ML15119A292

Plan for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051

ML15119A292
Person / Time
Site:	Peach Bottom
Issue date:	05/06/2015
From:	Peter Bamford Japan Lessons-Learned Division
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Bamford P, NRR/JLD, 415-2833
References
EA-12-049, EA-12-051, TAC MF0845, TAC MF0846, TAC MF0849, TAC MF0850
Download: ML15119A292 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 6, 2015 Mr. Bryan Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3- PLAN FOR THE ONSITE AUDIT REGARDING IMPLEMENTATION OF MITIGATING STRATEGIES AND RELIABLE SPENT FUEL POOL INSTRUMENTATION RELATED TO ORDERS EA-12-049 AND EA-12-051 (TAC NOS. MF0845, MF0846, MF0849, AND MF0850)

Dear Mr. Hanson:

On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). The orders require holders of operating reactor licenses and construction permits issued under Title 10 of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML13059A305), Exelon Generation Company, LLC (Exelon, the licensee), submitted its OIP for Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS), in response to Order EA-12-049. By letters dated August 28, 2013, February 28, 2014, August 28, 2014, and February 27, 2015 (ADAMS Accession Nos. ML13246A412, ML14059A222, ML14241A252, and ML15058A263, respectively), Exelon submitted its first four six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA-12-049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction LIC-111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the PBAPS interim staff evaluation (ISE) dated November 22, 2013 (ADAMS Accession No. ML13220A105), and continues with in-office and onsite portions of this audit.

By letter dated February 28, 2013 (ADAMS Accession No. ML13059A390), the licensee submitted its OIP for PBAPS, in response to Order EA-12-051. By letter dated June 24, 2013 (ADAMS Accession No. ML13171A354), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated July 19, 2013, August 28, 2013, February 28, 2014, August 28, 2014, and February 27, 2015 (ADAMS Accession Nos. ML13200A343, ML13241A039, ML14059A227, ML14241A303, and ML15058A254, respectively), the licensee submitted its RAI responses and first four six-month updates to the OIP. The NRC staff's

B. Hanson review to date led to the issuance of the PBAPS ISE and RAI dated October 30, 2013 (ADAMS Accession No. ML13295A303). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess whether it has enough information to make a safety evaluation of the Integrated Plans. The audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns. The audit's onsite portion will occur prior to declarations of compliance for the first unit at each site.

This document outlines the on-site audit process that occurs after ISE issuance as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents/Final Integrated Plans, and continue in-office audit communications with staff while proceeding towards compliance with the orders.

The staff plans to conduct an onsite audit at PBAPS in accordance with the enclosed audit plan from June 22 - 26, 2015.

If you have any questions, please contact me at 301-415-2833 or by e-mail at Peter.Bamford@nrc.gov.

Sincerely, Peter Bamford, Senior Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278

Enclosure:

Audit plan cc w/encl: Distribution via Listserv

Audit Plan Peach Bottom Atomic Power Station, Units 2 and 3 BACKGROUND AND AUDIT BASIS On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events" and Order EA-12-051, "Order to Modify Licenses With Regard To Reliable Spent Fuel Pool Instrumentation," (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12054A736 and ML12054A679, respectively). Order EA-12-049 directs licensees to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities in the event of a beyond-design-basis external event (BDBEE). Order EA-12-051 requires, in part, that all operating reactor sites have a reliable means of remotely monitoring wide-range SFP levels to support effective prioritization of event mitigation and recovery actions in the event of a BDBEE. The orders require holders of operating reactor licenses and construction permits issued under Title 1O of the Code of Federal Regulations Part 50 to submit for review, Overall Integrated Plans (OIPs) including descriptions of how compliance with the requirements of Attachment 2 of each order will be achieved.

