IR 05000219/2013002
| ML13119A046 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/29/2013 |
| From: | Hunegs G NRC/RGN-I/DRP/PB6 |
| To: | Pacilio M Exelon Nuclear |
| HUNEGS, GK | |
| References | |
| IR-13-002 | |
| Download: ML13119A046 (32) | |
Text
April 29, 2013
SUBJECT:
OYSTER CREEK GENERATING STATION - NRC INTEGRATED INSPECTION REPORT 05000219/2013002
Dear Mr. Pacilio:
On March 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Oyster Creek Generating Station. The enclosed inspection report documents the inspection results, which were discussed on April 18, 2013 with Mr. G. Stathes, Oyster Creek Site Vice President, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
This report documents one NRC-identified finding of very low safety significance (Green) which was determined to involve a violation of NRC requirements. Additionally, a licensee-identified violation, which was determined to be of very low safety significance, is listed in this report.
However, because of the very low safety significance, and because they are entered into your corrective action program, the NRC is treating these findings as non-cited violations (NCVs),
consistent with Section 2.3.2 of the NRC Enforcement Policy. If you contest any NCVs in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk, Washington, DC 20555-0001; with copies to the Regional Administrator, Region I; the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001; and the NRC Resident Inspectors at Oyster Creek. In addition, if you disagree with the cross-cutting aspect assigned to any finding in this report, you should provide a response within 30 days of the date of this inspection report, with the basis for your disagreement, to the Regional Administrator, Region I, and the NRC Resident Inspectors at Oyster Creek. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of the NRCs document system (ADAMS). ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Gordon K. Hunegs, Chief Reactor Projects Branch 6 Division of Reactor Projects
Docket Nos.: 50-219 License Nos.: DPR-16
Enclosure:
Inspection Report 05000219/2013002
w/Attachment: Supplementary Information
REGION I==
Docket No.:
50-219
License No.:
Report No.:
Licensee:
Exelon Nuclear
Facility:
Oyster Creek Generating Station
Location:
Forked River, New Jersey
Dates:
January 1, 2013 - March 31, 2013
Inspectors:
J. Kulp, Senior Resident Inspector A. Patel, Resident Inspector W. Schmidt, Senior Reactor Analyst D. Spindler, Senior Resident Inspector (Beaver Valley)
J. Richmond, Senior Reactor Inspector T. Hedigan, Operations Engineer T. OHara, Reactor Inspector A. Dugandzic, Project Engineer B. Dionne, Health Physicist
Approved By:
Gordon Hunegs, Chief
Reactor Projects Branch 6
Division of Reactor Projects
Enclosure
SUMMARY OF FINDINGS
IR 05000219/2013002, 01/01/2013 - 03/31/2013; Exelon Energy Company, LLC (Exelon),
Oyster Creek Generating Station; Operability Determinations and Functionality assessments.
This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors. Inspectors identified one finding of very low safety significance (Green), which was a non-cited violation (NCV). The significance of most findings is indicated by their color (Green, White, Yellow, Red) using Inspection Manual Chapter (IMC) 0609, Significance Determination Process (SDP). The cross-cutting aspects for the findings were determined using IMC 0310, Components Within Cross-Cutting Areas. All violations of NRC requirements are dispositioned in accordance with the NRCs Enforcement Policy, dated January 28, 2013. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process,
Revision 4, dated December 2006.
Cornerstone: Mitigating Systems
- Green.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI,
"Corrective Action," when Exelon did not promptly identify or correct a condition adverse to quality. Specifically, Exelon did not identify and correct misaligned flanges between the D emergency service water pump and the associated discharge pipe during inspection activities in 2008 and subsequent maintenance activities in 2013. The misalignment of the flanges caused the expansion joint being installed in a configuration which exceeded design criteria of the emergency service water pump. Exelon entered this issue into the corrective action program for resolution as issue report (IR)1481670.
This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective to ensure the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. This issue was also similar to Example 3j of NRC IMC 0612,
Appendix EProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0612,</br></br>Appendix E" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Examples of Minor Issues, because the condition resulted in reasonable doubt of the operability of emergency service water system and additional analysis was necessary to verify operability. The inspectors evaluated the finding using IMC 0609,
Appendix AProperty "Inspection Manual Chapter" (as page type) with input value "NRC Inspection Manual 0609,</br></br>Appendix A" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., and determined this finding was a deficiency affecting the design or qualification of a mitigating SSC, where the SSC maintained its operability or functionality.
Therefore, inspectors determined the finding to be of very low safety significance (Green).
This finding has a cross-cutting aspect in the area of Problem Identification and Resolution,
Corrective Action Program, because Exelon did not identify the issue associated with the non-conforming emergency service water expansion joint in a timely manner P.1(a).
(Section 1R15)
Other Findings
A violation of very low safety significance that was identified by Exelon was reviewed by the inspectors. Corrective actions taken or planned by Exelon have been entered into Exelons corrective action program. This violation and corrective action tracking number are listed in Section 4OA7 of this report.
