ML091980299

Draft Ltr. from D. Roberts of USNRC to C. Pardee of Exelon Generation Company, Regarding Oyster Creek Generating Station - NRC License Renewal Follow-Up IR 05000219-2008-007, Rev 2a

ML091980299
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 IR-08-007
Download: ML091980299 (7)

See also: IR 05000219/2008007

Text

,,,OBe-WT"H~ELD 110lN,5

G:\DRS\Engineering Branch 1\_LicRenewal\Oyster Creek\2008 Outage\lnReport\OC 2008-07

LRIrev-2A Upfront Guts.doc

Conte Input for Upfront Guts of Report

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

in a telephone conference observed by representatives from the State of New Jersey.

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 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 1845C. (b)(5)

(b)(5) Ifi ý"'

(b)(5)

I

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

- (b)(5)

7z4 ý

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)

÷ , /

kibWrAdw, hithsreconwas delugedm

Woedac with the reedom of Informago ftL

Exemptions

&175- -7

FOIN"PA AOC -j o

A-3

(b)(5)

I ;)I

A-4

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 " (b)(5) (b)(5)

(b)(5) J

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.htmi (the Public Electronic Reading Room),

IN LIGHT OF THE REUESTS FOR INFORMATION DD SHOULD SIGN

Sincerely,

Darrell Roberts, Director

Division of Reactor Safety

A-5

REPORT DETAILS

4. OTHER ACTIVITIES (OA)

4OA2 License Renewal Follow-up (IP 71003)

1. Background

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, the standards used

to judge the adequacy of selected IP 71003 inspection samples do not apply.

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."

2. Inspection Sample Selection Process

The. inspection team selected a number of inspection samples for review, using the NRC

accepted guidance based on their importance in the license renewal application

process, as an opportunity to make observations on license renewal activities.

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.

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

A-6

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.

A-7

I . . I

A-8

3. Review Details

3.1 NRC Unresolved Item

10 CFR 50 existing requirements (e.g., current licensing basis (CLB)

xxx USE words from PN

• The conclusions of PNO-1-08-012 remain unchanged

" An Unresolved Item (URI) will be opened to evaluate whether existing current licensing basis

commitments were adequately performed and, if necessary, assess the safety significance for

any related performance deficiency.

• The issues for follow-up include the strippable coating de-lamination, reactor cavity trough

drain monitoring, and sand bed drain monitoring.

e The commitment tracking, implementation, and work control processes will be reviewed,

based on corrective actions resulting from AmerGen's review of deficiencies and operating

experience, as a Part 50 activity.

3.2 Drywell Floor Trench Inspections