orientation, vents, instructions and procedures,tests, and training, would ensure that each system was sufficiently full of water to ensureoperability, The inspectors reviewed Exelon's methodology used to determine systempiping high points, identification of negative sloped piping, and calculations of void sizesbased on UT equipment readings, to ensure the methods were reasonable. Theinspectors also reviewed engineering analyses associated with the development ofacceptance criteria for as-found voids. The review included engineering assumptions forvoid transport and acceptability of void fractions at the suction and discharge piping ofthe applicable system pumps. In addition, the inspectors verified that Exelon's reviewincluded all emergency core cooling systems, along with supporting systems, withinscope of the GL.Enclosure 16The inspectors reviewed a sample of Exelon's procedures used for filling and venting theassociated GL 2008-01 systems to verify that the procedures were effective in venting orreducing voiding to acceptable levels. The inspectors reviewed a sample of systemventing and UT surveillance results to ensure proper implementation of the surveillanceprogram.The inspectors reviewed corrective action program (CAP) documents to verify thatselected actions described in Exelon's nine month and supplemental submittals wereacceptably documented including completed actions, and implementation schedule forincomplete actions. The inspectors also verified that the NRC commitments in Exelon'ssubmittals were included in the CAP. Additionally, the inspectors reviewed evaluationsand corrective actions for various issues Exelon identified during their GL 2008-01review. The inspectors performed this review to ensure Exelon appropriately evaluatedand adequately addressed any gas voiding concerns. Finally, the inspectors reviewedExelon's training associated with gas accumulation to assess if appropriate training hadbeen provided to the operations and engineering support staff to ensure appropriateawareness of the effects of gas voiding. Documents reviewed are listed in theAttachment.b. FindinqsNo findings were identified. This completes the inspection requirements for Tl 25151177.4OAO Meetinqs. Includinq ExitOn October 17, the inspectors presented the inspection results to Mr. M. Massaro, andother members of the Exelon staff. The inspectors verified that no proprietaryinformation was retained by the inspectors or documented in this report4C.A7 Licensee-ldentified ViolationsNoneATTACHMENT: SUPPLEM ENTARY INFORMATIONEnclosure A-1

SUPPLEMENTARY INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Massaro, Site Vice-President

R. Peak, Plant Manager

D. Dicello, Director, Work Management

M. McKenna, Director, Operations

G. Malone, Director, Engineering

C. Symonds, Director, Training

J. Dostal, Director, Maintenance

J. Barstow, Manager, Regulatory Assurance

T. Keenan, Manager, Security

M. Ford, Manager, Environmental/Chemistry

J. Renda, Manager, Site Radiation Protection

A. Farenga, Manager, Radiological Engineering

D. Chernesky, Assistant Director, Maintenance

R. Skelsky, Senior Manager, Systems Engineering

H. Ray, Senior Manager, Design Engineering

G. Flesher, Shift Operations Superintendent

J. McDaniel, Manager, Nuclear Oversight

M. Rossi, RequalTraining Lead

M. Seeloff, Manager, Corrective Action Program

J. Chrisley, Regulatory Assurance Specialist

J. Kerr, Regulatory Assurance Specialist

K. Wolf, Radiation Protection Support Manager

M. Nixon, Chemistry Supervisor

D. Moore, Regulatory Assurance Specialist

J. McCarthy, Radiological Engineer

K. Martin, Project Manager, lFSl

S. Schwartz, Design EngineerOthers:State of New Jersey, Bureau of Nuclear Engineering

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/ClosedNoneOpenedNoneClosedNoneAttachment

A-2

Section 1R01: Adverse Weather ProtectionProceduresOP-OC-108-109-1001, Preparation for Severe Weather T&RM for Oyster Creek, Revision 1 1OP-AA-108-1 1

1-1001 , Severe Weather and Natural Disaster Guidelines, Revision 6WC-AA-107, Seasonal Readiness, Revision 9OP-OC-108-1001, Preparation for Severe Weather T&RN for Oyster Creek, Revision 1OP-OC-108-109-1002, Cold Weather Freeze Inspection, Revision 4ABN-31, High Winds, Revision 15ABN-32, Abnormal Intake Level, Revision 18Condition Reports (lR)1256245

