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 Days
| ML23349A033 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 12/15/2023 |
| From: | Humphrey M Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-23-128 | |
| Download: ML23349A033 (1) | |
Text
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office
10 CFR 50.90 10 CFR 50.91(a)(5)
RS-23-128 December 15, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265
Subject:
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
References:
- 1. Letter from M. Humphrey (Constellation Energy Generation, LLC) to U.S.
NRC, "Emergency License Amendment Request - Increase Technical Specifications Completion Time in TS 3.8.1.B.4 from 7 Days to 30 Days,"
dated December 13, 2023 (ADAMS Accession No. ML23347A217)
- 2. Email from R. Kuntz (U.S. NRC) to R. L. Steinman (Constellation Energy Generation, LLC), "RE: DRAFT Request for Additional Information RE:
Quad Cities Emergency Amendment Related to Unit 1 Diesel Generator Inoperability," dated December 14, 2023 In Reference 1, Constellation Energy Generation, LLC (CEG) requested an emergency amendment to the Technical Specifications (TS) for Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2. The proposed change to TS 3.8.1, "AC Sources - Operating" is being requested on an emergency basis pursuant to 10 CFR 50.91 (a)(5). The original proposed change extends the TS 3.8.1 Required Action B.4 Completion Time from 7 days to 30 days.
The extended completion time is only applicable to the Unit 1 emergency diesel generator failure that occurred on December 11, 2023. The proposed change also suspends surveillance testing of the Unit 2 and 1/2 DG during the extended period when the Unit 1 DG is inoperable.
The NRC requested additional information that is needed to complete review of the change proposed in Reference 2. The response to this request is provided in Attachment 1. As described in Attachment 1, CEG has revised the proposed change to extend the TS 3.8.1 Required Action B.4 Completion Time from 7 days to 14 days (instead of 30 days).
December 15, 2023 U.S. Nuclear Regulatory Commission Page 2 CEG has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of Reference 1. The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the additional information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Ms. Rebecca L. Steinman at (779) 231-6162.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 15th day of December 2023.
Respectfully, Mark Humphrey Senior Manager Licensing Constellation Energy Generation, LLC Attachments:
- 1. Response to Request for Additional Information
- 2. Revised Mark-up of QCNPS Technical Specifications Pages
- 3. Clean QCNPS Technical Specifications Pages
- 4. Compensatory Actions for One-Time CT Extension for TS 3.8.1.B.4 cc:
NRC Regional Administrator, Region III NRC Senior Resident Inspector, Quad Cities Nuclear Power Station NRC Project Manager, Quad Cities Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety
- Humphrey, Mark D.
Digitally signed by Humphrey, Mark D.
Date: 2023.12.15 07:39:42
-06'00'
ATTACHMENT 1 Response to Request for Additional Information
Page 1 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO REVISE THE TECHNICAL SPECIFICATIONS TO ALLOW EXTENSION FOR TS 3.8.1 REQUIRED ACTION B.4 COMPLETION TIME QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-254 AND 50-265 (EPID NO. L-2023-LLA-0171)
Regulatory Requirements and Guidance Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, "Technical specifications,"
requires, in part, that the applicants for a license authorizing operation of a production or utilization facility must include in their application proposed TSs in accordance with the requirements of 10 CFR 50.36. 10 CFR 50.36(c) requires that TS include items in five specific categories related to station operation. These categories are (1) Safety limits, limiting safety system settings, and limiting control settings, (2) Limiting conditions for operation (LCOs), (3)
Surveillance requirements (SRs), (4) Design features, and (5) Administrative controls. The proposed change to the Quad Cities TSs relates to the LCO and SRs categories.
10 CFR, Section 50.63, Loss of All Alternating Current Power, requires that each light-water-cooled nuclear power plant to be able to withstand and recover from a station blackout (i.e., loss of the offsite electric power system concurrent with reactor trip and unavailability of the onsite emergency alternating current electric power system) of a specified duration. The 10 CFR 50.63 requirements provide assurance that necessary operator actions can be performed and that necessary control room -area equipment will be functional under the expected environmental conditions during and following a station blackout, thereby ensuring that the core will be cooled and appropriate containment integrity will be maintained.
NUREG-0800, Branch Technical Position (BTP) 8-8, "Onsite (Emergency Diesel Generators) and Offsite Power Sources Allowed Outage Time Extensions," (ML113640138) provides guidance, from a deterministic perspective, for reviewing an Emergency Diesel Generators (EDGs) outage time extension request up to 14 days. Although the requested extension for the Required Action B.4 completion time exceeds 14 days, for defense-in-depth review purpose, the NRC staff uses the guidance in BTP 8-8 to review the proposed change. It should be noted that the terms allowed outage time (AOT) and completion time (CT) are interchangeable.
Request for Additional Information (RAI) #1 Describe the plant response in case of following scenario:
x Total loss of offsite power (LOOP) concurrent with EDG-1 (for connection to Bus 14-1) out of service and the common EDG (EDG-1/2) starts but fails to connect to Bus 13-1, thus resulting in a station blackout (SBO) of Unit 1.
