ML18282A029

Plan for the In-Office Regulatory Audit Regarding the Subsequent License Renewal Application Review

ML18282A029
Person / Time
Site:	Peach Bottom
Issue date:	10/16/2018
From:	Bennett Brady NRC/NRR/DMLR/MRPB
To:	Gallagher M Exelon Generation Co
Bennett Brady, NRR/DMLR (301) 415-2981
References
EPID L-2018-RNW-0012
Download: ML18282A029 (7)

Text

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October 16, 2018 Mr. Michael Gallagher Vice President, License Renewal and Decommissioning 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - PLAN FOR THE IN-OFFICE REGULATORY AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2018-RNW-0012)

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 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). Exelon requested renewal of the Peach Bottom operating 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 is reviewing this application in accordance with the guidance in NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants.

The NRC plans to conduct an in-office regulatory audit at NRC headquarters offices from November 13 - December 14, 2018, in accordance with the enclosed regulatory audit plan. 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

Enclosure:

Regulatory Audit Plan cc w/encl: Listserv

SUBJECT:

PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 - PLAN FOR THE IN-OFFICE REGULATORY AUDIT REGARDING THE SUBSEQUENT LICENSE RENEWAL APPLICATION REVIEW (EPID NO. L-2018-RNW-0012)

DISTRIBUTION:

PUBLIC

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RidsNrrDmlr Resource Justin.Heinly@nrc.gov; RI/DRP RidsNrrDmlrMrpb Resource Brian.Smith@nrc.gov; RI/DRP RidsNrrDmlrMenb Resource Tara.Inverso@nrc.gov; OEDO RidsNrrDmlrMphb Resource Jeremy.Bowen@nrc.gov OEDO RidsNrrDmlrMccb Resource Mel.Gray@nrc.gov; RI/DRP RidsNrrDmlrMvib Resource Jon.Grieves@nrc.gov; RI/DRS RidsNrrPMPeachBottom Resource Kevin.Mangan@nrc.gov; RI/DRS

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Larry.Burkhard@nrc.gov; OEDO George.Wilson@nrc.gov; NRR/DMLR Doug.Tiff@nrc.gov; RI/SLO Joseph.Donoghue@nrc.gov; NRR/DMLR Darrell.Adams@nrc.gov, OCA Eric.Oesterle@nrc.gov; NRR/DMLR Benjamin.Beasley@nrc.gov; NRR/DMLR Yvonne.Edmonds@nrc.gov; NRR/DMLR Bennett.Brady@nrc.gov; NRR/DMLR David.Drucker@nrc.gov, NRR/DMLR Brice.Bickett@nrc.gov; RI/ORA John.Hufnagel@exeloncorp.com, Scott.Burnell@nrc.gov; HQ/OPA Paul.Weyhmuller@exeloncorp.com Diane.Screnci@nrc.gov; RI/OPA John.Hilditch@exeloncorp.com Neil.Sheehan@nrc.gov; RI/OPA David.Decker@nrc.gov; OCA Lauren.Gibson@nrc.gov, NRR/DMLR Jennefer,Tobin@nrc.gov; NRR/DORL Mitzi.Young@nrc.gov; OGC Anita.Ghosh@nrc.gov; OGC ADAMS Accession Nos. ML18282A029 OFFICE PM:MRPB:DMLR LA:MRPB:DMLR PM:MRPB:DMLR BC:MRPB:DLR PM:MRPB:DMLR NAME BBrady SLent BRogers EOesterle BBrady DATE 10/11 /2018 10/9/2018 10/12/2018 10/15/2018 10/16/2018

Audit Plan In-Office Regulatory Audit Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent License Renewal Application November 13-December 14, 2018 Division of Materials and License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission

Audit Plan In-Office Regulatory Audit Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent License Renewal Application

1. Background By letter dated July 10, 2018 (Agencywide Documents Access and Management System (ADAMS) Package Accession No. ML18193A689), Exelon Generation Company, LLC, (Exelon, the applicant) 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). Exelon requested renewal of the Peach Bottom operating 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 is reviewing this application in accordance with the guidance in NUREG-2192, Standard Review Plan for Review of Subsequent License Renewal Applications for Nuclear Power Plants.

In accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR)

Part 54, the NRC will perform an in-office regulatory audit to gain a better understanding of (1)

Exelons methodology to identify the systems, structures, and components (SSCs) to be included within the scope of license renewal and subject to an aging management review (AMR), and (2) Exelons aging management programs (AMPs), AMR items, Time-Limited Aging Analyses (TLAAs) and associated bases and documentation as applicable.

2. Regulatory Audit Bases License renewal requirements are specified in 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 Scoping and Screening Review The range of scoping and screening review of this regulatory audit is to review the applicants scoping and screening methodology used to identify SSCs within the scope of license renewal and subject to aging management review. The review is performed to evaluate the scoping and screening process as documented in the license renewal application, implementing procedures, reports and drawings, such that the NRC staff:

• Obtains an understanding of the process used to identify the SSCs within the scope of license renewal and to identify the structures and components subject to an aging management review.

