ML071590365
| ML071590365 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 06/05/2007 |
| From: | Grant G Region 3 Administrator |
| To: | Crane C Exelon Generation Co, Exelon Nuclear |
| References | |
| EA-06-229, IR-06-002 | |
| Download: ML071590365 (9) | |
See also: IR 05000254/2006002
Text
June 5, 2007
Mr. Christopher M. Crane
President and Chief Nuclear Officer
Exelon Nuclear
Exelon Generation Company, LLC
Quad Cities Nuclear Power Station
4300 Winfield Road
Warrenville, IL 60555
SUBJECT:
RESPONSE TO DISPUTED NON-CITED VIOLATIONS
QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2
INSPECTION REPORT 05000254/2006002(DRS); 05000265/2006002(DRS)
Dear Mr. Crane:
Thank you for your response by letter dated August 31, 2006, to our inspection report issued on
July 31, 2006, concerning activities conducted at your facility. In your response, you denied two
of the Non-Cited Violations (NCVs) contained in the inspection report: NCV 05000254(265)/
2006002-01, associated with the safe shutdown makeup pump; and NCV 05000254(265)/
2006002-02, associated with residual heat removal service water cross-tie. You also denied
the existence of a cross-cutting aspect to NCV 05000254(265)/2006002-04, associated with
your stations fire pre-plans. By letter dated September 27, 2006, we informed you that we
were evaluating your reply and would inform you of the results of our evaluations. We have
completed our review of your response.
The NRC conducted a detailed review of your response and the applicable licensing and
regulatory documents. The review was conducted by NRC staff that were independent of the
initial inspection effort, including the Office of Nuclear Reactor Regulation, and the results were
reviewed by the NRC Office of Enforcement. After careful consideration of the bases for your
denial of the NCV, we have concluded that the violations occurred as stated in the inspection
report. We have provided a summary of our evaluation and conclusions as an enclosure to this
letter. The enclosure also discusses an evaluation of your denial of an existing cross-cutting
aspect for an inspection finding.
C. Crane
-2-
In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its
enclosure and your August 31, 2006, response will be available electronically for public
inspection in the NRC Public Document Room or from the NRC's document system (ADAMS),
accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
Geoffrey E. Grant
Deputy Regional Administrator
Docket Nos. 50-254; 50-265
Enclosure:
(EA-06-229) Evaluation of Basis for Disputed Non-Cited
Violations and Conclusions
cc w/encl:
Site Vice President - Quad Cities Nuclear Power Station
Plant Manager - Quad Cities Nuclear Power Station
Regulatory Assurance Manager - Quad Cities Nuclear Power Station
Chief Operating Officer
Senior Vice President - Nuclear Services
Senior Vice President - Mid-West Regional
Operating Group
Vice President - Mid-West Operations Support
Vice President - Licensing and Regulatory Affairs
Director Licensing - Mid-West Regional
Operating Group
Manager Licensing - Dresden and Quad Cities
Senior Counsel, Nuclear, Mid-West Regional
Operating Group
Document Control Desk - Licensing
Vice President - Law and Regulatory Affairs
Mid American Energy Company
Assistant Attorney General
Illinois Emergency Management Agency
State Liaison Officer, State of Illinois
State Liaison Officer, State of Iowa
Chairman, Illinois Commerce Commission
Chief Radiological Emergency Preparedness Section,
Dept. Of Homeland Security
D. Tubbs, Manager of Nuclear
MidAmerican Energy Company
Crane
-2-
In accordance with 10 CFR 2.390 of the NRC's Rules of Practice, a copy of this letter, its enclosure and your
August 31, 2006, response will be available electronically for public inspection in the NRC Public Document Room or
from the NRC's document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-
rm/adams.html.
