IR 05000219/2010005

IR 05000219-10-005, on 10/01/10 - 12/31/10, Exelon Energy Company, LLC, Oyster Creek Generating Station, Maintenance Effectiveness, Event Followup

ML110390509
Person / Time
Site:	Oyster Creek
Issue date:	02/08/2011
From:	Bellamy R R NRC/RGN-I/DRP/PB6
To:	Pacilio M J Exelon Nuclear
BELLAMY RR
References
IR-10-005
Download: ML110390509 (64)

Text

and the NRCResident Inspector at oysier creek Generating station.-ln addition, if you disagree with thecharacterization of any finding in this report, you should provide a response within 30 days ofthe date of this inspection report, with the baiis for your'oirrgr"ement, to the RegionalAdministrator, Region l, and the NRC Resident lnsdectoi a1 oyster creek Generating Station.I$;

"ttation you provide will be considered in iccoroance witn Inspection Manuat chapter In accordance with 10 CFR 2.390 of the NRC's "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 ofNRC's document system (ADAMS). ADAMS is accessible from the NRC Website athttp:i/wwl.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).We appreciate your cooperation. Please contact me at (610) 337-5232 if you have anyquestions regarding this letter.

Sincerely,Ronald R. Bellamy, Ph.D., ChiefProjects Branch 6Division of Reactor ProjectsDocket No. 50-219License No. DPR-16

Enclosure:

Inspection Report05000219/20'10005

w/Attachment:

Supplemental Informationcc w/encls: Distribution via ListServ

SUMMARY OF FINDINGS

lR 05000219/2010005;101112010 - 1213112010; Exelon Energy Company, LLC, Oyster CreekGenerating Station; Maintenance Effectiveness, Event Followup.The report covered a 3-month period of inspection by resident inspectors, a regional projectengineer, and regional specialist inspectors. Three Green non-cited violations (NCV) wereidentified. The significance of most findings is indicated by their color (Green, White, Yellow, orRed) using Inspection Manual Chapter (lMC) 0609, "Significance Determination Process"(SDP). The cross-cutting aspects were determined using tMC 0310, "Components Within theCross Component Areas." Findings for which the SDP does not apply may be Green or beassigned a severity level after NRC management review. The NRC's program for overseeingthe safe operation of commercial nuclear power reactors is described in NUREG-1649, "ReactorOversight Process," Revision 4, dated December 2006.Gornerstone: Initiating EventGreen: A Green, self-revealing NCV of Technical Specification (TS) 6.8.1.a occurredwhen Exelon did not adequately implement plant startup procedures which resulted in anautomatic reactor scram. lmmediate corrective actions included just in time training withall reactor operators, increased management oversight during the subsequent startup,and procedural changes to list all alarms by name that must be cleared prior to raisingreactor pressure above 500 psig. Exelon is performing a full root cause evaluation onthe event (lR 1 155520).The inspectors determined that the performance deficiency was similar to the "not minorif'statement contained in example 4b of IMC 0612, Appendix E, "Examples of Minorlssues," because the performance issue resulted in a manual reactor scram. The findingwas more than minor in accordance with IMC 0612, Appendix B, "lssue Screening,"because it was associated with the equipment performance attribute of the initiatingevents cornerstone and atfected the objective to limit the likelihood of those events thatupset plant stability and challenge critical safety functions during power operation. Inaccordance with IMC 0609.04 (Table 4a), "Phase 1 - Initial Screen and Characterizationof Findings," the finding was determined to be of very low safety significance (Green)because the finding did not contribute to both the likelihood of a reactor trip and thelikelihood that mitigation equipment or functions would not be available. This finding hasa cross-cutting aspect in the area of human performance, work practices (H.4(b)), wherepersonnef work practices support human performance, specifically, Exelon defines andetfectively communicates expectations regarding procedural compliance and personnelfollow procedures. On December 23, operators did not verify that condenser vacuumwas adequate prior to raising reactor pressure above 500 psig, contrary to establishedprocedural guidance. (Section 4OA3)Gornerstone: Mitigating SystemsGreen: AGreen, inspectoridentifiedNCVof TS4.5.M.1.f, "SnubberServiceLifeMonitoring", was identified while inspecting four snubber testing failures that occurredduring refueling outage 1R23. Specifically, Exelon's snubber testing program, containedin SP-1302-52-O4S, "Requirements for Functional Testing of Snubbers", does notEnclosure 4evaluate snubber maintenance and test records to identify common cause failures ofsnubbers due to environmental (temperature, vibration, humidity) conditions and adjustsnubber service life expectations accordingly, such that snubber service life reviews canbe accomplished effectively without service life affecting reactor operations. Exelon tookimmediate corrective action to repair or replace the failed snubbers, performed ananalysis to ensure the snubber failures had no impact on system operation, and enteredthis issue into their corrective action program (1R1138622, lR1139897, lR1143332,rR1143829)There are no similar examples in IMC 0612, Appendix E, "Examples of Minor lssues".This finding is more than minor because it affects the equipment performance attribute ofthe mitigating systems cornerstone to ensure the availability, reliability and capability ofsystem that respond to initiating events to prevent undesirable consequences,specifically the safety related piping systems in containment. ln accordance with Table4a of IMC 0609.04, "Phase 1 - Initial Screening and Characterization of Findings," thefinding was determined to be of very low safety significance (Green) because it was aqualification deficiency confirmed not to result in loss of operability or functionality. Thisfinding has a cross-cutting aspect in the area of problem identification and resolution(P.1(c)) because Exelon did not thoroughly evaluate problems such that the resolutionsaddress causes and extent of conditions. Additionally, Exelon did not conducteffectiveness reviews of corrective actions to ensure that the problems are resolved.(Section 1R12)

Cornerstone: Public Radiation Safety

Green: A Green, self-revealing NCV of TS 6.8.4 occurred due to Exelon's failure tomaintain continuous, representative monitoring and sampling of plant stack gaseouseffluents, as required by the Offsite Dose Calculation Manual. The cause wasdegradation of sample line integrity over the period March 2006 through March 2010.Exelon reported the issue, initiated compensatory monitoring, repaired the stack sampletubing, conducted bounding dose calculations, and entered this issue, including theevaluation of extent-of-condition, into the conective action program (lR 01053577).This finding is more than minor because the performance deficiency adversely impactedthe Public Cornerstone objective of ensuring adequate protection of public health andsafety in that effluent releases were not fully monitored in accordance with applicablerequirements to ensure proper quantification and characterization of radioactivereleases. This finding was assessed for significance using IMC 0609, Appendix D, anddetermined to be of very low safety significance because: Exelon was able to re-assessthe radioactive effluent using alternative radiation monitoring instrumentation andprograms, therefore Exelon had data by which to assess dose to a member of the public,determine the dose impact to the public, and conclude that the doses were less than thedose values in Appendix I to 10 CFR Part 50 and/or 10 CFR 20J301(e). This findinghas a cross-cutting aspect in the area of Human Performance, Resources (H.2(c))because procedures were not sufficiently robust for review of reasonableness andconsistency of data from samples to support identification of the issue in a timelymanner. (Section 4OA3)

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REPORT DETAILS

Summarv of Plant StatusThe Oyster Creek Generating Station (Oyster Creek) began the inspection period operating atfull power.On October 31, operators commenced a planned shutdown and started the

==1R23 refuelingoutage. The plant returned to power generation on December 1.On December 2, operators performed an unplanned downpower from 35% to 2oo/o reaclorpower due to indications of an internal fault on the M1B transformer. Operators took thegenerator of1ine and started the 1F23 forced outage to electrically disconnect the M1Biransformer. The operators placed the generator online and returned to 50% power onDecember 4 after disconnecting the M1B transformer.On December 9th, operators performed a planned downpower to 20o/o reactor power, took thegenerator offline and' started in" fzqforced outage to replace the M1B transformer with an6nsite spare. The operators placed the generator online and returned to 50% power onDecember 12, after placing the spare M1B transformer on its storage pad.On December 15, operators performed a planned downpower to 20% reactor power, took thegenerator offline and started ine t rzs forced outage to electrically reconnect the M1Btransformer with an onsite spare. The operators placed the generator online and returned to fullpower on December 17.On December 18, operators responded to a trip of the "A" reactor recirculation pump wlt_chresulted in an unplanned downpower. Exelon chose to remain at 55% power while 2 of 5reactor recirculation pumps were unavailable.On December 19, operators commenced an unplanned shutdown and started the 1F26 forcedoutage to repair the "8" reactor recirculation pump mechanical seal. Operators commenced a,ercior startup on Decemb er 23. While heating up the plant following reactor startup, anautomatic scram occurred. The automatic scrim ls discussed in detail in section

4OA3 of thisreport. Operators performed another reactor startup on December 24 and returned to full poweron December 25.Oyster Creek operated at 100% (full) power for the remainder of the inspection period'1. REACTOR SAFEWGornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity1R01 Adverse Weather Protection

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a. lnspection ScoPe (1 samPle)The inspectors peformed one adverse weather preparation inspection'Enclosure 6The inspectors reviewed Exelon's activities associated with seasonal readiness for coldweather conditions. The inspectors reviewed the updated final safety analysis report(UFSAR) to identify risk significant systems that require protection from cold weatherconditions. The inspectors performed a walkdown of the intake structure, the heattracing of outdoor components including temporary water storage tanks, and theemergency diesel generators. The inspectors reviewed Exelon's cold weatherpreparation activities to assess their adequacy and to verify they were completed inaccordance with procedural requirements. The inspectors also reviewed applicablecorrective action program condition reports to assess their reliability and materialcondition of their systems.Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.b. FindinqsNo findings were identified.

1R04 EquipmentAlignment (71111.04)a. Inspection Scope (4 samples)The inspectors performed 3 partial and 1 complete equipment alignment inspections.The partialequipment alignment inspections were completed during conditions when theequipment was of increased safety significance such as would occur when redundantequipment was unavailable during maintenance or adverse conditions, or afterequipment was recently returned to service after maintenance. The inspectorsperformed a partial walkdown of the following systems, and when applicable, theassociated electrical distribution components and control room panels, to verify theequipment was aligned to perform its intended safety functions:r 'A' Containment Spray system on November 29 and November 30 after the systemwas returned to service following the 1R23 refueling outage;. 'A' and 'B' lsolation Condenser system on December 6 after the equipment wasreturned to service following the 1R23 refueling outage; ando 'A' control rod drive system on December 30 following planned maintenance on the Bcontrol rod drive system.The inspectors performed a complete system alignment inspection on the standby liquidcontrol (SLC) system on November 29 and 30 after it was returned to service followingthe 1R23 refueling outage to determine whether the system was aligned and capable ofproviding a backup method of shutting down the reactor in accordance with design basisrequirements. The inspectors reviewed operating procedures, the surveillance testprocedure, piping and instrument drawings, and the applicable equipment lineup list, todetermine if the equipment was aligned to perform its safety function upon actuation.Documents reviewed for this inspection activity are listed in the Supplementallnformation attachment to this report.Enclosure

b.7FindinosNo findings were identified.Fire Protection (71111.05)lnspection Scope (71111.05Q - 3 samples)The inspectors performed a walkdown of three plant areas to assess their vulnerability tofire. During plant walkdowns, the inspectors observed combustible material control, firedetection and suppression equipment availability, visible fire barrier configuration, and theadequacy of compensatory measures (when applicable). The inspectors reviewed"Oyster Creek Fire Hazards Analysis Report" and "Oyster Creek Pre-Fire Plans" for riskinsights and design features credited in these areas. Additionally, the inspectorsreviewed corrective action program condition reports documenting fire protectiondeficiencies to verify that identified problems were being evaluated and corrected.Documents reviewed for this inspection activity are listed in the Supplemental lnformationattachment to this report. The following plant areas were inspected:. Demineralizer Tanks and Steam Jet Air Ejector Area (TB-FZ-11H) on November 16;o Emergency Diesel Generator Room #1 (DG-FA-15) on November 18; ando Emergency Diesel Generator Room #2 (DG-FA-17) on November 18.1

==R05 a.b. FindinosNo findings were identified.

1R08 Inservice Inspection (lSl) Activities

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a. Inspection 9cope (71 11 1.08 - 1 Sample)The inspectors selected samples for inspection based upon the guidance in lnspectionProcedure 71111.08 and the risk priority of those components and systems wheredegradation could result in a significant increase in the risk of core damage. Theobservations and documentation reviews were conducted to verify that inspectionactivities are being performed in accordance with the American Society of MechanicalEngineers (ASME) Boiler, and Pressure Vessel Code requirements.Drvwell Sandbed Bav Visual (W) and Ultrasonic (UT) InspectionsThe inspectors reviewed the Exelon procedures for performing drywell ultrasonic (UT)wall thickness measurements and for performing visual inspection (VT) of the drywellprotective coating in the sandbed regions. The inspectors observed Exelon performthese inspections in sandbed bays #1, #3 and #11. The inspectors also reviewed thecompleted inspection reports (both UT and W) for sandbed bays #1, #3, #5, #7 , #9,#11, #13, #15, #17 and #19. The inspectors verified that Exelon successfully completedthe planned inspections, documented the observed conditions, analyzed and evaluatedthe conditions identified and entered all conditions into the corrective action process forfollow up and resolution.Enclosure IDissimilar Metal Weld lnspectionsDuring this refueling outage, the inspectors reviewed Exelon's conduct of automated,phased-array, ultrasonic examinations of four reactor vessel nozzle dissimilar metalwelds in accordance with Boiling Water Reactor Vessel Internals Project (BWRVIP)inspection requirements. The inspectors determined that Exelon had conducted adetailed review of pre-1R23 performance demonstration initiative (PDl) ultrasonicinspection data to determine whether any significant weld indications had existed thatwere undetected by prior inspections. The inspectors verified that Exelon's detailedreview, conducted in 2008, did not reveal any significant defect indications.The inspectors verified that the inspections completed during the November 2010refueling outage met the requirements of the ASME Boiler and Pressure Vessel Code,Section Xl, Amendment lll, Supplement 10. The inspectors reviewed the proceduresused in these inspections, verified the process qualification documentation, and remotelyobserved the collection of inspection data by Exelon personnel. Upon completion ofthese inspections, the inspectors reviewed a sample of the inspection data sheets.Additional Non-Destructive Examination (NDE) SamplesThe inspectors verified that NDE activities were performed in accordance with the ASMEBoiler and Pressure Vessel Code, Section Xl, by reviewing inspection procedures,personnel NDE documentation, and by direct observation and data report reviews. Theinspectors reviewed the completed inspection reports (data sheets) from six primarysystem ultrasonic weld inspections, one dye penetrant examination, and 1 radiographicexamination of a core spray piping weld replacement.The inspectors reviewed a sample of the in-reactor vessel visual inspection (lwl)indications recorded from Exelon's visual inspection of the reactor steam dryer. Theinspectors verified that Exelon's inspection results documented no change in the priorsteam dryer indications during the past operating cycle. The inspectors reviewedcondition reports which reported indications discovered as a result of visual inspection ofthe steam dryer and evaluated the reported conditions as acceptable for use "as-is" forcontinued operation with re-inspection during the next refueling outage. The inspectorsassessed Exelon's evaluation and disposition for continued service without repair ofthese non-conforming conditions identified during lSl activities.The inspectors reviewed a sample of the ultrasonic examination personnel certificationsand reviewed the NDE qualifications for the technicians responsible for the datacollection, review and interpretation of the inspection results. This review wasconducted to confirm that the examiner skill, the test equipment capabilities, theexamination techniques used, and the examination procedures enabled the performanceof the ultrasonic and visual examination of the selected components. The inspectorsverified that the manual and automatic remote ultrasonic examinations met therequirements of ASME Section Xl.ASME. Section Xl Repair Replacement SamplesThe inspectors reviewed work order (WO) C2023465, which controlled the replacementof the internals of valve V-2-73 as specified by engineering change request (ECR) 09-00499. The inspectors verified that the work and the post repair NDE (VT-3 of the valveEnclosure Ibody and W-1 of all bolting materials) were completed in accordance with ASME CodeCase N-416-3,The inspectors also reviewed WO C2023712 which accomplished the replacement of asection of core spray piping. With respect to this work order, the inspectors reviewed:AR01076164, which reported two areas of core spray pipe wall thinning which waseroded below minimum wallthickness; inspection results reported via NER-NC-09-035Y;and the technical evaluation (AR01076164-03) which recommended replacement of theaffected piping during the November 2010 refueling outage. The inspectors reviewedthe welding process for the replacement of the core spray pipe and the NDE (magneticparticle testing (MT) during the welding process and radiographic testing (RT) of thecompleted weld) used to inspect the repair. The final RT was accomplished with eightRT films. One of the films showed evidence of incomplete weld fusion. The inspectorsreviewed the issue report (lR 1144878) which evaluated this condition and specifiedexcavation of the affected area and re-welding and post-repair RT. Upon repair of theweld, the inspectors verified acceptable RT results. The inspectors verified thecompletion of this replacement after reviewing the acceptance by Exelon and theAuthorized Nuclear Inspector.b. FindinqsNo findings were identified.1R1 1 Licensed Operator Requalificatig! Prooram (71111.11)a. Inspection Scops (1 sample)The inspectors observed one simulator training scenario on October 6 to assessoperator performance and training effectiveness. The inspectors observed trainingscenario 2612.CREW10-6.01. The inspectors assessed whether the simulatoradequately reflected the expected plant response, operator performance met Exelon'sprocedural requirements, and the simulator instructor's critique identified crewperformance problems. Documents reviewed for this inspection activity are listed in theSupplemental Information attachment to this report.b. FindinqsNo findings were identified.