ATTACHMENT 1 Response to Request for Additional Information
Page 2 Describe whether the SBO DG-1 can be aligned and connected to Bus 14-1 in requisite time to bring the Unit 1 to Mode 3 or cold shutdown in case of extended LOOP.
Constellation Response to RAI #1 The expected performance time for starting the Unit 1 SBO and providing power to Bus 14-1 is 4.32 minutes. Additionally, in the event of a failure of remote functionality from the Main Control Room, local start of the Unit 1 SBO DG is assumed to be dispatched within 10 minutes, with an expected execution time of 18.7 minutes, leading to a total time of 28.7 minutes against a required completion time of 40 minutes for PRA availability in this condition. The shutdown time per the fire protection report is 32 minutes; therefore, there is reasonable assurance that the Unit 1 SBO DG would be started within this time period.
RAI #2 Describe the following:
a)
Clarification that the SBO DG will be used as the AAC power source (described in BTP 8-8) during the proposed extended CT.
b)
How frequent the SBO DGs are tested to ensure their availability when required?
c)
When were the most recent SBO DGs successfully tested?
d)
What is the approximate onsite fuel capacity, in terms of days/hours, for operating the EDGs and SBO DGs, before the additional fuel supply from an offsite source is needed?
Constellation Response to RAI #2 a) On a loss of Bus 14-1, operators would take the following actions - in order of preference -
to energize Bus 14-1 (assuming Bus 14-1 in not faulted and the Unit 1 EDG is unavailable):
- 1. Close crosstie breaker from Bus 24-1 to 14-1 which could be fed from the unit auxiliary transformer (T21), reserve auxiliary transformer (T22), Unit 2 EDG, or Unit 2 SBO.
- 2. Start and load the Unit 1 SBO Diesel Generator to Bus 14-1.
b) The SBO diesel generators (DGs) are tested quarterly.
c) The Unit 1 SBO DG was last tested for a two-hour loaded run on November 4, 2023 at 1326 CST. Even though this test was performed slightly outside of the BTP 8-8 suggested window of 30 days, there is reasonable assurance that the Unit 1 SBO will start and load.
d) Both Fuel Oil Day Tanks (1,200 gallon capacity per tank) provide an immediate source of fuel oil to the SBO DG engine. Each day tank contains enough fuel for about 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of single unit operation at 100% load without refilling. The shared filled storage tank has
ATTACHMENT 1 Response to Request for Additional Information
Page 3 enough fuel to operate both SBO DGs at 100% load for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The SBO DG fuel oil storage tank holds 15,000 gallons, measured at 85% on December 14, 2023. The SBO DG burns 325 gal/hr at a normal load of 4350 KW, far above an EDG load of 2600 KW.
This would equate approximately 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> at full load before refueling for a single SBO DG.
The SBO DG is considered functional above 30% tank level to meet the mission time of the SBO.
There is an additional 13,500 gallons available in the Unit 1 EDG fuel oil storage tank that can be transferred to the SBO fuel oil storage tank that would not be needed for any other credited source. This would provide an additional 41 hours4.74537e-4 days <br />0.0114 hours <br />6.779101e-5 weeks <br />1.56005e-5 months <br /> of full SBO load at 4350 KW once transferred to the SBO storage tank. This fuel is transferred with various methods of portable transfer pumps credited for FLEX.
RAI #3 TS LCO 3.8.1 states, in part:
The following AC electrical power sources shall be OPERABLE:
- d. The opposite unit's DG capable of supporting the equipment required to be OPERABLE by LCO 3.6.4.3, LCO 3.7.4 (Unit 2 only), and LCO 3.7.5 (Unit 2 only).
Describe the impact of the proposed change to the opposite units equipment (Unit 2) supported by EDG-1 (and required to be OPERABLE by LCO 3.6.4.3) during the extended completion time for EDG-1 and how to mitigate such impacts if any.
Constellation Response to RAI #3 The SGT System consists of two fully redundant subsystems (A and B) that are shared between Units 1 and 2, each with its own set of ductwork, dampers, charcoal filter train, and controls. LCO 3.6.4.3, Standby Gas Treatment (SGT) System addresses operability of A and B SGT. A SGT is powered from Unit 2, Division II, Bus 29 (i.e., the Unit 2 EDG during a LOOP event). B SGT is powered from Unit 1, Division II (i.e., the Unit 1 EDG during a LOOP event).
Start of B SGT would be delayed due to manual initiation of the Unit 1 SBO supplying power to Bus 14-1 which will take approximately 4 minutes and 32 seconds. The 'A' SBGT train would be expected to have auto-started on low flow in this time frame if power is available to MCC 29-4 to support this key safety function. Since A SGT is independent of B SGT and the Unit 1 EDG it will meet the post-accident requirements for SGT.
LCO 3.7.4, Control Room Emergency (CREV) System and LCO 3.7.5, Control Room Emergency Ventilation Air Conditioning (AC) System are powered from Unit 1, Division I (Bus 18). Ordinarily, the Unit 1 DG can supply power to Bus 18 via the Bus 18 and 19 crosstie.