• Has sufficient docketed information to allow the NRC staff to reach a conclusion on the adequacy of the scoping and screening methodology as documented and applied.

Enclosure

AMP, AMR, and TLAA Review The scope of the AMP, AMR, and TLAA review of this regulatory audit is to: (a) examine Exelons AMPs, AMR items, and TLAAs for Peach Bottom; (b) verify Exelons claims of consistency with the corresponding GALL-SLR Report AMPs, and AMR items, and (c) assess the adequacy of the TLAAs. Enhancements and exceptions will be evaluated on a case-by-case basis. The NRC staffs review of enhancements and exceptions will be documented in the safety evaluation report.

During this portion of the audit, the NRC staff will audit Program Elements 1 - 10 (scope, preventive actions, parameters monitored or inspected, detection of aging effects, monitoring and trending, acceptance criteria, corrective actions for general recommendations such as compliance with Appendix B, confirmation process, administrative controls, and operating experience) of the applicants AMPs against the elements of the associated AMP described in the GALL-SLR Report. In addition, the NRC staff will verify that the conditions at the plant are bounded by the conditions for which the GALL-SLR Report program was evaluated.

The NRC staff will also examine the applicants program bases documents and related references for AMPs, AMR items, and TLAAs, and interview applicant representatives to obtain additional clarification. Walk downs, if necessary will be performed in a subsequent audit to be performed onsite.

The NRC staff will use risk insights to inform the prioritization of its review of documentation associated with AMPs, AMR items, and TLAAs. The NRC staff will use risk insights to focus the breadth and depth of its review of plant specific operating procedures and 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 and 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 subsequent period of extended operation for all structures and components within the scope of Part 54.

The NRC staff will use risk insights in setting priorities for the scoping and screening methodology.

4. Information and Other Material Necessary for the Regulatory Audit For the in-office audit November 13 - December 14, 2018, the project team will review the license renewal application, as supplemented and revised, the AMP basis documents and other Exelon supporting documents as appropriate and requested

• The project team would like continued Exelon document review capability via the document portal. Document requests for upload to the portal shall be made as needed via the NRC safety project manager to the appropriate Exelon licensing manager.

• The NRC staff would like to hold break-out sessions, via telephone conference calls and/or official internet-based desktop sharing means, with Exelon and Peach Bottom subject matter experts to discuss various basis documents, references, condition/corrective action reports, and to interview Exelon representatives to obtain additional clarification related to the license renewal review. Break-out sessions for various technical review areas will occur at predesignated time slots during the audit, with preassigned NRC and Exelon representatives. The NRC staff will provide

discussion topics and technical requests and questions to the NRC safety project manager, who will then relay the information to the Exelon licensing manager at least a week before the break-out session. All break-out sessions will be coordinated via the NRC safety project manager and the Exelon licensing manager.

5. Team Assignments Name Area Allik, Brian Reviewer - Mechanical Brady, Bennett Project Manager Brimfield, Terrence Reviewer - Scoping and Screening Buford, Angela Reviewer - Structural Chereskin, Alexander Reviewer - Chemical Engineer Cheruvenki, Ganesh Reviewer - Mechanical Cuadrado de Jesus, Samuel Reviewer - Structural Fitzpatrick, Robert Reviewer - Scoping and Screening Fu, Bart Reviewer - Mechanical Gardner, William Reviewer - General Scientist Gavula, James Reviewer - Mechanical Hoang, Dan Reviewer - Mechanical Hoffman, Keith Reviewer - Mechanical Holston, William Reviewer - Mechanical Hovanec, Christopher Reviewer - Mechanical Huynh, Alan Reviewer - Mechanical Iqbal, Naeem Reviewer - Fire Protection Jenkins, Joel Reviewer - Mechanical Johnson, Andrew Reviewer - Mechanical Jones, Steve Reviewer - Scoping and Screening Khan, Nadim Reviewer - Electrical Lehman, Bryce Reviewer - Structural Lopez, Juan Reviewer - Structural Medoff, Jim Reviewer - Mechanical Min, Seung Reviewer - Mechanical Mitchell, Jeff Reviewer - Mechanical Nguyen, Duc Reviewer - Mechanical Nold, David Reviewer - Scoping and Screening Prinaris, Andrew Reviewer - Structural Rezai, Ali Reviewer - Mechanical Rogers, Bill Project Manager Sadollah, Mohammad Reviewer Electrical Thomas, George Reviewer - Structural Yoder, Matthew Reviewer - Chemical Engineer Young, Austin Reviewer - Mechanical

6. Logistics The regulatory audit will be conducted as an in-office (at NRC Headquarters) audit from November 13, 2018, to December 14, 2018. Entrance and exit briefings will be held at the beginning and end of the in-office audit via conference calls. Status calls during the in-office (at NRC Headquarters) audit will occur at least weekly, more if deemed necessary.

7. Special Requests The NRC staff requests the applicant to make available the license renewal application program basis documentation and license renewal drawings, and other documents as requested for independent searches by the regulatory audit team via the portal.

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