IR 05000265/2012008

IR 05000265-12-008, on 03/19/2012-03/28/2012, Quad Cities Nuclear Power Station, Unit 2, Post-Approval Site Inspection for License Renewal

ML12129A226
Person / Time
Site:	Quad Cities
Issue date:	05/08/2012
From:	Ann Marie Stone NRC/RGN-III/DRS/EB2
To:	Pacilio M Exelon Generation Co, Exelon Nuclear
References
IR-12-008
Download: ML12129A226 (17)

Text

May 8, 2012

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNIT 2 NRC POST APPROVAL SITE INSPECTION FOR LICENSE RENEWAL INSPECTION REPORT 05000265/2012008

Dear Mr. Pacilio:

On March 28, 2012, the U.S. Nuclear Regulatory Commission (NRC) completed Phase I of the Post-Approval Site Inspection for License Renewal at your Quad Cities Nuclear Power Station, Unit 2. The enclosed report documents the inspection activities, which were discussed on March 28, 2012, with Mr. T. Hanley and other members of your staff.

This inspection was an examination of activities conducted under your renewed license as they relate to the completion of commitments made during the renewed license application process and compliance with the Commissions rules and regulations and the conditions of your operating license. Within these areas, the inspection involved examination of selected procedures and representative records, observations of activities, and interviews with personnel. On the basis of the sample selected for review, there were no findings of significance identified during this inspection. The NRC staff did not identify any instances of incomplete commitments with respect to timeliness or adequacy.

In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Docket No. 50-265 License No. DPR-30

Enclosure:

Inspection Report 05000265/2012008 w/Attachment: Supplemental Information

REGION III==

Docket No: 50-265 License No: DPR-30 Report No: 05000265/2012008 Licensee: Exelon Generation Company, LLC Facility: Quad Cities Nuclear Power Station, Unit 2 Location: Cordova, IL Dates: March 19-28, 2012 Inspectors: T. Bilik, Senior Reactor Engineer (Lead)

D. Jones, Reactor Engineer Approved by: Ann Marie Stone, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY OF FINDINGS

IR 05000265/2012008; 03/19/2012-03/28/2012; Quad Cities Nuclear Power Station, Unit 2;

Post-Approval Site Inspection for License Renewal The inspection was conducted by two regional based inspectors. No instances were noted of incomplete license renewal commitments with respect to timeliness or adequacy. The NRCs program for overseeing the safe operation of commercial nuclear power reactors as described in NUREG-1649, Reactor Oversight Process, Revision 4, dated December 2006.

NRC-Identified

and Self-Revealed Findings

Cornerstone: Initiating Events, Mitigating Systems, Barrier Integrity

No findings were identified.

Licensee-Identified Violations

No violations of significance were identified.

REPORT DETAILS

Summary of Plant Status

Quad Cities Nuclear Power Station, Unit 2 was in a refueling outage during the period of this inspection.

4OA5 Other Activities

.1 Post-Approval Site Inspection for License Renewal (Phase I) - IP 71003

a. Inspection Scope

(1) Review of Newly Identified Structures Systems and Components (SSC)

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 licensees license renewal staff. The licensee personnel indicated that 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. The AMP will manage the effects of aging for those newly identified components.

The License Renewal Updated Final Safety Analysis Report 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) Review of Revised Commitments As part of reviewing the AMPs associated with the commitments, the inspectors reviewed a sample of commitment revisions related to license renewal. It was identified that of the six commitment revisions provided, five had already been provided during the Phase I inspection of Quad Cities Units 1. As a result, the inspectors reviewed the most recent commitment revision provided, a revision to Commitment No. 44 (AMP B.2.6),as documented in Appendix A of NUREG 1796, NRC Safety Evaluation of the Dresden Nuclear Power Station, Units 2 and 3 and Quad Cities Nuclear Power Station, Units 1 and 2. In Commitment No. 44, Exelon Generation Company, LLC (EGC) made the following commitment:

An aging management program will be developed and implemented for heat exchangers in the scope of license renewal that are not tested and inspected by the Open-Cycle Cooling water System and Closed-Cycle Cooling Water System aging management programs.

Further, in NUREG-1796, the original commitment states that Eddy current testing is to be performed at least once every ten years, and the procedure provides for increasing the inspection frequency based on the results.

The licensee revised the commitment description to read, Eddy current testing is to be performed at least once every ten years, or no greater than once every fifth refuel outage if on an outage schedule. The eddy current testing procedure provides for increasing the inspection frequency based on the results.

The inspectors noted that the verbiage in the commitment in its current form, the modifier of no greater than could be tied to the frequency once which would indicate that the licensee could not test more than once during the five refueling outage period.

The licensee initiated action request AR 01376172 to address the issue. The licensee plans to clarify the language in the commitment revision to reflect the intent of the revision, that is, to specify that the test interval cannot exceed every fifth refueling outage.

