ML24088A320

Beyond 60 Years - Audit Plan

ML24088A320
Person / Time
Site:	Peach Bottom
Issue date:	03/28/2024
From:	Tanya Hood Reactor Decommissioning Branch
To:	Gropp R Constellation Nuclear
References
EPID L-2023-LLN-0004
Download: ML24088A320 (1)

Text

Enclosure AUDIT PLAN REGARDING PROPOSED ALTERNATIVE SCHEDULE TO COMPLETE DECOMMISSIONING BEYOND 60 YEARS CONSTELLATION ENERGY GENERATION, LLC PEACH BOTTOM ATOMIC POWER STATION, UNIT 1 DOCKET NO. 50-171 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 60 years 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 10 CFR Part 50 that are associated with sharing of structures, systems, and components (GDC 5), 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 Unit 1 warrant needing an alternative schedule.

16. Since the alternative decommissioning schedule exemption request is tied to the 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:

Tanya Hood, Project Manager, (Tanya.Hood@nrc.gov)

Amy Snyder, Sr. Project Manager, (Amy.Snyder@nrc.gov)

Christine Pineda, Sr. Environmental Project Manager, (Christine.Pineda@nrc.gov)

Gregory Chapman, Sr. Health Physicist, (Gregory.Chapman@nrc.gov)

Kayleh Hartage, Electrical Engineer (Kayleh.Hartage@nrc.gov)

Patrick Koch, Structural Engineer, (Patrick.Koch@nrc.gov)

Sheila Ray, Sr. Electrical Engineer, (Sheila.Ray@nrc.gov)

Vince Williams, Security Specialist, (Vince.Williams@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.

Proposed Audit Agenda Thursday, April 11, 2024 9:30 am to 5:00 pm TIME TOPIC 9:30 a.m. - 10:00 a.m.

Entrance briefing - NRC and licensee.

Introductions and logistics.

10:00 a.m. - 12:00 p.m.

Site Visit 12:00 p.m. - 12:30 p.m.

Lunch 12:30 p.m. - 4:30 p.m.

Audit Question Discussions 4:30 p.m. - 5:00 p.m.

Summary of Audit and Exit Meeting

Audit Questions By requests 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 proposed request would allow the completion of decommissioning for Peach Bottom Unit 1 beyond 60 years of permanent cessation of operations. The U.S. Nuclear Regulatory Commission (NRC) has determined that the following information is needed in order to complete its review.

Question 01 - Protective Relay Discuss the following regarding the protective relay scheme housed in Peach Bottom Unit 1 that is credited as offsite sources for Peach Bottom Units 2 and 3.

a. Protective relay functions and the enclosure (i.e., relay house)

b. Costs or effort required to move the Peach Bottom Unit 1 protective relay scheme and the impact to Peach Bottom Units 2 and 3 if the relay scheme has to be moved.

c. Discuss the interconnection of the protective relay scheme housed on Peach Bottom Unit 1 and if it is required for GDC 17 and 18 compliance for Peach Bottom Units 2 and 3.

d. Provide the applicable North American Electric Reliability Corporation standards that pertain.

e. The radiological status of the Peach Bottom Unit 1 facility and the subsurface area(s) that houses the protective relay scheme.

Question 02 - Security Measures Peach Bottom Unit 1 is within the Peach Bottom Owner Controlled Area. The Physical Security Plan is inclusive of all three units and the adjacent Independent Spent Fuel Storage Installation (ISFSI). The submittal does not describe which site security measures are associated with, or credited for, the security of Peach Bottom Unit 1.

Describe the security measures for Peach Bottom Unit 1 during the proposed extended period for decommissioning and provide the rationale for why these security measures are adequate for Peach Bottom Unit 1 during safe storage (SAFSTOR) prior to dismantlement. Confirm that the security measures for Peach Bottom Unit 1 during the proposed extended period of decommissioning would not adversely impact the physical protection of Peach Bottom Units 2 and 3 and the associated ISFSI.

Describe whether there would be any impacts to the implementation of physical security for Peach Bottom Units 2 and 3 that could not be reasonably mitigated during the partial or full decommissioning of Peach Bottom Unit 1, if it were to be conducted as scheduled (i.e., without an exemption for an alternative schedule). If so, describe those impacts and why reasonable mitigation wouldnt be possible.

Question 03 - Decommissioning Measures Peach Bottom Unit 1 has been monitored and controlled in SAFSTOR in accordance with the Facility Operating License, Technical Specifications as amended, and Decommissioning Plan.

