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PEACH BOTTOM ATOMIC POWER STATION, UNIT 1 - SAFSTOR INSPECTION REPORT 05000171/2021001
PEACH BOTTOM ATOMIC POWER STATION, UNIT 1 - SAFSTOR INSPECTION REPORT 05000171/2021001


==Dear Mr. Hanson:==
==Dear Mr. Hanson :==
On December 7, 2021, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the Peach Bottom Atomic Power Station Unit 1 (Peach Bottom 1). An on-site inspection was performed December 6-7, 2021. Additional inspection activities (in-office reviews) were conducted remotely as a consequence of the COVID-19 public health emergency (PHE) during this inspection. The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and the conditions of your license. The inspection consisted of plant walk-downs by the inspectors, interviews with site personnel, and a review of procedures and records.
On December 7, 202 1, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the Peach Bottom Atomic Power Station Unit 1 (Peach Bottom 1). An on-site inspection was performed December 6-7, 202 Additional inspection activities (in -office reviews) were conducted remotely as a consequence of the COVID-19 public health emergency (PHE) during this inspectio The inspection examined activities conducted under your license as they relate to safety and compliance with the Com mission's rules and regulations and the conditions of your licens The inspection consisted of plant walk -downs by the inspectors, interviews with site personnel, and a review of procedures and record The results of the inspection were discussed with Mr. Matt Herr, Site Vice President, and other members of your organization on December 16, 2021, via teleconference, at the conclusion of the inspection and are described in the enclosed report. No violations were identifie In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redactio Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communication The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-180 The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).


The results of the inspection were discussed with Mr. Matt Herr, Site Vice President, and other members of your organization on December 16, 2021, via teleconference, at the conclusion of the inspection and are described in the enclosed report. No violations were identified.
B. Hanson


In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
No reply to this letter is require Please contact Orysia Masnyk Bailey at 864-427-1032 if you have any questions regarding this matte


Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communications. The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-1800. The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays). No reply to this letter is required. Please contact Orysia Masnyk Bailey at 864-427-1032 if you have any questions regarding this matter.
Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security


Sincerely, Anthony M. Digitally signed by Anthony M.
Docket No: 05000171 License No: DPR-12


Dimitriadis Dimitriadis Date: 2022.01.12 14:25:11 -05'00'
Enclosure: Inspection Report N
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security Docket No: 05000171 License No: DPR-12 Enclosure: Inspection Report No. 0500171/2021001 w/ Attachment cc w/encl: Distribution via ListServ


=EXECUTIVE SUMMARY=
=EXECUTIVE SUMMARY=
Exelon Generation Company LLC
Exelon Generation Company LLC


Peach Bottom Atomic Power Station, Unit 1 NRC Inspection Report No. 05000171/2021001 An announced routine SAFSTOR inspection was completed on December 7, 2021 at the permanently shut down Peach Bottom Atomic Power Station, Unit 1 (Peach Bottom 1). The inspectors reviewed activities related to the safe storage of radioactive material, including site operations, engineering, maintenance, plant support activities, management oversight, and corrective action program (CAP) implementation. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. At the time of the inspection, no decommissioning activities were being conducted at Peach Bottom 1. The U.S. Nuclear Regulatory Commissions (NRCs) program for overseeing the safe storage of a shutdown nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program.
Peach Bottom Atomic Power Station, Unit 1 NRC Inspection Report No. 05000171 /2021001
 
An announced routine SAFSTOR inspection was completed on December 7, 2021 at the permanently shut down Peach Bottom Atomic Power Station, Unit 1 (Peach Bottom 1). The inspectors reviewed activities related to the safe storage of radioactive material, including site operations, engineering, maintenance, plant support activities, management oversight, and corrective action program (CAP) implementation. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. At the time of the inspection, no decommissioning activities were being conducted at Peach Bottom 1. The U.S. Nuclear Regulatory Commissions (NRCs) program for overseeing the safe storage of a shutdown nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program.