1R12 Maintenance Effectiveness (71111

.12 )a. lnspection Scope (2 samples)The inspectors performed two maintenance effectiveness inspection activities. Theinspectors reviewed the following degraded equipment issues in order to assess theeffectiveness of maintenance by Exelon:o Main steam isolation valves (lR 1 1 37357 and 1 138356) on November 10; and. Adverse trend on snubbers (lR 1139909) on December 29.Enclosure

b.10The inspectors also verified that the systems or components were being monitored inaccordance with Exelon's maintenance rule program requirements. The inspectorscompared documented functionalfailure determinations and unavailable hours to thosebeing tracked by Exelon. The inspectors reviewed completed maintenance work ordersand procedures to determine if inadequate maintenance contributed to equipmentperformance issues. The inspectors also reviewed applicable work orders, correctiveaction program condition reports, operator narrative logs, and vendor manuals.Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.Findinqslntroduction: The inspectors identified a Green NCV of TS 4.5.M.1.f, "Snubber ServiceLife Monitoring", while inspecting 4 snubber testing failures that occurred during 1R23.Specifically, Exelon's snubber testing program, contained in SP-1302-52-045,"Requirements for Functional Testing of Snubbers", does not evaluate snubbermaintenance and test records to identify common cause failures of snubbers due toenvironmental (temperature, vibration, humidity) conditions and adjust snubber servicelife expectations accordingly so snubber service life reviews can be accomplishedeffectively without service life affecting reactor operations.Description:During 1R23, Exelon experienced functional failures on a total of four safety relatedmechanical snubbers during the TS required functional tests, specifically, the runningdrag test. The four snubber functional failures were entered into the corrective actionprogram in lRs 1138622,1139897, 1143332 and 1143829. TS 4.5.M.1.c, "FunctionalTests", states that at least every 24 months, a representative sample (defined as 10o/o ofthe total of each type of snubber in use at the plant) shall be functionally tested either inplace or in a bench test. TS 4.5.M.1.c further states: for each snubber that does notmeet the functional test criteria, an additional 10% of that type of snubber shall befunctionally tested. In accordance with TS 4.5.M.1.c, the four functional failures causeExelon to expand their inspection scope and an additional 40o/o of the installedmechanical snubbers be tested. The apparent cause of the failures for all four snubberswas either hardened or missing grease. The snubbers were either repaired or replacedwith new snubbers and reinstalled into the appropriate piping supports. For each failedsnubber, Exelon performed engineering evaluations to determine if the failed snubberhad adverse affects on the attached piping systems. No adverse effects were identifiedthat would have affected reactor operations.TS 4.5.M.1.f, "snubber Service Life Monitoring", states, in part, that records of theservice life of each snubber shall be maintained, to include the date at which thedesignated service life commences, the date of installation, and the maintenancerecords on which the designated service life is based. TS 4.5.M.1.f also requires thatthe installation and maintenance records be reviewed on a 24 month basis to verify thatthe indicated service life of the snubbers will not be exceeded prior to the next review.The TS also specifies that service life shall not at any time affect reactor operations.ln 1977, Exelon installed mechanical snubbers on safety related systems withincontainment. The snubbers were built by Pacific Scientific (PSA) and have a designEnclosure 11service life of 40 years. Exelon has assigned each snubber a service life of 40 yearsfrom time of installation.ln 2004, PSA issued technical bulletin DR-19, "Mechanical Shock Arrestor StandardDesign Specification." In this technical bulletin, PSA modified the design service life as"40 years effective service life with appropriate maintenance and operation within therated load and environmental limits." ln 2006, PSA issued technical bulletin DR-20,"Mechanical Shock Arrestor Service Life Extension Program & Preventive MaintenanceRecommendations." In this technical bulletin, PSA provided guidance for a preventivemaintenance program based upon a graduated response to snubbers found degraded orfailed. The program includes failure analysis, increased monitoring and preventivemaintenance. The preventive maintenance program in this bulletin is being consideredbut has not been implemented at Oyster Creek.In 1994, the NRC issued information notice (lN)94-048, "Snubber Lubricant Degradationin High-Temperature Environments", which alerted licensees to possible degradation ofthe lubricant used in mechanical snubbers manufactured by PSA when the snubber isused in a high temperature environment. The lN describes failure of the grease bymechanisms of hardening and loss of viscosity in PSA mechanical snubbers whenexposed to high temperatures. The NRC issued lN 94-048 for licensees to review andfor consideration of appropriate actions to avoid similar problems but did not require anyregulatory action.Oyster Creek's snubber testing program is contained in SP-1302-52-045, "Requirementsfor Functional Testing of Snubbers". This procedure defines the requirements andacceptance criteria for functional testing of PSA mechanical snubbers, as well as the testand acceptance criteria required by technical specifications.The inspector reviewed available maintenance records for the four failed snubbersidentified in 1R23. These snubbers had failed or were found degraded and had to bereplaced at a time-in-service ranging from 6 to 17 years despite having a designatedservice life of 40 years. The four failed snubbers had a history of repetitive failures.Three of the snubbers were found to be failed or degraded three times including thefailure identified in 1R23. The remaining snubber failed for the second time in 1R23.Despite the maintenance and testing history of these snubbers, no change to thedesignated 40 year service life was made. The testing requirements in TS 4.5.M.1.c(10% every 24 months) ensure that each snubber will be tested once every 20 years.The demonstrated service lives of snubbers that were identified as failed during 1R23are much shorter than the time between TS required testing intervals. SP-1302-52-045,"Requirements for Functional Testing of Snubbers", does not have any provisions toupdate service life of snubbers after they are found degraded or failed, which inhibitsExelon's ability to meet TS 4.5.M.1.f to conduct a review of snubber records to verify thatindicated service life will not exceeded until the next service life review. Additionally, thediscovery of a failed snubber requires that engineering perform an evaluation to showthat the failed snubber had no adverse effects on the piping. This does not meet therequirement contained in TS 4.5.M.1.f stating that the service life of a snubber shall notat any time affect reactor operation, but instead provides a reactive means to reviewpast operability.The inspectors noted that Exelon has two corporate procedures, ER-AA-330-010"snubber Functional Testing" and ER-AA-330-011 "Snubber Service Life Monitoring"Enclosure 12that serve as guidance for individual sites to test and monitor seryice life of snubbers.These procedures have not been implemented at Oyster Creek.Analvsis: Exelon's failure to take into account the maintenance and testing history ofsnubbers when determining designated service life so that a review of the snubbertesting plan to ensure that service life is not exceeded prior to the scheduled snubberservice life review is a performance deficiency.There are no similar examples in IMC 0612, Appendix E, "Examples of Minor lssues".This flnding is more than minor because it affects the equipment performance attribute ofthe mitigating systems cornerstone to ensure the availability, reliability and capability ofsystems that respond to initiating events to prevent undesirable consequences,specifically the safety related piping systems in containment.ln accordance with table 4a of IMC 0609.04, "Phase 1 - lnitial Screening andCharacterization of Findings," the finding was determined to be of very low safetysignificance (Green) because it was a qualification deficiency confirmed not to result inloss of operability or functionality.This finding has a cross-cutting aspect in the area of problem identification andresolution because Exelon did not thoroughly evaluate problems such that theresolutions address causes and extent of conditions. Additionally, Exelon did notconduct effectiveness reviews of corrective actions to ensure that the problems areresolved. (P.1(c)).Enforcement: TS 4.5.M.1.f requires that installation and maintenance records for eachsnubber be reviewed to verify that the indicated service life has not been exceeded orwill not be exceeded prior to the next schedule snubber service life review. Contrary tothe above, Exelon failed to consider snubber maintenance history when evaluatingdesignated service life values and conducting snubber service life reviews required byTS. Because this violation was of very low safety significance and it was entered intoExelon's corrective action program as lR 1170026, this violation is being treated as anNCV, consistent with the Enforcement Policy. (NCV 05000219/2010-005-01, SnubberMaintenance History Not Taken Into Account When Conducting Service LifeReviews).

1R13 Maintenance Risk Assessments and Emersent Work Control (71111.13)a. lnspection Scope (4 samples)The inspectors reviewed four on-line risk management evaluations through directobservation and document reviews for the following plant configurations:. Bank 6 startup transformer, 'B'battery charger, and 'B'control rod drive systemunavailable due to planned maintenance on October 20;. Core spray system #2 planned unavailability and reactor water inventorymanagement during refueling outage on November 22;o 'A' control rod drive system and main transformer M1B unavailable due to plannedmaintenance on December 6; ando Both station blackout combustion turbines unavailable due to adverse weatherconditions, and #1 EDG unavailable due to a battery charger failure onDecember 29.Enclosure

13The inspectors reviewed the applicable risk evaluations, work schedules, and controlroom logs for these configurations to verify the risk was assessed correctly andreassessed for emergent conditions in accordance with Exelon's procedures. Exelon'sactions to manage risk from maintenance and testing were reviewed during shiftturnover meetings, control room tours, and plant walkdowns. The inspectors also usedExelon's on-line risk monitor (Paragon) to gain insights into the risk associated withthese plant configurations. Additionally, the inspectors reviewed corrective actionprogram condition reports documenting problems associated with risk assessments andemergent work evaluations. Documents reviewed for this inspection activity are listed inthe Supplemental lnformation attachment to this report.b. FindinqsNo findings were identified.

1R15 Operabilitv Evaluations (71111.15)a. Inspection Scope (5 samples)The inspectors reviewed five operability evaluations for degraded or non-conformingconditions associated with:o fnoperable core spray snubber on October 1 (lR 1120002);o lP20B power supply failure on October 18 (lR 1123503);o Degraded weld on embedded plate in torus bay 9 on November 16 (lR 1138764);e Emergency diesel generator after discrepancies following loss of offsite power teston November 29 (lR 1145338); and. Torus to drywell vacuum breakers on November 30 (lR 1145393).The inspectors reviewed the technical adequacy of the operability evaluations to ensurethe conclusions were technically justified. The inspectors also walked down accessibleportions of equipment to corroborate the adequacy of Exelon's operability evaluations.Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.FindinqsNo findings were identified.Plant Modifications (7 1 1 1 1

===.18 )a. Inspection Scope (1 temporary and 1 permanent modification samples)The inspectors reviewed one temporary and one permanent plant modification that wereimplemented by Exelon personnel at Oyster Creek. The inspectors reviewed thefollowing modifications:. Bypass valve opening jack circuitry (temporary modification 10-00601); and. Deluge system modification for M1B transformer replacement (permanentmodification 09-00573);b.

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14The inspectors reviewed the engineering/procedure change packages, design basis, andlicensing basis documents associated with each of the modifications to ensure that thesystems associated with each of the modifications would not be adversely impacted bythe change. The inspectors walked down portions of the systems associated with themodification when applicable and prudent. The inspectors reviewed the modifications toensure they were performed in accordance with Exelon's modification process. Theinspectors also ensured that revisions to licensing/design basis documents andoperating procedures were properly revised to support implementation of themodification. The inspectors also reviewed Exelon's 10 CFR 50.59 screening for eachof the modifications. Documents reviewed for this inspection activity are listed in theSupplemental Information attachment to this report.b. FindinqsNo findings were identified.

1R19 Post-Maintenance Teetinq (71111.19)a. Inspection ScEre (5 samples)The inspectors observed portions of and/or reviewed the results of five post-maintenancetests for the following equipment:Containment spray and emergency service water (ESW) system 2 followinginspection of keepfill checkvalve V-3-131 on October 6 (R2162788);Main steam isolation valve (MSIV) V-1-9 leak rate test following completion of valvemaintenance on November 22 (42263426);MSIV V-1-8 leak rate test following completion of valve maintenance on November23 (R213%a$;lnservice test baseline after core spray NZO1B motor replacement on November 17(R2138066); and. M1B Hyundai main transformer replacement with Utah transformer on December 16(c20246e4).The inspectors verified that the post-maintenance tests conducted were adequate for thescope of the maintenance performed and that they ensured component functionalcapability. Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.b. FindinqsNo findings were identified.1R20 Refuelinq and OthelOutaqe Activities (71111.20)a. lnspection Scope (3 samples)The inspectors monitored Exelon's activities associated with the outage activitiesdescribed below. Documents reviewed for this inspection activity are listed in theSupplemental lnformation attachment to this report.Enclosure

15Refuelinq Outaqe (1 R23)On October 31, operators initiated a plant shutdown to support the 1R23 refuelingoutage. The inspectors observed portions of the shutdown from the control room, andreviewed plant logs to ensure that technical specification requirements were met forplacing the reactor in "hot shutdown" and "cold shutdown." The inspectors alsomonitored Exelon's controls over outage activities to determine whether they were inaccordance with procedures and applicable TS requirements.The inspectors verified that cool down rates during the plant shutdown were within TSrequirements. The inspectors performed a walkdown of accessible portions of thedrywell (primary containment) on November 2, and the condenser bay and the mainsteam tunnel on November 3, to verify that sources of leakage were identified and thatthere was no evidence of visual damage to passive systems contained in these areas.The inspectors noted the presence of a small amount of water in the bay 5 drywelltrench. The bay 17 drywelltrench was dry. The inspectors verified that Exelonassessed and managed outage risk. The inspectors confirmed, on a sampling basis,that tagged equipment was properly controlled and equipment configured to safelysupport maintenance and plant operations. During control room tours, the inspectorsverified that operators maintained reactor vessel level and temperature within theprocedurally required ranges for the operating condition. The inspectors also verifiedthat the decay heat removal function was maintained by performing a walkdown of thesystem on November 7 and by periodically monitoring shutdown cooling (SDC)parameters throughout the outage. The inspectors observed Oyster Creek's plant onsitereview committee (PORC) startup affirmations on November 29.The inspectors performed an inspection and walkdown of portions of the drywell prior tocontainment closure on November 29, to verify there was no evidence of leakage orvisual damage to passive systems and to verify that debris was not left which couldaffect drywell suppression pool performance during postulated accident conditions. Theinspectors monitored restart activities that began on November 30. The inspectorsensured that, through verification of technical specification requirements, licenseconditions, and procedural requirements, required equipment was available to supportoperational condition changes. Portions of the startup activities were observed from thecontrol room to assess operator and equipment performance. The inspectors furtherverified that unidentified leakage and identified leakage rate values were within expectedvalues and within technical specification requirements.During startup activities on December 1, control room operators responded to indicationsof an unidentified leak rate of approximately 17 GPM. The operators isolated the 'B'recirculation loop due to indications that the leakage was from the 'B' recirculation pumpmechanical seal, which stopped the leak. Operators then declared an Unusual Eventper Emergency Action Level (EAL) guidance. This event is described in detail in section4OA3 of this report. After this event, Exelon commenced startup on 4 recirculation loopsinstead of the typical five loop operation.Other Outaoe Activitv - Forced Outaqe due to Main Transformer Failure andReolacement (1F23. 24. 25)ln December, operators reduced power and took the turbine offline three times tosupport a planned maintenance outage due to a failure of the M1B main transformer.Enclosure 16Exelon replaced both the M1A and M1B main transformers with new transformers duringrefueling outage 1R23 in November. During power ascension following 1R23, online oilmonitoring equipment on the M1B main transformer indicated the increasing presence ofacetylene and other gases, which was indicative of an internal fault. As a result, Exelondecided to remove the newly installed Hyundai transformer and replace it with thepreviously installed Utah transformer. On December 2, operators reduced power andtook the generator offline to electrically disconnect Hyundai transformer (1F23). Exelonplaced the generator online and returned to 50% power on December 4. On December9, operators reduced power and took the generator offline to move the Hyunda,transformer from the transformer pad to a storage area and moved the spare Utahtransformer from the storage area to the transformer pad (1F24). Exelon placed thegenerator online and returned to 50% power on December 12. On December 15,operators reduced power and took the generator offline to electrically connect the Utahtransformer (1F25). The plant returned to 100% power on December 17.Other Outaqe Activitv - Forced Outaqe due to Recirculation Pump Trip (1F26)On December 19, operators initiated and completed an unplanned plant shutdown tosupport a forced outage to repair the 'B' reactor recirculation pump mechanical seal andto perform electrical troubleshooting on the 'A' reactor recirculation pump, which hadtripped on December 18 and is described in section

4OA3 of this report. The inspectorsobserved portions of the shutdown from the control room, and reviewed plant logs toensure that TS requirements were met for placing the reactor in "hot shutdown" and"cold shutdown." The inspectors also monitored Exelon's controls over outage activitiesto determine whether they were in accordance with procedures and applicable TSrequirements.The inspectors verified that cool down rates during the plant shutdown were within TSrequirements. The inspectors performed a walkdown of portions of the drywell onDecember 21. The inspectors noted the presence of standing water in the bay 5 and 17drywell trenches, which Exelon placed in the corrective action program (lR 1 155037).The inspectors verified that Exelon assessed and managed outage risk. The inspectorsconfirmed on a sampling basis that tagged equipment was properly controlled andequipment configured to safely support maintenance and plant operations. Duringcontrol room tours, the inspectors verified that operators maintained reactor vessel leveland temperature within the procedurally required ranges for the operating condition. Theinspectors also verified that the decay heat removal function was maintained throughmonitoring SDC parameters. The inspectors observed Oyster Creek's PORC startupaffirmations on December 22.The inspectors performed an inspection and walkdown of portions of the drywell prior tofinal containment closure on December 22, to verify that any observed leakage wasdocumented, that there was no visual damage to passive systems and to determine thatdebris was not left which could affect drywell suppression pool performance duringpostulated accident conditions. The inspectors again noted the presence of standingwater in the bay 5 and 17 drywelltrenches, which Exelon placed in the corrective actionprogram (lR 1155422). The inspectors monitored restart activities that began onDecember 23, to ensure that required equipment was available for operational conditionchanges, including verifying TS requirements, license conditions, and proceduralrequirements. Portions of the startup activities were observed from the control room toassess operator and equipment performance. During the plant startup, an automaticEnclosure

17scram occurred and is described in section

==4OA3 of this report. The inspectorsmonitored portions of the subsequent startup that began on December 24 to ensure thatrequired equipment was available for operational condition changes, including verifyingTS requirements, license conditions, and procedural requirements. Oyster Creeksynchronized the main generator to the grid and achieved full power on December 25.The inspectors verified that unidentified leakage and identified leakage rate values werewithin expected values and within TS requirements following return to power operations.b. FindinosNo findings were identified.

