|
|---|
Category:Letter
MONTHYEARIR 05000254/20230042024-02-0505 February 2024
Integrated Inspection Report 05000254/2023004 and 05000265/2023004
ML24004A0052024-01-17017 January 2024
Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0042 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting))
RS-24-001, Response to Request for Additional Information Regarding Relief Request I5R-26, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval2024-01-0303 January 2024
Response to Request for Additional Information Regarding Relief Request I5R-26, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval
IR 05000254/20234032023-12-22022 December 2023
Public- Quad Cities Nuclear Power Station Security Baseline Inspection Report 05000254/2023403 and 05000265/2023403
IR 05000254/20230102023-12-20020 December 2023
Comprehensive Engineering Team Inspection Report 05000254/2023010 and 05000265/2023010
ML23349A1622023-12-17017 December 2023
Issuance of Amendment Nos. 298 and 294 Increase Completion Time in Technical Specification 3.8.1.B.4 (Emergency Circumstances)
RS-23-128, Response to Request for Additional Information for the Emergency License Amendment Request Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days2023-12-15015 December 2023
Response to Request for Additional Information for the Emergency License Amendment Request Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days
ML23305A1402023-12-13013 December 2023
Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580
RS-23-123, Emergency License Amendment Request - Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days2023-12-13013 December 2023
Emergency License Amendment Request - Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days
ML23339A1762023-12-0505 December 2023
Notification of NRC Baseline Inspection and Request for Information (05000265/2024001)
ML23319A3342023-11-20020 November 2023
Regulatory Audit in Support of License Amendment Requests to Adopt TSTF 505, Revision 2 and 10 CFR 50.69
RS-23-104, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-17017 November 2023
Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation
ML23317A1192023-11-10010 November 2023
Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums
IR 05000254/20230032023-11-0909 November 2023
Integrated Inspection Report 05000254/2023003 and 05000265/2023003
RS-23-113, Submittal of Updated Final Safety Analysis Report (Ufsar), Revision 17 and Fire Protection Report (Fpr), Revision 262023-10-20020 October 2023
Submittal of Updated Final Safety Analysis Report (Ufsar), Revision 17 and Fire Protection Report (Fpr), Revision 26
RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023
Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans
ML23206A0382023-09-21021 September 2023
Proposed Alternative to the Requirements of the ASME Code
IR 05000254/20230112023-09-20020 September 2023
Safety-Conscious Work Environment Issue of Concern Team Inspection Report 05000254/2023011 and 05000265/2023011
RS-23-089, Sixth Ten-Year Interval Inservice Testing Program2023-09-0505 September 2023
Sixth Ten-Year Interval Inservice Testing Program
RS-23-080, Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs2023-08-30030 August 2023
Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-264-A, Revision 0, 3.3.9 and 3.3.10 - Delete Flux Monitors Specific Overlap Requirement SRs
RS-23-086, Relief Request I5R-26, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval2023-08-28028 August 2023
Relief Request I5R-26, Inservice Inspection Program Relief Request Regarding Examination Coverage for the Fifth Inservice Inspection Interval
SVP-23-038, Owner'S Activity Report Submittal Fifth 10-Year Interval 2023 Refueling Outage Activities2023-08-14014 August 2023
Owner'S Activity Report Submittal Fifth 10-Year Interval 2023 Refueling Outage Activities
IR 05000254/20230022023-08-0808 August 2023
Integrated Inspection Report 05000254/2023002 and 05000265/2023002
ML23178A0742023-08-0707 August 2023
Issuance of Amendment Nos. 296 and 292 Adoption of TSTF-416 Low Pressure Coolant Injection (LPCI) Valve Alignment Verification Note Location
ML23216A0362023-08-0707 August 2023
Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and RFI
ML23216A0562023-08-0404 August 2023
Information Meeting (Open House) with a Question and Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Quad Cities Nuclear Power Station, Units 1 and 2
SVP-23-031, Regulatory Commitment Change Summary Report2023-07-14014 July 2023
Regulatory Commitment Change Summary Report
ML23181A1062023-06-30030 June 2023
Postponement- Information Meeting (Open House) with a Question-And-Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Quad Cities Nuclear Power Station
ML23178A2422023-06-28028 June 2023
Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III
ML23179A1932023-06-28028 June 2023
07122023 Letter-Significant Public Meeting to Discuss NRC End-of-Cycle Performance Assessment of Quad Cities Nuclear Plant for Performance for 2022 Calendar Year
IR 05000254/20234012023-06-26026 June 2023
Cyber Security Inspection Report 05000254/2023401 and 05000265/2023401
IR 05000265/20230402023-06-22022 June 2023
Reissue Quad Cities Nuclear Power Station 95001 Supplemental Inspection Supplemental Report 05000265/2023040 and Follow Up Assessment Letter
RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023
Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations
ML23167B1722023-06-16016 June 2023
95001 Supplemental Inspection Report 05000265/2023040 and Follow-Up Assessment Letter
RS-23-060, Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors2023-06-0808 June 2023
Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors
RS-23-059, License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b2023-06-0808 June 2023
License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b
ML23144A3632023-05-26026 May 2023
Information Meeting (Open House) with a Question and Answer Session to Discuss NRC 2022 End-of-Cycle Plant Performance Assessment of Quad Cities Nuclear Power Station, Units 1 and 2
RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023
Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling
ML23033A4042023-05-15015 May 2023
Exemption from the Requirements of 10 CFR Part 2, Section 2.109(B) Related to Submission of Subsequent License Renewal Application Letter
IR 05000254/20234022023-05-15015 May 2023
Security Baseline and ISFSI Inspection Reports 05000254/2023402, 05000265/2023402, 07200053/2023401
ML23132A2022023-05-12012 May 2023
Annual Radiological Environmental Operating Report
ML23125A0612023-05-0808 May 2023
Proposed Alternative to the Requirements of the ASME Code
IR 05000254/20230012023-05-0808 May 2023
Integrated Report 05000254/2023001 and 05000265/2023001
RS-22-067, 10 CFR 50.46 Annual Report2023-05-0404 May 2023
10 CFR 50.46 Annual Report
ML23118A3472023-05-0101 May 2023
County, 1 & 2; Nine Mile Point, 2; and Quad Cities, 1 & 2 - Correction of Amendment No. 193 Adoption of TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration EPID L-2022-LLA-0143
RS-23-068, Response to Request for Additional Information for Quad Cities Relief Request I6R-11, Proposed Alternatives for a Temper Bead Weld Repair of the Mating Surfaces of the Reactor Pressure Vessel Head and Shell2023-04-28028 April 2023
Response to Request for Additional Information for Quad Cities Relief Request I6R-11, Proposed Alternatives for a Temper Bead Weld Repair of the Mating Surfaces of the Reactor Pressure Vessel Head and Shell
SVP-23-018, Radioactive Effluent Release Report for 20222023-04-28028 April 2023
Radioactive Effluent Release Report for 2022
ML23114A2522023-04-28028 April 2023
Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI
ML23110A0622023-04-25025 April 2023
Transmittal of Final Quad Cities Nuclear Power Plant, Unit 1 Accident Sequence Precursor Report (Licensee Event Report 254-2022-001)
ML23081A0382023-04-25025 April 2023
County, 1 & 2; Nine Mile Point, 2; and Quad Cities, 1 & 2 - Issuance of Amendments to Adopt TSTF-306, Rev. 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration
2024-02-05
[Table view] |
See also: IR 05000265/2017001
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION III
2443 WARRENVILLE RD. SUITE 210
LISLE, ILLINOIS 60532-4352
March 9, 2018
David A. Lochbaum
Director, Nuclear Safety Project
Union of Concerned Scientists
PO Box 15316
Chattanooga, TN 37415
SUBJECT: NRC RESPONSE TO UNION OF CONCERNED SCIENTISTS COMMENTS
REGARDING QUAD CITIES NUCLEAR POWER STATION, UNIT 2, HIGH
PRESSURE COOLANT INEJCTION LICENSEE EVENT REPORT
05000265/2017-001-00
Dear Mr. Lochbaum:
On July 26, 2017, the Region III office received a letter from you (ML17321A947) providing
comments based upon your review of Licensee Event Report (LER) 05000265/2017-001-00 for
Quad Cities Nuclear Power Station, Unit 2 (ML17194A817). This licensee event report is
related to an event that occurred on May 15, 2017. As stated in the report, the High Pressure
Coolant Injection (HPCI) system minimum flow valve did not open as expected during HPCI
system testing. Based upon our review of the LER and the specific HPCI system issue, the
inspectors concluded that the licensee immediately declared the HPCI system inoperable,
entered the appropriate Technical Specification Limiting Condition for Operation, replaced a
failed flow switch, and returned the HPCI system to service within the Technical Specification
allowed completion time.
As you are likely aware, letters to senior NRC officials are generally placed into ADAMS as
publically available documents unless there is a reason to exclude the letter from ADAMS.
Several weeks before your letter was received by our prior Regional Administrator, Cynthia
Pederson, the Quad Cities HPCI issue was under review by our resident inspectors. Shortly
after receiving your email, I and several members of the NRC staff conducted a phone call with
you to determine if our understanding of the issue was the same as yours. The result was that
we (you and the NRC) had a similar understanding of the issue and you provided no information
that would prompt us to modify our inspection of this issue; therefore, your letter was placed in
ADAMS as publically available. Ms. Pederson has since retired and Mr. K. Steven West has
been appointed as the Region III Regional Administrator. I have discussed your letter with him,
and he has authorized me to respond for him. This response will be placed into ADAMS as a
publically available document.
In your letter, you raised three concerns:
1. The licensee made two seemingly contradictory statements in the LER related to
whether the HPCI system minimum flow valve failure is an event or condition that could
have prevented the fulfillment of its safety function. Additionally, you questioned why the
licensee did not retract the LER if they determined that the event would not have
affected a safety function.
D. Lochbaum -2-
2. The licensee stated that the failure of the minimum flow valve to open did not contribute
to an increase in risk since the operation of the minimum flow valve was not modeled in
the plants Probabilistic Risk Assessment (PRA). You referenced NUREG/CR-5934,
High Pressure Coolant Injection System Risk-Based Inspection Guide for Quad-Cities
Station, Units 1 and 2, and questioned whether this conclusion was appropriate.