Based on the results of this inspection, no violations were identified.
Based on the results of this inspection, no violations were identified.
Line 48: Line 49:
=REPORT DETAILS=
=REPORT DETAILS=


1.0 Background Peach Bottom Unit 1 was a high temperature gas-cooled demonstration power reactor that operated from February 1966 until October 31, 1974. It was permanently shut down and has been in safe storage (SAFSTOR) since that time. Exelon plans to dismantle Unit 1 in parallel with the decommissioning of the operational Units 2 and 3 after they have been permanently shut down. All fuel from Unit 1 has been removed from the reactor and shipped to an offsite facility. The spent fuel pool has been drained, decontaminated, and radioactive liquids have been removed. Intrusion water that occasionally collects in the reactor containment sump is periodically pumped out of the sump and transferred to the common radwaste building used for Peach Bottom Units 2 and 3 for processing.
1.0 Background
 
Peach Bottom Unit 1 was a high temperature gas-cooled demonstration power reactor that operated from February 1966 until October 31, 1974. It w as permanently shut down and has been in safe storage (SAFSTOR) since that time.
 
Exelon plans to dismantle Unit 1 in parallel with the decommissioning of the operational Units 2 and 3 after they have been permanently shut down. All fuel from Unit 1 has been removed from the reactor and shipped to an offsite facility. The spent fuel pool has been drained, decontaminated, and radioactive liquids have been removed. Intrusion water that occasionally collects in the reactor containment sump is periodically pumped out of the sump and transferred to the common radwaste building used for Peach Bottom Units 2 and 3 for processing.


The NRC's program for overseeing the safe storage and decommissioning of a shut-down nuclear power reactor is described in IMC 2561.
The NRC's program for overseeing the safe storage and decommissioning of a shut-down nuclear power reactor is described in IMC 2561.
Line 56: Line 61:
====a. Inspection Scope====
====a. Inspection Scope====
(Inspection Procedures 37801, 40801, 60801, 64704, 71801, 83750, 84750, 86750)
(Inspection Procedures 37801, 40801, 60801, 64704, 71801, 83750, 84750, 86750)
A routine announced safety inspection was conducted from December 6-7, 2021. The inspection consisted of plant walkdowns, interviews with Exelon personnel, and a review of procedures and records. The inspectors reviewed the SAFSTOR program as outlined in the Updated Final Safety Analysis Report (UFSAR), technical specifications (TS), and procedure DC-PB-800, Unit 1 Process Control Program, to assess the adequacy of management oversight for the Unit 1 facility. Specifically, the inspectors reviewed the decommissioning management and staff organization and Exelons implementation of Unit 1 programs for the SAFSTOR phase of decommissioning. The inspectors also conducted plant walk-downs to assess the material condition of the Unit 1 buildings.


The inspectors reviewed the results of the Exelon Unit 1 Exclusion Area Inspection semi-annual surveillance tests to ensure exclusion area barriers, radiological conditions, water intrusion, and effluent release limits are as specified in the TS. Additionally, as part of this review, the inspectors reviewed the program for structural monitoring inspections at Unit 1.
A routine announced safety inspection was conducted from December 6-7, 2021.
 
The inspection consisted of plant walkdowns, interviews with Exelon personnel, and a review of procedures and records. The inspectors reviewed the SAFSTOR program as outlined in the Updated Final Safety Analysis Report (UFSAR), technical specifications (TS), and procedure DC-PB-800, Unit 1 Process Control Program, to assess the adequacy of management oversight for the Unit 1 facility. Specifically, the inspectors reviewed the decommissioning management and staff organization and Exelons implementation of Unit 1 programs for the SAFSTOR phase of decommissioning.
 
The inspectors also conducted plant walk-downs to assess the material condition of the Unit 1 buildings.
 
The inspectors reviewed the results of the Exelon Unit 1 Exclusion Area Inspection semi -annual surveillance tests to ensure exclusion area barriers, radiological conditions, water intrusion, and effluent release limits are as specified in the TS. Additionally, as part of this review, the inspectors reviewed the program for structural monitoring inspections at Unit 1.


The inspectors reviewed activities, components, and documentation associated with the following SAFSTOR programs: decommissioning organization, staffing, and cost controls; safety reviews and modifications; fire protection, maintenance and surveillance, and license compliance.
The inspectors reviewed activities, components, and documentation associated with the following SAFSTOR programs: decommissioning organization, staffing, and cost controls; safety reviews and modifications; fire protection, maintenance and surveillance, and license compliance.