1R22 Surveillance Testinq (7 1 1 1 1

==

RADIATION SAFETY

Cornerstone:

Occupational Radiation Safety (OS)RS01 Access Control to Radiolooicallv Siqnificant Areas (71124.01)a. lnspection Scope (1 sample)The inspectors reviewed licensee activities and associated documentation to inspectExelon's performance in the inspection areas listed below. The evaluation of Exelon'sperformance was against criteria contained in 10 CFR 20, TSs, and applicable stationprocedures.Enclosure 18lnspection PlanninoThe inspectors reviewed Performance Indicators (Pls) for the Occupational ExposureCornerstone. The inspectors also reviewed the results of recent radiation protectionprogram audits and assessments and any reports of operational occurrences related tooccupational radiation safety since the last inspection. (See Section 4OA1)Radiological Hazard AssessmenlThe inspectors discussed plant operations to identify any significant new radiologicalhazards for onsite workers or members of the public. The inspectors assessed thepotential impact of the changes and monitoring to detect and quantify the radiologicalhazard.The inspectors toured radiological controlled areas and reviewed radiological surveys ofplant areas (e.g., refueling floor, reactor cavity, reactor building, turbine building,condenser bay, drywell, and the torus), and outdoor areas to verify that thethoroughness and frequency of the surveys were appropriate for the given radiologicalhazard.The inspectors conducted walkdowns of the facility, including the dry-active wastestorage buildings and outdoor storage areas, to evaluate material conditions andpotential radiological conditions. The inspectors made independent radiationmeasurements to verify condition.The inspectors selected various radiological risk significant work activities (reactorcavity, in vessel work activities, drywell work activities, condenser bay work, turbine workand iorus diving activities) that involved exposure to radiation to verify that appropriatepre-work surveys were performed to identify and quantify the radiological hazard and toestablish adequate protective measures. The review included identification of discreteparticles, the presence of alpha emitters, the potential for airborne radioactive materials,potential changes in radiological conditions, and non-uniform exposures of the body.The inspectors reviewed and discussed air sample survey records associated withvarious work activities to verify that samples were representative of breathing zone andcollected and counted in accordance with procedures. The inspectors reviewed the useand operation of continuous air monitors during plant tours. The inspectors reviewedconsideration of potential airborne radioactivity generation in areas of loose surfacecontamination.lnstructions to WorkersThe inspectors toured radiologically controlled areas, including outage work areas, andreviewed labeling of containers of radioactive materials to verify that container labelingwas consistent with requirements and was informative to workers'The inspectors reviewed a sample of radiation work permits (RWP), ALARA reviews,and radiological surveys used to access high radiation areas (HRA). The purpose of thereview was to verify that work control instructions, specified control barriers, stay timesor permissible dose limits, and electronic personal dosimeter (EPD) alarm set-pointswere in conformance with survey indications. Areas reviewed included the drywell,Enclosure 19turbine work areas, refueling floor, and the condenser bay. The inspectors evaluatedExelon's changes to setpoints for specified conditions and subsequent updating ofradiation work permits. The inspectors reviewed ongoing remote monitoring viateledosimetry.The inspectors reviewed ongoing work activities in the radiological controlled area toevaluate methods used by Exelon to update workers on changes in radiologicalworkconditions.Contamination and Radioactive Material ControlThe inspectors observed locations where Exelon monitors potentially contaminatedmaterial leaving the radiologically controlled area (RCA), and inspected the methodsused for control, survey, and release from the RCA. The inspectors observed theperformance of personnel surveying and releasing materialfor unrestricted use to verifythat the work was performed in accordance with plant procedures. The inspectorsreviewed the procedures to ensure that they were sufficient to control the spread ofcontamination and prevent unintended release of radioactive materials from the site.The inspectors evaluated the radiation monitoring instrumentation sensitivity to verifythat it was adequate for the types of radiation present.The inspectors reviewed Exelon's criteria for the survey and release of potentiallycontaminated material. The inspectors verified that there was guidance on how torespond to an alarm that indicates the presence of radioactive material.The inspectors reviewed procedures and records to verify that the radiation detectioninstrumentation was used at an appropriate sensitivity level based on observedbackground parameters in the counting area. The inspectors ensured that applicationof alarm setpoints was based on the instrument's sensitivity. The inspectors alsodiscussed alarm setpoints and typical detection capabilities with licensee personnel.The inspectors selected a sample of sealed sources, those presenting the greatestradiological risk, from Exelon's inventory records and verified that the sources wereaccounted for and have been verified to be intact. The inspectors discussed anytransactions involving nationally tracked sources to evaluate reporting in accordancewith 10 CFR20.2207.Radiolooical Hazards Control and Work CoveraqeThe inspectors toured the facility and reviewed ongoing work and evaluated ambientradiological conditions (e.9., actual or potential radiation levels or airborne radioactivitylevels). The inspectors verified the existing conditions were consistent with postedsurveys, RWPs, and worker briefings.The inspectors observed ongoing work activities and verified the adequacy ofradiological controls, such as required surveys (including system breach radiation,contamination, and airborne surveys), radiation protection job coverage (including audioand visual surveillance for remote job coverage), and contamination controls. Theinspectors evaluated Exelon's use of electronic personnel dosimeters (EPDs) in highnoise areas as HRA monitoring devices (e.9., use of teledosimetry).Enclosure 20The inspectors verified that radiation monitoring devices (thermoluminescent dosimeters(TLD))were placed on the monitored individual's body consistent with the method thatExelon was employing, to monitor dose from external radiation sources. The inspectorsverified, by direct observation, that the dosimeters were placed in the location of highestexpected dose. As part of this review, the inspectors reviewed the use of dosimetry toeffectively monitor exposure to personnel in high-radiation work areas with significantdose rate gradients.The inspectors reviewed three radiation work permits for work within potential airborneradioactivity areas with the potentialfor individual worker internal exposures. Theinspectors evaluated airborne radioactive controls and monitoring, including potentialsfor significant airborne levels (e.9., grinding, grit blasting, system breaches, entry intotanks, cubicles, reactor cavities). The inspectors reviewed system breech activitiesincluding use of local ventilation system and respiratory protection equipment tominimize airborne radioactive exposure.The inspectors observed ongoing work activities within flooded pools and examinedExelon's physical and programmatic controls for highly activated or contaminatedmaterials (nonfuel) stored within storage pools. The inspectors verified that appropriatecontrols (i.e., administrative and physical controls) were in place to preclude inadvertentremoval of these materials from the pool.The inspectors conducted inspection of posting and physical controls for HRAs and VeryHigh Radiation Areas (VHRA), to the extent necessary to verify conformance with theOccupational Pl. The inspectors evaluated reduction in controls of areas (e.9., changingposting of areas from HRAs to Radiation Areas).Risk-Sionificant Hioh Radiation Area and Verv Hiqh Radiation Area ControlsThe inspectors discussed with the Radiation Protection Manager (RPM), the controlsand procedures for high-risk HRAs and VHRAs and any procedural changes since thelast inspection. The inspectors discussed methods employed by Exelon to providestricter control of VHRA access including potential reduction in the effectiveness andlevel of worker protection (e.9., use of lock boxes).The inspectors discussed with health physics supervisors, controls for special areas thathad the potential to become VHRAs during certain plant operations including controls toensure that an individualwas not able to gain unauthorized access to the VHRA.Radiation Worker PerformanceThe inspectors observed radiation worker performance with respect to stated radiationprotection work requirements to determine if performance reflected the level ofradiological hazards present. The inspectors interviewed numerous workers conductingwork activities in the radiological controlled area to determine if workers were aware ofthe radiological conditions in their workplace and the RWP controls/limits in place.The inspectors reviewed at least ten radiological problem reports since the lastinspection to identify human performance errors and determine if there were anyobservable patterns. The inspectors discussed corrective actions for identified concernswith licensee personnel.Enclosure b.a.RSO221Radiation Protection Technician ProficiencvThe inspectors observed the performance of radiation protection technicians withrespect to radiation protection work requirements to determine if technicians were awareof the radiological conditions in their workplace and the RWP controls/limits and if theirperformance was consistent with their training and qualifications with respect to theradiological hazards and work activities.The inspectors reviewed outage radiological problem reports to identify those thatindicate the cause of the event to be radiation protection technician error and to evaluatethe corrective action approach taken by Exelon to resolve the reported problems.FindinqsNo findings were identified.Occupational ALARA Planninq and Controls (71124.02)lnspection ScopeThe inspectors reviewed Exelon's performance, in the below identified areas, withrespect to maintaining individual and collective radiation exposure ALARA.lnspection PlanninqThe inspectors reviewed pertinent information regarding plant collective exposurehistory, current exposure trends, and ongoing or planned activities in order to assesscurrent performance and exposure challenges. The inspectors determined the plant's 3-year rolling average collective exposure.The inspectors determined the site-specific trends in collective exposures using variousmethods such as plant historical data, including outage work dose based on task,evaluation of ALAM data, and licensee source term data.The inspectors reviewed site-specific procedures associated with maintainingoccupational exposures ALARA including the processes used to estimate and trackexposures from specific work activities.Radioloqical Work PlanningThe inspectors obtained from Exelon a list of work activities ranked by actual orestimated exposure that were planned or in progress and selected work activities of thehighest exposure significance. These included reactor disassembly, control rod drivework, scaffolding, torus diving, and valve work.The inspectors reviewed the ALARA work activity evaluations, exposure estimates, andexposure mitigation requirements. The inspectors determined if Exelon reasonablygrouped the radiologicalwork into work activities, based on historical precedence,industry norms, and/or special circumstances.Enclosure 22The inspectors determined if Exelon's planning identified appropriate dose mitigationfeatures; considered, commensurate with the risk of the work activity, alternatemitigation features; and defined reasonable dose goals. As applicable, the inspectorsverified that Exelon's ALARA assessment had taken into account decreased workerefficiency from use of respiratory protective devices.The inspectors determined if Exelon's work planning considered the use of remotetechnologies (such as teledosimetry, remote visual monitoring, or robotics) as a meansto reduce dose and the use of dose reduction insights from industry operatingexperience and plant-specific lessons learned. The inspectors verified the integration ofALARA requirements into work procedure and radiation work permit (RWP) documents.The inspectors compared accrued results achieved (person-rem), with the intended doseestablished in Exelon's ALARA planning for work activities that exceeded 5 person-remaggregate dose. The inspectors determined the reasons for any inconsistenciesbetween intended and actualwork activity doses, as accrued. The inspectors discussedaggregate exposure sustained during the 1R23 outage as compared to established pre-outage goals.Verification of Dose Estimates and Exposure Trackinq SvstemsThe inspectors selected at least five ALARA work packages and reviewed theassumptions and bases for the collective exposure estimate for reasonable accuracy.The inspectors reviewed applicable procedures to determine the methodology forestimating exposures from specific work activities and the intended dose outcome. Theinspectors also reviewed approvals by the station ALARA committee.The inspectors verified, for the selected work activities, that Exelon establishedmeasures to track, trend, and if necessary to reduce, occupational doses for ongoingwork activities including criteria to prompt additional reviews and/or controls.The inspectors evaluated the adequacy of Exelon's method of adjusting exposureestimates when unexpected changes in scope or emergent work are encountered.Source Term Reduction and ControlThe inspectors used licensee records to determine the historical trends and currentstatus of significant tracked plant source terms known to contribute to elevated facilityaggregate exposure. The inspectors discussed source term mitigation with licenseestaff and reviewed the stations Five-Year ALARA plan. The inspectors discussedcontingency plans for potential changes in the source term as the result of changes inplant fuel performance issues or changes in plant primary chemistry.Radiation Worker and Radiation Protection Technician PerformanceThe inspectors observed both radiation worker and radiation protection technicianperformance during work activities being performed in radiation areas, airborneradioactivity areas, or high radiation areas. The inspectors determined if workersdemonstrated the ALARA philosophy in practice and whether there were any procedurecompliance issues. The inspectors observed performance to determine whether thetraining and skill level were sufficient with respect to the radiological hazards and thework involved.Enclosure b.a.RSO323FindinqsNo findings were identified.ln-Plant Airborne Radioactivitv Control and Mitiqation (71 124.03)Inspection ScopeThe inspectors assessed Exelon's performance associated with efforts to limitgeneration and minimization of occupational intake of airborne radioactive material.Inspection PlanninqThe inspectors reviewed the UFSAR to identify areas of the plant designed as potentialairborne radiation areas and any associated ventilation systems or airborne monitoringinstrumentation. The inspectors also reviewed the UFSAR for overview of respiratoryprotection program and a description of the types of devices used.The inspectors reviewed Exelon's procedures for maintenance, inspection, and use ofrespiratory protection equipment including procedures for air quality maintenance. Theinspectors directly observed and evaluated the use of respiratory protection equipmentduring ongoing work activities.The inspectors reviewed the reported Occupational Performance lndicators to identifyany related to unintended dose resulting from intakes of radioactive materials.Enqineerino ControlsThe inspectors evaluated Exelon's use of ventilation systems as part of its engineeringcontrols to control airborne radioactivity. The inspectors discussed procedural guidancefor use of installed plant systems to verify system use, to the extent practicable, duringhigh-risk activities. The inspectors discussed verification of plant ventilation systemsduring reactor cavity work.The inspectors reviewed installed ventilation systems used to mitigate the potentialforairborne radioactivity. The inspectors discussed use of installed systems during workactivities associated with reactor cavity work.The inspectors selected two temporary ventilation system setups (high efficiencyparticulate absolute) filters to support work in contaminated areas. The inspectorsdiscussed the use of these systems with respect to procedural guidance and ALARA.The inspectors selected installed systems to monitor and warn of changing airborneconcentrations in the plant. The inspectors evaluated the alarms and setpoints toprompt licensee/worker action to ensure that doses are maintained within the limits of10 CFR Part2Q and ALAM. The inspectors observed monitoring of ambient conditions.The inspectors evaluated that licensee's use of trigger points for evaluating levels ofhard{o detect airborne radionuclides.Enclosure 24Use of Respiratorv Protection DevicesThe inspectors evaluated Exelon's use of respiratory protection devices to maintainoccupational doses ALARA. The inspectors selected work activities where respiratoryprotection devices were used (e.9., control rod drive removal, grit blasting) to limit theintake of radioactive materials, and evaluated the use of respirators. The inspectorsevaluated Exelon's means to verify that the level of protection (protection factor)provided by the respiratory protection devices during use was at least as good as thatassumed in Exelon's work controls and dose assessment.The inspectors evaluated the use of certified equipment (respiratory protection devices)to limit the intake of radioactive materials and evaluated that the devices were usedconsistent with their NIOSH/MSHA certification or any conditions of their NRC approval.The inspectors reviewed records of air testing for supplied-air devices to verify that airused in these devices meets or exceeded appropriate quality. The inspectors evaluatedthe breathing air supply systems against the minimum pressure and airflow requirementsfor the devices in use.The inspectors selected individuals qualified to use respiratory protection devices, andverified that they have been deemed qualified to use the devices.The inspectors observed individuals assigned to wear a respiratory protection deviceand observed them donning and functionally checking the device as appropriate. Theinspectors discussed their use of the devices including how to properly respond to anydevice malfunction or unusual occurrence.b. FindinqsNo findings were identified.RS04 Occupational Dose Assessment (71124.04)a. Inspection ScopeThe inspectors evaluated Exelon's occupational dose assessment program to assessthe accuracy and effectiveness of Exelon's ability to measure occupational dose,including internal dose.Inspection PlanninoThe inspectors reviewed the results of available radiation protection program auditsrelated to internal and external dosimetry to gain insights into overall licenseeperformance in the area of dose assessment.The inspectors reviewed Exelon's current National Voluntary Laboratory AccreditationProgram (NVLAP) accreditation report for Exelon personnel dosimetry.The inspectors reviewed licensee procedures associated with dosimetry operations,including issuance/use of external dosimetry (routine, multi-badging, extremity, neutron,Enclosure 25etc.), and assessment of internal dose. The inspectors evaluated procedure guidancefor personnel monitoring.External DosimetrvThe inspectors evaluated the use of Exelon's personnel dosimeters that requireprocessing, to determine if they were NVLAP accredited. The inspectors determined ifExelon uses a "correction facto/'to address the response of the electronic dosimeter(ED) as compared to its TLD for situations when the ED must be used to assign dose.Intern?l DosimetrvThe inspectors reviewed routine bioassay (in vivo) procedures used to assess dose frominternally deposited nuclides using whole body counting equipment. The inspectorsdetermined if the procedures address methods for determining if an individual isinternally or externally contaminated, the release of contaminated individuals, thedetermination of entry route (ingestion, inhalation), and assignment of dose.The inspectors evaluated the minimum detectable activity (MDA) of Exelon'sinstrumentation used for passive whole body counting to determine if the MDA wasadequate to determine the potential for internally deposited radionuclides sufficient toprompt additional investigation.Special Dosimetric SituationsThe inspectors reviewed Exelon's program to inform workers of the risks of radiationexposure to the embryo/fetus, the regulatory aspects of declaring a pregnancy, and thespecific process to be used for (voluntarily) declaring a pregnancy.The inspectors reviewed Exelon's methodology for monitoring external dose in situationsin which non-uniform fields are expected or large dose gradients could exist (e.9,, divingactivities, valve work) to verify that Exelon established criteria for determining whenalternate monitoring techniques (i.e., use of multi-badging or determination of effective' dose equivalent for external exposures using an approved method) were to beimplemented.b. FindinqsNo findings were identified.RS05 Radiation Monitorinq Instrumentation (71 122.05)a. lnspection ScopeThe inspectors evaluated Exelon's radiation monitoring instrumentation to assess theperformance of Exelon in ensuring the accuracy and operability of radiation monitoringinstruments.Enclosure 26Inspection PlanninqThe inspectors reviewed the UFSAR to identify radiation instruments associated withmonitoring area radiological conditions including airborne radioactivity, process streams,effluents, materials/articles, and workers.The inspectors obtained a listing of in-service survey instrumentation including airsamplers and small article monitors (SAMs), along with instruments used for detectingand analyzing workers'external contamination (personnel contamination monitors(PCMs)) and workers' internal contamination (portal monitors (PMs), whole bodycounters (WBCs)), including neutron monitoring instrumentation to determine whether anadequate number and type of instruments are available to support operations.The inspectors obtained and reviewed copies of licensee and third-party (independent)evaluation reports of the radiation monitoring program since the last inspection, includingaudits of Exelon's offsite calibration facility and reviewed the reports for insights intoExelon's program.The inspectors reviewed procedures that govern instrument source checks andcalibrations. The inspectors review the calibration and source check procedures foradequacy. The inspectors reviewed calibration records and source checks forcontamination monitoring instruments.Walkdowns and ObservationsThe inspectors walked down the stack monitoring system, to verify that effluenUprocessmonitor configurations align with ODCM descriptions. The inspectors looked for monitordegradation and/or out-of-service tags.The inspectors selected at least five portable survey instruments in use or available forissuance and checked calibration and source check stickers for currency, and to assessinstrument material condition and operability. The inspectors evaluated instrumentationin use within the radiological controlled area to validate current calibration and sourcechecking. The inspectors reviewed source checking of different types of portable surveyinstruments.The inspectors walked down five area radiation monitors, including portable areamonitors, and continuous air monitors (CAMs) to determine whether they wereappropriately positioned relative to the radiation source or area they were intended tomonitor. The inspectors compared monitor response (via local or remote indication) withactual area conditions for consistency. The inspectors evaluated instrumentation in-place on the refueling bridge and work platforms.The inspectors selected PCMs, PMs, and SAMs and verified that the periodic sourcechecks were performed in accordance with licensee procedures. The inspectorsreviewed alarm set-point data for various personnel and equipment monitors at threeradiological controlled area exits to verify that the alarm set-point values werereasonable under the circumstances to ensure that licensed material was not releasedfrom the radiological controlled area.Enclosure b.27Calibration and Check SourcesThe inspectors reviewed Exelon's latest 10 CFR Part 61 source term to determine if thecalibration sources used were representative of the types and energies of radiationencountered in the plant.FindinosNo findings were identified.Cornerstone: Public Radiation Safety (PS)Radioactive Gaseous and Liquid Effluent Treatment (71124.06)Inspection ScopeThe inspectors reviewed aspects of Exelon's gaseous and liquid effluent control programin the below listed areas.(Note: Exelon identified operability issues with the Plant Stack Monitor in April 2010.This issue was previously reviewed and discussed in NRC Inspection Report05000219/2010003, dated August 9,2010 (ADAMS ML1022101 1 1). See Section 4OA5for a discussion of this issue.)Event Report and Effluent Report ReviewsThe inspector's reviewed the 2006, 2007,2008, and 2009 Annual Radiological EffluentRelease Reports. The inspectors determined if the reports were submitted as requiredby the ODCM/Technical Specifications. The inspectors reviewed the reports foranomalous results, unexpected trends or abnormal releases identified by Exelon forfurther inspection to determine if they were evaluated, were entered in the correctiveaction program, and were adequately resolved.The inspectors reviewed the Radiological Effluent Release reports to ldentify radioactiveeffluent monitor operability issues reported by Exelon as provided in effluent releasereports. The inspectors reviewed these issues during the onsite inspection, aswarranted, given their relative significance. The inspectors determined if the issueswere entered into the corrective action program and adequately resolved.ODCM and UFSAR ReviewsThe inspectors reviewed the UFSAR descriptions of the radioactive effluent monitoringsystems, treatment systems, and effluent flow paths during inspection walk-downs.The inspectors reviewed changes to the ODCM made by Exelon since the lastinspection, to review the technical basis or evaluations of the change and to determinewhether they were technically justified and maintained effluent releases ALARA.RSO6Enclosure 28Groundwater Protection Initiative (GPl) ProoramThe inspectors reviewed reported groundwater monitoring results, and changes to theprogram for identifying and controlling contaminated spills/leaks to groundwater.The inspectors reviewed Exelon's evaluations and program to provide for release oftritiated groundwater associated with its remediation of tritium groundwater. Theinspectors reviewed changes made to the ODCM to support this activity. The inspectorsreviewed projected dose calculations with respect to guidance contained in NRCRegulatory Guide 1