1255744

1256409 1256421

==Section 1R04: Equipment AlignmentProcedures310, Containment Spray System Operation, Revision

102307, lsolation Condenser System, Revision 103DrawinqsG8148F740, Containment Spray System Flow DiagramGE148F262, Emergency Condenser Flow DiagramGE885D781, Core Spray System Flow DiagramBR 2005, Reactor & Turbine Building Service Water System Flow DiagramSection 1R05: Fire ProtectionProceduresABN-29, Plant Fires, Revision 26101.2, Oyster Creek Site Fire Protection Program, Revision 67CC-AA-211, Fire Protection Program, Revision 4333, Plant Fire Protection System, Revision 106OP-AA-201-010-1001, 8.5.8 Mitigating Strategies Equipment Expectations, Revision 0MiscellaneousOyster Creek Generating Station Pre-Fire Plan:Northeast Corner RoomOyster Creek Generating Station Pre-Fire Plan:Oyster Creek Generating Station Pre-Fire Plan:Oyster Creek Generating Station Pre-Fire Plan:RoomOyster Creek Generating Station Pre-Fire Plan:Elevation)Oyster Creek Generating Station Pre-Fire Plan:Guest Trolling Charger Series Owner's Manual,RB-FZ-1F4, Reactor Building (-19' Elevation)NW-FA-23, New WarehouseOB-FZ-68, 480V Switchgear Room "8"OB-FZ-8C, A and B Battery Room, Electric TrayTB-FZ-11A, Turbine Operating Floor (46'-0"RB-FA-2, Reactor Building (Drywell and Torus)On Board Battery ChargersAttachment==

A-3

==Section 1R06: Flood Protection MeasuresCondition Reports (lR)813797

813958

810465

821411

1240067 852471201634

1184058

1105157 427972Work Orders (AR)R2095953 C2018682MiscellaneousInformation Notice 2005-30, Safe Shutdown Potentiatty Challenged by Unanalyzed lnternalFlooding Events and Inadequate DesignC-1302-822-E610-076, Flooding Due to==

HELB Outside Containment28063-005, Design and Licensing Bases for Flooding at OCGSOCGS Internal Flood Evaluation Summary and Notebook

Section 1Rl1: Licensed Operator Requalification ProqramMiscellaneousEOP User's Guide (2000-BAS -3200.02)2612.CREW.1

1-5.01Section 1 R12: Maintenance EffectivenessProceduresER-AA-310, lmplementation of Maintenance Rule, Revision 8ER-AA-310-1005, Maintenance Rule - Disposition Between (a)(1) and (a)(2) , Revision 5LS

AA-125-1003, Apparent Cause Evaluation Manual, Revision 9CC-AA-309-1012, 10 CFR Part 21 Technical Evaluations, Revision 2Condition Reoorts (lR)1193928

985629

874285

983355

1208455 1193928618930

1178900

932736

879452

1247448 12129221055456

1206399 1055456MiscellaneousNEI 93-01, Industry Guideline for monitoring the Effectiveness of Maintenance at Nuclear PowerPlantsC-1302-241-5450-073, Acceptable Containment Spray Heat Exchanger Fouling ResistanceC-1302-241-E610-080, Calculation of Torus Pool Temperature for NPSH and to DetermineContainment Spray System Design Basis Requirements, Revision 4TDR 993, Evaluation of Containment Spray/ESW Performance at Elevated Intake TemperatureNRC lnformation Notice20QT-40,Inadequate lmplementation of 10 CFR Part21 Requirementsby Vendors who Supply Basic Components to Nuclear Power Plant Licensees

Section 1R13: Maintenance Risk Assessments and Emergent Work ControlProceduresER-AA-600-1042, On-line Risk Management, Revision 7ER-AA-600-1021, Risk Management Application Methodologies, Revision 4ER-AA-600-1014, Risk Management Configuration Control, Revision 6Attachment

