IR 05000219/2011004

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

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

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION I 475 ALLENDALE ROAD KING OF PRUSSIA. PENNSYLVANIA 19406.1415 Nrivember 2, 20ll Mr, MichaelJ.

Pacilio Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer, Exelon Nuclear 4300 Winfield Road Warrenville, lL 60555

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

Dear Mr. Pacilio:

On September 30, 2011, 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 October 17 with Mr. M. Massaro, 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 Commission's rules and regulations and with the conditions of your license.The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.

Based upon the results of this inspection, no findings were identified.

ln accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter, 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 NRC's document system (ADAMS). ADAMS is accessible from the NRC website at htto://www.nrc.qov/readinq-rm/adams.html (the Public Electronic Reading Room).

Sincerely,Eugene M. DiPaolo, Acting Chief Reactor Projects Branch 6 Division of Reactor Projects 50-219 DPR-16 I nspection Report 050002 1 9/2Afi OO4

w/Attachment:

Supplemental I nformation Distribution via ListServ Docket No,: License No.:

Enclosure:

cc w/encl:

Mr. Michael

SUMMARY OF FINDINGS

lR 0500021912011004;

July 1 - September 30, 2Q11; Oyster Creek Generating Station;Integrated Report This report covered a three-month period of inspection by resident inspectors and announced inspections performed by regional inspectors.

The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.No findings were identified.

4

REPORT DETAILS

Summarv of Plant Status Oyster Creek began the inspection period at 100 percent power. Operators performed short duration unplanned power reductions on July 19, 21 , 22, 23, 24, 25, 26, 27 , and 31 and August 1 and 6 to adhere to environmental thermal discharge permit limitations.

The operators returned the plant to 100 percent power following each of these power reductions.

On July 28, operators performed an unplanned power reduction to 70 percent power due to loss of the B 34.5kV bus which interrupted power to the dilution pumps. Power was subsequently lowered to 52 percent to adhere to environmental thermal discharge permit limitations.

Following restoration of power to the dilution pumps, operators returned the plant to 100 percent power on July 29.On July 29, operators performed an unplanned power reduction to 70 power due to a loss of power to the dilution pumps caused by a lightning strike on the Q121 offsite power line.Following restoration of power to the dilution pumps, operators returned the plant to 100 percent power on July 30.On August 23, operators performed an unplanned power reduction to 70 percent to perform repairs to the A reactor feedwater pump. The plant returned to 100 percent power on August 25.On August 27, operators commenced an unplanned reactor shutdown due to the approach of Hurricane lrene. Cold shutdown was achieved on August 28. After consultation with the State of New Jersey and the Federal Emergency Management Agency (FEMA) on August 28, operators commenced a reactor startup and returned the plant to 100 percent power on August 30.On August 31, operators reduced power to 70 percent to perform a rod pattern adjustment.

The plant returned to 100 percent power later the same day.On September 21, operators performed an unplanned power reduction to 65 percent power to repair leaking tubes in the B main condenser.

The plant returned to 100 percent power on September 22.Oyster Greek remained at or near 100 percent power for the remainder of the inspection period.1. REACTORSAFETY Cornerstones:

Initiating Events, Mitigating Systems, and Barrier Integrity 1 R01 Adverse Weather Protection (71111.01 - 1 sample).1 Evaluate Readiness for lmpendinq Adverse Weather Conditions a. lnspection Scope The inspectors reviewed Exelon's preparations and readiness for Hurricane lrene from August 25 through August 28. The inspectors performed walkdowns of the areas that Enclosure 5 could be impacted by hurricane conditions such as the intake structure, emergency diesel building and transformer yard. The walkdown verified that station personnel secured loose materials prior to the arrival of high winds and implemented compensatory actions specified in Exelon severe weather procedures.

The inspectors verified that Exelon monitored the approach of the storm and took appropriate actions as required.The inspectors provided continuous onsite coverage starting prior to arrival of the storm on August 27 until the storm passed on August 28. Documents reviewed are listed in the Attachment.

b. Findinos No findings were identified.

1R04 EquipmentAliqnment

.1 Partial Svstem Walkdowns

(71111.04Q - 4 samples)a. Inspection Scope The inspectors performed partialwalkdowns of the following systems: r Containment spray system 2 with containment spray system 1 unavailable during surveillance testing on July 12 r A isolation condenser while B isolation condenser was unavailable due to planned maintenance on August 11. Core spray system 2 with core spray system 1 unavailable during surveillance testing on September 6 o 1-2 Service water pump while 1-1 service water pump was unavailable due to planned maintenance on September 19 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 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.

Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

1R05 Fire Protection

6.1 Resident Inspector Quarterlv Walkdowns (71111.05Q - 6 samples)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.

Documents reviewed are listed in the Attachment.. New warehouse (NW-FA-23)on July 7 o Northeast corner room (RB-FZ-lF ) on July 11 o 480V switchgear room B (OB-FZ-68)on August 4 r A and B battery room (OB-FZ-9C)on August 11 o Turbine operating floor (TB-FZ-114)on August 23. Torus room (RB-FA-2)on September 15 b. Findinqs No findings were identified.

