ML091980299
| 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
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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.
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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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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.
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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
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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
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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
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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.
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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