REPORT DETAILS
Summary of Plant Status
Oyster Creek began the inspection period at 100 percent power. On January 5, 2013, operators reduced power to 60 percent to support planned corrective maintenance in the condenser bay and a rod pattern adjustment. Operators returned the plant to 100 percent power the following day. On March 2, 2013, operators reduced power to 60 percent to support planned corrective maintenance in the condenser bay, repair the B feedwater regulating valve, remove the B loop recirculation pump motor generator set from service for maintenance and perform a rod pattern adjustment. Operators returned the plant to 100 percent power the following day. Oyster Creek remained at or near 100 percent power for the remainder of the inspection period.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
1R01 Adverse Weather Protection
.1 Readiness for Impending Adverse Weather Conditions
a. Inspection Scope
The inspectors reviewed Exelons response to a cold weather alert issued by the grid operator for the period of January 23 - 24, 2013 and a winter storm warning for February 8, 2013. The inspectors verified that Exelon implemented their cold weather procedures and that operators monitored plant equipment that could have been affected by the cold weather conditions. The inspectors performed walkdowns to verify that temperatures for equipment and areas in the plant were maintained within procedural limits, and when necessary, compensatory actions were properly implemented in accordance with procedures.
The inspectors reviewed Exelons response to a high wind warning issued by the National Weather Service for the period of January 30 - 31, 2013. The inspectors verified that Exelon implemented its adverse weather procedures and that operators reviewed applicable emergency procedures and performed procedural briefs for the expected adverse weather conditions. The inspectors performed independent walkdowns of the site to verify the site was ready for the onset of adverse weather.
b. Findings
No findings were identified.
==1R04 Equipment Alignment
==
.1 Partial System Walkdowns
a. Inspection Scope
The inspectors performed partial walkdowns of the following systems:
B main control room heating ventilation and air conditioning system while the A main control room heating ventilation and air conditioning system was inoperable for planned maintenance on January 7, 2013
B isolation condenser while the A isolation condenser was inoperable for planned surveillance on January 8, 2013
B standby liquid control system while the A standby liquid control system was inoperable for corrective maintenance on January 8, 2013
Containment spray system I while containment spray system II was inoperable for preventive maintenance on January 14, 2013
Emergency service water system I while emergency service water system II was inoperable for preventive maintenance on January 15, 2013
The inspectors selected these systems based on their risk-significance relative to the reactor safety cornerstones at the time they were inspected. The inspectors reviewed applicable operating procedures, system diagrams, the updated final safety analysis report (UFSAR), technical specifications, work orders, condition reports, and the impact of ongoing work activities on redundant trains of equipment in order to identify conditions that could have impacted system performance of their intended safety functions. The inspectors also performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and were operable.
The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. The inspectors also reviewed whether Exelon staff had properly identified equipment issues and entered them into the corrective action program for resolution with the appropriate significance characterization.
b. Findings
No findings were identified.
.2 Full System Walkdown
a. Inspection Scope
On March 25 and 26, 2013, the inspectors performed a complete system walkdown of accessible portions of the standby liquid control system to verify the existing equipment lineup was correct. The inspectors reviewed operating procedures, surveillance tests, drawings, equipment check-off lists, and the UFSAR to verify the system was aligned to perform its required safety functions. The inspectors also reviewed electrical power availability, component lubrication and equipment cooling, hangar and support functionality, and operability of support systems. The inspectors performed field walkdowns of accessible portions of the systems to verify system components and support equipment were aligned correctly and operable. The inspectors examined the material condition of the components and observed operating parameters of equipment to verify that there were no deficiencies. Additionally, the inspectors reviewed a sample of related condition reports and work orders to ensure Exelon appropriately evaluated and resolved any deficiencies.
b. Findings
No findings were identified.
==1R05 Fire Protection
==
.1 Resident Inspector Quarterly Walkdowns
a. Inspection Scope
The inspectors conducted tours of the areas listed below to assess the material condition and operational status of fire protection features. The inspectors verified that Exelon controlled combustible materials and ignition sources in accordance with administrative procedures. The inspectors verified that fire protection and suppression equipment was available for use as specified in the area pre-fire plan, and passive fire barriers were maintained in good material condition. The inspectors also verified that station personnel implemented compensatory measures for out of service, degraded, or inoperable fire protection equipment, as applicable, in accordance with procedures.
Cable spreading room (OB-FZ-22A) on January 7, 2013
Reactor Building (RB-FZ-1B, 95 Elevation) on March 5, 2013
Turbine Building Mezzanine South (TB-FZ-11G, 23 Elevation) on March 5, 2013
Reactor Building (RB-FZ-1F3, -196 & -1-11) on March 12, 2013
Reactor Building (RB-FZ-1F4, -196) on March 13, 2013
b. Findings
No findings were identified.
1R07 Heat Sink Performance
a. Inspection Scope
The inspectors reviewed the containment spray system II heat exchangers to determine its readiness and availability to perform their safety function. The inspectors reviewed the design basis for the components and verified Exelons commitments to NRC Generic Letter 89-13. The inspectors reviewed the results of previous inspections of the containment spray system II heat exchangers. The inspectors discussed the results of the most recent inspection with engineering staff including the as-found and as-left conditions. The inspectors verified that Exelon initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that the number of tubes plugged within the heat exchanger did not exceed the maximum number allowed.
