ML13127A451
| ML13127A451 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 05/30/2013 |
| From: | Blake Purnell Plant Licensing Branch III |
| To: | Pacilio M Exelon Generation Co |
| Miller E, NRR/JLD, 415-2481 | |
| References | |
| TAC MF0270, TAC MF0271 | |
| Download: ML13127A451 (9) | |
Text
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 30, 2013 Mr. Michael J. Pacilio Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
PLAN FOR THE REGULATORY AUDIT REGARDING FLOODING WALKDOWNS TO SUPPORT IMPLEMENTATION OF NEAR-TERM TASK FORCE RECOMMENDATION 2.3 RELATED TO THE FUKUSHIMA DAI-ICHI NUCLEAR POWER PLANT ACCIDENT - QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 (TAC NOS. MF0270 AND MF0271)
Dear Mr. Pacilio:
On March 12, 2012, the U.S. Nuclear Regulatory Commission (NRC) issued a letter requesting information per Title 10 of the Code of Federal Regulations, Paragraph 50.54(f) (50.54(f) letter). The 50.54(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11,2011, Great Tohoku Earthquake and subsequent tsunami. The request addressed, in part, the methods and procedures for plants to conduct flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures. By letter dated November 27,2012, Exelon Generation Company, LLC submitted a flooding walkdown report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the 50.54(f) letter for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. The NRC staff plans to conduct a regulatory audit to gain a better understanding of the methods and procedures used by QCNPS to conduct the flooding walkdowns and facilitate NRC staff review of the walkdown report. The audit will be conducted at QCNPS from July 9-12,2013, in accordance with the enclosed regulatory audit plan.
M. Pacilio - 2 If you have any questions, please contact me by telephone at 301-415-1380 or bye-mail at blake.purnell@nrc.gov. Sincerely, Blake A. Purnell, Project Manager Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-254 and 50-265
Enclosure:
Audit Plan cc w/encl: Distribution via Listserv
Audit Plan Flooding Walkdown Review for Quad Cities Nuclear Power Station, Units 1 and 2 Audit Date: July 9-12, 2013 Japan Lessons Learned Project Directorate Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ENCLOSURE
Audit Plan Quad Cities Nuclear Power Station, Units 1 and 2
- 1.
Background
On March 12, 2012, the U.S. Nuclear Regulatory Commission staff (NRC) issued a letter1 requesting information per Title 10 to the Code of Federal Regulations, Paragraph 50.54(f) (50.54(f) letter). The 50.54(f) letter was issued to power reactor licensees and holders of construction permits requesting addressees to provide further information to support the NRC staff's evaluation of regulatory actions to be taken in response to lessons learned from Japan's March 11, 2011, Great Tohoku Earthquake and subsequent tsunami. The request addressed, in part, the methods and procedures for plants to conduct flooding hazard walkdowns to identify and address degraded, nonconforming, or unanalyzed conditions through the corrective action program, and to verify the adequacy of the monitoring and maintenance procedures. By letter dated November 27,2012, Exelon Generation Company, LLC (the licensee) submitted a flooding walkdown report as requested per Enclosure 4, "Recommendation 2.3: Flooding," of the 50.54(f) letter for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2.
- 2.
Regulatory Audit Bases The NRC staff intends to conduct a regulatory audit to gain a better understanding of the methods and associated procedures used by the licensee to conduct the flooding walkdowns at QCNPS and facilitate NRC staff review of the walkdown report. Guidance for performing the flooding walkdowns was developed by the Nuclear Energy Institute (NEI) with extensive review and input from NRC staff in numerous public meetings, webinars, and public conference calls during its development. NEI submitted NEI 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features" (walkdown guidance)3 for endorsement, and the staff subsequently endorsed the walkdown guidance by letter dated May 31, 20124. By letter dated June 11, 2012,5 the licensee indicated that they would utilize the NRC-endorsed guidance in the performance of the walkdowns at QCNPS. The 50.54(f) letter and the walkdown guidance are used as the basis documents upon which this regulatory audit is to be performed.
- 3.
Regulatory Audit Scope The scope of this regulatory audit for QCNPS is to examine relevant flooding walkdown documents, interview flooding walkdown participants, observe areas of the plant walked down, review and understand how the reasonable simulations were performed as part of the walkdowns (if applicable), and examine other relevant materials used to conduct the flooding walkdowns. This will assist the staff in identifying whether the flood walkdowns were conducted in accordance with the walkdown guidance and the 50.54(f) letter. The NRC staff will request additional information using the appropriate regulatory process. 1 The 50.54(f) letter is available in the Agencywide Document Access and Management System (ADAMS) under Accession No. ML12053A340. 2 QCNPS flooding walkdown report is available in ADAMS under Accession No. ML12332A307. 3 NEI 12-07 is available ADAMS under Accession No. ML12144A401. 4 The NRC endorsement of NE112-07 is available in ADAMS under Accession No. ML12144A142. 5 The licensee's letter is available in ADAMS under Accession No. ML12164A569.
-2 The NRC staff reviewed the walkdown report for aCNPS and compared it with the requested information in the 50.54(f) letter and the walkdown guidance. The factors that the NRC staff considered in choosing sites to audit were: Lack of clarity as to how the walkdown was consistent with the guidance based on the review of the walkdown report. Plant-specific areas of interest identified during review of the walkdown report.
- Feedback and information gained during performance of regional inspections (e.g.,
Temporary Instruction 2515/187).
- 4.
