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| number = ML15091A265
| number = ML15091A265
| issue date = 03/30/2015
| issue date = 03/30/2015
| title = Ltr 03/30/15 Quad Cities Nuclear Power Station Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information Inspection Report 05000254/2015002; 05000265/2015002
| title = Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information Inspection Report 05000254/2015002; 05000265/2015002
| author name = Lipa C
| author name = Lipa C
| author affiliation = NRC/RGN-III/DRS/EB2
| author affiliation = NRC/RGN-III/DRS/EB2
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES
{{#Wiki_filter:UNITED STATES  
                              NUCLEAR REGULATORY COMMISSION
NUCLEAR REGULATORY COMMISSION  
                                                REGION III
REGION III  
                                      2443 WARRENVILLE RD. SUITE 210
2443 WARRENVILLE RD. SUITE 210  
                                            LISLE, IL 60532-4352
LISLE, IL 60532-4352  
                                            March 30, 2015
Mr. Bryan C. Hanson
March 30, 2015  
Senior VP, Exelon Generation Company, LLC
President and CNO, Exelon Nuclear
Mr. Bryan C. Hanson  
4300 Winfield Road
Senior VP, Exelon Generation Company, LLC  
SUBJECT: QUAD CITIES NUCLEAR POWER STATION-NOTIFICATION OF AN NRC
President and CNO, Exelon Nuclear  
              TRIENNIAL HEAT SINK PERFORMANCE INSPECTION AND REQUEST FOR
4300 Winfield Road  
              INFORMATION INSPECTION REPORT 05000254/2015002; 05000265/2015002
SUBJECT: QUAD CITIES NUCLEAR POWER STATION-NOTIFICATION OF AN NRC  
Dear Mr. Hanson:
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION AND REQUEST FOR  
On May 18, 2015, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite portion
INFORMATION INSPECTION REPORT 05000254/2015002; 05000265/2015002
of the Triennial Heat Sink Performance Inspection at your Quad Cities Nuclear Power Station.
Dear Mr. Hanson:  
This inspection will be performed in accordance with NRC Baseline Inspection Procedure (IP)
On May 18, 2015, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite portion  
71111.07.
of the Triennial Heat Sink Performance Inspection at your Quad Cities Nuclear Power Station.
In order to minimize the impact that the inspection has on the site, and to ensure a productive
This inspection will be performed in accordance with NRC Baseline Inspection Procedure (IP)  
inspection, we have enclosed a request for documents needed for the inspection. The
71111.07.  
documents have been divided into three groups.
In order to minimize the impact that the inspection has on the site, and to ensure a productive  
*   The first group lists information necessary for our initial inspection scoping activities. This
inspection, we have enclosed a request for documents needed for the inspection. The  
    information should be available to the lead inspector no later than April 20, 2015. By
documents have been divided into three groups.  
    April 27, 2015, the inspector will communicate the initial selected set of approximately
*  
    2-3 risk-significant heat exchangers.
The first group lists information necessary for our initial inspection scoping activities. This  
*   The second group is needed to support our in-office preparation activities. This set of
information should be available to the lead inspector no later than April 20, 2015. By  
    documents, including the calculations associated with the selected heat exchangers, should
April 27, 2015, the inspector will communicate the initial selected set of approximately  
    be available at the Regional Office no later than May 4, 2015. This information should be
2-3 risk-significant heat exchangers.  
    separated for each selected component, especially if provided electronically (e.g., folder with
*  
    component name that includes calculations, condition reports, maintenance history, etc.).
The second group is needed to support our in-office preparation activities. This set of  
    During the in-office preparation activities, the inspector may identify additional information
documents, including the calculations associated with the selected heat exchangers, should  
    needed to support the inspection.
be available at the Regional Office no later than May 4, 2015. This information should be  
*   The last group includes the additional information above, as well as plant-specific reference
separated for each selected component, especially if provided electronically (e.g., folder with  
    material. This information should be available onsite to the inspector on May 18, 2015. It is
component name that includes calculations, condition reports, maintenance history, etc.).
    also requested that corrective action documents and/or questions developed during the
During the in-office preparation activities, the inspector may identify additional information  
    inspection be provided to the inspector as the documents are generated.
needed to support the inspection.  
All requested documents are to be for the time period from the onsite inspection period back to
*  
the documents that were provided in response to the previous Heat Sink Performance
The last group includes the additional information above, as well as plant-specific reference  
Inspection. If no activities were accomplished in that time period, then the request applies to the
material. This information should be available onsite to the inspector on May 18, 2015. It is  
last applicable document in the previous time period. It is important that these documents be as
also requested that corrective action documents and/or questions developed during the  
complete as possible, in order to minimize the number of documents requested during the
inspection be provided to the inspector as the documents are generated.  
preparation week or during the onsite inspection.
All requested documents are to be for the time period from the onsite inspection period back to  
the documents that were provided in response to the previous Heat Sink Performance  
Inspection. If no activities were accomplished in that time period, then the request applies to the  
last applicable document in the previous time period. It is important that these documents be as  
complete as possible, in order to minimize the number of documents requested during the  
preparation week or during the onsite inspection.  


