IR 05000254/2019011

NRC Temporary Instruction 2515/191 and 2515/193 Inspection Report 05000254/2019011 and 05000265/2019011

ML19140A084
Person / Time
Site:	Quad Cities
Issue date:	05/17/2019
From:	Ann Marie Stone NRC/RGN-III/DRP/TSS
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
IR 2019011
Download: ML19140A084 (12)

Text

May 17, 2019 Mr. Bryan Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUBJECT: QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2NRC TEMPORARY INSTRUCTION 2515/191, MITIGATION STRATEGIES, SPENT FUEL POOL INSTRUMENTATION AND EMERGENCY PREPAREDNESS AND TEMPORARY INSTRUCTION 2515/193, IMPLEMENTATION OF RELIABLE HARDENED CONTAINMENT VENTS INSPECTION REPORT 05000254/2019011 AND 05000265/2019011

Dear Mr. Hanson:

On April 26, 2019, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Quad Cities Nuclear Power Station, Units 1 and 2 and discussed the results of this inspection with Mr. K. Ohr and other members of your staff. The results of this inspection are documented in the enclosed report.

The NRC inspectors did not identify any finding or violation of more than minor significance.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Ann Marie J. Stone, Team Leader Technical Support Staff Division of Reactor Projects Docket Nos.: 05000254; 05000265 License Nos.: DPR-29; DPR-30

Enclosure:

IR 05000254/2019011; 05000265/2019011

Inspection Report

Docket Numbers: 05000254 and 05000265 License Numbers: DPR-29 and DPR-30 Report Numbers: 05000254/2019011 and 05000265/2019011 Enterprise Identifier: I-2019-011-0031 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station, Units 1 and 2 Location: Cordova, IL Inspection Dates: April 22, 2019 to April 26, 2019 Inspectors: J. Benjamin, Senior Reactor Inspector J. Gilliam, Reactor Inspector G. O'Dwyer, Reactor Engineer S. Sheldon, Project Engineer D. Tesar, Resident Inspector Approved By: Ann Marie J. Stone, Team Leader Technical Support Staff Division of Reactor Projects Enclosure

SUMMARY

The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting a Temporary Instruction 2515/191, Mitigation Strategies, Spent Fuel Pool Instrumentation and Emergency Preparedness and Temporary Instruction 2515/193,

Implementation of Reliable Hardened Containment Vents inspection at Quad Cities Nuclear Power Station, Units 1 and 2 in accordance with the Reactor Oversight Process. The Reactor Oversight Process is the NRCs program for overseeing the safe operation of commercial nuclear power reactors. Refer to https://www.nrc.gov/reactors/operating/oversight.html for more information. Findings and violations being considered in the NRCs assessment are summarized in the table below.

List of Findings and Violations No findings or violations were identified.

Additional Tracking Items None.

INSPECTION SCOPES

Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Samples were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2515, Light-Water Reactor Inspection Program - Operations Phase. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.

OTHER ACTIVITIES

- TEMPORARY INSTRUCTIONS, INFREQUENT AND ABNORMAL 2515/191 - Inspection of Licensee's Responses to Order EA-12-049, EA-12-051 & EP Info Request March 12, 2012 The inspectors verified plans for complying with NRC Orders EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML12056A045) and EA-12-051, Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (ML12054A679) are in place and are being implemented by the licensee. Additionally, the inspection verified implementation of staffing and communications information provided in response to the March 12, 2012, request for information letter (ML12053A340) and multiunit dose assessment information provided per COMSECY-13-0010, Schedule and Plans for Tier 2 Order on Emergency Preparedness for Japan Lessons Learned, dated March 27, 2013 (ML12339A262).

Inspection of Licensee Responses (3 Samples)

(1) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the Diverse and Flexible Coping Strategies (FLEX) as described in the plant specific submittals and the associated safety evaluation (ML18333A016) and determined that the licensee is in compliance with NRC Order EA-12-049. The inspectors verified the licensee satisfactorily:

• developed and issued FLEX Support Guidelines (FSGs) to implement the FLEX strategies for postulated external events;

• integrated their FSGs into their existing plant procedures such that entry into and departure from the FSGs were clear when using existing plant procedures;

• protected FLEX equipment from site-specific hazards;

• developed and implemented adequate testing and maintenance of FLEX equipment to ensure their availability and capability;

• trained their staff to assure personnel proficiency in the mitigation of beyond-design basis events; and

• developed the means to ensure the necessary off-site FLEX equipment would be available from off-site locations.