3. The licensee stated that the HPCI system had a 10-minute mission time. You
questioned whether it is acceptable for the licensee to consider only one short-duration
design basis event and exclude all longer duration events when assessing safety
impacts.
The NRC staff has reviewed your concerns and provides our assessment below. We note that
the event described in the LER was under review by the NRC resident inspectors at the time we
received your letter.
Concern 1 - Contradictions Regarding Loss of Safety Function
The NRC reviewed the information provided in LER 2017-001, including the potential
contradictory information regarding the loss of safety function, and discussed this information
with the licensee. The NRC determined that the HPCI system was declared inoperable due to a
note in the surveillance procedure acceptance criteria. After declaring the HPCI system
inoperable, the licensee reported the HPCI system inoperability to the NRC in accordance with
the guidance provided in NUREG-1022, Event Report Guidelines, Revision 3, Section 3.2.7,
Event of Conditions that Could have Prevented the Fulfillment of a Safety Function. After
determining the cause of this event, the licensee performed an engineering evaluation as
discussed in NEI 99-02, Regulatory Assessment Performance Indicator Guideline, and
concluded that this event did not constitute a safety system functional failure because the HPCI
system remained available to perform its specified safety function. This conclusion was based
upon information provided by General Electric demonstrating that the HPCI system would
continue to function even though the HPCI system minimum flow valve was not operating as
expected.
The NRCs review of the LER is documented in Section 4OA3 of Integrated Inspection
Report 05000254/2017004 and 05000265/2017004 (ML18047A566). The inspectors reviewed
the licensees engineering analysis and agreed with their conclusion that HPCI remained able to
perform its safety function. In this instance, despite the conclusion of licensees engineering
assessment, the NRC does not require retraction of LERs if the system is later determined to
have always been operable. The inspectors review retracted event notifications to validate the
licensees conclusions and basis for the retraction. In addition, the inspectors review the safety
system functional failure performance indicator once per year, and this event would be in the
scope of that review.
Concern 2 - Risk Perspectives
As noted in the LER, the licensee stated the HPCI minimum flow valve was not credited in the
plants PRA and therefore did not contribute to an increase in risk. The NRC staff agrees that
this statement alone would not be an adequate justification for determining the risk significance
of the event. However, the licensee also stated in the LER that the overall safety significance
and risk impact of the event was minimal due to the fact that the HPCI system was available to
perform its safety function.
D. Lochbaum -3-
The inspectors reviewed the licensees evaluation and found it to be in accordance with
NUREG/CR-5934. Specifically, Section 6.14 discusses that the medium risk aspect of a HPCI
minimum flow valve failure is due to a coincident normally open pump discharge valve failing
closed or becoming plugged. With respect to the issue discussed in the LER, the pump
discharge valve operated as expected. The NRC staff did not identify any additional concerns
with the licensees risk evaluation.
Concern 3 - Mission Time
As stated previously, the licensee ultimately determined that the HPCI system remained
operable and available to inject in the event of a loss of coolant accident. The NRC did not
identify any concerns with the licensees assessment. As part of the LER review, the NRC also
noted the statement regarding the HPCI mission time. This event and the condition of the
minimum flow valve had no impact on the HPCI systems function or the systems ability to
continue to run, and therefore the inspectors did not pursue the mission time statement further,
other than noting the 10 minute mission time was as described in the licensees UFSAR.
The 10 minute time is based on a limited set of event scenarios, as described in the licensees
fuel analysis, in which HPCI operates for 10 minutes and then other systems are used to
mitigate the postulated event. Finally, the NRC significance determination process generally
uses a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> mission time and if HPCI could not meet this mission time successfully due to a
performance deficiency, the NRC would assess the significance using this process and mission
time.
Thank you for communicating your comments to the Region III office. If you have any
questions, please contact me at 630-829-9731 or via e mail at karla.stoedter@nrc.gov.
Sincerely,
/RA/
Karla K. Stoedter
Chief, Branch 1
Division of Reactor Projects
D. Lochbaum -4-
Letter to David A. Lochbaum from Karla K. Stoedter dated March 9, 2018
SUBJECT: NRC RESPONSE TO UNION OF CONCERNED SCIENTISTS COMMENTS
REGARDING QUAD CITIES NUCLEAR POWER STATION, UNIT 2, HIGH
PRESSURE COOLANT INEJCTION LICENSEE EVENT REPORT
05000265/2017-001-00
DISTRIBUTION:
Jeremy Bowen
RidsNrrDorlLpl3
RidsNrrPMQuadCities Resource
RidsNrrDirsIrib Resource
Steven West
Darrell Roberts
Richard Skokowski
Allan Barker
DRPIII
DRSIII
ROPassessment.Resource@nrc.gov
ADAMS Accession Number: ML18068A147
OFFICE RIII RIII
NAME JHeller:lg KStoedter
DATE 3/1/2018 3/2/2018
OFFICIAL RECORD COPY