After discussion with licensee staff on this commitment revision, the inspectors find the licensees commitment revision acceptable once edited.

The inspectors also reviewed the licensees commitment tracking program to evaluate its effectiveness.

(3) Review of Commitments The inspectors reviewed supporting documents including completed surveillance records, conducted interviews, observed non-destructive examination (NDE) activities, performed visual inspection of structures and components, including those not accessible during power operation, and observed the activities described below to verity 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 outage related aging management programs included in NUREG 1796, in accordance with 10 CFR Part 54, Requirements for the Renewal of Operating Licenses for Nuclear Power Plants. The inspectors also verified a selected sample of corrective actions taken as a result of the license renewal inspection.

b. Findings and Observations

Results of Detailed Reviews The inspectors reviewed portions of the commitments below, which are referenced to Appendix A of NUREG 1796. Activities observed related to these commitments are also listed.

(1) (B.1.1) ASME Code,Section XI Inservice Inspection, Subsections IWB, IWC, and IWD (Commitment 1)

The ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD aging management program (AMP) is part of the inservice inspection (ISI) program (an existing program) and provides for condition monitoring of reactor coolant pressure retaining piping and components within the scope of license renewal, except for the reactor pressure vessel. It also provides for condition monitoring of reactor internal components within the scope of license renewal. The program is implemented through procedures that require examinations consistent with ASME Section XI and approved relief request I4R-02.

A Risk-Informed Inservice Inspection (RISI) is implemented in lieu of ASME Section XI requirements for portions of Class 1 and Class 2 systems. The RISI is implemented as an alternative to the 1995 Edition through 1996 Addenda of ASME Section XI requirements for portions of Class 1 and Class 2 systems.

With enhancement, the ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD, the AMP is consistent with the ten elements of Aging Management Program XI.M1, "ASME Section XI Inservice Inspection, Subsections IWB, IWC, and IWD," specified in NUREG-1801.

The inspectors conducted interviews and reviewed documentation. The inspectors also observed a number of NDE examinations as part of the RISI Program. These included ultrasonic testing (UT) of containment spray system, elbow-to-pipe welds, 1401-7, 1402-5, and 1402-7 (recorded in report numbers Q2R21-045, 46, and 47 respectively). The inspectors had no concerns with the observed activities.

(2) (B.1.11) Flow Accelerated Corrosion (FAC) (Commitment No. 11)

The Flow Accelerated Corrosion (FAC) AMP is an existing program which will be enhanced to include portions of the main steam and the reactor vessel head vent systems that are within the scope of license renewal. The programs activities predict, detect, and monitor wall thinning in piping and valves due to flow-accelerated corrosion.

It also provides for prediction of the amount of wall thinning in pipes and fittings through analytical evaluations and periodic examinations of locations most susceptible to FAC induced loss of material. Specifically, the program includes analyses to determine critical locations, baseline inspections to determine the extent of thinning at these locations, and follow-up inspections to confirm the predictions. Repairs and replacements are performed as necessary.

The inspectors observed a surveillance credited for the FAC AMP. This surveillance, documented in report 2FD01DD, performed an ultrasonic testing thickness measurement of portions of the feedwater tee to detect any material loss as a result of FAC. The inspectors also reviewed UT thickness measurement records for report number 2FR13C. The inspectors had no concerns with the observed activities.

(3) (B.1.23) One-Time Inspection Program (Commitment No. 23 (H, I and J))

The One-Time Inspection AMP is a new program which provides one-time inspections to manage aging effects of identified components within the scope of license renewal. The purpose of the program is to determine if a specified aging effect is occurring. If the aging effect is occurring, the program provides for evaluation of the affected components ability to perform their intended functions for the period of extended operation, and appropriate corrective action. The program is implemented through station procedures.

The inspectors reviewed the licensees activities to implement Commitment Item No. 23 which documents the agreement to perform one-time inspection sampling of 11 specific inspection areas.

To verify the programs effectiveness the inspectors interviewed the program owner and reviewed completed WO 00725725, related to AMP B.1.23H, which credits the One-Time Inspection Program to perform a one-time visual examination of the Unit 2 diesel generator filter housing and external surfaces for evidence of general, crevice, or pitting corrosion. In addition, the inspectors reviewed completed WO 00738013, related to AMP B.1.23I, which credits the One-Time Inspection Program to perform a one-time visual examination of the Unit 2 condensate valve, 2-3399-547, also for evidence of general, surface, or pitting corrosion. Lastly, the inspectors reviewed completed WO 001127927, related to AMP B.1.23J, which credits the One-Time Inspection Program to perform a one-time UT examination of a nozzle-to-safe end weld of the capped control rod drive (CRD) return system. The inspectors had no concerns with the reviewed activities.

