Text

IR 05000254-12-010, 05000265-12-010; 10/22/12 - 11/09/12; Quad Cities Nuclear Power Station, Units 1 and 2; Post Approval Site Inspection for License Renewal
	ML12356A431
Person / Time
Site:	Quad Cities
Issue date:	12/21/2012
From:	Stone A M; NRC/RGN-III/DRS/EB2
To:	Pacilio M J; Exelon Generation Co, Exelon Nuclear
	Benny Jose
References
	IR-12-010
	Download: ML12356A431 (43)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION REGION III 2443 WARRENVILLE ROAD, SUITE 210 LISLE, IL 60532

-4352 December 21, 2012 Mr. Michael Senior Vice President, Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO), Exelon Nuclear 4300 Winfield Road Warrenville , IL 60555

SUBJECT: QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 NRC POST-APPROVAL SITE INSPECTION FOR LICENSE RENEWAL REPORT 050002 54/201 2 0 10; 05000265/2012010

Dear Mr. Pacilio:

On November 9, 201 2 , the U.S. Nuclear Regulatory Commission (NRC) completed Post-Approval Site Inspection for License Renewal at your Quad Cities Nuclear Power Station, Unit s 1 and 2. The enclosed report documents the results of this inspection, which were discussed on November 9, 201 2 , with Mr. T. Hanley, and other members of your staff.

The inspection examined activities conducted under your license as they relate to safety and compliance with the Commission's rules and regulations and with the conditions of your license. The inspectors reviewed selected procedures and records, and interviewed personnel.

Based on the results of this inspection, there were no findings of significance identified

. In accordance with 10 CFR 2.390 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 NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's document system (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading

-rm/adams.html (the Public Electronic Reading Room).

Sincerely,/RA/

Ann Marie Stone, Chie f Engineering Branch 2 Division of Reactor Safety Docket Nos.

50-254; 50-265 License Nos. DPR

-29; DPR 30

Enclosure:

Inspection Report 05000 254/2012010; 05000265/201210

w/Attachment:

Supplemental Information cc w/encl:

Distribution via ListServŽ

Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket Nos:

50-254; 50-265 License Nos: DPR-29, DPR-30 Report No:

05000254/20 12010; 05000265/20 12010 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: Cordova, IL Dates: October 22, 201 2 - November 9, 201 2 Inspectors:

B. Jose, Senior Reactor Engineer (Lead)

N. Féliz Adorno

, Reactor Engineer G. O'Dwyer, Reactor Engineer J. Bozga, Reactor Engineer E. Sanchez, Reactor Engineer J. Corujo, Reactor Engineer J. Gilliam, Reactor Engineer D. Betancourt, Reactor Engineer Approved by:

A. M. Stone, Chief Engineering Branch 2 Division of Reactor Safety 1 Enclosure

SUMMARY OF FINDINGS

IR 05000254/2012010, 05000265/2012010; 10/22/12

- 11/09/12; Quad Cities Nuclear Power Station, Units 1 and 2; Post Approval Site Inspection for License Renewal

. The report covers a team inspection conducted by region-based engineering inspectors. The inspectors concluded that items, license conditions, and regulatory requirements associated with the issuance of the renewed operating license were being met. The NRC's program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

A.

Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity

N RC-Identified and Self-Revealed Findings No findings of significance were identified.

B. No violations of significance were identified.

=

Licensee-Identified Violations===

4. OTHER ACTIVITIES

REPORT DETAILS

4OA5

.1 Other Activities

The purpose of this inspection is to verify committed actions and license conditions associated with the renewed license for Unit s 1 and 2 are implemented in accordance with 10 CFR Part 54.

Post-Approval Site Inspection for License Renewal (Phase II) - IP 71003 a. (1) Inspection Scope The inspectors discussed the identification of new SSCs, under the purview of title 10 of the code of federal regulations (CFR) 54.37(b), with the licensee's license renewal staff.

The licensee personnel indicated newly identified components had resulted from a change to the Environmental Qualification (EQ) Program. The components were subsequently added to the site EQ Program , which is also credited as the license renewal (LR) Aging Management Program (AMP) B1.35. T he AMP will manage the effects of aging for those newly identified components.

Review of Newly Identified SSCs

[Systems Structures and Components]

The license renewal Updated Final Safety Analysis Report (UFSAR) Supplement, Appendix A.1.35, "Environmental Qualification (EQ) of electrical components," remains an accurate summary of the AMP, and does not require revision as a result of the newly identified components.

(2) As part of reviewing the Aging Management Programs (AMPs) associated with the Commitment Items, the inspectors reviewed the UFSAR descriptions to confirm the implemented programs were consistent with the UFSAR descriptions

. Review of Updated Final Safety Analysis Report and Commitment Item Change Process The inspectors reviewed the licensee's procedures to ensure that Commitment Item revisions would follow the guidance in NEI 99

-04, "Guidelines for Managing NRC Commitment Item Changes," including the elimination of commitment, and would properly evaluate, report, and approve changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59. The inspectors also reviewed the licensee's Commitment Item tracking program to evaluate its effectiveness.

With respect to implementation, the inspectors reviewed changes associated with each commitment. One Unresolved Item (URI) was identified and is documented in Section 4OA5.1.b (1). (3) The inspectors reviewed supporting documents including completed surveillance records, conducted interviews, performed visual inspection of structures and components to veri fy the licensee completed the necessary actions to comply with the license conditions that are a part of the renewed operating license. The inspectors verified the licensee implemented the Aging Management Programs and time

-limited Review of Commitment Item s

3 Enclosure aging analyses (TLAA) included in NUREG

-1796, "Safety Evaluation Report (SER) Related to the License Renewal of Dresden Nuclear Power Station Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2 ," in accordance with Title 10 of the Code of Federal Regulations (CFR) Part 54, "Requirements for the Renewal of Operating Licenses for Nuclear Power Plants." The inspectors verified a selected sample of corrective actions taken to address issues identified during the Dresden Unit s 2 and 3 license renewal inspection s , which w as documented in Inspection Report s 05000237/2009007 and 05000249/2010010 , and were also applicable to Quad Cities Units 1 and 2

. When changes to these items were identified, the inspectors reviewed the Commitment Item Change Evaluation Form (CCEF) to verify the licensee followed the guidance in NEI 99-04 for the license renewal Commitment Item change process, including the elimination of commitments, and properly evaluated, reported, and approved where necessary, changes to license renewal commitments listed in the UFSAR in accordance with 10 CFR 50.59.

The inspectors reviewed the Commitment Items listed below which are referenced to Appendix A of the SER. Specific documents reviewed are listed in the enclosure.

1. Commitment Item 1 specified the existing ASME Section XI, Subsections IWB, IWC, and IWD Aging Management Program

, is part of the Inservice Inspection (ISI) Program. It provides identification of signs of degradation, and establishment of corrective actions for condition monitoring of reactor coolant pressure retaining piping and components within the scope of license renewal.