Sincerely,
/RA/
Geoffrey E. Grant
Deputy Regional Administrator
Docket Nos. 50-254; 50-265
Enclosure:
(EA-06-229) Evaluation of Basis for Disputed Non-Cited
Violations and Conclusions
cc w/encl:
Site Vice President - Quad Cities Nuclear Power Station
Plant Manager - Quad Cities Nuclear Power Station
Regulatory Assurance Manager - Quad Cities Nuclear Power Station
Chief Operating Officer
Senior Vice President - Nuclear Services
Senior Vice President - Mid-West Regional
Operating Group
Vice President - Mid-West Operations Support
Vice President - Licensing and Regulatory Affairs
Director Licensing - Mid-West Regional
Operating Group
Manager Licensing - Dresden and Quad Cities
Senior Counsel, Nuclear, Mid-West Regional
Operating Group
Document Control Desk - Licensing
Vice President - Law and Regulatory Affairs
Mid American Energy Company
Assistant Attorney General
Illinois Emergency Management Agency
State Liaison Officer, State of Illinois
State Liaison Officer, State of Iowa
Chairman, Illinois Commerce Commission
Chief Radiological Emergency Preparedness Section,
Dept. Of Homeland Security
D. Tubbs, Manager of Nuclear
MidAmerican Energy Company
See Previous Concurrence
Distribution:
See Next Page
DOCUMENT NAME: C:\\FileNet\\ML071590365.wpd
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To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy
OFFICE RIII
RIII
NAME
Jlara: jb
- CCarpenter
CPederson
DATE
05/25/07
05/24/07
05/28/07
OFFICE RIII
RIII
RIII
RIII
NAME
MRing
KOBrien
GGrant
DATE
05/29/07
05/24/07
06/05/07
OFFICIAL RECORD COPY
- OE concurrence provided by Cheryl Montgomery in email from D. Starkey to K. OBrien
C. Crane
-3-
Letter to Mr. Christopher M. Crane from Mr. Geoffrey E. Grant dated June 5, 2007.
SUBJECT:
RESPONSE TO DISPUTED NON-CITED VIOLATIONS
QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2
INSPECTION REPORT 05000254(265)/2006002
DISTRIBUTION:
MXM2
JFW1
KKB
SECY
W. Kane, DEDR
C. Carpenter, OE
D. Solorio, OE
D. Starkey, OE
J. Caldwell, RIII
G. Grant, RIII
L. Chandler, OGC
B. Jones, OGC
J. Dyer, NRR
S. Richards, Chief, IIPB, NRR
M. Tschiltz, Chief, SPSB, NRR
D. Merzke, NRR
J. Stang, NRR
D. Holody, Enforcement Officer, RI
C. Evans, Enforcement Officer, RII
K. OBrien, Enforcement Officer, RIII
K. Fuller, Enforcement Officer, RIV
R. Pascarelli, Enforcement Coordinator, NRR
K. Stoedter, Seniro Resident Inspector
E. Brenner, OPA
H. Bell, OIG
G. Caputo, OI
P. Pelke, RIII:EICS
V. Mitlyng, RIII:PA
R. Lickus, RIII
J. Lynch, RIII
OEWEB
OEMAIL
TEB
RidsNrrDirsIrib
MPP
SXB3
CAA1
DRPIII
DRSIII
PLB1/TXN
ROPreports@nrc.gov
Enclosure
1
QUAD CITIES NUCLEAR POWER STATION (QCNPS) UNITS 1 AND 2; INSPECTION REPORT
05000254(265)/2006002
(EA-06-229) EVALUATION OF BASIS FOR DISPUTED NON-CITED VIOLATIONS AND CONCLUSIONS
NRCs Evaluation of Licensees Response:
Region III conducted an independent review of the technical and enforcement issues associated with the
two Non-Cited Violations (NCVs) referenced in Inspection Report
No. 05000254(265)/2006002. As part of this review process, the Region III staff reviewed QCNPS
August 31, 2006 response, requested additional information and conducted a teleconference with licensee
staff to ensure a clear understanding of QCNPS position. Furthermore, the Region III staff received
technical assistance from the Office of Nuclear Reactor Regulation (NRR) staff responsible for fire
protection issues. The technical assistance was provided via a Task Interface Agreement (TIA) (2006-
005, dated September 28, 2006; ADAMS Accession Number ML062710539), and the associated
response dated
March 27, 2007; (ADAMS Accession Number ML070640415). In accordance with 10 CFR 2.390 of the
NRC's Rules of Practice, a copy of this letter, its enclosure and your
August 31, 2006, response will be available electronically for public inspection in the NRC Public
Document Room or from the NRC's document system (ADAMS), accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html.