By letter dated February 28, 2013 (ADAMS Accession No. ML13059A305), Exelon Generation Company, LLC (Exelon, the licensee), submitted its OIP for Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS), in response to Order EA-12-049. By letters dated August 28, 2013, February 28, 2014, August 28, 2014, and February 27, 2015 (ADAMS Accession Nos. ML13246A412, ML14059A222, ML14241A252, and ML15058A263, respectively), Exelon submitted its first four six-month updates to the OIP. By letter dated August 28, 2013 (ADAMS Accession No. ML13234A503), the NRC notified all licensees and construction permit holders that the staff is conducting audits of their responses to Order EA 12 049 in accordance with NRC Office of Nuclear Reactor Regulation (NRR) Office Instruction UC 111, "Regulatory Audits" (ADAMS Accession No. ML082900195). This audit process led to the issuance of the PBAPS interim staff evaluation (ISE) dated November 22, 2013 (ADAMS Accession No. ML13220A105), and continues with in-office and onsite portions of this audit.

By letter dated February 28, 2013 (ADAMS Accession No. ML13059A390), the licensee submitted its OIP for PBAPS, in response to Order EA-12-051. By letter dated June 24, 2013, (ADAMS Accession No. ML13171A354), the NRC staff sent a request for additional information (RAI) to the licensee. By letters dated July 19, 2013, August 28, 2013, February 28, 2014, August 28, 2014, and February 27, 2015 (ADAMS Accession Nos. ML13200A343, ML13241A038, ML14059A227, ML14241A303, and ML15058A254, respectively), the licensee submitted its RAI responses and first four six-month updates to the OIP. The NRC staff's review to date led to the issuance of the PBAPS ISE and RAI dated October 30, 2013 (ADAMS Accession No. ML13295A303). By letter dated March 26, 2014 (ADAMS Accession No. ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

Enclosure

The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess whether it has enough information to make a safety evaluation of the Integrated Plans. The audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation (SFPI) ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns. The audit's onsite portion will occur prior to declarations of compliance for the first unit at each site.

This document outlines the onsite audit process that occurs after ISE issuance as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents (OPDs)/Final Integrated Plans (FIPs), and continue in-office audit communications with staff while proceeding towards compliance with the orders.

Following the licensee's declarations of order compliance, the NRC staff will evaluate the OIPs, as supplemented, the resulting site-specific OPDs/FIPs, and, as appropriate, other licensee submittals based on the requirements in the orders. For Order EA-12-049, the staff will make a safety determination regarding order compliance using the Nuclear Energy Institute (NEI) guidance document NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide" issued in August, 2012 (ADAMS Accession No. ML12242A378), as endorsed, by NRC Japan Lessons-Learned Directorate (JLD) interim staff guidance (ISG) JLD-ISG-2012-01 "Compliance with Order EA-12-049, 'Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events"' (ADAMS Accession No. ML12229A174) as providing one acceptable means of meeting the order requirements. For Order EA-12-051, the staff will make a safety determination regarding order compliance using the NEI guidance document NEI 12-02, "Industry Guidance for Compliance with NRC Order EA-12-051, 'To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML12240A307), as endorsed, with exceptions and clarifications, by NRC ISG JLD-ISG-2012-03 "Compliance with Order EA-12-051, 'Reliable Spent Fuel Pool Instrumentation"' (ADAMS Accession No. ML12221A339), as providing one acceptable means of meeting the order requirements. Should the licensee propose an alternative strategy or other method deviating from the guidance, additional staff review will be required to evaluate if the alternative strategy complies with the applicable order.

AUDIT SCOPE As discussed, onsite audits will be performed per NRR Office Instruction LIC-111, "Regulatory Audits," to support the development of safety evaluations. Site-specific OIPs and OPDs/FIPs rely on equipment and procedures that apply to all units at a site, therefore, audits will be planned to support the "first unit at each site." On-site audits for subsequent units at a site will be on an as-needed basis.

