ML091040522

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G20090195/LTR-09-0134/EDATS: SECY-2009-0155 - Ltr. Rep. Eugene Depasquale Follow Up Communication to the Nuclear Regulatory Commission'S Response on Findings and Responses of the Nrc'S Office of the Inspector General Report on the License R
ML091040522
Person / Time
Site: Three Mile Island, Susquehanna  Constellation icon.png
Issue date: 04/24/2009
From: Leeds E
Office of Nuclear Reactor Regulation
To: Depasquale E
State of PA, House of Representatives
Homiack, M, NRR/DLR/RPOB 415-1683
Shared Package
ML091050241 List:
References
EDATS: SECY-2009-0155, G20090195, LTR-09-0134, SECY-2009-0155, TAC ME1022
Download: ML091040522 (2)


Text

April 24, 2009 The Honorable Eugene A. DePasquale Pennsylvania State Legislature 111A East Wing PO Box 202095 Harrisburg, PA 17120

Dear Representative DePasquale:

On behalf of the U.S. Nuclear Regulatory Commission (NRC or the staff), I am responding to your letter of March 23, 2009, regarding your interest in the staffs improvements to the documentation of technical reviews for license renewal applications. The NRC discussed these improvements previously in our September 22, 2008, response to your earlier request.

Specifically, you expressed interest in implementation of the improvements for the Three Mile Island Nuclear Station, Unit 1 (TMI) and Susquehanna Steam Electric Station, Units 1 and 2 (SSES) applications.

In response to the NRCs Office of the Inspector General (OIG) audit report on the license renewal program, the staff has implemented actions to improve license renewal report documentation. Concerning the OIG recommendation to establish report writing standards, the staff updated report-writing guidance to communicate management expectations and report-writing standards for adequately documenting license renewal technical reviews. One guidance document entitled, General Safety Evaluation Report Writing Expectations, addresses the fundamental shortcomings identified by the OIG. Specifically, this document states managements expectations that safety evaluation reports (SERs) are to differentiate clearly between applicant-provided information and the staffs independent analysis and conclusions, and that SERs are to adequately summarize the staffs review methodology and explain the technical basis for staff findings and conclusions. Another guidance document entitled, Safety Evaluation Report Writing Guidelines and Samples, provides the staff with specific examples for implementation of the general writing expectations. This document focuses on improving documentation of reviews of aging management programs and aging management review results, an area of focus in the OIG audit report.

Concerning the recommendation to revise the report quality assurance process, the staff developed a procedure entitled, Safety Evaluation Report Process Review Procedure, to gauge the adequacy and effectiveness of SER preparation. The purpose of the process review is to verify the staffs appropriate implementation of writing guidance and consistency with management expectations. The goal of the procedure is to ensure that each report (1) adequately summarizes rather than copies relevant licensee and NRC information, (2) clearly differentiates between applicant-provided information and the staffs independent conclusions, and (3) provides a well-articulated basis for staff findings and conclusions. Through this process an independent review of the SER is conducted and feedback provided on any areas not meeting the writing standards. Before the SER is issued, the process reviewer verifies that the identified issues are resolved. Issues and suggestions identified during these reviews are communicated to management to further ensure expectations are met.

E. DePasquale The staff provided its response to these OIG recommendations in a letter dated June 26, 2008.

Based on the staffs response regarding the improvements implemented, the OIG subsequently closed those recommendations as being adequately resolved. The staff used the guidance and conducted a process review to support development of the SERs for both the SSES and TMI applications. Based on the findings during the process reviews, implementation of the staffs resolutions to the OIG recommendations resulted in improved SERs for SSES and TMI. Issues identified during these reviews will also be used to continue to improve staff guidance and future SERs.

As a further indication of improvement, during the April 1, 2009, Advisory Committee on Reactor Safeguards (ACRS) Subcommittee meeting for the TMI SER, the ACRS Subcommittee Chairman commented that he was impressed with the thoroughness of the staffs SER on the scoping and screening review and that it was one of the better jobs hed seen. Upcoming milestones for the TMI and SSES projects include planned issuance of the final SERs in July 2009, followed by full-committee ACRS meetings in September and October 2009, respectively.