The inspectors reviewed the reactor building closed cooling water heat exchangers to determine its readiness and availability to perform its safety functions. The inspectors reviewed the design basis for the components and verified Exelons commitments to NRC Generic Letter 89-13. The inspectors reviewed the results of previous inspections of the reactor building closed cooling water heat exchangers. The inspectors discussed the results of the most recent inspection with engineering staff including the as-found and as-left conditions. The inspectors verified that Exelon initiated appropriate corrective actions for identified deficiencies. The inspectors also verified that no tube plugs were installed.
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification Program
.1 Quarterly Review of Licensed Operator Requalification Testing and Training
a. Inspection Scope
The inspectors observed a licensed operator simulator training scenario involving a manual reactor scram after a simulated security event, on January 16, 2013. The inspectors evaluated operator performance during the simulated event and verified completion of risk significant operator actions, including the use of abnormal and emergency operating procedures. The inspectors assessed the clarity and effectiveness of communications, implementation of actions in response to alarms and degrading plant conditions, and the oversight and direction provided by the control room supervisor. The inspectors verified the accuracy and timeliness of the emergency classification made by the shift manager and the technical specification action statements entered by the shift technical advisor. Additionally, the inspectors assessed the ability of the crew and training staff to identify and document crew performance issues.
b. Findings
No findings were identified.
.2 Quarterly Review of Licensed Operator Performance in the Main Control Room
a. Inspection Scope
The inspectors observed operators during feedwater string flow balancing and return to rated power evolutions on January 3, 2013. The inspectors observed infrequently performed test or evolution briefings, pre-shift briefings, and reactivity control briefings to verify that the briefings met the criteria specified in Exelon briefing and human performance procedures. Additionally, the inspectors observed crew performance to verify that procedure use, communications, and coordination of activities met established expectations and standards.
b. Findings
No findings were identified.
1R12 Maintenance Effectiveness
a. Inspection Scope
The inspectors reviewed the sample listed below to assess the effectiveness of maintenance activities on system, structure or component performance and reliability.
The inspectors reviewed system health reports, corrective action program documents, maintenance work orders, and maintenance rule basis documents to ensure that Exelon was identifying and properly evaluating performance problems within the scope of the maintenance rule. For the sample selected, the inspectors verified that the system, structure or component was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2) performance criteria established by Exelon staff was reasonable. As applicable, for systems, structures or components (SSCs)classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these systems, structures or components to (a)(2). Additionally, the inspectors ensured that Exelon staff was identifying and addressing common cause failures that occurred within and across maintenance rule system boundaries.
B control room heating, ventilation and air conditioning inoperability (IR 1452636) on January 24, 2013
b. Findings
No findings were identified.
1R13 Maintenance Risk Assessments and Emergent Work Control
a. Inspection Scope
The inspectors reviewed station evaluation and management of plant risk for the maintenance and emergent work activities listed below to verify that Exelon performed the appropriate risk assessments prior to removing equipment for work. The inspectors selected these activities based on potential risk significance relative to the reactor safety cornerstones. As applicable for each activity, the inspectors verified that Exelon personnel performed risk assessments as required by 10 CFR 50.65(a)(4) and that the assessments were accurate and complete. When Exelon performed emergent work, the inspectors verified that operations personnel promptly assessed and managed plant risk.
The inspectors reviewed the scope of maintenance work and discussed the results of the assessment with the stations probabilistic risk analyst to verify plant conditions were consistent with the risk assessment. The inspectors also reviewed the technical specification requirements and inspected portions of redundant safety systems, when applicable, to verify risk analysis assumptions were valid and applicable requirements were met.
B isolation condenser out of service for valve cycling and S-2045 offsite power line unavailable for maintenance on January 3, 2013
A standby liquid control system and A isolation condenser unavailable for planned maintenance on January 8, 2013
Emergency service water system II and containment spray system II unavailable for planned maintenance on January 15-16, 2013
Containment spray system I unavailable for planned maintenance on January 22, 2013
A isolation condenser and emergency service water system II unavailable for planned maintenance on January 23, 2013
Turbine building closed cooling water heat exchanger 1-2 and circulating water pump 1-4 unavailable for planned maintenance on March 26, 2013
b. Findings
No findings were identified.
1R15 Operability Determinations and Functionality Assessments
a. Inspection Scope
The inspectors reviewed operability determinations for the following degraded or non-conforming conditions:
D electromatic relief valve accident instrument operability due to failed thermocouple (IR 1460383) on January 11, 2013
Increasing trend in drywell air temperatures (IR 1464943) on January 22-23, 2013
N1A nozzle indication (IR 1465637) on January 23, 2013
Scram contactor open (G-1-C) alarm failed to clear after resetting a half scram during testing (IR 1473196) on February 9, 2013
D emergency service water pump expansion joint misalignment (IR 1481670) on March 1, 2013
Non-conservative acceptance criteria for standby gas treatment system isolation valves, V-28-21 and V-28-22, (IR 1469105) on March 17, 2013
Emergency diesel generator #2 after low battery charger current was identified (IR 1488751) on March 18, 2013 The inspectors selected these issues based on the risk significance of the associated components and systems. The inspectors evaluated the technical adequacy of the operability determinations to assess whether technical specification operability was properly justified and the subject component or system remained available such that no unrecognized increase in risk occurred. The inspectors compared the operability and design criteria in the appropriate sections of the technical specifications and UFSAR to Exelons evaluations to determine whether the components or systems were operable.