.109 . As part of this review, the inspectors walked-down thepumping system at the intake, used for the groundwater remediation effort.Procedures. Special Reports & Other DocumentsThe inspectors reviewed LERs, event reports and special reports related to the effluentprogram issued since the previous inspection. The inspectors reviewed thesedocuments to identify any additional focus areas for the inspection based on thescope/breadth of problems described in these reports.Walkdowns and ObservationsThe inspectors determined if Exelon made any significant changes to its effluent releasepoints,

e.9., changes subject to a 10 CFR 50.59 review or requiring NRC approval ofalternate discharge points.Samplinq and AnalvsesThe inspectors determined if Exelon was routinely relying on the use of compensatorysampling in lieu of adequate system maintenance.Effluent Flow Measurinq lnstrumentsThe inspectors reviewed the methodology used to determine the effluent stack and plantvent flow rates.Problem ldentification and ResolutionThe inspectors reviewed problems associated with the effluent monitoring and controlprogram to determine if they were identified by Exelon at an appropriate threshold andwere properly addressed for resolution in the corrective action program. (See Section4c.A2)b. FindinqsNo findings were identified.4. OTHER ACTTVTTTES [OA]4OA1 Performance lndicator Verification (71151)a. Inspection Scope (7 samples)Enclosure

.1 a.29Occupational Exposure Control Effectiveness (1 Sample)Inspection Scope (71 151)The inspectors reviewed Exelon's program to gather, evaluate, and report information onthe occupational exposure control effectiveness performance indicator (Pl). Theinspectors used the guidance provided in Nuclear Energy Institute (NEl) 99-02, Revision6, "Regulatory Assessment Performance Indicator Guideline" to assess the accuracy ofExelon's collection and reporting of Pl data. The inspectors reviewed corrective actionprogram records for occurrences involving High Radiation Areas, Very High RadiationAreas, and unplanned personnel radiation exposures since the last inspection in thisarea. The purpose of this review was to verify that occurrences that met NEI criteriawere recognized and identified as Performance Indicators.FindinqsNo findings were identified.RETS/ODCM Radioloqical Effluent Occurrences (1 Sample)Inspection Scope (71 1 51 )The inspectors reviewed Exelon's program to gather, evaluate, and report information onthe radiological effluents technical specification/offsite dose calculation manual(RETSiODCM) Pl. The inspectors used the guidance provided in NEI 99-02 to assessthe accuracy of Exelon's collection and reporting of Pl data. The inspectors reviewedcorrective action program records and projected monthly and quarterly dose assessmentresults due to radioactive liquid and gaseous effluent releases for the past four completequarters. The purpose of this review was to verify that occurrences that met NEI criteriawere recognized and identified as Performance Indicators. As part of this review, theinspectors also reviewed Exelon's evaluations and public dose assessments associatedwith identification of localized ground water contamination within the restricted area.FindinosNo findings were identified.Mitiqatino Svstems Performance Indicators (5 samples)The inspectors reviewed Exelon's program to gather, evaluate, and report informationon five Pls associated with the mitigating systems performance index (MSPI). Theinspectors used the guidance provided in NEI 99-02 to assess the accuracy of Exelon'scollection and reporting of Pl data. The inspectors reviewed operating logs andcorrective action program condition reports. The inspectors verified the accuracy andcompleteness of the reported data from October 1,2009 through September 30, 2010for the following Pls:o Emergency AC power system;. High pressure injection system;. Heat removal system;. Residual heat removal system; andr Cooling water systems.b.a.b.Enclosure

b.30Documents reviewed for this inspection activity are listed in the SupplementalInformation attachment to this report.FindinqsNo findings were identified.ldentification and Resolution of Problems (71152)Review of ltems Entered Into the Corrective Action ProqramThe inspectors performed a daily screening of items entered into Exelon's correctiveaction program to identify repetitive equipment failures or specific human performanceissues for follow-up. The screening was accomplished by reviewing hard copies ofcondition reports, attending daily screening meetings, or accessing Exelon'scomputerized database.Semi-Annual Review to ldentifv TrendsInspection Scope (1 sample)The inspectors performed one semi-annualtrend review. The inspectors reviewedExelon's corrective action program documents to identify trends that could indicate theexistence of a more significant safety issue. The inspectors also performed a walkdownof equipment important to safety to ensure issues were being properly identified andcorrected in the corrective action program. The inspectors review was focused onrepetitive equipment problems, human performance issues, and programimplementation issues. The results of the trend review by the inspectors were comparedwith the results of normal baseline inspections. The review included issues documentedoutside the normal corrective action system, such as in system health reports andOyster Creek monthly management reports. The review considered a six-month periodof June through December 2010.Assessment and ObservationsNo findings were identified.Annual Sample ReviewInspection Scope (1 Operator Work Around and 1 annual sample)The inspectors reviewed Exelon's evaluation and corrective actions associated with thefollowing two issues. Documents reviewed for these inspection activities are listed in theSupplemental Information attachment to this report.Operator Work-Arounds (Cumulative Review). The inspectors reviewed equipmentissues that Exelon identified as operator work-arounds (OWA) or operator challenges.The inspectors verified that the OWAs were being properly controlled as specified byOP-AA-102-103, "Operator Work-Around Program." The inspectors assessed thecumulative impact of the identified OWAs, operator challenges, and control roomdeficiencies by performing a detailed document review and interviewing operations4c.42,1,2b..3a.Enclosure b.31personnel during the week of December 15. In addition, the inspectors conducted awalkdown of the main control room and risk significant plant areas to determine if thesedeficiencies adversely affected the ability of operations personnel to implementemergency operating procedures or respond to plant transients.Torus Vacuum Breaker V-26-18 O-Rinq Missinq. The inspectors reviewed Exelon'sevaluation and corrective actions associated with the torus vacuum breaker V-26-18actuator o-ring missing (lR 1142958). Exelon noted an air leak on the piston actuator forthe reactor building to torus vacuum breaker air actuator during the last run cycle. WhenExelon performed corrective maintenance on the actuator during the

1R23 outage,maintenance personnel noted the o-ring was missing on the cylinder flange. Exelonrebuilt the actuator with a correctly installed o-ring under work order C2024491. Theinspectors reviewed relevant corrective action program condition reports to ensure thatthe full extent of the issue was identified, appropriate evaluations were performed, andcorrective actions were specified and prioritized.Findinqs and ObservationsNo findings were identified.Problem ldentification and Resolution for Inservice Inspection