Explain how decommissioning the remainder of Peach Bottom Unit 1 would differ from the activities that occurred in the past with respect to safety of Peach Bottom Units 2 and 3 and the

licensees ability to maintain public health and safety? Include a discussion about why decommissioning of Peach Bottom Unit 1 on schedule creates site-specific conditions that impact Peach Bottom Units 2 and 3 resulting in an increased risk to public health and safety that would not allow the licensee to maintain safety requirements without an alternative schedule necessary to protect public health and safety.

The application requested that the alternative decommissioning schedule for Peach Bottom Unit 1 coincide with the schedule for Peach Bottom Units 2 and 3, whichever is the first to transition to permanent cessation of operations. Clarify the additional period of required surveillance and maintenance that would result from the alternative decommissioning schedule for Peach Bottom Unit 1.

Question 04 - Mitigative Measures The 1996 Decommissioning Cost Estimate (DCE) assumes that the decommissioning will be conducted concurrent with Peach Bottom Units 2 and 3. In Section 3.2 of the 1996 DCE, the estimate provides a detailed list of activities needed to conduct decommissioning. This list identifies the need for improving roads, building temporary structures for decommissioning, but does not mention any contingencies or mitigative measures needed for decommissioning of Peach Bottom Unit 1 in the presence of Peach Bottom Units 2 and 3. The cost estimate does identify that if the units were not decommissioning concurrently, more resources and time would be needed. Please explain if there are any site-specific factors due to the presence of Peach Bottom Units 2 and or 3 that would prohibit the maintenance of public health and safety.

For SSCs not related to safety, discuss the SSC impact to safe operations of the other nuclear facilities during decommissioning. Share what reasonable mitigative measures may be applied to all or any of the components related to the presence of other nuclear facilities that would result in not needing an alternative schedule for the purpose of maintaining public health and safety.

Question 05 - Shared Structures, Systems, and Components (SSCs)

Provide an assessment of the connection between physical, functional, and spatial interaction between any operating unit as related to the components identified in the October 20, 2023, request that it asserts merit an alternative schedule.

Provide or reference the document(s) containing the potential risk to health and safety of the public on the operating units due to decommissioning one or more units. Also, provide or reference your assessment of risk from potential decommissioning accidents that could affect the safe-operation of the other nuclear facilities to ensure appropriate treatment of important insights related to operation of the other nuclear facilities present such as the ability to:

Control the power Cool the fuel and Maintain containment (defense in depth).

Describe any impacts that decommissioning activities for Peach Bottom Unit 1 following the current decommissioning schedule would have on the structural integrity or intended safety functions of any SSCs important to the safety of Peach Bottom Units 2 and 3. If any structural impacts are identified, discuss whether they could be reasonably prevented or mitigated.

Describe the current structural material condition of and any degradations and/or aging effects on Peach Bottom Unit 1 SSCs that are important to safety. Describe the sources of residual radioactivity including the reactor vessel, reactor coolant system, containment, the spent fuel pool and spent fuel pool building, piping, tanks, and storage containers as applicable and how they would be controlled and contained over the proposed extended period of decommissioning.

Question 06 - Limitations of the request, states:

Limitations on available physical space due to configuration of the site and functional facilities adjacent to PBAPS [Peach Bottom], Unit 1, increase the risk of performing decommissioning activities. The facilities in the vicinity of PBAPS [Peach Bottom], Unit 1, support operation of PBAPS [Peach Bottom], Units 2 and 3, and therefore there will not be limitations following cessation of operations of the adjacent units on site.

Please characterize the limitations based on common decommissioning techniques used in industry today or the ones planned to be use and the degree of increased risk from Peach Bottom Unit 1 decommissioning activities. Indicate whether this increased risk of performing decommissioning prohibit the ability to protect public health and safety.

Question 07 - Heavy Haul Path The Heavy Haul Path is designed to handle traffic with fully loaded casks.

1. What type of inadvertent damage to the Heavy Haul Path due to decommissioning is envisioned that could not be reasonably mitigated?

2. How often will the heavy haul path be used for Peach Bottom Units 2 and 3 in relation to or concurrent with the proposed Peach Bottom Unit 1 demolition and waste removal decommissioning activities?

3. Can decommissioning and fuel transfer campaigns in the portion of the heavy haul path be coordinated or addressed in some other manner so that public health and safety can be maintained? If not, please explain.

Question 08 - Cumulative Damage or Duration of the request discusses the cumulative duration of demolition and dismantling activities.

1. Explain why the cumulative duration of demolition and dismantling activities would be less if all three units were decommissioning together.

2. Explain how the factors stated apply to the criterion in 10 CFR 50.82(a) about the need for an extended decommissioning schedule and would be necessary to protect public health and safety.

3. Explain how waiting beyond 60 years would provide appreciable safety benefits in dose rate or source term reduction by completing decommissioning past the regulatory timeline. Additionally, the unrestricted release criteria under the current regulations are the same for each individual site, regardless of the timeline. How would site-specific factors prevent meeting public health and safety standards?

