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:	Roberts D J 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

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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-7z4 ý(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)÷ , /kibWrAdw, hithsreconwas

delugedm Woedac with the reedom of Informago

ftL Exemptions

FOIN"PA AOC -j o&175- -7

A-3 (b)(5)I ;)II

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