If you have any further questions regarding the license renewal process, please have your staff contact Brian E. Holian, Director of the Division of License Renewal at 301-415-1183.

Sincerely,

/RA/

Eric J. Leeds, Director Office of Nuclear Reactor Regulation cc: See next page

E. DePasquale The staff provided its response to these OIG recommendations in a letter dated June 26, 2008.

Based on the staffs response regarding the improvements implemented, the OIG subsequently closed those recommendations as being adequately resolved. The staff used the guidance and conducted a process review to support development of the SERs for both the SSES and TMI applications. Based on the findings during the process reviews, implementation of the staffs resolutions to the OIG recommendations resulted in improved SERs for SSES and TMI. Issues identified during these reviews will also be used to continue to improve staff guidance and future SERs.

As a further indication of improvement, during the April 1, 2009, Advisory Committee on Reactor Safeguards (ACRS) Subcommittee meeting for the TMI SER, the ACRS Subcommittee Chairman commented that he was impressed with the thoroughness of the staffs SER on the scoping and screening review and that it was one of the better jobs hed seen. Upcoming milestones for the TMI and SSES projects include planned issuance of the final SERs in July 2009, followed by full-committee ACRS meetings in September and October 2009, respectively.

If you have any further questions regarding the license renewal process, please have your staff contact Brian E. Holian, Director of the Division of License Renewal at 301-415-1183.

Sincerely,

/RA/

Eric J. Leeds, Director Office of Nuclear Reactor Regulation cc: See next page DISTRIBUTION: G20090195/LTR-09-0134/EDATS: SECY-2009-0155 See next page

  • concurred via e-mail Adams Accession Nos.: (Package) ML091050241, (Incoming) ML090970044, (Response) ML091040522 OFFICE PM:RPOB:DLR LA:DLR TechEd* BC:RPOB:DLR NAME MHomiack YEdmonds KAzariah-Kribbs TTate (JDaily for)

DATE 04/22/09 04/22/09 04/20/09 04/22/09 OFFICE BC:DRS:RI* D:NRR:DLR OD:NRR NAME RConte BHolian ELeeds DATE 04/17/09 04/22/09 04/24/09 OFFICIAL RECORD COPY

Letter to E. DePasquale from E. Leeds, dated April 24, 2009

SUBJECT:

FOLLOW UP COMMUNICATION TO THE NUCLEAR REGULATORY COMMISSION'S RESPONSE ON FINDINGS AND RESPONSES OF THE NRC'S OFFICE OF THE INSPECTOR GENERAL REPORT ON THE LICENSE RENEWAL PROGRAM, SEPTEMBER 22, 2008 DISTRIBUTION: G20090195/LTR-09-0134/EDATS: SECY-2009-0155 HARD COPY:

DLR RF E-MAIL:

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cc:

The Honorable Jeffrey E. Piccola Senate of Pennsylvania Senate Box 203015 Harrisburg, PA 17120

Susquehanna Steam Electric Station, Units 1 and 2 cc:

Cornelius J. Gannon Associate General Counsel Vice President - Nuclear Operations PPL Services Corporation PPL Susquehanna, LLC Two North Ninth Street, GENTW3 769 Salem Blvd., NUCSB3 Allentown, PA 18101-1179 Berwick, PA 18603-0467 Document Control Services Robert M. Paley PPL Susquehanna, LLC General Manager - Plant Support Two North Ninth Street, GENPL4 PPL Susquehanna, LLC Allentown, PA 18101-1179 769 Salem Blvd., NUCSB2 Berwick, PA 18603-0467 Richard W. Osborne Allegheny Electric Cooperative, Inc.

