ML24166A117

Regulatory Audit Summary Regarding Proposed Alternative Schedule to Complete Decommissioning Beyond 60 Years

ML24166A117
Person / Time
Site:	Peach Bottom
Issue date:	06/20/2024
From:	Tanya Hood Reactor Decommissioning Branch
To:	David Helker Constellation Energy Generation
References
EPID L- 2023-LLN-0004
Download: ML24166A117 (1)

Text

David P. Helker, Sr. Manager of Licensing Constellation Energy Generation, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNIT 1 - REGULATORY AUDIT

SUMMARY

REGARDING PROPOSED ALTERNATIVE SCHEDULE TO COMPLETE DECOMMISSIONING BEYOND 60 YEARS (EPID L-2023-LLN-0004)

Dear David P. Helker By letter dated October 20, 2023 (Agencywide Documents Access and Management System Accession No. ML23293A305), Constellation Energy Generation, LLC (Constellation, 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.

To support its review of the request, the U.S. Nuclear Regulatory Commission (NRC) staff conducted a regulatory audit that was conducted on April 11, 2024, at the Peach Bottom Atomic Power Station in Delta, PA. The NRC staff reviewed documents and held discussions with members of Constellation. A summary of the regulatory audit, schedule of activities, list of participants, and list of documents are enclosed.

Sincerely, Tanya E. Hood, Project Manager Reactor Decommissioning Branch Division of Decommissioning, Uranium Recovery and Waste Programs Office of Nuclear Material Safety and Safeguards Docket No. 50-171

Enclosures:

1. Regulatory Audit Summary

2. Schedule of Activities

3. List of Participants

4. List of Documents Reviewed During Audit cc: ListservJune 20, 2024 Signed by Hood, Tanya on 06/20/24

ML24166A117 OFFICE NMSS/DUWP:PM NMSS/DUWP:PM NMSS/DUWP: BC NMSS/DUWP:PM NAME THood JParrott NWarnek (Acting) THood DATE 06/17/2024 06/20/2024 06/20/2024 06/20/2024 OFFICE OF OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

REGULATORY AUDIT

SUMMARY

DECOMMISSIONING BEYOND 60 YEARS

CONSTELLATION ENERGY GENERATION, LLC

PEACH BOTTOM ATOMIC POWER STATION, UNIT 1

DOCKET NO. 50-171

1.0 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 proposed request would allow the completion of decommissioning for Peach Bottom Unit 1 beyond 60 years of permanent cessation of operations.

An audit plan was issued by the U.S. Nuclear Regulatory Commission (NRC) staff by email on March 28, 2024 (ML24088A318). The scope of the audit was to gain a more detailed understanding of the licensees processes and procedures to support the NRC staffs licensing decision regarding the request and to identify any information that may require docketing to support the NRC staffs licensing basis.

An audit was determined to be the most efficient approach toward a timely resolution of questions associated with this request. The audit was performed consistent with NRC Office of Nuclear Reactor Regulation Office Instruction LIC-111, Revision 1, Regulatory Audits, dated October 31, 2019 (ML19226A274). A regulatory audit is a planned license or regulation-related activity that includes the examination and evaluation of primarily non-docketed information.

Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This approach is expected to 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.

2.0 AUDIT DATES AND LOCATION

The regulatory audit was conducted on April 11, 2024, at the Peach Bottom Atomic Power Station in Delta, PA. The NRC staff reviewed documents and held technical discussions of audit questions with members of the licensee according to the audit plan.

Enclosure 1 3.0 AUDIT ACTIVITIES

The NRC audit team held a full one-day audit with the licensees staff and contractors that consisted of touring the site which allowed the NRC staff to examine and evaluate information with the intent to gain understanding, verify information, and identify information that will require docketing to support a regulatory decision. The licensee established an online portal in advance of the meeting which allowed the NRC staff to access documents remotely via the internet. This action allowed the NRC staff the opportunity to participate in detailed technical discussions on various topics with the licensee. The detailed discussions were also aided by information needs identified by the NRC staff in the audit plan, along with the licensees presentations and prepared responses to audit questions.

The NRC staff identified information it needed on the docket to support its review. Enclosure 2 provides the schedule of activities during the audit. Enclosure 3 lists audit participants on the NRC audit team. Enclosure 4 lists the documents reviewed during the audit. There were no deviations from the finalized audit plan. No regulatory decisions were made during the audit.

4.0 RESULTS OF THE AUDIT

An audit exit meeting was held at the end of the day, the NRC staff reviewed the proposed resolution to the audit questions with the licensee and reached a consensus regarding the proposed responses to the questions. Based on insights from the audit, the licensee indicated that they could provide a supplement to the request that would address the majority of audit questions asked by the NRC staff. By letter dated May 13, 2024 (ML24134A179), the licensee provided a supplement to the requested licensing action.