A-4ER-AA-600-1011, Risk Management Program, Revision 9WC-OC-101-100'1, On-line Risk Management and Assessment, Revision 8ABN-60, Grid Emergency, Revision 9Condition Report (lR)1268453Section 1 R15: Operabllitv EvaluationsProceduresOP-AA-108-1 15, Operability Determination, Revision 10101.2, Oyster Creek Site Fire Protection Program, Revision 67413, Operation of the Safety valve/EMRV Acoustic Monitoring System, Revision 19602.3.008, Main Steam Line Safety/ EMRV Acoustic VMS Test, Revision 29Condition Reports (lR)1239504 1057101Work Orders (AR)A2112538

42248892 C2020245A2276012 A2283257MiscellaneousNRC Inspection Manual - Part 9900 Technical Guidance, Operability Determinations &Functionality Assessments for Resolution of Degraded or Nonconforming ConditionsAdverse to Quality or Safety2611-PGD-2621, Nuclear Plant Operator Initial Training Course, Fire Protection ProgramNFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2000 edition990-1746, Oyster Creek Nuclear Generating Station Fire Hazards Analysis ReportC-1302-730-5350-017, Stroke Time Calculation for

GL 89-10 MOVsSE-328212-003,

GL 89-10 Motor Operated Valve ModificationOyster Creek Generating Station UFSAR, Table 6.3-1, lsolation Condenser SystemComponentsASME OM Code-1995, Code for Operation and Maintenance of Nuclear Power Plants,Subsection ISTC, Inservice Testing of Valves in LighfWater Reactor Power PlantsOyster Creek Generating Station Pre-Fire Plan:

TB-FA-3A/38, 4160V C & D Vaults

Section 1R19: Post-Maintenance TestinqProceduresMA-AA-71

6-012, Post Maintenance Testing, Revision 15OP-MA-109-101, Clearance and Tagging, Revision 12645.4.001, Fire Pump #1 Operability Test, Revision 65645.4.018, Fire Pump Monitoring Test, Revision 62636.4.013, Diesel Generator #2Load Test, Revision 36641.4.001, Service Water Pump Operability and In-Service Test, Revision 70Condition Report (lR)1244421 76195412593431250414 7619541252766 12656241250988

1250909

1250917 1259347Attachment

A-5Work Order (AR)c2026219 A2283257

C2025687 A2276012

42236563 R2148297R2169826 R2180110 R2143612 R2187785MiscellaneousC-1302-730-5350-017, Stroke Time Calculations for the

GL 89-10 MOVsSE-315403-032, Justification for lC AC Condensate Valves Revised Open Area

Section 1R22: Surveillance TestinqProceduresSA-AA-129, Electrical Safety, Revision 7MA-AA-1000, Conduct of Maintenance, Revision 14609.4.007, Fire Water Makeup to lsolation Condensers In-Service Test, Revision 19607.4.014, Containment Spray and

ESW System 1 Pump Operability, IST and ContainmentSpray Pumps Trip, Revision 37610.4.003, Core Spray Valve Operability and In-Service Test, Revision 40651 .4.002, Standby Gas Treatment System 1O-Hour Run - System 1 , Revision 5Condition Reports (lR)1236410

1240072 1099012Work Orders (AR)R2183971 A2280062MiscellaneousR2165849 R2186029 R2186125NRC Inspection Manual Part 9900 Technical Guidance, Maintenance- Preconditioning ofStructures, Systems, and Components Before Determining OperabilityOyster Creek UFSAR Section 6.2.2, Containment Heat Removal System

==Section 1EP6: Drill EvaluationProceduresEP-AA-1010, Radiological Emergency Plan Annex for Oyster Creek Station, Revision 3Condition Reports1258579

1258580

1258577

1258397

1258396 1258394MiscellaneousOyster Creek 2011 Pre-Exercise Evaluation Report, dated 912512011Section==

RS07 Radioloqical Environmental Monitoring ProqramProceduresCY-AA-170-000, Radioactive Effluent and Environmental Monitoring Program, Revision 4CY-AA-1 70-1 00, Radiological Environmental Monitoring Program, Revision 2CY-AA-170-200, Radioactive Effluent Control Program, Revision 1CY-AA-130-201, Radiochemistry Quality Control, Revision 0CY-AA-170-300, Offsite Dose Calculation Manual Administration, Revision 2CY-AA-1 70-1 000, Radiological Environmental Monitoring Program and MeteorologicalProgram lmplementation, Revision 5Attachment