In addition, the 1/2 DG can promptly supply power to Bus 18. Alternatively, the Unit 1 SBO can also supply Bus 18 once it is loaded to Bus 14-1, Bus 19, and with the Bus 18 and 19 crosstie closed.
ATTACHMENT 1 Response to Request for Additional Information
Page 4 RAI #4 Section B of BTP 8-8 states, in parts:
The TS must contain Required Actions and Completion Times to verify that the supplemental AC [alternating current] source is available before entering extended AOT.
The availability of AAC [alternate alternating current] or supplemental power source shall be checked every 8-12 hours (once per shift). If the AAC or supplemental power source becomes unavailable any time during extended AOT, the unit shall enter the LCO and start shutting down within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This 24-hour period will be allowed only once within any given extended EDG AOT.
The availability of AAC or supplemental power source should be verified within the last 30 days before entering extended AOT by operating or bringing the power source to its rated voltage and frequency for 5 minutes and ensuring all its auxiliary support systems are available or operational.
The TS markup in the LAR does not provide the AAC power source(s) and associated Required Action and Completion Time as a condition to enter the extended CT.
Describe the Required Action and Completion Time of TS 3.8.1, Required Action B.4 when the AAC power source(s) (i.e., SBO DG) becomes unavailable during the extended CT.
Constellation Response to RAI #4 Rounds on the SBO will be changed to shiftly (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) to provide increased monitoring on this supporting AAC system during the extended CT period. This is captured as a compensatory action in Attachment 4.
As stated in the response to RAI #2, the preference for energizing Bus 14-1 would be to use the crosstie from Bus 24-1 which could be fed from unit aux transformer (T21), reserve auxiliary transformer (T22), Unit 2 EDG, or Unit 2 SBO. If the crosstie to Bus 24-1 were not available, either due to a loss of power to the bus or a failure of the crosstie itself, then operators would proceed to energize Bus 14-1 with the Unit 1 SBO DG. In the event the Unit 1 SBO DG becomes unavailable during the extended CT period, the crosstie options would be evaluated as a supplemental power source. If none of these options were available, the unit shall start shutting down within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. See the response to RAI #2 for the details regarding the last Unit 1 SBO DG load test.
RAI #5 Section B of BTP 8-8 states, in part:
Additionally, the staff expects that the licensee will provide the following Regulatory Commitments:
ATTACHMENT 1 Response to Request for Additional Information
Page 5 The extended AOT will be used no more than once in a 24-month period (or refueling interval) on a per diesel basis to perform EDG maintenance activities, or any major maintenance on offsite power transformer and bus.
The preplanned maintenance will not be scheduled if severe weather conditions are anticipated.
The system load dispatcher will be contacted once per day to ensure no significant grid perturbations (high grid loading unable to withstand a single contingency of line or generation outage) are expected during the extended AOT.
Component testing or maintenance of safety systems and important non safety equipment in the offsite power systems that can increase the likelihood of a plant transient (unit trip) or LOOP will be avoided. In addition, no discretionary switchyard maintenance will be performed.
TS required systems, subsystems, trains, components, and devices that depend on the remaining power sources will be verified to be operable and positive measures will be provided to preclude subsequent testing or maintenance activities on these systems, subsystems, trains, components, and devices.
Steam-driven emergency feed water pump(s) in case of PWR units, and Reactor Core Isolation Cooling and High Pressure Coolant Injection systems in case of BWR units, will be controlled as protected equipment.
Describe the proposed compensatory actions similar to the above which will be applicable prior to and during the CT extension.
Constellation Response to RAI #5 The proposed change is a one-time extension, so the first bullet from BTP 8-8 does not apply to this QCNPS request. All other proposed compensatory actions applicable prior to and during the CT extension are captured in Attachment 4.
RAI #6 The LAR does not explain why the repairs of EDG-1 needs 30 days to complete. Provide justification for the requested CT extension to 30 days.
Constellation Response to RAI #6 The duration required to safely implement repairs to EDG-1 may exceed 7 days due to the performance of extensive Unit 1 DG circuit and equipment testing and limited parts availability associated with the affected components. Additional information available since the initial submittal has determined that a CT extension of 14 days would be sufficient for performance of the currently understood scope of repair work. The TS mark-ups in Attachment 2 reflect this change in the requested extension of the CT as well as the changes described in the responses to RAIs #7 and #10.
ATTACHMENT 1 Response to Request for Additional Information
Page 6 RAI #7 The LAR proposed to suspend performance of SRs during the extended EDG AOT. Provide clarification on when the suspended SRs will be completed and describe how the licensee will ensure these SRs are completed as described. For example, the proposed TS changes could include the following for each affected SR:
- a. Describe the event or condition where the SR may be suspended.
- b. Describe when past due surveillances will be completed.
(Note: As an example, see precedent 2017 Brunswick amendment (ML17328B072)).
Constellation Response to RAI #7 The markup of the proposed TS changes has been revised to provide clarification on when the suspended SRs will be completed. The revised markup is provided in Attachment 2. provides revised clean TS pages with the proposed changes incorporated.