B. Hanson                                     -2-
B. Hanson  
The lead inspector for this inspection is Michael Jones. We understand that our regulatory
-2-  
contact for this inspection is Tom Peterson of your organization. If there are questions about
The lead inspector for this inspection is Michael Jones. We understand that our regulatory  
the material requested, or the inspection, please call Mr. Jones at (630) 829-9745. Please send
contact for this inspection is Tom Peterson of your organization. If there are questions about  
the information to the following e-mail address Michael.Jones@nrc.gov. A hard-copy with the
the material requested, or the inspection, please call Mr. Jones at (630) 829-9745. Please send  
required information is also an acceptable option.
the information to the following e-mail address Michael.Jones@nrc.gov. A hard-copy with the  
This letter does not contain new or amended information collection requirements subject
required information is also an acceptable option.  
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information
This letter does not contain new or amended information collection requirements subject
collection requirements were approved by the Office of Management and Budget, Control
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information  
Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to
collection requirements were approved by the Office of Management and Budget, Control  
respond to, a request for information or an information collection requirement unless the
Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to  
requesting document displays a currently valid Office of Management and Budget Control
respond to, a request for information or an information collection requirement unless the  
Number.
requesting document displays a currently valid Office of Management and Budget Control  
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public
Number.  
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public  
of this letter, its enclosure, and your response (if any) will be available electronically for public
Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy  
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)
of this letter, its enclosure, and your response (if any) will be available electronically for public  
component of the NRC's Agencywide Documents Access and Management System (ADAMS).
inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)  
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html
component of the NRC's Agencywide Documents Access and Management System (ADAMS).
(the Public Electronic Reading Room).
ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html  
                                              Sincerely,
(the Public Electronic Reading Room).  
                                              /RA Benny Jose Acting for/
Sincerely,  
                                              Christine A. Lipa, Chief
                                              Engineering Branch 2
/RA Benny Jose Acting for/  
                                              Division of Reactor Safety
Docket Nos. 50-254; 50-265
License Nos. DPR-29; DPR-30
Christine A. Lipa, Chief  
Enclosure:
Engineering Branch 2  
   Triennial Heat Sink Performance Inspection
Division of Reactor Safety
   Document Request
Docket Nos. 50-254; 50-265  
cc w/encl: Distribution via LISTSERV
License Nos. DPR-29; DPR-30  
Enclosure:  
   Triennial Heat Sink Performance Inspection
   Document Request  
cc w/encl: Distribution via LISTSERV  


        TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST  
  Inspection Report:           05000254/2015002; 05000265/2015002
Enclosure
  Inspection Dates:             May 18-22, 2015
Inspection Report:
  Inspection Procedure:         IP 71111.07T, Heat Sink Performance
05000254/2015002; 05000265/2015002  
  Lead Inspector:               Michael A. Jones, Jr.
Inspection Dates:  
                                (630) 829-9745
                                Michael.Jones@nrc.gov
May 18-22, 2015  
I.   Information Requested By April 20, 2015:
Inspection Procedure:  
      1.     List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting
IP 71111.07T, Heat Sink Performance  
            Safety-Related Equipment, heat exchangers in order of risk significance.
Lead Inspector:  
      2.     Copy of heat exchanger performance trending data tracked for each GL 89-13 heat
            exchanger.
Michael A. Jones, Jr.  
      3.     List of Corrective Action Program (CAP) documents (with a short description)
(630) 829-9745
            associated with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling, or
            heat exchanger testing, for the previous 3 years, or since the last CAP document list
Michael.Jones@nrc.gov  
            was sent to the NRC for the previous Heat Sink Performance Inspection. The list
I.  
            should include all CAP documents not on the last CAP document list.
Information Requested By April 20, 2015:  
      4.     Copy of any self-assessment done on any of GL 89-13 heat exchangers.
1.  
      5.     Last two System Health Report(s) and maintenance rule system notebooks for all the
List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting  
            GL 89-13 heat exchangers.
Safety-Related Equipment, heat exchangers in order of risk significance.  
      6.     List of engineering-related operator workarounds (with a short description)
2.  
            associated with GL 89-13 heat exchangers. The requested documents are to be for
Copy of heat exchanger performance trending data tracked for each GL 89-13 heat  
            the time period from the onsite inspection period back to the documents that were
exchanger.  
            provided in response to the previous heat sink performance inspection.
3.  
      7.     List of permanent and temporary modifications (with a short description) associated
List of Corrective Action Program (CAP) documents (with a short description)  
            with GL 89-13 heat exchangers. The requested documents are to be for the time
associated with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling, or  
            period from the onsite inspection period back to the documents that were provided in
heat exchanger testing, for the previous 3 years, or since the last CAP document list  
            response to the previous Heat Sink Performance Inspection.
was sent to the NRC for the previous Heat Sink Performance Inspection. The list  
II.   Information Requested By May 4, 2015
should include all CAP documents not on the last CAP document list.  
      1.     Copies of the GL 89-13 responses.
4.  
      2.     Copy of the Updated Final Safety Analysis Report (UFSAR) section applicable to the
Copy of any self-assessment done on any of GL 89-13 heat exchangers.  
            GL 89-13 Heat Exchanger Program.
5.  
      3.     Copies of procedures developed to implement the recommendations of GL 89-13
Last two System Health Report(s) and maintenance rule system notebooks for all the  
            (e.g., the GL 89-13 Heat Exchanger Program description).
GL 89-13 heat exchangers.  
                                                                                        Enclosure
6.  
List of engineering-related operator workarounds (with a short description)  
associated with GL 89-13 heat exchangers. The requested documents are to be for  
the time period from the onsite inspection period back to the documents that were  
provided in response to the previous heat sink performance inspection.  
7.  
List of permanent and temporary modifications (with a short description) associated  
with GL 89-13 heat exchangers. The requested documents are to be for the time  
period from the onsite inspection period back to the documents that were provided in  
response to the previous Heat Sink Performance Inspection.  
II.  
Information Requested By May 4, 2015  
1.  
Copies of the GL 89-13 responses.
2.  
Copy of the Updated Final Safety Analysis Report (UFSAR) section applicable to the  
GL 89-13 Heat Exchanger Program.  
3.  
Copies of procedures developed to implement the recommendations of GL 89-13  
(e.g., the GL 89-13 Heat Exchanger Program description).  


  TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST  
4.     Copies of the selected CAP documents.
2
5.     For the specific heat exchangers selected:
4.  
      a.       Copies of the UFSAR sections applicable for each heat exchanger.
Copies of the selected CAP documents.  
      b.       Copy of system description and design basis document for the heat
5.  
                exchangers (as applicable).
For the specific heat exchangers selected:  
      c.       Provide a list of calculations (with a short description) which currently apply to
a.  
                each heat exchanger.
Copies of the UFSAR sections applicable for each heat exchanger.  
              i.         establish the limiting design basis heat load required to be removed
b.  
                        by each of these heat exchangers;
Copy of system description and design basis document for the heat  
            ii.         demonstrate the heat exchangers capacity to remove the limiting heat
exchangers (as applicable).  
                        load;
c.  
            iii.         correlate surveillance testing and/or inspection results from these heat
Provide a list of calculations (with a short description) which currently apply to  
                        exchangers with design basis heat removal capability (e.g., basis for
each heat exchanger.  
                        surveillance test and/or inspection acceptance criteria);
i.  
            iv.         evaluate the potential for water hammer in each heat exchanger or
establish the limiting design basis heat load required to be removed  
                        associated piping; and
by each of these heat exchangers;  
            v.         evaluate excessive tube vibration in each heat exchanger.
ii.  
      d.       Copy of any operability determinations or other documentation of degradation
demonstrate the heat exchangers capacity to remove the limiting heat  
                associated with the heat exchangers or the systems that support the
load;  
                operation for the selected heat exchangers.
iii.  
      e.       Copy of the construction code, Design Specification, heat exchanger data
correlate surveillance testing and/or inspection results from these heat  
                sheets, and vendor documents including component drawings applicable for
exchangers with design basis heat removal capability (e.g., basis for  
                the heat exchangers.
surveillance test and/or inspection acceptance criteria);  
      f.       Copies of normal, abnormal, and emergency operating procedures
iv.  
                associated with the selected heat exchangers.
evaluate the potential for water hammer in each heat exchanger or  
6.     For the ultimate heat sink (UHS) and the safety-related service water system (or
associated piping; and
      equivalent):
v.  
      a.       Copies of the applicable UFSAR sections.
evaluate excessive tube vibration in each heat exchanger.  
      b.       Copy of system description and design basis document (as applicable).
d.  
      c.       Copy of any operability determinations or other documentation of degradation
Copy of any operability determinations or other documentation of degradation  
                associated with the UHS, and the safety-related service water system.
associated with the heat exchangers or the systems that support the  
      d.       Copy of the document (e.g., UFSAR or Technical Requirements Manual) that
operation for the selected heat exchangers.  
                states the maximum cooling water system inlet temperature limit that still
e.  
                allows full licensed power operation of the nuclear reactor.
Copy of the construction code, Design Specification, heat exchanger data  
      e.       Copy of system description and design basis document (as applicable).
sheets, and vendor documents including component drawings applicable for  
                                                2
the heat exchangers.  
f.  
Copies of normal, abnormal, and emergency operating procedures  
associated with the selected heat exchangers.  
6.  
For the ultimate heat sink (UHS) and the safety-related service water system (or  
equivalent):  
a.  
Copies of the applicable UFSAR sections.  
b.  
Copy of system description and design basis document (as applicable).  
c.  
Copy of any operability determinations or other documentation of degradation  
associated with the UHS, and the safety-related service water system.  
d.  
Copy of the document (e.g., UFSAR or Technical Requirements Manual) that  
states the maximum cooling water system inlet temperature limit that still  
allows full licensed power operation of the nuclear reactor.  
e.  
Copy of system description and design basis document (as applicable).  


        TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST  
            f.     Copy of the construction code and Design Specification.
3
            g.     Copies of normal, abnormal, and emergency operating procedures
f.  
                    associated with the UHS and safety-related service water systems including
Copy of the construction code and Design Specification.  
                    procedures for loss of these systems.
g.  
            h.     Copy of any operability determinations or other documentation of degradation
Copies of normal, abnormal, and emergency operating procedures  
                    associated with the UHS, and the safety-related service water system.
associated with the UHS and safety-related service water systems including  
            i.     Copies of corrective action documents associated with water hammer or
procedures for loss of these systems.  
                    hydraulic transients in the service water system since the last Heat Sink
h.  
                    Performance Inspection.
Copy of any operability determinations or other documentation of degradation  
            j.     If available, provide an electronic copy of piping and instrumentation
associated with the UHS, and the safety-related service water system.  
                    diagrams (P&IDs) for the service water system, including the intake structure.
i.  
            k.     Provide a list of calculations (with a short description), which currently apply
Copies of corrective action documents associated with water hammer or  
                    to UHS, and service water system.
hydraulic transients in the service water system since the last Heat Sink  
            l.     Provide a list of instruments (with a short description) associated with
Performance Inspection.  
                    automatic or alarm functions for the safety-related service water system
j.  
                    and/or UHS.
If available, provide an electronic copy of piping and instrumentation  
            m.     Provide a list of any design change (with a short description) performed on
diagrams (P&IDs) for the service water system, including the intake structure.  
                    the UHS or safety-related service water system since the last heat sink
k.  
                    performance inspection.
Provide a list of calculations (with a short description), which currently apply  
    7.     A schedule of all inspections, cleanings, maintenance, or testing of any
to UHS, and service water system.  
            safety-related plant heat exchanger to be performed during the on-site portion of the
l.  
            inspection.
Provide a list of instruments (with a short description) associated with  
III. Information Requested to be Available on First Day of Inspection, May 18, 2015
automatic or alarm functions for the safety-related service water system  
    1.     For the specific heat exchangers selected:
and/or UHS.  
            a.     Copy of the calculation which correlates surveillance testing results from
m.  
                    these heat exchangers with design basis heat removal capability (e.g., basis
Provide a list of any design change (with a short description) performed on  
                    for surveillance test acceptance criteria).
the UHS or safety-related service water system since the last heat sink  
            b.     Copies of the two most recent completed tests and evaluation data
performance inspection.  
                    confirming thermal performance for those heat exchangers which are
7.  
                    performance tested.
A schedule of all inspections, cleanings, maintenance, or testing of any  
            c.     Documentation and procedures that identify the types, accuracy, and location
safety-related plant heat exchanger to be performed during the on-site portion of the  
                    of any special instrumentation used for the two most recently completed
inspection.  
                    thermal performance tests for the heat exchangers (e.g., high accuracy
III.  
                    ultrasonic flow instruments or temperature instruments). Include calibration
Information Requested to be Available on First Day of Inspection, May 18, 2015  
                    records for the instruments used during these tests.
1.  
            d.     Information regarding any alarms which monitor on-line performance.
For the specific heat exchangers selected:  
                                                    3
a.  
Copy of the calculation which correlates surveillance testing results from  
these heat exchangers with design basis heat removal capability (e.g., basis  
for surveillance test acceptance criteria).  
b.  
Copies of the two most recent completed tests and evaluation data  
confirming thermal performance for those heat exchangers which are  
performance tested.
c.  
Documentation and procedures that identify the types, accuracy, and location  
of any special instrumentation used for the two most recently completed  
thermal performance tests for the heat exchangers (e.g., high accuracy  
ultrasonic flow instruments or temperature instruments). Include calibration  
records for the instruments used during these tests.  
d.  
Information regarding any alarms which monitor on-line performance.


  TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST  
      e.     Copy of the document describing the inspection results of each heat
4
              exchanger. The requested documents are to be for the time period from the
e.  
              onsite inspection period back to the documents that were provided in
Copy of the document describing the inspection results of each heat  
              response to the previous Heat Sink Performance Inspection.
exchanger. The requested documents are to be for the time period from the  
      f.     The cleaning and inspection maintenance schedule for each heat exchanger
onsite inspection period back to the documents that were provided in  
              for the next 5 years.
response to the previous Heat Sink Performance Inspection.
      g.     Copy of the design specification and heat exchanger data sheets for each
f.  
              heat exchanger.
The cleaning and inspection maintenance schedule for each heat exchanger  
      h.     Copy of the vendor manuals including component drawings for each heat
for the next 5 years.  
              exchanger.
g.  
      i.     Copy of the calculation which establishes the limiting (maximum) design
Copy of the design specification and heat exchanger data sheets for each  
              basis heat load which is required to be removed by each of these heat
heat exchanger.
              exchangers.
h.  
      j.     Copy of the operating procedure that ensures that the maximum cooling
Copy of the vendor manuals including component drawings for each heat  
              water system inlet temperature limit is not exceeded.
exchanger.  
      k.     Copy of the calculations or documents which evaluate the potential for water
i.  
              hammer in each heat exchanger or associated piping.
Copy of the calculation which establishes the limiting (maximum) design  
      l.     Copy of the calculations that evaluate excessive tube vibration in each heat
basis heat load which is required to be removed by each of these heat  
              exchanger and the documents that describe the controls that prevent heat
exchangers.  
              exchanger degradation due to excessive flow induced vibration during
j.  
              operation.
Copy of the operating procedure that ensures that the maximum cooling  
      m.     Copy of the periodic flow testing at or near maximum design flow. The
water system inlet temperature limit is not exceeded.  
              requested documents are to be for the time period from the onsite inspection
k.  
              period back to the documents that were provided in response to the previous
Copy of the calculations or documents which evaluate the potential for water  
              Heat Sink Performance Inspection.
hammer in each heat exchanger or associated piping.
      n.     Copy of the document which identifies the current number of tubes in service
l.  
              for each heat exchanger and the supporting calculation which establishes the
Copy of the calculations that evaluate excessive tube vibration in each heat  
              maximum number of tubes which can be plugged in each heat exchanger.
exchanger and the documents that describe the controls that prevent heat  
      o.     Copy of the document establishing the repair criteria (plugging limit) for
exchanger degradation due to excessive flow induced vibration during  
              degraded tubes which are identified in each heat exchanger.
operation.  
      p.     Copies of the documents that verify the structural integrity of the heat
m.  
              exchanger (e.g., eddy current summary sheets, ultrasonic testing results, and
Copy of the periodic flow testing at or near maximum design flow. The  
              visual inspection results).
requested documents are to be for the time period from the onsite inspection  
      q.     Copies of those documents that describe the methods taken to control water
period back to the documents that were provided in response to the previous  
              chemistry in the heat exchangers.
Heat Sink Performance Inspection.  
2.     For the review of the performance testing of the safety-related service water system
n.  
      (or equivalent) and the UHS:
Copy of the document which identifies the current number of tubes in service  
      a.     Copies of the last two performance tests, such as the American Society of
for each heat exchanger and the supporting calculation which establishes the  
              Mechanical Engineers in-service test, for the pumps, valves, and, if
maximum number of tubes which can be plugged in each heat exchanger.  
                                            4
o.  
Copy of the document establishing the repair criteria (plugging limit) for  
degraded tubes which are identified in each heat exchanger.
p.  
Copies of the documents that verify the structural integrity of the heat  
exchanger (e.g., eddy current summary sheets, ultrasonic testing results, and  
visual inspection results).  
q.  
Copies of those documents that describe the methods taken to control water  
chemistry in the heat exchangers.  
2.  
For the review of the performance testing of the safety-related service water system  
(or equivalent) and the UHS:  
a.  
Copies of the last two performance tests, such as the American Society of  
Mechanical Engineers in-service test, for the pumps, valves, and, if  


        TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST
TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST  
                    applicable, the towers fans in the safety-related service water system. If the
2
                    components are not performance tested, please provide documentation
applicable, the towers fans in the safety-related service water system. If the  
                    verifying performance by the methods actually used.
components are not performance tested, please provide documentation  
            b.     Copies of the documents that demonstrate that flow balance testing was
verifying performance by the methods actually used.  
                    performed during the last 3 years. If the last flow test was performed longer
b.  
                    than 3 years, then provide the last flow test.
Copies of the documents that demonstrate that flow balance testing was  
            c. Copies of the documents that demonstrate that flow balance testing will continue
performed during the last 3 years. If the last flow test was performed longer  
                to be periodically done in the future.
than 3 years, then provide the last flow test.  
            d.     Copies of procedures used to monitor interface valves between the safety
c. Copies of the documents that demonstrate that flow balance testing will continue  
                    related section of the service water system, and the non-safety related
to be periodically done in the future.  
                    section, and the associated results. The requested documents are to be for
d.  
                    the time period from the onsite inspection period back to the documents that
Copies of procedures used to monitor interface valves between the safety  
                    were provided in response to the previous Heat Sink Performance Inspection.
related section of the service water system, and the non-safety related  
            e.     Copies of the procedures that verify the performance of risk significant non-
section, and the associated results. The requested documents are to be for  
                    safety functions, and the associated results. The requested documents are
the time period from the onsite inspection period back to the documents that  
                    to be for the time period from the onsite inspection period back to the
were provided in response to the previous Heat Sink Performance Inspection.  
                    documents that were provided in response to the previous Heat Sink
e.  
                    Performance Inspection.
Copies of the procedures that verify the performance of risk significant non-
    3.     For the review associated with the system walkdown of the service water system.
safety functions, and the associated results. The requested documents are  
            a.     Copies of the Testing, Inspection, or Monitoring Program Procedures for
to be for the time period from the onsite inspection period back to the  
                    buried or inaccessible piping, and the associated results. The requested
documents that were provided in response to the previous Heat Sink  
                    documents are to be for the time period from the onsite inspection period
Performance Inspection.  
                    back to the documents that were provided in response to the previous Heat
3.  
                    Sink Performance Inspection.
For the review associated with the system walkdown of the service water system.  
            b.     Copies of the ultrasonic test results and/or visual inspections that verify the
a.  
                    structural integrity of the piping.
Copies of the Testing, Inspection, or Monitoring Program Procedures for  
            c.     Copies of the procedures to monitor, assess, and disposition active thru wall
buried or inaccessible piping, and the associated results. The requested  
                    pipe leaks, including structural evaluations and/or planned corrective actions.
documents are to be for the time period from the onsite inspection period  
            d.     History of any through wall pipe leak on the system. The requested
back to the documents that were provided in response to the previous Heat  
                    documents are to be for the time period from the onsite inspection period
Sink Performance Inspection.  
                    back to the documents that were provided in response to the previous Heat
b.  
                    Sink Performance Inspection.
Copies of the ultrasonic test results and/or visual inspections that verify the  
            e.     Copies of the documents associated with the Periodic Inspection Program
structural integrity of the piping.  
                    used to detect protective coating failure, corrosion, and erosion.
c.  
            f.     Copies of the Inservice Test vibration monitoring results and operational
Copies of the procedures to monitor, assess, and disposition active thru wall  
                    history for deep draft vertical pumps, if applicable. The requested documents
pipe leaks, including structural evaluations and/or planned corrective actions.  
                    are to be for the time period from the onsite inspection period back to the
d.  
                    documents that were provided in response to the previous heat sink
History of any through wall pipe leak on the system. The requested  
                    performance inspection.
documents are to be for the time period from the onsite inspection period  
If the information requested above will not be available, please contact Michael Jones as soon
back to the documents that were provided in response to the previous Heat  
Sink Performance Inspection.  
e.  
Copies of the documents associated with the Periodic Inspection Program  
used to detect protective coating failure, corrosion, and erosion.  
f.  
Copies of the Inservice Test vibration monitoring results and operational  
history for deep draft vertical pumps, if applicable. The requested documents  
are to be for the time period from the onsite inspection period back to the  
documents that were provided in response to the previous heat sink  
performance inspection.  
If the information requested above will not be available, please contact Michael Jones as soon  
as possible at (630) 829-9745, or e-mail Michael.Jones@nrc.gov.
as possible at (630) 829-9745, or e-mail Michael.Jones@nrc.gov.
                                                    2


B. Hanson                                                                 -2-
The lead inspector for this inspection is Michael Jones. We understand that our regulatory contact for this
inspection is Tom Peterson of your organization. If there are questions about the material requested, or
B. Hanson  
the inspection, please call Mr. Jones at (630) 829-9745. Please send the information to the following e-
-2-  
mail address Michael.Jones@nrc.gov. A hard-copy with the required information is also an acceptable
The lead inspector for this inspection is Michael Jones. We understand that our regulatory contact for this  
option.
inspection is Tom Peterson of your organization. If there are questions about the material requested, or  
This letter does not contain new or amended information collection requirements subject
the inspection, please call Mr. Jones at (630) 829-9745. Please send the information to the following e-
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection
mail address Michael.Jones@nrc.gov. A hard-copy with the required information is also an acceptable  
requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The
option.  
NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or
This letter does not contain new or amended information collection requirements subject
an information collection requirement unless the requesting document displays a currently valid Office of
to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection  
Management and Budget Control Number.
requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The  
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections,
NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or  
Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its
an information collection requirement unless the requesting document displays a currently valid Office of  
enclosure, and your response (if any) will be available electronically for public inspection in the NRCs
Management and Budget Control Number.  
Public Document Room or from the Publicly Available Records (PARS) component of the NRC's
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections,  
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the
Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its  
NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
enclosure, and your response (if any) will be available electronically for public inspection in the NRCs  
                                                                          Sincerely,
Public Document Room or from the Publicly Available Records (PARS) component of the NRC's  
                                                                          /RA Benny Jose Acting for/
Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the  
                                                                          Christine A. Lipa, Chief
NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).  
                                                                          Engineering Branch 2
Sincerely,  
                                                                          Division of Reactor Safety
/RA Benny Jose Acting for/  
Docket Nos. 50-254; 50-265
License Nos. DPR-29; DPR-30
Christine A. Lipa, Chief  
Enclosure:
Engineering Branch 2  
   Triennial Heat Sink Performance Inspection
Division of Reactor Safety
   Document Request
Docket Nos. 50-254; 50-265  
                                                         