The inspections will be implemented in accordance with 10 CFR 50.55(a). Also Quad Cities implemented Risk Informed Inservice Inspection and the alternative Risk Informed Inservice Inspection programs for Class 1 and 2 piping.

Commitment Item 1, ASME [American Society of Mechanical Engineers] Code,Section XI Inservice Inspection, Subsections IWB, IWC, and IWD The inspectors reviewed the licensing basis, program basis documents, implementing procedures, non

-destructive examination (NDE) records, and related condition reports; and interviewed the responsible plant personnel regarding these documents. The inspectors verified the licensee incorporated the Risk Informed ISI Program for Class 1 and 2 Systems.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 1. 2. Commitment Item 2 specified the existing water chemistry program was credited for license renewal for both Units 1 and 2 and that the program was enhanced prior to the period of extended operation

. Commitment Item 2, Water Chemistry The inspectors reviewed changes and enhancements to the program and ensured the program remained effective for both units

. The inspectors verified procedure CY-QC-110-608, Reactor/Turbine Building Sample Panel Sample Collection, Revision 21 was revised to ensure the integrity of the samples collected.

The inspectors reviewed the licensing basis, program basis document s, planned and completed work orders, Commitment Item changes, Issue Reports, inspection 4 Enclosure procedures and interviewed the plant personnel responsible for the program.

Planned and completed chemistry surveillance tests and related Issue Reports demonstrated the water chemistry program was appropriately applied to Unit s 1 and 2. Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 2 for Units 1 and 2.

3. Commitment Item 3 specified the existing Reactor Head Closure Studs Aging Management Program was credited. The program is implemented through station procedures, ISI program plan for Quad Cities, and corporate procedures for inservice inspection of welds and components. The program implements inspection requirements of ASME Section XI and preventive measures described in Regulatory Guide 1.65, "Materials and Inspection for Reactor Vessel Closure Studs

." The reactor head studs at Quad Cities are not metal plated and have had manganese phosphate coatings applied.

Commitment Item 3, Reactor Head Closure Studs The inspectors interviewed the plant personnel responsible for the program and reviewed the program bas is documents, implementing procedures, work orders, and related IRs to verify the program was being implemented on Unit s 1 and 2. Based on review of the licensee actions, the inspectors determined the licensee met Commitment Item 3. 4. Commitment Item 4 specified the existing BWR Vessel Attachment Welds Aging Management Program activities incorporated the inspection and evaluation recommendations of BWRVIP

-48, 'Vessel ID Attachment Weld Inspection and Evaluation Guidelines," as well as the water chemistry recommendations of EPRI TR-103515-R2, "BWR Water Chemistry Guidelines." The program is implemented through station procedures that provide for mitigation of cracking through water chemistry and monitoring for cracking through in vessel examinations.

Commitment Item 4, BWR [Boiling Water Reactor] Vessel ID [Internal Diameter] Attachment Welds The inspectors reviewed the licensing basis, program basis documents, implementing procedures, NDE examination records, and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented on Unit s 1 and 2. Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 4. 5. Commitment Items 5 specified the existing BWR Feedwater Nozzle program was credited for license renewal and would be enhanced prior to the period of extended operation. This program implemented inservice inspection specified in ASME Code,Section XI and enhanced it with recommendations from General Electric NE A71-0594-A, Revision 1 "Alternate BWR Feedwater Nozzle Inspection Requirements

." Per their enhancements

, the licensee will perform periodic ultrasonic testing inspection of certain critical regions of the BWR feedwater nozzles. Commitment Item 5, BWR Feedwater Nozzle

5 Enclosure The inspectors reviewed the licensing basis, program basis documents, implementing procedures, NDE examination records, related condition reports, and interviewed the responsible plant personnel. The inspectors verified the licensee implement ed the recommendations of report GE

-NE-523-A71-0594-A, Revision 1, which was approved by the NRC staff.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 5. 6. Commitment Item 6 specified the existing BWR Control Rod Drive Return Line Nozzle inspection program was credited for license renewal. This program implemented inservice inspection in accordance with ASME Code Section XI. The licensee cut and capped the CRD return line nozzle. As a result, the augmented inspections described in NUREG

-0619 "BWR Feedwater Nozzle and Control Rod Drive Return Line Nozzle Cracking" or GE NE A71-0594, "Alternative BWR Feedwater Nozzle Inspection Requirements" are not required.

Commitment Item 6, Control Rod Drive (CRD) Return Line Nozzle The inspectors reviewed the licensing basis, program basis documents, implementing procedures, NDE examination records, related condition reports, and interviewed the plant personnel regarding these documents.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 6. 7. Commitment Item 7 specified the existing BWR SCC Program was credited for license renewal. The BWR SCC Program is credited for managing the aging effects of crack initiation and growth, loss of fracture toughness, and loss of material in susceptible components. The program was also enhanced to include an additional ultrasonic examination of the Quad Cities Unit 2 reactor vessel head crack (detected in 1990) to verify the relevant indication has remained essentially unchanged.

Commitment Item 7, BWR Stress Corrosion Cracking (SCC)

The inspectors reviewed the licensing basis, program basis document s , implementing procedures, weld examination records, and related IRs; and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 7. 8. Commitment Item 8 specified the existing BWR reactor vessel penetration inspection program was credited for license renewal. The license renewal program applies only to the Standby Liquid Control/Core Plate DP penetrations and Instrument penetrations N11A/B and N12A/B. This program implemented inspection and flaw evaluation in conformance with BWRVIP

-27 and BWRVIP

-49. Commitment Item 8, BWR Penetrations The inspectors reviewed the program basis documents, procedures, and NDE examination records to verify the program was adequately implemented.

6 Enclosure Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 8. 9. Commitment Item 9 specified the existing BWR Vessel Internals Program (VIP) would be credited for license renewal and enhanced with inspections consistent with BWRVIP-48. The BWR Vessel internals Aging Management Program mitigates the effect of stress corrosion cracking, intergranular stress corrosion cracking (IGSCC), and irradiation assisted stress corrosion cracking in reactor pressure vessels internals through water chemistry activities that are implemented through station procedures and are consistent with the guidelines of year 2000 revision of EPRI TR-103515-R2, BWR Water Chemistry Guidelines. The program also manages cracking of reactor pressure vessel internals through condition monitoring activities that consist of examinations and the BWRVIP guidelines, as well as the requirements of ASME Section XI.

Commitment Item 9, BWR Vessel Internals The inspectors reviewed the licensing basis, program basis documents, implementing procedures, NDE examination records; and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 9. 10. Commitment Item 10 specified a new Aging Management Program for thermal aging and neutron irradiation embrittlement of CASS reactor internal components within the scope of license renewal, to ensure the integrity of the CASS components exposed to high temperature and neutron fluence present in the reactor environment. This program includes a component specific evaluation of the loss of fracture toughness. For those components

, where the loss of fracture toughness may affect function of the component, an enhanced VT

-1 inspection will be conducted. These inspections will be in accordance with BWRVIP

-03, and will be performed as part of the ISI program.