The inspectors evaluated whether the following programs that remain associated with programs for Units 2 and 3 are being adequately applied and administered for Unit 1:
The inspectors evaluated whether the following programs that remain associated with programs for Units 2 and 3 are being adequately applied and administered for Unit 1:
occupational radiation exposure, radioactive effluent technical specifications (RETS), the site radiological environmental monitoring program (REMP), and the processing and transportation of radioactive waste.
occupational radiation exposure, radioactive e ffluent technical specifications (RETS), the site radiological environmental monitoring program (REMP), and the processing and transportation of radioactive waste.


The inspectors reviewed Exelon fleet audit reports, corrective action program (CAP)documents, and the onsite and offsite safety review committee activities associated with Unit 1 to determine if issues were being appropriately identified, assessed, and reviewed and that corrective actions had been appropriately implemented.
The inspectors reviewed Exelon fleet audit reports, corrective action program (CAP)documents, and the onsite and offsite safety review committee activities associated with Unit 1 to determine if issues were being appropriately identified, assessed, and reviewed and that corrective actions had been appropriately implemented.
Line 74: Line 84:
The inspectors reviewed information relevant to the status of the decommissioning trust fund and its expenditures, as provided by Exelon during the inspection period, with no concerns identified.
The inspectors reviewed information relevant to the status of the decommissioning trust fund and its expenditures, as provided by Exelon during the inspection period, with no concerns identified.


During the previous NRC inspection in 2020, the NRC identified a non-cited violation of Section 2.3 of Amendment 10, Appendix A, Technical Specifications, which requires that a semi-annual inspection, including a radiological survey, of the accessible portions of the exclusion area and inspection of the accessible areas below ground level in the containment vessel. Specifically, from July 1978 until October 2020, these inspections did not include areas of containment that could be accessed by unlocking barrier B-14 on the Refueling Floor to access the intermediate and ground-level floors.
During the previous NRC inspection in 2020, the NRC i dentified a non-cited violation of Section 2.3 of Amendment 10, Appendix A, Technical Specifications, which requires that a semi-annual inspection, including a radiological survey, of the accessible portions of the exclusion area and inspection of the accessible areas below ground level in the containment vessel. Specifically, from July 1978 until October 2020, these inspections did not include areas of containment that could be accessed by unlocking barrier B-14 on the Refueling Floor to access the intermediate and ground-level floors.
 
The licensee addressed this violation by revising ST-H-099-960-2, Unit 1 Exclusion Area Inspection on March 25, 2021 (Rev. 27) to allow access to the areas in question by granting entry to the southwest stairway leading from the refueling floor to the lower levels. This was done by providing the key to unlock barrier B -14.


The licensee addressed this violation by revising ST-H-099-960-2, Unit 1 Exclusion Area Inspection on March 25, 2021 (Rev. 27) to allow access to the areas in question by granting entry to the southwest stairway leading from the refueling floor to the lower levels. This was done by providing the key to unlock barrier B-14. This required a revision to the Unit 1 UFSAR which clarified some ambiguity between periodic and special inspections of containment.
This required a revision to the Unit 1 UFSAR which clarified some ambiguity between periodic and special inspections of containment.


The boundary of the controlled area and the barriers in place to limit access to the controlled area had not been altered. Areas of containment which are sealed due to radiological concerns or other safety hazards will remain inaccessible.
The boundary of the controlled area and the barriers in place to limit access to the controlled area had not been altered. Areas of containment which are sealed due to radiological concerns or other safety hazards will remain inaccessible.


The inspectors entered the Unit 1 containment with members of the Peach Bottom staff for a plant walkdown. The entrances to containment were barricaded (as required by TS) with a locked fence and posted as a radiologically controlled area (RCA). All entrants were briefed on radiological conditions, signed-onto a radiological work permit, and escorted by a radiological protection technician.
The inspectors entered the Unit 1 containment with members of the Peach Bottom staff for a plant walkdown. The entrances to containment were barricaded (as required by TS) with a locked fence and posted as a radiologically controlled area (RCA).
 
All entrants were briefed on radiological conditions, signed-onto a radiological work permit, and escorted by a radiological protection technician.
 
The annual radiological effluent and the annual REMP reports demonstrated that all calculated doses were below regulatory dose criteria of 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents.


