ML091980291
| ML091980291 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/17/2009 |
| From: | Darrell Roberts Division of Reactor Safety I |
| To: | Pardee C Exelon Generation Co |
| References | |
| FOIA/PA-2009-0070 | |
| Download: ML091980291 (6) | |
See also: IR 05000219/2008007
Text
BC Input to OC 2008-07
COVER LETTER
G:\DRS\Engineering Branch 1\_LicRenewal\Oyster Creek\2008 Outage\InReport\COVER
LETTERRev0.doc t-
Mr. Charles G. Pardee
Chief Nuclear Officer (CNO) and Senior Vice President
Exelon Generation Company, LLC
200 Exelon Way
Kennett Square, PA 19348
SUBJECT: OYSTER CREEK GENERATING STATION - NRC LICENSE RENEWAL
FOLLOW-UP INSPECTION REPORT 05000219/2008007'
Dear Mr. Pardee
On December 23, 2008, the U. S. Nuclear Regulatory Commission (NRC) completed an
inspection at your Oyster Creek Generating Station. The enclosed report documents the
inspection results, which were discussed on December 23, 2008, with Mr. T. Rausch, Site Vice
President, Mr. M. Gallagher, Vice President License Renewal, and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commission's rules and regulations and with the conditions of your license.
Part 50 results
With respect to activities authorized by 10 CFR 50, the inspectors found no findings of safety
significance.
With respect to 10 CFR 54 activities and the NRC staffs Final Safety Evaluation Report (SER) -
NUREG 1845, we observed and have come to understand that you are implementing the
proposed license conditions of that document as listed in Section 1.7, Summary of Proposed
License Conditions (Volume 1 ml 071290023) and the regulatory commitments listed in
Appendix A of the SER (Volume 2 ml 071310246) as though you have an approved renewed
operating license. We also noted that the proposed license conditions of NUREG 1845 for
license renewal have evolved to that listed as Attachment 1 of SECY 08-0018 (ml 080110460)
As an example, the proposed license condition in SECY 08-0018, item 2.C (11) indicated, in
part, that you shall notify the NRC in writing when implementation of those license renewal
activities are complete and can be verified by NRC inspection; this statement was not in the
proposed license conditions of NUREG 1845. The question arises, which set of proposed
license conditions are you implementing on a voluntary basis - for example, will you be sending
such a "readiness letter"? If our understanding in these matters is not true or need to be
clarified, please notify us in writing as soon as possible and clarify you intentions in this regard.
Further, as you well know, an appeal of a licensing board decision regarding the Oyster Creek
application for a renewed license is pending before the Commission related to the adequacy of
the aging management program for the Oyster Creek drywell.
Infobmation inthis record was deleted in
accordance with the Ft£enom of Infotrmandn AOL
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BC Input to OC 2008-07
The midcycle letter of ................ Indicated that the inspections of
The NRC is conducting these inspections using the guidance of Inspection Procedure (IP)
71003 "Post-Approval Site Inspection for License Renewal" as a prudent measure in order to
take the opportunity to make observations of Oyster Creek license renewal activities during the
last refuel outage prior to entering the period of extended operation. The inspectors reviewed
selected procedures and records, observed activities, and interviewed personnel.
¶ (b)(5)
BC Input to OC 2008-07
The enclosed report records the inspector's observations, absent any determinations on
adequacy or significance. We are doing this because the proposed regulatory commitments
made as a part of the 10 CFR 54 application are not in effect pending the final licensing action
by the Director of NRR in conjunction with Commissioners' decision on the appeal of the
hearing issue. If you have any questions in this regard, please let us know.