The purpose of the audits is to obtain and review information responsive to the PBAPS OIPs, as supplemented, open and confirmatory items from the mitigation strategies ISE, RAI responses from the SFPI ISE, and to observe and gain a better understanding of the basis for the site's overall programs to ensure the licensee is on the correct path for compliance with the Mitigation Strategies and SFPI orders. These may include, but are not limited to:

• Onsite review and discussion for the basis and approach for detailed analysis and calculations (Orders EA-12-049, EA-12-051);

• Walk-throughs of strategies and laydown of equipment to assess feasibility, timing, and effectiveness of a given mitigating strategy or integration of several strategies (Order EA-12-049);

• Storage, protection, access, and deployment feasibility and practicality for onsite portable equipment (Order EA-12-049);

• Evaluation of staging, access, and deployment of offsite resources to include National SAFER Response Center (NSRC) provided equipment (Order EA-12-049); and

• Review dimensions and sizing of the SFP area, placement of the SFP level instrumentation, and applicable mounting methods and design criteria (Order EA-12-051 ).

NRC AUDIT TEAM Title Team Member Team Lead and Proiect Manager Peter Bamford Technical Support Joshua Miller Technical Support Khoi Nguyen Technical Support Michael Levine Technical Support Bruce Heida Technical Support Kerby Scales LOGISTICS The audit will be conducted onsite at PBAPS the week of June 22 - 26, 2015. Entrance and exit briefings will be held with the licensee at the beginning and end of the audit, respectively, as well as daily briefings of team activities. Additional details will be addressed over the phone prior to the onsite audit. A more detailed schedule is provided below.

A private conference room is requested for NRC audit team use with access to audit documentation upon arrival and as needed.

DELIVERABLES An audit report/summary will be issued to the licensee within 90 days from the end of the audit.

INFORMATION NEEDS

• Materials/documentation provided in responses to open or confirmatory items and RAls in the ISEs;

• OPD/FIP (current version), operator procedures, FLEX Support Guidelines, operator training plans, NSRC (SAFER) PBAPS Response Plan; and

• Materials/documentation for staff audit questions To provide supplemental input to the ongoing audit of documents submitted to the NRC and made available via e-portal, the onsite audit will have three components: 1) a review of the overall mitigating strategies for the site, including, if needed, walk-throughs of strategies and equipment laydown of select portions; 2) a review of material relating to open or confirmatory items and RAls from the ISEs, and staff audit questions; and 3) additional specific issues requested by NRC technical reviewers related to preparation of a safety evaluation. Each part is described in more detail below:

Part 1 - Overall Mitigating Strategies and Program Review:

During the onsite audit, please be prepared to conduct a tabletop discussion of the site's integrated mitigating strategies and SFPI compliance program. This discussion should address the individual components of the plans, as well as the integrated implementation of the strategies, including a timeline. The licensee team presenting this information should include necessary representatives from site management, engineering, training, and operations that were responsible for program development, and will be responsible for training and execution.

Following the tabletop discussion, please be prepared to conduct walk-throughs of procedures and demonstrations of equipment as deemed necessary by NRC audit team members. Include representatives from engineering and operations that will be responsible for training and execution. At this time we expect, at a minimum, to walk-through the items below. Based on the tabletop presentations and audit activities, this list may change.

WALK-THROUGH LIST:

1. Walk-through a sample of strategies that will be delineated by specific NRC technical staff audit team members.

2. Walk-through of portable (FLEX) diesel generator procedures, to include power supply pathways, areas where manual actions are required, and electrical isolation.

3. Walk-through of building access procedures, to include any unique access control devices.

4. Strategy walk-through of transfer routes from staging and storage areas to deployment locations for both onsite and offsite equipment.

5. Strategy walk-through for core cooling and reactor coolant system inventory, to include portable pumping equipment, flow paths, and water storage locations and the related reactor systems analysis and calculations.