The annual radiological effluent and the annual REMP reports demonstrated that all calculated doses were below regulatory dose criteria of 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents. The inspectors discussed shipping requirements and processes with site staff to gain an understanding of the sites experience and expertise on shipping radwaste.
The inspectors discussed shipping requirements and processes with site staff to gain an understanding of the sites experience and expertise on shipping radwaste.


Findings or issues identified in audits, plant equipment operator rounds, and staff observations were entered into the CAP. Site staff effectively addressed the issues identified, implemented corrective actions, and tracked them to closure. Condition reports and corrective actions appeared to be prioritized and evaluated commensurate with their safety significance.
Findings or issues identified in audits, plant equipment operator rounds, and staff observations were entered into the CAP. Site staff effectively addressed the issues identified, implemented corrective actions, and tracked them to closure. Condition reports and corrective actions appeared to be prioritized and evaluated commensurate with their safety significance.
Line 88: Line 104:
====c. Conclusions====
====c. Conclusions====
Based on the results of this inspection, no violations were identified.
Based on the results of this inspection, no violations were identified.
3.0  
3.0  


=====Exit Meeting Summary=====
=====Exit Meeting Summary=====
On December 16, 2021, the inspectors presented the inspection results to Mr. Matt Herr, Site Vice President, and other members of Exelons organization via teleconference. No proprietary information was retained by the inspectors or documented in this report.
On December 16, 2021, the inspectors presented the inspection results to Mr. Matt Herr, Site Vice President, and other members of Exelons organization via teleconference. N o proprietary information was retained by the inspectors or documented in this report.
 
KEY POINTS OF CONTACT
 
Licensee
 
M. Herr, Site Vice President S. ODwyer, Manager of Regulatory Assurance D. Turek, Director of Organizational Performanc e and Regulatory Assurance T. Angelbert, Senior Engineer R. Disabatino, Operations Director B. Dizebba, Manager of Radiation Protection Programs A. Frain, Senior Manager Maintenance Execution D. Williams, Unit 1 Project Manager
 
ITEMS OPEN, CLOSED, AND DISCUSSED


KEY POINTS OF CONTACT Licensee M. Herr, Site Vice President S. ODwyer, Manager of Regulatory Assurance D. Turek, Director of Organizational Performanc e and Regulatory Assurance T. Angelbert, Senior Engineer R. Disabatino, Operations Director B. Dizebba, Manager of Radiation Protection Programs A. Frain, Senior Manager Maintenance Execution D. Williams, Unit 1 Project Manager ITEMS OPEN, CLOSED, AND DISCUSSED The inspectors reviewed the corrective measures implemented for the non-cited violation (NCV)associated with TS Section 2.3 identified during the previous NRC inspection.
The inspectors reviewed the corrective measures implemented for the non-cited violation (NCV)associated with TS Section 2.3 identified during the previous NRC inspection.


LIST OF  
LIST OF  
Line 108: Line 133:
Incident Reports 04448852, 04448849, 04425572, 04418564, 04408190, 04367008, 04367005,
Incident Reports 04448852, 04448849, 04425572, 04418564, 04408190, 04367008, 04367005,
and 04367002
and 04367002
LS-AA-104-1001, Rev. 4, UFSAR Change 2021-002
LS-AA-104-1001, Rev. 4, UFSAR Change 2021 -002
Entry Into Unit 1 During SAFSTOR Decommissioning Status, DC-PB-800-1000, Revision 2
Entry Into Unit 1 During SAFSTOR Decommissioning Status, DC -PB-800-1000, Revision 2
Quality Assurance Topical Report (QATR), NO-AA-10, Revision 97
Quality Assurance Topical Report (QATR), NO -AA-10, Revision 97
Radiation Work Permit PB-C-21-00121, Revision 0
Radiation Work Permit PB-C-21-00121, Revision 0
Radiological surveys, Unit 1, dated May 7, 2021
Radiological surveys, Unit 1, dated May 7, 2021
Report on Status of Decommissioning Funding for Shutdown Reactors, RS-20-030,
Report on Status of Decommissioning Funding for Shutdown Reactors, RS -20- 030,
February 24, 2021
February 24, 2021
Spreadsheet, Peach Bottom Expenses for 2020
Spreadsheet, Peach Bottom Expenses for 2020
Technical Specifications for Peach Bottom Atomic Power Station Unit No. 1, Appendix A to
Technical Specifications for Peach Bottom Atomic Power Station Unit No. 1, Appendix A to
License No. DPR-12, Amendment 11
License No. DPR-12, Amendment 11
LIST OF ACRONYMS USED
LIST OF ACRONYMS USED
CAP     Corrective Action Program
CAP Corrective Action Program
Exelon Exelon Generation Company, LLC
Exelon Exelon Generation Company, LLC
IMC     Inspection Manual Chapter
IMC Inspection Manual Chapter
IP     Inspection Procedure
IP Inspection Procedure
NCV     Non- Cited Violation
NCV Non-Cited Violation
NRC     Nuclear Regulatory Commission
NRC Nuclear Regulatory Commission
PBAPS   Peach Bottom Atomic Power Station
PBAPS Peach Bottom Atomic Power Station
RCA     Radiologically Controlled Area
RCA Radiologically Controlled Area
REMP   Radiological Environmental Monitoring Program
REMP Radiological Environmental Monitoring Program
RETS   Radiological Environmental Technical Specifications
RETS Radiological Environmental Technical Specifications
SAFSTOR safe storage
SAFSTOR safe storage
TS     Technical Specification
TS Technical Specification
UFSAR   Updated Final Safety Analysis Report
UFSAR Updated Final Safety Analysis Report
Unit 1 Peach Bottom Atomic Power Station Unit 1
Unit 1 Peach Bottom Atomic Power Station Unit 1
 