RAI #8 In Attachment 1 of its submittal, the licensee provided risk insights related to the proposed one-time change to the Completion Time in TS Action Statement 3.8.1B. Regulatory Guide (RG) 1.177, Revision 2, Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications, states that changes in CT which result in an incremental conditional core damage probability (ICCDP) of greater than 1 x 10-5 is acceptable if effective compensatory measures of implemented. In its submittal, the licensee provides examples of compensatory measures to protect systems associated with providing AC power. These measures were stated to be recommended and not required.
Provide a list of more specific compensatory measures that shall be performed in order to mitigate any increase in conditional core damage probability (CCDP) with regards to the following systems:
- a. Systems impacting the inoperable EDG, such as SBO or diesel generators. Address maintenance in these systems.
- b. Systems associated with offsite AC power, such as the switchyard. Address maintenance in areas such as the switchyard.
- c. Measures to ensure grid reliability and stability given changing weather conditions.
- d. Systems which provide DC power, such as station batteries, back-up batteries, and any back-up sources of DC power including FLEX and B.5.b.
Constellation Response to RAI #8 The compensatory actions applicable prior to and during the CT extension are captured in.
ATTACHMENT 1 Response to Request for Additional Information
Page 7 RAI #9 Provide an analysis of the impact of the extended CT on the risk associated with external hazards, such as seismic activity or weather-related loss of onsite or offsite power.
Constellation Response to RAI #9 The impact due to external hazards, such as seismic, high winds, and external floods, were addressed consistent with 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 4b [Reference 1]. TS 3.8.1, Required Action B.4, is proposed to be within the scope of the QCNPS risk-informed completion time (RICT) program. To ensure risk was appropriately captured, penalty factors were applied to this one-time Completion Time (CT) extension where applicable.
For seismic considerations, the Unit 1 and Unit 2 emergency diesel generators (DGs) are of similar design and located on the same elevation of the Turbine Building such that they are modeled to be seismically correlated, which means a seismic event that fails one unit DG is assumed to also fail the other unit DG. The 1/2 DG is of similar design to the Unit 1 and Unit 2 DGs; however, it is located in the Reactor Building and therefore is modeled as not seismically correlated with the two unit DGs. The two station blackout (SBO) DGs are also of similar design to the emergency DGs but are located in the SBO DG building and as such the SBO DGs are modeled to be seismically correlated. The emergency and SBO DGs are of sufficiently different design that the emergency DGs are not seismically correlated with the SBO DGs. Given that the emergency and SBO DGs are not all seismically correlated, current defense-in-depth with the three fragility groups would support that a single DG unavailable would have minimal impact on seismic risk for the increase in Completion Time (CT) for TS 3.8.1, Required Action B.4.
However, conservative penalties for seismic CDF and LERF that were developed for the QCNPS TSTF-505 program were applied to the risk assessment performed for this one-time CT extension.
For high winds considerations, defense-in-depth realized through different locations of the emergency and SBO DGs qualitatively decreases the impact that high winds would have on the one-time extension of the CT for TS 3.8.1, Required Action B.4. Similar to the seismic risk considerations, tornado missile penalties for CDF and LERF that were developed for the QCNPS TSTF-505 program were applied to the risk assessment performed for the one-time CT extension. The penalty factor methodology used for the Quad Cities TSTF-505 license amendment request (LAR) is consistent with methodology previously approved for other Constellation LARs, such as R.E. Ginna, Peach Bottom, and Nine Mile Point, Unit 1
[References 2, 3, and 4].
For external flooding considerations, there is again defense-in-depth achieved by location of the emergency and SBO DGs. Additionally, site procedures require both reactors to be shut down when water reaches an elevation lower than that which would cause damage to the either of the units. Given that external flooding would be a developing event over time with advanced warning and both reactors would be shut down, the unavailability of the Unit 1 DG would have negligible impact on external flooding risk.
ATTACHMENT 1 Response to Request for Additional Information
Page 8 In accordance with RS-23-059 [Reference 1], all other external hazards were considered insignificant and screened due to either not presenting a design-basis challenge to QCNPS, the challenge being adequately addressed in the PRA, or the hazard having a negligible impact to RICT program.
The evaluation of the incremental conditional core damage probability (ICCDP) and incremental conditional large early release probability (ICLERP) for this evaluation include the external event penalties as described and are still within the acceptance guidelines established for compatibility with the ICCDP and ICLERP limits of Regulatory Guide (RG) 1.177.
RAI #10 The proposed note to TS 3.8.1 required action B.4 states, For the Unit 1 DG failure on December 11, 2023, restore the inoperable DG to OPERABLE status within 30 days. This note is missing some pertinent information. Because the DG has already been declared inoperable, the proposed TS note could reflect the actual ending date and time. Additionally, the response to RAIs 1 through 9 above may require identification of compensatory actions. The proposed TS note could include reference to the document that contains the list of compensatory actions required during the extended period. Describe how the proposed changes to the license (including the proposed note in TS 3.8.1) provide a clearly defined end date of applicability and ensure that any compensatory actions required during the extend completion time are clearly indicated.
