ML081710787

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GL 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems, Proposed Alternative Course of Action
ML081710787
Person / Time
Site: Dresden, Peach Bottom, Oyster Creek, Byron, Braidwood, Limerick, Quad Cities, LaSalle, Crane
Issue date: 09/18/2008
From: Joel Wiebe
Plant Licensing Branch III
To: Pardee C
AmerGen Energy Co, Exelon Generation Co
Wiebe, Joel NRR/DORL/LPL3-2, 415-6606
References
TAC MD7797, TAC MD7798, TAC MD7804, TAC MD7805, TAC MD7822, TAC MD7823, TAC MD7839, TAC MD7840, TAC MD7841, TAC MD7842, TAC MD7855, TAC MD7860, TAC MD7861, TAC MD7868, TAC MD7869, TAC MD7888
Download: ML081710787 (42)
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Text

September 18, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC Chief Nuclear Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; OYSTER CREEK NUCLEAR GENERATING STATION; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; AND THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7797, MD7798, MD7804, MD7805, MD7822, MD7823, MD7839, MD7840, MD7841, MD7842, MD7855, MD7860, MD7861, MD7868, MD7869, MD7888)

Dear Mr. Pardee:

On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), Exelon Generation Company, LLC, and AmerGen Energy Company, LLC (the licensees) replied to GL 2008-01 for the subject plants, and included 3-month responses for the following plants: Braidwood Station, Unit 1; Byron Station, Unit 2; Dresden Nuclear Power Station, Units 2 and 3; LaSalle County

Station, Units 1 and 2; Limerick Generating Station, Unit 2; Oyster Creek Nuclear Generating Station; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Unit 1; and Three Mile Island Nuclear Station, Unit 1. The NRC staffs assessment of the responses for each plant is contained in Enclosures 1 through 9 of this letter.

The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance for the above plants and concluded that, with the exception of the clarifications and associated requests discussed in the enclosures, it is acceptable. This letter allows the licensees to implement their proposed alternative course of action provided that implementation is consistent with the clarifications and associated requests discussed in the enclosures.

If you have any questions, please contact me at (301) 415-6606.

Sincerely,

/RA/

Joel Wiebe, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-237, 50-249, 50-373, 50-374, 50-352, 50-353, 50-219, 50-277, 50-278, 50-254, 50-265, and 50-289

Enclosures:

- Braidwood Station, Unit 1 - Byron Station, Unit 2 - Dresden Nuclear Power Station, Units 2 and 3 - LaSalle County Station, Units 1 and 2 - Limerick Generating Station, Unit 2 - Oyster Creek Nuclear Generating Station - Peach Bottom Atomic Power Station, Units 2 and 3 - Quad Cities Nuclear Generating Station, Unit 1 - Three Mile Island Nuclear Station, Unit 1 cc w/encl: See next page

ML081710787 OFFICE LPL3-2/PM LPL3-2/LA DSS/DD DPR/PGCB/BC LPL1-2/BC LPL3-2/BC NAME JWiebe THarris*

JWermiel MMurphy HChernoff (REnnis for)

RGibbs DATE 9/17/08 9/17/08 9 / 16 /08 9/ 17 /08 9/17/08 9/18/08

Braidwood/Byron Stations cc:

Corporate Distribution Exelon Generation Company, LLC Via e-mail Byron Distribution Exelon Generation Company, LLC Via e-mail Braidwood Distribution Exelon Generation Company, LLC Via e-mail Dwain W. Alexander, Project Manager Westinghouse Electric Corporation Via e-mail Howard A. Learner Environmental Law and Policy Center of the Midwest Via e-mail Byron Resident Inspector U.S. Nuclear Regulatory Commission Via e-mail Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Chairman, Ogle County Board Oregon IL, 61061 Via e-mail Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, IL 61107 Attorney General Springfield, IL 62701 Via e-mail Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness Via e-mail Mr. Barry Quigley 3512 Louisiana Rockford, IL 61108 Braidwood Resident Inspector U.S. Nuclear Regulatory Commission Via e-mail Will County Executive Via e-mail Ms. Bridget Little Rorem Appleseed Coordinator Via e-mail Dresden and Quad Cities Nuclear Power Stations cc:

Corporate Distribution Exelon Generation Company, LLC Via e-mail Dresden Distribution Exelon Generation Company, LLC Via e-mail Quad Cities Distribution Exelon Generation Company, LLC Via e-mail Dresden Resident Inspector U.S. Nuclear Regulatory Commission Via e-mail Chairman Grundy County Board Via e-mail

