ML050680270

Recovery of Nine Mile Point License Renewal Application Quality

ML050680270
Person / Time
Site:	Nine Mile Point
Issue date:	03/03/2005
From:	O'Connor T Constellation Energy Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NMP1L 1933, TAC MC3272, TAC MC3273
Download: ML050680270 (3)

Text

Constellation Energya P.O. Box 63 Lycoming, NY 13093 Nine Mile Point Nuclear Station March 3, 2005 NMP1L 1933 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

SUBJECT:

Nine Mile Point Units 1 and 2 Docket Nos. 50-220 and 50-410 Facility Operating License Nos. DPR-63 and NPF-69 Recovery of Nine Mile Point License Renewal Application Quality (TAC Nos.

MC3272 and MC3273)

Gentlemen:

The purpose of this letter is to advise you that Nine Mile Point Nuclear Station, LLC (NMPNS) requests a grace period not to exceed 90 days to recover the quality of the License Renewal Application (LRA) for Nine Mile Point Units I and 2. We believe this grace period will allow NMPNS to aggressively address the quality issues defined during the course of the NRC LRA review and inspection process, and will allow the NRC to optimize the critical staff resources needed to complete our pending application review.

Examples of specific recovery actions that NMPNS will take to address LRA quality issues include:

Develop a detailed self-assessment, and a detailed recovery plan with key performance indicators that will be utilized to monitor progress by NMPNS and the NRC.

• Assign an experienced outside advisor as a direct report to our Chief Nuclear Officer (CNO).

This action will ensure that independent facts are provided to our CNO concerning the quality of our grace period recovery effort.

• Reorganize the license renewal project team to become a direct report to the Constellation Generation Group (CGG) Fleet Licensing Manager, Mark Flaherty. This action will ensure that fleet standards, expectations, and processes used in licensingiactivities will be applied to the grace period recovery effort.

• Add any needed resources to implement the recovery.

• Conduct periodic meetings with the NRC to define the current quality issues and their extent of condition.

Page 2 NMPIL 1933

• Per telephone discussions with Mr. P.T. Kuo, address, as a minimum, the following seven issues:

1. Complete the non-safety-related affecting safety-related interaction scoping study (license renewal criterion 10 CFR 54.4(a)(2)).

2. Ensure completeness of the January 10, 2005 responses to the staff Requests for Additional Information (RAls).

3. Correct the last license renewal submittal to ensure all changes are highlighted.

4. Answer questions provided during the license renewal audit in future submittals.

5. Ensure supplements are consistent with RAI responses.

6. The license renewal submittal credits the ISI program for vessel thermal sleeve aging assessment, which the NRC has identified as not being technically appropriate. NMP will reassess the technical approach and resubmit their response.

7. Completeness of RAP s needs improvement. For example, the BWRVIP Program was credited for managing the effects of intergrannular stress corrosion cracking (IGSCC) in reactor coolant system components; however, other systems susceptible to IGSCC were not addressed.

• Improve the frequency and quality of our communication with the NRC to prevent the development of any new quality issues.

• Enter all concerns identified within this letter into the site corrective action program.

NMPNS respectfully requests this grace period in order to aggressively recover the quality of our LRA and to allow the NRC to optimize the critical staff resources needed to complete our pending application review.

A TJO/DEV/sac

Page 3 NMPIL 1933 cc:

Mr. J. E. Dyer, Director, Office of Nuclear Reactor Regulation Mr. S. J. Collins, NRC Regional Administrator, Region I Mr. D. B. Matthews, Director, Division of Regulatory Improvement Programs Mr. F. P. Gillespie, Deputy Director, Division of Regulatory Improvement Programs Mr. P. T. Kuo, Director, License Renewal and Environmental Impacts Program Mr. N. B. Le, License Renewal Project Manager, NRR Mr. G. K. Hunegs, NRC Senior Resident Inspector Mr. P. S. Tam, Senior Project Manager, NRR