IR 05000254/2019011
| ML19140A084 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/17/2019 |
| From: | Ann Marie Stone NRC/RGN-III/DRP/TSS |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| IR 2019011 | |
| Download: ML19140A084 (12) | |
Text
May 17, 2019 Mr. Bryan Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2NRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS AND TEMPORARY INSTRUCTION 2515/193, IMPLEMENTATION OF RELIABLE HARDENED CONTAINMENT VENTS INSPECTION REPORT 05000254/2019011 AND 05000265/2019011
Dear Mr. Hanson:
On April 26, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Quad Cities Nuclear Power Station, Units 1 and 2 and discussed the results of this inspection with Mr. K. Ohr and other members of your staff. The results of this inspection are documented in the enclosed report.
The NRC inspectors did not identify any finding or violation of more than minor significance.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely,
/RA/
Ann Marie J. Stone, Team Leader Technical Support Staff Division of Reactor Projects
Docket Nos.: 05000254; 05000265 License Nos.: DPR-29; DPR-30
Enclosure:
IR 05000254/2019011; 05000265/2019011
Inspection Report
Docket Numbers:
05000254 and 05000265
License Numbers:
Report Numbers:
05000254/2019011 and 05000265/2019011
Enterprise Identifier: I-2019-011-0031
Licensee:
Exelon Generation Company, LLC
Facility:
Quad Cities Nuclear Power Station, Units 1 and 2
Location:
Cordova, IL
Inspection Dates:
April 22, 2019 to April 26, 2019
Inspectors:
J. Benjamin, Senior Reactor Inspector
J. Gilliam, Reactor Inspector
G. O'Dwyer, Reactor Engineer
S. Sheldon, Project Engineer
D. Tesar, Resident Inspector
Approved By:
Ann Marie J. Stone, Team Leader
Technical Support Staff
Division of Reactor Projects
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Temporary Instruction 2515/191, Mitigation Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness and Temporary Instruction 2515/193,
Implementation of Reliable Hardened Containment Vents inspection at Quad Cities Nuclear Power Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and violations being considered in the NRCs assessment are summarized in the table below.
List of Findings and Violations
No findings or violations were identified.
Additional Tracking Items
None.
INSPECTION SCOPES
Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
OTHER ACTIVITIES
- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL
2515/191 - Inspection of Licensee's Responses to Order EA-12-049, EA-12-051 & EP Info Request March 12, 2012
The inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ML12053A340) and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ML12339A262).
Inspection of Licensee Responses (3 Samples)
- (1) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals and the associated safety evaluation (ML18333A016) and determined that the licensee is in compliance with NRC Order EA-12-049. The inspectors verified the licensee satisfactorily:
- developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events;
- integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;
- protected FLEX equipment from site-specific hazards;
- developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;
- trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and
- developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.
- (2) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is in compliance with NRC Order NRC Order EA-12-051. The inspectors verified the licensee satisfactorily:
- installed the spent fuel pool (SFP) instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation;
- installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals;
- trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and
- developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation.
- (3) The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter, and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force (NTTF) Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to all site units and impedes access to the site. The inspectors verified the following:
- the licensee satisfactorily implemented required staffing changes to support a multi-unit extended loss of alternating current
- (ac) power (ELAP) scenario;
- emergency preparedness (EP) communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and
- the licensee implemented multi-unit dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.
2515/193 - Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions
The inspectors verified plans for complying with NRC Order EA-13-109, Order Modifying Licenses with regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13143A321) are in place and are being implemented by the licensee.
Inspection of the Implementation of EA-13-109 (1 Sample)
Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the reliable hardened containment wetwell vent as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML18348B251) and determined that the licensee is in compliance with NRC Order EA-13-109 Phase 1, Reliable, Severe Accident Capable Wetwell Venting System.
The inspectors verified that the licensee satisfactorily:
- Installed the hardened containment vent system (HCVS) to meet the performance objectives outlined in Section A.1.1 of Attachment 2 to the Order EA-13-109;
- Installed the HCVS system with the design features specified in Section A.1.2 of 2 to the Order EA-13-109;
- Designed the HCVS to meet the quality standards described in Section A.2 of 2 to the Order EA-13-109;
- Developed and implemented adequate maintenance and testing of HCVS equipment to ensure their availability and capability;
- Developed and issued procedures to safely operate the HCVS using normal power supplies, during an ELAP, and during a postulated severe accident scenario, and integrated the procedures into existing plant procedures and,
- Trained their staff to assure personnel can proficiently operate the HCVS.