Further, the observation of your activities with respect to proposed activities for license renewal
indicated that implementation did not go as you expected in association with certain regulatory
commitments listed in the staff's final SER. These dealt with. the installation of the strippable
coating, the monitoring of the cavity drain trough drain, and the monitoring of the sand bed
drains. At the exit meeting of December 23, 2008, you indicated that you were conducting a
common cause analysis in addition to placing this information into your corrective action
process, at a minimum, for future enhancement. With respect to the current situation for your
10 CFR 50 activities, we continue to believe that it is prudent for us to continue conducting
observations of your license renewal activities and we plan a team inspection starting March 9,
2009 usina the same auidance for this inspection.[ (b)(5)
(b)(5)
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
Room or from the Publicly Available Records (PARS) component of NRC's document system
(ADAMS). ADAMS is accessible from the NRC Web-site at
http://www.nrc.qov/NRC/ADAMS/index.html (the Public Electronic Reading Room).
IN LIGHT OF THE REUESTS FOR INFORMATION DD SHOULD SIGN
Sincerely,
Darrell Roberts, Director
Division of Reactor Safety
BC Input to OC 2008-07
SUMMARY OF FINDINGS
IR 05000219/2008007; 10/27/2008 - 12/23/2008; Exelon, LLC, Oyster Creek
Generating Station; License Renewal Follow-up
The report covers a multi-week inspection of license renewal follow-up items. Itwas conducted
by five region based engineering inspectors and the Oyster Creek resident inspector. The
inspection was conducted in accordance with Inspection Procedure 71003 "Post-Approval Site
Inspection for License Renewal."
(b)(5)
In accordance with the NRC's agreement with the State of New Jersey, state engineers
observed portions of the NRC's staff review. The report documents inspection observations
only.
K (b)(5)
BC Input to OC 2008-07
BODY OF REPORT - SAMPLE SELECTION PROCESS
1. Purpose of Inspection and Sample Selection Process
Background and Purpose
This inspection was conducted in order to observe AmerGen's continuing license
renewal activities during the last refueling outage prior to Oyster Creek (OC) entering the
extended period of operation.
(b)(5)
Accordingly, the inspectors recorded observations, without any assessment of
implementation adequacy or safety significance. Inspection observations were
considered, in light of pending 10 CFR 54 license renewal commitments and license
conditions, as documented in NUREG-1875, "Safety Evaluation Report (SER) Related to
the License Renewal of Oyster Creek Generating Station," as well as programmatic
performance under on-going implementation of 10 CFR 50 current licensing basis (CLB)
requirements.
(5)
I ~(b)
This inspection was conducted in order to observe AmerGen's continuing license renewal
activities during the last refueling outage prior to Oyster Creek (OC) entering the extended
period of operation.
Accordingly, the inspectors recorded observations, without any assessment of implementation
adequacy or safety significance.
IP 71003 verifies license conditions added as part of a renewed license, license renewal
commitments, selected aging management programs, and license renewal commitments
revised after the renewed license was granted, are implemented in accordance with Title 10 of
the Code of Federal Regulations (CFR) Part 54, "Requirements for the Renewal of Operating
Licenses for Nuclear Power Plants."
At the time of the inspection, AmerGen Energy Company, LLC was the licensee for
Oyster Creek Generating Station. As of January 8, 2009, the OC license was
transferred to Exelon Generating Company, LLC by license amendment No. 271
(ML082750072).
Sample Selection Process
BC Input to OC 2008-07
The reviewed SER proposed commitments and license conditions were selected based
on several attributes including: the risk significance using insights gained from sources
such as the NRC's "Significance Determination Process Risk Informed Inspection
Notebooks," revision 2; the extent and results of previous license renewal audits and
inspections of aging management programs; the extent or complexity of a commitment;
and the extent that baseline inspection programs will inspect a system, structure, or
component (SSC), or commodity group.
For each commitment and on a sampling basis, the inspectors reviewed supporting
documents including completed surveillances, conducted interviews, performed visual
inspection of structures and components including those not accessible during power
operation, and observed selected activities described below. The inspectors also
reviewed selected corrective actions taken as a consequence of previous license
renewal inspections.