ML093220598

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E-mail from R. Webster, Eastern Environmental Law Center, to S. Collins Reply Related to R. Webster - Follow Ups to the Annual Assessment Meeting
ML093220598
Person / Time
Site: Oyster Creek
Issue date: 06/03/2009
From: Webster R
Eastern Environmental Law Ctr
To: Collins S
NRC Region 1
References
FOIA/PA-2009-0214
Download: ML093220598 (2)


Text

Fdrfar, Karl From:

Richard Webster [rwebster@easternenvironmental.org]

Sent:

Wednesday, June 03, 2009 5:29 PM To:

Sam Collins Cc:

Richard Barkley; Brian Harris; Karl Farrar

Subject:

Re: REPLY re: R. Webster-Follow ups to the Annual assessment meeting Thanks. I look forward to your response.

Richard Webster Legal Director Eastern Environmental Law Center 744 Broad Street, Suite 1525 Newark NJ, 07102 Tel. 973 424 1166 Fax. 973 710 4653 rwebster(-easternenvironmental.orpq On Jun 3, 2009, at 5:26 PM, Sam Collins wrote:

> Mr. Webster: I have received your E-Mail and it is under consideration

> for an appropriate response. Best Regards, Sam Collins Original Message -----

> From: Richard Webster [1]

> Sent: Monday, June 01, 2009 1:03 PM

> To: Sam Collins

> Cc: Joseph McMillan; Jill Lipoti; Richard Conte; Janet Tauro;

> paul@beyondnuclear.org ; Hannah Faddis

Subject:

Follow ups to the Annual assessment meeting

> Mr. Collins,

> In order to follow up on our discussions at the annual assessment

> meeting, please find attached a letter I wrote today to OIG forwarding

> the e-mail that we discussed. As I stated to you, the opacity and

> vagueness of the CLB to all parties remains a key problem that we

> believe needs attention.

> More specifically, I would like to confirm my understanding of our

> discussions on May 28 that the CLB for the underground pipes at Oyster

> Creek requires intended function be maintained, where intended

> function does not include containment of radioactive water. If this

> is incorrect, please let me know as soon as possible.

> I also seek clarification of Mr. Conte's statements about the purpose

> of the aging management programs. I note that the applicant must

> "demonstrate that the effects of aging will be adequately managed so

> ffi~t the intended function(s) will be maintained

> consistent with the CLB for the period of extended operation."[1]

> Can you confirm that the goal of the aging management programs is to

> prevent any violations of the CLB due to aging during the period of

> extended operation?

> Finally, a question was raised at the meeting as to whether these

> pipes were inspected prior to relicensing and if so, how. The NRC

> Staff responded that this question was under review. What is the

> status of this review? Did the safety review conducted prior to

> relicensing also review the dates, spatial extent, and findings of

> prior pipe inspections? If so, why couldn't NRC Staff provide any

> information on these issues at the meeting?

> Additionally, you stated at the meeting that inspection requirements

> for these pipes may be based upon on the guidance of American Society.

> of Mechanical Engineers (ASME) standards and the Generic Aging Lessons

> Learned (GALL) report.[2] To the extent that inspections have relied

> on the guidance, what requirements as to inspection frequency and

> spatial coverage are contained in this guidance?

> Finally, at the meeting Exelon stated that the underground pipe

> systems carrying radioactive water will be moved above ground pr place

> in vaults. Please confirm what is planned, whether this is a binding

> a commitment for Exelon, and what is the schedule for completion of

> that project.

> I appreciate your attention to these issues and I look forward to

> hearing further from you.

> [1] 10 C.F.R. § 54.21(a)(3) (2009).

> [2] Nuclear Regulatory Commission. NUREG-1801, Rev. 1. (2005).

" Richard Webster

" Legal Director

" Eastern Environmental Law Center

" 744 Broad Street, Suite 1525

" Newark NJ, 07102

" Tel. 973 424 1166

" Fax. 973 710 4653

> rwebster~a)easternenvi ron mental. orQ 2