ML091980295
| ML091980295 | |
| 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: ML091980295 (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\InReport\BC Input to
OC 2008-07UpFrontGutsRev-0.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.
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, we observed and have come to understand that you are
implementing regulatory commitments as listed in Appendix A of NUREG 1845 (ml .......) and
the proposed license conditions of that document (section 1.7, Summary of Proposed License
Conditions) 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-XXX (ml .......... ) As an example, the proposed license condition
XXX indicated that you will be sending in a readiness letter to indicate readiness for inspection,
this was not in the proposed license condition 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 in the 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.
The midcycle letter of ................ Indicated that the inspections of
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Exemptions with the *_edom of It)fonno AA,
BC Input to OC 2008-07
(b)(5) .
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 expected associated with certain proposed
regulatory commitments. 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 using the same
guidance for this inspection.E (b)(5)
(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.gov/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. 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."
Lnpcin(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.
L (b)(5)7
BC Input to OC 2008-07
BODY OF REPORT -- SAMPLE SELECTION PROCESS
1. Purpose of Inspection and Sample Selection Process
Backgqround 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. The inspection team selected a number of inspection
samples for review, using the NRC accepted guidance based on their importance in the
license renewal apFJcation process, as an opportunity to make observations on license
renewal activities.j (b)(5) -
(b)(5)
(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.
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
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.