License Nos. DPR-29; DPR-30  
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Enclosure:  
DISTRIBUTION:
   Triennial Heat Sink Performance Inspection
Kimyata MorganButler
   Document Request  
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DISTRIBUTION:  
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Allan Barker
Cynthia Pederson  
Carole Ariano
Darrell Roberts  
Linda Linn
Richard Skokowski  
DRPIII
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DRSIII
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Jim Clay
Linda Linn  
Carmen Olteanu
DRPIII  
ADAMS Accession Number ML15091A265
DRSIII  
    Publicly Available                           Non-Publicly Available                   Sensitive               Non-Sensitive
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To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
Carmen Olteanu  
OFFICE             RIII                                 RIII                           RIII                               RIII
  NAME               MJones:cl                           BJose for CLipa
ADAMS Accession Number ML15091A265  
  DATE               03/30/15                             03/30/15
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OFFICE  
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}}
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Latest revision as of 13:34, 10 January 2025

Notification of an NRC Triennial Heat Sink Performance Inspection and Request for Information Inspection Report 05000254/2015002; 05000265/2015002
ML15091A265
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 03/30/2015
From: Christine Lipa
NRC/RGN-III/DRS/EB2
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2015002
Download: ML15091A265 (8)


See also: IR 05000254/2015002

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION III

2443 WARRENVILLE RD. SUITE 210

LISLE, IL 60532-4352

March 30, 2015

Mr. Bryan C. Hanson

Senior VP, Exelon Generation Company, LLC

President and CNO, Exelon Nuclear

4300 Winfield Road

SUBJECT: QUAD CITIES NUCLEAR POWER STATION-NOTIFICATION OF AN NRC

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION AND REQUEST FOR

INFORMATION INSPECTION REPORT 05000254/2015002; 05000265/2015002

Dear Mr. Hanson:

On May 18, 2015, the U.S. Nuclear Regulatory Commission (NRC) will begin the onsite portion

of the Triennial Heat Sink Performance Inspection at your Quad Cities Nuclear Power Station.

This inspection will be performed in accordance with NRC Baseline Inspection Procedure (IP)

71111.07.

In order to minimize the impact that the inspection has on the site, and to ensure a productive

inspection, we have enclosed a request for documents needed for the inspection. The

documents have been divided into three groups.

The first group lists information necessary for our initial inspection scoping activities. This

information should be available to the lead inspector no later than April 20, 2015. By

April 27, 2015, the inspector will communicate the initial selected set of approximately

2-3 risk-significant heat exchangers.

The second group is needed to support our in-office preparation activities. This set of

documents, including the calculations associated with the selected heat exchangers, should

be available at the Regional Office no later than May 4, 2015. This information should be

separated for each selected component, especially if provided electronically (e.g., folder with

component name that includes calculations, condition reports, maintenance history, etc.).

During the in-office preparation activities, the inspector may identify additional information

needed to support the inspection.

The last group includes the additional information above, as well as plant-specific reference

material. This information should be available onsite to the inspector on May 18, 2015. It is

also requested that corrective action documents and/or questions developed during the

inspection be provided to the inspector as the documents are generated.

All requested documents are to be for the time period from the onsite inspection period back to

the documents that were provided in response to the previous Heat Sink Performance

Inspection. If no activities were accomplished in that time period, then the request applies to the

last applicable document in the previous time period. It is important that these documents be as

complete as possible, in order to minimize the number of documents requested during the

preparation week or during the onsite inspection.

B. Hanson

-2-

The lead inspector for this inspection is Michael Jones. We understand that our regulatory

contact for this inspection is Tom Peterson of your organization. If there are questions about

the material requested, or the inspection, please call Mr. Jones at (630) 829-9745. Please send

the information to the following e-mail address Michael.Jones@nrc.gov. A hard-copy with the

required information is also an acceptable option.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information

collection requirements were approved by the Office of Management and Budget, Control

Number 3150-0011. The NRC may not conduct or sponsor, and a person is not required to

respond to, a request for information or an information collection requirement unless the

requesting document displays a currently valid Office of Management and Budget Control

Number.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public

Inspections, Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy

of this letter, its enclosure, and your response (if any) will be available electronically for public

inspection in the NRCs Public Document Room or from the Publicly Available Records (PARS)

component of the NRC's Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html

(the Public Electronic Reading Room).

Sincerely,

/RA Benny Jose Acting for/

Christine A. Lipa, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-254; 50-265

License Nos. DPR-29; DPR-30

Enclosure:

Triennial Heat Sink Performance Inspection

Document Request

cc w/encl: Distribution via LISTSERV

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

Enclosure

Inspection Report: 05000254/2015002; 05000265/2015002

Inspection Dates:

May 18-22, 2015

Inspection Procedure:

IP 71111.07T, Heat Sink Performance

Lead Inspector:

Michael A. Jones, Jr.