4. Explain what intensive demolition and dismantling activities will be used for the decommissioning of Peach Bottom Unit 1 and whether they are needed due to the unique site-specific factors present. Would there also be significant impacts to the environment due to these intensive activities?

Question 09 - Radiological Status of Buildings of the request discusses the cumulative duration of demolition and dismantling activities. Does the location (building or subsurface) of the Emergency Operation Center (EOC),

TSC, and Peach Bottom Units 2 and 3 Control Room Simulator need to be decommissioned because of the radiological status? If they do not need to be decommissioning, then how would their presence impact decommissioning on the current decommissioning schedule or an alternative decommissioning schedule. Explain how would decommissioning surrounding them prohibit maintaining public health and safety?

Explain how decommissioning of Peach Bottom Unit 1 would cause major disruptions to the EOC, TSC, and Peach Bottom Units 2 and 3 Control Room Simulator which are located at Peach Bottom Unit 1. Explain the types of major disruptions and if they could be avoided. Would these disruptions prohibit maintaining public health and safety because mitigative measures would be unreasonable?

Question 10 - Decommissioning Conducted of the request states that Peach Bottom Unit 1 facilities have been integrated into the support infrastructure and are actively utilized by Peach Bottom Units 2 and 3. Please clarify what decommissioning activities would be conducted, if the proposed amendment to allow Peach Bottom Unit 1 decommissioning were approved, and their duration if an exemption from 10 CFR 50.82(a)(3) to completion of decommissioning within 60 years were granted.

Question 11 - Hazards Assessment In the 2022 Peach Bottom Unit 1 Decommissioning Status Report, dated March 23, 2023 (ML23090A048) it was reported that:

The inspection of the upper portion of the moisture barrier between the containment shell and the concrete foundation was identified as degraded in December, 2022. At the time of the most recent inspection, the ring trench was dry as past ground water intrusion mitigation efforts have resulted in limited amounts of water from entering containment. Repair of this barrier has been proactively scheduled for 2023 to be completed to ensure the prevention of water intrusion into the Unit 1 containment.

All remaining structural inspections performed in accessible areas showed no indication of significant corrosion, cracks, or structural integrity concerns. The water intrusion has remained at a low level.

Provide a hazards assessment of the containment structure that is inclusive of the proposed extended decommissioning schedule to ensure that the radioactive material would remain contained and that underground contamination through the groundwater pathway remain contained.

Also, identify whether there would be significant construction hazards during demolition of the radiologically contaminated buildings that require decommissioning due to the physical presence of other nuclear facilities that could not be reasonably mitigated.

Question 12 - Environmental The NRC staff will prepare an environmental assessment (EA) pursuant to 10 CFR 51.21 and 51.30. To support a complete description in the EA of the proposed action, provide a written description of activities that would be conducted under the proposed action, such as maintenance, monitoring, and any planned physical changes (e.g., to structures or other features) related to Peach Bottom Unit 1. Include a timeline for the activities from the present to the proposed decommissioning completion date.

Provide a written description of the no action alternative along with a timeline. This includes activities to be conducted if the NRC denies the request for an alternative schedule, including (but not limited to) license termination plan submittal, infrastructure changes (e.g., new roads or structures) to accommodate decommissioning, any intensive decommissioning and demolition techniques, radioactive waste generation and disposal (estimate of rates and quantities), and plans for consultation with the State Historic Preservation Office regarding historic properties.

Several factors may change for residual radioactivity in the groundwater system beyond 60 years, including changes to the groundwater system from changes in climatic conditions since the latest license renewal, cessation of pumping, or from partial decommissioning activities that alter surficial characteristics. These changes may lead to changes in flow direction and magnitude that may lead to new or additional mobilization or acceleration of migration of radionuclides offsite. These potential changes may be offset by reductions in groundwater contamination due to radionuclide decay and additional dilution associated with groundwater flushing and dispersion. How does climate change impact erosion and containment of the radioactivity at Peach Bottom Unit 1 over the proposed alternative decommissioning schedule?

Describe any effects of potential changes to the groundwater system beyond 60 years and whether those changes may lead to increased magnitude and spreading of groundwater residual radioactivity.

Question 13 - Structural Describe any maintenance, surveillance, inspection, or aging management performed to ensure the structural integrity are maintained for Peach Bottom Unit 1. Justify their adequacy to minimize the introduction of residual radioactivity into the site if the decommissioning schedule were extended. In particular, discuss the visual inspections of SSCs described in section 6.4.g of the updated final safety analysis report including the frequency, acceptance criteria, any findings of significance, and how findings are addressed.