(2) Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the FLEX strategy as described in the plant specific submittals and the associated safety evaluation and determined that the licensee is in compliance with NRC Order NRC Order EA-12-051. The inspectors verified the licensee satisfactorily:

• installed the spent fuel pool (SFP) instrumentation sensors, cabling and power supplies to provide physical and electrical separation as described in the plant specific submittals and safety evaluation;

• installed the SFP instrumentation display in the location, environmental conditions and accessibility as described in the plant specific submittals;

• trained their staff to assure personnel proficiency with the maintenance, testing, and use of the SFP instrumentation; and

• developed and issued procedures for maintenance, testing and use of the reliable SFP instrumentation.

(3) The inspectors reviewed information provided in the licensees multi-unit dose submittal and in response to the NRCs March 12, 2012, request for information letter, and verified that the licensee satisfactorily implemented enhancements pertaining to Near-Term Task Force (NTTF) Recommendation 9.3 response to a large scale natural emergency event that results in an extended loss of all ac power to all site units and impedes access to the site. The inspectors verified the following:

• the licensee satisfactorily implemented required staffing changes to support a multi-unit extended loss of alternating current

(ac) power (ELAP) scenario;

• emergency preparedness (EP) communications equipment and facilities are sufficient for dealing with a multi-unit ELAP scenario; and

• the licensee implemented multi-unit dose assessment capabilities (including releases from spent fuel pools) using the licensees site-specific dose assessment software and approach.

2515/193 - Inspection of the Implementation of EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions The inspectors verified plans for complying with NRC Order EA-13-109, Order Modifying Licenses with regard to Reliable Hardened Containment Vents Capable of Operation under Severe Accident Conditions, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13143A321) are in place and are being implemented by the licensee.

Inspection of the Implementation of EA-13-109 (1 Sample)

Based on samples selected for review, the inspectors verified that the licensee satisfactorily implemented appropriate elements of the reliable hardened containment wetwell vent as described in the plant specific submittals and the associated safety evaluation (ADAMS Accession No. ML18348B251) and determined that the licensee is in compliance with NRC Order EA-13-109 Phase 1, Reliable, Severe Accident Capable Wetwell Venting System.

The inspectors verified that the licensee satisfactorily:

• Installed the hardened containment vent system (HCVS) to meet the performance objectives outlined in Section A.1.1 of Attachment 2 to the Order EA-13-109;

• Installed the HCVS system with the design features specified in Section A.1.2 of 2 to the Order EA-13-109;

• Designed the HCVS to meet the quality standards described in Section A.2 of 2 to the Order EA-13-109;

• Developed and implemented adequate maintenance and testing of HCVS equipment to ensure their availability and capability;

• Developed and issued procedures to safely operate the HCVS using normal power supplies, during an ELAP, and during a postulated severe accident scenario, and integrated the procedures into existing plant procedures and,

• Trained their staff to assure personnel can proficiently operate the HCVS.

Based on samples selected for review, the inspectors verified the licensee satisfactorily implemented appropriate elements of the reliable wetwell venting strategy as described in the plant specific submittals and the associated safety evaluation and determined the licensee is in compliance with NRC Order EA-13-109 Phase 2, Reliable, Severe Accident Capable Drywell (or alternative strategy) Venting System. The inspectors verified the licensee satisfactorily developed a strategy making it unlikely that the licensee would need to vent from the containment drywell that included the following:

• Implemented the severe accident water addition (SAWA) and severe accident water management (SAWM) systems as defined and fulfilled functional requirements for installed and portable equipment;

• Installed and/or identified the previously-installed instrumentation necessary to implement SAWM;

• Developed and implemented adequate maintenance and testing of SAWA/SAWM equipment to ensure availability and capability;

• Developed and issued procedures to safely operate the SAWA/SAWM during an ELAP and during postulated severe accident scenario, and integrated their procedures into their existing plant procedures such that entry into and exiting from the procedures are clear when using existing plant procedures; and

• Trained their staff to assure personnel can proficiently operate the HCVS during an ELAP and accident scenario.