1R06 Flood Protection

Measures (71111.06

• 1 samples).1 Internal Floodinq Review

a. Inspection Scope

The inspectors reviewed the UFSAR, the site flooding analysis, and plant procedures to assess susceptibilities involving internalflooding.

The inspectors also reviewed the corrective action program to determine if Exelon identified and corrected flooding problems and whether operator actions for coping with flooding were adequate.

The inspectors also focused on the southeast corner room of the reactor building/turbine building which contains the containment spray C and D pumps to verify the adequacy of equipment seals located below the flood line, floor and water penetration seals, common drain lines and sumps, sump pumps, level alarms, control circuits, and tempo.ary ol removable flood barriers.

Documents reviewed are listed in the Attachment.

b. Findinos No findings were identified.

1R11 Licensed Operator Requalification

Proqram (71111.11 - l sample)Resident Inspector Quarterlv Review

a. Inspection Scope

Enclosure 7 The inspectors observed licensed operator simulator training scenario 2612.CREW.11-5.01 on August 24. 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 problems.

Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

1R12 Maintenance

Effectiveness (71111.12-2 samples)a. Inspection Scope The inspectors reviewed the samples listed below to assess the effectiveness of maintenance activities on SSC 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 each sample selected, the inspectors verified that the SSC was properly scoped into the maintenance rule in accordance with 10 CFR 50.65 and verified that the (a)(2)performance r:riteria established by Exelon staff was reasonable.

As applicable, for SSCs classified as (a)(1), the inspectors assessed the adequacy of goals and corrective actions to return these SSCs 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.

Documents reviewed are listed in the Attachment.. Containment spray heat exchangers (lR 1193928) on July 25 o lsolation r:ondenser initiation logic relays (lR 1 178900) on August 8 b. Findinqs No findings were identified.

1R13 Maintenance

Risk Assessments and Emerqent Work Control (71111.13 - 4 samples)a. lnspection 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 thesel 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(aX4)and that the Enclosure 8 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 station's 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. Documents reviewed are listed in the Attachment.

o Containment spray system 1 unavailable due to surveillance testing during a grid heavy load voltage warning on July 12. Standby gas treatment system 2 unplanned outage for maintenance on August 8. Service water pump 1-1 and A control room ventilation system unavailable due to planned maintenance on September 19. 1-1 reactor building closed cooling water (RBCCW) heat exchanger unavailable for unplanned corrective maintenance with 1-1 RBCCW pump unavailable due to planned corrective maintenance on September 27 b. Findinqs No findings were identified.

1R15 Operabilitv

Determinations and Functionalitv Assessments (71111.15 - 4 samples)a. Inspection Scope The inspectors reviewed operability determinations for the following degraded or non-conform ing conditions:

o Low pressure carbon dioxide system on July 12 (lR 1239504). 'B' isolation condenser steam supply valve (V-14-33)stroke time on August 17 (lR 1250414). Safety relief valve acoustic monitoring system operability on August 23 (lR 1252766)r CV-305-127\42-19 - Control rod drive outlet scram valve air leak on September 22 (]R 1265624)The inspectors selected these issues based on the risk significance of the 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 Exelon's 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.

Documents reviewed are listed in the Attachment.

b. Findinqs Enclosure 9 No findings were identified.

1R19 Post-Maintenance

Testinq (71111.19 - 5 samples)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 andior 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.

Documents reviewed are listed in the Attachment.

r B isolation condenser steam inlet valve (V-14-33)on August 11 (C2026219)o 1 diesel fire pump starting battery replacement on August 12 (R2148297)o 2 diesel fire pump following annual preventive maintenance on September 3 (R2169826/

R21801 10). #2 emergency diesel generator planned maintenance on September 16 (R2143612). 1-1 service water pump preventive maintenance on September 19 (R21 87785)b. Findinqs No findings were identified.

1R22 Surveillance

Testins (71111.22 - 4 samples)a. lnspection 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.

Documents reviewed are listed in the Attachment.

The inspectors reviewed the following surveillance tests: r Firewater makeup to isolation condensers inservice test on July 6. Containment spray and emergency service water system 1 pump operability and inservice test on July 12 o Standby gas treatment system 1O-hour run - system 1 on August 15. Core spray valve operability and inservice test on September 1 b. Findinqs Enclosure 10 No findings were identified.

Cornerstone:

Emergency Preparedness lEPO Drill Evaluation (71114.06 - 1 sample).1 Emerqencv Preparedness Drill Observation

a. Inspection Scope

The inspectors evaluated the conduct of a routine Exelon emergency drill on August 31 to identify any weaknesses and deficiencies in the classification, notification, and protective action recommendation development activities.

The inspectors observed emergency response operations in the simulator, technical support center, and emergency operations facility to determine whether the event classification, notifications, and protective action recommendations were performed in accordance with procedures.

The inspectors also attended the station drill critique to compare inspector observations with those identified by Exelon staff in order to evaluate Exelon's critique and to verify whether the Exelon staff was properly identifying weaknesses and entering them into the corrective action program. Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

2. RADIATION

SAFETY Cornerstone:

Occupational Radiation Safety [OS]RS07 Radioloqical Environmental Monitorinq Proqram (REMP) (7 1124.07)a. Inspection Scope (1 Sample)The inspectors reviewed Oyster Creek's annual radiological environmental and effluent operating reports (2009, 2010) and the results of Exelon's assessments to verify that the REMP was implemented in accordance with technical specifications (TS) and the offsite dose calculation manual (ODCM). The inspectors reviewed the report for changes to the ODCM with respect to environmental monitoring, commitments in terms of sampling locations, monitoring and measurement frequencies, land use census, inter-laboratory comparison program, and analysis of data.The inspectors reviewed the ODCM and associated maps to identify locations of environmental monitoring stations.