(4) (B.1.24) Selective Leaching of Materials (Commitment No. 24)

The Selective Leaching of Materials AMP is a new program. The Selective Leaching of Materials AMP consists of numerous one-time inspections to determine if selective leaching of materials is occurring. The scope of the program includes susceptible components within the scope of license renewal that are exposed to chemically treated water, de-mineralized water, raw water and ground water, and moist ventilation and gas environments. Susceptible component materials are gray cast iron, copper alloys with less than 85 percent copper, aluminum bronze, and Muntz metal.

The program is consistent with the ten elements of Aging Program XI.M33, "Selective Leaching of Materials," specified in NUREG-1801 with the following exceptions.

NUREG-1801 indicates that the Selective Leaching of Materials AMP includes a one-time hardness measurement of a selected set of components. The Quad Cities program provides for visual examination in lieu of hardness testing.

The commitment documents that a sample of components that are made of susceptible materials will be visually inspected for evidence of selective leaching and that the sample will be expanded if failed conditions are identified.

To verify the programs effectiveness, the inspectors reviewed program documents and completed WO 00692750 results for a diesel generator cooling water drain valve.

While conducting the Phase I inspection of Quad Cities Unit 1 in the spring of 2011, an issue was identified which led the inspectors to question the adequacy of the selective leaching exams being performed. In a letter to staff dated November 20, 2003, the licensee indicated that visual inspections [for the Selective Leaching Program] would be performed in accordance with ASME Code Section XI Visual Testing (VT) -1. The inspectors, with concurrence from NRR, understood this to mean that the examinations would be performed with VT-1 qualified personnel following the requirements of ASME Section XI for VT-1 examinations. It was the licensees belief that the commitment was limited to the use of VT-1 qualified personnel to perform the examinations but not to the requirements of the ASME Code. This issue was capture in the licensees corrective action program.

At the time of the Unit 1 inspection, the licensee agreed, based on the verbiage, an ASME Code Section XI VT-1 should have been completed for the selective leaching exams. As such, the licensee intended to submit a commitment revision to clarify their position to NRR for revision and acceptability. However, while addressing the issue, the licensee concluded the scope was broader than originally identified in AMP B.1.24, and resolution was delayed to address the expanded issue. Their extent of condition identified a number of other AMPs with a commitment to perform ASME Code exams and AR 01220460 was issued to track activities related this action. The revision has yet to be submitted and resolution has been extended at least six times.

The licensee proposes to revise these additional commitments to limit the visual examination requirements to the use of VT-1/VT-3 qualified personnel, performing limited VT exams. This is the same limitation as proposed for AMP B.2.6. However, while the Selective Leaching AMP language contains some ambiguity, the other AMPs specifically require ASME Code exams. Furthermore, Q2R21 is the last scheduled outage before the period of extended operation and the licensee has elected to perform all one-time and other license renewal inspections in accordance with the proposed revision and not as indicated in the AMP commitments. The inspectors noted the licensee had not submitted the commitment revision for the Office of Nuclear Reactor Regulation (NRR) review; therefore, the acceptability of their completed actions has not been determined. This will be inspected further during the subsequent IP 71003 inspection.

(5) (B.1.26) ASME Code Section XI, Subsection IWE (Commitment No. 26)

The ASME Section XI, Subsection IWE aging management program is an existing program and provides for primary containment inspections for loss of material. The program includes visual examination and limited surface or volumetric examination, when augmented examination is required. It is implemented through station plans and procedures and covers steel containment shells and their integral attachments; containment hatches and airlocks; seals, gaskets and moisture barriers; and pressure retaining bolting. This AMP will be enhanced as follows:

• The program will be based on the latest edition and addenda, which is approved by the NRC 12 months prior to the end of the current 120-month inspection interval.

• The program will be updated in accordance with 10 CFR 50.55(a).

• Requirements will be provided in procedures to ensure sand pocket drains are clear.

• The pressurized testing methodology will be credited for managing the aging of bellows.

The inspectors reviewed completed WO 01333337, which performed a surveillance of water leakage through the Dryer-Separator Pool, Spent Fuel Pool, and Drywell Liners to verify the integrity of these components. The inspectors had no concerns with the reviewed activities.

(6) (B.1.32) Protective Coating Monitoring and Maintenance Program (Commitment No. 32)

The inspectors reviewed the licensees activities to implement Commitment Item No. 32 which documents the crediting of the existing Protective Coating Monitoring and Maintenance Program and commitments to enhance the program as follows:

(1) visual inspection of Service Level I coatings near sumps or screens associated with the emergency core cooling system;

(2) pre-inspection review of previous reports so that trends can be identified for the program; and

(3) analysis of coating failures to determine reasons for failures.