Inspection ScopeThe inspectors reviewed a sample of corrective action reports that identifiednonconforming conditions discovered during the most recent and previous refuelingoutages. The inspectors verified that flaws and other nonconforming conditionsidentified during nondestructive testing were reported, characterized, evaluated andappropriately dispositioned for continued operation or for repair or replacement.FindinqsNo findings were identified.Problem ldentification and Resolution for Radiation Protection Inspections (71 153.7 1 1 24.01 . 7 1 1 24.02. 7 1 1 24.03. 7 1 1 24.04. 7 1 1 24.05. 7 1 1 24.06. 60855.1\Inspection ScopeThe inspectors reviewed a sample of corrective action documents to determine ifidentified problems were entered into the corrective action program for resolution and toevaluate Exelon's threshold for entering issues into the program. The review included acheck for possible repetitive issues, such as radiation worker or radiation protectiontechnician errors. The inspectors also reviewed recent audits and assessments toensure that identified issues were entered into the corrective action program.FindinosNo findings were identified.,4a.b..5a.b.Enclosure 40A3.1a.32Event Followup (71 153) (7 samples)The inspectors performed seven event followup inspection activities. Documentsreviewed for this inspection activity are listed in the Supplemental Information attachedto this report.Ground Water (Pipe Vault #1)lnspection Scope (71 153. 71 124.06)On May 14,2010 Exelon notified the NRC and the State of New Jersey of theidentification of tritiated water, measuring about 18,000 pCi/l, in pipe vault #1. Theestimated quantity of water was approximately 2,000 to 3,000 gallons which waspumped into a tank for processing. The pipe vault is located on the southeast corner ofthe Reactor Building and was being entered and inspected as part of Exelon's buriedpipe remediation program. This issue was initially discussed in NRC quarterly inspectionreport 05000219/2010003, dated August 9, 2010 (ADAMS Mt1022101 1 1).As part of the review at that time, the inspectors performed walkdowns of the area andentered the vault to review material conditions. The inspectors confirmed that, prior tothe 2008 outage, the isolation condensers (lC)were filled from the condensate storagetank, which contains tritiated water. During the 2008 refueling outage, Exelon installed ademineralized water system to provide a non{ritiated water source for the lCs andserves as the preferred source of filling the lCs to maintain system water levels.Although the condensate storage tank and fire main continue to be the credited sourcesof lC shell side fill water for the licensing basis, Exelon's preferential use of thedemineralized water system will minimize future tritium releases during use of the lCs.The inspectors conducted a follow-up review as to the source of the tritium in pipe vault#1. The inspectors interviewed Exelon personnel and evaluated the likely causes oftritium. The inspectors walked down the area near the vault to identify likely sources.The inspectors reviewed the following items:Latest radiological data, including well samples from newly installed wells;Efforts to radiological characterizalion of area;Exelon's failure modes analysis (FMA);Inspection results of potential piping sources in the area including determination oflikely sources;Assessments as to the source of the tritium;Records of the site characterization of geology and hydrology;Systems, structures, and/or components that contain or could contain licensedmaterial in the area;Evaluations of work practices that involved licensed material for which there is acredible mechanism for the licensed material to reach the groundwater at thatlocation;lmplementation of the onsite groundwater monitoring program;Records of leaks and spills;Dose projections available;Disposition of water; andReporting and notification records.Enclosure b.33Exelon's evaluation determined that the source of the tritium identified in the water foundin pipe vault #1 was from local tritiated steam condensate deposition associated withactuation of the lCs in July 2007. No other credible source of the tritium was identifiedthrough the Exelon's failure modes analysis, evaluation and inspection of the condition ofunderground piping, or evaluation of well sample results for the wells surrounding and inthe vicinity of pipe vault #1. The evaluation of well data included that from new wellsinstalled in the vicinity of pipe vault #1. Exelon conducted dose projections associatedwith the releases and did not identify any significant public or occupational dose impact.FindinqsNo findings were identified.RAGEMS MonitorinqInspection Scope (71 153. 71 124.06)On April 7, Exelon technicians ascending the plant ventilation stack identified that thestack radioactive effluent sample line of the radioactive gaseous etfluent monitoringsystem (RAGEMS) was disconnected at a pipe union at about the 260 foot elevation ofthe stack. The sample line was found to be displaced laterally resulting in theinterruption of the sample flow path. The stack sample line is used to deliver acontinuous sample of stack effluents to the RAGEMS located in the RAGEMS Buildingat the base of the stack. The technician who discovered the piping discontinuityreconnected the fitting. Subsequent Exelon investigation identified that three sampleline unions had failed in the line to varying degrees. Two were found disconnected andthe third was loose. The RAGEMS system had been declared inoperable on April 7, tosupport the flow transmitter work. Exelon evaluated reportability and subsequentlymade a 10 CFR 50.72 notification (ENS 45824) on April 8.The inspectors reviewed the circumstances surrounding the issue, the duration of thecondition, and public dose projection implications of the condition. The inspectorsreviewed Exelon's root cause investigation as well as bounding dose reconstruction.The review was with respect to 10 CFR 20,10 CFR 50, the station TSs, and the ODCM.(Note: This issue was initially reviewed and discussed in NRC quarterly inspection report05000219/2010003, dated August 9, 2010 (ADAMS ML1022101 1 1). Both thereportability aspects of this issue as well as the emergency preparedness (EP) aspectswere reviewed and evaluated during that NRC inspection. Preliminary assessment ofthe public dose impact of this issue was also reviewed during that inspection whichindicated no public doses in excess of 10 CFR 50, Appendix l, ALARA designspecifications were exceeded. )During this inspection, the inspectors reviewed Exelon's dose assessment in regards tothe maximum projected doses during the time period that the RAGEMS was in adegraded condition. The inspectors also reviewed secondary effluent controls containedwithin the Radioactive Effluents Control Program, including monitoring systems,sampling, coolant monitoring, and environmental monitoring to provide secondarycontrols on radioactive effluents and control of doses to the public. The inspectors alsoreviewed bounding dose calculations associated with effluent release conditionsconsidering secondary controls and/or monitoring systems.Enclosure 34As part of this review, the inspectors evaluated: potential release paths, projected sourceterms, projected doses, bounding sources terms and controls, to determine if during thetime period of degraded monitor performance, with the existing source term, 10 CFR 50,Appendix I doses were exceed or likely exceeded. The inspectors also evaluatedpotential projected doses, assuming a less favorable source term and use of secondarycontrols, to limit doses to the public to 10 CFR 50, Appendix I ALAM designspecifications.The inspectors also confirmed that Exelon conformed to the requirements of TSs relatedto the protective instrumentation specifications pertaining to the off-gas system radiationmonitoring functions.FindinqsIntroduction: A Green, self-revealing NCV of Technical Specification 6.8.4 occurredwhen Exelon failed to maintain continuous representative sampling of plant stackradioactive gaseous effluents. Specifically, Exelon did not fully conduct monitoring andsampling of stack gaseous effluents in accordance with the methodology in the ODCM,as required by TS 6.8.4.Description: Effluents from the plant stack are principally monitored and sampled by theinstalled stack radioactive gaseous effluent monitoring system (RAGEMS). Thismonitoring system is described in the UFSAR and the system provides for on-line noblegas monitoring as well as continuous particulate and iodine sampling and the collectionof tritium samples. The RAGEMS system provides for monitoring and sampling ofcombined ventilation system inputs from various plant ventilated spaces including thereactor building, off-gas system, turbine building, and radwaste facilities. The stackeffluent sample line runs down the stack and is used to deliver a sample to the stackRAGEMS sample and monitoring system located in the RAGEMS Building at the base ofthe stack. The station has secondary controls in-place (e.9., off-gas monitoring, sourceterm analysis and monitoring, in-plant monitoring, bounding analyses and controls) toalert plant staff to changes in release rates and source term. In addition, the station'senvironmental monitoring program provides secondary checks of the efficacy of theeffluents program.Exelon's root cause analysis identified that the stack monitoring system showed veryslight declining performance beginning as early as March 2006. This decliningperformance was evidenced by a very gradual decline in live-time radioactivity count ratefor the stack gas channel. Further, the stack monitor gas channel computer traceshowed decreasing gas channel count rates associated with occasional off-gas systemoutages as compared to earlier traces. Exelon's post identification review concludedthat its secondary effluent program monitoring capabilities provided for sufficientdetection of changes in source term and release rates to ensure conformance with 10CFR 50 Appendix I ALARA design values.TS 6.8.4 requires that Exelon conduct, in-part, monitoring and sampling of radioactivegaseous effluent in accordance with the methodology and parameters in the ODCM.The ODCM specifies in section 4.11.2, that the effluent doses shall be determined byobtaining representative samples. The ODCM also specifies in section 4.11.2 that noblegas radionuclides in gaseous effluents may be identified by taking a grab sample andanalyzing it using criteria specified. Table 4.11.2.1.2-1 requires that the sampling beEnclosure 35continuous and that the noble gases be monitored continuously with a noble gasmonitor. Since the same sample line also provides the stack effluent sample for grabsampling, this capability atso degraded over time and was eventually lost due to loss ofline integrity.Exelon's root cause analysis indicated the MGEMS stack effluent system did not collecta fully representative sample of the effluents due to the sample line integrity issue.Based on data analysis, Exelon concluded the initial degradation of integrity occurred inor about March 2006.Exelon conducted a multi-faceted re-analysis of projected releases and offsite doses.Exelon conducted bounding dose analyses to estimate potential public doseconsequences during the period of sample line degradation, evaluated reactor coolanthistory, and normalized stack releases using post-system restoration data. Exelon alsoreviewed environmentalsample data, including ambient radiation levels and particulateand iodine environmental sample station data and did not identify any indication thatelevated releases occurred during periods of potential degradation of the samplingcapability. Exelon evaluated in-plant work activities during the period to identify anypotential airborne events. Exelon also evaluated fuel integrity, coolant concentrations,leak rates, and dose consequences associated with potential changes thereto. Exelonconcluded that the degradation of the stack effluent sample line did not result nor waslikely to result in any member of the public exceeding applicable 10 CFR 50, Appendix l,ALAM design specifications.Exelon's failure analysis indicated the degradation of sample line integrity was due toimproper line connection assembly in conjunction with with sample line weight stress.Exelon repaired the connections and installed tube supports to support the sample lineand to prevent wind induced motion of the line causing stress at the fittings. Exelondeclared the stack RAGEMS system (including the sample line) operable on April 20,after conducting a satisfactory leak check of the sample line.Exelon's root cause analysis identified that procedures for conduct of review of data fromactual samples and quality control activities for reasonableness and consistency werenot sufficient to critically review and evaluate the stack sample data. The need for suchdata reviews is specified in Regulatory Guide 4.15, Rev. 1, which is incorporated byreference into the TS for effluent monitoring.Analvsis: Exelon did not fully monitor or collect representative samples of plant stackeffluents, as required by TS 6.8.4 and the ODCM during the period between March 2006and March 2010 as a result of sample line integrity issues. The failure to monitor orcollect representative samples of the plant stack effluent was reasonably within Exelon'sability to foresee and should have been prevented.This finding was not willful and did not involve a violation that impacted the regulatoryprocess or contribute to an actual safety consequence. The finding is more than minorbecause it is associated with the plant facilities, equipment, and instrumentation attributeof the Public Radiation Safety Cornerstone and adversely impacted the objective ofensuring adequate protection of public health and safety from exposure to radioactivematerials released into the public domain. Specifically, during the period March 2006through at least March 2A1A, stack monitoring and sampling degraded over time due tosample line integrity issues. Following identification, Exelon initiated an enhancedEnclosure 36compensatory monitoring program, repaired the cause of the non-representativesampling, and entered this issue, including the evaluation of extent-of-condition, into thecorrective action program. This finding was assessed using IMC 0609, Appendix D, anddetermined to be of very low safety significance (Green) because: the issue wascontrary to Exelon's TSs and is a radioactive effluent release program deficiency; therewas no spill; secondary radioactive effluent monitoring and control program elementsprovided for control of effluents releases. In addition, Exelon was able to assess thedose to members of the public from routine releases and determined that projecteddoses did not nor were likely to exceed applicable limits including ALAM designspecifications of 10 CFR 50, Appendix l. Exelon's review of environmental radiationmonitoring data, during the period of sample line degradation, did not identify anyadverse effect or delectable activity in the environment attributable to the condition.The inspectors' independent review of Exelon's data, assessment, dose projections, andsource term, indicated that both pre-and post correction assessment public doses werea small fraction of the 10 CFR 50, Appendix I ALARA dose specifications. Theinspectors identified that during the period, fuel integrity remained high, there were noabnormal releases, principal radioactive effluent reduction equipment (e.9., augmentedoff-gas system) were maintained operable to reduce effluents, and secondary controlscontained in Exelon's effluent program and source term monitoring provided forcharacterization and control of effluents to ensure conformance with 10 CFR 50Appendix l. Exelon plans to provide updated effluent release and dose reports, asnecessary, to reflect revised analyses.The cause of this finding is related to the crosscutting area of human performance,resources aspect (H.2(c)) because procedures for conduct of review of data from actualsamples and quality control activities for reasonableness and consistency were notsufficient to recognize deficiencies (e.9., detect degradation of sampling capabilities).Enforcement: TS 6.8.4 requires Exelon to conduct, in-part, monitoring and sampling ofradioactive gaseous effluent in accordance with the methodology and parameters in theODCM. The ODCM specifies in Section 4.11.2 that, for purposes of determining publicdose rates to be within the limits specified therein, the doses due to iodine-131 , iodine-133, tritium, and all radionuclides, in particulate form, with half-lives greater than 8 daysin gaseous effluents shall be determined by obtaining representative samples. TheODCM also specifies in section 4.11.2 that noble gas radionuclides in gaseous effluentsmay be identified by taking a grab sample and analyzing it using criteria specifiedtherein. ln addition, section 2.4 of the ODCM specifies that the quantity of noble gasesreleased will be determined from the continuous noble gas monitor and periodic isotopicanalyses.Contrary to these requirements, Exelon failed to conduct representative monitoring andsampling of noble gasses, iodine, particulates, and tritium during the period March 2006through at least March 2010, due to degradation in stack effluent sampling line integrity.Exelon initiated compensatory monitoring, repaired the cause of the non-representativesampling, and entered this issue, including the evaluation of extent-of-condition, into thecorrective action program (lR 01053577). Because this finding is of very low safetysignificance, and because it was entered into Exelon's corrective action program (lR01A$577), this violation is being treated as an NCV, consistent with the EnforcementPolicy. (NCV 05000219/2010005.02, Failure to Conduct Representative Sampling ofStack Effluents)Enclosure

.337 Loss of4160V 1D BusInspection ScopeOn October 7, Exelon personnelwere performing procedure 632.2.002,"GridUndervoltage Channel FunctionalTest" when the 1D 4160V breaker tripped. Asdesigned, the#2 emergency dieselgenerator (EDG) received a fast start signal, itsoutput breaker closed, and the diesel powered the load from the 1D 4160V bus. Exelonlater determined that the cause of the failure was a fault in the test equipment.The inspectors verified that operations personnel responded in accordance withprocedures and equipment responded as intended by reviewing the completedprocedures, control room narrative logs, corrective action program condition reports, andthrough interviews of operations personnel. The inspectors also reviewed TSrequirements to ensure that Oyster Creek was operated in accordance with its operatinglicense. The inspectors performed a walkdown of the main control room panels andindications to verify equipment status and plant parameters. Exelon notified the NRCwith an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> report (ENS 46315) and submitted a licensee event report (LER0500021 912010-001-00) for this event. The loss of the 4160V 1D bus is described andevaluated in corrective action program condition report lR 1123363.Unusual Event declared to Unidentified Leak Rate qreater than 10 GPMInspection ScopeOn December 1, control room operators responded to indications of an unidentified leakrate of approximately 17 GPM. The operators isolated the "B" recirculation loop due toindications that the leakage was from the "B" recirculation pump mechanical seal, whichstopped the leak.The inspectors responded to the control room following site announcement declaring anUnusual Event due to an Unidentified Leak Rate in excess of 10 GPM and observed theresponse of Exelon personnel to the event, including operator actions in the controlroom. At the time of the event, the inspectors verified that conditions met the entrycriteria for an emergency action level (EAL) as described in the Oyster Creek EALmatrix. ln addition, the inspectors reviewed 10 CFR 50.72, "lmmediate NotificationRequirements for Operating Nuclear Power Reactors," to verify that Exelon properlynotified the NRC during the event. The inspectors also reviewed TS requirements toensure that Oyster Creek operated in accordance with its operating license.The inspectors reviewed plant process computer (PPC) data, control room logs, anddiscussed the event with Exelon personnel to gain an understanding of how operationspersonnel and plant equipment responded during the event. The inspectors evaluatedExelon's program and process associated with event response to ensure theyadequately implemented station procedure OP-M-106-101-1001, "Event ResponseGuidelines."The Unusual Event is described and evaluated in corrective action program conditionreport lR 1147123..4Enclosure

b.a.b.a..638FindinosNo findings were identified.'A' Reactor Recirculation Pump Trip on December 18Inspection ScopeOn December 18, Oyster Creek experienced a trip of the 'A' recirculation pump. At thetime, Oyster Creek was in four loop operation due to the previous failure of the "B"recirculation pump mechanical seal. Control room operators responded to severalrecirculation pump and motor generator set alarms and confirmed that the "A"recirculation pump had tripped. Oyster Creek performed simple troubleshooting anddetermined the pump tripped due to an electricalfault in the system, but could not isolatethe location of the fault while at power. Exelon chose to remain at 55 percent powerduring initial troubleshooting while two of the recirculation loops were unavailable.At the time of the event, the inspectors verified that conditions did not meet the entrycriteria for an EAL as described in the Oyster Creek EAL matrix. In addition, theinspectors reviewed 10 CFR 50.72, "lmmediate Notification Requirements for OperatingNuclear Power Reactors," to verify that Exelon properly notified the NRC during theevent. The inspectors also reviewed TS requirements to ensure that Oyster Creekoperated in accordance with its operating license.The inspectors reviewed PPC data, control room logs, and discussed the event withExelon personnel to gain an understanding of how operations personneland plantequipment responded during the event. The inspectors evaluated Exelon's program andprocess associated with event response to ensure they adequately implemented stationprocedures OP-AA-108-114, "Post Transient Review" and OP-M-106-101-1001, "EventResponse Guidelines."Exelon initiated an unplanned plant shutdown on December 19 to support a forcedoutage (1F26) to repair the "8" reactor recirculation pump mechanical seal and tocontinue electrical troubleshooting on the "A" reactor recirculation pump. This forcedoutage is described in detail in section 1R20.FindinosNo findings were identified.Automatic reactor scram durinq critical plant heatup on December 23Inspection ScopeOn December 23, operating personnel in control room responded to an automaticreactor scram.The inspectors responded to the site after being informed of the event on December 23.At the time of the event, the inspectors verified that conditions did not meet the entrycriteria for an EAL as described in the Oyster Creek EAL matrix. In addition, theinspectors reviewed 10 CFR 50.72, "lmmediate Notification Requirements for OperatingEnclosure b.39Nuclear Power Reactors," to verify that Exelon properly notified the NRC during theevent. The inspectors also reviewed TS requirements to ensure that Oyster Creekoperated in accordance with its operating license.The inspectors reviewed PPC data, control room logs, and discussed the event withExelon personnel to gain an understanding of how operations personnel and plantequipment responded during the event. The inspectors evaluated Exelon's program andprocess associated with event response to ensure they adequately implemented stationprocedures OP-AA-108-1 14, "Post Transient Review" and OP-AA-106-101-1001 , "EventResponse Guidelines."The inspectors observed the plant onsite review committee (PORC) meeting prior toplant startup to ensure Exelon identified the cause of the event and appropriatelyresolved issues identified during the event. The inspectors reviewed Exelon's promptinvestigation (lR 1 155520) to gain additional information pertaining to the event, andensure that human performance and equipment issues were properly evaluated andunderstood prior to plant startup.Findinqslntroduction. A Green, self-revealing NCV of Technical Specification 6.8.1.a occurredwhen Exelon did not adequately implement plant startup procedures which resulted in anautomatic reactor scram.Description. On December 23, Exelon operators were performing a reactor startupfollowing forced outage 1F26. The mode switch was in startup with the reactor power inrange 9 of the intermediate range monitor (lRM) nuclear instrumentation. Reactorpressure was approximately 570 psig with main condenser vacuum at 24 inches Hgwhen both reactor protection systems (RPS) activated and the reactor received anautomatic scram signal on low condenser vacuum.The condenser low vacuum trip relay setpoint is 22 inches Hg while reactor pressure isabove 600 psig. The automatic reset for the low vacuum trip relay is between 25 and 26inches Hg. ln order to ensure the low vacuum trip relay has reset, procedure 201, "PlantStartup", step 5.44.2, directs the operators to confirm that "all main condenser vacuumtrips have cleared and all main condenser alarms have cleared prio/'to exceeding 500psig reactor pressure. Operators did not verify that condenser vacuum was adequate orthat all main condenser vacuum trips had cleared, prior to raising reactor pressure above500 psig.Exelon's preliminary evaluation (lR 1 155520) determined that operators had verified thatthe low vacuum turbine trips were reset, but did not verify that the main condenser lowvacuum alarm and the RPS main condenser low vacuum alarms were clear prior toraising reactor pressure above 500 psig. lmmediate corrective actions included just intime training with all reactor operators, increased management oversight during thestartup, and procedural changes to list all alarms by name that must be cleared prior toraising reactor pressure above 500 psig. Exelon is performing a full root causeevaluation on the event (lR 1 155520).Analvsis. Exelon's failure to implement procedure 201, "Plant Startup," is a performancedeficiency that was reasonably within Exelon's ability to foresee and prevent. TheEnclosure