Where compensatory measures were required to maintain operability, the inspectors determined whether the measures in place would function as intended and were properly controlled by Exelon. The inspectors determined, where appropriate, compliance with bounding limitations associated with the evaluations.
b. Findings
Introduction.
The inspectors identified a Green NCV of 10 CFR 50, Appendix B, Criterion XVI, "Corrective Action," because Exelon did not promptly identify or correct a condition adverse to quality. Specifically, Exelon did not identify and correct misaligned flanges between the D emergency service water pump and the associated discharge pipe during inspection activities in 2008 and during maintenance activities in 2013.
Description.
On February 28, 2013, inspectors conducted a walk down of the D emergency service water pump following its replacement and system reassembly on February 27, 2013. The inspectors noted that a significant misalignment existed between the D emergency service water pump flange and the discharge piping flange.
An expansion joint is installed between the two flanges to account for minor piping misalignments and thermal expansion. The inspectors further noted that the expansion joint was contorted and may have been installed in a configuration that exceeded the manufacturers tolerances. The inspectors identified the issue to Exelon and it was entered into the corrective action program as IR 1481670. Although the pump had not been returned to operability following the maintenance, Exelon operators declared the D emergency service water pump inoperable based upon the conditions caused by the observed misalignment. At the time of the walkdown, Exelon staff had removed maintenance tags and was preparing to perform the post maintenance and surveillance test to return the system to service. The inspectors concluded that the post maintenance and surveillance testing would have identified leakage at the flange - expansion joint interface or a failed expansion joint. However, the inspectors concluded these tests would not have likely identified a latent system integrity condition caused by the misalignment.
On March 1, 2013, Exelon completed an operability evaluation which concluded that although the displacement of the expansion joint was in excess of the manufacturers acceptance criteria, further evaluation and calculations determined that the emergency service water pump, piping and expansion joint were operable and could still perform their design functions. Exelon staff performed the post maintenance and surveillance tests on March 1, 2013 and returned the emergency service water system to service.
Exelons evaluation further indicated that the cause of the misalignment was a misaligned flange on a piping spoolpiece which was installed in 2006. The 2006 work order completion comments did not indicate a flange misalignment and no issue report was submitted to document that the flanges were misaligned or that the expansion joint was stressed. The expansion joint was inspected by station personnel in 2008 as part of a 6-year preventive maintenance action. A printout of the work order from Exelons electronic maintenance management system for the 2008 preventive maintenance inspection did not document degradation. The NRC inspectors identified that the original work package from the 2008 inspection with an Exelon inspectors written notations identified that the flange was misaligned and that the expansion joint bellows were flattened, both of which would have required more analysis to show that the joint was installed in an acceptable manner. The NRC inspectors noted that a transcription error took place between the handwritten work package and the electronic system. No issue report was submitted by station personnel to document the deficiencies noted in 2008.
The inspectors determined the misalignment of the piping was a nonconformance because it was a condition where the construction of the pipe reduced the quality of the system as it caused the design parameters of the expansion joint to be exceeded.
Further, the inspectors determined that the inspection and maintenance activities in 2008 and 2013 were both reasonable opportunities for Exelon staff to have identified the non-conformance in the corrective action program for resolution consistent with guidance in Exelon procedure LS-AA-125 Corrective Action Program (CAP) Procedure, and LS-AA-120, Issue Identification and Screening Process.
Analysis.
The inspectors determined that inadequate identification and resolution of the condition adverse to quality into the corrective action program is a performance deficiency that was within Exelons ability to foresee and correct. This finding is more than minor because it is associated with the design control attribute of the Mitigating Systems cornerstone and affected the cornerstone objective of ensuring the availability, reliability and capability of systems that respond to initiating events to prevent undesirable consequences. Specifically, the performance deficiency affected the reliability of an emergency service water pump to perform its safety function during a seismic event. This issue was also similar to Example 3j of NRC IMC 0612, Appendix E, Examples of Minor Issues, because the condition resulted in reasonable doubt of the operability of emergency service water system II and additional analysis was necessary to verify operability.
The inspectors evaluated the finding using exhibit 2, "Mitigating System Screening Questions" in Appendix A to IMC 0609, "Significance Determination Process." The inspectors determined that this finding was a deficiency affecting the design or qualification of a mitigating SSC, where the SSC maintained its operability or functionality. Therefore, inspectors determined the finding to be of very low safety significance (Green). The finding has a cross-cutting aspect in the area of Problem Identification and Resolution, Corrective Action Program, because Exelon did not identify the issue associated with the non-conforming emergency service water expansion joint in a timely manner in 2008 and 2013 P.1(a).