Commitment Item 10, Thermal Aging and Neutron Irradiation Embrittlement of Cast Austenitic Stainless Steel (CASS)

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, completed inspections and interviewed the plant personnel responsible for the program regarding these documents to verify the program is being implemented.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 10. 11. Commitment Item 11 specified the existing FAC Program was credited for license renewal with enhancements to include portions of the main steam and the reactor vessel head vent systems prior to the period of extended operation. The site's FAC program is based on EPRI guidelines found in NSAC

-202L-R3, "Recommendations for an Effective Flow Accelerated Corrosion Program."

The program is credited for Commitment Item 11, Flow Accelerated Corrosion (FAC)

7 Enclosure predicting, detecting, and monitoring for loss of material by wall thinning in piping, fittings, and valve bodies due to FAC.

The inspectors reviewed the licensing basis, program basis document s , implementing procedures, pipe examination records and related IRs and interviewed the responsible plant personnel regarding these documents.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 11. 12. Commitment Item 12 specified the existing bolting integrity program was credited for license renewal and that the program would be enhanced prior to the period of extended operation. The Bolting Integrity Program is an existing program that consist s of the preventive and condition monitoring of pressure retaining bolted joints o f piping and components for age

-related degradation to discover and correct conditions that could lead to a loss of intended function.

Commitment Item 12, Bolting Integrity The inspectors reviewed the licensing basis, the Bolting Integrity Program basis documentation, implementing procedures, planned and completed work orders, related corrective action documents, and interviewed responsible program personnel regarding these documents.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 12. 13. Commitment Item 13 specified the existing program was credited for license renewal and had been enhanced, prior to the period of extended operation, to include periodic inspections of cooling water pump internal linings, additional heat exchangers and sub

-components, external surfaces of various submerged pumps, components in the high humidity/moisture environments of the pump vaults, and piping. Commitment Item 13, Open-Cycle Cooling Water Program The inspectors reviewed changes and enhancements to the program and ensured that the program remained effective for both units

. The inspectors reviewed the licensing basis, program basis document s, planned and completed work orders, Commitment Item changes, Issue Reports, inspection procedures and interviewed the plant personnel responsible for the program to verify the program w as being implemented

. General program requirements for this commitment were inspected and determined to be complete for Quad Cities Unit s 1 and 2. Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 13 for Units 1 and 2.

14. Commitment Item 14 specified the existing closed

-cycle cooling water chemistry program was enhanced and credited for license renewal for both Units 1 and 2.

Commitment Item 14, Closed

-Cycle Cooling Water Chemistry The inspectors reviewed the licensing basis, program basis document s, planned and completed work orders, Issue Reports, inspection procedures and interviewed 8 Enclosure plant personnel responsible for the program to verify the program w as being implemented

. General program requirements for this commitment were inspected and determined to be complete for Quad Cities Unit 1 and 2.

The licensee changed this commitment Item to use the guidance from the latest Electric Power Research Institute (EPRI) guidance document, EPRI TR 1007820, "Closed Cooling Water Chemistry Guideline," Revision 1 instead of a previous EPRI Guidance procedure. The inspectors noted Revision 2 of the GALL endorsed the latest EPRI guidance document, EPRI TR 1007820. The inspectors verified this commitment change was appropriate.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 14. 15. Commitment Item 15 specified the existing inspection of overhead heavy load and light load (related to refueling) handling systems program was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

Commitment Item 15, Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems The inspectors reviewed the licensing basis, the program basis documentation, implementing procedures, completed work orders, related corrective action documents and interviewed personnel responsible for the program regarding these documents.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 15. 16. Commitment Item 16 specified the existing compressed air monitoring program was credited for license renewal and that the program would be enhanced prior to the period of extended operation

. Commitment Item 16, Compressed Air Monitoring The inspectors reviewed the licensing basis, program basis document s, planned and completed work orders, Issue Reports, inspection procedures and interviewed the plant personnel responsible for the program to verify the program w as being implemented

. General program requirements for this commitment were inspected and determined to be complete for Quad Cities Unit 1 and 2.

Based on review of the timeliness and adequacy of the licensee's actions the inspectors determined the licensee met Commitment Item 16. 17. Commitment Item 17 specifie d the existing program was credited for license renewal and was consistent with NUREG

-1801 "Generic Aging Lessons Learned (GALL)." Commitment Item 17, BWR Reactor Water Cleanup (RWCU) System The inspectors reviewed the licensing basis, program basis document s, and work orders. The licensee has replaced all in

-scope portions of the RWCU system piping with IGSCC resistant piping. The RWCU portions that are inboard of the second 9 Enclosure isolation valve are being managed by the ISI program. The inspectors reviewed selected samples to confirm the ISI program was being utilized for the sections of the RWCU previously mentioned

. Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 17. 18. Commitment Item 18 specified the licensee would enhance the existing fire protection program as follows:

Commitment Item 18, Fire Protection (non-water) Provide specific guidance to check fire doors for wear and holes in skin that could affect intended function during weekly tours as well as check the fire door clearances.

Inspect external surfaces of the carbon dioxide system.

Perform a visual inspection (VT

-1 or equivalent) on a 10 percent sample population of each type of fire seal on a refueling outage frequency. Expand the sample population by 10 percent if any of the inspected seals are found to have abnormal degradation that could prevent the seal from performing its intended function. The inspectors reviewed the licensing basis, program basis document s, and existing implementing procedures. The inspectors verified the above

enhancements were incorporated into the existing program documents and implementing procedures. The inspectors also reviewed the completed inspections and training requirements.

Based on the review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 18. 19. Commitment Item 19 specified the existing fire water system program was credited for license renewal and that the program would include several enhancements prior to the period of extended operation

. Commitment Item 19, Fire Water System The inspectors reviewed the licensing basis, the program basis documentation, implementing procedures, completed work orders and related corrective action documents.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 19. 20. Commitment Item 20 specified the existing above

-ground carbon steel tanks program was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

The enhancements included periodic system engineer walkdowns on the nitrogen storage tanks utilizing a standalone procedure and a one

-time UT thickness inspection will be performed o n the aluminum condensate storage tank or demineralized water storage tank

.Commitment Item 20, Above-ground Carbon Steel Tanks

10 Enclosure The inspectors reviewed the licensing basis, program basis document s , implementing procedures, scheduled, and completed work orders, related action requests, engineering changes, and evaluations. The inspectors verified the licensee has implemented procedure changes to address the documentation of inspection results by system engineers. In addition, the inspectors verified the licensee has implemented procedures to address internal/external inspections as well as committed UT inspections.

