ML071290546
| ML071290546 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/29/2007 |
| From: | Catherine Haney Plant Licensing Branch III-2 |
| To: | Webster R Rutgers Environmental Law Clinic |
| Miller G, NRR/DORL, 415-2481 | |
| Shared Package | |
| ml071290525 | List: |
| References | |
| Y020070094 | |
| Download: ML071290546 (4) | |
Text
June 29, 2007 Richard Webster, Esq.
Rutgers Environmental Law Clinic 123 Washington Street Newark, NJ 07102-3094
Dear Mr. Webster:
This letter provides a response to the concerns raised in your March 30, 2007, letter which raises additional questions about the operability of the containment drywell shell at Oyster Creek Nuclear Generating Station (Oyster Creek). In this and previous communications (Letter dated November 7, 2006, Agencywide Documents Access and Management System (ADAMS)
Accession Number ML063120572; e-mail dated November 9, 2006, ADAMS Accession Number ML070260177), you questioned the Nuclear Regulatory Commission (NRC) staffs basis for allowing restart of Oyster Creek from its most recent refueling outage (RFO 21) and the acceptability of confirmatory calculations performed by the NRCs contractor Sandia National Laboratories (SNL). The NRC responded to these communications by letters dated November 9, 2006 (ADAMS Accession No. ML063120196), and March 16, 2007 (ADAMS Accession No. ML070660182), respectively.
Paragraph 4 of our March 16, 2007, letter provided a discussion of information provided in the licensees calculations. As a point of clarification, the NRC staff reviewed the licensee's calculations as well as confirmatory calculations performed on the NRC's behalf by SNL. The NRC staff did not perform independent calculations regarding the structural integrity of the Oyster Creek drywell shell. Therefore, no NRC-performed calculations or associated numerical assessments of uncertainty can be provided.
Prior to the restart from RFO 21, the NRC staff inspected the condition of the containment drywell shell as well as reviewed the AmerGen Energy Company, LLCs (AmerGens) evaluation of the drywell shell condition. The results of these activities are documented in NRC In-Service Inspection and License Renewal Commitment Followup Inspection Report 05000219/2006013, dated January 17, 2007 (ADAMS Accession Number ML070170396). In this inspection report, the NRC staff determined that there were no safety significant conditions with respect to the primary containment that would prohibit plant startup and there was reasonable assurance that the primary containment was capable of performing its design function throughout the upcoming operating cycle.
Further, the NRC staff discusses the SNL analysis and its applicability to the Oyster Creek licensing basis analysis in the Safety Evaluation Report Related to the License Renewal of Oyster Creek Generating Station, dated March 2007 (ADAMS Accession Number ML070890637). In this report, the NRC staff concluded that the SNL report results support and confirm that the drywell will be able to perform its intended functions in its present condition.
Also, Section 4.7.2 of the Safety Evaluation discusses the NRC staff's review of the drywell shell corrosion rate and concludes that licensee corrective actions have been successful in reducing and arresting the corrosion in the drywell shell. Conservative projections of the shell thickness to the year 2029, indicating adequate margin to the minimum wall thickness criteria,
R. Webster and the licensee's drywell shell monitoring plan, which allows timely corrective action for any future degradation, provide assurance that the drywell will be able to perform its design function.
Additionally, in an e-mail to Mr. Richard Conte, dated June 4, 2007, and a letter dated June 7, 2007, you included a copy of the AmerGen Calculation C-1302-187-5320-024, Revision 2. In these communications, you asserted that several areas in the sandbed region do not meet the local thinning limits and as an example, you indicated that Figure 1-7 shows such an area. This calculation is not part of the current licensing basis for Oyster Creek and has not been submitted by AmerGen for NRC staff review in conjunction with a licensing action. The NRC staff notes, however, that while Figure 1-7 depicts a 9-square-foot thinned area, Section 7.1.3.4 of the calculation indicates that the cumulative size of the ten locally thin areas measured is significantly smaller than the analyzed 9-square-foot area.
The NRC staff considers the above referenced documents to be responsive to your information requests. If you wish to formally request the NRC to take a specific action with respect to the condition of the Oyster Creek drywell, you may do so pursuant to Title 10 of the Code of Federal Regulations, Part 2, Section 2.206. Additional concerns may be submitted through the NRCs allegation process. For more information on this process please refer to our website (http://www.nrc.gov/about-nrc/regulatory/allegations/safety-concern.html).
Sincerely,
/ra/
Catherine Haney, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-219 cc: See next page
R. Webster and the licensee's drywell shell monitoring plan, which allows timely corrective action for any future degradation, provide assurance that the drywell will be able to perform its design function.
Additionally, in an e-mail to Mr. Richard Conte, dated June 4, 2007, and a letter dated June 7, 2007, you included a copy of the AmerGen Calculation C-1302-187-5320-024, Revision 2. In these communications, you asserted that several areas in the sandbed region do not meet the local thinning limits and as an example, you indicated that Figure 1-7 shows such an area. This calculation is not part of the current licensing basis for Oyster Creek and has not been submitted by AmerGen for NRC staff review in conjunction with a licensing action. The NRC staff notes, however, that while Figure 1-7 depicts a 9-square-foot thinned area, Section 7.1.3.4 of the calculation indicates that the cumulative size of the ten locally thin areas measured is significantly smaller than the analyzed 9-square-foot area..
The NRC staff considers the above referenced documents to be responsive to your information requests. If you wish to formally request the NRC to take a specific action with respect to the condition of the Oyster Creek drywell, you may do so pursuant to Title 10 of the Code of Federal Regulations, Part 2, Section 2.206. Additional concerns may be submitted through the NRCs allegation process. For more information on this process please refer to our website (http://www.nrc.gov/about-nrc/regulatory/allegations/safety-concern.html).
Sincerely,
/ra/
Catherine Haney, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-219 cc: See next page DISTRIBUTION: Y20070094 PUBLIC LPL1-2 R/F RidsNrrPMGMiller RidsNrrLACBaxter RidsNrrDorl RidsOgcRp RidsAcrsAcnwMailCenter RidsNrrDorlDpr RidsRgn1MailCenter RidsNrrOd RidsNrrAdro RidsEdoMailCenter RidsOgcMailCenter RidsNrrDpr RidsOpaMail RidsOcaMailCenter RidsRgnIMailCenter RidsNrrWpcMail RidsNrrDorlLpl1-2(HChernoff)
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Oyster Creek Nuclear Generating Station Site Vice President - Oyster Creek Nuclear Generating Station AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Senior Vice President of Operations AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Kathryn M. Sutton, Esquire Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Manager Licensing - Oyster Creek Exelon Generation Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Regulatory Assurance Manager Oyster Creek AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Assistant General Counsel AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348 Ron Bellamy, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Correspondence Control Desk AmerGen Energy Company, LLC 200 Exelon Way, KSA 1--1 Kennett Square, PA 19348 Oyster Creek Nuclear Generating Station Plant Manager AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731