ML18249A280

Plan for the Operating Experience Audit Regarding the Subsequent License Renewal Application Review

ML18249A280
Person / Time
Site:	Peach Bottom
Issue date:	09/13/2018
From:	Bennett Brady NRC/NRR/DMLR/MRPB
To:	Gallagher M Exelon Generation Co
Brady Bennett, DMLR/MRPB, 415-2981
References
Download: ML18249A280 (10)

Text

September 13, 2018

.

Mr. Michael P. Gallagher Vice President, License Renewal and Decommissioning Exelon Nuclear 200 Exelon Way Kennett Square. PA 19348

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3, PLAN FOR THE OPERATING EXPERIENCE AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW Dear Mr. Gallagher By letter dated July 10, 2018 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18193A689), Exelon Generation Company, LLC (Exelon) submitted to the U.S. Nuclear Regulatory Commission (NRC) an application to renew the Renewed Facility Operating License Nos. DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom).

The NRC staff plans to conduct the operating experience audit at the Excel Services Corporation offices in Rockville, Maryland, from September 17 through September 28, 2018, in accordance with the enclosed operating experience audit plan and audit needs list. If you have any questions, please contact me at 301-415-2981 or by e-mail at Bennett.Brady@nrc.gov.

Sincerely,

/RA/

Bennett M. Brady, Senior Project Manager License Renewal Project Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278

Enclosures:

1. Audit Plan

2. Audit Needs List cc w/encls: Listserv

ML18249A280 OFFICE PM:MRPB:DMLR LA:MRPB:DMLR PM:MRPB:DMLR NAME BBrady SLent BRogers DATE 9/12/2018 9/10/2018 9/13/2018 OFFICE BC:MRPB:DMLR PM:MRPB:DMLR NAME EOesterle BBrady DATE 9/13/2018 9/13/2018

Audit Plan Operating Experience Review Audit Regarding the Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent License Renewal Application September 17 - 28, 2018 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Enclosure 1

The Operating Experience Review for the Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent License Renewal Application September 17 - 28, 2018

1. Background By letter dated July 10, 2018 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18193A689), Exelon Generation Company, LLC (Exelon) submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Renewed Facility Operating License Nos. DPR-44 and DPR-56 for the Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom) licenses for an additional 20 years beyond the current renewed 60-year current license terms, which expire on August 8, 2033, for Unit 2 and July 2, 2034, for Unit 3. The staff of the U.S. NRC performs an independent review of plant-specific operating experience to identify examples of age-related degradation, as documented in the applicants corrective action program database.

2. Regulatory Audit Bases License renewal requirements are specified in Title 10 of the Code of Federal Regulations (10 CFR), Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants.

Guidance is provided in NUREG-2192, Rev. 0, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants (SRP-SLR), dated July 2017, and NUREG-2191, Rev. 0, Generic Aging Lessons Learned for Subsequent License Renewal (GALL-SLR) Report, dated July 2017.

3. Regulatory Audit Scope The scope of this SLR regulatory audit of Peach Bottom is the NRC staffs independent review of plant-specific operating experience. The review is performed to identify pertinent examples of age-related degradation, as documented in the applicants corrective action program (CAP) database. The results of the audit will be used to support the NRC staffs further review of aging management programs (AMPs), time limited aging analyses (TLAAs) and aging management review (AMR) items to provide a basis for the NRC staffs conclusions on the ability of the applicants proposed AMRs, AMPs and TLAAs to manage the effects of aging in the subsequent period of extended operation.

The NRC staff will use risk insights to focus the breadth and depth of its review of plant-specific operating experience. However, the NRC staffs review is not limited to risk-significant systems and components because 10 CFR Part 54 is a deterministic rule. The NRC staff must conclude that there is reasonable assurance that activities will continue to be conducted in accordance with the current licensing basis and the effects of aging will be managed during the period of extended operation for all structures and components within the scope of 10 CFR Part 54.

4. Information and Other Material Necessary for the Regulatory Audit As described in the Audit Needs List in Enclosure 2.