The inspectors also reviewed the updated final safety analysis report (UFSAR) for information regarding the environmental monitoring program and meteorological monitoring instrumentation.

The inspectors reviewed quality assurance (QA) audit results of the program to assist in selection of samples. The inspectors reviewed available audits and technical evaluations performed on the vendor's program, as applicable, if used to analyze REMP samples.Enclosure 11 The inspectors reviewed the annual effluent release report and the 10 CFR Part 61 ,"Licensing Requirements for Land Disposal of Radioactive Waste," report, to determine if Exelon was appropriately sampling for the predominant and dose-causing radionuclides likely to be released in effluents.

The inspectors observed the collection and preparation of various environmental samples from different environmental media (three particulate and iodine air monitoring stations, one drinking water locations, and one surface water location).

Documents reviewed are listed in the Attachment.

Site Inspection The inspectors walked down and observed sample collection for three air sampling stations (5T-66, ST-72, and ST-73), three thermoluminescent dosimeter (TLD)monitoring stations (5T-66, ST-72, and ST-73), one drinking water station (Station 1 14), and one surface water sample (Station 33) to determine whether the stations were located as described in the ODCM. The inspectors also reviewed Exelon gardens (ST 66 and ST 35) and reviewed material conditions of monitoring equipment.

Consistent with smart sampling techniques, the inspectors selected air sampling station locations based on the locations with the highest X/Q, D/Q wind sectors selected the TLD stations based on the most risk-significant locations.

The inspectors observed the collection and preparation of various environmental samples from different environmental media (three particulate and iodine air monitoring stations, one drinking water locations, and one surface water location).

The inspectors verified that environmental sampling was representative of the release pathways as specified in the ODCM and that sampling techniques were in accordance with controlled procedures.

For the air samplers and TLDs, the inspectors reviewed the calibration and maintenance records/data (orifices, vacuum gauge) to verify that they demonstrate operability of these components.

The inspectors evaluated Exelon's criteria for sampling of other media upon loss of a required sampling station.Based on direct observation and review of records, the inspectors verified that the meteorological instruments were operable, calibrated, and maintained in accordance with guidance contained in the FSAR, NRC Regulatory Guide 1.23, "Meteorological Monitoring Programs for Nuclear Power Plants," and Exelon procedures.

The inspectors verified that the meteorological data readout and recording instruments in the control room and at the tower were operable.

The inspectors toured the meteorological tower and reviewed meteorological data readouts, The inspectors compared readouts with control room indications.

The inspectors reviewed monthly meteorological monitoring reports.The inspectors verified that missed and or anomalous environmental samples were identified and reported in the annual environmental monitoring report. The inspectors selected events that involved a missed sample, an inoperable sampler, a lost TLD, or an anomalous measurement, and verified that Exelon had identified the cause and implemented corrective actions. The inspectors reviewed Exelon's assessment of any Enclosure 12 positive sample results (i.e., licensed radioactive material detected above the lower limits of detection (LLD). The inspectors reviewed the associated radioactive effluent release data that was the source of the released material.The inspectors selected structures, systems, or components (SSCs) that involve or could reasonably involve licensed material for which there is a credible mechanism for licensed materialto reach groundwater, and verified that Exelon had implemented a sampling and monitoring program sufficient to detect leakage of these SSCs to groundwater.

The inspectors reviewed the Annual 2010 Radiological Ground Water Protection Program Report.The inspectors verified that records, as required by 10 CFR 50.75(9), of leaks, spills, and remediation generated since the previous inspection, were being retained in a retrievable manner.The inspectors reviewed any significant changes made by Exelon to the ODCM as the result of changes to the land use census, long-term meteorological conditions (e.9., three-year average) or modifications to the sampler stations.

The inspectors reviewed technicaljustifications for any changed sampling locations.

The inspectors verified that Exelon performed the reviews required to ensure that the changes did not affect its ability to monitor the impacts of radioactive effluent releases on the environment.

The inspectors verified that appropriate detection sensitivities with respect to TS/ODCM were used for counting samples (i.e., the samples meet the TS/ODCM required LLDs).The inspectors reviewed quality control charts, as appropriate, for maintaining radiation measurement instrument status and actions taken for degrading detector performance, as applicable.

For vendor laboratory analysis results for REMP samples, the inspectors reviewed the results of the vendor's quality control program, including the inter- and intra-laboratory comparison program, to verify the adequacy of the vendor's program.The inspectors reviewed the results of Exelon's inter-laboratory comparison program to verify the adequacy of environmental sample analyses performed by Exelon. The inspectors verified that the inter-laboratory comparison test included the media/nuclide mix appropriate for the facility.

