ML061000208

Letter from Alex S. Polonsky Enclosing a Letter Dated 04/04/06 Regarding Commitments Associated with Containment (Drywell and Torus) Condition Monitoring Related to the License Application for Oyster Creek

ML061000208
Person / Time
Site:	Oyster Creek
Issue date:	04/05/2006
From:	Polonsky A AmerGen Energy Co, Morgan, Morgan, Lewis & Bockius, LLP
To:	NRC/SECY
Byrdsong A T
References
2130-06-20284, 50-219-LR, ASLBP 06-844-01-LR, RAS 11509
Download: ML061000208 (9)

Text

R1 g l/5Foc Morgan, Lewis & Bockius LIP 1111 Pennsylvania Avenue, NW Morgan Levis Washington, DC 20004 C O UNS E LOR S A T LAW Tel: 202.739.3000 Fax: 202.739.3001 www.morilanlewis.com Alex S. Polonsky 202.739.t;830 apolonskyfmorganlewis.com DOCKETED USNRC April 6, 2006 (7:34am)

April 5, 2006 OFFICE OF SECRETARY RULEMAKINGS AND VIA E-MAIL & FIRST CLASS MAIL ADJUDICATIONS STAFF Secretary of the Commission U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Re: Additional Commitments Associated with the Drywell Shell (License Renewal Proceeding for the Oyster Creek Nuclear Generating Station, Docket No. 50-219)

Dear Secretary:

AmerGen Energy Company, LLC ("AmerGen") informed the Commission on March 14, 2006 t1.at it would be formally docketing commitments related to the sand bed region of the drywell. shell of the Oyster Creek Generating Station. These commitments are in response to comments made by NRC Staff license renewal audit team members, and include a commitment to perform ultrasonic testing (UT) measurements in the sand bed region once every ten years during the period of extended operation. Enclosed is a copy of the commitment letter, as submitted to the docket yesterday.

Sincerely, Alex S. Polonsky cc: service list I-WA/2549549 C 0

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of: ) April 5, 2006

)

AmerGen Energy Company, LLC )

Docket No. 50-219 (License Renewal for Oyster Creek Nuclear )

Generating Station) )

)

CERTIFICATE OF SERVICE I hereby certify that copies of AmerGen's letter regarding Additional Commitments Associated with the Drywell Shell were served this day upon the persons listed below, by E-mail and first class mail, unless otherwise noted.

Secretary of the Commission* Administrative Judge U.S. Nuclear Regulatory Commission E. Roy Hawkens, Chair Attn: Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Panel One White Flint North Mail Stop - T-3 F23 11555 Rockville Pike U.S. Nuclear Regulatory Commission Rockville, Maryland 20852-2738 Washington, D.C. 20555-0001 (E-mail: HEARINGDOCKET()nrc.gov) (E-mail: erh(a)nrc.gov)

Administrative Judge Administrative Judge Paul B. Abramson Anthony J. Baratta Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 Mail Stop - T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 (E-mail pbaq)nrc.gov ) (E-mail: aib5(i)nrc.gov)

I-WAV2549552.1

John A. Covino Office of Commission Appellate Ellen Barney Balint Adjudication**

Valerie Anne Gray U.S. Nuclear Regulatory Commission Caroline Stahl Washington, DC 20555-0001 Division of Law Ensironmental Permitting and Counseling Section P.O. Box 093 Hughes Justice Complex Richard Webster Trenton, NJ 08625 Rutgers Environmental Law Clinic (E-mail: john.covino()dol.lps.state.nR.us) 123 Washington Street (E-mnail: Ellen.Balint(ai).lps.state.ni.us) Newark, NJ 07102-5695 (E-mail: Valerie.Gray(idol.lps.state.ni.us) (E-mail: rwebster()kinoy.rutgers.edl)

(E-mail: Caroline.Stahl(ilps.state.ni.us Suzanne Leta Paul Gunter NJI'RG Nuclear Information and Resource Service 11 N. Willow Street 1424 16th Street, NW Trenton, NJ 08608 Suite 404 (E-mail: sleta(inipirg.org) Washington, DC 20036 (E-mail: pgunter(i)nirs.org)

Ami P. Hodgdon Office of the General Counsel, 0-15D21 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 (E-mail: aph(~inrc.gov)

• Original and 2 copies

• • First Class Mail only aphael P. kuyler

Michal P.Galagher, PE Telephore 610.765.S952 An Exelon Cormpany Vice Pres;dent vv""niv.exeloncorp.com LUcn- lenevvia Projects nd.cp.ca1aqner5exe-rcorp.com 10CER50 Anme!Ge n 10 CFR 51 t fo!bT W.v;y 10 CFR 54 KSA12-IF Kennett SqcJare. PA-193,42 2130-06-20284 April 4, 2006 U.S. Nuclear Regulatory Commission ATTN': Document Control Desk Washington, DC 20555 Oyster Creek Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219

Subject:

Commitments Associated with Containment (Drywell and Torus) Condition Monitoring Related to AmerGen Application for Renewed Operating License -

Oyster Creek Generating Station (TAC No. MC7624)

References:

1. Letter from C.N. Swenson (AmerGen Energy Company, LLC) to USNRC "Application for Renewed Operating License, Oyster Creek Generating Station," dated July 22, 2005

2. Letter 2130-05-20238 from C. N. Swenson to USNRC "Additional Commitments Associated with Application for Renewed Operating License -

Oyster Creek Generating Station," dated December 9, 2005 In Reference 1,AmerGen Energy Company, LLC (AmerGen) committed to manage the aging of the Oyster Creek Generating Station (OCGS) containment in accordance with its ASME Sectio, Xl, Subsection IWE Program. In Reference 2, AmerGen made a commitment to perform certain inspections of the Drywell shell in the sand bed region to confirm that actions previously taken have eliminated corrosion that had been occurring in that area of the Oyster Creek Generating Station (OCGS) primary containment.