During this review, the inspectors identified the 'B' Contaminated Condensate Storage Tank (CCST) inspection performed in 2007 time frame did not include NDE. Specifically, the license renewal commitment specified NDE would be performed once before the period of extended operation (PEO) and every five years thereafter. The inspectors noted this omission in 2007 was a failure to follow the requirements of the commitment. However, since th e licensee performed a UT inspection of the 'B' CCST in November 2012 (before the PEO) in accordance with the requirements of the commitment, th is commitment was met. Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 20. 21. Commitment Item 21 specified the existing fuel oil chemistry program was credite d for license renewal and that the program would be enhanced prior to the period of extended operation.

Th e program was to be enhanced to include inspection of the fuel oil tank interiors for corrosion during regularly scheduled tank cleanings.

Commitment Item 21, Fuel Oil Chemistry The inspectors interviewed the program owner, reviewed the licensing basis, program basis document s , scheduled, and completed work orders and implementing procedures. The inspectors verified the licensee has implemented a program that evaluates the material condition and bottom thickness of the fuel oil storage tanks to ensure aging effects are effectively managed.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 21. 22. Commitment Item 22 specified the existing reactor vessel surveillance Aging Management Program was credited for license renewal and that the program would be enhanced prior to the period of extended operation. The program i s implemented through station procedures that conform to the requirements of 10 CFR Part 50, Appendix H, "Reactor Vessel Material Surveillance Program Requirements." Neutron embrittlement is predicted utilizing chemistry tables and Position 1.3 limitations as described in Regulatory Guide 1.99, Revision 2, "Radiation Embrittlement of Reactor Vessel Materials." Commitment Item 22, Reactor Vessel Surveillance The inspectors reviewed the licensing basis, program basis documents, implementing procedures and interviewed the AMP owner regarding these documents. The inspectors verified the licensee incorporated the testing requirements for reactor vessel test capsules have been incorporated into station programs and procedures.

11 Enclosure Based on review and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 22. 23. Commitment Item 23 specified the licensee perform one

-time inspections of selected plant equipment to verify current plant Aging Management Program s were effective in managing the effects of aging prior to the period of extended operation

. Commitment Item 23, One-Time Inspection The licensee had established separate one

-time inspection programs covering the specific commitments listed in the SER. The inspectors reviewed the licensing basis, each program basis document, implementing procedures, inspection results and related I Rs , and interviewed the responsible plant personnel regarding these documents.

The inspectors verified the licensee had documented the results of the one

-time inspections, and with one exception, had followed up appropriately when aging effects were identified. For the one exception, a one

-time inspection of the clean demineralized water check valve 0

-4399-16 was performed and the results showed significant corrosion in the seating surface.

In addition, all internal surfaces revealed moderate corrosion with some material wastage. The valve was replaced and the licensee performed an evaluation to determine if any aging management actions were needed. The site performed additional inspections at other valves belonging to the same sample group and th ose were found in good condition. Based on those results the licensee determined the valve that had been replaced was an outlier and no aging management was needed. However, the licensee did not address the two additional check valves that share d the same environment as the one affected. During the inspection

, the inspectors questioned why these other valves didn't need to be age manage d. The licensee was able to provide additional information that showed based on the replacement history of the other two valves and the physical state of the pressure boundary (the license renewal function) there was reasonable assurance that the components could meet the function for another 20 years. Also, the inspectors determined in some cases the licensee had performed inspections on only one Unit. For eleven cases

, the inspectors could not find a justification for the basis of selecting one Unit as a representative sample of both Units. Specifically, no evaluation was performed to demonstrate the most susceptible environment was selected. During the inspection

, the licensee was able to provide additional information to show the environment in both Units is similar enough that sampling one Unit was representative of both.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 23 with the exception of the URI documented in Section 4OA5.1.b(1)

. 24. Commitment Item 24 specified one

-time visual inspection of a sample of materials susceptible to selective leaching of materials prior to the period of extended operation.Commitment Item 24, Selective Leaching of Materials

12 Enclosure The inspectors reviewed the licensing basis, the Selective Leaching of Materials Program basis documentation, completed work orders, and interviewed personnel responsible for the program regarding these documents and verified the program was appropriately applied to both Units 1 and 2. Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 24 with the exception of the URI documented in Section 4OA5.1.b(1)

. 25. Commitment Item 25 specified an enhancement to complete one

-time inspections prior to the period of extended operation as well as periodic checks on buried carbon steel fuel oil storage tanks. The Buried Piping and Tanks Inspection Program was an existing program that provided preventive and condition monitoring measures to manage loss of material, due to either corrosion of ferrous piping and tanks or aggressive chemical attack of asbestos concrete piping, from external environments for buried piping and tanks.

Commitment Item 25, Buried Piping and Tanks Inspection The inspectors reviewed the licensing basis, the Buried Piping and Tanks Inspection Program basis documentation, implementing procedures, completed work orders, the results of the onetime inspections, related corrective action documents, and interviewed responsible program personnel regarding these documents. The inspectors verified planned and completed work orders and related IRs demonstrated that the program was appropriately applied Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 25. 26. Commitment Item 26 specified the existing ASME Code,Section XI, Subsection IWE program was credited for license renewal and would be enhanced prior to the period of extended operation.

Commitment Item 26, ASME Code,Section XI, Subsection IWE The inspectors reviewed the licensing basis, the program basis documentation, implementing procedures, completed work orders, related corrective action documents and interviewed personnel responsible for the program regarding these documents.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 26. 27. Commitment Item 27 ASME Code Section XI, Subsection IWF Component Support Program specified the existing ASME Code Section XI, Subsection IWF Component Support Program was credited for license renewal with enhancement to include inspection of Code Class MC supports.

Commitment Item 27, ASME Code,Section XI, Subsection IWF The inspectors reviewed the licensing basis, the program basis documentation, implementing procedures, completed work orders, related corrective action documents, and interviewed personnel responsible for the program regarding these documents.

13 Enclosure Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 27. 28. Commitment Item 28 specifie d the existing 10 CFR Part 50; Appendix J Aging Management Program was credited for license renewal. The program provides for aging management of pressure boundary degradation due to loss of material in the primary containment and various systems penetrating primary containment. The program also manages changes in material properties of gaskets, "O" rings, and packing materials for the primary containment pressure boundary access points.

Commitment Item 28, Appendix J of 10 CFR Part 50, The program includes an exception to NUREG 1801 for two

-ply design bellows that cannot be tested to satisfy the requirements of Appendix J. Testing is in accordance with NRC approved alternate test until the bellows are replaced.

The inspectors reviewed the licensing basis, program basis documents, implementing procedures, and interviewed the responsible plant personnel regarding these documents. The inspectors verified the requirements for testing two-ply bellows have been incorporated into station programs and procedures.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 28. 29. Commitment Item 29 specified the existing masonry wall program was credited for license renewal.

