IR 05000171/2020001
| ML20315A407 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 11/10/2020 |
| From: | Anthony Dimitriadis Decommissioning Branch I |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2020001 | |
| Download: ML20315A407 (11) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ber 10, 2020
SUBJECT:
NRC INSPECTION REPORT NO. 05000171/2020001, EXELON GENERATION COMPANY, LLC, PEACH BOTTOM ATOMIC POWER STATION, UNIT 1
Dear Mr. Hanson:
On August 31 - October 16, 2020, the U.S. Nuclear Regulatory Commission (NRC) conducted 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 August 31 - September 2, 2020. Additional inspection activities (in-office reviews) were conducted remotely as a consequence of the COVID-19 public health emergency (PHE) during the inspection period. 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 walkdowns by the inspectors, observations, interviews with site personnel, and a review of procedures and records.
The results of the inspection were discussed with Mr. Matt Herr, Site Vice President, and other members of your organization on October 21, 2020, via teleconference at the conclusion of the inspection. The enclosed report presents the results of this inspection.
The report documents one NRC-identified violation of NRC requirements of very low safety significance (Severity Level IV). Because of the very low safety significance and because it was entered into your corrective action program, the NRC is treating the violation as a Non-Cited Violation (NCV) consistent with Section 2.3.2.a of the NRC Enforcement Policy.
If you contest the subject or severity of this NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the U.S. Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, DC 20555-0001, with a copy to the Regional Administrator, U.S. Nuclear Regulatory Commission - Region I, 2100 Renaissance Blvd., Suite 100, King of Prussia, PA 19406-2713; the Director, Office of Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001; and the Resident Inspector Office at the Peach Bottom Atomic Power Station.
In accordance with Title 10 Code of Federal Regulations (CFR) 2.390 of the NRCs "Rules of Practice," a copy of this letter, its enclosure(s), and your response 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, if any, should not include any personal privacy, proprietary, or safeguards information so that it can be made available to the Public without redaction.
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 Harry Anagnostopoulos at 610-337-5322 if you have any questions regarding this matter.
Sincerely,
/RA/
Anthony Dimitriadis, Chief Decommissioning, ISFSI, and Reactor HP Branch Division of Nuclear Materials Safety Enclosure: Inspection Report No.
05000171/2020001 cc w/encl: Distribution via ListServ
EXECUTIVE SUMMARY
Exelon Generation Company, LLC
Peach Bottom Atomic Power Station Unit 1 (Unit 1)
NRC Inspection Report No. 05000171/2020001 An announced safety inspection was conducted on August 31 - October 16, 2020. The onsite inspection was conducted on August 31 - September 2, 2020, with additional inspection activities conducted remotely during the inspection period as a consequence of the COVID-19 public health emergency (PHE). The inspectors reviewed activities associated with decommissioning performance and status, management oversight, corrective action program (CAP), and site radiological programs. The inspection consisted of plant walkdowns, interviews with Exelon personnel, and a review of procedures and records. The NRCs program for overseeing the safe operation of a shut-down nuclear power reactor is described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program. Based on the results of this inspection, one Non-cited Violation of NRC requirements was identified.
List of Violations A non-cited violation (NCV) associated with Technical Specification, (TS), Section 2.3 was identified by the inspectors because Exelon Generation, LLC (Exelon) had not performed semi-annual inspections of PBAPS Unit No. 1 that included a radiological survey of all of the accessible portions of the exclusion area and inspection of all of the accessible areas below ground level in the containment vessel to monitor for potential water accumulation. From approximately July 1978 until October 16, 2020, the radiological surveys and inspections did not routinely include the areas of containment that may be accessed by unlocking a barrier on the Refueling Floor in order to access the intermediate and ground-levels floors. All or portions of these floors are located within additional controlled areas inside of the containment. Upon identification, Exelon entered the issue into its corrective action program as IR4367002.
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 has been 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 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 collects in the reactor containment sump is periodically pumped out of the sump and transferred to the common radwaste building for Peach Bottom Units 2 and 3 for processing.
The NRC's program for overseeing the safe operation of a shut-down nuclear power reactor is described in IMC 2561.