The inspectors reviewed as applicable, Exelon's determination of any bias to the data and the overall effect on the REMP.ldentification and Resolution of Problems The inspectors determined if problems associated with the REMP were being identified by Exelon at an appropriate threshold and were properly addressed for resolution in the corrective action program. In addition to the above, the inspectors verified the appropriateness of the corrective actions for a selected sample of problems documented by Exelon that involve the REMP.b. Findinqs No findings were identified.

4OA1 Performance

lndicator Verification (71151)Enclosure

.1 13 Reactor Coolant Svstem (RCS) Specific Activitv and RCS Leak Rate (2 samples)Inspection

Scope The inspectors reviewed Exelon's submittal for the RCS specific activity and RCS leak rate performance indicators for the period of July 1, 2010 and June 30, 2011. To determine the accuracy of the performance indicator data reported dudng those periods, the inspectors used definitions and guidance contained in NEI Document 99-02,"Regulatory Assessment Performance Indicator Guideline," Revision 6. The inspectors also reviewed RCS sample analysis and control room logs of daily measurements for RCS leakage, and compared that information to the data reported by the performance indicator.

Documents reviewed are listed in the Attachment.

Inspection Findinqs No findings were identified.

4OA2 Problem ldentification

and Resolution (71152 - 1 sample).1 Routine Review of Problem ldentification and Resolution Activities

a. Inspection Scope

As required by Inspection Procedure71152, "Problem ldentification 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. Findinqs No findings were identified.

4OA3 Follow-Up

of Events (71153 - 3 samples).1 Plant Events

a. Inspection Scope

For the plant events listed below, the inspectors reviewed and/or observed plant parameters, reviewed personnel performance, and evaluated performance of mitigating systems. The inspectors communicated the plant events to appropriate regional personnel, and compared the event details with criteria contained in IMC 0309, "Reactive lnspection Decision Basis for Reactors," for consideration of potential reactive inspection activities.

As applicable, the inspectors verified that Exelon made appropriate emergency classification assessments and properly reported the event in accordance with 10 CFR Parts 50.72 and 50,73. The inspectors reviewed Exelon's follow-up actions related to the events to assure that Exelon implemented appropriate corrective actions a.b.Enclosure b.14 commensurate with their safety significance.

Documents reviewed are listed in the Attachment.. Loss of the B 34.5kV electrical bus on July 28. Declaration of Unusual Event due to seismic activity on August 23. Response to Hurricane lrene during the period August 25-28 Findinqs No findings were identified.

Other Activities Follow-up On Traditional Enforcement Actions (lP 92702) (1 sample)Inspection Scope The U.S. Nuclear regulatory Commission Office of Investigations completed an investigation at Oyster Creek Nuclear Generating Station (OCNGS) on January 14,2010 which confirmed that a contract employee, who had unescorted access to vital areas of the plant, deliberately failed to report an arrest while employed for Bartlett at OCNGS.The contract employee's action caused Exelon to be in violation of License Condition 2.C.(4) of the OCNGS operating license and Section 9.1 of the OCNGS Physical Security Plan. A severity level lV non-cited violation was issued in investigation report l-2009-047 (ML092580013)on April 12,2Q10. The inspectors reviewed Exelon's corrective actions, ensured that any generic implications were addressed, and verified that Exelon's programs and practices are adequate to prevent recurrence.

No inadequacies were noted. Documents reviewed are listed in the Attachment.

Findinqs No findings were identified.

Independent Spent Fuel Storase Installation (lSFSl) (60855.1)40A5 ,1 b..2 a. lnspection Scope (1 Sample)The inspector reviewed routine operational surveillance data, including radiological surveillance, for the ISFSI facility.

The inspector toured the facility, reviewed TLD monitoring data, and made independent radiation measurements.

Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

.3 (Closed) NRC Temporarv

Instruction 2515/177 - Manaoinq Gas Accumulation in Emerqencv Core Coolinq. Decav Heat Removal and Containment Sprav Svstems

a. Inspection Scope

Enclosure 15 The inspectors performed the inspection in accordance with Temporary Instruction (Tl) 25151177, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." The NRC staff developed Tl 25151177 to support the NRC's confirmatory review of Exelon's responses to NRC Generic Letter (GL) 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal and Containment Spray Systems." Based on a review of Exelon's GL 2008-01 response letters, the Office of Nuclear Reactor Regulation (NRR) staff provided additional plant specific guidance on inspection scope to the regional inspectors.

The inspectors used this inspection guidance along with the Tl to verify that Exelon implemented or was in the process of acceptably implementing the commitments, modifications, and programmatically controlled actions described in their GL 2008-01 response.

The inspectors verified that the plantspecific information (including licensing basis documents and design information)was consistent with the information that Exelon submitted to the NRC in response to GL 2008-01.The inspectors reviewed a sample of isometric drawings, and piping and instrument diagrams, and conducted selected system piping walkdowns to verify that Exelon's drawings reflected the subject system configurations and Updated Final Safety Analysis Report (UFSAR) descriptions.