A-2
A-2
}}
}}

Latest revision as of 00:02, 19 November 2024

Safstor Inspection Report 05000171/2021001
ML22012A005
Person / Time
Site: Peach Bottom Constellation icon.png
Issue date: 01/12/2022
From: Anthony Dimitriadis
Division of Nuclear Materials Safety I
To: Bryan Hanson
Exelon Generation Co
References
IR 2021001
Download: ML22012A005 (10)
v • d • e


Text

January 12, 2022

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNIT 1 - SAFSTOR INSPECTION REPORT 05000171/2021001

Dear Mr. Hanson :

On December 7, 202 1, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection under Inspection Manual Chapter 2561, Decommissioning Power Reactor Inspection Program, at the Peach Bottom Atomic Power Station Unit 1 (Peach Bottom 1). An on-site inspection was performed December 6-7, 202 Additional inspection activities (in -office reviews) were conducted remotely as a consequence of the COVID-19 public health emergency (PHE) during this inspectio The inspection examined activities conducted under your license as they relate to safety and compliance with the Com mission's rules and regulations and the conditions of your licens The inspection consisted of plant walk -downs by the inspectors, interviews with site personnel, and a review of procedures and record The results of the inspection were discussed with Mr. Matt Herr, Site Vice President, and other members of your organization on December 16, 2021, via teleconference, at the conclusion of the inspection and are described in the enclosed report. No violations were identifie In accordance with 10 Code of Federal Regulations (CFR) 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be made available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS), accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. To the extent possible, your response should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redactio Current NRC regulations and guidance are included on the NRC's website at www.nrc.gov; select Radioactive Waste; Decommissioning of Nuclear Facilities; then Regulations, Guidance and Communication The current Enforcement Policy is included on the NRC's website at www.nrc.gov; select About NRC, Organizations & Functions; Office of Enforcement; Enforcement documents; then Enforcement Policy (Under 'Related Information'). You may also obtain these documents by contacting the Government Printing Office (GPO) toll-free at 1-866-512-180 The GPO is open from 8:00 a.m. to 5:30 p.m. EST, Monday through Friday (except Federal holidays).

B. Hanson

No reply to this letter is require Please contact Orysia Masnyk Bailey at 864-427-1032 if you have any questions regarding this matte

Sincerely, Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor Health Physics Branch Division of Radiological Safety and Security

Docket No: 05000171 License No: DPR-12

Enclosure: Inspection Report N

EXECUTIVE SUMMARY

Exelon Generation Company LLC

Peach Bottom Atomic Power Station, Unit 1 NRC Inspection Report No. 05000171 /2021001

An announced routine SAFSTOR inspection was completed on December 7, 2021 at the permanently shut down Peach Bottom Atomic Power Station, Unit 1 (Peach Bottom 1). The inspectors reviewed activities related to the safe storage of radioactive material, including site operations, engineering, maintenance, plant support activities, management oversight, and corrective action program (CAP) implementation. The inspection consisted of observations by the inspectors, interviews with site personnel, a review of procedures and records, and plant walk-downs. At the time of the inspection, no decommissioning activities were being conducted at Peach Bottom 1. The U.S. Nuclear Regulatory Commissions (NRCs) program for overseeing the safe storage of a shutdown nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program.