Constellation Response to RAI #10 The proposed note to TS 3.8.1 Required Action B.4 has been revised to reflect the actual ending date and time of 1056 CST on December 25, 2023. The revised note also includes a reference to the list of compensatory actions required during the extended period. The revised markup is provided in Attachment 2. Attachment 3 provides revised clean TS pages with the proposed changes incorporated.
RAI #11 In Section 3.2 of the LAR, Risk Insights, the licensee stated that changes would be made within the guidance of Regulatory Guide (RG) 1.177 R2, Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications. In Section 2.3.3.1.d., it is stated that, Component unavailability models should include contributions from random failure, common-cause failure (CCF), test downtime, and maintenance downtime. Common cause failures are also further addressed in Appendix A, Section A-1.3.1.1 which states, contributions from common-cause failures (CCFs) need special attention when calculating the increased risk level R1. If the component is down because of a failure, the common-cause contributions should be divided by the probability of the component being down because of failure since the component is given to be down.
- a. In computing this 30-day completion time for EDG-1, state how CCF is addressed and how it will be adjusted as suggested in the RG 1.177 guidance for component failures.
- b. If it will not be adjusted, justify what methods are to be used to incorporate the potential impact of increased CCF.
ATTACHMENT 1 Response to Request for Additional Information
Page 9 Constellation Response to RAI #11 Common cause failure for the DGs was not adjusted in the original risk assessment performed for the one-time CT extension for TS 3.8.1, Required Action B.4. The risk assessment used both the average maintenance internal events and fire PRA models, as well as calculated an ICCDP and ICLERP consistent with the methodology that is used in the risk-informed completion time (RICT) program.
Compensatory measures and risk management actions (RMAs) are identified to protect redundant equipment, such as other emergency DGs and the Unit 1 SBO DG, delay maintenance activities on the Unit 2 and 1/2 emergency DGs, and to pre-stage FLEX equipment that could help to provide redundant onsite emergency AC power. This is also consistent with methodology that is used in the RICT program where emergent RICT entries use RMAs related to the success of redundant and diverse equipment and to address the increased likelihood of a common cause event.
Additionally, a sensitivity analysis was performed using cutset manipulation to adjust all common cause failure (CCF) rates that include the failure of the Unit 1 DG in the internal events and fire PRA models. This sensitivity calculation includes common cause failure events for the emergency and SBO DGs. For the sensitivity analysis, updated common cause failure rates were developed by dividing the baseline (nominal) CCF probabilities for failure to start events with the individual failure probability to start of the Unit 1 DG. This is consistent with the methodology outlined in Regulatory Guide 1.177. Table RAI.11-1 below gives ICCDP and ICLERP values for Units 1 and 2 with adjusted CCF rates as well as the external hazard penalties implemented as discussed in RAI #9. The ICCDP and ICLERP values for Units 1 and 2 with no adjusted common cause failure implemented are also included for comparison.
Table RAI.11-1: ICCDP and ICLERP Values for Extended CT for TS 3.8.1 Unit 1 Unit 2 ICCDP ICLERP ICCDP ICLERP Non-CCF Adjusted Total 1.3E-06 6.0E-08 1.2E-06 5.8E-08 CCF Adjusted Total 3.3E-06 9.0E-08 1.4E-06 6.2E-08 The numbers in Table RAI.11-1 calculate ICCDP and ICLERP assuming the CT is extended to 30 days and therefore would be bounding for a 14 day CT extension. This sensitivity again demonstrates that the proposed TS changes are within the current risk acceptance guidelines in RG 1.177 for one-time changes with an ICCDP of less than 1E-05, an ICLERP of less than 1E-06, and compensatory measures to be implemented during the extended CT.
References
[1]
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 4b'," dated June 8, 2023 (ADAMS Accession No. ML23159A249)
ATTACHMENT 1 Response to Request for Additional Information
Page 10
[2]
R.E. Ginna Nuclear Power Plant, "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'," dated May 28, 2021 (ADAMS Accession No. ML21140A324)
[3]
Peach Bottom Atomic Power Station, Units 2 and 3, "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',"
dated May 29, 2020 (ADAMS Accession No. ML20150A007)
[4]
Nine Mile Point Station, Unit 1, "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'," dated December 23, 2022 (ADAMS Accession No. ML22349A10)
ATTACHMENT 2 QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-264 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 REVISED MARK-UP OF QCNPS TECHNICAL SPECIFICATIONS PAGES
INSERT 1
- 4. Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.2 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
INSERT 2
- 6. Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.3 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
INSERT 3
NOTE-------------------------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.4 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
INSERT 4
NOTE-------------------------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.5 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
INSERT 5
NOTE-------------------------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.6 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
INSERT 6
- 2. Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.21 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
INSERT 7
NOTE-------------------------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.3.1 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
INSERT 8
NOTE-------------------------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.3.2 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-3 Amendment No. 275/270 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG inoperable.
B.1 Perform SR 3.8.1.1 for OPERABLE required offsite circuit(s).
