ML23251A078

DRE1 Decom Pre-Submittal Slides

ML23251A078
Person / Time
Site:	Dresden, Peach Bottom
Issue date:	09/06/2023
From:	Constellation Energy Generation
To:	Office of Nuclear Material Safety and Safeguards
References
Download: ML23251A078 (1)

Text

Peach Bottom Atomic Power Station Unit 1 Dresden Nuclear Power Station Unit 1 Alternate Decommissioning Schedule NRC PreSubmittal Meeting 9/14/2023

Agenda

• Purpose

• Regulatory Background

• Planned Submittal Strategy

• Peach Bottom Unit 1

• Dresden Unit 1

• Timeline 2

Purpose

• Provide overview of two separate submittals requesting alternate decommissioning schedules for Peach Bottom Unit 1 (PB1) and Dresden Unit 1 (DRE1)

- Completion of decommissioning beyond 60 years of permanent cessation of operations

- Sitespecific factors unique to PB1 and DRE1

- Necessary to protect public health and safety with the presence of operating nuclear facilities at a common site

• Solicit feedback from the NRC on the information presented and gain insight on NRC's information needs and review schedule considerations 3

Regulatory Background 10 CFR 50.82(a)(3): Decommissioning will be completed within 60 years of permanent cessation of operations. Completion of decommissioning beyond 60 years will be approved by the Commission only when necessary to protect public health and safety. Factors that will be considered by the Commission in evaluating an alternative that provides for completion of decommissioning beyond 60 years of permanent cessation of operations include unavailability of waste disposal capacity and other sitespecific factors affecting the licensee's capability to carry out decommissioning, including presence of other nuclear facilities at the site.

• Regulation expressly contemplates sitespecific factors, such as other operating units, as a consideration for whether completion of decommissioning beyond 60 years is necessary to protect public health and safety

- Statements of Consideration for Final Rule specifically note the presence of an adjacent reactor whose safety might be affected by dismantlement procedures as a consideration

• Recent Commission decision (SECY210033) denying an exemption request under 10 CFR 50.12 to extend decommissioning beyond 60 years is not binding precedent and is distinguishable from sitespecific PB1 and DRE1 factors 4

Planned Submittal Strategy Alternate decommissioning schedule under 10 CFR 50.82(a)(3):

• Independent submittals with common approach

• Sitespecific factors impacting public health and safety should Unit 1 decommissioning be performed with Units 2 and 3 in operation

• Decommissioning and license termination of Units 1, 2, and 3 performed concurrently eliminates safety concerns related to a shutdown unit sharing SSCs with operating units

• Unit 1 remains under an extended SAFSTOR period with all existing processes and regulations in place to ensure adequate monitoring and aging management

• Requesting alignment of Unit 1 decommissioning schedule with operating units decommissioning schedules 5

Peach Bottom Unit 1 - Background

• First High Temperature Gas Reactor prototype under the Atomic Energy Commission

• 200 MWt/40 MWe, helium cooled, graphite moderated

• Operated 19671974

• Decommissioning activities completed by February 1978 to achieve SAFSTOR

• PB1 continues to be maintained in SAFSTOR

• Decommissioning 60 year timeline October 2034

• PB Unit 2 license expiration August 2053*

• PB Unit 3 license expiration July 2054*

• Based on Subsequent Renewed Facility Operating License (SRFOL) issued March 2020; however, NRC Order CLI2204 issued February 2022 reverted license expiration dates back to Renewed Facility Operating License dates of 2033 and 2034, respectively. Awaiting final resolution of generic environmental impact issues in support of SRFOL.

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Peach Bottom Unit 1 - SiteSpecific Factors

• Units 1, 2, and 3 on common site and Owner Controlled Area

• Legacy structures support Units 2 and 3 operations

- NERCrequired protective relay scheme SSCs for Units 2 and 3 offsite power sources credited via Technical Specifications

- Technical Support Center is former Unit 1 Control Room, facility and support systems vital to site Emergency Plan

- Licensed operator training facilities, including control room simulator, are integrated with Unit 1 structures

• Adjacent to the heavy haul path for Units 2 and 3 dry cask storage operations, which must continue until permanent cessation of operations 7

Peach Bottom Unit 1 - Related Licensing Actions

• PB1 license amendment request to revise license conditions and Technical Specifications which preclude decommissioning activities without prior NRC approval and implement PSDAR process per 10 CFR 50.82 using Reg Guide 1.185

• Awaiting final resolution of generic environmental impact issues in support of SRFOL for Units 2 and 3 8

Dresden Unit 1 - Background

• First privately funded commercial nuclear power station under the Atomic Energy Commission

• 700 MWt/200 MWe, dual cycle boiling water reactor

• Operated 19601978

• Decommissioning activities completed by January 2007 to achieve SAFSTOR

• DRE1 continues to be maintained in SAFSTOR

• Decommissioning 60 year timeline October 2038

• DRE Unit 2 license expiration December 2029**

• DRE Unit 3 license expiration January 2031**

• • Subsequent License Renewal (SLR) submittal planned for April 2024, requesting 20year license extensions 9

Dresden Unit 1 - SiteSpecific Factors

• Adjoined structures support Units 1, 2, and 3 operations

- Common Main Control Room partially in Unit 1

- Unit 1 and Unit 2 Turbine Building adjoined

• Common systems support Units 1, 2, and 3 operations located adjacent to Unit 2 and Main Control Room

- Unit 1 4kV and 480V distribution power Unit 1 systems and site buildings supporting Units 2 and 3

- Station Blackout (SBO) Building auxiliary power supplied from Unit 1 AC distribution; SBO cables routed adjacent to Unit 1

- Prime Computer Room, associated uninterruptible power supply and batteries

- Unit 1 125V DC chargers and batteries

- Units 2 and 3 Recirculation pump adjustable speed drive (ASD) I/O cabinets 10 - Licensed/NonLicensed Operator staging areas

Dresden Unit 1 - SiteSpecific Factors (cont.)

• Unit 1 Chimney located adjacent to underground SBO electrical ducts

• Unit 1 ISFSI located in Unit 1 operating area requiring relocation

• Units 1, 2, and 3 on common site and Protected Area (PA)

- Adjoined structures do not support PA reconfiguration

- Impacts Units 2 and 3 Security Plan

• Units 2 and 3 functions in Unit 1 operating area

- SBO Diesel Building

- Interim Radioactive Storage Facility

- Diesel Fire Pump in Unit 1 Intake Structure

- Robust FLEX Building

- Site facilities supporting maintenance functions

- Containment structure adjacent to site support facilities 11

Dresden Unit 1 - Related Licensing Actions

• DRE Units 2 and 3 SLR submittal planned for Q2 of 2024, and if granted, will extend operation to 2049 and 2051, respectively 12

Timeline

• PB1

- Prioritize submittal over DRE1 due to 60 year decommissioning timeline ending in 2034

- Targeting September 2023 submittal

• DRE1

- Subsequent to Peach Bottom submittal, targeting 4th Quarter 2023 13

Discussion/Questions 14