ML091700523

E-mail from R. Conte of USNRC to M. Modes of Usrnc, Regarding Oc Exit Meeting Next Steps

ML091700523
Person / Time
Site:	Oyster Creek
Issue date:	12/03/2008
From:	Conte R NRC Region 1
To:	Modes M NRC Region 1
References
FOIA/PA-2009-0070
Download: ML091700523 (6)

Text

John Richmond From:

Sent:

To:

Cc:

Subject:

Attachments:

Richard Conte 1 ?-T.

Wednesday, December 03, 2008 2:26 PM Michael Modes John Richmond I HEAR YOU AGREED TO HELP OC Exit Meeting Next Steps.doc Please review attached.

Keep you pen in your pocket and you fingeres off the key board.

This is my product for my boss. Call me on high level concems and factual inadequacies or Am I missing a key question for debate.

agoomCe wft the Freedor of lnftarmu!oV AM 1

/57

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([148.184.99.10]) with mapi; Wed, 3 Dec 2008 14:26:15 -0500 Content-Type: application/ms-tnef; name="winmail.dat" Content-Transfer-Encoding: binary From: Richard Conte <Richard.Conte@nrc.gov>

To: Michael Modes <Michael. Modes@nrc.gov>

CC: John Richmond <John.Richmond@nrc.gov>

Date: Wed, 3 Dec 2008 14:26:14 -0500

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I HEAR YOU AGREED TO HELP Thread-Topic: I HEAR YOU AGREED TO HELP Thread-Index: AclVfQGyDGxvZ9vwRW+M24FbE3H4pA==

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OYSTER CREEK COMMITMENT INSPECTION Per IP 71003 - App. C MC 2515, Infrequent Procedures STATUS AND NEXT STEPS (As of 12/02/08)

DISCUSSION:

(b)(5)

(b)(5) the Deputy Division Director of DRS assignedEB 1 to build consensus in this area by developing and implementing an action plan.

On December 2, 2008, Region I staff met with cognizant representatives of DRP PB6, NRR/DLR, OGC, SLO, PAO in order to dry-run the exit notes for the subject inspection. The telephonic exit with Amergen was to be conducted on December 3, 2008 with a separate brief for the State of New Jersey, who had been observing the inspection since the start and have expressed concerns about Amergens continued failure to meet commitments, etc. Amergen started up Oyster Creek the Week of Nov. 17 based on no immediate safety concerns with the problems found (self revealing or licensee identified) in the outage related specifically the license renewal commitments area with particular focus on Drywell integrity. Region I also issued a PN on the matter on December 18, 2008, Attachment 1.

And executive summary of the inspection results can be characterized as follows:

• Satisfactory Actions to evaluate primary containment structural integrity L

(b)(5) have roots in actions from a significant condition adverse to quality - Drywell Corrosion o

Monitoring of various drain lines for the refueling cavity and former sand bed region.

o Strippable Coating to Prevent Water Intrusion For the selected samples r-(b)(5)

O Sampled 9 AMPs to Verify Commitment Implementation o

No Problems or Issues Identified, 3 exceptions noted above C'

(b)(5) o Perform Full Scope inspections of sand bed region every other outage o

Monitor drywell trenches every refueling outage, until trenches are restored Verified 2 commitment changes were done iaw Exelon commitment management program o

Bolting Integrity Program (commitment 12) o Rx Vessel Axial Weld Examination Relief Request (commitment 48)

(b)(5) 73 Based on the results of discussion on the briefing of December 2, 2008, Region I management decided to postpone the brief with the State of New Jersey and the exit meeting with Amergen because there were too many debatable answers to questions on how certain problems were being addressed.

(b)(5)

(b)(5)

1. A strippable coating will be applied to the reactor cavity liner to prevent water intrusion into the.gap between the drywell shield wall and the drywell shell during periods when the reactor cavity is flooded.

a. The strippable coating initially limited leakage into the cavity drain trough at < 1 gpm.

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b. On Nov 7, the leakage rate took a step change to 4 to 6 gpm. Water was subsequently identified in 4 sand bed bays (the sand bed bays are air connected to the area between the drywell shield wall and the shell itself).

2. Sand bed region drains will be monitored daily during refueling outages.

a. Daily, the sand bed drains were remotely monitored by checking poly bottles, attached via tygon tubing to funnels hanging below the drain lines.

b. The drain lines were not directly observed and in fact, 2 of the 5 tygon tubing became disconnected from the drains and the drains were not readily visible to those monitoring the poly bottles.

3. Reactor cavity seal leakage trough drains and the drywell sand bed region drains will be monitored for leakage, periodically.

a. The drain line for the trough drain was found isolated during a boroscope examination to verify no line blockage during a period when the strippable coating in the refueling cavity was mitigating leakage into this'area.

b. When the strippable coating started to give way, the drain line was clear to perform its function and it was being periodically monitored.

The questions with answers under debate were as follows:

1. Why is the inspector talking/documenting these areas if indeed they are minor issues, appears to be contrary to MC 0612?

2. What process are we in, 2516 or 2515 ROP?

3. If the basis for the commitment statements is a license renewal document, which they are, then how can you say they are performance deficiencies since the licensing action has not been taken on these commitments?

a. OR We can agonize over wording in an SER listing of commitments but we are going to have to wait until they get a renewed license and we are going to have to wait until they enter the period of extended operation before you can proclaim it a "finding".

4. If the commitment statements are duplicated or slightly different in Part 50 documents, can we still use the ROP guidance document to address the performance deficiencies (potentially use separate section of the report so as to not confuse the reader that we are taking a Part 54 action here)?

a. Is there agreement that a commitment is a standard for which Amergen had reasonable control on implement as a Part 50 activity?

b. Should we only be processing failures to properly implement a commitment for which the commitment is uniquely a Part 50 activity with absolutely no overlap to Part 54?

5. How do we determine failures to implement commitments?

a. NEI has defined a regulatory commitment a mostly a future action, which the agency has endorsed; has the staff defined a regulatory commitment in terms of any statements made describing things as they are (designed) or how they have or intend to operate, maintain (including surveillance) (such as the statement of the USAR or application documents).

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b.

Is it true that there is no standard in license renewal called "adequate" or "inadequate" (the old regional inspectors discussing license renewal are completely corrupted by ROP).

c. Is it true that the standard in license renewal is: Were the commitments implemented so there is REASONABLE ASSURANCE the affects of aging is managed?

An assignment was given to EB 1 to build consensus in this area by developing and implementing an action plan - next page.

4 ACTION PLAN:

Action Responsible Expected Organization Completion Date I

Discuss the part 50 activities for the EB1 TLJBC Action started 12/3 commitments in question with Amergen and get

+ 3 days there perspective on references and revisit the adequacy of implementation, thereof, for each of the 3 commitments.

2 Start new time clock on following conditions:

EB1 Est. 12/15

a. TL submits complete draft of BV Lic.

Ren. Report to BC

b. Amergen reports back on item 1

c. Whichever is later 3

Key Offices review debatable questions in the OE/Rl/OGC/DRIS/DLR 12/15+3 context of what is learned from item 2 above 4

Discuss in conference - achieve consensus for EB 1 lead 12/19 exit meeting.

OGC/DLR Revisit need for Board Notification from Region I.

5 Prebrief State of New Jersey - AM EBI/SLO 12/22 Telephonic exit - PM 6

Issue Report EB1 Shoot 1/23/09 DD 2/5/09 7

8 9

10 11 12 13