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Category:Letter
MONTHYEARML24022A2262024-01-22022 January 2024
(PBAPS) Unit 3 - Submittal of the Inservice Inspection (ISI) Owner'S Activity Report (OAR) for the 24th Refueling Outage for Unit 3
ML23346A2412024-01-17017 January 2024
Staff Assessment of Updated Seismic Hazards Following the NRC Process for the Ongoing Assessment of Natural Hazards Information (EPID L-2019-PMP-0061) - Letter
IR 05000277/20234022024-01-11011 January 2024
Security Baseline Inspection Report 05000277/2023402 and 05000278/2023402 and Independent Spent Fuel Storage Installation Security Inspection 07200029/2023401
ML23354A1922024-01-0505 January 2024
Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)
ML23355A0622023-12-18018 December 2023
Independent Spent Fuel Storage Installation (Isfsi), Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan
ML23278A1292023-12-14014 December 2023
Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines
ML23305A1402023-12-13013 December 2023
Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580
ML23334A2502023-11-30030 November 2023
Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation
ML23270C0072023-11-29029 November 2023
Notice of Proposed Amendment to Decommissioning Trust Agreement
ML23317A1192023-11-10010 November 2023
Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums
ML23305A3472023-11-0101 November 2023
Revision of One Form That Implements the Radiological Emergency Response Plan (RERP)
IR 05000277/20230032023-10-30030 October 2023
Integrated Inspection Report 05000277/2023003 and 05000278/2023003 and Exercise of Enforcement Discretion
ML23286A0012023-10-13013 October 2023
Reply to a Notice of Violation (NOV) - NOV 05000277, 05000278/2023010-01
RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023
Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans
ML23271A1342023-10-11011 October 2023
Dtf Analysis Letter
IR 05000277/20244012023-10-0505 October 2023
Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000277/2024401 and 05000278/2024401
ML23265A1502023-09-22022 September 2023
License Amendment Request Revise a License Condition and Certain Technical Specifications to Remove Restrictions in Support of Decommissioning Activities
ML23264A8682023-09-21021 September 2023
Independent Spent Fuel Storage Installation Registration of Dry Storage Canister WC-EOS-37PTH-008-B4L, WC-EOS-37PTH-007-B4L, and WC-EOS-37PTH-002-B4L
IR 05000277/20230102023-09-15015 September 2023
Biennial Problem Identification and Resolution Inspection Report 05000277/2023010 and 05000278/2023010 and Notice of Violation
ML23251A2022023-09-11011 September 2023
Cover Letter W/Report
LR-N23-0045, and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement2023-09-0808 September 2023
and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement
IR 05000277/20230052023-08-31031 August 2023
Updated Inspection Plan for Peach Bottom Atomic Power Station, Units 2 and 3 (Report 05000277/2023005 and 05000278/2023005)
ML23158A1952023-08-30030 August 2023
R. E. Ginna - Issuance of Amendments to Adopt TSTF-273-A, Revision 2, Safety Function Determination Program Clarifications
ML23232A0012023-08-19019 August 2023
Revision of One Procedure That Implements the Radiological Emergency Response Plan (Rerp). Includes EPP 06-009, Rev. 13
IR 05000277/20230112023-08-15015 August 2023
Comprehensive Engineering Team Inspection Report 05000277/2023011 and 05000278/2023011
ML23226A1112023-08-14014 August 2023
10 CFR 50.46 Annual Report
IR 05000277/20230022023-08-0808 August 2023
Integrated Inspection Report 05000277/2023002 and 05000278/2023002
RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023
Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor
IR 05000277/20230402023-07-17017 July 2023
95001 Inspection Supplemental Report 05000277/2023040 and Follow-Up Assessment Letter
ML23188A0532023-07-0707 July 2023
Registration of Use of Independent Spent Fuel Storage Installation (ISFSI) Casks
ML23186A1272023-07-0606 July 2023
Response to Disputed Non-Cited Violation Documented in Peach Bottom Atomic Power Station, Units 2 and 3, Inspection Report 05000277/2022004 and 05000278/2022004
ML23178A0352023-06-27027 June 2023
Senior Reactor and Reactor Operator Initial License Examinations
RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023
Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations
ML23151A4162023-05-31031 May 2023
Revision of One Form That Implements the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS)
ML23150A2052023-05-30030 May 2023
Independent Spent Fuel Storage Installation (Isfsi), Annual Radiological Environmental Operating Report 80 January 1, 2022 Through December 31, 2022
RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023
Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling
ML23142A1602023-05-23023 May 2023
Summary of April 11, 2023, Public Observation Meeting with Constellation Energy Generation, LLC Re Proposed Exemption Request from Work Hour Requirements
ML23132A1582023-05-18018 May 2023
Correction to Technical Specification 3.4.7 (Page 3.4-16) Issued in Amendment No. 337
ML23132A1532023-05-12012 May 2023
Transmittal of 2022 Annual Financial Reports
WM 23-0009, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1)2023-05-10010 May 2023
Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1)
IR 05000277/20230012023-05-0808 May 2023
Integrated Inspection Report 05000277/2023001 and 05000278/2023001
ML23114A2522023-04-28028 April 2023
Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI
2024-01-05
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Category:Licensee Response to Notice of Violation
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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 Notice of Violation, dated September 15, 2023 (ADAMS Accession No. ML23258A049) to this letter provides Constellation Energy Generations (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 provided 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 05000277,05000278/2023010-01 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 05000277,05000278/2023010-01 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 quality, such as deficiencies, defective material, and non-conformances are promptly identified and corrected.
PI-AA-125, Corrective Action Program Procedure, Revision 7, step 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, Peach 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 Determination 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 associated with the erosion of structural backfill material in the pipe trench on the West side of the site. The NCV was documented in NRC inspection report 05000277/2021012 and 05000278/2021012 (ML21265A334). Although the site completed corrective actions to address the human performance issues that resulted in the NCV, the NRC found that the site has not yet created corrective actions to fully address the identified erosion due to ongoing troubleshooting of the condition. Confirmation of the suspected cause and the development of corrective actions is predicated 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 actions for the settlement issue.
The station determined that the cause of the insufficient use of resources was due to untimely prioritization due to misperception of risk.
Reply to a Notice of Violation (NOV) - NOV 05000277,05000278/2023010-01 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 associated with the affected piping to biannual. This action allows for increased monitoring of the condition and will measure the effectiveness of future corrective actions.
- 2. Inspection of the storm drain system and identification of areas of blockage. This information will be incorporated into the investigation revision, and ongoing efforts are in place to clear the drain.
- 3. Installation of a yard drain sump pump with setpoints that facilitated inspection of the yard drainage piping and lowered the water levels in the area West 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 can be developed.
4.0 CORRECTIVE STEPS THAT WILL BE TAKEN The station is revising CAPE 04424065 to incorporate the results of the actions completed above, document the cause and establish the remaining corrective actions to address the erosion of structural backfill. A scope of work is being developed to fully mitigate the erosion in a timeframe commensurate with the safety significance of the issue. A Project Manager has been assigned to ensure that the appropriate resources are prioritized to resolve this issue.
5.0 DATE OF FULL COMPLIANCE The station is implementing corrective actions through a revision 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, thereby achieving full compliance.
Reply to a Notice of Violation (NOV) - NOV 05000277,05000278/2023010-01 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 document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRCs information and are not regulatory commitments.)
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.