AND B.2 Declare required feature(s), supported by the inoperable DG, inoperable when the redundant required feature(s) are inoperable.
AND B.3.1 Determine OPERABLE DG(s) are not inoperable due to common cause failure.
OR B.3.2 Perform SR 3.8.1.2 for OPERABLE DG(s).
AND B.4 Restore required DG to OPERABLE status.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours 7 days (continued)
- Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, the 7 day Completion Time is extended to 14 days. During the extended period, the compensatory actions listed in Attachment 4 of letter RS-23-128, dated December 15, 2023, shall be implemented. If SBO DG-1 becomes unavailable at any time during the extended period, the Required Action is to restore SBO DG-1 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or enter Condition F.
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-6 Amendment No. 248/2435 SURVEILLANCE REQUIREMENTS
NOTES -----------------------------------
- 1.
SR 3.8.1.1 through SR 3.8.1.20 are applicable only to the given unit's AC electrical power sources.
- 2.
SR 3.8.1.21 is applicable to the opposite unit's AC electrical power sources.
SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each required offsite circuit.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.2
NOTES-------------------
- 1.
All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
- 2.
A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.
When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.8 must be met.
- 3.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
Verify each DG starts from standby conditions and achieves steady state voltage t 3952 V and d 4368 V and frequency t 58.8 Hz and d 61.2 Hz.
In accordance with the Surveillance Frequency Control Program (continued)
INSERT 1
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-7 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.3
NOTES-------------------
- 1.
DG loadings may include gradual loading as recommended by the manufacturer.
- 2.
Momentary transients outside the load range do not invalidate this test.
- 3.
This Surveillance shall be conducted on only one DG at a time.
- 4.
This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.8.
- 5.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
Verify each DG is synchronized and loaded and operates for t 60 minutes at a load t 2340 kW and d 2600 kW.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.4 Verify each day tank contains t 205 gal of fuel oil and each bulk fuel storage tank contains t 10,000 gal of fuel oil.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.5 Remove accumulated water from each day tank.
In accordance with the Surveillance Frequency Control Program (continued)
INSERT 2 INSERT 3 INSERT 4
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-8 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.6 Verify each fuel oil transfer pump operates to automatically transfer fuel oil from the storage tank to the day tank.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.7 Check for and remove accumulated water from each bulk storage tank.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.8
NOTES-------------------
- 1.
All DG starts may be preceded by an engine prelube period.
- 2.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
Verify each DG starts from standby condition and achieves:
- a.
In d 13 seconds, voltage t 3952 V and frequency t 58.8 Hz; and
- b.
Steady state voltage t 3952 V and d 4368 V and frequency t 58.8 Hz and d 61.2 Hz.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.9 Verify manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit.
In accordance with the Surveillance Frequency Control Program (continued)
INSERT 5
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-15 Amendment No. 248/2439 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.20
NOTE--------------------
All DG starts may be preceded by an engine prelube period.
Verify, when started simultaneously from standby condition, each DG achieves, in d 13 seconds, voltage t 3952 V and frequency t 58.8 Hz.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.21
NOTE--------------------
When the opposite unit is in MODE 4 or 5, or moving recently irradiated fuel assemblies in secondary containment, the following opposite unit SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, and SR 3.8.1.14 through SR 3.8.1.17.
For required opposite unit AC electrical power sources, the SRs of the opposite unit's Specification 3.8.1, except SR 3.8.1.9, SR 3.8.1.13, SR 3.8.1.18, SR 3.8.1.19, and SR 3.8.1.20, are applicable.
In accordance with applicable SRs INSERT 6 S
1.
Diesel Fuel Oil and Starting Air 3.8.3 Quad Cities 1 and 2 3.8.3-2 Amendment No. 248/243 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D.
Required Action and associated Completion Time of Condition A, B, or C not met.
OR One or more DGs with stored diesel fuel oil or starting air subsystem not within limits for reasons other than Condition A, B, or C.
D.1 Declare associated DG inoperable.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1 Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
In accordance with the Diesel Fuel Oil Testing Program SR 3.8.3.2 Verify each required DG air start receiver pressure is t 230 psig.
In accordance with the Surveillance Frequency Control Program INSERT 7 INSERT 8
ATTACHMENT 3 QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-264 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 REVISED CLEAN QCNPS TECHNICAL SPECIFICATIONS PAGES
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-3 Amendment No. 298/294 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One required DG inoperable.
B.1 Perform SR 3.8.1.1 for OPERABLE required offsite circuit(s).
AND B.2 Declare required feature(s), supported by the inoperable DG, inoperable when the redundant required feature(s) are inoperable.
AND B.3.1 Determine OPERABLE DG(s) are not inoperable due to common cause failure.
OR B.3.2 Perform SR 3.8.1.2 for OPERABLE DG(s).
AND B.4 Restore required DG to OPERABLE status.
1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> AND Once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours 7 days*
(continued)
- Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, the 7 day Completion Time is extended to 14 days. During the extended period, the compensatory actions listed in Attachment 4 of letter RS-23-128 dated December 15, 2023, shall be implemented. If SBO DG-1 becomes unavailable at any time during the extended period, the Required Action is to restore SBO DG-1 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or enter Condition F.