(630) 829-9745

Michael.Jones@nrc.gov

I.

Information Requested By April 20, 2015:

1.

List of the Generic Letter (GL) 89-13, Service Water System Problems Affecting

Safety-Related Equipment, heat exchangers in order of risk significance.

2.

Copy of heat exchanger performance trending data tracked for each GL 89-13 heat

exchanger.

3.

List of Corrective Action Program (CAP) documents (with a short description)

associated with GL 89-13 heat exchangers, heat sinks, silting, corrosion, fouling, or

heat exchanger testing, for the previous 3 years, or since the last CAP document list

was sent to the NRC for the previous Heat Sink Performance Inspection. The list

should include all CAP documents not on the last CAP document list.

4.

Copy of any self-assessment done on any of GL 89-13 heat exchangers.

5.

Last two System Health Report(s) and maintenance rule system notebooks for all the

GL 89-13 heat exchangers.

6.

List of engineering-related operator workarounds (with a short description)

associated with GL 89-13 heat exchangers. The requested documents are to be for

the time period from the onsite inspection period back to the documents that were

provided in response to the previous heat sink performance inspection.

7.

List of permanent and temporary modifications (with a short description) associated

with GL 89-13 heat exchangers. The requested documents are to be for the time

period from the onsite inspection period back to the documents that were provided in

response to the previous Heat Sink Performance Inspection.

II.

Information Requested By May 4, 2015

1.

Copies of the GL 89-13 responses.

2.

Copy of the Updated Final Safety Analysis Report (UFSAR) section applicable to the

GL 89-13 Heat Exchanger Program.

3.

Copies of procedures developed to implement the recommendations of GL 89-13

(e.g., the GL 89-13 Heat Exchanger Program description).

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

2

4.

Copies of the selected CAP documents.

5.

For the specific heat exchangers selected:

a.

Copies of the UFSAR sections applicable for each heat exchanger.

b.

Copy of system description and design basis document for the heat

exchangers (as applicable).

c.

Provide a list of calculations (with a short description) which currently apply to

each heat exchanger.

i.

establish the limiting design basis heat load required to be removed

by each of these heat exchangers;

ii.

demonstrate the heat exchangers capacity to remove the limiting heat

load;

iii.

correlate surveillance testing and/or inspection results from these heat

exchangers with design basis heat removal capability (e.g., basis for

surveillance test and/or inspection acceptance criteria);

iv.

evaluate the potential for water hammer in each heat exchanger or

associated piping; and

v.

evaluate excessive tube vibration in each heat exchanger.

d.

Copy of any operability determinations or other documentation of degradation

associated with the heat exchangers or the systems that support the

operation for the selected heat exchangers.

e.

Copy of the construction code, Design Specification, heat exchanger data

sheets, and vendor documents including component drawings applicable for

the heat exchangers.

f.

Copies of normal, abnormal, and emergency operating procedures

associated with the selected heat exchangers.

6.

For the ultimate heat sink (UHS) and the safety-related service water system (or

equivalent):

a.

Copies of the applicable UFSAR sections.

b.

Copy of system description and design basis document (as applicable).

c.

Copy of any operability determinations or other documentation of degradation

associated with the UHS, and the safety-related service water system.

d.

Copy of the document (e.g., UFSAR or Technical Requirements Manual) that

states the maximum cooling water system inlet temperature limit that still

allows full licensed power operation of the nuclear reactor.

e.

Copy of system description and design basis document (as applicable).

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

3

f.

Copy of the construction code and Design Specification.

g.

Copies of normal, abnormal, and emergency operating procedures

associated with the UHS and safety-related service water systems including

procedures for loss of these systems.

h.

Copy of any operability determinations or other documentation of degradation

associated with the UHS, and the safety-related service water system.

i.

Copies of corrective action documents associated with water hammer or

hydraulic transients in the service water system since the last Heat Sink

Performance Inspection.

j.

If available, provide an electronic copy of piping and instrumentation

diagrams (P&IDs) for the service water system, including the intake structure.

k.

Provide a list of calculations (with a short description), which currently apply

to UHS, and service water system.

l.

Provide a list of instruments (with a short description) associated with

automatic or alarm functions for the safety-related service water system

and/or UHS.

m.

Provide a list of any design change (with a short description) performed on

the UHS or safety-related service water system since the last heat sink

performance inspection.

7.

A schedule of all inspections, cleanings, maintenance, or testing of any

safety-related plant heat exchanger to be performed during the on-site portion of the

inspection.

III.

Information Requested to be Available on First Day of Inspection, May 18, 2015

1.

For the specific heat exchangers selected:

a.

Copy of the calculation which correlates surveillance testing results from

these heat exchangers with design basis heat removal capability (e.g., basis

for surveillance test acceptance criteria).

b.

Copies of the two most recent completed tests and evaluation data

confirming thermal performance for those heat exchangers which are

performance tested.

c.

Documentation and procedures that identify the types, accuracy, and location

of any special instrumentation used for the two most recently completed

thermal performance tests for the heat exchangers (e.g., high accuracy

ultrasonic flow instruments or temperature instruments). Include calibration

records for the instruments used during these tests.

d.

Information regarding any alarms which monitor on-line performance.

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

4

e.

Copy of the document describing the inspection results of each heat

exchanger. The requested documents are to be for the time period from the

onsite inspection period back to the documents that were provided in

response to the previous Heat Sink Performance Inspection.

f.

The cleaning and inspection maintenance schedule for each heat exchanger

for the next 5 years.

g.

Copy of the design specification and heat exchanger data sheets for each

heat exchanger.

h.