2.0 SAFSTOR Performance and Status Review
a. Inspection Scope
(Inspection Procedures (IPs) 36801, 37801, 40801, 71801, 83750, 84750, 86750)
A routine announced safety inspection was conducted from August 31 - October 16, 2020 (onsite from August 31 - September 2, 2020), at Unit 1. 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 a walk-down 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 effluent 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 were being appropriately implemented.
The inspectors also reviewed radiological survey reports and condition reports.
b. Observations and Findings
The inspectors verified that management oversight was adequate for the SAFSTOR phase of decommissioning and that no significant changes had been made to the Unit 1 SAFSTOR organization since the previous inspection. The inspectors confirmed that no design changes or plant modifications were made since the previous inspection.
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. Upon entry, the inspectors noted that several additional areas within the containment were also barricaded and posted as RCAs. In some cases, the barricades were expanded metal barriers that were bolted into the wall. In two cases, the barricades consisted of fences with locked gates.
The inspectors questioned the use of the additional barricades, and the reasons for which the walkdowns and surveillances were limited to a small portion of the facility.
Site personnel indicated that inspection of the balance of the facility was limited by the UFSAR and that entry into these controlled areas was only permitted if routine inspections indicated a potential problem. The inspectors completed the tour of the allowed areas of the Unit 1 containment.
The inspectors then reviewed the last two semi-annual surveillances (ST-H-099-960-2, Revision 26) for the Unit 1 Exclusion Areas, which included the Unit 1 containment. The surveillances are intended to satisfy TS 2.3(b)2 and 2.3(b)4 for radiological survey and water inspection, respectively. The inspectors also reviewed the last set of routine radiological surveys for Unit 1. The inspectors found that for the 2019 and 2020 surveillance efforts, the grating over the southwest stairway leading from the refueling floor to the lower levels (B-14) had not been unlocked or opened to allow for full inspection of the intermediate and ground level floors.
The inspectors identified a non-cited violation (NCV) for NRC License No. DPR-12, Amendment 10, Appendix A, Technical Specifications (TS) for Peach Bottom Atomic Power Station (PBAPS) Unit No. 1, Section 2.3 that requires, in part, the performance of semi-annual inspections, 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 for potential water accumulation.
TS Section 1.0 defines the exclusion area as the area within the PBAPS which is enclosed within locked barriers, and contains the Containment Vessel, Spent Fuel Pool Building and Radwaste Building. TS 2.1(b) specifies exclusion area barriers that shall remain locked except when opened to provide egress for inspections, surveys and repairs. These barriers are described in TS 2.1(b)1 and include the grating over the Southwest stairwell (B-14) on the Refueling Floor.
Contrary to the above, from 1978 until October 16, 2020, Exelon Generation, LLC (Exelon) had not performed semi-annual inspections of PBAPS Unit No. 1 that include a radiological survey of all of the accessible portions of the exclusion area and inspection of all of the accessible areas below ground level in the containment vessel for potential water accumulation. Specifically, from approximately July 1978, until October 16, 2020, the radiological surveys and water accumulation inspections had not routinely included the areas of containment that may be accessed by unlocking barrier B-14 on the Refueling Floor in order to survey and inspect the intermediate and ground-level floors.
All or portions of these floors are located within additional controlled areas inside of the containment. Upon identification, Exelon entered the issue into its corrective action program as IR4367002.
Because this violation was of low safety significance and was entered into Exelons CAP, this violation is being treated as a Non-cited Violation, consistent with Section 2.3.2.a of the Enforcement Policy.
The inspectors confirmed that other surveillances were performed as required by the TS.
During the inspection, it was noted that although Exelon had performed structural monitoring inspections at Unit 1, it did not have a specific procedure that governs the effort. In addition, while the structural inspections are documented in surveillance records, the auxiliaries building (which includes the radwaste facility) was not explicitly included in the scope of those surveillance records. The inspectors also noted that the structural inspections inside the reactor containment did not include several large areas located behind the controlled area barricades (as identified in the non-cited violation).