Commitment Item 29, Masonry Wall Program The inspectors reviewed the licensing basis, the program basis documentation, implementing procedures, completed work orders, related corrective action documents and interviewed personnel responsible for the program regarding these documen ts. The inspectors performed walkdowns of masonry walls that perform a high energy line break barrier function.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 29. 30. Commitment Item 30 specified the existing structures monitoring program was credited for license renewal and would be enhanced prior to the period of extended operation.

The structures monitoring program was an existing program that provided for aging management of various structures and external surfaces of mechanical components within the scope of license renewal

. Commitment Item 30, Structures Monitoring Program The inspectors reviewed the licensing basis, the program basis documentation, implementing procedures, completed work orders, related corrective action documents and interviewed personnel responsible for the program regarding these documents. The inspectors also walked down several jet impingement shield supports. Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 30.

14 Enclosure 31. Commitment Item 31 specified the existing RG 1.127, "Inspection of Water

-Control Structures Associated with Nuclear Power Plants," program was credited for license renewal and would be enhanced prior to the period of extended operation. This program was part of the Structures Monitoring Program and consisted of procedures that provided for condition monitoring of structural steel elements, concrete, and earthen structures within the scope of license renewal.

Commitment Item 31, Regulatory Guide (RG) 1.127, Inspection of Water

-Control Structures Associated with Nuclear Power Plants The inspectors reviewed the licensing basis, program basis documentation, and revised implementing procedures. The inspectors reviewed completed work orders and associated condition reports

, and interviewed responsible water control structure program personnel.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 31 with the exception of the URI described in section 4OA5.1.b(2). 32. Commitment Item 32 specified enhancements to the Protective Coating Monitoring and Maintenance Program to be implemented prior to the period of extended operation. The Protective Coating Monitoring and Maintenance Program was an existing program that provided for aging management of Service Level I coatings inside primary containment. Service Level I coatings were used in areas where the coating failure could adversely affect the operation of post

-accident fluid systems and thereby impair safe shutdown. The program provided for visual inspections to identify any condition that adversely affects the ability of the coating film to function as intended.

Commitment Item 32, Protective Coating Monitoring and Maintenance Program The inspectors reviewed the program basis documentation, revised implementing procedures, completed inspections, and interviewed responsible plant personnel regarding these documents.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 32. 33. Commitment Item 33 specified licensee would develop a program that wa s consistent with NUREG

-1801 AMP XI.E1 for electrical cables and connections installed in adverse localized environments not subject to 10 CFR 50.49 environmental qualification requirements.

Commitment Item 33, Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements The licensee developed a program to visually inspect all accessible electrical cables and connections installed in adverse localized environments for signs of accelerated age-related degradation. Additional inspections, repairs, or replacements are to be initiated as appropriate.

The inspectors interviewed the program owner, reviewed licensing basis, the

program basis documentation, implementing procedures, work orders and records of walk downs for determining adverse localized environments and visual 15 Enclosure inspections for cables. The inspectors also reviewed corrective actions, which addressed and identified cable issues and their associated corrective actions.

Also , the inspectors reviewed the corrective action taken in reference to the finding from Dresden Inspection Report 05000237/2009007.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 33. 34. Commitment Item 34 specified for the Metal Fatigue of Reactor Coolant Pressure Boundary the existing program was credited with enhancements. The licensee will enhance the program by utilizing the EPRI

-licensed FatiguePro computer software for counting fatigue stress cycles and track fatigue usage factors for selected components. The enhanced program calculates and tracks cumulative usage factors for bounding locations in the reactor coolant pressure boundary (reactor pressure vessel and Class I piping), containment torus, torus vents, torus attached piping and penetrations.

Commitment Item 34, Metal Fatigue of Reactor Coolant Pressure Boundary The inspectors reviewed the licensing basis, Metal Fatigue and Reactor Coolant Pressure Boundary Program basis documentation, FatiguePro implementing procedures, fatigue and transient monitoring program report, related corrective action documents, and interviewed the program owner regarding these documents. The inspectors reviewed changes to the program to ensure the program remained effective for both units.

Based on review of the licensee's actions, the inspectors determined the licensee met Commitment Item 34. 35. Commitment Item 35 specified the licensee was to maintain the existing environmental qualification program of the electrical components for the period of extended operation

. Commitment Item 35, Environmental Qualification (EQ) of Electrical Components Program activities establish, demonstrate and document the level of qualification, qualified configuration, maintenance, surveillance and replacement requirements necessary to meet 10 CFR 50.49.

The inspectors interviewed the program owner, reviewed the licensing basis, program basis document s, and various existing EQ Binders

. Based on the review of the licensee's action, the inspectors determined the licensee met Commitment Item 35. 36. Commitment Item 3 6 specified the existing Boraflex monitoring program was credited for license renewal.

The Boraflex monitoring program is based on manufacturer's recommendations relies on periodic inspection, testing, monitoring and analysis of the criticality design to assure the required 5percent subcriticality margin is maintained.Commitment Item 36, Boraflex Monitoring

16 Enclosure The inspectors interviewed the program owner, reviewed the licensing basis, program basis documents, implementing procedures, planned and completed work orders and related corrective actions.

Based on review of the licensee's actions, the inspectors determined the licensee met Commitment Item 3 6. 37. Commitment Item 37 specified the licensee was to develop a program to manage aging of cables in sensitive instrumentation circuits with low level signals in the Nuclear Instrumentation Systems and Radiation Monitoring Systems

. Commitment Item 37, Electrical Cables Not Subject to 10 CFR 50.49 Environmental Requirements Used in Instrument Circuits The program is applied to the cables of the Nuclear Instrumentation Systems

, which included source range monitors (SRMs), intermediate range monitors (IRMs), local power range monitors, and Radiation Monitoring Systems, which included drywell high range radiation monitors, main steam line radiation monitors, and the steam jet air ejector radiation monitors. The program specified a review of calibration and surveillance results, and cable testing for cable aging degradation before the period of extended operation and every 10 years thereafter

. The inspectors interviewed the program owner, reviewed the licensing basis, program basis document s, implementing procedures, work orders and related corrective actions.

Based on the review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 37. 38. This Commitment Item does not apply to Quad Cities.

Commitment Item 38, Inaccessible Medium

-Voltage Cables Not Subject to 10 CFR 50.49 Environmental Requirements 39. Commitment Item 39 specified the existing corrective action program was credited for license renewal.

Commitment Item 39, Corrective Action Program The inspectors interviewed the program owner, reviewed the licensing basis, implementing procedures, corrective action program results, and interviewed the responsible plant personnel regarding this program. The inspectors also reviewed training given to engineers to increase awareness of aging concerns and license renewal. The inspectors verified the licensee was entering issues related to license renewal in the corrective action program.

The inspector also reviewed a corrective action, AR 01352551, which is tracking actions to revise various procedures to reflect aging management focus. This AR also track s actions to establish aging

-related degradation Passport coding and determine orientation/training needs.