The inspectors verified noncompliances with requirements, and standards identified during the inspection were entered into the licensee's corrective action program as appropriate.

The corrective action program documents generated as a result of the inspection are listed in the Documents Reviewed section of this inspection report.

INSPECTION RESULTS

No findings were identified.

EXIT MEETINGS AND DEBRIEFS

The inspectors verified no proprietary information was retained or documented in this report.

• On April 26, 2019, the inspector presented the Temporary Instruction 2515/191 and Temporary Instruction 2515/193 inspection results to Mr. K. Ohr and other members of the licensee staff.

DOCUMENTS REVIEWED

Inspection Type Designation Description or Title Revision or

Procedure Date

2515/191 Corrective Action 02474611-02 QDC-0000-5-2153 Impact on Robust FLEX Bldg Roll-Up Door 12/31/2015

Documents 04098335 Workorder to Set SAWA Flow Meter Parameter 01/29/2018

04137905 PM's for FLEX/SAWA Installed Valves 05/15/2018

224363 Local Intense Precipitation Response Procedure Clarification 02/28/2018

240219 EOID: SAWA Flow Meter Needs Troubleshooting/Calibration 04/16/2019

240525 FLEX SAWA Flow Meter Pushbutton Broken 04/16/2019

Corrective Action 04202046 Recommend Installing Jack Stands on Flex Diesel Generators 12/11/2018

Documents 04242835 NRC Identified Potential Base Metal Corrosion on Deep Well 4/23/2019

Resulting from Pump Casing

Inspection 04242950 Flex Inspection - LIP Procedure Change Documentation 04/24/2019