Information needs The licensee is requested to have the following documentation available on site for the audit team. The documentation may be provided electronically or by paper copies. If provided electronically, the licensee is requested to have at least three computers available for the audit team with a printer attached.
- Walkdown record forms (as described in Appendix B of NEI 12-07) and other supplemental forms and worksheets used to document observations from performance of the walkdowns, including reasonable simulation worksheets (as described in Section C of the licensee walkdown submittal) and the basis for the time estimates provided in Table 2 of the licensee walkdown submittal.
Supplemental guidelines or procedures used, in addition to NEI 12-07, for the implementation of the flooding walkdowns, including industry, fleet, or site-specific guidelines or procedures (this includes, but is not limited to, "Walkdown Inspection Guidance" developed by the licensee to supplement NEI 12-07 and any site-specific acceptance criteria developed to support the walkdowns). Flood-specific procedures that are part of flood protection and mitigation strategy and hazardous weather response that were reviewed as part of the flood walkdowns, including, but not limited to, flood barrier drawings (FL-1 through FL-52) and the following: aCOA 0010-16, Flood Emergency Procedure, Revisions 15, 16, and 17 MA-AB-756-600, Reactor Disassembly acop 0201-06, Filling the Reactor Vessel/Reactor Cavity using the Core Spray System acop 4100-11, Using Diesel Fire Pumps via Safe Shutdown Hose Line for Reactor Vessel Level Control or Flood Emergency Injection Source acop 4300-08, Makeup Demineralizer System Mobile Demineralizer
-3
- Listing of entries into the corrective action program resulting from the performance of the flood walkdowns, including condition report number, title, and brief summary of the issue or observation and its disposition.
Documentation of the basis that there is reasonable assurance that inaccessible features are available and will perform credited functions, including inaccessible penetrations and seals that were not visually inspected during the walkdown. Additional information needs identified during the audit will be communicated to the designated point of contact. The NRC staff also requests the licensee to make personnel who performed the walkdowns (including site personnel and contractors) accessible upon request (either in person or by phone). The personnel should be able to answer questions about: (1) how the visual inspections and reasonable simulations were performed; (2) how the available physical margins were determined; and (3) discuss engineering analyses that were developed in support of the walkdown.
- 5.
Team Assignments
- '1 1"',,
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- "".', '1' ~,'.1/
"(<<:">>,, I," "'h,i '*.i.l~~~~g~'~l~utlitor Team Lead Stephen Campbell (NRC) Flooding Walkdown Technical Lead Michelle Bensi (NRC) Flooding Technical Support Peter Chaput (NRC) Flooding Technical Support Joseph Kanney (NRC) Technical Support Brian Cushman (NRC) Flooding Technical Support TBD (ORNL)
- 6.
Logistics The audit will be conducted at QCNPS from July 9-12, 2013. Entrance and exit briefings will be held at the beginning and end of this audit, respectively. The licensee is requested to provide a room for the use of the audit team. A more detailed proposed audit schedule is attached.
- 7.
Deliverables An audit report or summary will be issued to the licensee within 90 days from the end of the audit. Additionally, the results of the audit will be utilized to focus the scope of any requests for additional information issued in the course of this review.
Proposed Quad Cities Nuclear Power Station July 9,2013 A.M. P.M. July 10,2013 A.M. P.M. Flooding Walkdown Audit Schedule July 9-12, 2013
- 8:30 a.m. Check-in at site - receive badges, meet licensee contact(s),
and setup for entrance meeting.
- 9:30 a.m. Entrance Meeting - introductions, audit activities and goals, and audit logistics.
- 10:30 a.m. NRC Team Breakout - staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown.
- 1 :00 p.m. Discussion with QCNPS on flooding walkdown methodology
- 3:30 p.m. Audit Team Caucus
- 5:00 p.m. NRC I Licensee Interim Meeting
- 6:00 p.m. Audit Team Daily Closeout
- 8:00 a.m. NRC Team Breakout - staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown.
- 10:00 a.m. Plant walkdown - walkdown reasonably accessible areas in accordance with ALARA.
- 1 :30 p.m. Discussion(s) with QCNPS flooding walkdown team members and contractors
- 4:00 p.m. Audit Team Caucus
- 5:00 p.m. NRC I Licensee Interim Meeting
- 6:00 p.m. Audit Team Daily Closeout
-2 July 11. 2013 A.M. P.M. July 12.2013 A.M.
- 8:00 a.m. NRC Team Breakout - staff review of procedures, basis documents and reports related to licensees conduct of flooding walkdown.
- 10:00 a.m. Plant walkdown - walkdown reasonably accessible areas in accordance with ALARA.
- 1 :30 p.m. Discussion(s) with QCNPS flooding walkdown team members and contractors
- 4:00 p.m. Audit Team Caucus
- 5:00 p.m. NRC I Licensee Interim Meeting
- 6:00 p.m. Audit Team Daily Closeout
- 9:00 a.m. NRC I Licensee Exit Meeting.
ML13127A451 OFFICE DORULPL3-2/PM JLD/PMB/PM DORULPL3-2/LA NRO/DSEAlRHMB NAME BPurnell GEMiller SRohrer PCha ut DATE 5/09/2013 5121/2013 5/09/2013 5/09/2013 OFFICE ' NROIDSEAlRHMB/BC DORULPL3-2/BC DIRSIIRIB DORULPL3-2/PM DATE CCook NAME 51 30 12013 JBowen SCampbell -'--------+ 51 09 12013 12013
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