Based on review of the timeliness and adequacy of the licensee actions, the inspectors determined the licensee met Commitment Item 39.

17 Enclosure 40. Commitment Item 40 specified the licensee was to develop and implement a program to periodically inspect non

-segregated bus ducts that connect the reserve auxiliary transformers (RATs) to 4160 V essential service system (ESS)

, the non-segregated bus ducts that connect the Emergency Diesel Generators (EDGs) to the ESS buses, and the non

-segregated bus ducts that connect ESS buses.

Commitment Item 40, Periodic Inspection of Non

-EQ, Non-Segregated Electrical Bus Ducts The inspectors interviewed the program owner, reviewed the licensing basis, program basis document s, implementing procedures, planned and completed work orders and related corrective actions.

Based on the review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 40. 41. Commitment Item 41 specified the existing periodic inspection of ventilation system elastomers was credited for license renewal and that the program would be enhanced prior to the period of extended operation.

Commitment Item 41, Periodic Inspection of Ventilation System Elastomers The inspectors reviewed the licensing basis, program basis documentation, implementing procedures, completed work orders, related corrective action documents and interviewed personnel responsible for the program regarding these documents.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 41. 42. Commitment Item 42 specified the existing periodic testing of drywell and torus spray nozzles was credited for license renewal.

Commitment Item 42, Periodic Testing of Drywell and Torus Spray Nozzles The inspectors reviewed the program basis documentation, Drywell and Torus Spray Nozzle test procedures, completed work orders and condition reports to verify the program has been implemented

. Based on review of the timeliness and adequacy of the licensee

's actions, the inspectors determined the licensee met Commitment Item 42. 43. Commitment Item 43 specified the existing lubricating oil monitoring program would be enhanced to include components exposed to an environment of lubricating oil in the following systems: reactor core isolation cooling system, main generator hydrogen seal oil system, high pressure coolant injection system, emergency diesel generator and auxiliaries system, station blackout system, and electro

-hydraulic control system prior to the period of extended operation.

Commitment Item 43, Lubricating Oil Monitoring Activities The inspectors reviewed licensing basis, program basis document s, implementing procedures, scheduled and completed work orders, result trends, completed oil 18 Enclosure analysis laboratory results, and applicable corrective action program documents. Additionally, the program owner was interviewed regarding these documents. The inspectors verified the licensee has enhanced the program to include the systems and subsystems listed in the Commitment Item in necessary documents to ensure aging is managed through the period of extended operation.

Based on review of the timeliness and adequacy of the licensee

's actions, the inspectors determined the licensee met Commitment Item 43. 44. Commitment Item 44 specified the licensee would develop and implement an Aging Management Program for heat exchangers in the scope of License Renewal that are not tested or inspected by the open

-cycle and closed

-cycle cooling water system aging management programs, to be completed prior to the period of extended operation

. Commitment Item 44, Heat Exchanger Test and Inspection Activities The inspectors reviewed the licensing basis, program basis document s , commitment changes, planned and completed work orders, Issue Reports, inspection procedures and interviewed the plant personnel responsible for the program to verify the program w as being implemented

. For example, the inspectors reviewed commitment change 11-02 which was a clarification in response to an NRC observation in Section 4OA5.1.a (2) of NRC inspection report 05000265/2012008 and verified the proper implementation of the change.

General program requirements for this commitme nt were inspected and determined to be complete for Quad Cities Units 1 and 2.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 44. 45. Commitment Item 45 specified the licensee would use the existing Generator Stator Water Chemistry program to manage aging effects by monitoring and controlling stator water chemistry per established procedures.

Commitment Item 45, Generator Stator Water Chemistry Activities The inspectors reviewed Units 1 and 2 chemistry reports to verify parameters were monitored. General program requirements for this commitment were inspected and determined to be complete for Quad Cities Units 1 and 2.

Based on the review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 45. 46. Commitment Item 46 specified the licensee would develop and implement an Aging Management Program to inspect components in the plant heating system once before the end of the current operating term and periodically at intervals not to exceed once every 5 years during the period of extended operation.

Commitment Item 46, Periodic Inspection of Plant Heating System The inspectors reviewed the licensing basis, program basis document s, planned and completed work orders, Issue Reports, inspection procedures and interviewed 19 Enclosure the plant personnel responsible for the program to verify the program was being implemented on Units 1 and 2. Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 46 with the exception of the URI documented in Section 4OA5.1.b(1)

. 47. Commitment Item 47 specified revised Pressure Temperature (P/T) limits will be prepared and submitted to the NRC for approval prior to the period of extended operation using an approved fluence methodology. On October 17, 2005 License Amendment No. 228 and No. 223 approved the revised P/T limits. The amendments revise d Technical Specification (TS) Section 3.4.9, "Reactor Coolant System Pressure, and Temperature (P/T) Limits," by incorporating revisions to the P/T limit curves for 54 effective full power years (extending to the end of the renewed license). The amendment also resolved a non

-conservative condition for TS 2.4.9, Figure 3.4.9

-2, "Non-Nuclear Heatup/Cooldown Curve."

The inspectors verified the program requirements have been incorporated into station programs.

Commitment Item 47, Time-limited Aging Analysis (TLAA)

- Neutron Embrittlement of the Reactor Vessel and Internals Based on the licensee

's actions, the inspectors determined the licensee met Commitment Item 47. 48. Commitment Item 48 specified commitments of the TLAA related to metal fatigue.

Quad Cities is taking credit for an existing program for monitoring the metal fatigue of reactor coolant pressure boundary. As discussed in Commitment Item 34 , the licensee enhanced their current AMP with the EPRI

-licensed FatiguePro computer software. In addition, prior to the period of extended operation, plant

-specific calculations were performed for applicable locations identified in NUREG/CR

-6260, "Application of NUREG/CR

-5999 Interim Fatigue Curves to Selected Nuclear Power Plant Components

." Commitment Item 48, TLAA - Metal Fatigue The inspectors reviewed the licensing basis, Fatigue and Transients monitoring program implementing procedures, Commitment Item change documents, calculations that assessed effects of reactor coolant on component fatigue life, related corrective action documents, and interviewed the program owner regarding these documents.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 48. 49. Commitment Item 49 specified a reanalysis will be applied to EQ components now qualified for the current operating term of 40 years. The EQ binders for components within the scope of 10 CFR 50.49 will be updated to include environmental conditions associated with Extended Power Uprate implementation together with an extended operating period of 60 years. Commitment Item 49, TLAA -Environmental Qualification of Electrical Equipment

20 Enclosure The inspectors reviewed several examples of EQ Binders for components within the scope of 10 CFR 50.49. The inspectors verified these EQ Binders were updated to include an extended operating period of 60 years. The inspectors also verified where a qualified life of 60 years could not be achieved; measures were in place to replace components before or at the end of the qualified life.

Based on the examples reviewed and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 49. 50. Commitment Item 50 specified two specific TLAAs would be updated prior to the period of extended operation.