243132 FLEX Inspection - FLEX Equipment Refueling Methods 04/24/2019

243508 FLEX - Evaluate Enhancement Alternatives to Yanmar 04/28/2019

Placement

Drawings 4E-1791 Unit 1 External Wiring Diagram, Spent Fuel Pool Level A

Instrumentation

4E-2661A Local Intense Precipitation Response Procedure Clarification F

4E-2791 Unit 2 External Wiring Diagram, Spent Fuel Pool Level A

Instrumentation

Engineering EC 0000399944 FLEX Diesel Fuel Oil Plan Fukushima 2/24/2015

Changes EC 395862 Fuel Oil Storage Tanks FLEX Vent Installation 1

EC 398181 EOC - FLEX Robust Storage Building 2

Miscellaneous Lesson N-QC-EP- GAP Training for Flex Core Cooling 0

FLEX-REC4

LN-1602 Containment Auxiliaries Training 11

LN-1900 Operator Initial/ Continuing Training- Fuel Pool Cooling 4

LN-Flex 1 Diverse and Flexible Coping Strategies 2

LN-Flex 2 Flex Equipment 5

RS-13-035 Overall Integrated Plan in Response to Commission Order 02/28/2013

Modifying Licenses with Regard to Requirements for Reliable

Spent Fuel Pool Instrumentation

RS-18-087 Final Integrated Plan Document Mitigating Strategies NRC 08/14/2018

Inspection Type Designation Description or Title Revision or

Procedure Date

Order EA-12-049

Procedures 189937-01 PMID Preventive Maintenance Monthly Check for FLEX and 4

B.5.b. Pumps, Equipment and Trailers

CC-AA-118 Diverse and Flexible Coping Strategies (FLEX), Spent Fuel 4

Pool Instrumentation (SFPI), and Hardened Containment Vent

System (HCVS) Program Document

CC-QC-118 Site Implementation of Diverse and Flexible Coping Strategies 6

CC-QC-118 FLEX Periodic Activities 6

EP-AA-100-200 Dose Assessment 12

EP-AA-110-200- URI Detailed Assessment - Summing Dose Assessments A

F-39

EP-AA-110-201 On Shift Dose Assessment 6

OU-AA-103 Shutdown Safety Management Program 20

OU-AA-103 Shutdown Safety Management Program 20

QCAP 1500-07 Administrative Tracking Requirements For Unavailable FLEX, 6

HCVS, And SAWA

QCIPM 1900-01 Spent Fuel Pool Indication System Calibration 0

QCOA 0010-22 Local Intense Precipitation Response Procedure 15

QCOA 6100-02 Loss of Offsite Power 42

QCOA 6100-04 Station Blackout 24

QCOP 0050-01 Unit 1 FLEX DC Load Shed 4

QCOP 0050-02 Unit 2 FLEX DC Load Shed 4

QCOP 0050-04 FLEX Refuel Floor Action 3

QCOP 0050-05 FLEX/SAWA Fire Hose Deployment 5

QCOP 0050-06 FLEX RPV, Suppression Pool, and Spent Fuel Pool Level 7

Control

QCOP 0050-07 FLEX Generator and Pump Power Cable Deployment 4

QCOP 0050-08 FLEX Electrical Restoration 7

QCOP 0050-09 FLEX Response Instrumentation and Communication 8

Equipment

QCOP 0050-10 FLEX Battery Room Ventilation 3

QCOP 0050-11 FLEX Control Room Ventilation 1

Inspection Type Designation Description or Title Revision or

Procedure Date

QCOP 0050-12 FLEX RCIC System Operation 002

QCOP 0050-13 FLEX Generator/Pump Refueling 6

QCOP 0050-16 FLEX National SAFER Response Center Interface 3

QCOP 0050-17 FLEX RCIC Room Cooler Lineup 2

QCOP 1300-10 Bypassing RCIC Isolations: Low RPV Pressure or High Area 7

Temperature

QCOS 0050-01 Flex Generator Test 1

QCOS 0050-01- Flex Well Pump Test 2

QCOS 0050-06 HCVS Rupture Disc Integrity Test 0

QGA 100 RPV Control 12

QGA 200 Primary Containment Control 12

QGA 500-4 RPV Flooding 15

QGA 6900-07 Loss of AC Power to the 125 VDC Battery Chargers 24

Self-Assessments Quad Cities Nuclear Power Station 11/03/2014

NEI 12-01 Phase 2 Staffing Assessment Report

Work Orders 04678198 480 VAC Annual Inspection and Load Test (DG-1) 03/17/2019

04760168 01 Pre-Outage - SFP Level Probe Camera Inspect and Calibration 12/18/2018

Check

047771006 Emergency Portable Pump A Surveillance 09/03/2018

04796512 FLEX Deep Well Flow Rate Test 12/06/2018

04825926 Security Event Support Equipment Surveillance 11/25/2018

04828799 Emergency Portable Pump C Surveillance 03/12/2019

04896251 01 PMID Preventive Maintenance Monthly Check for FLEX and 4/10/2019

B.5.b. Pumps, Equipment and Trailers Completed 4/10/2019

1740593 FLEX Robust Storage Building Construction EC 398181 05/04/2016

2515/193 Corrective Action 02473798 Potential Hardened Vent Tower Fabrication Issues 10/07/2016

Documents 04024472 HCVS AOV Assembly Bettis Actuator Part 21 Applicability 05/18/2017

04035644 NOS ID: HCVS EC DCS Not Updated to Reflect Calc Revision 07/24/2017

04036129 NOS ID: HCVS Nitrogen Pipe Model Omitted Elements 03/27/2017

04072155 HCVS Battery Charger Not Functioning 11/07/2017

Engineering 624618 HCVS Phase 2 Validation Evaluation 0

Changes

Inspection Type Designation Description or Title Revision or

Procedure Date

Miscellaneous Initial and Requal Severe Accident Guidelines Management 1

Training N-AN-

EP-SAM

Procedures QCOP 1600-13 Venting of Containment 31

QCOP 6900-56 Hardened Containment Vent 125 VDC Battery System 1

QCOS 1600-59 Hardened Containment Vent System Test 1

QCOS 1600-60 Hardened Containment Vent System (HCVS) Operating Cycle 0

Walkdown

SAMG-1 RPV and Primary Containment Injection 6

SAMG-2 RPV, Containment, and Radioactivity Release Control 8

Work Orders 04627858 EC 618667 U1 Hardened Containment Vent System (HCVS) 03/06/2019

Phase 2

04802810 Hardened Containment Vent System Test (IST) 03/18/2019

10