Enforcement.
10 CFR 50, Appendix B, Criterion XVI, Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected. Contrary to the above, Exelon did not identify or correct the condition adverse to quality regarding the misaligned flanges during inspection activities in 2008 or during maintenance activities in 2013. Specifically, Exelon maintenance and inspection personnel did not identify that the misaligned flanges caused an expansion joint to be installed in excess of the tolerances specified by the manufacturer and challenged the operability of the system.
Because this issue is of very low safety significance (Green) and Exelon entered this issue into their corrective action program as IR 1481670, this finding is being treated as an NCV consistent with the NRC Enforcement Policy. (NCV 05000219/2013002*01, Emergency service water non-conformance not identified in the corrective action program)
1R18 Plant Modifications
.1 Temporary Modifications
a. Inspection Scope
The inspectors reviewed the temporary modification listed below to determine whether the modification affected the safety functions of a system that is important to safety. The inspectors reviewed 10 CFR 50.59 documentation and post-modification testing results, and conducted field walkdowns of the modifications to verify that the temporary modifications did not degrade the design bases, licensing bases, and performance capability of the affected systems.
Drywell ventilation supply valve (V-28-42) placed in closed position
b. Findings
No findings were identified.
.2 Permanent Modifications
a. Inspection Scope
The inspectors evaluated a modification to the 34.5 KV switchyard breakers implemented by engineering change package 11-00362, JCP&L 34.5 kV Breaker Failure Relay Addition. The inspectors verified that the design bases, licensing bases, and performance capability of the affected systems were not degraded by the modification. In addition, the inspectors reviewed modification documents associated with the upgrade and design change, including installing additional tripping schemes to all 34.5 kV breakers and providing additional signals to lockout relays to prevent unnecessary tripping of both A and B 34.5kV buses.
b. Findings
No findings were identified.
1R19 Post-Maintenance Testing
a. Inspection Scope
The inspectors reviewed the post-maintenance tests for the maintenance activities listed below to verify that procedures and test activities ensured system operability and functional capability. The inspectors reviewed the test procedure to verify that the procedure adequately tested the safety functions that may have been affected by the maintenance activity, that the acceptance criteria in the procedure was consistent with the information in the applicable licensing basis and/or design basis documents, and that the procedure had been properly reviewed and approved. The inspectors also witnessed the test or reviewed test data to verify that the test results adequately demonstrated restoration of the affected safety functions.
A standby liquid control system after accumulator valve V-19-54 replacement (C2028431) on January 9, 2013
V-14-30 following stem lubrication and packing adjustment (R2170039) on January 9, 2013
V-3-84 and V-3-85 valve replacement (R2191763) on January 17, 2013
Emergency service water pump #2 motor after motor louver and gasket replacement (R2195853) on January 24, 2013
2K52A contactor burnishing to correct scram contactor open (G-1-C) alarm failing to clear following reset of a half scram during testing on February 11, 2013
Remove/Replace emergency service water pump (P-3-3D) and motor (R0805387)on March 1, 2013
Findings
No findings were identified.
1R22 Surveillance Testing
a. Inspection Scope
The inspectors observed performance of surveillance tests and/or reviewed test data of selected risk-significant SSCs to assess whether test results satisfied technical specifications, the UFSAR, and Exelon procedure requirements. The inspectors verified that test acceptance criteria were clear, tests demonstrated operational readiness and were consistent with design documentation, test instrumentation had current calibrations and the range and accuracy for the application, tests were performed as written, and applicable test prerequisites were satisfied. Upon test completion, the inspectors considered whether the test results supported that equipment was capable of performing the required safety functions. The inspectors reviewed the following surveillance tests:
609.4.001, Isolation condenser valve operability and in-service test on January 2, 2013
612.4.001, Standby liquid control pump A and valve operability and in-service test on January 8, 2013
617.4.001, Control rod drive pump B operability test on January 14, 2013
607.4.017, Containment spray and emergency service water pump system #2 operability and quarterly in-service test on January 17, 2013
636.4.003, Emergency diesel generator #1 operability test on January 22, 2013
642.4.001, Reactor building closed cooling water system in-service test on January 23, 2013
610.4.012, Core spray system #1 pump comprehensive/pre-service in-service test on February 21, 2013
Unidentified leak rate - Post 1R24 refueling outage on March 18, 2013
b. Findings
No findings were identified.
Cornerstone: Emergency Preparedness
1EP4 Emergency Action Level and Emergency Plan Changes (IP
71114.04 - 1 sample)
a. Inspection Scope
NRC staff from the Office of Nuclear Security and Incident Response performed an in-office review of the latest revisions of various emergency plan implementing procedures and the emergency plan located under ADAMS accession numbers ML123260651 and ML130180297 as listed in the attachment.