Specifically, the inspectors verified the following related to a sample of isometric drawings for the core spray, containment spray, isolation condenser and shutdown cooling systems:. High point vents were identified;. High points that did not have vents were recognized and evaluated with respect to their potential for gas buildup;. Other areas where gas could accumulate and potentially impact subject system operability, such as orifices in horizontal pipes, isolated branch lines, heat exchangers, improperly sloped piping, and under closed valves, were acceptably evaluated in engineering reviews or had ultrasonic testing (UT) points which would reasonably detect void formation; and, o For piping segments reviewed, branch lines and fittings were clearly shown.The inspectors conducted walkdowns of portions of the above systems to evaluate the acceptability of Exelon's drawings utilized during their review of GL 2008-01. The inspectors verified that Exelon conducted walkdowns of the applicable systems to confirm that the combination of system orientation, vents, instructions and procedures, tests, and training, would ensure that each system was sufficiently full of water to ensure operability, The inspectors reviewed Exelon's methodology used to determine system piping high points, identification of negative sloped piping, and calculations of void sizes based on UT equipment readings, to ensure the methods were reasonable.

The inspectors also reviewed engineering analyses associated with the development of acceptance criteria for as-found voids. The review included engineering assumptions for void transport and acceptability of void fractions at the suction and discharge piping of the applicable system pumps. In addition, the inspectors verified that Exelon's review included all emergency core cooling systems, along with supporting systems, within scope of the GL.Enclosure 16 The inspectors reviewed a sample of Exelon's procedures used for filling and venting the associated GL 2008-01 systems to verify that the procedures were effective in venting or reducing voiding to acceptable levels. The inspectors reviewed a sample of system venting and UT surveillance results to ensure proper implementation of the surveillance program.The inspectors reviewed corrective action program (CAP) documents to verify that selected actions described in Exelon's nine month and supplemental submittals were acceptably documented including completed actions, and implementation schedule for incomplete actions. The inspectors also verified that the NRC commitments in Exelon's submittals were included in the CAP. Additionally, the inspectors reviewed evaluations and corrective actions for various issues Exelon identified during their GL 2008-01 review. The inspectors performed this review to ensure Exelon appropriately evaluated and adequately addressed any gas voiding concerns.

Finally, the inspectors reviewed Exelon's training associated with gas accumulation to assess if appropriate training had been provided to the operations and engineering support staff to ensure appropriate awareness of the effects of gas voiding. Documents reviewed are listed in the Attachment.

b. Findinqs No findings were identified.

This completes the inspection requirements for Tl 25151177.4OAO Meetinqs.

Includinq Exit On October 17, the inspectors presented the inspection results to Mr. M. Massaro, and other members of the Exelon staff. The inspectors verified that no proprietary information was retained by the inspectors or documented in this report 4C.A7 Licensee-ldentified Violations None ATTACHMENT:

SUPPLEM ENTARY INFORMATION A-1

=SUPPLEMENTARY

INFORMATION=

KEY POINTS OF CONTACT

Licensee Personnel

M. Massaro, Site Vice-President

R. Peak, Plant Manager

D. Dicello, Director, Work Management

M. McKenna, Director, Operations

G. Malone, Director, Engineering

C. Symonds, Director, Training

J. Dostal, Director, Maintenance

J. Barstow, Manager, Regulatory

Assurance

T. Keenan, Manager, Security

M. Ford, Manager, Environmental/Chemistry

J. Renda, Manager, Site Radiation

Protection

A. Farenga, Manager, Radiological

Engineering

D. Chernesky, Assistant

Director, Maintenance

R. Skelsky, Senior Manager, Systems Engineering

H. Ray, Senior Manager, Design Engineering

G. Flesher, Shift Operations

Superintendent

J. McDaniel, Manager, Nuclear Oversight

M. Rossi, RequalTraining

Lead

M. Seeloff, Manager, Corrective

Action Program

J. Chrisley, Regulatory

Assurance

Specialist

J. Kerr, Regulatory

Assurance

Specialist

K. Wolf, Radiation

Protection

Support Manager

M. Nixon, Chemistry

Supervisor

D. Moore, Regulatory

Assurance

Specialist

J. McCarthy, Radiological

Engineer

K. Martin, Project Manager, lFSl

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

LIST OF ITEMS OPENED, CLOSED, DISCUSSED, AND UPDATED

Opened/Closed

None

Opened

None

Closed

None Attachment

LIST OF DOCUMENTS

REVIEWED

Section 1R01: Adverse Weather Protection

Procedures

OP-OC-108-109-1001, Preparation for Severe Weather T&RM for Oyster Creek, Revision 1 1

OP-AA-108-1

1-1001 , Severe Weather and Natural Disaster Guidelines, Revision 6

WC-AA-107, Seasonal Readiness, Revision 9

OP-OC-108-1001, Preparation for Severe Weather T&RN for Oyster Creek, Revision 1

OP-OC-108-109-1002, Cold Weather Freeze Inspection, Revision 4

ABN-31, High Winds, Revision 15

ABN-32, Abnormal Intake Level, Revision 18 Condition Reports (lR)1256245

1255744

1256409 1256421

Section 1R04: Equipment

Alignment Procedures

310, Containment Spray System Operation, Revision 102 307, lsolation Condenser System, Revision 103 Drawinqs G8148F740, Containment Spray System Flow Diagram GE148F262, Emergency Condenser Flow Diagram GE885D781, Core Spray System Flow Diagram

BR 2005, Reactor & Turbine Building Service Water System Flow Diagram

Section 1R05: Fire Protection

Procedures

ABN-29, Plant Fires, Revision 26 101.2, Oyster Creek Site Fire Protection Program, Revision 67

