ML24088A319

From kanterella
Jump to navigation Jump to search

Audit Plan Associated with Peach Bottom, Unit 1 - 10 CFR 50.82(a)(3) Alternate Decommissioning Schedule
ML24088A319
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 03/28/2024
From: Tanya Hood
Reactor Decommissioning Branch
To: Gropp R
Constellation Nuclear
References
EPID L-2023-LLN-0004
Download: ML24088A319 (1)
v • d • e


Text

From: Tanya Hood To: Gropp Jr, Richard W:(Constellation Nuclear)

Cc: Jack Parrott; Shaun Anderson

Subject:

Audit Plan Associated with Peach Bottom, Unit 1 - 10 CFR 50.82(a)(3) Alternate Decommissioning Schedule Request Date: Thursday, March 28, 2024 12:36:00 PM Attachments: Peach Bottom Unit 1 Beyond 60 Years - Audit Plan 3-28-24.pdf

Good Afternoon Richard,

The U.S. Nuclear Regulatory Commission (NRC) staff has started our review of the request to allow the completion of decommissioning for Peach Bottom Atomic Power Station, Unit 1 (Peach Bottom Unit 1) beyond 60 years of permanent cessation of operations. The NRC staff has determined that a regulatory audit of was the most efficient approach toward a timely resolution of questions associated with this request. A regulatory audit is a planned activity that includes the examination and evaluation of primarily non-docketed information.

The audit will be conducted to increase the NRC staffs understanding of the request and identify information that will require docketing to support the NRC staffs regulatory finding.

The NRC staff will conduct a regulatory audit to support its review of the request in accordance with the following audit plan.

I. BACKGROUND

By letter dated October 20, 2023 (Agencywide Documents Access and Management System Accession No. ML23293A305), Constellation Energy Generation, LLC (the licensee) submitted a request for Peach Bottom Atomic Power Station, Unit 1 (Peach Bottom Unit 1). The request, if approved, would allow the completion of decommissioning for Peach Bottom Unit 1 beyond 60years of permanent cessation of operations.

II. REGULATORY AUDIT BASES

A regulatory audit is a tool available to the staff that can help to efficiently gain understanding, verify information, and/or identify information that will require docketing to support a staff decision. This audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information. An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this request. Performing a regulatory audit is expected to assist the U.S.

Nuclear Regulatory Commission (NRC) staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. This approach is expected minimize the potential for multiple rounds of requests for additional information (RAIs) and eliminate questions that would no longer be necessary to make a safety determination.

The basis of this audit is the licensees request for Peach Bottom Unit 1 and Title 10 of the Code of Federal Regulations (CFR) 50.82 (a). General Design Criteria (GDCs) from Appendix A to 10CFR Part 50 that are associated with sharing of structures, systems, and components (GDC5), electric power systems, (GDC 17), and inspection and testing of electric power systems (GDC 18) are used to support the review of the coupled elements associated with the operating units. The audit will be performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ML19226A274).

III. PURPOSE AND SCOPE

The purpose of the audit is to gain a more detailed understanding of licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. The areas of focus for the regulatory audit are the information contained in the licensees submittal, the enclosed audit information needs, and all associated and relevant supporting documentations (e.g., methodology, process information, calculations). The relevant supporting documents are identified below.

IV. INFORMATION AND OTHER MATERIAL NECESSARY FOR THE REGULATORY REMOTE AUDIT

The NRC audit team will require access to licensees personnel knowledgeable of the technical aspects of the request and the audit questions attached to the plan. The licensee is requested to compile all the information identified in this section prior to the audit so that it is readily available to the staff. The documentation can be provided by presentations, documents, or calculation details.

Documents

1. Single line diagrams of electrical power distribution systems for Peach Bottom Unit 1.
2. Diagram of relay scheme of the affected 220-08 line.
3. List the structures, systems, and components (SSC) important to safety that are shared between the Peach Bottom Units.
4. Copies of correspondence with the State Historic Preservation Office since 2018 concerning unit 1, if any.
5. Environmental documents relevant to activities that would be conducted under the proposed action, including any environmental surveillance/monitoring plans and effluent and waste management plans or procedures.
6. Records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site impacting Peach Bottom Unit 1.