5. Team Assignments Area of Review Assigned Auditors (include, but not limited to)

Documentation of plant-specific operating Allik, Brian experience as described in the Peach Brimfield, Terrence Bottom Atomic Power StationUnits 2 and 3 Buford, Angela CAP database. Disciplines include Chereskin, Alexander mechanical, materials, structural and Cheruvenki, Ganesh electrical systems. Cuadrado de Jesus, Samuel Fitzpatrick, Robert Fu, Bart Gardner, William Gavula, James Hoang, Dan Hoffman, Keith Holston, William Huynh, Alan Iqbal, Naeem Jenkins, Joel Johnson, Andrew Jones, Steve Khan, Nadim Lehman, Bryce Lopez, Juan Min, Seung Mitchell, Jeff Nguyen, Duc Nold, David Prinaris, Andrew Rezai, Ali Rogers, Bill Sadollah, Mohammad Thomas, George

6. Logistics The audit will be conducted on location at the Excel Services Corporation offices in Rockville, Maryland, from September 17 - 28, 2018. Entrance and exit briefings will be held at the beginning and end of this audit, respectively.

7. Special Requests The NRC staff requests that Exelon staff at the audit perform special searches of the CAP database as requested by NRC staff. The NRC staff requests a suitable facility for the audit team to caucus during the audit and to hold meetings between NRC staff and Exelon personnel.

8. Deliverables An audit report should be issued within 90 days from the end of the audit.

Operating Experience Audit Regarding the Peach Bottom Atomic Power Station Unit Nos. 2 and 3, Subsequent License Renewal Application Audit Needs List

1. Corrective Action Program Database The U.S. Nuclear Regulatory Commission (NRC) staff requests that Exelon Generation Company, LLC (Exelon) staff, using Exelon equipment, perform searches of the Exelons corrective action program (CAP) database as requested by NRC staff during the Operating Experience (OpE) Audit.

2. License Renewal Portal The NRC staff requests electronic access, using their own equipment, to the Exelon license renewal portal.

3. Prepared Operating Experience Keyword Review Results The NRC staff requests that 10 years of plant-specific CAP entries be compiled into an excel workbook, organized by keywords. The data entered would be all CAP entries (e.g., issue reports, condition reports) that cite one of the keywords in the table below. This spreadsheet will be used by the staff during the OpE Audit. The parameters for the database should be as follows.

• The CAP entries should be compiled with an individual datasheet for each term. Some CAP entries could appear in multiple datasheets due to the use of multiple search terms when the CAP entry was initiated.

• At a minimum, each entry should include the CAP entry number, date of initiation, and the title of the CAP entry or a brief summary. The efficiency of the staffs screening review is increased with more details in the Excel spreadsheet. For example, a simple title might result in the CAP entry appearing to be an applicable age-related issue; however, when the full entry is reviewed, it may be noted that the degradation was not age-related (e.g., damage during excavating buried pipe, damage to internal coatings as a result of scaffold installation).

• For efficiency, it would be helpful to the staff if the CAP entries include the plant system number. This is not required, but it can improve the efficiency of the staffs review process. Specifically, generic search terms such as corros, indication, pit, etc.,

provide a large number of entries and the staffs search time can be significantly reduced if the plant system is identified.

The staff requests electronic access, using Exelon equipment, to the results of the operating keyword list query of Exelons corrective action database. The results are expected to be in an Excel workbook, organized by keywords.

In preparation for the OpE audit, the Project Manager will forward the following key words to the applicant. The applicant will create a searchable database containing these terms and all associated CAP entries that cite the term. The applicant typically provides 10 years of CAP data.

For terms enclosed in quotation marks, the intent is that when compiling the database, only CAP entries where the term is used independently are included. For example, for age, CAP entries would not be included where age was used in package or signage.

It would be helpful to the staff to have one datasheet which incorporates all of the entries associated with the OpE key word terms. This datasheet would be used by staff to search for CAP entries that might not be associated with a specific OpE search term, but is of interest due to data reviewed by accessing the search terms.