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-6 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS
NOTES -----------------------------------
- 1.
SR 3.8.1.1 through SR 3.8.1.20 are applicable only to the given unit's AC electrical power sources.
- 2.
SR 3.8.1.21 is applicable to the opposite unit's AC electrical power sources.
SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each required offsite circuit.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.2
NOTES-------------------
- 1.
All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading.
- 2.
A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.
When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1.8 must be met.
- 3.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
- 4.
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.2 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
(continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-7 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.2 Verify each DG starts from standby (continued) conditions and achieves steady state voltage 3952 V and 4368 V and frequency 58.8 Hz and 61.2 Hz.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.3
NOTES-------------------
- 1.
DG loadings may include gradual loading as recommended by the manufacturer.
- 2.
Momentary transients outside the load range do not invalidate this test.
- 3.
This Surveillance shall be conducted on only one DG at a time.
- 4.
This SR shall be preceded by and immediately follow, without shutdown, a successful performance of SR 3.8.1.2 or SR 3.8.1.8.
- 5.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
- 6.
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.3 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
Verify each DG is synchronized and loaded and operates for 60 minutes at a load 2340 kW and 2600 kW.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-8 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.4
NOTES-------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.4 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
Verify each day tank contains 205 gal of fuel oil and each bulk fuel storage tank contains 10,000 gal of fuel oil.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.5
NOTES-------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.5 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
Remove accumulated water from each day tank.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-9 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.6
NOTES-------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.6 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
Verify each fuel oil transfer pump operates to automatically transfer fuel oil from the storage tank to the day tank.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.7 Check for and remove accumulated water from each bulk storage tank.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.8
NOTES-------------------
- 1.
All DG starts may be preceded by an engine prelube period.
- 2.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
Verify each DG starts from standby condition and achieves:
- a.
In 13 seconds, voltage 3952 V and frequency 58.8 Hz; and
- b.
Steady state voltage 3952 V and 4368 V and frequency 58.8 Hz and 61.2 Hz.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-10 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.9 Verify manual transfer of unit power supply from the normal offsite circuit to the alternate offsite circuit.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.10
NOTE--------------------
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
Verify each DG rejects a load greater than or equal to its associated single largest post-accident load, and:
- a.
Following load rejection, the frequency is 66.73 Hz;
- b.
Within 3 seconds following load rejection, the voltage is 3952 V and 4368 V; and
- c.
Within 4 seconds following load rejection, the frequency is 58.8 Hz and 61.2 Hz.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.11
NOTES--------------------
- 1.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
- 2.
Momentary transients outside the voltage limit do not invalidate this test.
Verify each DG does not trip and voltage is maintained 5000 V during and following a load rejection of 2340 kW and 2600 kW.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-11 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.12
NOTE--------------------
All DG starts may be preceded by an engine prelube period.
Verify on an actual or simulated loss of offsite power signal:
- a.
De-energization of emergency buses;
- b.
Load shedding from emergency buses; and
- c.
DG auto-starts from standby condition and:
- 1. energizes permanently connected loads in 13 seconds,
- 2. maintains steady state voltage 3952 V and 4368 V,
- 3. maintains steady state frequency 58.8 Hz and 61.2 Hz, and
- 4. supplies permanently connected loads for 5 minutes.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-12 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.13
NOTE--------------------
All DG starts may be preceded by an engine prelube period.
Verify on an actual or simulated Emergency Core Cooling System (ECCS) initiation signal each DG auto-starts from standby condition and:
- a.
In 13 seconds after auto-start, achieves voltage 3952 V and frequency 58.8 Hz;
- b.
Achieves steady state voltage 3952 V and 4368 V and frequency 58.8 Hz and 61.2 Hz; and
- c.
Operates for 5 minutes.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.14 Verify each DG's automatic trips are bypassed on actual or simulated loss of voltage signal on the emergency bus concurrent with an actual or simulated ECCS initiation signal except:
- a.
Engine overspeed; and
- b.
Generator differential current.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-13 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.15
NOTES-------------------
- 1.
Momentary transients outside the load range and power factor limit do not invalidate this test.
- 2.
If grid conditions do not permit, the power factor limit is not required to be met. Under this condition, the power factor shall be maintained as close to the limit as practicable.
- 3.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
Verify each DG operating within the power factor limit operates for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:
- a.
For 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 2730 kW and 2860 kW; and
- b.
For the remaining hours of the test loaded 2340 kW and 2600 kW.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-14 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.16
NOTES-------------------
- 1.
This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 2340 kW.
Momentary transients below the load limit do not invalidate this test.
- 2.
All DG starts may be preceded by an engine prelube period.
- 3.
A single test of the common DG at the specified Frequency will satisfy the Surveillance for both units.
Verify each DG starts and achieves:
- a.
In 13 seconds, voltage 3952 and frequency 58.8 Hz; and
- b.