Commitment Item 50, Other Plant-Specific TLAAs The first specified the licensee conduct a UT inspection of the Dresden Unit 3 (the lead unit) drywell steel plate remaining thickness at the sand pocket level and use the results to revise the associated corrosion calculation and validate an acceptable wall thickness will remain to the end of the 60

-year licensed operating period for Dresden and Quad Cities Plants

.

The second TLAA specified the licensee conduct a UT inspection of the ECCS suction strainer flange remaining thickness and use the results to revise the associated galvanic corrosion calculation and validate an acceptable thickness will remain to the end of the 60

-year licensed operating period for Quad Cities Units 1 and 2. The inspectors reviewed the licensing basis documents , UT inspection results of the Quad Cities Units 1 and 2 ECCS suction strainer flanges and interviewed the plant personnel responsible for the program

.

Based on review of the timeliness and adequacy of the licensee

's actions, the inspectors determined the licensee met Commitment Item 50. 51. Commitment Item 51 specified the licensee perform an evaluation of operating experience at EPU levels to ensure operating experience at EPU levels is properly addressed by the Aging Management Programs, and submit this evaluation to the NRC for review prior to entering the period of extended operation.

Commitment Item 51, BWR Operating Experience

- EPU levels The licensee performed this evaluation and submitted it for NRC review on October 18, 2012 and therefore, met this commitment.

52. This commitment, discussed in SER Section 3.0.3.18, specified the licensee would manage the aging of components within the scope of the LR program through the performance of periodic UT inspections, visual (VT

-3) inspections, and visual inspection of flexible hoses for age related degradation.

AMP B.2.9, Periodic Inspection of Components Subject to Moist Air This program is a new program that manages the loss of material aging degradation of stainless steel, carbon steel, cast iron, aluminum, copper, brass, and bronze 2 1 Enclosure components. The licensee created this program to ensure aging degradation of components is inspected at a frequency that allows the identification of any degradation that may occur due to the component

's exposure to a moist air environment. If abnormal conditions are identified as a result of any of the program's UT or visual inspections, the licensee committed to performing engineering evaluations to address the progression of the degradation and identifying appropriate corrective actions in accordance with the site controlled Quality Assurance Program.

The inspectors reviewed the licensing basis, program basis document s , implementing procedures, scheduled, and completed work orders, action requests, engineering changes and evaluations and issue reports.

Based on review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met Commitment Item 52 with the exception of the URI documented in Section 4OA5.1.b(1)

. 53. This aging management program commits to the periodic inspection of steam dryers, which are normally exposed to a 288

°Celsius high purity water environment and are subject to cracking. This aging management program manages the cracking of the stainless steel plate and weld materials.

The periodic inspections will be performed in accordance with NRC staff approved frequency and guidance AMP B.2.10, Periodic Inspection of Steam Dryers The inspectors reviewed the program basis documentation, implementing procedures, completed inspections, related corrective action documents, and interviewed responsible program personnel regarding these documents.

Based on the review of the timeliness and adequacy of the licensee's actions, the inspectors determined the licensee met this Commitment Item

. b. (1) Findings and Observations Concern with Meeting One Time Visual Inspections IAW ASME Section XI Requirements Introduction

As part of the review of various licensee Commitment Items, the inspectors identified an unresolved item (URI) related to potential non-conformance with the commitments as described in Appendix A of the UFSAR.

Specifically, the licensee did not follow the requirements of the ASME Section XI when performing various visual examinations.

Description B.1.23 One Time Inspection

- Ventilation Systems, Compressed Gas Systems, SBLC Chemistry Program

During the Phase I inspection of Commitment Item s (IR 05000265/2012008; ML12129A226), the inspectors identified the licensee was not performing visual examinations in accordance with the ASME code.

The inspectors identified this through direct observation, review of the work orders used to perform these examinations and interviews with the appropriate plant personnel.

The commitment to perform visual examinations in accordance with the ASME Section XI code applies to the following programs:

B.1.24 Selective Leaching

B.2.8 Periodic Inspection of Plant Heating Steam; and B.2.9 Periodic Inspection of Components Subject to Moist Air Environments

. The Commitment Item specifically states, "The inspection will be performed in accordance with ASME Code requirements.

Certified NDE examiners will conduct a VT-3 visual inspection (VT-1 for the Selective Leaching program , these inspections will consist of visual inspection consistent with ASME Section XI VT

-1 visual inspection requirements.

)." For visual examinations performed in accordance with the code

, ASME section XI IWA 2210 requires visual examination be performed in accordance with ASME Section V Article 9.

This section requires a procedure be used when performing visual examinations that include instructions on how the visual inspection is to be performed as well as illumination and instruments to be used.

ASME Section XI has specific requirements associated with the different levels of visual examinations (VT

-1 or VT-3) including distance, illumination, and character card resolution requirements.

Contrary to this the licensee did not perform the VT

-1 or VT-3 examinations in accordance with written procedures which document ed the requirements for lighting, distance and other key parameters as well as acceptance criteria. Failure to do so did not ensure an ASME qualified process is used and clear requirements are provided and met.

The licensee submitted a Commitment Item change to clarify their position, indicating the intent was to have a qualified person performing the inspection, not to perform the examination in accordance with the requirements of the code. The licensee also indicated ASME requirements were verbally communicated to the examiners during their pre-job brief therefore, ensuring compliance with the code. In a letter dated May 18, 2012 (ML# 12173A423) the licensee request ed a Commitment Item change. NR R staff subsequently issued a Request for Additional Information (ML 12291A831

) and is awaiting the licensee

's response in order to make a decision regarding these Commitment Item s.

Therefore, this issue is considered unresolved pending resolution of the above issue. (URI 05000254/2012010

-0 1; 05000265/2012010

-0 1: Concern with Meeting One Time Visual Inspections IAW ASME Section XI Requirements

) (2) Questions Regarding Aging Management Inspections on the 16 foot diameter Discharge Piping

Introduction:

As part of the review of licensee Commitment Item 31, the inspectors identified an unresolved item (URI) related to a 16 foot diameter discharge piping. Specifically, the licensee does not physically inspect the piping for aging effects so that the intended functions of this component will be maintained during the period of extended operation.

Description:

As part of the review of Commitment Item 31 associated with the Water Control Structures inspection program, the inspectors reviewed the components that are within the scope of this program and how effects of aging are managed. NUREG 1796; "Safety Evaluation Report Related to the License Renewal of the Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2

"; dated 2004

, Section 3.5.2.3.4 "RG 1.127, Inspection of Water

-Control Structures 23 Enclosure Associated with Nuclear Power Plants

" described the scope of the program and how the effects of aging are managed. Page 3

-426 of NUREG 1796 identified the 16 foot diameter discharge piping as an in

-scope component. The 16 foot diameter discharge piping provides an Ultimate Heat Sink (UHS) function in that during a Lock and Dam No. 14 failure the discharge piping provides suction source for portable pumps to provide cooling water flow to the Residual Heat Removal Service Water (RHRSW) pumps and Diesel Generator Cooling Water (DGCW) Pumps. The licensee

, however , does not physically inspect the discharge piping. The licensee provided aging management of the discharge piping by crediting the performance of a one-time inspection of a 96 inch diameter ice melt line. The ice melt line prevents freezing of the river water entering the plant intake and also performs a support function for the UHS. During this inspection, the licensee was unable to locate where the Office of Nuclear Reactor Regulation (NRR) had reviewed and approved this method of aging management of the discharge piping.