89-13 COAT FIRE BARRIER AGE1 COMPONENT COOLING FLAK AGED1 WATER RADIATION FLAW AGING MONITOR FLOW ACCELERATED ALUMINUM CONCRETE FLOW ACCELERATED ARC CONDUCTIVITY CORROSION ARCING CONNECTION FLOW RESTRICT BAC CONTAMINATED CABLE FLOW RESTRICTOR BIOFOUL COOLER FLOW-ACCELERATED BIOLOGICAL COPPER FLOW-ASSIST BLISTER CORONA CAMERA FLUORIDE BLOCK CORRO FOUL BOLT CORROS FRACTURE BORAL CRACK FUEL HANDLING BORIC CRACKED CABLE BUILDING RADIATION BREAK CRANE MONITOR BRITTLE CREVICE FUEL OIL BRITTLE CABLE CYCL FUSE HOLDER BRITTLE INSULATION DAMAGE GALVANIC BRONZE DAMPER GROUT BRYOZOA DEALLOY HALON BURIED DEALUM HANGER BUS DEGRAD HARDEN CABLE DEGRADED CABLE HEAT EXCH CABLE BURNED DEGRAPH HEAT SINK CABLE BUS DELAMIN HEAT TRANS CABLE BUS - DEPOSITS HIGH RANGE EXTERNAL SURFACE - DETECTION CONTAINMENT AREA CORROSION - PITTING DETERIORATED CABLE MONITOR CABLE BUS - REDUCED DEZINC HIGH RANGE ELECTRICAL DISSOLVED OXYGEN RADIATION MONITOR INSULATION DRAINAGE HIGH VOLTAGE CABLE CONTAMINATION DRIP INSULATOR CABLE DEGRADATION DROP HIGH VOLTAGE CABLE DISCOLORED DUG INSULATOR - CRACKS -

CABLE INSULATION EPR FOREIGN DEBRIS CABLE REPLACED EQ HIGH VOLTAGE CABLE RESIDUE EQ AUDIT INSULATOR -

CABLE TESTING EQ INSPECTION MECHANICAL WEAR-CARBON DIOXIDE EQ REANALYSIS CORROSION CAST EQ SELF ASSESSMENT HIGH VOLTAGE CAVITAT EROSI INSULATOR - REDUCED CHECWORK ETHYLENE PROPYLENE ELECTRICAL CHLORIDE RUBBER INSULATION CLAM EXCAVAT HIGH VOLTAGE CLEVIS EXCORE INSULATOR - SALT -

CLOG FAC DUST - COOLING CLOSURE STUD FAIL TOWER PLUME -

CMU FATIGUE CONTAMINATION CO2 FEEDWATER NOZZLE HOLE

HOLIDAY PIPING TRANSIENT HWC PIT MONITORING HYDROGEN WATER POLYMER TRANSMISSION CHEMISTRY POLYMER HV CONDUCTOR - LOSS OF IMPINGE INSULATORS STRENGTH -

INDICATION PRELOAD CORROSION INFRARED INSPECTION PWSCC TRANSMISSION INSTRUMENT AIR Q LIST CONNECTORS -

INSULATION QUALIFICATION OXIDATION - LOSS OF INSULATION RADIATION PRELOAD RESISTANCE MONITORING TRANSMISSION LINE INSULATOR RECUR UNDERGROUND INTERG REDU VAULT INTERMITTENT RESIDUE VESSEL INTERNALS IRON RETURN LINE NOZZLE VIBRATION JACKET RUPTURE VOLTAGE LEACH RUST WALL LOSS LEAK SCALE WALL THICK LINED SCALING WALL THIN LINING SCC WASTAGE LITHIUM SEDIMENT WASTED LOSS OF MATERIAL SEEP WATER INTRUSION MAIN CONTROL ROOM SERVICE WATER WEAR RADIATION MONITO SHELL WELD MANHOLE SILICONE RUBBER WORN MASONRY SILT WRAP MEB SIR ZINC MEDIUM VOLTAGE SPALL CABLE SPRAY METAL ENCLOSED BUS SPRINKLER MIC STEEL MICROBIOLOGIC STRESS MIN WALL STRESS CORROSION MOLLUSK CRACKING MOLY STRUCTURAL SUPPORT MORTAR STUCK NEUTRON ABSORB SUBMERGED CABLE NEUTRON FLUX SULFATE NEUTRON FLUX SUMP DETECTOR SUMP PUMP NEUTRON-ABSORB SWITCHYARD NICKEL-ALLOY TAN DELTA NOBLE TANK NODUL TERMINATION OIL ANALYSIS THERMAL ORGANIC THERMOGRAPHY OXIDATION THREAD OXYGEN THROUGH WALL PARTIAL DISCHARGE TRACKING PEEL TRANSGRA PERFORAT