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LER-2018-002, Tornado Missile Protection Non-Conformance in Association with Egm 15-002
Event date:
Report date:
Reporting criterion:	10 CFR 50.73(a)(2)(i)(B), Prohibited by Technical Specifications; 10 CFR 50.73(a)(2)(ii)(B), Unanalyzed Condition; 10 CFR 50.73(a)(2)(vii), Common Cause Inoperability; 10 CFR 50.73(a)(2)(ii)(A), Seriously Degraded; 10 CFR 50.73(a)(2)(viii)(A); 10 CFR 50.73(a)(2)(viii)(B); 10 CFR 50.73(a)(2)(ix)(A); 10 CFR 50.73(a)(2)(iv)(A), System Actuation; 10 CFR 50.73(a)(2)(x); 10 CFR 50.73(a)(2)(v)(A), Loss of Safety Function - Shutdown the Reactor; 10 CFR 50.73(a)(2)(v), Loss of Safety Function; 10 CFR 50.73(a)(2)(i)(A), Completion of TS Shutdown; 10 CFR 50.73(a)(2)(i)
	2542018002R00 - NRC Website
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Tornado Missile Protection Non-Conformance in Association with Egm 15-002
	ML18120A157
Person / Time
Site:	Quad Cities
Issue date:	04/30/2018
From:	Ohr K; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	SVP-18-033 LER 2018-002-00
	Download: ML18120A157 (5)
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=~Exelon Generation April 30, 2018 SVP-18-033 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Quad Cities Nuclear Power Station, Units 1 and 2 10 CFR 50.73 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Licensee Event Report 254/2018-002-000 "Tornado Missile Protection Non-Conformance in Association with EGM 15-002" Enclosed is Licensee Event Report (LEA) 254/2018-002-00, "Tornado Missile Protection Non-Conformance in Association with EGM 15-002," for Quad Cities Nuclear Power Station, Unit 1 and 2.

This report is submitted in accordance with the following:

10 CFR 50.73(a)(2)(i)(B) for operation or condition prohibited by Technical Specifications, 10 CFR 50.73(a)(2)(ii)(B) for a condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety, 1 O CFR 50. 73(a)(2)(v)(D) for a condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident, and 10 CFR 50.73(a)(2)(vii) for an event where a single cause or condition causes two independent trains or channels to become inoperable in a single system designed to mitigate the consequences of an accident.

There are no regulatory commitments contained in this letter.

Should you have any questions concerning this report, please contact Mark Humphrey at (309) 227-2800.

Respec~~

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Kenneth S. Ohr Site Vice President Quad Cities Nuclear Power Station cc:

Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Quad Cities Nuclear Power Station

NRC FORM 366 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB: NO. 3150-0104 EXPIRES:

(02-2018) 03/31/2020

,_pM R*Gtt; LICENSEE EVENT REPORT (LER)

Estmated, the NAG may no! conduct or sponsor, and a person is not required to respond to, the infonmetion collection.

3.Page Quad Cities Nuclear Power Station Unit 1 05000254 1

OF 4

4. Title Tornado Missile Protection Non-Conformance in Association with EGM 15-002

5. Event Date

6. LEA Number

7. Report Date

8. Other Facilities Involved Year I Sequential IA N

Facility Name Docket Number Month Day Year Number ev 0

Month Day Year Quad Cities Nuclear Power Station Unit 2 05000265 Facility Name Docket Number 03 01 2018 2018 002

- 00 04 30 2018 N/A N/A

9. Operating Mode

11. This Report is Submitted Pursuant to the Requirements of 10 CFR §: (Check all that apply)

D 20.2201 (b)

D 20.2203(a)(3)(i)

D 50.73(a)(2)(ii)(A)

D 50.73(a)(2)(viii)(A)

D 20.2201 (d)

D 20.2203(a)(3}(ii)

~ 50.73(a)(2)(ii)(B)

D 50.73(a)(2)(viii)(B) 1 D 20.2203(a)(1)

D D so.13(a)(2)(iii)

D 50.73(a)(2)(ix)(A) 20.2203(a)(4)

D 20.2203(a)(2)(i)

D 50.36(c)(1 )(i)(A)

D 50.73(a)(2)(iv)(A)

D 50.73(a)(2)(x)

10. Power Level D 20.2203(a)(2)(ii)

D 50.36(c)(1 )(ii)(A)

D 50.73(a)(2)(v)(A)

D 73.71(a)(4)

D 20.2203(a)(2)(m)

D 50.36(c)(2)

D 50.73(a}(2)(v)(B)

D 13.11(a)(s)

D 20.2203(a)(2)(iv)

D 50.46(a}(3)(ii)

D 50.73(a)(2)(v)(C)

D 13.77(a)(1) 100 D 20.2203(a)(2)(v)

D 50.73(a)(2)(i)(A)

~ 50.73(a)(2)(v)(D)

D 73.77(a)(2)(ii)

D 20.2203(a)(2)(vi)

~ 50.73(a}(2)(i)(B)

~ 50.73(a)(2)(vii)

D 13.77(a)(2)(m)

D 50.73(a)(2)(i)(C)

D Other (Specify in Abstract below or in

C. CAUSE OF EVENT

SEQUENTIAL NUMBER 002 REV NO.

00 The cause of the non-conforming conditions is a legaC::y design issue that was identified as part of the response to RIS 2015-06. These conditions were part of the original plant design and have existed since the initial construction and licensing of the plant.