The licensee determined that in accordance with 10 CFR 50.54(q), the changes made in the revisions resulted in no reduction in the effectiveness of the emergency plan, and that the revised emergency plan continued to meet the requirements of 10 CFR 50.47(b)and Appendix E to 10 CFR Part 50. The NRC review was not documented in a safety evaluation report and did not constitute approval of licensee-generated changes; therefore, this revision is subject to future inspection. The specific documents reviewed during this inspection are listed in the attachment.
b. Findings
No findings were identified.
1EP6 Drill Evaluation
.1 Training Observations
a. Inspection Scope
The inspectors observed simulator training scenario for licensed operators on March 14, 2013 which required emergency plan implementation by an operations crew. Exelon planned for this evolution to be evaluated and included in performance indicator data regarding drill and exercise performance. The inspectors observed event classification and notification activities performed by the crew. The inspectors also attended the post-evolution critique for the scenario. The focus of the inspectors activities was to note any weaknesses and deficiencies in the crews performance and ensure that Exelon evaluators noted the same issues and entered them into the corrective action program.
b. Findings
No findings were identified.
Cornerstone: Radiation Safety
2RS2 Occupational ALARA Planning and Controls
a. Inspection Scope
During January 28 - 30, 2013, the inspectors assessed performance with respect to maintaining occupational individual and collective radiation exposures as low as is reasonably achievable (ALARA). The inspectors compared the results achieved (dose rate reductions, actual dose) with the intended dose established in Exelons ALARA planning for the 1R24 refueling outage work activities. The inspectors compared the person-hour estimates provided by maintenance planning and other groups to the radiation protection group actual person-hours for the work activity, and evaluated the accuracy of these time estimates. The inspectors assessed the reasons for any inconsistencies between intended and actual work activity doses for outage ALARA plans. The inspectors determined whether post-job reviews were conducted to identify lessons learned. The inspectors verified that worker suggestions for improving dose and contamination reduction techniques were entered into Exelons corrective action program at an acceptable threshold. The ALARA post job reviews for the following jobs were reviewed.12-402 1R24, Reactor Disassembly/Reassembly and Refuel Floor Activities12-505 1R24, Drywell Radiation Protection/Observation/Inspection/Operations12-508 1R24, Drywell Scaffolding 12-511 1R24, Drywell CRD Exchange and Support Work 12-513 1R24, Drywell Safety and EMRV Exchange 12-519 1R24, Drywell ISI, NDE, WCR, Pipe Repair
b. Findings
No findings were identified.
2RS6 Radioactive Gaseous and Liquid Effluent Treatment
a. Inspection Scope
The inspectors verified that gaseous and liquid effluent processing systems are maintained so radiological discharges are properly reduced, monitored, and released.
The inspectors also verified the accuracy of the calculations for effluent releases and public doses. The inspectors reviewed the Oyster Creek Nuclear Generating Station Annual Radioactive Effluent Release Reports for 2011 and 2012 to determine if the reports were submitted as required by the Offsite Dose Calculation Manual and Technical Specifications.
The inspectors identified radioactive effluent monitor operability issues reported by Exelon as provided in the Oyster Creek Nuclear Generating Station Annual Radioactive Effluent Release Reports, and determined if the issues were entered into the corrective action program and were adequately resolved. The inspectors reviewed changes to the Offsite Dose Calculation Manual made by Exelon since the last inspection. The inspectors reviewed reported groundwater monitoring results and changes to Exelons written program for identifying and controlling contaminated spills/leaks to groundwater.
The inspectors reviewed effluent program implementing procedures, including those associated with effluent sampling, effluent monitor set-point determinations, and dose calculations.
The inspectors observed portions of the routine processing and discharge of radioactive gaseous and liquid effluents to verify that appropriate treatment equipment was used and the processing activities were effective at reducing radioactive releases. The inspectors observed the effluent sampling activities and assessed whether adequate controls have been implemented to ensure representative samples were obtained. The inspectors reviewed the results of the inter-laboratory and intra-laboratory comparison program to verify the quality of the radioactive effluent sample analyses. The inspectors assessed whether surveillance test results for technical specification required ventilation effluent discharge systems meet technical specification acceptance criteria. The inspectors reviewed the latest Land Use Census to verify changes that affect public dose pathways have been factored into the dose calculations and environmental sampling/analysis program. The inspectors reviewed monitoring results of the Nuclear Energy Institute voluntary groundwater protection initiative to determine if Exelon has implemented the initiative as intended.
b. Findings
No findings were identified.
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution (71152 - 3 annual samples)
.1 Routine Review of Problem Identification and Resolution Activities
a. Inspection Scope
As required by Inspection Procedure 71152, Problem Identification and Resolution, the inspectors routinely reviewed issues during baseline inspection activities and plant status reviews to verify that Exelon entered issues into the corrective action program at an appropriate threshold, gave adequate attention to timely corrective actions, and identified and addressed adverse trends. In order to assist with the identification of repetitive equipment failures and specific human performance issues for follow-up, the inspectors performed a daily screening of items entered into the corrective action program and periodically attended condition report screening meetings.
b. Findings
No findings were identified.