Copy of the vendor manuals including component drawings for each heat

exchanger.

i.

Copy of the calculation which establishes the limiting (maximum) design

basis heat load which is required to be removed by each of these heat

exchangers.

j.

Copy of the operating procedure that ensures that the maximum cooling

water system inlet temperature limit is not exceeded.

k.

Copy of the calculations or documents which evaluate the potential for water

hammer in each heat exchanger or associated piping.

l.

Copy of the calculations that evaluate excessive tube vibration in each heat

exchanger and the documents that describe the controls that prevent heat

exchanger degradation due to excessive flow induced vibration during

operation.

m.

Copy of the periodic flow testing at or near maximum design flow. The

requested documents are to be for the time period from the onsite inspection

period back to the documents that were provided in response to the previous

Heat Sink Performance Inspection.

n.

Copy of the document which identifies the current number of tubes in service

for each heat exchanger and the supporting calculation which establishes the

maximum number of tubes which can be plugged in each heat exchanger.

o.

Copy of the document establishing the repair criteria (plugging limit) for

degraded tubes which are identified in each heat exchanger.

p.

Copies of the documents that verify the structural integrity of the heat

exchanger (e.g., eddy current summary sheets, ultrasonic testing results, and

visual inspection results).

q.

Copies of those documents that describe the methods taken to control water

chemistry in the heat exchangers.

2.

For the review of the performance testing of the safety-related service water system

(or equivalent) and the UHS:

a.

Copies of the last two performance tests, such as the American Society of

Mechanical Engineers in-service test, for the pumps, valves, and, if

TRIENNIAL HEAT SINK PERFORMANCE INSPECTION DOCUMENT REQUEST

2

applicable, the towers fans in the safety-related service water system. If the

components are not performance tested, please provide documentation

verifying performance by the methods actually used.

b.

Copies of the documents that demonstrate that flow balance testing was

performed during the last 3 years. If the last flow test was performed longer

than 3 years, then provide the last flow test.

c. Copies of the documents that demonstrate that flow balance testing will continue

to be periodically done in the future.

d.

Copies of procedures used to monitor interface valves between the safety

related section of the service water system, and the non-safety related

section, and the associated results. The requested documents are to be for

the time period from the onsite inspection period back to the documents that

were provided in response to the previous Heat Sink Performance Inspection.

e.

Copies of the procedures that verify the performance of risk significant non-

safety functions, and the associated results. The requested documents are

to be for the time period from the onsite inspection period back to the

documents that were provided in response to the previous Heat Sink

Performance Inspection.

3.

For the review associated with the system walkdown of the service water system.

a.

Copies of the Testing, Inspection, or Monitoring Program Procedures for

buried or inaccessible piping, and the associated results. The requested

documents are to be for the time period from the onsite inspection period

back to the documents that were provided in response to the previous Heat

Sink Performance Inspection.

b.

Copies of the ultrasonic test results and/or visual inspections that verify the

structural integrity of the piping.

c.

Copies of the procedures to monitor, assess, and disposition active thru wall

pipe leaks, including structural evaluations and/or planned corrective actions.

d.

History of any through wall pipe leak on the system. The requested

documents are to be for the time period from the onsite inspection period

back to the documents that were provided in response to the previous Heat

Sink Performance Inspection.

e.

Copies of the documents associated with the Periodic Inspection Program

used to detect protective coating failure, corrosion, and erosion.

f.

Copies of the Inservice Test vibration monitoring results and operational

history for deep draft vertical pumps, if applicable. The requested documents

are to be for the time period from the onsite inspection period back to the

documents that were provided in response to the previous heat sink

performance inspection.

If the information requested above will not be available, please contact Michael Jones as soon

as possible at (630) 829-9745, or e-mail Michael.Jones@nrc.gov.

B. Hanson

-2-

The lead inspector for this inspection is Michael Jones. We understand that our regulatory contact for this

inspection is Tom Peterson of your organization. If there are questions about the material requested, or

the inspection, please call Mr. Jones at (630) 829-9745. Please send the information to the following e-

mail address Michael.Jones@nrc.gov. A hard-copy with the required information is also an acceptable

option.

This letter does not contain new or amended information collection requirements subject

to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et seq.). Existing information collection

requirements were approved by the Office of Management and Budget, Control Number 3150-0011. The

NRC may not conduct or sponsor, and a person is not required to respond to, a request for information or

an information collection requirement unless the requesting document displays a currently valid Office of

Management and Budget Control Number.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390, Public Inspections,

Exemptions, Requests for Withholding, of the NRC's "Rules of Practice," a copy of this letter, its

enclosure, and your response (if any) will be available electronically for public inspection in the NRCs

Public Document Room or from the Publicly Available Records (PARS) component of the NRC's

Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the

NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA Benny Jose Acting for/

Christine A. Lipa, Chief

Engineering Branch 2

Division of Reactor Safety

Docket Nos. 50-254; 50-265

License Nos. DPR-29; DPR-30

Enclosure:

Triennial Heat Sink Performance Inspection

Document Request

cc w/encl: Distribution via LISTSERV

DISTRIBUTION:

Kimyata MorganButler

RidsNrrDorlLpl3-2 Resource

RidsNrrPMQuadCities Resource

RidsNrrDirsIrib Resource

Cynthia Pederson

Darrell Roberts

Richard Skokowski

Allan Barker

Carole Ariano

Linda Linn

DRPIII

DRSIII

Jim Clay

Carmen Olteanu

ADAMS Accession Number ML15091A265

Publicly Available

Non-Publicly Available

Sensitive

Non-Sensitive

To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy

OFFICE

RIII

RIII

RIII

RIII

NAME

MJones:cl

BJose for CLipa

DATE

03/30/15

03/30/15

OFFICIAL RECORD COPY