A-6CY-AA-170-1100, Quality Assurance for Radiological Monitoring Program, Revision 1CY-OC-120-1200, REMP sample Collection - Well Water, Revision 1CY-AA-170-2000, Annual Radioactive Effluent Release Report, Revision 5CY-OC-170-2001, Quality Control for Radioactive Effluents, Revision 0CY-AA-170-2300, Determination of Carbon 14 in Gaseous Effluents, Revision 0CY-AA-170-3100, Offsite Dose Calculation Manual Revision, Revision 3EN-AA-408, Radiological Ground water Protection Program, Revision 0EN-AA-408-4000, Radiological Ground Water Protection Program lmplementation, Revision 0Work Orders (AR)41 06881 3MiscellaneousOrifice Calibration data -

269341 1,

269341 3, 2693421Meteorological Data Summary (2000-2009)Annual Metrological Monitoring Report 2010NUPIC CGI Audit, March 2011Annual Report TB Engineering Environmental Service (January-December 2010)10

CFR 50.75(9) fileCheck-in Self-Assessments2010 Land Use CensusAn nual Rad iolog ical Envi ronmental, Effluent Release Reports- 2009, 20 1 QQuality Assurance Confirmatory Testing of Environmental TLDsSection 4OAl : Performance Indicator VerificationProceduresLS-AA-2001, Collecting and Reporting of NRC Performance Indicator Data, Revision 14MiscellaneousReactor coolant chemistry logs, dated July 2010 through June 2011Drywell identified and unidentified leak rate logs, dated July 2010 through June 201 1Oyster Creek Performance Indicator Summary dated 712012011NEI 99-02, Regulatory Assessment Performance Indicator GuidelineNEI 99-02 Frequently Asked Question Archive, dated 10113110

Section 4OA2: . Problem ldentification and ResolutionMiscellaneousCheck-in AssessmentsANI Assessment, March 2011Audit

SR-2011-009, February 2011, NUPIC Audit (Teledyne Brown)DOE MAPEPTeledyne Brown Engineering Quarterly Reports

Section 4OA3: Followup of EventsProceduresABN-21, Radwaste Service Water Failure, Revision 5ABN-22,

AOG Building Loss of Power, Revision 7ABN-52, Loss of USS 1E1, Revision 5Attachment

A-7ABN-56, Loss of the J69361 North Yard Distribution System, Revision 5ABN-57, Loss of Site Emergency Building Power and/or the Plant Process Computer systemUPS, Revision 8ABN-38, Station Seismic Event, Revision 11ABN-31, High Winds, Revision 15ABN-32, Abnormal lntake Level, Revision 18OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Revision 6OP-OC-108-109-1001, Preparation for Severe Weather T&RM for Oyster Creek, Revision 1 1Condition Reports (lR)1245786

1246235

1245329 12452931256421

1256445

1256245 12563491243571 12564091254651 12576751257893MiscellaneousNUREG-1022,Event Reporting Guidelines 10

CFR 50.72 and 50.73ENS Notification 47107, Offsite Notification Due to Fish Kill EventENS Notification 47188, Notification of an Unusual Event due to a Seismic EventOyster Creek UFSAR, Figure 8.2-3,34.5 kV Substation - One Line DiagramOyster Creek Operations Logs, dated 7128 and 7129Oyster Creek Operations Logs, dated 8/23Oyster Creek Operations Logs, dated 8127, 8128 and 8129

==Section 4OA5: Other ActivitiesProceduresSY-AA-103-513, Behavioral Observation Program, Revision 8305, Shutdown Cooling System Operation, Revision

107307, lsolation CondenserSystem, Revision

113308, Emergency Core Cooling System Operation, Revision 89310, Containment Spray System Operation, Revision 102Drawinos3E-214-A2-1000, Sht.4, lSl Configuration Drawing Shutdown Cooling System, Revision 3GE 148F262, Emergency Condenser, Revision 53GE 148F740, Containment Spray System, Revision 43GE148F711, Shutdown Cooling System, Revision 44GE885D781, Core Spray System Flow Diagram, Revision 72JCP-19433, Shts.==