.2 Annual Sample:
Potentially Degraded Medium Voltage Cable
a. Inspection Scope
The inspectors performed an in-depth review of Exelon's evaluations and corrective actions associated with issue report (IR) 1430624, for a potentially degraded safety related 4kV cable. Specifically, the most recent partial discharge test results revealed a potential adverse trend in observed high frequency discharge signals for the emergency diesel generator #2, conduit # 2, feeder cable.
The inspectors assessed the adequacy of Exelon's problem identification threshold, problem analysis, extent of condition reviews, compensatory actions, and the prioritization and timeliness of corrective actions. The inspectors compared the actions taken to the requirements of Exelon's corrective action program and 10 CFR Part 50, Appendix B. The inspectors performed field walkdowns, and interviewed engineering personnel to assess the effectiveness of the implemented corrective actions, the reasonableness of the planned corrective actions, and to evaluate the extent of any on-going cable degradation problems. In addition, the inspectors reviewed Exelon's cable monitoring program, routine cable preventive maintenance testing, selected cable test results, and cable test schedules. Specific documents reviewed are listed in the attachment to this report.
b. Findings and Observations
No findings were identified.
Based on previous test results, Exelon had increased the frequency of testing for the emergency diesel generator #2 feeder cable, scheduled a re-test within one year from the most recent test, verified that replacement cable was available on-site, and initiated a work request to plan a contingency action for cable replacement during the next refueling outage. The inspectors noted that Exelon was in the process of transitioning from an on-line partial discharge cable test program to an off-line tan-delta cable test program. The inspectors determined Exelon's overall response to the issue was commensurate with the safety significance and the actions taken or planned were reasonable to resolve the identified cable issue.
Exelon self-identified a weakness in the cable monitoring program, in that a tan-delta test had been scheduled for the #2 emergency diesel generator cable during the 2012 fall refueling outage, but had not been accomplished because of unanticipated scheduling conflicts. As a result, a follow-up on-line partial discharge test had been rescheduled for 2013.
The inspectors identified a weakness in Exelon's oversight of vendor cable testing activities. Exelon did not perform a formal review or approval of the vendor test results.
The inspectors review of the 2009, 2011, and 2012 vendor test reports identified inconsistencies in cable component identification, cable and insulation type, and other minor documentation deficiencies. In addition, the vendor test reports had not been retained as a test record within Exelon's plant records system. The inspectors determined these were minor issues because engineering personnel responsible for the cable test program were knowledgeable of the test results; test results indicative of cable degradation were routinely entered into the corrective action program for further evaluation or corrective actions; and the test records were not irretrievably lost. Exelon entered the inspectors observations into their corrective action program as IR 1484661.
.3 Annual Sample: Emergency Service Water System Corrosion
a. Inspection Scope
A problem identification and resolution sample inspection was conducted during the period of February 19-20, 2013. The inspectors performed an in-depth review of Exelons corrective actions associated with condition reports IR 1432554 and 1456300, which were initiated to document the corroded condition of the emergency service water piping. The Oyster Creek emergency service water piping is safety-related 14-inch carbon steel piping which was originally coated on the inside diameter. Exelon has been collecting pipe wall ultrasonic thickness data during outages from 1R11 (1986) through
1R24 (2012). In 2012, Exelon identified that the coating was experiencing localized
failure and that corrosion was occurring on the inside diameter of the piping.
The inspectors reviewed revision 10 of the Oyster Creek Nuclear Generating Station, Pipe Integrity Inspection Program, TDR No. 829, which presents the results of wall thickness measurements and evaluations of raw water and closed cooling water system pipe inspections. These inspections are part of an Oyster Creek monitoring program to detect wall-thinning mechanisms other than flow accelerated corrosion. The inspectors also performed an in-depth review of Exelons technical evaluation 1432554-02, which evaluated the American Society of Mechanical Engineers (ASME) Code class 3 emergency service water system piping corrosion rates.
The inspectors assessed the adequacy of Exelons problem identification threshold, prioritization and timeliness of corrective actions. The inspectors also verified that planned or completed corrective actions were appropriate. The inspectors performed system documentation reviews and interviewed engineering to assess the effectiveness of any implemented corrective actions. The inspectors compared the actions taken to the requirements of Exelons corrective action program and 10 CFR Part 50, Appendix B. The inspectors considered aspects of the License Renewal Aging Management Program B.1.13, Open-Cycle Cooling Water System, when conducting this inspection.
b. Findings and Observations
No findings were identified.
The inspectors determined that Exelon had conducted a reasonable assessment of emergency service water system remaining margins. Future planned inspections of the emergency service water system during the 1R26 refueling outage, will provide the opportunity to validate the assumed corrosion rate and develop revised strategies, if warranted. Exelon intends to validate the corrosion rate and internal coating condition by re-inspecting the degraded area during 1R26 refueling outage.
.4 Annual Sample: Review of root cause analysis associated with the July 23, 2012
generator load reject reactor scram
a. Inspection Scope
The inspectors reviewed Exelons root cause analysis which included equipment design and licensing basis performance analysis conducted following the July 23, 2012, reactor scram and the associated licensee event report 2012-001-00, dated September 21, 2012 and its supplement 2012-001-01, dated December 12, 2012. Specifically, the inspectors reviewed the plant data presented and compared them to the UFSAR concerning offsite power.
b. Findings and Observations
No findings were identified.