Based on the results of this inspection, no violations were identified.

ii

REPORT DETAILS

1.0 Background

Peach Bottom Unit 1 was a high temperature gas-cooled demonstration power reactor that operated from February 1966 until October 31, 1974. It w as permanently shut down and has been in safe storage (SAFSTOR) since that time.

Exelon plans to dismantle Unit 1 in parallel with the decommissioning of the operational Units 2 and 3 after they have been permanently shut down. All fuel from Unit 1 has been removed from the reactor and shipped to an offsite facility. The spent fuel pool has been drained, decontaminated, and radioactive liquids have been removed. Intrusion water that occasionally collects in the reactor containment sump is periodically pumped out of the sump and transferred to the common radwaste building used for Peach Bottom Units 2 and 3 for processing.

The NRC's program for overseeing the safe storage and decommissioning of a shut-down nuclear power reactor is described in IMC 2561.

2.0 SAFSTOR Performance and Status Review

a. Inspection Scope

(Inspection Procedures 37801, 40801, 60801, 64704, 71801, 83750, 84750, 86750)

A routine announced safety inspection was conducted from December 6-7, 2021.

The inspection consisted of plant walkdowns, interviews with Exelon personnel, and a review of procedures and records. The inspectors reviewed the SAFSTOR program as outlined in the Updated Final Safety Analysis Report (UFSAR), technical specifications (TS), and procedure DC-PB-800, Unit 1 Process Control Program, to assess the adequacy of management oversight for the Unit 1 facility. Specifically, the inspectors reviewed the decommissioning management and staff organization and Exelons implementation of Unit 1 programs for the SAFSTOR phase of decommissioning.

The inspectors also conducted plant walk-downs to assess the material condition of the Unit 1 buildings.

The inspectors reviewed the results of the Exelon Unit 1 Exclusion Area Inspection semi -annual surveillance tests to ensure exclusion area barriers, radiological conditions, water intrusion, and effluent release limits are as specified in the TS. Additionally, as part of this review, the inspectors reviewed the program for structural monitoring inspections at Unit 1.

The inspectors reviewed activities, components, and documentation associated with the following SAFSTOR programs: decommissioning organization, staffing, and cost controls; safety reviews and modifications; fire protection, maintenance and surveillance, and license compliance.

The inspectors evaluated whether the following programs that remain associated with programs for Units 2 and 3 are being adequately applied and administered for Unit 1:

occupational radiation exposure, radioactive e ffluent technical specifications (RETS), the site radiological environmental monitoring program (REMP), and the processing and transportation of radioactive waste.

The inspectors reviewed Exelon fleet audit reports, corrective action program (CAP)documents, and the onsite and offsite safety review committee activities associated with Unit 1 to determine if issues were being appropriately identified, assessed, and reviewed and that corrective actions had been appropriately implemented.

The inspectors also reviewed radiological survey reports and condition reports.

b. Observations and Findings

The inspectors confirmed that the SAFSTOR program was being effectively implemented. The inspectors verified that the maintenance and surveillance program for systems and components had been conducted in accordance with the technical specification requirements and established procedures. The inspectors also confirmed that no dismantlement or decommissioning activities were performed since the previous inspection.

The inspectors reviewed information relevant to the status of the decommissioning trust fund and its expenditures, as provided by Exelon during the inspection period, with no concerns identified.

During the previous NRC inspection in 2020, the NRC i dentified a non-cited violation of Section 2.3 of Amendment 10, Appendix A, Technical Specifications, which requires that a semi-annual inspection, including a radiological survey, of the accessible portions of the exclusion area and inspection of the accessible areas below ground level in the containment vessel. Specifically, from July 1978 until October 2020, these inspections did not include areas of containment that could be accessed by unlocking barrier B-14 on the Refueling Floor to access the intermediate and ground-level floors.

The licensee addressed this violation by revising ST-H-099-960-2, Unit 1 Exclusion Area Inspection on March 25, 2021 (Rev. 27) to allow access to the areas in question by granting entry to the southwest stairway leading from the refueling floor to the lower levels. This was done by providing the key to unlock barrier B -14.