.740 inspectors determined that the performance deficiency was similar to example 4b in IMC0612, Appendix E, "Examples of Minor lssues," and is more than minor because theperformance deficiency resulted in a plant transient.Additionally, the finding was more than minor in accordance with IMC 0612, Appendix B,"lssue Screening," because it was associated with the equipment performance attributeof the initiating events cornerstone and affected the objective to limit the likelihood ofthose events that upset plant stability and challenge critical safety functions duringpower operation. ln accordance with IMC 0609.04 (Table 4a), "Phase 1 - Initial Screenand Characterization of Findings," the finding was determined to be of very low safetysignificance (Green) because the finding did not contribute to both the likelihood of areactor trip and the likelihood that mitigation equipment or functions would not beavailable.This finding has a cross-cutting aspect in the area of human performance, workpractices (H.4(b)), where personnelwork practices support human performance.Specifically, Exelon defines and effectively communicates expectations regardingprocedural compliance and that personnelfollow procedures. On December 23,operators did not verify that condenser vacuum was adequate nor that all maincondenser vacuum trips had cleared prior to raising reactor pressure above 500 psigcontrary to established procedural guidance.Enforcement. TS 6.8.1a states, in part, that written procedures shall be established,implemented, and maintained as recommended in Regulatory Guide 1.33. Contrary tothe above, Exelon failed to implement procedure 201, "Plant Startup," in a manner thatwould have prevented the automatic scram which occurred on December 23. Becausethis violation was of very low safety significance and it was entered into Exelon'scorrective action program as lR 1155520, this violation is being treated as an NCV,consistent with the Enforcement Policy. (NCV 05000219/2011-01-03, Failure tolmplement Procedures Resulting in Reactor Scram).(Closed) LER 0500021 9/201 0-001 -00,Inspection ScopeThis LER discussed an automatic start of the # 2 emergency diesel generator due to anunexpected trip of the 1D bus normal feeder breaker caused by a fault in a piece of testequipment during a surveillance test on October 7. The inspectors reviewed this LERand no new issues were identified. This LER is closed.The inspectors noted that this LER was submitted on December 17, which was 10 dayslater than the requirement of 60 days following the discovery of the event as required in1O CFR 50.73(a). Exelon made a timely I hour report (ENS 46315) following the eventon October 7. The inspectors evaluated that the issue of the timely submission of theLER was a minor violation, as it did not meet the examples of a severity level lV violationprovided in section 6.9.d of the NRC Enforcement Policy.FindinosNo findings were identified.b.Enclosure

414OA5 Other.1lndependent Spent Fuel Storaqe Installation (lSFSl) (60855.1)Inspection Scope (1 Sample)The inspectors reviewed routine operational surveillance data, including radiologicalsurveillance, for the ISFSI facility. The inspectors toured the facility and madeindependent radiation measurements of the facility. The data was evaluated against10 CFR Part20 and applicable Exelon procedures.FindinqsNo findings were identified.Post-Approval Site Inspection for License Renewal (71003)Inspection Scope (1 Sample)The inspectors reviewed Exelon's plans to comply with license condition (2XcX1 1) forthe inspection of the drywell sand bed region. The inspectors compared Exelon's plansagainst the requirement to perform full scope inspections (as defined in Appendix A ofthe license renewal safety evaluation report dated March 20, 2007 , and summarized inthe UFSAR) of the drywell sand bed region every other refueling outage beginning in therefueling outage prior to April 9, 2009. The inspectors also compared Exelon plansagainst commitment (4) in Appendix A of the license renewal safety evaluation reportwhich states the Inservice Inspection Program will be enhanced to require inspection of100Yo of the epoxy coating. The inspectors further reviewed Exelon's inspection plans todetermine if the inspections were performed in accordance with ASME section Xl,subsection IWE and if the inspections met the scheduler requirements of the note tocommitment 4 to inspect all 10 bays every other refueling outage, in accordance withitem 21of the IWE inspection program.The inspectors reviewed Exelon'compliance with license condition (2)(c)(13) whichrequires Exelon perform an engineering study prior to April 9, 2009 to identify options toeliminate or reduce the leakage in the facility cavity liner. The inspectors alsodetermined if Exelon was continuing to monitor for leakage of the refueling cavity linerand other water sources associated with the drywell and if they had implemented plansto eliminate routine leakage in order to provide increased protection against furtherdegradation as stated in the Safety Evaluation Report (SER) at 5-5. The inspectorsreviewed Exelon's response to their choice to install a flow indicating device on therefueling drain and the subsequent failure of the device due to clogging. The inspectorsreviewed the impact of the resultant water flowing down the containment vessel gap andinto the sandbeds. The inspectors reviewed photographs of the moisture in the sandbedregions caused by the failure of the flow indicating device and the evidence that thewater did not appear to impinge on the containment vessel wall but flowed down thevertical concrete wall of the sandbed.The inspectors reviewed changes made to commitments prior, and subsequent to, theperiod of extended operation. The inspectors compared the process and consequenceof changes to update a vessel inspection program commitment, change the period ofa.b.a.Enclosure b..242replacement for the diesel fire pump day tank, modify the buried pipe programprocedure, and modify a commitment related to fire pump surveillance. The changeprocess was compared with the expectations in NRR Office Letter No. 807 "ControlofLicensing Bases for Operating Reactors", NEI 99-04 "Guidelines for Managing NRCCommitment Changes," and NRC Regulatory lssue Summary 2000-17 "ManagingRegulatory Commitments Made by Power Reactor Licensees to the NRC Staff."The inspectors reviewed results of the mitigation of the buried piping degradationprogram, including the methodology used to identify vulnerable piping. This reviewcompared Exelon's progress against the SER, Appendix A, Commitment 26, whichincluded the provisions to enhance the program to include inspection of buried pipingwithin ten years of entering the period of extended operation, unless an opportunisticinspection occurs within this ten year period. The inspectors reviewed Exelon's actionsin order to determine if the inspections included at least one carbon steel, one aluminumand one cast iron pipe or component and if the locations selected for inspection includedat least one location where the previously replaced or recoated. Because Exelon choseto pface piping, whose failure would result in significant consequences, inside a vault orsecondary barrier, the inspectors discussed the progress of the remediation programwith the program owners.The inspectors reviewed the process, procedures, and results of compliance with10 CFR 54.37 (b). The inspectors compared this against the UFSAR update required by10 CFR 50.71(e) which must include any systems, structures, and components newlyidentified that would have been subject to an aging management review or evaluation oftime-limited aging analyses in accordance with S 54.21. The inspectors verified if theOyster Creek UFSAR update described how the effects of aging will be managed suchthat the intended functions in S 54.a(b) will be effectively maintained during the period ofextended operation.The inspectors reviewed the results of all one{ime inspections and the plans for one-time inspections during and after the current outage to determine compliance withcommitment24 of appendix A of the SER. The standard of evaluation was if theprogram provided reasonable assurance that during the extended period operation anaging effect is not occurring, or that the aging effect is occurring slowly enough to notaffect the component or structure intended function during the period of extendedoperation, and therefore will not require additional aging management. The inspectorsascertained if the commitment to include two stainless steel pipe sections in a stagnantbr low flow area in the reactor water cleanup system, and two stainless steel pipesections in a stagnant or low flow area in the isolation condenser system were includedin the one-time inspection samples.FindinqqNo findings were identified.(Closed) URI 05000219/2010004-01 : EDG Pillow-Block BearinqInspection ScopeOuring tfre routine overhaul and inspection of the #1 emergency diesel generator (EDG)on June 8, maintenance personnel identified damage to the cooling fan shaft pillow-block bearing. Exelon removed the bearing for further analysis by an offsite lab andreplaced the bearing and shaft with new components on June 9. Exelon entered thisa.Enclosure b.43issue into the corrective action program as lR 1078312 and lR 1103610 and performedan equipment apparent cause evaluation (EACE) to review the offsite lab report todetermine the cause of the failure and any additional corrective actions. This EACE wasnot complete at the conclusion of the third quarter 2010 inspection period, so theinspectors opened a URI to follow the issue. The inspectors reviewed the offsite labreport and Exelon's EACE and discussed the results with regional specialist inspectors.FindinqsNo findings were identified.Meetinqs. Includinq ExitResident Inspector Exit Meetinq. On January 26, the inspectors presented their overallfindings to members of Exelon's management led by Mr. Michael Massaro, Site VicePresident, and other members of his staff who acknowledged the findings. Theinspectors confirmed that proprietary information reviewed during the inspection periodwas returned to Exelon.Radiation Protection Exit Meetinq. The inspectors presented the inspection findings tomembers of Exelon management on October 8, November 12, and December 10, 2010.Exelon personnel acknowledged the inspection findings. No proprietary material isincluded in this inspection report.Inservice Inspection Exit Meetinq. The inspectors presented the inspection findings tomembers of Exelon management on December 13, 2010. Exelon personnelacknowledged the inspection findings. No proprietary material is included in thisinspection report.Post-Approval Site Inspection for License Renewal Exit Meetinq. The inspectorspresented the inspection findings to members of Exelon management on December 13,2010. Exelon personnel acknowledged the inspection findings. No proprietary materialis included in this inspection report.ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee Personnel

M. Massaro, Site Vice-President

P. Orphanos, Plant Manager

R. Peak, Plant Manager

D. Dicello, Director, Work Management

M. McKenna, Director, Operations

G. Malone, Acting Director, Engineering

C. Symonds, Acting Director, Training

J. Dostal, Director, Maintenance

J. Barstow, Manager, Regulatory Assurance

T. Keenan, Manager, Security

R. Skelsky, Senior Manager, Systems Engineering

H. Ray, Senior Manager, Design Engineering

G. Flesher, Acting Shift Operations Superintendent

J. McDaniel, Manager, Nuclear Oversight

M. Seeloff, Manager, Corrective Action Program

M. Ford, Manager, EnvironmentaliChemistry

A. Farenga, Manager, Radiation Protection

J. Chrisley, Regulatory Assurance Specialist

J. Kerr, Regulatory Assurance Specialist

Z. Demeke, Engineering

G. Harttraft, Engineering

M. McAllister, NDE Senior Site Specialist

R. Healey, GEH

P. Tamburo, Senior Staff Engineer

R. Alger, GEH

A. Paschal, GEH

S. Schwartz, Senior Staff Engineer

P. Bloss, Work Management Director

R. Heffner, Radiation Protection Supervisor

Z. Karpe, Corporate Environmental Manager

K. Leonard, Program Owner, Buried Pipe

M. Nelson, Project Manager

S. Sklenar, Environmental Manager, Mid-Atlantic

C. Taylor, Licensing EngineerOthers:State of New Jersey, Bureau of Nuclear EngineeringAttachment

A-2

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened/Closed0500021 9/201 0005-0105000219/2010005.020500021 9/201 0005-03Closed05000219/2010-001-00LER0500021 9/201 0004-01URISnubber Maintenance History Not Taken IntoAccount When Conducting Service LifeReviews (Section 1R12)Failure to Conduct Representative Sampling ofStack Effluents (Section 4OA3)Failure to lmplement Procedures Resulting inReactor Scram (Section 4OA3)Automatic start of emergency diesel generator dueto unexpected trip of the 1D bus normal feederbreaker (Section 4OA3)EDG Pillow-Block Bearing (Section 4OA5)NCVNCVNCVAttachment

A-3

LIST OF DOCUMENTS REVIEWED

In addition to the documents identified in the body of this report, the inspectors reviewed thefollowing documents and records.

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

1-1001 , "Severe Weather and Natural Disaster Guidelines"WC-AA-1 07, "Seasonal Readiness"OP-OC-1 08-1 09-1 002, "Cold Weather Freeze Inspection"OP-OC-1 08-1 09-1 003, "Winter Readiness"Condition Reports (lR)1150402 1013027Work Orders (AR)42233818 42249499Other DocumentsExelon Letter, "Certification of 2010-2A11 Winter Readiness", dated November 15,2010

==Section 1R04: Equipment AliqnmentProcedures304, "Standby Liquid Control System Operation"307, "lsolation Condenser System"310, "Containment Spray System Operation"612.4.001, "standby Liquid Control Pump and Valve Operability and In-Service Test302.1, "Control Rod Drive System"DrawinqSGE 148F262, "Emergency Condenser Flow Diagram"GE 148F723, "Liquid Poison System Flow Diagram"GE 148F740, "Containment Spray System Flow Diagram"GE237E487, "CRD System Flow Diagram"Condition Reports (lR)0921274

1110221 11229141138352 1145150Section 1R05: Fire Protection1132790

1136378 1138158ProceduresABN-29, "Plant Fires"101.2, "Oyster Creek Site Fire Protection Program"CC-AA-21 1, "Fire Protection Program"333, "Plant Fire Protection System"Other DocumentsPre-Fire Plan==

TB-FZ-11H, "Demineralizer Tanks and Steam Jet Air Ejector Area, Elev. 23'6""Pre-Fire Plan, "Emergency Diesel Generator Room #2 (DG-FA-17)"Pre-Fire Plan, "Emergency Diesel Generator Room #1 (DG-FA-15)"1144319A22512301120679A2266263 4226390110747381 097855Attachment

A-4

Section 1R08: Inservice Inspection ActivitiesProceduresCC-M-501-1008, "Exelon Nuclear Welding Program, Welding General Requirements"ER-OC-330-1001,'

ASME Piping System Classification Changes"CC-AA-SO1-1003, "Exelon Nuclear Welding Program, Visual Weld Acceptance Criteria"MA-AA-733-1001, "Exelon Nuclear Guidance For Check Valve General Visual Inspection"ER-AA-335-004, "Ultrasonic Measurement of Material Thicknesses and Interfering Conditions"GE-PDl-UT-3, GE Energy Nuclear Procedure, "PDl Generic Procedure For UltrasonicThru Wall Sizing ln Piping Welds"GEH-PDI-UT-1, GE Hitachi Nuclear Energy Procedure, "PDl Generic Procedure for theUltrasonic Examination of Ferritic Pipe Welds"ER-M-335-018, "Detailed, General,

VT-1,

VT-1C,

VT-3, and W-3C Visual Examination ofASME Class MC and CC Containment Surfaces and Components"GEH-PDI-UT-10, GE Hitachi Nuclear Energy Procedure, " PDI Generic Procedure for theUltrasonic Examination of Dissimilar Metal Welds"GE-UT-304, GE Energy Nuclear Procedure, " Procedure for Manual Ultrasonic Planar FlawSizing In Vessel Materials"GE-UT-300, GE Hitachi Nuclear Energy Procedure, "Procedure for Manual Examination ofReactor Vessel Assembly Welds ln Accordance With PDl"GE-UT-309, GE Energy Nuclear Procedure, " Procedure for Manual Ultrasonic Planar FlawSizing Of Nozzle Inner Radius And Bore Regions"GE-UT-31 1, GE Hitachi Nuclear Energy Procedure, " Procedure for Manual Ultrasonic OfNozzle Inner Radius, Bore And Selected Nozzle To Vessel Regions"Cgndition Reports (lR)74968681 93651022703107616411372511 1

368581 1

364651 1

369201 13699911370137979081 01 0090102552684249285270211370131 1

365551 1 365551374111 1 3683982621110255268930901 1 1670811372511 1

366631 1

369201 1 369941137006825919853894878804872994113701411357321 1368391137002113728710761649637098360478856021 1 36465113700211371091 1

370061

1368581 1 359399838881

0628041 1

000531 1

368581 1

369941 1 3692011370111137417Radioqraph ReviewCore Spray piping replacement weld radiograph report

RT-001 , 11127110NDE fnspection Reports & Data SheetsGEH Report, Dissimilar Metal Weld Ultrasonic Examination Review, eDRF Number 0000-0088-3338, Revision 0, 7 15108W.O.

C2023027-05, Report No. 1R23-145; PT of Component Weld

RHC-2-0044DOyster Creek Report No. R-16R-025; UT Inspection of Safe End To Nozzle weld no.

NRO2-2-565D, 9117196Oyster Creek Report No. R-16R-057; UT Inspection of Safe End To Nozzle weld no.

NRO2-2-565E(NG-E -27), 9125196Oyster Creek Report No. R-16R-052; UT Inspection of Safe End To Nozzle weld no.

NRO2-2-5654( N G-A -26), I / 24/ 96Attachment

A-5Oyster Creek Report No. R-16R-049; UT Inspection of Safe End To Nozzle weld no.

