ML091690457
| ML091690457 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/21/2009 |
| From: | Richmond J NRC Region 1 |
| To: | Mcnamara N NRC Region 1 |
| References | |
| FOIA/PA-2009-0070 | |
| Download: ML091690457 (11) | |
Text
Nathan Lafferty From: John Richmond )
Sent: Wednesday, January 21, 2009 3:07 PM To: Nancy McNamara
Subject:
OC 2008-07 Comm Plan Attachments: OC LRI 2008-07 Comm Plan Final.doc I
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Date: Wed, 21 Jan 2009 15:06:49 -0500
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OC 2008-07 Comm Plan Thread-Topic: OC 2008-07 Comm Plan Thread-Index: Acl8A8uM M12jPFK/TeeEWQfsz8dVsg==
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OF(IC(AL U7 ON{(Y - PRkDECIKONAL- t WWE Fý Communications Plan and Notification Sequence Issuance of the License Renewal Commitment Inspection for Oyster Creek Drywell Containment Shell Goal To communicate the results of the NRC staffs inspection during the recent refueling outage of Exelon's activities to assess the operability of the drywell primary containment and the implementation of various license renewal commitments for Oyster Creek,with particular focus on the drywell primary containment shell.
Key Messages
- 1) Region I completed a multi-week inspection of AmerGen's aging management programs associated with the drywell primary containment, including the:
" Containment Metallic Liner Inservice Inspection
" Structures Monitoring Program
" Protective Coating Monitoring and Maintenance Program The State of New Jersey State Engineers observed portions of the NRC staff review.
- 2) The NRC staff determined AmerGen has provided an adequate basis to conclude the drywell primary containment will remain operable during' the period until the next scheduled examination at a refueling outage in 2012.
- 3) The NRC staff concluded there were no safety significant conditions affecting the drywell steel shell.
- 4) Since a renewed license has not been issued, the proposed license conditions and associated commitments, made as a part of the license renewal application, are not yet in effect. As a consequence, the report only records the inspectors"observations. Four observations made during this inspection, involving issues entered into Exelon's corrective action program, were listed in the inspection report as an unresolved item. More information is required in order to determine whether the unresolved item conditions are acceptable, or to evaluate if any future enforcement action is necessary if a renewed license is issued.
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Time ACTION Responsible Sequence Organization/Individual T= 0 Hour Inspection report signed by Regional Management RI - Roberts T = 0.5 Hour Call Exelon's VP - License Renewal and Communicate Report RI - Roberts Issuance T = 1.5 Hours Communicate key messages to the New Jersey DEP RI - McNamara T = 1.5 Hours Communicate key messages to Local Officials, if any, as determined by the responsible DRP Branch Chief RI - Bellamy T= 1.5 Hours Communicate key messages to NJ Congressional Offices, particularly Congressman Smith OCA - Dacus T= 3 Hours + Respond to Media Inquiries - see developed Q&As attached RI - Screnci / Sheehan Audience / Stakeholders Exelon (Oyster Creek Nuclear Generating Station)
Senators for New Jersey (Senators Lautenberg & Menendez)
House of Representatives for NJ (Representatives Saxton, Smith, Andrews, Holt, Pallone &
Pascrell)
New Jersey Department of Environmental Protection Selected local officials Communication Team Eugene Dacus Office of Congressional Affairs 301/415-3693 Richard Conte Chief, Engineering Branch 1, DRS 610/337-5183 Nancy McNamara State Liaison Officer 610/337-5337 John Richmond Reactor Inspector 610/337-5220 Ron Bellamy Chief, Projects Branch 6, DRP 610/337-5200 Diane Screnci Senior Public Affairs Officer 610/337-5330 Neil Sheehan Public Affairs Officer 610/337-5331
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OF,/CPU_-eON PRED Cl/IONAL INIFO(ATICON Drywell Shell Background In the mid-1 980s, GPU Nuclear (the previous licensee) identified corrosion of selected lower portions of the Oyster Creek drywell containment steel shell in the so-called "sand bed" region.
Initial licensee actions were not effective in arresting the corrosion. In 1992, all sand was removed from the sand bed region and the accessible exterior surfaces of the drywell shell were cleaned and coated with epoxy. Ultrasonic test (UT) thickness measurements of the drywell shell taken in 1992 and 1996 indicated the corrosion had been effectively arrested. This information was confirmed by UT measurements in 2006 during a refueling outage.