The NRC staff recognizes that fire protection program changes made following the 1998 Confirmatory
Action Letter resulted in a decrease in the number and the complexity of operator actions required to meet
Appendix R,Section III.G.3 requirements. Nonetheless, the program changes must continue to meet
existing regulations consistent with established regulatory guidance.
In summary, the NRC staff concluded that QCNPS made changes to the plants fire protection program
which were not consistent with 10 CFR 50 Appendix R requirements, as stated in the NCVs. Therefore,
the NRC staff reaffirmed the original NCVs. The reasons are discussed below.
The Region III staff also reviewed the additional information provided by QCNPS with regard to the cross-
cutting aspect of NCV 05000254(265)/2006002-04. The results of this review are also documented below.
1.
Non-Cited Violation 05000254(265)/2006002-01
Restatement of Violation:
Title 10 CFR Part 50.48, Fire Protection, and 10 CFR Part 50, Appendix R, Fire Protection Program for
Nuclear Power Facilities Operating Prior to January 1, 1979, establishes specific fire protection features
required to satisfy 10 CFR Part 50, Appendix A, General Design Criterion 3, Fire Protection. Appendix R
applies to licensed nuclear power electric generating stations that were operating prior to January 1, 1979,
which included QCNPS. Section III.G.2 of Appendix R to 10 CFR Part 50 requires, in part, that, where
cables or the equipment of a redundant train of systems necessary to achieve and maintain hot shutdown
conditions are located within the same fire area outside of primary containment, one of a specified means
of ensuring that one of the redundant trains is free of fire damage shall be provided.
Section III.G.3 of Appendix R to 10 CFR Part 50 requires, in part, that, alternative or dedicated shutdown
capability should be provided where the protection of systems whose function is required for hot shutdown
does not satisfy the requirement of Paragraph III.G.2. Subsection 3 of Section III.L., Alternative and
Dedicated Shutdown Capability, to 10 CFR Part 50,
Appendix R requires, in part, that the shutdown capability shall be independent of the specific fire area(s)
Enclosure
2
and shall accommodate postfire conditions where offsite power is available and where offsite power is not
available for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Procedures shall be in effect to implement this capability.
Contrary to the above, in the event of a fire in any of these fire areas (TB-III, 13-1, or 24-1), QCNPS failed
to ensure that one of the redundant trains of reactor coolant inventory makeup water remained free of fire
damage. Instead, QCNPS credited the use of the dedicated safe shutdown makeup pump (SSMP) for
reactor coolant inventory makeup without having analyses and procedures that demonstrated their full
compliance with Sections III.G.3 and III.L, or requesting prior NRC approval. Once identified, QCNPS
entered the finding into their corrective action program as IR 00502702, NRC Inspection Finding
Concerning Appendix R Redundant Trains, dated June 22, 2006. Because this violation was of very low
safety significance and it was entered into QCNPS corrective action program, this violation is being
treated as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy.
Summary of Licensees Response and NRC Evaluations
Licensee Response:
In summary, QCNPS maintained that the SSMP and reactor core isolation cooling (RCIC) systems meet
the NRC requirements to be considered redundant and therefore no violation of NRC requirements exists.
This is based on the SSMP and RCIC performing the same design functions. The QCNPS cited two
primary documents as a basis: Generic Letter (GL) 86-10, Implementation of Fire Protection
Requirements, [Question 3.8.3 Redundant Trains/Alternate Shutdown,] and Nuclear Energy Institute
(NEI) Guidance Document 00-01, Guidance for Post-Fire Safe Shutdown Circuit Analysis. The QCNPS
maintained that the basis for the NCV was inconsistent with NRC or industry guidance related to Appendix
R redundant versus alternate system classification.