1-6, lsolation Condenser System, Revs. 2, 3, 3, 4, 3, and 2JCP-19434, Shts. 1-3, Shutdown Cooling System, Revs.2,3 and 5JCP-19436, Shts. 1-11, Containment Spray System, Revs. 3,2,2,2,2,2,2,2,2,2, and 2JCP-19440, Shts. 1-11, Core Spray System, Revs. 2,3,2,2,2,2,2,2,2,2, and 2Condition Reoorts (lR)9547651263536

1240313

1228883

1236753 12391201239386 1239094Work OrdersR2169237 R2170284Attachment

A-8MiscellaneousSupervisory Brief, lmportant Security lnformation, dated 6117111Nuclear General Employee Study Guide, dated 3131l1ONRC Letter lA-2010-009, NRC lnvestigation Report No. l-2009-047, dated 4112110NRC Letter

EA-2010-007, NRC Investigation Report No. l-2009-047, dated

4112110,(M1101030075)Security Incident Report number 2009-141VPF 1259-18-1 , lnstructions for lnstallation, Operation and Maintenance of Heat Exchangers,Revision 0LS-AA-1 26-1 005, Managing Gas Accumulation Self-Assessment, dated 7 l 1 5l I 1EAS-57-0989, Design Basis Document for Containment Spray System, Revision 5Letter from K. R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC)toUSNRC, "Three Month Response to Generic Letter 2008-01," dated 4111108Letter from K. R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) toUSNRC, "Nine-Month Response to

GL 2008-01," dated 10114108Letter from P. R. Simpson (Exelon Generation Company, LLC) to USNRC, "Response toRequest for Additional Information Regarding Generic Letter 2008-01," dated 1128110Letter from P. R. Simpson (Exelon Generation Company, LLC/AmerGen Energy Company,LLC) to USNRC, "Supplemental Response to Generic Letter 2008-01," dated 1120109Oyster Creek Nuclear Generating Station - Technical Specifications, Amendment 280Oyster Creek Nuclear Generating Station Updated Final Safety Analysis Report, Revision 16SDBD-OC-212-A, Design Basis Document for Low Pressure Core Spray System, Revision 3GENE-813-01805-77, Evaluation of Condensation-lnduced Water Hammer for Core Spray Lineof Oyster Creek Nuclear Generating Station, dated 9/1996NRC

GL 2008-01 Containment Spray System Evaluation, dated 8/19/08NRC

GL 2008-01 lsolation Condenser Evaluation, dated 8/19/08NRC

GL 2008-01 Shutdown Cooling System Evaluation, dated 8/19/08NRC

GL 2008-01 Core Spray System Evaluation, dated 8120108NRC

GL 2008-01 Venting and Gas Accumulation Evaluations for ECCS, Revision 0Attachment

ADMBCOBVPSCAPCFRCRFAFENOCrMcroDIPrslLCOLERMRMSPNEINRCODODCMOSTPIPI&RPODPMTREMPSSCSWSTLDTSUFSARA-9

LIST OF ACRONYMS

Ad m i nistrative Proced ureBasis for Continued OperationsBeaver Valley Power StationCorrective Action ProgramCode of Federal RegulationsCondition Report(s)Functionality AssessmentsFirst Energy Nuclear Operating Companylnspection Manual Chapterlmmediate Operability DeterminationInspection ProcedureInservice lnspectionLimiting Conditions for OperationsLicensee Event ReportMaintenance RuleMaintenance Surveillance PackageNuclear Energy InstituteNuclear Regulatory CommissionOperability DeterminationsOff-Site Dose Calculation ManualOperations Surveillance TestPerformance lndicatorProblem ldentification and ResolutionPrompt Operability DeterminationPost Maintenance TestingRadiological Environmental Monitoring Prog ramStructures, Systems, and ComponentsService Water SystemThermo-Luminescent DosimeterTechnical SpecificationUpdated Final Safety Analysis ReportAttachment