License Renewal Background AmerGen (now Exelon) submitted a License Renewal Application (LRA) for Oyster Creek on July 22, 2005. The license renewal team inspection occurred in March 2006. Inspection Report 50-219/2006-007 dated September 21, 2006, documented the inspection results. Among many other areas, the LRA addressed the management of aging effects for primary containment, including drywell shell corrosion in the sand bed region.
The Atomic Safety and Licensing Board (ASLB) held a hearing on a contention regarding the frequency of planned drywell shell UT inspections. In December 2007, the ASLB ruled in AmerGen's (Exelon's) favor. Citizens (intervener) appealed this decision to the Commission on January 14, 2008. In May 2008, the Commission requested the ASLB to resolve concerns related to planned 3 dimensional (3-D) finite analysis of the drywell shell. The ASLB held oral arguments on September 18, 2008, and responded in a memorandum to the Commission on October 29, 2008.
Citizens had another appeal to the Commission related to a July 2008 ASLB decision to deny admitting a new contention on metal fatigue and the issue is under Commission review.
Future Actions NRC Commissioners decide on two ASLB appeals related to renewed license - TBD Region I will perform a non-outage license renewal inspection - planned for March 9 - 27, 2009.
The current operating license for Oyster Creek expires on April 9, 2009.
Anticipated Questions and Answers QI: What prompted this inspection?
Al: This was a scheduled inspection, in accordance with the license renewal process, and used NRC Inspection Procedure 71003, "Post-Approval Site Inspection for License Renewal." The inspection is intended to ensure proper implementation of license renewal conditions and associated regulatory commitment activities, which occur during the refueling outage just prior to the period of extended operation. NRC inspectors focus on equipment which would be inaccessible during reactor operation, such as the drywell.
Representatives of the State of New Jersey observed elements of this inspection.
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Q2: How do the inspection results affect the license renewal process?
A2: Normally for a renewed license, they confirm proper implementation of conditions and commitments made by the licensee during the course of the application review and approval process, as documented in the NRC staffs safety evaluation report (SER).
Q3: Why is the reactor safe to operate given the observations made by the NRC during the inspection?
A3: There were no identified significant conditions affecting the drywell primary containment structural integrity.
Q4: What do the issues identified during the inspection mean for license renewal?
A4: The issues found were identified through the implementation of several aging management programs which were in place to manage the effects of aging in the sand bed regionof the drywell shell.
Q5: When will the drywell coating in the sand bed region of the drywell shell be inspected again?
A5: The next visual inspection of the coating in the sand bed region of the drywell shell is scheduled for every other refueling outage, or four years from now. Exelon reports that this frequency will be reviewed and evaluated as a result of observing several drywell coating blisters during the recent inspection.
Q6: What has the NRC done in response to these observations?
A6: The NRC Region I staff closely followed Exelon's investigation, including performing an independent inspection of the drywell coating blisters and observation of the removal of the blisters. The Region I staff was also in contact with the State of New Jersey and the NRC Headquarters staff. A follow-up inspection is planned for March 2009.
Q7: The inspection report says there was a challenge to keep water out of the sand bed region. What can you say about that?
A7: On November 7, 2008, AmerGen reported an apparent de-lamination of the strippable coating applied to the liner of the reactor refueling cavity; this was visually evident over the ensuing weekend. Water subsequently overflowed the reactor cavity drain trough (which is designed to collect small amounts of water that may leak from the reactor cavity seal during refueling) and into the sand bed region (i.e., evidence of moisture was observed in several sand bed bays). There was also increased cavity trough drain leakage estimated at 4 to 6 gallons per minute.
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?FI<AL U E/O Y -PREA C IONAL INF 7 (M ION After the reactor cavity was drained, there was a final inspection of all 10 sand bed bays, and no adverse effects were identified. AmerGen/Exelon confirmed there was a substantial margin in the drywell shell thickness in the upper drywell elevations where some water may have impinged on the uncoated drywell shell surface.
Q8: Will the UT data collected during this outage regarding the drywell liner be used as an input for the 3-D finite element analysis AmerGen must perform prior to entering a period of license renewal?