NRC Evaluation:
The NRC staff performed a review of the regulatory guidance documents relating to Appendix R as part of
this review, including those referenced by QCNPS. While the NRC inspection report and licensee position
reference GL 86-10, Question 3.8.3, the NRC staff response to GL 86-10 Question 5.1.2, also provides
regulatory guidance with respect to what constitutes a preferred system. In that response, the staff stated,
in part, For the purposes of analysis to
Section III.G.2 criteria, the safe shutdown capability is defined as one of the two normal safe shutdown
trains. If the criteria of Section III.G.2 are not met, an alternative shutdown capability is required.
The QCNPS originally did not protect redundant safe shutdown trains in specific fire areas and did not
provide an alternate shutdown capability using existing sytems. Therefore, the SSMP was installed as a
new system to provide dedicated shutdown system capability to comply with 10 CFR Part 50, Appendix R,
Section III.G.3. This new system installation approach was consistent with the response to Question 3.8.3
and Footnote 1 in Appendix R, ...dedicated shutdown capability is provided by installing new structures
and systems for the function of post-fire shutdown.
With respect to QCNPS position that classification of the SSMP as redundant is supported by the
guidance in NEI 00-01, the NRC staff notes that this guidance document was developed, and endorsed by
NRC, for resolving circuit failure issues; which is not pertinent to this NCV. Nonetheless, the guidance
contained therein (i.e., 3.1.1 Criteria Assumptions) with respect to identifying systems required for safe
shutdown functions is consistent with the NCV basis and the associated TIA response.
Licensees can perform a 10 CFR 50.59 evaluation (or other equivalent adverse effects evaluation) for fire
protection program changes to change compliance strategies
(i.e., Sections III.G.2 to III.G.3, and vice versa). However, licensees must evaluate the adverse effects on
Enclosure
3
safe shutdown and remain in compliance with the provisions of the specified requirements in 10 CFR Part 50, Appendix R. In this particular case, QCNPS reclassified the SSMP from a dedicated shutdown system
to a redundant system, and asserted that the SSMP met the Appendix R,Section III.G.2 requirements.
However, since the function of the SSMP system (a dedicated system) is for Appendix R safe shutdown,
the SSMP did not perform the same design function as the RCIC system. Additionally, since the SSMP
was also not one of the two normal safe shutdown trains, it was therefore an alternative (dedicated)
shutdown capability. Furthermore, in accordance with Section III.L.3, dedicated systems must
demonstrate shutdown capability when offsite power is and is not available.
Accordingly, the SSMP system is not redundant and the design function of the SSMP system should
remain characterized as a Dedicated Shutdown system. The QCNPS has not demonstrated that the
SSMP design function is the same as the RCIC system design function (i.e., a redundant system). As
stated in the referenced TIA documents, the acceptability of reliance on a system, other than the normal
shutdown trains for the purpose of establishing compliance with 10 CFR Part 50, Appendix R, Section
III.G.2, necessitates significant safety analysis and regulatory reviews.
For the above reasons, the staff concludes that the violation occurred as stated.
Enclosure
4
2.
Non-Cited Violation 05000254(265)/2006002-02
Restatement of Violation:
Title 10 CFR Part 50.48, Fire Protection, and 10 CFR Part 50, Appendix R, Fire Protection Program for
Nuclear Power Facilities Operating Prior to January 1, 1979, establishes specific Fire Protection features
required to satisfy 10 CFR Part 50, Appendix A, General Design Criterion 3, Fire Protection. Appendix R
applies to licensed nuclear power electric generating stations that were operating prior to January 1, 1979,
which includes QCNPS. Section III.G.2 of Appendix R to 10 CFR Part 50 required, in part, that, where
cables or equipment of redundant trains of systems necessary to achieve and maintain hot shutdown
conditions are located within the same fire area outside of primary containment, one of a specified means
of ensuring that one of the redundant trains is free of fire damage be provided.