CC-AA-211, Fire Protection Program, Revision 4 333, Plant Fire Protection System, Revision 106

OP-AA-201-010-1001, 8.5.8 Mitigating Strategies Equipment Expectations, Revision 0 Miscellaneous Oyster Creek Generating Station Pre-Fire Plan: Northeast Corner Room Oyster Creek Generating Station Pre-Fire Plan: Oyster Creek Generating Station Pre-Fire Plan: Oyster Creek Generating Station Pre-Fire Plan: Room Oyster Creek Generating Station Pre-Fire Plan: Elevation)

Oyster Creek Generating Station Pre-Fire Plan: Guest Trolling Charger Series Owner's Manual,

RB-FZ-1F4, Reactor Building (-19' Elevation)

NW-FA-23, New Warehouse

OB-FZ-68, 480V Switchgear Room "8"

OB-FZ-8C, A and B Battery Room, Electric Tray

TB-FZ-11A, Turbine Operating Floor (46'-0"

RB-FA-2, Reactor Building (Drywell and Torus)On Board Battery Chargers Attachment

Section 1R06: Flood Protection

Measures Condition Reports (lR)813797

813958

810465

821411

1240067 85247

1201634

1184058

1105157

427972 Work Orders (AR)R2095953

C2018682 Miscellaneous Information Notice 2005-30, Safe Shutdown Potentiatty Challenged by Unanalyzed lnternal Flooding Events and Inadequate Design

C-1302-822-E610-076, Flooding Due to HELB Outside Containment

28063-005, Design and Licensing Bases for Flooding at OCGS OCGS Internal Flood Evaluation Summary and Notebook

Section 1Rl1: Licensed Operator Requalification

Proqram Miscellaneous

EOP User's Guide (2000-BAS

-3200.02)2612.CREW.1

1-5.01 Section 1 R12: Maintenance Effectiveness

Procedures

ER-AA-310, lmplementation of Maintenance Rule, Revision 8

ER-AA-310-1005, Maintenance Rule - Disposition Between (a)(1) and (a)(2) , Revision 5 LS

AA-125-1003, Apparent Cause Evaluation Manual, Revision 9

CC-AA-309-1012, 10 CFR Part 21 Technical Evaluations, Revision 2 Condition Reoorts (lR)1193928

985629

874285

983355

1208455

1193928

618930

1178900

932736

879452

1247448

1212922

1055456

1206399

1055456 Miscellaneous

NEI 93-01, Industry Guideline for monitoring the Effectiveness of Maintenance at Nuclear Power Plants

C-1302-241-5450-073, Acceptable Containment Spray Heat Exchanger Fouling Resistance

C-1302-241-E610-080, Calculation of Torus Pool Temperature for NPSH and to Determine Containment Spray System Design Basis Requirements, Revision 4

TDR 993, Evaluation of Containment Spray/ESW

Performance at Elevated Intake Temperature

NRC lnformation Notice20QT-40,Inadequate lmplementation of 10 CFR Part21 Requirements by Vendors who Supply Basic Components to Nuclear Power Plant Licensees

Section 1R13: Maintenance

Risk Assessments and Emergent Work Control Procedures

ER-AA-600-1042, On-line Risk Management, Revision 7

ER-AA-600-1021, Risk Management Application Methodologies, Revision 4

ER-AA-600-1014, Risk Management Configuration Control, Revision 6 Attachment

ER-AA-600-1011, Risk Management Program, Revision 9

WC-OC-101-100'1, On-line Risk Management and Assessment, Revision 8

ABN-60, Grid Emergency, Revision 9 Condition Report (lR)1268453 Section 1 R15: Operabllitv Evaluations

Procedures

OP-AA-108-1

15, Operability Determination, Revision 10 101.2, Oyster Creek Site Fire Protection Program, Revision 67 413, Operation of the Safety valve/EMRV

Acoustic Monitoring System, Revision 19 602.3.008, Main Steam Line Safety/ EMRV Acoustic VMS Test, Revision 29 Condition Reports (lR)1239504

1057101 Work Orders (AR)A2112538

42248892

C2020245 A2276012 A2283257 Miscellaneous

NRC Inspection Manual - Part 9900 Technical Guidance, Operability Determinations

&Functionality Assessments for Resolution of Degraded or Nonconforming Conditions Adverse to Quality or Safety 2611-PGD-2621, Nuclear Plant Operator Initial Training Course, Fire Protection Program NFPA 12, Standard on Carbon Dioxide Extinguishing Systems, 2000 edition 990-1746, Oyster Creek Nuclear Generating Station Fire Hazards Analysis Report

C-1302-730-5350-017, Stroke Time Calculation for

GL 89-10 MOVs

SE-328212-003,

GL 89-10 Motor Operated Valve Modification Oyster Creek Generating Station UFSAR, Table 6.3-1, lsolation Condenser System Components

ASME OM Code-1995, Code for Operation and Maintenance of Nuclear Power Plants, Subsection

ISTC, Inservice Testing of Valves in LighfWater Reactor Power Plants Oyster Creek Generating Station Pre-Fire Plan:

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

Section 1R19: Post-Maintenance

Testinq Procedures

MA-AA-71 6-012, Post Maintenance Testing, Revision 15

OP-MA-109-101, Clearance and Tagging, Revision 12 645.4.001, Fire Pump #1 Operability Test, Revision 65 645.4.018, Fire Pump Monitoring Test, Revision 62 636.4.013, Diesel Generator

1. 2Load Test, Revision 36 641.4.001, Service Water Pump Operability and In-Service Test, Revision 70 Condition Report (lR)1244421

761954

1259343

1250414

761954

1252766

1265624

1250988

1250909

1250917

1259347 Attachment Work Order (AR)c2026219 A2283257

C2025687 A2276012

42236563 R2148297 R2169826 R2180110 R2143612 R2187785 Miscellaneous

C-1302-730-5350-017, Stroke Time Calculations for the

GL 89-10 MOVs

SE-315403-032, Justification for lC AC Condensate Valves Revised Open Area

Section 1R22: Surveillance

Testinq Procedures

SA-AA-129, Electrical Safety, Revision 7

MA-AA-1000, Conduct of Maintenance, Revision 14 609.4.007, Fire Water Makeup to lsolation Condensers In-Service Test, Revision 19 607.4.014, Containment Spray and ESW System 1 Pump Operability, IST and Containment Spray Pumps Trip, Revision 37 610.4.003, Core Spray Valve Operability and In-Service Test, Revision 40 651 .4.002, Standby Gas Treatment System 1O-Hour Run - System 1 , Revision 5 Condition Reports (lR)1236410

1240072

1099012 Work Orders (AR)R2183971 A2280062 Miscellaneous

R2165849 R2186029 R2186125 NRC Inspection Manual Part 9900 Technical Guidance, Maintenance-

Preconditioning of Structures, Systems, and Components Before Determining Operability Oyster Creek UFSAR Section 6.2.2, Containment Heat Removal System

Section 1EP6: Drill Evaluation

Procedures

EP-AA-1010, Radiological Emergency Plan Annex for Oyster Creek Station, Revision 3 Condition Reports

1258579

1258580

1258577

1258397

1258396

1258394 Miscellaneous Oyster Creek 2011 Pre-Exercise Evaluation Report, dated

912512011 Section RS07 Radioloqical Environmental Monitoring Proqram Procedures

CY-AA-170-000, Radioactive Effluent and Environmental Monitoring Program, Revision 4

CY-AA-1 70-1 00, Radiological Environmental Monitoring Program, Revision 2

CY-AA-170-200, Radioactive Effluent Control Program, Revision 1

CY-AA-130-201, Radiochemistry Quality Control, Revision 0

CY-AA-170-300, Offsite Dose Calculation Manual Administration, Revision 2

CY-AA-1 70-1 000, Radiological Environmental Monitoring Program and Meteorological Program lmplementation, Revision 5 Attachment

CY-AA-170-1100, Quality Assurance for Radiological Monitoring Program, Revision 1

CY-OC-120-1200, REMP sample Collection - Well Water, Revision 1

CY-AA-170-2000, Annual Radioactive Effluent Release Report, Revision 5

CY-OC-170-2001, Quality Control for Radioactive Effluents, Revision 0

CY-AA-170-2300, Determination of Carbon 14 in Gaseous Effluents, Revision 0

CY-AA-170-3100, Offsite Dose Calculation Manual Revision, Revision 3

EN-AA-408, Radiological Ground water Protection Program, Revision 0

EN-AA-408-4000, Radiological Ground Water Protection Program lmplementation, Revision 0 Work Orders (AR)41 06881 3 Miscellaneous Orifice Calibration data -

269341 1,

269341 3,

2693421 Meteorological Data Summary (2000-2009)

Annual Metrological Monitoring Report 2010 NUPIC CGI Audit, March 2011 Annual Report TB Engineering Environmental Service (January-December

2010)10

CFR 50.75(9) file Check-in Self-Assessments

2010 Land Use Census An nual Rad iolog ical Envi ronmental, Effluent Release Reports- 2009, 20 1 Q Quality Assurance Confirmatory Testing of Environmental

TLDs Section 4OAl : Performance Indicator Verification

Procedures

LS-AA-2001, Collecting and Reporting of NRC Performance Indicator Data, Revision 14 Miscellaneous Reactor coolant chemistry logs, dated July 2010 through June 2011 Drywell identified and unidentified leak rate logs, dated July 2010 through June 201 1 Oyster Creek Performance Indicator Summary dated

712012011

NEI 99-02, Regulatory Assessment Performance Indicator Guideline

NEI 99-02 Frequently Asked Question Archive, dated 10113110

Section 4OA2: . Problem ldentification

and Resolution

Miscellaneous

Check-in Assessments

ANI Assessment, March 2011 Audit

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

Section 4OA3: Followup of Events Procedures

ABN-21, Radwaste Service Water Failure, Revision 5

ABN-22, AOG Building Loss of Power, Revision 7

ABN-52, Loss of USS 1E1, Revision 5 Attachment

ABN-56, Loss of the J69361 North Yard Distribution System, Revision 5

ABN-57, Loss of Site Emergency Building Power and/or the Plant Process Computer system UPS, Revision 8

