ML18017A117

NRC PBAPS SLRA Pre-Submittal Meeting Jan 2018 PM Copy

ML18017A117
Person / Time
Site:	Peach Bottom
Issue date:	01/18/2018
From:	Exelon Generation Co
To:	Office of Nuclear Reactor Regulation
Brady B, NRR-DMLR 415-2981
References
Download: ML18017A117 (13)

Text

Peach Bottom Atomic Power Station 2 & 3 Second License Renewal Application Pre-submittal Meeting January 18, 2018

Agenda Introductions: Mike Gallagher, VP License Renewal &

Decommissioning

Background:

Mike Gallagher Part 54 Safety Application Approach : Paul Weyhmuller, Peach Bottom Project Tech Lead Discussion Topics/Lessons Learned: All Project Management: John Hufnagel, Peach Bottom Project Licensing Lead Closing Remarks: Mike Gallagher 1

Site Information Turbine Building Intake Susquehanna River Discharge 2

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Background===

First License Renewal Application submitted July 2, 2001 Approved May 7, 2003 IP 71003 Unit 2 completed January 31, 2013 IP 71003 Unit 3 completed March 31, 2014 Entered PEO 2013 (Unit 2) and 2014 (Unit 3)

Well run and maintained 12 years without an automatic scram Over $1.3 billion on capital improvements 2012 -2016 Unit 3 completed 731 days of continuous operation 3

Background - Power Uprate History Peach Bottom Authorized Power History Unit 2 Unit 3 Initial License, 3293 MWt 10/25/1973 07/02/1974 5% Uprate, 3458 MWt 10/18/1994 07/18/1995 1.62% Uprate, 3514 MWt 11/22/2002 11/22/2002 Extended Power Uprate, 3951 MWt 08/25/2014 08/25/2014 Measurement Uncertainty Recapture, 11/15/2017 11/15/2017 4016 MWt Current License Expiration Date 08/08/2033 07/02/2034 4

Background - Part 54 Safety Application Approach Lessons learned from previous Exelon and industry license renewal projects are utilized in the PBAPS SLRA Project Exelon has extensive aging management experience 22 of 23 units have renewed operating licenses 13 units are operating in the PEO Exelon has held leadership positions and participates in NEI and EPRI initiatives that prepared the industry for Subsequent License Renewal & Long Term Operations Exelon participated through NEI in providing comments to the staff on GALL/SRP - SLR Current NRC Expectations and SRP Guidance Exelon reviewed RAIs that have been issued to recent license renewal applicants to ensure consistency with current NRC expectations and SRP guidance Includes lessons learned from River Bend acceptance review 5

Part 54 Safety Application Approach Safety portion format is based on NUREG -2192 (SRP-SLR),

NEI 17-01, and Reg. Guide 1.188 (pending)

Comprehensive Scoping & Screening was performed Aging Management Reviews Highly consistent : >98% A through E notes (approx. 6400 line items)

No new aging effects since first license renewal Aging Management Programs Goal is to maximize consistency with GALL-SLR Includes Aging Management Effectiveness Review of First LR programs TLAAs Addressed First License Renewal TLAAs Extensive review for additional TLAAs Review of SLRA Internal consistency checks being performed (e.g., enhancements, aging effects)

Industry Peer review will be performed 6

GALL-SLR Consistency and Commitments 47 AMP License Renewal Commitments (preliminarily)

UFSAR Supplement (Appendix A of the SLRA)

Managed by Exelon Commitment Tracking program based on Nuclear Energy Institute 99-04, Guidelines for Managing NRC Commitment Changes AMPs AMPs AMPs with AMPs with Plant Consistent Consistent Exception Exception Specific with GALL with without and AMPs Enhancement Enhancement Enhancement Existing 36 7 20 2 6 1 New 11 8 0 3 0 0 Total 47 AMPs 7

Discussion Topics/Lessons Learned GAP Analysis for Reactor Internals: Section 3.1.2.2.12 for BWR Internals Bases for projecting neutron fluence values for RPV and RVI to the end of a proposed subsequent period of extended operation Are there changes in methods of analysis since first license renewal?

RPV Fluence Methodology consistent with CLB Environmental qualification of electrical equipment consistent with CLB Fatigue Analysis consistent with CLB EAF analysis consistent with GALL-SLR guidance EAF Screening methodology for limiting Class 1 locations Any changes in Technical Specifications anticipated for SLR?

Is Noble Metal Chemical Addition or Hydrogen Water Chemistry credited in reducing ISI inspection requirements?

Will BWRVIP-62 Rev. 1 be used for BWR Vessel and Internals?

Concrete degradation including irradiation effects 8

Discussion Topics/Lessons Learned Cable and Electrical AMPs BWRVIP Integrated Surveillance Program (ISP)

BWRVIP-135 BWRVIP-86 Rev. 1-A Use of the BWRVIP-74 App. B generic equivalent margins analysis methodology for Upper Shelf Energy (USE) TLAA Any new aging effects identified for SLR?

Westinghouse Steam Dryer aging management Use of SLRA Appendix C Relationship between 1st and 2nd LR UFSAR supplements 9

Project Management Exelon plans to provide electronic SLRA submittal, web-ready CD and reviewers aid information including: Reviewer version CDs including SLRA, ER, boundary drawings, UFSAR, and FPP, with links SLRA and boundary drawing hard copies will be provided Exelon will utilize Scientech eDocs portal to make supporting documents available upon NRC completion of SLRA acceptance review Frequent project calls between the Exelon Licensing Lead and NRC PM Operating Experience Audit in Rockville, MD Exelon will support with utility laptops, spreadsheet data and connection to Station CAP database In-Office and On-Site Audit Support Exelon will work with NRC PM to establish and manage remote breakout session schedules Exelon will track NRC audit questions, requests, and the responses in a database Coordination of plant walkdowns and other on-site activities RAI Responses Exelon will meet NRC response schedules 10

Closing Remarks The Peach Bottom SLR application will be consistent with GALL-SLR and GEIS to the greatest extent possible Exelon will submit a high quality application that can support an 18 month staff review Recent industry RAIs addressed in the SLR application Timely RAI responses Frequent NRC interface The Peach Bottom SLR application is on track to be submitted to the NRC in 3rd quarter 2018 11

Questions?

12