D. SAFETY ANALYSIS

No actual safety consequence resulted from the identified non-conforming condition since QCNPS has not experienced an on-site tornado missile event in the past three years, and no equipment damage has taken place.

QCNPS licensing bases for tornados and tornado generated missiles are summarized in original plant licensing documents, including these requirements:

The tornado has a tangential velocity of 300 mph and a translational velocity of 60 mph.

The tornado causes a pressure change of three pounds per square inch at the vortex in three seconds.

One evaluated missile type is a utility pole 50 feet 0 inches long with a butt diameter of 13 inches and a unit weight of fifty pounds per cubic foot, with a velocity of 150 mph.

The second evaluated missile type is a I -ton mass with a contact area of 25 square feet and a velocity of 100 mph.

NRC EGM 15-002, Revision I, provides for application of NRC enforcement discretion which allows the identified non-conforming conditions to be returned to an operable status based on the application of compensatory measures which are intended to reduce the likelihood that the tornado event would result in a failure of any of the identified non-conforming conditions. QCNPS applied the guidance in EGM 15-002, Revision I, and NRC DSS-ISG-2016-01 Appendix A, Revision I, to determine the acceptable initial and comprehensive compensatory measures necessary to ensure that the identified non-conforming conditions could be treated by the NRC with enforcement discretion.

An engineering analysis demonstrated this event did not constitute a Safety System Functional Failure (SSFF).

(Reference NEI 99-02, Revision 7, Regulatory Assessment Performance Indicator Guideline, Section 2.2, Mitigating Systems Cornerstone, Safety System Functional Failures, Clarifying Notes, Engineering analyses.) As such, this event will not be reported in the NRC Performance Indicator (Pl) for safety system functional failures.

E. CORRECTIVE ACTIONS

SEQUENTIAL NUMBER 002 REV NO.

00 Compensatory measures were implemented in accordance with NRC guidance contained in EGM 15-002 Revision 1 and DSS-ISG-2016-01 Revision 1.

Enforcement discretion provided by EGM 15-002 remains in effect until June 20, 2018. QCNPS letter dated March 23, 2018, to the NRC requested extension of this enforcement discretion to June 10, 2020, at which time modifications, license amendments, or other actions must be implemented to fully resolve the issue.

F. PREVIOUS OCCURRENCES

No previous similar events have occurred at the site based on a search of station LERs and I Rs.

G. COMPONENT FAILURE DATA

No component failures were identified.

PLANT AND SYSTEM IDENTIFICATION

General Electric - Boiling Water Reactor, 2957 Megawatts Thermal Rated Core Power SEQUENTIAL NUMBER 002 REV NO.

00 Emergency Onsite Power Supply System [EK], Emergency Diesel Generators [DG], and Fuel Oil Storage and Transfer System [DE]

Energy Industry Identification System (EllS) codes are identified in the text as [XX].

EVENT IDENTIFICATION During a systematic review of the plant protection for tornado generated missiles the Unit 1, 2, and Common Emergency Diesel Generators [DG](EDG) were identified as non-conforming to the station Licensing Basis.

A. CONDITION PRIOR TO EVENT

Unit: 1 Reactor Mode: 1 Event Date: March 1, 2018 Mode Name: Power Operation Event Time: 1210 hours0.014 days 0.336 hours 0.002 weeks 4.60405e-4 months Power Level: 100%

There were no structures, systems, or components (SSCs) out of service or inoperable that contributed to the event.

B. DESCRIPTION OF EVENT

In response to Regulatory Issue Summary (RIS) 2015-06 Quad Cities Nuclear Power Station (QCNPS) reevaluated tornado missile protection under the Enforcement Guidance Memorandum (EGM) 15-002 to insure compliance with the Current Licensing Basis (CLB). The QCNPS CLB requires protection against the effects of single bounding tornado generated missile impacts. Protection against multiple missiles outside the Power Block is not part of the QCNPS CLB. The EDGs [DG] have intake and exhaust piping, and fuel storage [DE] tank vents that are located outside the protection of concrete structures. The potential crimping of these lines from missile impact could prevent the associated Diesel Generator from performing its safety function. Although not described in the CLB, a multiple missile event could prevent redundant EDGs from performing their required safety functions. Therefore, it was conservatively decided to report the EDGs as non-conforming.

On March 1, 2018, at 121 O hours, the Unit 1, 2 and Common Emergency Diesel Generators [DG] were declared inoperable. Compensatory actions in accordance with EGM 15-002 guidance were implemented to return the equipment to operable but non-conforming status. On March 1, 2018, at 1243 hours0.0144 days 0.345 hours 0.00206 weeks 4.729615e-4 months , ENS#53235 was made to the NRG.

This event is reportable as a licensee event report (LER) in accordance with the following:

1 O CFR 50.73(a)(2)(i)(B) for operation or condition prohibited by TS, since the design deficiency (i.e.,

non-conforming condition) existed for a time longer than permitted by TS, 10 CFR 50.73(a)(2)(ii)(B) for a condition that resulted in the nuclear power plant being in an unanalyzed condition that significantly degraded plant safety, 10 CFR 50.73(a)(2)(v)(D) for a condition that could have prevented the fulfillment of the safety function of structures or systems that are needed to mitigate the consequences of an accident, and 10 CFR 50.73(a)(2)(vii) for an event where a single cause or condition causes two independent trains or channels to become ino erable in a sin le s stem desi ned to miti ate the conse uences of an accident.