6. Walk-through of communications enhancements.

7. Walk-through of SFP area, SFPI locations, main control room, and related equipment mounting areas.

Part 2 - Specific Technical Review Items:

During the visit, audit items will be addressed from the licensee's ISEs open items (01),

confirmatory items (Cl), and SFPI RAls; audit question list (AQ); and draft safety evaluation (SE) additional questions. Please provide documents or demonstrations as needed to respond to each item.

Part 3 - Specific Topics for Discussion:

1. Draft of PBAPS OPD/FIP

2. Training

3. Portable (FLEX) equipment maintenance and testing

4. SAFER Response Plan for PBAPS

Proposed Schedule Onsite Day 1, Monday, June 22, 2015 0800 Check in at site, badging 1000 Entrance meeting 1030 Licensee presentation of strategies 1200 Lunch 1300 NRG Audit Team Activities:

Technical area break-out discussions between NRG and licensee staff in the areas of reactor systems, electrical, balance-of-plant/structures, SFPI, and others Review documents relating to open or confirmatory items, RAls, codes, analyses, etc.

1630 NRG Audit Team meeting 1700 Team lead daily debrief/next day planning with licensee Onsite Day 2, Tuesday, June 23, 2015 0800 NRG Audit Team Activities 1200 Lunch 1300 NRG Audit Team Activities 1630 NRG Audit Team meeting 1700 Team lead daily debrief/next day planning with licensee Onsite Day 3, Wednesday, June 24, 2015 0800 Continue NRG Audit Team Activities - Mitigating Strategies/Sf Pl walk-throughs with licensee 1200 Lunch 1300 Continue NRG Audit Team Activities 1630 NRG Audit Team meeting 1700 Team lead daily debrief/next day planning with licensee

Onsite Day 4, Thursday, June 25, 2015 0800 Continue NRC Audit Team Activities 1200 Lunch 1300 NRC Audit Team meeting 1600 NRG/Licensee pre-exit meeting Onsite Day 5, Friday, June 26, 2015 0900 NRG/Licensee exit meeting 1000 Audit closeout/departure

ML14083A620), the NRC notified all licensees and construction permit holders that the staff is conducting in-office and onsite audits of their responses to Order EA-12-051 in accordance with NRC NRR Office Instruction LIC-111, as discussed above.

The ongoing audit process, to include the in-office and onsite portions, allows the staff to assess whether it has enough information to make a safety evaluation of the Integrated Plans. The audit allows the staff to review open and confirmatory items from the mitigation strategies ISE, RAI responses from the spent fuel pool instrumentation ISE, the licensee's integrated plans, and other audit questions. Additionally, the staff gains a better understanding of submitted information, identifies additional information necessary for the licensee to supplement its plan, and identifies any staff potential concerns. The audit's onsite portion will occur prior to declarations of compliance for the first unit at each site.

This document outlines the on-site audit process that occurs after ISE issuance as licensees provide new or updated information via periodic updates, update audit information on e-portals, provide preliminary Overall Program Documents/Final Integrated Plans, and continue in-office audit communications with staff while proceeding towards compliance with the orders.

The staff plans to conduct an onsite audit at PBAPS in accordance with the enclosed audit plan from June 22 - 26, 2015.

If you have any questions, please contact me at 301-415-2833 or by e-mail at Peter.Bamford@ n re. gov.

Sincerely, IRA/

Peter Bamford, Senior Project Manager Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278

Enclosure:

Audit plan cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsRgn1 MailCenter Resource JLD R/F MHalter, NRR/JLD RidsNrrDorllpl 1-2 Resource PBamford, NRR/JLD RidsNrrPMPeachBottom Resource RidsNrrLASLent Resource RidsAcrsAcnw_MailCTR Resource ADAMS Accession No. ML15119A292 OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NRR/JLD/JOMB/BC(A) NRR/JLD/JOMB/PM NAME PBamford Slent MHalter PBamford DATE 04/29/15 04/29/15 05/04/15 05/06/15