Based on samples selected for review, the inspectors verified the licensee satisfactorily implemented appropriate elements of the reliable wetwell venting strategy as described in the plant specific submittals and the associated safety evaluation and determined the licensee is in compliance with NRC Order EA-13-109 Phase 2, Reliable, Severe Accident Capable Drywell (or alternative strategy) Venting System. The inspectors verified the licensee satisfactorily developed a strategy making it unlikely that the licensee would need to vent from the containment drywell that included the following:
- Implemented the severe accident water addition (SAWA) and severe accident water management (SAWM) systems as defined and fulfilled functional requirements for installed and portable equipment;
- Installed and/or identified the previously-installed instrumentation necessary to implement SAWM;
- Developed and implemented adequate maintenance and testing of SAWA/SAWM equipment to ensure availability and capability;
- Developed and issued procedures to safely operate the SAWA/SAWM during an ELAP and during postulated severe accident scenario, and integrated their procedures into their existing plant procedures such that entry into and exiting from the procedures are clear when using existing plant procedures; and
- Trained their staff to assure personnel can proficiently operate the HCVS during an ELAP and accident scenario.
The inspectors verified noncompliances with requirements, and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.
The corrective action program documents generated as a result of the inspection are listed in the Documents Reviewed section of this inspection report.
INSPECTION RESULTS
No findings were identified.
EXIT MEETINGS AND DEBRIEFS
The inspectors verified no proprietary information was retained or documented in this report.
- On April 26, 2019, the inspector presented the Temporary Instruction 2515/191 and Temporary Instruction 2515/193 inspection results to Mr. K. Ohr and other members of the licensee staff.
DOCUMENTS REVIEWED
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
2515/191
Corrective Action
Documents
2474611-02
QDC-0000-5-2153 Impact on Robust FLEX Bldg Roll-Up Door
2/31/2015
04098335
Workorder to Set SAWA Flow Meter Parameter
01/29/2018
04137905
PM's for FLEX/SAWA Installed Valves
05/15/2018
224363
Local Intense Precipitation Response Procedure Clarification
2/28/2018
240219
EOID: SAWA Flow Meter Needs Troubleshooting/Calibration
04/16/2019
240525
FLEX SAWA Flow Meter Pushbutton Broken
04/16/2019
Corrective Action
Documents
Resulting from
Inspection
202046
Recommend Installing Jack Stands on Flex Diesel Generators
2/11/2018
242835
NRC Identified Potential Base Metal Corrosion on Deep Well
Pump Casing
4/23/2019
242950
Flex Inspection - LIP Procedure Change Documentation
04/24/2019
243132
FLEX Inspection - FLEX Equipment Refueling Methods
04/24/2019
243508
FLEX - Evaluate Enhancement Alternatives to Yanmar
Placement
04/28/2019
Drawings
Unit 1 External Wiring Diagram, Spent Fuel Pool Level
Instrumentation
A
Local Intense Precipitation Response Procedure Clarification
F
Unit 2 External Wiring Diagram, Spent Fuel Pool Level
Instrumentation
A
Engineering
Changes
FLEX Diesel Fuel Oil Plan Fukushima
2/24/2015
Fuel Oil Storage Tanks FLEX Vent Installation
EOC - FLEX Robust Storage Building
Miscellaneous
Lesson N-QC-EP-
FLEX-REC4
GAP Training for Flex Core Cooling
LN-1602
Containment Auxiliaries Training
LN-1900
Operator Initial/ Continuing Training-Fuel Pool Cooling
LN-Flex 1
Diverse and Flexible Coping Strategies
LN-Flex 2
Flex Equipment
Overall Integrated Plan in Response to Commission Order
Modifying Licenses with Regard to Requirements for Reliable