Demonstrations and Discussions

1. Describe shared Peach Bottom Unit 1 electrical systems with Peach Bottom Units 2 and 3 as it pertains to impacts to compliance with GDC 5, 17, and 18.
2. Discuss isolation and protection systems.
3. Describe any portions of the Peach Bottom Unit 1 that may be in radiation areas and how it is being managed to ensure the electrical systems remain functional.
4. Discuss how sufficient power for Peach Bottom Unit 1 decommissioning is available if Peach Bottom Units 2 and 3 are offline.
5. Describe, if any, backup power sources, other than the grid connection, and the reliability of the backup sources.
6. Describe the impact if no power is available to Peach Bottom Unit 1.
7. Provide the Technical Support Center (TSC) power needs and costs or effort required to move the TSC power cables and the impact to the other units.
8. Describe, if any, backup power sources for the TSC.
9. Describe what surveillance, maintenance, inspection, or aging management is needed on the Peach Bottom Unit 1 site for electrical power, lighting, and grounding systems over the proposed extended decommissioning period.
10. Describe, if any, buried cables that are on the Peach Bottom Unit 1 site and those that could not be relocated and therefore would impact the safe operation of Peach Bottom Units 2 and 3.
11. Describe, if any, the purpose or function of the buried cable that impact Peach Bottom Units 2 and 3.
12. Discuss cathodic protection, if any, and the power needed to support cathodic protection.
13. Discuss any impacts decommissioning Peach Bottom Unit 1 would have on the lighting, lightning protection, and grounding needs of Peach Bottom Units 2 and 3 or physical security of Units 2 and 3 and the onsite ISFSI.
14. Discuss the location of the affected 220-08 line and the radiological status of the line and its environs.
15. Describe the limitations on physical space that would increase the risk of performing Peach Bottom Unit 1 decommissioning activities mentioned in attachment 1 to the application and explain how the limitation on physical space for decommissioning at
16. Since the alternative decommissioning schedule exemption request is tied to theUnit1 warrant needing an alternative schedule.

pending license renewal applications for Peach Bottom Units 2 and 3 describe the limitations on the time frame that should be considered, if granted.

17. Audit questions (Attachment 2)

V. AUDIT TEAM

The following are members of the NRC audit team:

  • Amy Snyder, Sr. Project Manager, (Amy.Snyder@nrc.gov)
  • Kayleh Hartage, Electrical Engineer (Kayleh.Hartage@nrc.gov)
  • Sheila Ray, Sr. Electrical Engineer, (Sheila.Ray@nrc.gov)

VI. SPECIAL REQUESTS

The NRC staff would like access to the documents listed above in Section IV through an online portal that allows the NRC staff to access documents remotely via the internet at least 1 week prior to the start of the audit. NRC staffs access to the online portal should be terminated upon issuance of the audit summary discussed in Section VII of this audit plan.

The following conditions associated with the online portal must be maintained throughout the duration that the NRC staff has access to the online portal:

The online portal will be password-protected, and separate passwords will be assigned to the NRC staff who are participating in the audit.

The online portal will be sufficiently secure to prevent the NRC staff and contractors from printing, saving, downloading, or collecting any information on the online portal.

Conditions of use of the online portal will be displayed on the login screen and will require acknowledgement by each user.

Username and password information should be provided directly to the NRC staff. The NRC project manager will provide the licensee the names and contact information of the NRC staff who will be participating in the audit. All other communications should be coordinated with the NRC project manager.

VII. LOGISTICS

The audit will be held on April 11, 2023. If requested, the audit team will conduct a telephone conference with the licensee for the purposes of introducing the team, discussing the scope of the audit, and describing the information to be made available on the online portal. The NRC staff acknowledges the potential for the proprietary nature of some of the information requested. It will be handled appropriately throughout the audit. The NRC staff will take notes that will be marked as proprietary, for such material, and will not remove hard copies or copy electronic files. NRC project manager will coordinate any changes to the audit schedule and location with the licensee. A proposed agenda and the questions for the audit are attached to this audit plan.

VIII. DELIVERABLES

A public version of the audit summary will be prepared within 90 days of the completion of the audit. If the NRC staff identifies information during the audit that is needed to support its regulatory decision, the staff will issue RAIs to the licensee.

Tanya E. Hood Project Manager Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, Maryland 20852-2738 301-415-1387 Tanya.Hood@nrc.gov

Retrieved from "https://kanterella.com/w/index.php?title=ML24088A319&oldid=3686075"