Amersen is now committing to perform additional actions to provide further assurance that the Drywall shell will remain capable of performing its design functions throughout the license renewal period. These prior and new commitments are collectively detailed in the attached Enclosure.

A new commitment is also made with regard to inspecting the coating material applied to the inside of the OCGS containment torus. This commitment is included in the listing provided in the Enclosure.

April 4, 2006 Page 2 of 2 The above-described commitments will be specifically included as part of Commitment 27 from Table A.5 of Reference 1. Table A.5 contained the complete listing of Regulatory Commitments associated with the OCGS Ucense Renewal Application-. For completeness, Table A.5 will be re-submitted to the NRC under separate cover at a later date, capturing these and other comrritments (unrelated to the Oyster Creek primary containment) made during the NRC's review of the OCGS License Renewal Application.

If you have any questions regarding this information, please contact Fred Polaski, Manager, License Renewal, at 610-765-5935.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on 0'-o '-04.

Date Michael P. Gallagher Vice President, License Renewal Projects AmerGen Energy Company, LLC

Enclosure:

Regulatory Commitments cc: Regional Administrator, USNRC Region I NRC Project Manager, NRR - License Renewal, Safety NRC Project Manager, NRR - License Renewal, Environmental, w/o Enclosure NRC Project Manager,*OCGS, Part 50 NRC Senior Resident Inspector, OCGS Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Oyster Creek File No. 05040

ENCLOSURE REGULATORY COMMITMENTS

April 4, 2006 Page 1 of 3 ENCLOSURE - REGULATORY COMMITMENTS The following table identifies commitments made in this document. Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for information and are not regulatory commitments.

Committed One-Time Commitment Date or Action Programmatic Outage (Yes/No) (Yes/No)

1. Pribr to the period of extended operation, Prior to period No Yes AmerGen will perform additional visual of extended inspections of the epoxy coating that was operation and applied to the exterior surface of the Drywell every ten shell n the sand bed region, such that the years during coated surfaces in all 10 Drywell bays will the period of have been inspected at least once. In extended addition, the Inservice Inspection (ISI) operation Program will be enhanced to require inspection of 100% of the epoxy coating every 10 years during the period of extended operation. These inspections will be performed in accordance with ASME Section Xl, Subsection IWE. Performance of the inspections will be staggered such that at least three bays will be examined every other refueling outage.

2. Ultasonic Testing (UT) thickness Prior to period No Yes measurements of the drywell shell in the of extended sand bed region will be performed on a operation and frequency of every 10 years. The initial at 10-year inspection will occur prior to the period of intervals extended operation. The UT measurements thereafter will be taken from the inside of the drywell at the same locations where UT measurements were performed in 1996. The inspection results will be compared to previous results.

Statistically significant deviations from the 1992, 1994, and 1996 UT results will result in corrective actions that include the following:

• Perform additional UT measurements to confirm the readings.

• Notify NRC within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of confirmation of the identified condition.

• Conduct visual inspection of the

April 4, 2006 Page 2 of 3 Committed One-Time Commitment Date or Action Programmatic

________________ Ouag (Yes/No)_ (Yes/No) external surface in the sand bed region in areas where any unexpected corrosion may be detected.

• Perform engineering evaluation to assess the extent of condition and to determine if additional inspections are required to assure drywell integrity.

• Perform operability determination and justification for operation until next inspection.

These actions will be completed prior to restart from the associated outage.

3. Consistent with current practice, a Refueling No Yes strippable coating will be applied to the outages prior reactor cavity liner to prevent water intrusion to and during into the gap between the drywell shield wall the period of and the drywell shell during periods when extended the reactor cavity is flooded. operation

4. Th 9 reactor cavity seal leakage trough Periodically No Yes drains and the drywell sand bed region drains will be monitored for water leakage.

5. A visual examination of the drywell shell in Prior to the Yes, if Yes, if the diywell floor inspection access trenches period of equipment maintained will be performed to assure that the drywell extended restored to within IWE steel remains intact. If degradation is operation original Inspection identified, the drywell shell condition will be configuration. Program evaluated and corrective actions taken as necessary. These surfaces will either be inspected as part of the scope of the ASME Section Xl, Subsection IWE inspection program or they will be restored to the original design configuration using concrete or other suitable material to prevent moisture collection in these areas.

6. The coating inside the torus will be Every other No Yes visua'ly inspected in accordance with ASME refueling Section Xl, Subsection IWE, per the outage prior Protective Coatings Program. to and during the period of extended operation ___

April 4, 2006 Page 3 of 3 Committed One-Time Cornmitment Date or Action Programmatc

_ _ _ _ _ __ _ _ ~ Y s N )(Y es/N o)

7. AmnerGen will conduct UT thickness Every other No Yes measurements in the upper regions of the refueling drywoll shell every other refueling outage at outage prior the same locations as are currently to and during measured. the period of extended operation ______

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