Spent Fuel Pool Instrumentation
2/28/2013
Final Integrated Plan Document Mitigating Strategies NRC
08/14/2018
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Order EA-12-049
Procedures
189937-01
PMID Preventive Maintenance Monthly Check for FLEX and
B.5.b. Pumps, Equipment and Trailers
Diverse and Flexible Coping Strategies (FLEX), Spent Fuel
Pool Instrumentation (SFPI), and Hardened Containment Vent
System (HCVS) Program Document
CC-QC-118
Site Implementation of Diverse and Flexible Coping Strategies
CC-QC-118
FLEX Periodic Activities
Dose Assessment
EP-AA-110-200-
F-39
URI Detailed Assessment - Summing Dose Assessments
A
On Shift Dose Assessment
Shutdown Safety Management Program
Shutdown Safety Management Program
QCAP 1500-07
Administrative Tracking Requirements For Unavailable FLEX,
QCIPM 1900-01
Spent Fuel Pool Indication System Calibration
QCOA 0010-22
Local Intense Precipitation Response Procedure
QCOA 6100-02
QCOA 6100-04
Station Blackout
QCOP 0050-01
QCOP 0050-02
QCOP 0050-04
FLEX Refuel Floor Action
QCOP 0050-05
FLEX/SAWA Fire Hose Deployment
QCOP 0050-06
FLEX RPV, Suppression Pool, and Spent Fuel Pool Level
Control
QCOP 0050-07
FLEX Generator and Pump Power Cable Deployment
QCOP 0050-08
FLEX Electrical Restoration
QCOP 0050-09
FLEX Response Instrumentation and Communication
Equipment
QCOP 0050-10
FLEX Battery Room Ventilation
QCOP 0050-11
FLEX Control Room Ventilation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
QCOP 0050-12
2
QCOP 0050-13
FLEX Generator/Pump Refueling
QCOP 0050-16
FLEX National SAFER Response Center Interface
QCOP 0050-17
QCOP 1300-10
Bypassing RCIC Isolations: Low RPV Pressure or High Area
Temperature
QCOS 0050-01
Flex Generator Test
QCOS 0050-01-
Flex Well Pump Test
QCOS 0050-06
HCVS Rupture Disc Integrity Test
QGA 100
RPV Control
QGA 200
Primary Containment Control
QGA 500-4
RPV Flooding
QGA 6900-07
Loss of AC Power to the 125 VDC Battery Chargers
Self-Assessments
Quad Cities Nuclear Power Station
NEI 12-01 Phase 2 Staffing Assessment Report
11/03/2014
Work Orders
04678198
480 VAC Annual Inspection and Load Test (DG-1)
03/17/2019
04760168 01
Pre-Outage - SFP Level Probe Camera Inspect and Calibration
Check
2/18/2018
047771006
Emergency Portable Pump A Surveillance
09/03/2018
04796512
FLEX Deep Well Flow Rate Test
2/06/2018
04825926
Security Event Support Equipment Surveillance
11/25/2018
04828799
Emergency Portable Pump C Surveillance
03/12/2019
04896251 01
PMID Preventive Maintenance Monthly Check for FLEX and
B.5.b. Pumps, Equipment and Trailers Completed 4/10/2019
4/10/2019
1740593
FLEX Robust Storage Building Construction EC 398181
05/04/2016
2515/193
Corrective Action
Documents
2473798
Potential Hardened Vent Tower Fabrication Issues
10/07/2016
04024472
HCVS AOV Assembly Bettis Actuator Part 21 Applicability
05/18/2017
04035644
NOS ID: HCVS EC DCS Not Updated to Reflect Calc Revision
07/24/2017
04036129
NOS ID: HCVS Nitrogen Pipe Model Omitted Elements
03/27/2017
04072155
HCVS Battery Charger Not Functioning
11/07/2017
Engineering
Changes
24618
HCVS Phase 2 Validation Evaluation
Inspection
Procedure
Type
Designation
Description or Title
Revision or
Date
Miscellaneous
Initial and Requal
Training N-AN-
Severe Accident Guidelines Management
Procedures
QCOP 1600-13
Venting of Containment
QCOP 6900-56
Hardened Containment Vent 125 VDC Battery System
QCOS 1600-59
Hardened Containment Vent System Test
QCOS 1600-60
Hardened Containment Vent System (HCVS) Operating Cycle
Walkdown
SAMG-1
RPV and Primary Containment Injection
SAMG-2
RPV, Containment, and Radioactivity Release Control
Work Orders
04627858
EC 618667 U1 Hardened Containment Vent System (HCVS)
Phase 2
03/06/2019
04802810
Hardened Containment Vent System Test (IST)
03/18/2019