In response to this concern, the licensee initiated Condition Report 01434957 , "(LR) Scoping Review Required for UHS Discharge Piping

," dated November 2, 2012.

Therefore, this issue is considered unresolved pending additional review of the information provided by the licensee and consultation with NRR to determine the appropriate aging management of the 16 foot diameter discharge piping.

(URI 05000254/2012010

-02; 05000265/2012010

-02: Questions Regarding Aging Management Inspections on the 16 foot diameter Discharge Piping

). c. The inspectors did not identify any other substantive instances of incomplete license renewal commitment s with respect to timeliness or adequacy.

The inspectors concluded pending resolution of the above mentioned URIs, commitment s, license conditions, and regulatory requirements associated with the issuance of the renewed operating license were being met at the Quad Cities Nuclear Power Plant Unit s 1 and 2. Overall Conclusions

4OA6

.1 Management Meetings

O n November 9, 201 2 , the inspector s presented the inspection results to Mr. T. Hanley , and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors confirmed none of the potential report input discussed was considered proprietary.

Exit Meeting Summary

ATTACHMENT:

SUPPLEMENTAL INFORMATION

Attachment

SUPPLEMENTAL INFORMATION KEY POINTS OF CONTAC

T

T. Hanley, Site Vice President

Licensee

K. Ohr, Site Engineering Director

W. Beck, Regulatory Assurance Manager

K. O'Shea, Operations Director

T. Rushing, Sr. System Manager/Engineering

P. Yost, Program Engineering

M. Rice, Program Engineering

M. Dunlay, Design Engineering

B. Stedman, Design Engineering

N. Howard, System Engineering

A. Burress, System Engineering

D. Luebbe, System Engineering

M. Wagner, Regulatory Assurance

T. Petersen, Regulatory Assurance

LIST OF ITEMS OPENED, CLOSED AND DISCUSS

ED 050002 54/201 2 010-01 Opened 05000265/2012010

-01 URI Concerns with Meeting

One Time Visual Inspections IAW ASME Section XI Requirements (4OA5.1.b(1)) 05000254/2012010

-02 05000265/2012010

-02 URI Questions Regarding

Aging Management Inspections on the 16' Diameter Discharge Pipes (4OA5.1.b(2)) None Closed and

Discussed

Attachment

LIST OF DOCUMENTS REVIEWED The following is a partial list of documents reviewed during the inspection. Inclusion on this list does not imply that the NRC inspector reviewed the documents

in their entirety, but rather that selected sections or portions of the documents were evaluated as part of the overall inspection

effort. Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the Inspection Report

. UFSAR-11-R12-026; multiple UFSAR Appendix A AMP changes; October 25, 2005

General MOD 50.59 screening QC

-S-2012-0089 Issued on 10/03/2012 for

Multiple Appendix A AMP

Changes; Revision 00

UFSAR-05-R9-012; multiple UFSAR Appendix A AMP EPRI Guidance Changes and Updates; October 28, 2005 MOD 50.59 Screening QC

-S-2005-0198 Issued on October 28, 2005

, for Multiple Appendix A AMP EPRI Guidance Changes by

Updating; Revision 0

AR 01430273; LR

-Stator Water Condensation Water Dripping on Floor; October 23, 2012

Corrective Action Program Documents Generated as a Result of the Inspection

AR 01430839; LR

-ISI Pressure Test PM Model WOs were not Updated; October 24, 2012

AR 01430918; LR

-NRC Identified Visual Inspection was not Documented; October 24, 2012

AR 01431473; LR

-NRC Identified Wear on Piping from Diamond Plating; October 25, 2012

AR 01431795; Quad Cities License Renewal Concern; Checworks Software; October 26, 2012

AR 01432003; LR

- NRC Identified; Clarify Vent. Elastomer Requirements

-OPEX; October 26, 2012

AR 01433189; LR Drawing B

-1068 Update Required; October 30, 2012

AR 01433898; LR Clarify CCST Inspection Question Response; October 31, 2012

AR 01434957; LR Scoping Review Required for UHS Discharge Piping; November 2, 2012

AR 01436493; Typo in Quad Cities IVVI Basis Document in Appendix H; November 6, 2012

AR 01436538; LR

-UT Report of 1/2 EDG Non

-Seg Bus Duct not in WO 880854

-01; November 6, 2012 AR 01436872; Clarify Regulatory Commitment Regarding CASS; November 7, 2012

AR 01437012; ER

-AB-331 Attachment 1 Needs Enhancements; November 7, 2012

WO 01143493; EP Reactor Head Flange Leak Detection System VT

-2 Inspection

March 24, 2010

Commitment Item 1

WO 00880897; DGCW 2

nd Period Pressure Test; April

13, 2009 WO 01379576; DGCW 3

rd Period Pressure Test; March 9, 2012

WO 00885380

-01; RHRSW Suction 1

st Period Static VT2 Test; January 27, 2006

WO 00617085

-01; 1B RHRSW 1

st Period VT2 Pressure Test; December 2, 2005

WO 00617087

-01; 1A RHRSW 1

st Period VT2 Pressure Test; November 15, 2005

WO 01072305

-01; RHRSW Suction 2

nd Period Static VT2 Test; February 6, 2009

WO 00860809

-01; ECCS Ring/HPCI Level 1

st Period VT2 Pressure Test; January 20, 2006

MOD50.59 Screening QC

-S-2005-0198 Issued on 10/28/2005 for

Multiple Appendix A AMP EPRI Guidance Changes By Updating; Revision 0

Commitment Item 2

CY-QC-110-608, Reactor/Turbine Building Sample Panel Sample Collection, Revision 21

CY-AA-160-100 Attach 1; U1 and U2 Torus

Chem. Data for 11/18/2010

CY-AA-160-10 0 Attach 1; U1 and U2 Rx Water and RWCU

Data (Mode 1) for 02/01/2009

CY-AA-160-100 Attach 1; U1 and U2 Rx Water and RWCU

Data (Mode 1) for 02/11/2009

CY-AA-160-100 Attach 1; U1 and U2 Rx Water and RWCU

Data (Mode 1) for 04/16/2011

CY-AA-160-100 Attach 1; U1 and U2 Rx Water and RWCU

Data (Mode 1) for 04/29/2011