Exelon initiated Issue Report 04378229 to document and evaluate the NRCs concerns regarding the auxiliaries building.
The inspectors reviewed information associated with the status of the decommissioning trust fund and its expenditures, as provided by Exelon during the on-site inspection period, and with no immediate concerns identified.
Tours of the Unit 1 buildings and grounds indicated that the level of attention expended for maintenance, repair, storage, lighting, humidity, fire loading, and adverse weather protection were appropriate for a unit placed in SAFSTOR.
The inspectors verified that any groundwater collected in Unit 1 was transferred to Units 2 and 3 in accordance with plant procedures. The annual radiological effluent and the annual REMP reports demonstrated that all calculated doses were below regulatory dose criteria of 10 Code of Federal Regulations Part 50, Appendix I.
The inspectors verified that programs that remain relevant to Units 2 and 3 were being adequately applied and administered to Unit 1.
The inspectors determined that issues were being identified and entered into the CAP in a timely manner and the issues were effectively screened, prioritized and evaluated commensurate with their safety significance.
c. Conclusions
Based on the results of this inspection, one violation of NRC requirements was identified.
3.0
Exit Meeting Summary
On October 21, 2020, the inspectors presented the inspection results to Mr. Matt Herr, Site Vice President, and other members of Exelons staff. No proprietary information was retained by the inspectors or documented in this report.
PARTIAL LIST OF PERSONS CONTACTED Licensee M. Herr Site Vice President R. Stiltner Engineering Director J. Laverde Design Engineering Manager D. Baracco Radiation Protection Manager D. Dullum Senior Regulatory Engineer D. Mink Site Engineering D. Hines Radiation Protection Supervisor J. Neff Fire Marshall B. Miller Fire Protection Engineer C. Hardee Project Manager S. Patterson Radiation Protection Technician S. Hansell Regulatory Assurance R. Gropp Nuclear Licensing ITEMS OPEN, CLOSED, AND DISCUSSED None LIST OF
DOCUMENTS REVIEWED
Action Requests (AR) 4236437, 4297164, 4297294, 4299794, 4349717, 4367002, 4367005,
4367008
Condition Reports (CR) 808191, 886211, 924196, Decommissioning Peach Bottom Unit 1,
Final Report, Prepared by Catalytic, Inc., July 1978
Decommissioned Units Audit Report, NOSA-PEA-19-10 (AR4289618)
Entry Into Unit 1 During SAFSTOR Decommissioning Status, DC-PB-800-1000, Revision 2
Meeting minutes, PORC Meeting No. 19-15, August 2, 2019
PBAPS Unit 1 Decommissioning Status Report - 2019, March 27, 2020
Quality Assurance Topical Report (QATR), NO-AA-10, Revision 95
Radiation Work Permit PB-C-20-00121, Revision 0
Radiological surveys, Unit 1, dated May 18, 2020
Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel
Storage Installations, RS-19-045, April 1, 2019
Report on Status of Decommissioning Funding for Shutdown Reactors, RS-20-039, March 31,
20
Spreadsheet, Peach Bottom Expenses for 2019
Structures Monitoring, ER-AA-450, Revision 9
Technical Specifications for Peach Bottom Atomic Power Station Unit No. 1, Appendix A to
License No. DPR-12, Amendment 11
LIST OF DOCUMENTS REVIEWED (Contd)
Unit 1 Process Control Program, DC-PB-800, Revision 0
Updated Final Safety Analysis Report, Peach Bottom Atomic Power Station Unit 1, Revision 9,
April 2018
Work orders 0492695701, 04987515-01
LIST OF ACRONYMS USED
CAP Corrective Action Program
Exelon Exelon Generation Company, LLC
IMC Inspection Manual Chapter
IP Inspection Procedure
NRC Nuclear Regulatory Commission
PBAPS Peach Bottom Atomic Power Station
RCA Radiologically Controlled Area
REMP Radiological Environmental Monitoring Program
RETS Radiological Environmental Technical Specifications
TS Technical Specification
UFSAR Updated Final Safety Analysis Report
Unit 1 Peach Bottom Atomic Power Station Unit 1
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