NRO2-2-5658, 9123196Oyster Creek Report No. 1R23-LRA-001; UT Thickness Measurement Data Sheet, SandbedBay #1 , 1115110Oyster Creek Report No. 1R23-LRA-001; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #1, 1112110Oyster Creek Report No. 1R23-LRA-002; UT Thickness Measurement Data Sheet, SandbedBay #3, 1116110Oyster Creek Report No. 1R23-LM-002; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #3, 1116110Oyster Creek Report No. 1R23-LRA-024; UT Thickness Measurement Data Sheet, SandbedBay #5, 11117110Oyster Creek Report No. 1R23-LRA-024; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay#5, 11117110Oyster Creek Report No. 1R23-LRA-022: UT Thickness Measurement Data Sheet, SandbedBay #7, 11115110Oyster Creek Report No. 1R23-LRA-022; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #7, 11/15/10Oyster Creek Report No. 1R23-LM-023; UT Thickness Measurement Data Sheet, SandbedBay #9, 11116110Oyster Creek Report No. 1R23-LRA-023; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #9, 11116110Oyster Creek Report No. 1R23-LRA-003; UT Thickness Measurement Data Sheet, SandbedBay #11, 1119110Oyster Creek Report No. 1R23-LRA-003; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #11, 1119110Oyster Creek Report No. 1R23-LRA-004; UT Thickness Measurement Data Sheet, SandbedBay #13,1119110Oyster Creek Report No. 1R23-LRA-004; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #13,111911QOyster Creek Report No. 1R23-LRA-006; UT Thickness Measurement Data Sheet, SandbedBay #15,11113110Oyster Creek Report No. 1R23-LRA-006; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #15, 11113/1QOyster Creek Report No. 1R23-LRA-005; UT Thickness Measurement Data Sheet, SandbedBay #17,1119110Oyster Creek Report No. 1R23-LF{A-005; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #17, 1119110Oyster Creek Report No. 1R23-LRA-021; UT Thickness Measurement Data Sheet, SandbedBay #19, 11115110Oyster Creek Report No. 1R23-LRA-021; ASME IWE (Class MC) Containment VisualExamination NDE Report, Sandbed Bay #19, 11114110Oyster Creek, N2D, Examination Summary Sheet 1R23-1 12, NR02 2-565D WELD(IGSCC),Nozzle to Safe End, 11118110Oyster Creek, N2D, Liquid Penetrant Examination Report No. 1R23-1 11, NR02 2-565DWELD, Nozzle to Safe End, 11118110Oyster Creek, N2B, Examination Summary Sheet 1R23-110, NR02

2-5658 WELD(IGSCC),Nozzle to Safe End, 11118110Oyster Creek, N2B, Liquid Penetrant Examination Report No. 1R23-109, NR02

2-5658WELD, Nozzle to Safe End, 11118/10Attachment

A-6Oyster Creek, N2A, Examination Summary Sheet 1R23-108, NR02 2-565A WELD(IGSCC),Nozzle to Safe End, 11118110Oyster Creek, N2A, Liquid Penetrant Examination Report No.WELD, Nozzle to Safe End, 11118110AR01136716; INR OC1R23 lwl-10-04 SD Tie Bar K-1 Lower,AR01136717: INR OC1R23 lwl-10-05 SD Tie Bar N, 11i6l101R23-107, NR02

2-56541116t1AR01 1 36724; INR OC1R23 lwl-10-06 Steam Dryer Center Baffle Plate, 1116110AR01136718; INR OC1R23 lwl-10-08 SD Tie Bar B-1 Lower, 1116110AR01136999; INR OC1R23 lwl-10-09 SD Tie Bar C-1 Lower, 1116110AR01

137002; INR OC1R23 lwl-10-10

SD 310 degree HAD Swing Bar Stop Block, 1117110AR01137011; INR OC1R23 lwl-10-12

SD 135 degree Lifting Rod Lock Collar, 1117110Personnel NDE Certification Records0899 0977Repai r-Replacement Work OrdersC2A23465; Replace Internals In Valve V-2-73, 6130110C2023712; Replace Eroded Core Spray Piping, 11110110Proqram DocumentsOyster Creek Underground Piping Program Description and Status, Topical Report 116,Revision 6,10113110MiscellaneousVM-OC-0134, "Anchor Darling Valves Operating & Maintenance lnstruction Manual"EPRI Letter 2007-367, "BWR Vessel & Internals Project (BWRVIP); Subject: RecommendationsRegarding Dissimilar MetalWeld Examinations (lncludes Needed Requirement per NEI03-08)", dated 1214107EPRl Letter 2008-293, "BWR Vessel & Internals Project (BWRVIP) "Transmittal of "lnterimGuidance for an Accelerated Inspection Program for

BWRVIP-75-A Category CDissimilar MetalWelds Containing Alloy 182.", dated 10128108Focused Area Self Assessment (FASA), Inservice Inspection Oyster Creek, lSl Program 1R23Pre-NRC FASA, 8131110NRC Letter, "Oyster Creek Nuclear Generating Station (OCNGS) - Alternatives and ReliefsConcerning the Fourth 10 Year lnterval Inservice Inspection Program (TAC

NOS.M85790, M85791, MB5792 and MB5793) ", dated 1011lO3GEH, 10 CFR Part2l Communication

SC-09-06, "Anomaly Discovered in Tomo View 2 DataAnalysis Software", dated

912210910

CFR 21 - BWRVIP Survey; Attachment A, "Exelon Response to RLB Survey In Response toGEH Safety Communication 09-01 and 09-03"Exelon Letter

RA-09-019, "Oyster Creek Generating Station (OCGNS) Refueling Outage 22(1R22) Inservice lnspection (lSl) Summary Report and Attachments", dated 2l20l0gExelon Letter

RA-09-019, "Oyster Creek Generating Station (OCGNS) Refueling Outage22(1R22) Inservice Inspection (lSl) Summary Report and Attachments: Attachment 1,lSl Post 1R22 Outage Summary Report", dated 2120109Attachment

A-7Exelon Letter M-09-019, "Oyster Creek Generating Station (OCGNS) Refueling Outage22 (1R22) lnservice lnspection (lSl) Summary Report and Attachments: Attachment 2,Form

NIS-1, Containment lSl Program - lWE, 11108", dated 2120109Exefon Letter

RA-09-019, "Oyster Creek Generating Station (OCGNS) Refueling Outage 22(1R22) Inservice lnspection (lSl) Summary Report and Attachments: Attachment 3,Form

NIS-2, Owner's Report For Repairs and Replacements", dated 2120109Document Revision Request 10-19,

10114110; PDI Generic Procedure For The UltrasonicExamination Of Austenitic Pipe Welds,

GE-PDI-UT, Revision 5; 1111110Document Revision Request 06-35, 9/16/06; PDI Generic Procedure For The UltrasonicExamination Of Weld Overlaid Austenitic Pipe Welds,

GE-PDl-UT-8, Revision 4; 9/18/06Document Revision Request 10-08, 3lQIA\; Procedure For Phased Array UltrasonicExamination Of Dissimilar Metal Welds,

GEH-UT-247, Version 2;3118110Document Revision Request 06-35,

9116106; PDI Generic Procedure For The UltrasonicExamination Of Weld Overlaid Austenitic Pipe Welds,

GE-PDl-UT-8, Revision 4; 9/18i06

Section 1R11: Licensed Operator Requalification ProqramOther DocumentsEOP User's Guide (2000-BAS-3200.02)Scenario 261 2.CREW. 1

0-6.0 1EP-AA-1010 Table OCGS 3.1, "Emergency Action Level (EAL) Matrix"

Section 1Rl2: Maintenance EffectivenessProceduresER-AA-31 0, "lmplementation of Maintenance Rule"ER-AA-310-1005, "Maintenance Rule - Disposition Between (aX1)and (a)(2)"LS

AA-125-1003, "Apparent Cause Evaluation Manual"ER-AA-330-01 l, "Snubber Service Life Monitoring"2400-GMM-3921.52, "Removal, lnspection and Installation of Mechanical Snubbers"SP- 1 302-5 2-045, "Req uirements for Functional Testing of Sn ubbers"ER-AA-330-004, "Visual Examination of Snubbers"ER-AA-330-01 0, "Snubber Functional Testing"675.1.001, "Hydraulic Snubber Inspection and Replacement"602.4.004, "Main Steam lsolation Valve 10% Closure Test"Condition Reports (lR)1138622

1143829

1144054 11438741144738

1135806

1136893 11369001143148

1143332

1143829 11438741139909

1105782

1136893 1120002825932

796399

912272 9527721137357

1026563

552088 549352551773

553354

553324 547992656696

631031

1162972 554069Work Orders (AR)A2237605 A2237605 R2153133 C2024166M2236053 R2090403 R2142691 R2133416R2151915 A2153352

C2014200 C20245811149674

11433321

138096 1

1386201

139516 1

1398971

138356 1137357984533 1138356547308 549352551808 62420611700264207993R2155457R2094386R2162019Attachment

A-8Other DocumentsNEI 93-01, "lndustry Guideline for Monitoring the Effectiveness of Maintenance at NuclearPower Plants"NRC Letter, "Oyster Creek Nuclear Generating Station - lssuance of Amendment RE; Revisionto Mechanical Snubber FunctionalTest Requirements (TAC NO. MD8566)", datedOctober 10,2008VM-OC-0026, "Pacific Scientific Mechanical Snubbers Manual"VM-OC-0006, "Technical Maintenance Manualfor Hydraulic Shock and Sway Arrestors"Technical Specification 4.5.M, "Shock Suppressors (Snubbers)"lnformation Notice 94-48, "Snubber Lubricant Degradation in High-Temperature Environments"NEI 94-01, "NEl Industry Guideline for lmplementing Performance-Based Option of 10CFR Part50, Appendix JPacific Scientific letter, ""ln-Service" Testing of Pacific Scientific Shock Arrestors", datedSeptember 5,1984Basic-PSA, Inc. DR1319, "Mechanical Shock Arrestors Standard Design Specification"Basic-PSA, lnc. DR1320, "Mechanical Shock Arrestors Service Life Extension Program &Preventive Maintenance Recommendations"PS193, "lnstruction Manual Repair and Overhaul Mechanical Shock Arrestors"

==Section 1R13: Maintenance Risk Assessments and Emerqent Work GontrolProceduresER-M-600-1042, "On-line Risk Management"ER-AA-600-1021, "Risk Management Application Methodologies"ER-AA-600 -1 01 4, "Risk Management Configuration Control"ER-AA-600-1011, "Risk Management Program"WC-OC-101-1001, "On-line Risk Management and Assessment"Section 1 Rl 5: Operabilitv EvaluationsProceduresOP-M-1 08-1 1 5, "Operability Determination"CC-AA-309-1 01, "Engineering Technical Evaluations"ER-AA-330-004, "Visual Examination of Snubbers"310, "Containment Spray System Operation"636.4.002, "Diesel Generator No. 2 Automatic Actuation Test"604.4.016, "Torus to Drywell Vacuum Breaker Operability and In-Service Test"Condition Reports (lR)1138764

1138997

1145338 11408321139817

1139419

1139413 11394041145393

1145392

1145390

11453891

139815 1 1398191139393 11393451145387 112Q002Work Orders (AR)R2133261 A2057287 R2123655 A2260563Other Documentsf.tRC lnspeCtion Manual - Part 9900 Technical Guidance, "Operability Determinations &Functionality Assessments for Resolution of Degraded or Nonconforming ConditionsAdverse to Quality or Safety"MPR-2974, "Oyster Creek Nuclear Generating Station Torus Pitting Inspection EvaluationCriteria"MPR-953, "Oyster Creek Nuclear Generating Station Torus ShellThickness Margin"Attachment==

A-9UFSAR Table 6.2-10, "Containment Spray System Control and Instrumentation"SE 315403-018, "Safety Significance of Torus Spray Nozzle Blockage"C-1302-741-5350-001, "Loading of Emergency Diesel Generators and Unit Substations"UFSAR Chapter 6.2, "Containment Systems"

Section 1Rl8: Plant ModificationsProcedures101.2, "Fire Protection Program"LS-AA-128, "Regulatory Review of Proposed Changes to the Approved Fire ProtectionProgram"CC-AA-209, "Fire Protection Program Configuration Change Review"Condition Report (lR)1119356 1115667Work Order (AR)A2258869 4220918642218333OtherNFPA 15,2007 edition, "Standard for Water Spray Fixed Systems for Fire Protection"UFSAR 9.5.1, "Fire Protection Program"ECR 09-00573Section 1 R19: Post-Maintenance TestinqProceduresMA-AA-71

6-01 2, "Post Maintenance TestingOP-MA-1 09-1 01, "Clearance and Tagging"607.4.015, "Containment Spray and ESW System 2 Pump Operability, lST, and ContainmentSpray Pumps Trip"665.5.003, "Main Steam lsolation Valve Leak Rate Test"Condition Report (lR)1158113c20235011133544

1136887 825932984533

1138356 1137357Work Order (AR)R2162788 A2218728 A2263426R209403 R2142691 R2133416R2119989 R2133448 R2119989R21681751132417c2024694114376342259830 R2132957796399

912272 9527721139821

1139842 1139818A207993 R2094386 M2236053R2155457 R2162019 R2151915R2138066

C2024694 R2132348Drawings20451-H, "24in Globe Body MSIV w/Cyl Operator, Modification for Oyster Creek"BR 2002, "Main Steam System"OtherNEI 94-01, "NEl Industry Guideline for lmplementing Performance-Based Option of 1OCFR Part50, Appendix JAttachment

A-10

==Section 1R20: Refuelinq and Outaqe ActivitiesProcedures201, "Plant Startup"203, "Plant Shutdown"305, "Shutdown Cooling System Operation"OP-M-1 08-1 08, "Unit Restart RevieW'Condition Report (lR)113692011381241 13916111400621 1 3933411413741 1 36849115541011554221 1 3460011013351097285113646511386221 '14080011423901143220114544611544841 1

550371

3305921 1 39334109863410972871 1

383561 1 386201140079114298911407811145220115441811549541 1 33268113982110984931147123R21380661 1

386891 1 3859011391611 1 3983911431821143022115439111547441133745113981810978081 1

383801

1403311 1

388821 140319114311511370031 1 54389115404211425651139842109728111381261

1403351 140060114032111332471 1

369161 15531

111554541 1 3688711445521097283Work Order (AR)R2133486 R2060260Drawinqs1 12C37==

SS, "Penetration RP"R2132344 R2132345 42263006OtherOyster Creek Generating Station 1R23 Refueling Outage Shutdown Safety Plan, Revision

01141374-04, OTDM "Operating the B Low Pressure Turbine following Repair of 11 Cracks onBuckets following repairs of L-1 bucket indications"USNRC Letter, "Oyster Creek Nuclear Generating Station - lssuance of Amendment RE:Secondary Containment Boundary Definition During Shutdown Conditions (TAC

NO.ME3475", dated October 18,2010Exelon Letter, "Oyster Creek Nuclear Generating Station (OCNGS) NJPDES Discharge toSurface Water Permit No NJ0005550 Emergent Maintenance Activity", dated December19,2010Section 1 R22: Surveillance TestinqProceduresSA-AA-1 29, "Electrical Safety"MA-AA-1 000, "Conduct of Maintenance"602.4.002, "MSIV Closure and IST Test"602.4.005, "MSIV Closure and IST (<40o/o Power)"645.6.010, "SBO Transformer Deluge System #10 Functional Test"MA-AA-733-1001, "Guidance for Check Valve lnspections"619.2.019, "Rx Protection M-G Set Generator Output Breaker Trip Test and Calibration"Condition Reports (lR)1133544

1129497 1125710Attachment

Work Orders

(AR)A2263426 R2026637A-11A2214272 R2135571Drawinos20451-H, "24in Globe Body MSIV w/Cyl Operator, Modification for Oyster Creek"BR 2002, "Main Steam System"GE 885D781, "Core Spray System Flow Diagram"Other DocumentsNRC Inspection Manual Part 9900 Technical Guidance, "Maintenance- Preconditioning ofStructures, Systems, and Components Before Determining Operability"

Section RS01: Access Controlto Radioloqicallv Siqnificant AreasProceduresRP-M-1 1, "External Dose Control program Description"RP-AA-12, "lnternal Dose Control program Description"RP-AA-203, "Exposure Control and Authorization"RP-AA-201, "Access to

RCA for Escorted Visitors"RP-AA-4O1 -1 001, "On-line Dose Performance Threshold Reporting"RP-AA-4O1 -1Q02, "Radiological Risk Management"RP-AA-400-1007, "Elevated Dose rate Exposure Planning"RP-AB-460, "TlP Area Access Control"RP-M-460, "Control of High and Locked High Radiation Areas"RP-AA-460-001, "Control for Very High radiation Areas"RP-AA-460-002, "Additional High Radiation Exposure Control"233.2, "DrywellAccess and Control During Fuel Movement"RP-AA-462, "Controls for Radiographic Operation"RP-AA-463-1001, "Failed Fuel Surveillance Guidance"RP-AA-300, "Radiological Survey Program"RP-AA-503, "Unconditional Release Survey Method"RP-AA-800-001, "Nationally Tracked Source Program"Other DocumentsRadioactive Source Records 1A0096-5, JP71JQ7, JP11/JQ11Source Reconciliation Report and leak test dataGeneral Source Term DataBRAC point data (Oyster Creek Cycle 22 Dose Rate Projection)Oyster Creek Generating Station 2O10-2014, "Exposure Reduction Plan"ALARA Work In Progress ReviewsGeneral Employee Study Guide Rev. 35Radiation Work permits and ALARA plans -