Contrary to the above, in the event of a fire in Fire Areas TB-III, 13-1, or 24-1 (i.e., a III.G.2 area), QCNPS
failed to meet the requirement of Section III.G.2 of 10 CFR Part 50, Appendix R. Specifically, in the event of
a fire in any of these areas, QCNPS credited the opposite Unit RHRSW system instead of ensuring one of
the redundant trains of RHRSW from the respective unit with fire was available. Once identified, QCNPS
entered the finding into their corrective action program as IR 00502702, NRC Inspection Finding
Concerning Appendix R Redundant Trains, dated June 22, 2006. Because this violation was of very low
safety significance and it was entered into QCNPS corrective action program, this violation is being treated
as a NCV, consistent with Section VI.A.1 of the NRC Enforcement Policy.
Summary of Licensees Response and NRC Evaluations
Licensee Response:
In summary, QCNPS maintained that for multiple unit plants, the systems shared between units may be
credited as redundant for each unit, provided the system performs its design function within the design
basis of the plant. The residual heat removal (RHR) service water (RHRSW) system design function was
to provide cooling water to the RHR system heat exchangers, and was required for containment cooling
and safe reactor shutdown during abnormal operating events. The plant design basis fully acknowledged
the RHRSW system and inter-unit capabilities. Utilization of the crosstie was fully integrated into station
operating procedures, including certain procedures used for post-fire safe shutdown.
Furthermore, QCNPS maintained that the NRC acknowledged the industrys use of shared inter-unit
systems for redundant safe shutdown in Technical Report R7017/U7010-3/95.
NRC Evaluation:
The NRC staff performed a review of the regulatory guidance documents relating to Appendix R as part of
this review, including those referenced by QCNPS. The NRC staff concludes that QCNPS cannot rely
upon on a multi-unit cross-tie capability for the purpose of meeting 10 CFR Part 50, Appendix R, Section
III.G.2., unless an exemption request has been granted.
Enclosure
5
Title 10 CFR 50.48 states that, Each operating nuclear power plant must have a fire protection plan that
satisfies Criterion 3 of Appendix A of this part. Therefore, each of the QCNPS units must individually
comply with this regulation. With respect to compliance with 10 CFR Part 50, Appendix R, since the
redundant trains of the RHRSW system in one unit could be affected by a single fire, QCNPS seeks to
credit the non-fire affected units RHRSW system as being redundant to the fire affected units RHRSW
system and vice versa. Without an exemption, this approach does not satisfy the requirements of III.G.2
for a plant licensed to operate before January 1, 1979, because the redundant RHRSW system trains in
the same unit are not free of fire damage.
The QCNPS approach could be acceptable as an alternative shutdown method provided that the
requirements of 10 CFR Part 50, Appendix R, Section III.G.3 and Section III.L were met. This approach
would necessitate assurance that during all modes and alignments on one unit, the RHRSW system is
available to support fire safe shutdown of the opposite unit.
With respect to the referenced technical report and its examples of cross-tied equipment between units, the
report was intended as a general guidance document for international audiences and has no regulatory
basis for establishing compliance with NRC regulations.
For the above reasons, the staff concludes that the violation occurred as stated.
3.
Cross-Cutting Aspect of Non-Cited Violation 05000254(265)/2006002-04
The QCNPS provided additional information for consideration regarding this NCV. Specifically, while
QCNPS did not contest the NCV, QCNPS did not believe that there was a cross-cutting aspect to this NCV
because Problem identification and Resolution (PI&R) was not the underlying cause of the performance
deficiency.
The staff concludes that this issue did affect the cross-cutting area of PI&R because the previous
corrective actions developed were narrowly focused. The NRC PI&R cross-cutting area contains an area
component of Corrective Action Program. This area component is further defined by licencee actions
which ensure that issues potentially impacting nuclear safety are promptly identified and fully evaluated.
Actions are also taken to address the issues in a timely manner. The QCNPS corrective actions were
narrowly focused on individual specific deficiencies rather than the broader issue of inaccurate fire plans.
The staff recognizes that this finding had very low safety significance.