ABN-38, Station Seismic Event, Revision 11

ABN-31, High Winds, Revision 15

ABN-32, Abnormal lntake Level, Revision 18

OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines, Revision 6

OP-OC-108-109-1001, Preparation for Severe Weather T&RM for Oyster Creek, Revision 1 1 Condition Reports (lR)1245786

1246235

1245329

1245293

1256421

1256445

1256245

1256349

1243571

1256409

1254651

1257675

1257893 Miscellaneous

NUREG-1022,Event Reporting Guidelines

CFR 50.72 and 50.73 ENS Notification

47107, Offsite Notification Due to Fish Kill Event ENS Notification

47188, Notification of an Unusual Event due to a Seismic Event Oyster Creek UFSAR, Figure 8.2-3,34.5

kV Substation - One Line Diagram Oyster Creek Operations Logs, dated 7128 and 7129 Oyster Creek Operations Logs, dated 8/23 Oyster Creek Operations Logs, dated 8127, 8128 and 8129

Section 4OA5: Other Activities

Procedures

SY-AA-103-513, Behavioral Observation Program, Revision 8 305, Shutdown Cooling System Operation, Revision 107 307, lsolation CondenserSystem, Revision 113 308, Emergency Core Cooling System Operation, Revision 89 310, Containment Spray System Operation, Revision 102 Drawinos 3E-214-A2-1000, Sht.4, lSl Configuration Drawing Shutdown Cooling System, Revision 3

GE 148F262, Emergency Condenser, Revision 53

GE 148F740, Containment Spray System, Revision 43 GE148F711, Shutdown Cooling System, Revision 44 GE885D781, Core Spray System Flow Diagram, Revision 72

JCP-19433, Shts. 1-6, lsolation Condenser System, Revs. 2, 3, 3, 4, 3, and 2

JCP-19434, Shts. 1-3, Shutdown Cooling System, Revs.2,3 and 5

JCP-19436, Shts. 1-11, Containment Spray System, Revs. 3,2,2,2,2,2,2,2,2,2, and 2

JCP-19440, Shts. 1-11, Core Spray System, Revs. 2,3,2,2,2,2,2,2,2,2, and 2 Condition Reoorts (lR)954765

1263536

1240313

1228883

1236753

1239120

1239386

1239094 Work Orders R2169237 R2170284 Attachment

Miscellaneous

Supervisory Brief, lmportant Security lnformation, dated

6117111 Nuclear General Employee Study Guide, dated 3131l1O NRC Letter lA-2010-009, NRC lnvestigation Report No. l-2009-047, dated

4112110 NRC Letter

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

4112110, (M1101030075)

Security Incident Report number 2009-141

VPF 1259-18-1 , lnstructions for lnstallation, Operation and Maintenance of Heat Exchangers, Revision 0

LS-AA-1 26-1 005, Managing Gas Accumulation Self-Assessment, dated 7 l 1 5l I 1

EAS-57-0989, Design Basis Document for Containment Spray System, Revision 5 Letter from K. R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC)to USNRC, "Three Month Response to Generic Letter 2008-01," dated

4111108 Letter from K. R. Jury (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to USNRC, "Nine-Month Response to

GL 2008-01," dated

10114108 Letter from P. R. Simpson (Exelon Generation Company, LLC) to USNRC, "Response to Request for Additional Information Regarding Generic Letter 2008-01," dated

1128110 Letter from P. R. Simpson (Exelon Generation Company, LLC/AmerGen Energy Company, LLC) to USNRC, "Supplemental Response to Generic Letter 2008-01," dated

1120109 Oyster Creek Nuclear Generating Station - Technical Specifications, Amendment

280 Oyster Creek Nuclear Generating Station Updated Final Safety Analysis Report, Revision 16

SDBD-OC-212-A, Design Basis Document for Low Pressure Core Spray System, Revision 3

GENE-813-01805-77, Evaluation of Condensation-lnduced Water Hammer for Core Spray Line of Oyster Creek Nuclear Generating Station, dated 9/1996 NRC

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

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

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

GL 2008-01 Core Spray System Evaluation, dated

8120108 NRC

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

ADM BCO BVPS CAP CFR CR FA FENOC rMc roD IP rsl LCO LER MR MSP NEI NRC OD ODCM OST PI PI&R POD PMT REMP SSC SWS TLD TS UFSAR A-9

LIST OF ACRONYMS

Ad m i nistrative

Proced ure Basis for Continued

Operations

Beaver Valley Power Station Corrective

Action Program Code of Federal Regulations

Condition

Report(s)Functionality

Assessments

First Energy Nuclear Operating

Company lnspection

Manual Chapter lmmediate

Operability

Determination

Inspection

Procedure Inservice

lnspection

Limiting Conditions

for Operations

Licensee Event Report Maintenance

Rule Maintenance

Surveillance

Package Nuclear Energy Institute Nuclear Regulatory

Commission

Operability

Determinations

Off-Site Dose Calculation

Manual Operations

Surveillance

Test Performance

lndicator Problem ldentification

and Resolution

Prompt Operability

Determination

Post Maintenance

Testing Radiological

Environmental

Monitoring

Prog ram Structures, Systems, and Components

Service Water System Thermo-Luminescent

Dosimeter Technical

Specification

Updated Final Safety Analysis Report Attachment