ML091980292
| ML091980292 | |
| 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: ML091980292 (5) | |
See also: IR 05000219/2008007
Text
BC Input to OC 2008-07
COVER LETTER
G:\DRS\Engineering Branch 1\_LicRenewal\Oyster Creek\2008 Outage\I nReport\COVER
LETTER Up Front Rev-1 .doc
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.
Particular focus occurred on the inservice inspection of the drywell containment. Based on the
results of the NRC's, inspection, the NRC staff identified that there were no safety significant
conditions with respect to the drywell containment that effected current operations.'
With respect to 10 CFR 54 activities and the NRC staff's Final Safety Evaluation Report (SER)
for License Renewal - NUREG 1845 (Volume 1 ml 071290023 & Volume 2 ml 071310246), we
observed that you are implementing the proposed license conditions of that document and the
associated regulatory commitments as though they were in effect. 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. The NRC's Reactor Oversight Process mid-cycle letter of September
2, 2008 indicated that we would be Conducting inspections (outage and non-outage) related to
license renewal prior to the period of extended operations. 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
such observations of Oyster Creek license renewal activities during the last refuel outage prior
to entering the period of extended operations.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel. The enclosed report records the inspector's observations only. We are doing this
because the proposed license conditions and associated regulatory commitments made as a
part of the 10 CFR 54 application are not in effect. These conditions and commitments are not
in effect because the application for a renewed license remains under Commission review for
final decision, and a renewed license has not been approved for Oyster Creek
fn accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this fetter 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
Information inthis record was deleted ir#
accordance with the Freedom of Information A
FOWFIA . U 1
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(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 special nature of this problem and format DD SHOULD SIGN
Sincerely,
Darrell Roberts, Director
Division of Reactor Safety
BC Input to OC 2008-07
SUMMARY OF FINDINGS
(b)(5) I '...) .
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. It was 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." "
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.????
(b)(5)
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BODY OF REPORT -- SAMPLE SELECTION PROCESS
1. Purpose of Inspection and Sample Selection Process
Background and Purpose
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. The NRC's Reactor Oversight
Process mid-cycle letter of September 2, 2008 indicated that we would be conducting
inspections (outage and non-outage) related to license renewal prior to the period of
extended operations. 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 such observations of Oyster
Creek license renewal activities during the last refuel outage prior to entering the period of
extended operations.
Inspection observations were considered, in light of pending 10 CFR 54 license renewal
commitments and license conditions, as documented in NUREG-1 875, "Safety Evaluation
Report (SER) Related to the License Renewal of Oyster Creek Generating Station,"
(Volume 1 ml 071290023 & Volume 2 ml 071310246) as well as programmatic
performance under on-going implementation of 10 CFR 50 current licensing basis (CLB)
requirements.
Normally IP 71003 verifies that license renewal activities 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." The license renewal activities
are generally related to: 1) license conditions added as part of a renewed license and the
associated license renewal commitments; 2) selected aging management programs and
implementing procedures; 3) license renewal commitments revised after the renewed
license was granted; 4) need to revise the updated Safety Analysis Report; and, 5) newly
identified structures, systems and components. What was not completed in this inspection
for the reasons stated below was the implementation of guidance sections 03.01 .b. 1 and
03.01 .b.3 of the procedure which calls for a review of appropriate actions and evaluation
for enforcement and significance. Also items 4) and 5) above were not applicable for this
inspection.
For 10 CFR 54 activities, the report records the inspector's observations only. We are
doing this because the proposed license conditions and associated regulatory
commitments made as a part of the 10 CFR 54 application are not in effect. These
conditions and commitments are not in effect because the application for a renewed
license remains under Commission review for final decision, and a renewed license has
not been approved for Oyster Creek.
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).
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Sample Selection Process
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.