The NRC staff communicated to the licensee that upon review of the supplement the NRC staff would determine the need for an RAI. The information submitted in support of the request is under final review, and any additional information needed to support the review will be formally requested by the NRC staff using the RAI process in accordance with the Office of Nuclear Reactor Regulation Office Instruction LIC-101, Revision 6, License Amendment Review Procedures (ML19248C539).

SCHEDULE OF ACTIVITIES

Thursday, April 11, 2024

9:30 am - 10:00 am Eastern Daylight Time (EDT)

Entrance briefing - U.S. Nuclear Regulatory Commission (NRC) and Licensee. Introductions and Site Tour Logistics.

10:00 am - 12:00 pm EDT

Peach Bottom Site Tour

12:00 pm - 1:00 pm EDT

An interactive discussion with the NRC Staff and the Licensee working through lunch.

• Discussion of Audit Question 2 concerning Security Measures

• Discussion of Audit Question 3 concerning Decommissioning Measures

1:00 pm - 1:30 pm EDT

• Discussion of Audit Question 4 concerning Mitigative Measures

• Discussion of Audit Question 6 concerning Limitations

• Discussion of Audit Question 7 concerning Heavy Haul Path

• Demonstrations & Discussion Items 15

1:30 pm - 2:30 pm EDT

• Discussion of Audit Question 8 concerning Cumulative Damage or Duration

• Discussion of Audit Question 10 concerning Decommissioning Conducted

2:30 pm - 2:35 pm EDT - Break

2:35 pm - 3:00 pm EDT

• Discussion of Audit Question 9 concerning Radiological Status of Buildings

• Discussion of Audit Question 11 concerning Hazards Assessment

3:00 pm - 3:30 pm EDT

• Discussion of Audit Question 12 concerning Environmental

• Discussion of Audit Question 13 concerning Structural

Enclosure 2 3:30 pm - 4:30 pm EDT

• Discussion of Audit Question 1 concerning Protective Relay

• Discussion of Audit Question concerning Shared Structures, Systems, and Components (SSCs)

• Demonstrations & Discussion Items 1-14, 16

4:30 pm - 5:30 pm EDT

Final Questions and Exit Meeting Discussion

5:30 pm - 5:40 pm EDT

Closing Remarks and Adjourn

LIST OF PARTICIPANTS

U.S. Nuclear Regulatory Commission Team

• Tanya Hood, Project Manager

• Amy Snyder, Sr. Project Manager

• Christine Pineda, Sr. Environmental Project Manager

• Gregory Chapman, Sr. Health Physicist

• Jennifer Whitman, Deputy Division Director of the Division of Decommissioning, Uranium Recovery, and Waste Programs

• Kayleh Hartage, Electrical Engineer

• Patrick Koch, Structural Engineer

• Shaun Anderson, Reactor Decommissioning Branch Chief

• Sheila Ray, Sr. Electrical Engineer

• Stephen Wyman, Acting Reactor Decommissioning Branch Chief

• Vince Williams, Security Specialist

Enclosure 3 LIST OF DOCUMENTS REVIEWED

• Single line diagrams of electrical power distribution systems for Peach Bottom Unit 1.

• Diagram of relay scheme of the affected 220-08 line.

• List the SSC important to safety that are shared between the Peach Bottom Units.

• Diagram of relay scheme 2-51C-427-2SU, 220-08 Line Undervoltage Relay, GE 12IAV54E1A (electromechanical).

• Diagram of relay scheme 2-51C-459-2SU, 220-08 Line Zero-Sequence Overvoltage Relay, GE 12IAV51A1A (electromechanical).

• Diagram of relay scheme 2-51C-450-2SU, CB #SU25 Breaker Failure Fault Detector, GE NHC (electromechanical).

• Diagram of relay scheme 2-51C-462BF-2SU, CB #SU25 Breaker Failure Timer, GE RPM (electromechanical).

• Diagram of relay scheme 2-51C-86/CBSU25F (breaker failure scheme) lockout relay, GE type HEA.

• Transmission system single line diagram of Units 2 and 3

• Peach Bottom Units 2 and 3 updated final safety analysis report (UFSAR), Appendix F

• Diagram of the major reactor components

• Diagram of the Peach Bottom Unit 1 graphite fuel sleeve

• Diagram of the Peach Bottom Unit 1 top view of the vessel internals

• Diagram of the Peach Bottom Unit 1 heavy haul path and potential laydown area

• Diagram of the Peach Bottom Unit 1 Fort St. Vrain Vessel and Nuclear Steam Supply System

• Waterfall Graphic of planned decommissioning activities.

• Diagram of the monitoring locations around the Peach Bottom site.

Enclosure 4