ML23286A001

Reply to a Notice of Violation (NOV) - NOV 05000277,05000278/2023010-01

ML23286A001
Person / Time
Site:	Peach Bottom
Issue date:	10/13/2023
From:	Henry D Constellation Energy Generation
To:	Office of Nuclear Reactor Regulation, NRC Region 1, Document Control Desk
References
CCN 23-67, IR 2023010
Download: ML23286A001 (1)

Text

10 CFR 2.201

CCN 23-67

October 13, 2023

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Reply to a Notice of Violation (NOV) - NOV 05000277,05000278/2023010-01

Reference:

NRC Letter to Constellation Energy Generation, LLC, Peach Bottom Atomic Power Station, Units 2 and 3 - Biennial Problem Identification and Resolution Inspection Report 05000277/2023010 and 05000278/2023010 and Not ice of Violation, dated September 15, 2023 (ADAMS Accession No. ML2325 8A049) to this letter provides Constellation Energy Gener ations (CEG) reply to the Notice of Violation contained in Enclosure 2 to the referenced letter. The Notice of Violation was associated with failure to establish corrective action for erosion of structural backfill material in the pipe trench on the West side of the site.

This response includes a regulatory commitment, which is provid ed in Attachment 2. If you have any questions concerning this response, please contact the Peach Bottom Regulatory Assurance Manager, Wade Scott at (717) 456-3047.

Respectfully,

David A. Henry Site Vice President Peach Bottom Atomic Power Station

Attachments:

1. Reply to Notice of Violation (NOV) - NOV 05000277,05000278/2023010-01

2. Summary of Regulatory Commitments

cc: w/ Attachment Regional Administrator, Region I, USNRC USNRC Senior Resident Inspector, PBAPS Project Manager - PBAPS, USNRC W. DeHaas, Pennsylvania Bureau of Radiation Protection S. Seaman, State of Maryland Reply to a Notice of Violation (NOV) - NOV 05000277, 05000278/2 023010-01 Docket Nos. 50-277 and 50-278 Page 1 of 2

ATTACHMENT 1

Peach Bottom Atomic Power Station, Units 2 and 3

Docket Nos. 50-277 and 50-278

Reply to a Notice of Violation (NOV) - NOV 05000277, 05000278/2 023010-01

1.0 RESTATEMENT OF THE VIOLATION

10 CFR Part 50, Appendix B, Criterion XVI, Corrective Action, requires, in part, that measures shall be established to assure that conditions adverse to quali ty, such as deficiencies, defective material, and non-conformances are promptly identified and corr ected.

PI-AA-125, Corrective Action Program Procedure, Revision 7, s tep 4.5.2 states, in part, to create a corrective action for any planned actions necessary to restore a condition adverse to quality.

Contrary to the above, from at least May 10, 2021 to present, P each Bottom staff did not establish measures to correct the condition adverse to quality associated with the erosion of structural backfill material in the pipe trench.

This violation is associated with a Green Significance Determin ation Process finding.

2.0 REASON FOR THE VIOLATION

In August 2021, the NRC documented a finding and associated Non -Cited Violation (NCV) for the failure to correct a condition adverse to quality associate d with the erosion of structural backfill material in the pipe trench on the West side of the si te. The NCV was documented in NRC inspection report 05000277/2021012 and 05000278/2021012 (ML 21265A334). Although the site completed corrective actions to address the human perf ormance issues that resulted in the NCV, the NRC found that the site has not yet created correc tive actions to fully address the identified erosion due to ongoing troubleshooting of the condit ion. Confirmation of the suspected cause and the development of corrective actions is pr edicated on ongoing inspections of the drainage systems to gather data necessary to determine the cause of the erosion. The station acknowledges that insufficient resources had been dedicated to the completion of these actions and development of corrective actio ns for the settlement issue.

The station determined that the cause of the insufficient use o f resources was due to untimely prioritization due to misperception of risk.

Reply to a Notice of Violation (NOV) - NOV 05000277, 05000278/2 023010-01 Docket Nos. 50-277 and 50-278 Page 2 of 2

3.0 CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED

To date, the station has taken the following corrective steps:

1. Increased the frequency of inspection of pipe supports assoc iated with the affected piping to biannual. This action allows for increased monitorin g of the condition and will measure the effectiveness of future corrective actions.

2. Inspection of the storm drain system and identification of a reas of blockage. This information will be incorporated into the investigation revisio n, and ongoing efforts are in place to clear the drain.

3. Installation of a yard drain sump pump with setpoints that f acilitated inspection of the yard drainage piping and lowered the water levels in the area W est of the plant.

4. An inspection of yard drainage piping was recently performed which provides input to the investigation revision so that appropriate corrective actions c an be developed.

4.0 CORRECTIVE STEPS THAT WILL BE TAKEN

The station is revising CAPE 04424065 to incorporate the result s of the actions completed above, document the cause and establish the remaining correctiv e actions to address the erosion of structural backfill. A scope of work is being devel oped to fully mitigate the erosion in a timeframe commensurate with the safety significance of the is sue. A Project Manager has been assigned to ensure that the appropriate resources are prio ritized to resolve this issue.

5.0 DATE OF FULL COMPLIANCE

The station is implementing corrective actions through a revisi on to CAPE 04424065. This revision will be completed by December 1, 2023. At that time, corrective actions will be in place to assure that this condition will be promptly corrected, there by achieving full compliance.

Reply to a Notice of Violation (NOV) - NOV 05000277, 05000278/2 023010-01 Docket Nos. 50-277 and 50-278 Page 1 of 1

ATTACHMENT 2

SUMMARY

OF REGULATORY COMMITMENTS

The following table identifies commitments made in this documen t. (Any other actions discussed in the submittal represent intended or planned action s. They are described to the NRC for the NRCs information and are not regulatory commitment s.)

COMMITMENT COMMITTED DATE COMMITMENT TYPE OR OUTAGE ONE-TIME ACTION PROGRAMMATIC (Yes/No) (Yes/No)

Constellation December 1, 2023 Yes No Energy Generation, LLC, will develop and establish corrective actions to address the erosion of structural backfill in the pipe trench on the West side of the site.