This required a revision to the Unit 1 UFSAR which clarified some ambiguity between periodic and special inspections of containment.

The boundary of the controlled area and the barriers in place to limit access to the controlled area had not been altered. Areas of containment which are sealed due to radiological concerns or other safety hazards will remain inaccessible.

The inspectors entered the Unit 1 containment with members of the Peach Bottom staff for a plant walkdown. The entrances to containment were barricaded (as required by TS) with a locked fence and posted as a radiologically controlled area (RCA).

All entrants were briefed on radiological conditions, signed-onto a radiological work permit, and escorted by a radiological protection technician.

The annual radiological effluent and the annual REMP reports demonstrated that all calculated doses were below regulatory dose criteria of 10 CFR 50, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents.

The inspectors discussed shipping requirements and processes with site staff to gain an understanding of the sites experience and expertise on shipping radwaste.

Findings or issues identified in audits, plant equipment operator rounds, and staff observations were entered into the CAP. Site staff effectively addressed the issues identified, implemented corrective actions, and tracked them to closure. Condition reports and corrective actions appeared to be prioritized and evaluated commensurate with their safety significance.

c. Conclusions

Based on the results of this inspection, no violations were identified.

3.0

Exit Meeting Summary

On December 16, 2021, the inspectors presented the inspection results to Mr. Matt Herr, Site Vice President, and other members of Exelons organization via teleconference. N o proprietary information was retained by the inspectors or documented in this report.

KEY POINTS OF CONTACT

Licensee

M. Herr, Site Vice President S. ODwyer, Manager of Regulatory Assurance D. Turek, Director of Organizational Performanc e and Regulatory Assurance T. Angelbert, Senior Engineer R. Disabatino, Operations Director B. Dizebba, Manager of Radiation Protection Programs A. Frain, Senior Manager Maintenance Execution D. Williams, Unit 1 Project Manager

ITEMS OPEN, CLOSED, AND DISCUSSED

The inspectors reviewed the corrective measures implemented for the non-cited violation (NCV)associated with TS Section 2.3 identified during the previous NRC inspection.

LIST OF

DOCUMENTS REVIEWED

Annual Radiological Environmental Operating Report 76, January 1, 2020 through December

31, 2020, Peach Bottom Atomic Power Station Units 2 and 3

Annual Radiological Groundwater Protection Program Report (ARGPPR)

January 1 through December 31, 2020, Peach Bottom Atomic Power Station Units 2 and 3

Annual Radioactive Effluent Release Report 63, January 1, 2020 through December 31, 2020,

Peach Bottom Atomic Power Station Units 2 and 3 containing Appendix A Radiological Dose

Calculations Manual Specifications (ODCMS) and Bases, Rev. 16

Incident Reports 04448852, 04448849, 04425572, 04418564, 04408190, 04367008, 04367005,

and 04367002

LS-AA-104-1001, Rev. 4, UFSAR Change 2021 -002

Entry Into Unit 1 During SAFSTOR Decommissioning Status, DC -PB-800-1000, Revision 2

Quality Assurance Topical Report (QATR), NO -AA-10, Revision 97

Radiation Work Permit PB-C-21-00121, Revision 0

Radiological surveys, Unit 1, dated May 7, 2021

Report on Status of Decommissioning Funding for Shutdown Reactors, RS -20- 030,

February 24, 2021

Spreadsheet, Peach Bottom Expenses for 2020

Technical Specifications for Peach Bottom Atomic Power Station Unit No. 1, Appendix A to

License No. DPR-12, Amendment 11

LIST OF ACRONYMS USED

CAP Corrective Action Program

Exelon Exelon Generation Company, LLC

IMC Inspection Manual Chapter

IP Inspection Procedure

NCV Non-Cited Violation

NRC Nuclear Regulatory Commission

PBAPS Peach Bottom Atomic Power Station

RCA Radiologically Controlled Area

REMP Radiological Environmental Monitoring Program

RETS Radiological Environmental Technical Specifications

SAFSTOR safe storage

TS Technical Specification

UFSAR Updated Final Safety Analysis Report

Unit 1 Peach Bottom Atomic Power Station Unit 1

A-2

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