The Protective Coating Monitoring and Maintenance Program provide for aging management of Service Level I coatings inside primary containment. Service Level I coatings are used in areas where the coating failure could adversely affect the operation of post-accident fluid systems and thereby impair safe shutdown. With the enhancements noted, the program is consistent with the ten elements of Aging Management Program XI.S8, "Protective Coating Monitoring and Maintenance Program," specified in NUREG-1801.

The coatings program uses the guidance provided in Electric Power Research Institute (EPRI) Technical Report TR-109937, Guidelines on Nuclear Safety-Related Coating, to develop a corporate procedure for performing coating inspections.

The inspectors reviewed program documents and observed coating examinations of the centipede per direction of procedure ER-QC-330-1000. The inspection consisted of areas behind the missile shield, the vent headers, and the down-comers in accordance with WO01336189. As part of the same WO, the inspectors observed the coatings examinations of the drywell head, and levels three and four of the drywell. The inspectors had no concerns with the reviewed activities.

(7) (B.1.33) Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements (Commitment No. 33)

The inspectors reviewed the licensees activities to implement Commitment Item No. 33 which documents the agreement to develop a program consistent with NUREG-1801 AMP X1.E1 for electrical cables and connections installed in adverse localized environments not subject to 10 CFR 50.49 environmental qualification requirements.

The AMP for electrical cables and connections not subject to 10 CFR 50.49 environmental qualification requirements is a new program and is consistent with the ten elements of aging program XI.E1, "Electrical Cables and Connections Not Subject to 10 CFR 50.49 Environmental Qualification Requirements," specified in NUREG-1801.

The program manages cables and connections within the scope of license renewal that are subject to an adverse environment. It also identifies and manages cables and connections subject to an adverse localized environment.

Adverse localized environments include areas with temperature, radiation, and moisture significantly higher than the maximum normal (plant design) ambient conditions, and could appreciably increase the rate of aging of the cables or connections or have an immediate adverse effect on operability.

Cables and connections subject to an adverse environment are managed by inspection of a sample of these components. Selected cables and connections from accessible areas represent, with reasonable assurance, the cables, and connections in adverse environments and are inspected for signs of accelerated age-related degradation.

Additional inspections, repairs, or replacements are initiated as appropriate.

The Quad Cities AMP provides reasonable assurance the intended functions of the non-EQ electrical cables and connections within the scope of 10 CFR Part 54 exposed to adverse localized environments caused by heat, radiation or moisture will be maintained through the extended period of operation.

The licensee identified a representative sample of accessible electrical cables and connections installed in adverse localized environments and visually inspected for cable and connection jacket surface anomalies, such as discoloration, swelling, cracking, or surface contamination. The inspectors reviewed program documents and accompanied the licensee to observe a visual examination walkdown of cables in an adverse environmental area in the plant per direction of procedure MA-AA-723-500 and in accordance with WO 01415310 and WO 01418897. The inspectors had no concerns with the observed activities.

(8) (B.2.9) Periodic Inspection of Components Subject to Moist Environments (Commitment not included in Appendix A)

There are no commitments listed in Appendix A of NUREG 1796 for this program. The licensee created a new program as a stand-alone aging management program to manage components in moist air environments. This program is listed in UFSAR Appendix B and the intent of the program is noted in NUREG 1796, Section 3.0.3.18.

The program manages the loss of material for stainless steel, carbon steel, cast iron, aluminum, copper, brass, and bronze components in various systems exposed to moist air environments and subject to wetting conditions based on system operation. The program is not based on a Generic Aging Lessons Learned (GALL) report program; therefore, the applicant summarized the program in terms of the ten-element program as described in Branch Technical Position (BTP), Appendix A of the SRP-LR.

The staff determined that the program adequately addresses the ten program element as defined in the BTP, and that the program would provide adequately manage the aging effects for which it is credited.

The inspectors reviewed program documents and accompanied the licensee to observe visual examinations of the reactor core isolation cooling (RCIC) exhaust vacuum breaker valve, the RCIC torus suction check valve, and the high pressure coolant injection (HPCI) Turbine Casing in accordance with WO 00767199, WO 00709561, and WO 00880895. The inspectors had no concerns with the observed activities.

4OA6 Management Meetings

.1 Exit Meeting Summary

On March 28, 2012, the inspectors presented the inspection results to Mr. T. Hanley and other members of the licensee staff. The licensee acknowledged the issues presented.

The inspectors confirmed that none of the potential report input discussed was considered proprietary.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

T. Hanley, Site Vice President

W. Beck, Regulatory Assurance Manager

S. Darin, Engineering Director

A. Lewis, Regulatory Assurance

A. Misak, Nuclear Oversight Manager

M. Wagner, Regulatory Assurance

LIST OF ITEMS

Opened, Closed, and Discussed

None Attachment