A8: During this outage, AmerGen is taking ultrasonic thickness (UT) measurements of the drywell shell in numerous locations, as required by license renewal commitments.
AmerGen has stated that those UT data values will be used as inputs for the 3-D analysis. The 3-D analysis will confirm margins reflected in the current licensing basis, but is it is not required to replace the current licensing basis calculations.
Q9: Why doesn't this report look like a normal inspection report issued in accordance with ROP guidance (IMC 0612)?
Because an appealof a licensing board decision about the Oyster Creek application for a renewed license is pending before the Commission, a renewed license has not been issued and the proposed license conditions and associated regulation commitments, made as a part of the license renewal application, are not yet in effect. As a consequence, the report only records the inspectors' observations.
By way of background, the NRC's Reactor Oversight Process mid-cycle letter of September 2, 2008 (ML082470569) informed Exelon that the NRC would be conducting two license renewal inspections prior to the period of extended operation. The NRC conducted the first inspection using the guidance of Inspection Procedure (IP) 71003 "Post-Approval Site Inspection for License Renewal" as a prudent measure to observe Oyster Creek license renewal activities during the last planned refueling outage prior to entering the period of extended operation. The inspection examined important license renewal activities conforming to the Commission's rules and regulations. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel. This inspection focused on the inservice inspection of the drywell containment.
Q10: What is the safety significance of the follow-up issues noted? The issues noted in the unresolved item are:
- 1. Exelon applied a strippable coating to the refueling cavity liner to prevent water intrusion into the gap between the drywell steel shell and the concrete shield wall; however, the coating unexpectedly de-laminated. Moreover, Exelon established an administrative limit for cavity seal leakage had not been monitored as intended;
- 2. Exelon frequently monitored the cavity seal leakage by observing flow in the cavity trough drain line; however, Exelon subsequently determined that the drain line had been left isolated;
- 3. Exelon monitored for water leakage from the sand bed bay drains by checking poly bottles connected via tygon tubing and funnels to the sand bed drain lines; however, 02/13/2009 ORKA.L UK'V6 - PREq6C8f0AL INFOO'i10 C:\Documents and Settings\nnl\Local Settings\Temporary Internet Files\Content.Outlook\MUX1MXW1\OC LRI 2008-07 Comm Plan Final (3).doc Page 5 of 8
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Exelon subsequently discovered that the poly bottle tubing was not connected to the drain lines for two sand bays; and,
- 4. Four blisters on the epoxy coating in one sand bed bay were identified, the root cause of which remains to be finalized. A 2006 video recording appeared to indicate that one of the blisters existed at that time, but was not identified during Exelon's 2006 visual inspection.
A10: Based on the results of the NRC's inspection, the NRC determined there were no safety significant conditions affecting current operations.
As noted in the details of report (sections 2, 3.1, 3.2, 3.4, and 3.9), a few current licensing basis issues were observed that for which Exelon initiated corrective action.
Because the issues may be associated with performance deficiencies, an Unresolved Item (URI) is being opened for NRC follow-up. The NRC will review the available information to determine if any performance deficiency exists, along with its significance.
Q1 1: Doesn't this report show that the aging management program for the drywell is inadequate given the problems noted by Exelon and the NRC?.
Al 1: The NRC determined that Exelon provided an adequate basis to conclude the drywell primary containment will remain operable throughout the period to the next scheduled examination during the 2012 refueling outage. This was based on the NRC's evaluation of the drywell shell ultrasonic test (UT) thickness measurements, direct observation of drywell shell conditions both inside the drywell, including the floor trenches, and outside the drywell, in the sand bed regions, condition and integrity of the drywell shell epoxy coating, and condition of the drywell shell moisture barrier seals.
During a future inspection (TBD), the NRC will follow-up on Exelon's evaluation and the repair of four small blisters in sand bed bay 11. Exelon stated that some blistering was expected, and would be identified during routine visual examinations. The NRC staff will review Exelon's evaluation after it is completed.
The drywell shell epoxy coating and the moisture barrier seal, both in the sand bed region, are barriers used to protect the drywell from corrosion. The problems identified and corrected with these barriers had a minimal impact on the drywell steel shell. The shell corrosion rate remains very small, as confirmed by the NRC staff review of Exelon's technical evaluations of the 2008 UT data. The upper areas of the drywell have exhibited limited corrosion since water in that area quickly drains away or evaporates (unlike the former sand bed region which trapped moisture against the steel shell), even though these areas have been wetted in the past (and during this outage).