The inspectors determined that the root cause analysis contained appropriate detail and actions to prevent recurrence relative to Exelon interactions with Jersey Central Power and Light testing of grid protection instrumentation. Exelons licensee event report stated a loss of offsite power caused the emergency diesel generators to start. The inspectors determined the emergency diesel generators started because of a generator load reject. Exelon entered the inspectors observations into their corrective action program as IR 1460021 and determined an update of the licensee event report was warranted to note the generator load reject. Although the licensee event report needed to be updated to document the generator load reject, Exelon has corrective actions in place to prevent recurrence of a similar event therefore this issue is of minor significance. The updated licensee event report will be closed following review in a subsequent inspection report.
4OA3 Follow-Up of Events and Notices of Enforcement Discretion
.1 (Closed) Licensee Event Report
05000219/2012-004-00: MCR (Main Control Room)
HVAC (Heating Ventilation and Air Conditioning) System Technical Specification Violation
On November 9, 2012, Exelon self-identified that the shift operability review concerning an issue report identifying flow oscillations in the B control room HVAC system on October 29, 2012, incorrectly determined that the B control room HVAC system was not required to be operable in the cold shutdown mode of operation. As a result, the compensatory action required by technical specification 3.17.B.1 of placing A control room HVAC system in the recirculation mode daily was not performed from October 29, 2012 through November 9, 2012. The enforcement aspects of this issue are discussed in Section 4OA7. The inspectors did not identify any new issues during the review of the licensee event report. This licensee event report is closed.
4OA6 Meetings, Including Exit
On April 18, 2013, the inspectors presented the inspection results to Mr. G. Stathes, Oyster Creek Nuclear Generating Station Site Vice President and other members of the Oyster Creek staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report.
4OA7 Licensee-Identified Violations
The following violation of very low safety significance (Green) was identified by Exelon and is a violation of NRC requirements which meets the criteria of the NRC Enforcement Policy for being dispositioned as an NCV.
Technical specification 3.17.A, "Control Room Heating, Ventilating, and Air Conditioning (HVAC) System", requires that The control room HVAC system shall be operable during all modes of operation." With one control room HVAC system determined inoperable, technical specification 3.17.B requires Exelon to verify once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> the partial recirculation mode of operation for the operable system, or place the operable system in the partial recirculation mode. On October 29, 2012, the B control room HVAC system experienced flow oscillations, was taken out of service and A control room HVAC system was placed in service. On November 1, 2012, Exelon operators initially declared the B control room HVAC inoperable due to the observed flow oscillations; however, Exelon operators, in error, subsequently determined that the B control room HVAC was not required to be operable in the cold shutdown mode of operation. Exelon discovered the error on November 9, 2012 during troubleshooting activities on the B control room HVAC system. Contrary to technical specification 3.17.B, Exelon did not verify or place the A control room HVAC system in the partial recirculation mode daily from October 29, 2012 until November 9, 2012. Exelon entered this issue into the corrective action program as IR 1438918. The inspectors determined that the finding was of very low safety significance (Green) in accordance with NRC IMC 0609, Appendix G, "Shutdown Operations Significance Determination Process," Appendix 1, Checklist 7, because the finding did not affect core heat removal guidelines, did not affect inventory control guidelines, did not affect AC power guidelines, did not affect containment control guidelines, did not affect reactivity control guidelines and did not require a quantitative assessment.
ATTACHMENT:
SUPPLEMENTARY INFORMATION
KEY POINTS OF CONTACT
Licensee Personnel
- G. Stathes, Site Vice-President
- R. Peak, Plant Manager
- M. Ford, Director, Operations
- G. Malone, Director, Engineering
- J. Dostal, Director, Maintenance
- C. Symonds, Director, Training
- D. DiCello, Director, Work Management
- J. Barstow, Manager, Regulatory Assurance
- T. Farenga, Radiation Protection Manager
- D. Chernesky, Manager, Environmental/Chemistry
- T. Keenan, Manager, Site Security
- W. Trombley, Senior Manager, Plant Engineering
- H. Ray, Senior Manager, Design Engineering
- G. Flesher, Shift Operations Superintendent
- J. Chrisley, Regulatory Assurance Specialist
- D. Moore, Regulatory Assurance Specialist
- M. McAllister, Engineering
- K. Wolf, Radiation Protection Engineering Manager
- J. Murphy, Radiation Protection Engineer
- M. Nixon, Chemistry Technician
- J. Test, Chemistry Technician
- J. Bills, Chemistry Engineer
- G. Harttraft, Engineering
LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED
Opened/Closed
- 05000219/2013002-01 NCV Emergency service water non-conformance not identified in the corrective action program (Section 1R15)
Closed
- 05000219/2012-004-00 LER Main Control Room Heating Ventilation and Air Conditioning System Technical Specification Violation (Section 4OA3)