Michael H. Crowthers 212 Locust Street Manager - Nuclear Regulatory Affairs P.O. Box 1266 PPL Susquehanna, LLC Harrisburg, PA 17108-1266 Two North Ninth Street, GENPL4 Allentown, PA 18101-1179 Director, Bureau of Radiation Protection Pennsylvania Department of Ronald E. Smith Environmental Protection General Manager - Site Preparedness Rachel Carson State Office Building and Services P.O. Box 8469 PPL Susquehanna, LLC Harrisburg, PA 17105-8469 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467 Senior Resident Inspector U.S. Nuclear Regulatory Commission Michael H. Rose P.O. Box 35, NUCSA4 Manager - Quality Assurance Berwick, PA 18603-0035 PPL Susquehanna, LLC 769 Salem Blvd., NUCSB2 Regional Administrator, Region 1 Berwick, PA 18603-0467 U.S. Nuclear Regulatory Commission 475 Allendale Road Joseph J. Scopelliti King of Prussia, PA 19406 Community Relations Manager, Susquehanna Dr. Judith Johnsrud PPL Susquehanna, LLC National Energy Committee 634 Salem Blvd., SSO Sierra Club Berwick, PA 18603-0467 443 Orlando Avenue State College, PA 16803 Board of Supervisors Salem Township Dayne R. Brophy Bryan A. Snapp, Esq. Nuclear Regulatory Affairs P.O. Box 405 PPL Susquehanna, LLC Berwick, PA 18603-0035 769 Salem Blvd., NUCSA4 Berwick, PA 18603-0467

Three Mile Island Nuclear Station, Unit 1 cc:

Site Vice President - Three Mile Island Director Nuclear Station, Unit 1 Bureau of Radiation Protection Exelon Generation Company, LLC Pennsylvania Department of P.O. Box 480 Environmental Protection Middletown, PA 17057 Rachel Carson State Office Building P.O. Box 8469 Senior Vice President - Mid- Harrisburg, PA 17105-8469 Atlantic Operations Exelon Generation Company, LLC Plant Manager - Three Mile Island Nuclear 200 Exelon Way, KSA 3-N Station, Unit 1 Kennett Square, PA 19348 Exelon Generation Company, LLC P. O. Box 480 Vice President - Licensing and Regulatory Middletown, PA 17057 Affairs Exelon Generation Company, LLC Manager, Regulatory Assurance -

4300 Winfield Road Three Mile Island Nuclear Station, Unit 1 Warrenville, IL 60555 Exelon Generation Company, LLC P.O. Box 480 Regional Administrator Middletown, PA 17057 Region I U.S. Nuclear Regulatory Commission Ronald Bellamy, Region I 475 Allendale Road U.S. Nuclear Regulatory Commission King of Prussia, PA 19406 475 Allendale Road King of Prussia, PA 19406 Chairman Board of County Commissioners Michael A. Schoppman of Dauphin County Framatome ANP Dauphin County Courthouse Suite 705 Harrisburg, PA 17120 1911 North Ft. Myer Drive Rosslyn, VA 22209 Chairman Board of Supervisors Dr. Judith Johnsrud of Londonderry Township National Energy Committee R.D. #1, Geyers Church Road Sierra Club Middletown, PA 17057 433 Orlando Avenue State College, PA 16803 Senior Resident Inspector (TMI-1)

U.S. Nuclear Regulatory Commission Eric Epstein P.O. Box 219 TMI Alert Middletown, PA 17057 4100 Hillsdale Road Harrisburg, PA 17112 Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC Correspondence Control Desk Correspondence Control Exelon Generation Company, LLC P.O. Box 160 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348 Kennett Square, PA 19348

Three Mile Island Nuclear Station, Unit 1 cc:

Manager Licensing Albert A. Fulvio Exelon Generation Company, LLC License Renewal Senior Project Manager Correspondence Control Exelon Nuclear P.O. Box 160 200 Exelon Way Kennett Square, PA 19348 Kennett Square, PA 19348 Christopher M. Crane President and Chief Operating Officer Exelon Corporation Chief Operating Officer, Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Charles G. Pardee Senior Vice President, Exelon Generation Company, LLC President & Chief Nuclear Officer Exelon Nuclear, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Michael J. Pacilio Senior Vice President, Exelon Generation Company, LLC Chief Operating Officer, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 Senior Vice President, Operations Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL.60555 Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Frederick W. Polaski Manager License Renewal Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348