Q12: Describe what is normally done on a 71003 and how was this inspection at Oyster Creek different?
Al 2: IP 71003 consists of a number of site visits to determine the status of license renewal commitment implementation and overall readiness of the licensee to enter the period of extended operations. This was done at the Ginna facility in 2008, a plant that will enter into its period of extended operation in September of this year. However for Ginna, NRC staff observed those license conditions and associated regulatory commitments at that 02/13/2009 OFV~dIAL UP'O/L/Y - PRE~rECW(6NAL INFOý4I94*N C:\Documents and Settings\nnl\Local Settings\Temporary Internet Files\Content.Outlook\MUX1MXW1\OC LRI 2008-07 Comm Plan Final (3).doc Page 6 of 8
OFY ý(EO Y -PREDVIS/INAL INF 4RTON time since the plant was in the last outage before the start of extended period of operation, and thus provided an opportunity for such close inspections.
At the time of the Ginna review, the license had been renewed. For Oyster Creek, the license has not been renewed, and the proposed license conditions and associated regulatory commitments are not in effect yet. However, the inspection was conducted as a prudent measure to observe the implementation of license renewal activities, given the opportunity presented by the ongoing outage, in the event the renewal is granted.
Q13: Is this the final license renewal commitment inspection? Will the licensee enter the period of extended operations without any further NRC review and attention?
A13: The resident inspectors continue to conduct daily reviews of plant conditions and as aging management issues arise from the licensee monitoring of aging effects, region-based experts will be available to assist.
Those same region-based experts will be involved in the next site inspection in March 2009. The NRC will follow-up on Exelon's evaluation and the repair of four small blisters in sand bed bay 11. Exelon stated that some blistering was expected, and would be identified during routine visual examinations. The NRC staff will review Exelon's evaluation after it is completed, along with the above noted unresolved item.
Q14: When will the Commission rule on the issue in appeal and who issues the renewed Operating license?
Al 4: The completion of the Commission's review is indeterminate to the staff at this time.
Normally, the Director of NRR is the licensing authority for license renewal; however, there may be special direction from the Commission in this case when it decides on the issue on appeal Q1 5: Why was the December exit meeting on Oyster Creek closed to the public?
A15: Most NRC inspection exit meetings are not conducted in a public forum; instead, the resulting inspection report is issued and made publicly available. Throughout the license renewal process, there were a number of meetings open to public observation and questions, including after the NRC's license renewal inspection (Inspection Procedure 71002). Although this exit meeting was not open to the public, the inspection report contains all the information that was discussed during the December exit meeting.
Representative of the State of New Jersey monitored the exit meeting, which was conducted via telephone, as well as observed elements of the inspection.
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sl' OF 0 LY-PREý I ONAL INFO ION Q16: What happens on April 9th? Will Oyster Creek be forced to shutdown if a renewed license has not yet been issued?
Al 6: Under NRC regulations, if a licensee has made a timely filing for a renewed license, that license will continue in force while a license renewal decision remains to be finalized, provided the staff has found continued plant operation to be safe. This policy has been implemented at nuclear materials licensees in the past, but has not yet had to be implemented with a reactor licensee. We note that Exelon/AmerGen was granted an exemption to NRC regulations requiring the filing of a license renewal application by April 9, 2004, or 5 years before the expiration of the current license; Exelon/AmerGen submitted its application, as required by the exemption, by the end of July 2005. This afforded the NRC forty-four (44) months to review the application.
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t J 20 The inspectors also reviewed Exelon's current licensing basis commitment tracking program to evaluate its effectiveness. In addition, the following commitment change evaluation packages were reviewed:
- Commitment Change 08-003, OC Bolting Integrity Program
- b. Observations The inspectors observed that the commitment change activities were conducted in accordance with approved procedures, which required an annual update to the NRC with a summary of each change.
40A6 Meetings, IncludinQ Exit Meetinq Exit Meetinq Summary The inspectors presented the results of this inspection to Mr. T. Rausch, Site Vice President, Mr. M. Gallagher, Vice President License Renewal, and other members of Exelon's staff on December 23, 2008.
No proprietary information is present in this inspection report.