RWP 402, 508, 511, 519, 602, 613Work In progress Reviews -

RWP 502, 506, 507, 508, 519

Section RS02: OccupationalALARA Planninq and ControlsProceduresRP-AA-1 1, "External Dose Control program Description"RP-M-12, "lnternal Dose Control program Description"RP-AA-203, "Exposure Control and Authorization"RP-AA-201, "Access to

RCA for Escorted Visitors"RP-AA-4O1 -1 001, "On-line Dose Performance Threshold Reporting"RP-AA-40 1 -1 002, "Rad iological Risk Management"Attachment

2RP-AA-4O1, "Operational ALARA Planning and Control"RP-AA-400-1007, "Elevated Dose rate Exposure Planning"RP-AB-460, "TlP Area Access Control"Procedure 233.2, "DrywellAccess and Control During Fuel Movement"Other DocumentsGeneral Source Term dataBRAC point data (Oyster Creek Cycle 22 Dose Rate Projection)Oyster Creek Generating Station 201-2014, Exposure Reduction PlanALARA Work In Progress ReviewsGeneral Employee Study Guide Rev. 35Radiation Work permits and ALARA plans -

RWP 402, 508, 511, 519, 602, 613Work ln progress Reviews -

RWP 502, 506, 507, 508, 519

Section RS03: ln-Plant Airborne Radioactivitv Control and MitiqationProceduresRP-AA-11, "External Dose Control program Description"RP-AA-12, "lnternal Dose Control program Description"RP-AA-203, "Exposure Control and Authorization"RP-AA-220, "Bioassay Program"RP-OC-220,-1001, "Operation of the Canberra Fastscan Whole Body Counting System"RP-AA-270, "Pre-natal radiation Exposure"6610-ADM-426.01, "Operation, Calibration and Quality Assurance of the CanberraWhole Body Counting System"RP-AA-4O1 -1002, "Radiological Risk Management"RP-AA-4O1, "Operational

ALARA Planning and Control"RP-AA-463-1001, "Failed Fuel Surveillance Guidance"RP-AA-300, "Radiological Survey Program"RP-AA-302, "Determination of Alpha Levels and Monitoring"RP-OC-3O1-1001, "Air Sample Collection and Analysis TRM"RP-AA-301, "Radiological Air Sampling Program"RP-AA-870-1OQ2, "Use of Vacuum Cleaners in Radiologically Controlled Areas"RP-AA-870-1001, "Setup and Operation of Portable Air Filtration Equipment"RP-OC-825-1002, "Use of Compressed Air for Supplied Air Respirato/'Other DocumentsAnnual Radiological Environmental, Effluent Release Reports- 2006, 2007,2008, 2009Offsite Dose Calculation Manual and changesGeneral Source Term dataALARA Work In Progress ReviewsGeneral Employee Study Guide Rev. 35Contamination Monitoring Instrument MatrixCalibration Records and procedures (PM-7-70244-7,701842;

PCM-1

700539; ARGOS 0912'1 66, 091 2-1 67;

SAM-70231 8, 702315)

Section RS04: Occupational Dose AssessmentProceduresRP-AA-11, "External Dose Control program Description"RP-AA-12, "lnternal Dose Control program Description"RP-AA-201, "Access to

RCA for Escorted Visitors"RP-AA-203, "Exposure Control and Authorization"Attachment

A-13RP-OC-203-1 001, "Administrative Control for Personnel"RP-AA-210, "Dosimetry lssue, Usage and Control"RP-AA-220, "Bioassay Program"RP-OC-220,-1001, "Operation of the Canberra Fastscan Whole Body Counting System"RP-AA-270, "Pre-natal Radiation Exposure"661O-ADM-426.01,"Operation, Calibration and Quality Assurance of the Canberra Whole BodyCounting System"RP-AA-401 -1002, "Radiological Risk Management"RP-AA-400-1007, "Elevated Dose rate Exposure Planning"RP-AA-463-1001, "Failed Fuel Surveillance Guidance"RP-AA-300, "Radiological Survey Program"RP-AA-302, "Determination of Alpha Levels and Monitoring"RP-OC-3O1-1001 , "Air Sample Collection and Analysis TRM"RP-AA-301, "Radiological Air Sampling Program"Other DocumentsExposure Controland Dose RecordsGeneral Source Term dataBRAC point data (Oyster Creek Cycle 22Dose Rate Projection)Oyster Creek Generating Station 201-2014, Exposure Reduction PlanALARA Work In Progress ReviewsGeneral Employee Study Guide Rev. 35Personnel Contamination Event LogsPersonnel Intake Investigations

Section RS05: Radiation Monitorinq lnstrumentationProceduresRP-OC-700-1601, "Calibration and Preventative Maintenance of Eberline Model

PCM-1,Personnel Contamination Monitor"RP-OC-7340, "Operation and Calibration of the Canberra

ARGOS-SAB personnelContamination Monitor"RP-OC-700-1601, "Calibration and Preventative Maintenance of Eberline Model

PCM-1Personnel Contamination Monitor "RP-OC-7040, "Calibration of the NE technology Model

SAM-9,11, Small Articles Monitor"RP-OC-220,-1O01, "Operation of the Canberra Fastscan Whole Body Counting System"RP-AA-270, "Pre-natal radiation Exposure"661g-ADM-426.O1,"Operation, Calibration and Quality Assurance of the Canberra Whole BodyCounting System"RP-AA-463-1001, "Failed Fuel Surveillance Guidance"RP-AA-300, "Radiological Survey Program"RP-AA-302, "Determination of Alpha Levels and Monitoring"RP-OC-3O1-1001, "Air Sample Collection and Analysis TRM"RP-AA-3O1, "Radiological Air Sampling Program"Other DocumentsGeneral Source Term dataBRAC point data (Oyster Creek Cycle 22 Dose Rate Projection)ALARA Work In Progress ReviewsGeneral Employee Study Guide Rev. 35Contamination Monitoring lnstrument MatrixAttachment

A-14Calibration Records and procedures (PM-7-70244-7,701842;

PCM-1

700539; ARGOS 0912-1 66, 091 2-167 ;

SAM-7023 18, 7 0231 5)

Section RS06: Radioactive Gaseous and Liquid Effluent TreatmentProceduresRP-AA-463-1 001, "Failed Fuel Surveillance Guidance"RP-AA-300, "Radiological Survey Program"RP-AA-302, "Determination of Alpha Levels and Monitoring"RP-OC-301-1001, "Air Sample Collection and Analysis

TRM"RP-AA-3O1, "Radiological Air Sampling Program"CY-OC-1 20-1 103, "Radioactive Effluent Sample and Analysis Schedule"SP10-003, "Well 73, Pump and Sample Point Operation"CY-OC- 1 20-7 06, "G roundwater Remed iation Process sam ple Collection"CY-AA-1 1 0-200, "Sampling"Other DocumentsAnnual Radiological Environmental, Effluent Release Reports- 2006, 2007,2008, 2009Offsite Dose Calculation Manual10

CFR 50.75(9) - History file record summary/additionsReports (various) - Routine Ground WaterReport- Hydrogeology Investigation ReportGeneral Source Term DataContamination Monitoring Instrument MatrixGroundwater Sample Batch Analyses and Calculations

Section 4OA1: Performance Indicator (Bl) VerificationProceduresRP-M-203, "Exposure Control and Authorization"RP-AA-201, "Access to

RCA for Escorted Visitors"RP-AA-460, "Control of High and Locked High Radiation Areas"RP-AA-460-001, "Control for Very High radiation Areas"RP-AA-460-002, "Additional High Radiation Exposure Control"Procedure 233.2, "DrywellAccess and Control During Fuel Movement"RP-M-462, "Controls for Radiographic Operation"RP-AA-463-1001, "Failed Fuel Surveillance Guidance"ER-AA-2008, "Mitigating Systems Performance Index (MSPI) Failure Determination Evaluation"ER-M-600 -1047, "Mitigating Systems Performance I ndex Basis Document"LS-AA-2200, "Mitigating Systems Performance lndex Data Acquisition and Reports"OC-MSPI-O1, "Oyster Creek MSPI Basis Document"Condition Reports (lR)1135742 11360861139170 11404291145430

11465411

138485

1136114 1

139146 11391471140498

1143369

1143878 1145288Other DocumentsNEI 99-02, "Regulatory Assessment Performance Indicator Guideline"Annual Radiological Environmental, Effluent Release Reports- 2006, 2007,2008,

20092010 Public Dose Projections (Liquid, Gaseous)Offsite Dose Calculation Manual and changesTrain Unavailability Report (October 1 , 20Og through September 30, 2010)Attachment

A-15

==Section 4OA2: ldentification and Resolution of ProblemsProceduresOP-AA- 1 02-1 03, "Operator Work Arou nd Prog ram"OP-AA-102-103-1001 , "Operator Burden and Plant Significant Decision lmpact AssessmentProgram"OP-AA-1 02-1 03-F-01, "Operator Burden Aggregate Assessment Form"OP-AA-108-1 1 1, "Adverse Condition Monitoring and Contingency Planning"604.4.015, "Reactor Building to Torus Power Vacuum Breaker Check"Condition Reports (lR)1142958

914659 9174841125902

1126953 11269551133910

1134122 11342571135542

1135859 11362321113746

1137835 11389729124218

873482 11348461127560

1128430 11338011134516

1135537 11355401137384

1137451 11374551137429

1138259 10865899411781 1 39483Work Orders (AR)R2113884

C2021164

C2024491 A2211046 A2019573 A2223977Section 4OA3: Event FollowupProceduresABN-2, "Recirculation System Failures"ABN-47, "Loss of==

USS 181"632.2.002, "Grid UV Channel FunctionalTest"NF-AA-430, "Failed Fuel Action Plan"CY-OC-1 30-501, "Operations of Seeds Software"CY-OC-120-940, "Drywell Atmosphere Analysis and CAPGRMS Sampling"CY-OC-1 70-2001, "Quality Control for radioactive Effluents"CY-AB- 1 20-1 00, "Reactor water Chem istry"CY-AB-1 20-340, "Off-gas Chemistry"CY-AB-1 20-0001, "Chemistry Action Level lmpact Assessments, Engineering Evaluationand Clean-up Projection"406.8, "Operation of the Stack RAGEMS"406.2, "Operation of the Process Radiation Monitoring System"31 2.9, "Primary Containment Control"RP-AA-463-1001, "Failed Fuel Surveillance Guidance"RP-AA-300, "Radiological Survey Program"RP-AA-302, "Determination of Alpha Levels and Monitoring"RP-OC-3O1-1001, "Air Sample Collection and Analysis TRM"RP-AA-301," Radiological Air Sampling Program"Condition Reports (lR)1152255

1123363

1147123

1146755

1123402 11234931123503

1123514

1123516

1123423

1154389 11259021126953

1126955

1127560

1128430

1133801 11339101134122

1134257

1134516

1135537

1135540 11355421135859

1136232

1137384

1137451

1137455 11137461137835

1138972

1137429 1138259Attachment

A-16Work Orders (AR)R2169623Other DocumentsNUREG-1 022, "Event Reporting Guidelines 10

CFR 50.72 and 50.73"NRC Enforcement Policy, dated September 30, 2010ENS 46315Exelon letter, "Licensee Event Report (LER) 2010-001-00, "Unexpected trip of the 1 D 4106Vbreake/', dated December 17,2010Exelon

Memorandum, "Oyster Creek Generating Station,

12101110, Notice of Unusual EventReport", dated December 29,2010Oyster Creek Operations Log, dated December 1,2010Oyster Creek Outage Control Center Log, dated December 1,2010Event Notice 46443Annual Radiological Environmental, Effluent Release Reports- 2006, 2007,2008, 2009Offsite Dose Calculation Manualand changes10

CFR 50.75(g) - History file record summary/additionsStack Input Monitoring MatrixGeneral Source Term dataRAGEMS Flow DiagramEffluent Release and Purge CalculationsComplex Trouble Shooting PlanFailure Mode Causal table

Section 4OA5: OtherProcedures681.4.004, "Technical Specification Log Sheet"Other DocumentsRadiological Surveys -

ISFSITemperature and Screen Surveillance Monitoring DataCondition Reports (lR)828338

828327 8904531086111

1086111 7259431149074 11372591053875138293200175833310027951113908Attachment

ABNACACEADAMSALARAANSAPRMARMASMEATWSBWRBWRVIPCAMCAPCDFCEDECFRCRCRDCSDACDEPDMWEACEEALECREDEDEXEDGEMRVENSEOFEOPEPEPDEPRIEQEROESWExelonFEMAFINFWFZGEGLGPIGPUHCUA-17

LIST OF ACRONYMS

Abnormal Operating ProcedureAlternating CurrentApparent Cause EvaluationAgency-wide Documents Access and Management SystemAs Low As Reasonably AchievableAlert and Notification SystemAverage Power Range MonitorArea radiation MonitorAmerican Society of Mechanical EngineersAnticipated Transient Without ScramBoiling Water ReactorBoiling Water Reactor Vessel Internals ProjectContinuous Air MonitorsCorrective Action ProgramCore Damage FrequencyCommitted Effective Dose EquivalentCode of Federal RegulationsCondition ReportControl Rod DriveCore SprayDerived Air ConcentrationDrill and Exercise PerformanceDissimilar metalweldEquipment Apparent Cause EvaluationEmergency Action LevelEngineering Change RequestElectronic DosimeterEffective Dose Equivalent for External ExposureEmergency Diesel GeneratorElectromatic Relief ValveEmergency Notification SystemEmergency Operations FacilityEmergency Operating ProcedureEmergency Prepared nessElectronic Personal DosimetryElectric Power Research lnstituteEnvironmental QualificationEmergency Response OrganizationEmergency Service WaterExelon Energy Company, LLCFederal Emergency Management AgencyFindingFeedwaterFire ZoneGeneral ElectricGeneric LetterGroundwater Protection I nitiativeGeneral Public UtilitiesHydraulic Control UnitAttachment

A-18HELB High Energy Line BreakHEPA High Efficiency Particulate AirHRA High Radiation AreaHVAC Heating Ventilation and Air Conditioningl&C Instrumentation and ControllC lsolation CondenserIGSCC Inter Granular Stress Corrosion CrackingIMC Inspection Manual ChapterIPEEE lndividual Plant Examination for External EventslR lssue ReportIRM lntermediate Range MonitorISFSI lndependent Spent Fuel Storage lnstallationlsl ln Service InspectionISLOCA Interfacing System Loss of Coolant AccidentIST Inservice TestJCPL Jersey Central Power and LightLDE Lens Dose EquivalentLER License Event ReportLLC Limited Liability CompanyLOCA Loss of Coolant AccidentMCC Motor Control CenterMDA Minimum Detectable ActivityMG Motor GeneratorMSHA Mine Safety and Health AdministrationMSPI Mitigating Systems Performance IndexMT Magnetic Particle TestingNCV Non Cited ViolationNDE Non Destructive ExaminationNEI Nuclear Energy InstituteNIOSH National lnstitute for Occupational Safety and HealthNIST National lnstitute of Standards TechnologyNRC Nuclear Regulatory CommissionNUREG

NRC technical report designation (Nuclear Requlatory Commission)

NVLAP National Laboratory Accreditation ProgramOB Office BuildingODCM Offsite Dose Calculation ManualOSC Operations Support CenterOWA Operator WorkaroundsOyster Creek Oyster Creek Generating StationPARS Publicly Available RecordsPCM Personnel Contamination MonitorsPCP Process Control ProgramPDI Performance Demonstration lnitiativePl Performance IndicatorPl&R Problem ldentification and ResolutionPM Portal MonitorsPORC Plant Onsite Review CommitteePPC Process Plant ComputerPT Penetrant TestingRAGEMS Radioactive Gaseous Effluent Monitoring SystemRB Reactor BuildingAttachment

RBCCWR [[CARCSRCSARCSLREMPRP&CRPMRPSRSRSPSRTRWPSAMSDCSDPSGTSSJAESLCSRMT&RMTBTBCCWTCCPTEDETLDTSTSCTYRAUFSARUILRURIUTVDCVHRAVLCVTWBCWOA-19Reactor Building Closed Cooling WaterRadiological Controlled AreaReactor Coolant SystemReactor Coolant System ActivityReactor Coolant System ldentified Leak RateRadiological Environmental Monitoring ProgramRadiological Protection and ChemistryRadiation Protection ManagerReactor Protection SystemRadiation SafetyRisk Significant Planning StandardRadiographic TestingRadiation Work PermitSmallArticle MonitorsShutdown CoolingSignificance Determination ProcessStandby Gas Treatment SystemSteam Jet Air EjectorStandby Liquid ControlSource Range MonitorTraining & Reference MaterialTurbine BuildingTurbine Building Closed Cooling WaterTemporary Configuration Change PackageTotal Effective Dose EquivalentThermoluminescent DosimeterTech nical SpecificationsTechnical Support CenterThree Year Rolling AverageUpdated Final Safety Analysis ReportUnidentified Leak RateUnresolved ltemUltrasonic TestingVoltage Direct CurrentVery High Radiation AreaVoltage Level ControlVisualTestingWhole Body CounterWork OrderAttachment]]