Quad Cities Resident Inspector U.S. Nuclear Regulatory Commission Via e-mail David C. Tubbs MidAmerican Energy Company Via e-mail Managing Senior Attorney MidAmerican Energy Company Via e-mail Chairman Rock Island County Board of Supervisors Via e-mail LaSalle County Station, Units 1 and 2 cc:

LaSalle Distribution Exelon Generation Company, LLC Via e-mail LaSalle Resident Inspector U.S. Nuclear Regulatory Commission Via e-mail Phillip P. Steptoe, Esquire Sidley and Austin Via e-mail Assistant Attorney General Chicago, IL 60601 Via e-mail Chairman LaSalle County Board Via e-mail Chairman Illinois Commerce Commission Via e-mail Robert Cushing, Chief, Public Utilities Division Illinois Attorney General's Office 100 W. Randolph Street Chicago, IL 60601

Limerick Generating Station, Unit Nos. 1 and 2 cc:

Site Vice President Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Plant Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Vice President - Operations, Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Manager Licensing Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Director, Bureau of Radiation Protection Pennsylvania Dept. of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Associate General Counsel Exelon Generating Company, LLC 4300 Winfield Road Warrenville, IL 60555

Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:

Site Vice President Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Plant Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Regulatory Assurance Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station P.O. Box 399 Delta, PA 17314 Mr. Roland Fletcher Department of Environment Radiological Health Program 2400 Broening Highway Baltimore, MD 21224 Board of Supervisors Peach Bottom Township 545 Broad Street Ext.

Delta, PA 17314-9203 Mr. Richard McLean Power Plant and Environmental Review Division Department of Natural Resources B-3, Tawes State Office Building Annapolis, MD 21401 Manager-Financial Control & Co-Owner Affairs Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236 Three Mile Island Nuclear Station, Unit 1 cc:

Site Vice President AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057 Chairman Board of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120 Chairman Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 Senior Resident Inspector (TMI-1)

U.S. Nuclear Regulatory Commission P.O. Box 219 Middletown, PA 17057 Plant Manager AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057 Regulatory Assurance Manager AmerGen Energy Company, LLC P.O. Box 480 Middletown, PA 17057 Ronald Bellamy, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Michael A. Schoppman Framatome ANP, Suite 705 1911 North Ft. Myer Drive Rosslyn, VA 22209 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 Oyster Creek Nuclear Generating Station cc:

Site Vice President - Oyster Creek Nuclear Generating Station AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Kathryn M. Sutton, Esquire Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Oyster Creek Nuclear Generating Station Plant Manager AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 BRAIDWOOD STATION, UNIT 1 DOCKET NO. 50-456

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), Exelon Generation Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Braidwood Station, Unit 1. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of Unit 1 cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to elevated dose rates.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage of Unit 1 scheduled for spring 2009. The licensees letter dated April 11, 2008, listed the following commitments for Braidwood, Unit 1:

1. Complete detailed walkdowns of Unit 1 inaccessible piping sections of GL 2008-01 subject systems prior to startup from the spring 2009 refueling outage.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of Unit 1 inaccessible piping sections within 60 days following startup from the spring 2009 refueling outage.
3. Submit a supplemental response to the NRC documenting completion of the Unit 1 walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from the spring 2009 refueling outage.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems, can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for Unit 1, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at Braidwood, Unit 1.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the Braidwood, Unit 1, spring 2009, refueling outage, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the next refueling outage scheduled for spring 2009 at Braidwood, Unit 1.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 BYRON STATION, UNIT 2 DOCKET NO. 50-455

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), Exelon Generation Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Byron Station, Unit 2. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of Unit 2 cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to elevated dose rates.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage of Unit 2 scheduled for fall 2008. The licensees letter dated April 11, 2008, listed the following commitments for Byron Station, Unit 2:

1. Complete detailed walkdowns of Unit 2 inaccessible piping sections of GL 2008-01 subject systems prior to startup from the fall 2008 refueling outage.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of Unit 2 inaccessible piping sections within 60 days following startup from the fall 2008 refueling outage.
3. Submit a supplemental response to the NRC documenting completion of the Unit 2 walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from the fall 2008 refueling outage.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for Unit 2, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at Byron Station, Unit 2.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the Byron Station, Unit 2, fall 2008, refueling outage, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the next refueling outage scheduled for fall 2008 at Byron Station, Unit 2.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-237 AND 50-249

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), Exelon Generation Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Dresden Nuclear Power Station (DNPS), Units 2 and 3. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of DNPS, Units 2 and 3, cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to elevated dose rates and a nitrogen-inerted containment atmosphere.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage for Unit 3 scheduled for fall 2008 and for Unit 2 scheduled for fall 2009. The licensees letter dated April 11, 2008, listed the following commitments for DNPS, Units 2 and 3:

1. Complete detailed walkdowns of the inaccessible piping sections of GL 2008-01 subject systems prior to startup from each of the fall 2009 and fall 2008 refueling outages at DNPS, Units 2 and 3, respectively.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of DNPS inaccessible piping sections within 60 days following startup from each of the fall 2009 and fall 2008 refueling outages at DNPS, Units 2 and 3, respectively.
3. Submit a supplemental response to the NRC documenting completion of the DNPS walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from each of the fall 2009 and fall 2008 refueling outages at DNPS, Units 2 and 3, respectively.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for each unit, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at DNPS, Units 2 and 3.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the DNPS, Units 2 and 3, refueling outages, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from each of the fall 2009 and fall 2008 refueling outages at DNPS, Units 2 and 3, respectively.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 LASALLE COUNTY STATION, UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), Exelon Generation Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for LaSalle County Station (LSCS), Units 1 and 2. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of LSCS, Units 1 and 2, cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to high radiation areas and/or a nitrogen-inerted containment atmosphere during power operation.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage for Unit 2 scheduled for spring 2009 and for Unit 1 scheduled for spring 2010. The licensees letter dated April 11, 2008, listed the following commitments:

1. Complete detailed walkdowns of the LSCS inaccessible piping sections of GL 2008-01 subject systems prior to startup from each of the spring 2010 and spring 2009 refueling outages at LSCS, Units 1 and 2, respectively.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of LSCS inaccessible piping sections within 60 days following startup from each of the spring 2010 and spring 2009 refueling outages at LSCS, Units 1 and 2, respectively.
3. Submit a supplemental response to the NRC documenting completion of the LSCS walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from each of the spring 2010 and spring 2009 refueling outages at LSCS, Units 1 and 2, respectively.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for each unit, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at LSCS, Units 1 and 2.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the LSCS, Units 1 and 2, refueling outages, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from each of the spring 2010 and spring 2009 refueling outages at LSCS, Units 1 and 2, respectively.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 LIMERICK GENERATING STATION, UNIT 2 DOCKET NO. 50-353

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), Exelon Generation Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Limerick Generating Station, Unit 2. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of Limerick Generating Station, Unit 2, cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to high radiation areas and/or a nitrogen-inerted atmosphere.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage of Unit 2 scheduled for spring 2009. The licensees letter dated April 11, 2008, listed the following commitments for Limerick Generating Station, Unit 2:

1. Complete detailed walkdowns of the Unit 2 inaccessible piping sections of GL 2008-01 subject systems prior to startup from the spring 2009 refueling outage.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of Unit 2 inaccessible piping sections within 60 days following startup from the spring 2009 refueling outage.
3. Submit a supplemental response to the NRC documenting completion of the Unit 2 walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from the spring 2009 refueling outage.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for Unit 2, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at Limerick Generating Station, Unit 2.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the Limerick Generating Station, Unit 2, spring 2009, refueling outage, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the spring 2009 refueling outage at Limerick Generating Station, Unit 2.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 OYSTER CREEK NUCLEAR GENERATING STAION DOCKET NO. 50-219

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), AmerGen Energy Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Oyster Creek Nuclear Generating Station (OCNGS). The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of OCNGS cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to containment being inerted.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage of OCNGS scheduled for fall 2008. The licensees letter dated April 11, 2008, listed the following commitments:

1. Complete detailed walkdowns of the inaccessible piping sections of GL 2008-01 subject systems prior to startup from the fall 2008 refueling outage.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of inaccessible piping sections within 60 days following startup from the fall 2008 refueling outage.
3. Submit a supplemental response to the NRC documenting completion of the walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from the fall 2008 refueling outage.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for OCNGS, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at OCNGS.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the OCNGS, fall 2008, refueling outage, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the fall 2008 refueling outage at OCNGS.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), Exelon Generation Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of PBAPS, Units 2 and 3, cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to high radiation areas and nitrogen-inerted containment.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage for Unit 2 scheduled for fall 2008 and for Unit 3 scheduled for fall 2009. The licensees letter dated April 11, 2008, listed the following commitments:

1. Complete detailed walkdowns of the PBAPS inaccessible piping sections of GL 2008-01 subject systems prior to startup from each of the fall 2008 and fall 2009 refueling outages at PBAPS, Units 2 and 3, respectively.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of PBAPS inaccessible piping sections within 60 days following startup from each of the fall 2008 and fall 2009 refueling outages at PBAPS, Units 2 and 3, respectively.
3. Submit a supplemental response to the NRC documenting completion of the walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from each of the fall 2008 and fall 2009 refueling outages at PBAPS, Units 2 and 3, respectively.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for each unit, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at PBAPS.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the PBAPS, Units 2 and 3, refueling outages, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from each of the fall 2008 and fall 2009 refueling outages at PBAPS, Units 2 and 3, respectively.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 QUAD CITIES NUCLEAR POWER STATION, UNIT 1 DOCKET NOS. 50-254

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), Exelon Generation Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Quad Cities Nuclear Power Station (QCNPS), Unit 1. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of QCNPS, Unit 1, cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to high radiation areas and/or nitrogen-inerted containment.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage of Unit 1 scheduled for spring 2009. The licensees letter dated April 11, 2008, listed the following commitments:

1. Complete detailed walkdowns of the Unit 1 inaccessible piping sections of GL 2008-01 subject systems prior to startup from the spring 2009 refueling outage.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of Unit 1 inaccessible piping sections within 60 days following startup from the spring 2009 refueling outage.
3. Submit a supplemental response to the NRC documenting completion of the Unit 1 walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from the spring 2009 refueling outage.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for Unit 1, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at QCNPS, Unit 1.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the QCNPS, Unit 1, spring 2009, refueling outage, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the spring 2009 refueling outage at QCNPS, Unit 1.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

U.S. NUCLEAR REGULATORY COMMISSION ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 THREE MILE ISLAND NUCLEAR STATION, UNIT 1 DOCKET NO. 50-289

1. Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.

Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),

GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.

2. Licensees Proposed Alternative Course of Action By letter dated April 11, 2008 (ADAMS Accession No. ML081020758), AmerGen Energy Company, LLC (the licensee) submitted a 3-month response to GL 2008-01 for Three Mile Island Nuclear Station (TMI), Unit 1. The licensee stated they cannot meet the requested 9-month schedule for submitting the requested information because walkdowns of the GL subject systems of TMI, Unit 1, cannot be completed. The walkdowns cannot be completed because portions of the GL subject systems are inaccessible during power operation due to high radiation areas.

The licensee also stated that all other GL actions will be completed during the 9-month timeframe prescribed in the GL (i.e., by October 11, 2008). As an alternative course of action, the licensee plans to complete walkdowns of those areas only accessible during an outage during the next refueling outage for Unit 1 scheduled for fall 2009. The licensees letter dated April 11, 2008, listed the following commitments:

1. Complete detailed walkdowns of the Unit 1 inaccessible piping sections of GL 2008-01 subject systems prior to startup from the fall 2009 refueling outage.
2. Complete evaluations of GL 2008-01 subject systems using the results of the detailed walkdowns of Unit 1 inaccessible piping sections within 60 days following startup from the fall 2009 refueling outage.
3. Submit a supplemental response to the NRC documenting completion of the Unit 1 walkdowns and any impact upon the GL 2008-01 9-month response as a result of completed evaluations within 90 days following startup from the fall 2009 refueling outage.

The licensee stated that the alternative course of action is acceptable based on the following:

1. operating experience, which includes system walkdowns;
2. detailed evaluations; and
3. testing.

Based on the above considerations, the licensee stated that it has confidence that the subject systems can fulfill their required functions. As such, the licensee concluded that completing performance of the detailed walkdowns of a portion of piping sections outside of the requested 9-month timeframe, but no later than startup from the next refueling outage for Unit 1, is an acceptable alternative course of action.

3. NRC Staff Assessment The NRC staff finds that, with the exception of the clarifications and associated requests discussed below, that the licensees proposed alternative course of action is acceptable based on the above-described operating experience, testing, and detailed evaluations associated with managing gas accumulation at TMI, Unit 1.

The NRC staff notes examples where the licensees 3-month submittal dated April 11, 2008, does not clearly describe the content and/or schedule for the 9-month submittals. Specifically, the licensee does not provide information indicating if it will submit the walkdowns and evaluations of the accessible piping within the GL scope by the timeframe prescribed in the GL (i.e., by October 11, 2008).

The NRC staff requests the licensee to submit the information requested in GL 2008-01 as follows:

(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the TMI, Unit 1, fall 2009, refueling outage, provide all GL requested information to the NRC by October 11, 2008.

(2) 9-Month Supplemental (Post-Outage) Submittal - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from the fall 2009 refueling outage at TMI, Unit 1.

For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensee should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.

The NRC staff noted that the licensees submittal dated April 11, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.

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