Steady state voltage 3952 V and 4368 V and frequency 58.8 Hz and 61.2 Hz.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.17 Verify each DG:
- a.
Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power;
- b.
Transfers loads to offsite power source; and
- c.
Returns to ready-to-load operation.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-15 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.18 Verify interval between each sequenced load block is 90% of the design interval for each load sequence time delay relay.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.19
NOTE--------------------
All DG starts may be preceded by an engine prelube period.
Verify, on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ECCS initiation signal:
- a.
De-energization of emergency buses;
- b.
Load shedding from emergency buses; and
- c.
DG auto-starts from standby condition and:
- 1.
energizes permanently connected loads in 13 seconds,
- 2.
energizes auto-connected emergency loads including through time delay relays, where applicable,
- 3.
maintains steady state voltage 3952 V and 4368 V,
- 4.
maintains steady state frequency 58.8 Hz and 61.2 Hz, and
- 5.
supplies permanently connected and auto-connected emergency loads for 5 minutes.
In accordance with the Surveillance Frequency Control Program (continued)
AC SourcesOperating 3.8.1 Quad Cities 1 and 2 3.8.1-16 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.20
NOTE--------------------
All DG starts may be preceded by an engine prelube period.
Verify, when started simultaneously from standby condition, each DG achieves, in 13 seconds, voltage 3952 V and frequency 58.8 Hz.
In accordance with the Surveillance Frequency Control Program SR 3.8.1.21
NOTES-------------------
- 1.
When the opposite unit is in MODE 4 or 5, or moving recently irradiated fuel assemblies in secondary containment, the following opposite unit SRs are not required to be performed: SR 3.8.1.3, SR 3.8.1.10 through SR 3.8.1.12, and SR 3.8.1.14 through SR 3.8.1.17.
- 2.
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.1.21 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
For required opposite unit AC electrical power sources, the SRs of the opposite unit's Specification 3.8.1, except SR 3.8.1.9, SR 3.8.1.13, SR 3.8.1.18, SR 3.8.1.19, and SR 3.8.1.20, are applicable.
In accordance with applicable SRs
Diesel Fuel Oil and Starting Air 3.8.3 Quad Cities 1 and 2 3.8.3-2 Amendment No. 248/243 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action and associated Completion Time of Condition A, B, or C not met.
OR One or more DGs with stored diesel fuel oil or starting air subsystem not within limits for reasons other than Condition A, B, or C.
D.1 Declare associated DG inoperable.
Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.1
NOTE-------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.3.1 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
Verify fuel oil properties of new and stored fuel oil are tested in accordance with, and maintained within the limits of, the Diesel Fuel Oil Testing Program.
In accordance with the Diesel Fuel Oil Testing Program (continued)
Diesel Fuel Oil and Starting Air 3.8.3 Quad Cities 1 and 2 3.8.3-3 Amendment No. 248/243 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.3.2
NOTE-------------------
Until DG 1 is returned to OPERABLE status, not to exceed 1056 CST on December 25, 2023, performance of SR 3.8.3.2 for DGs 2 and 1/2 may be suspended. Past due surveillances will be completed within 7 days of restoration of DG 1 operability or January 1, 2024, whichever occurs first.
Verify each required DG air start receiver pressure is 230 psig.
In accordance with the Surveillance Frequency Control Program
ATTACHMENT 4 QUAD CITIES NUCLEAR POWER STATION UNITS 1 AND 2 Docket Nos. 50-264 and 50-265 Facility Operating License Nos. DPR-29 and DPR-30 COMPENSATORY ACTIONS FOR ONE-TIME CT EXTENSION FOR TS 3.8.1.B.4
Compensatory Actions for One-Time CT Extension for TS 3.8.1.B.4 Compensatory Action Description Details Emergent work will be assessed and managed in accordance with 10 CFR 50.65(a)(4) and the applicable TS.
x Limit maintenance activities while Unit 1
DG is unavailable.
x Protect the other DGs, SBO DG, and
switchyard (e.g., limit activities near
emergency DG equipment) to helpensure the availability of AC power.
x Reschedule surveillances/preventative
maintenance that could affect fire
protection equipment (e.g., detection and
suppression systems) in the RelayHouse.
x Follow on-line work control process
procedure guidance to continuously
evaluate the risk of scheduled
maintenance activities for severe weather
conditions Work on protected equipment will be scrutinized and evaluated for impact before execution.
Protected Equipment Program Equipment will be protected in accordance with the Protected Equipment Program, which supports the Configuration Risk Management Program and are classified as risk management actions for the purpose of compliance with 10CFR50.65 (a)(4).
Bus 13-1, 23-1 and 24-1 (4kv), Bus 28, 29 and 19 and associated MCCs (480V), and associated EDG rooms and pump vaults 345KV switchyard Unit 1 HPCI and RCIC RB1, RB2, 1A-1, 2B-1 (DC Buses and power supplies)
Unit 1 SBO
Compensatory Actions for One-Time CT Extension for TS 3.8.1.B.4 Compensatory Action Description Details 10 CFR 50.65 (a)(4)
Fire Risk Risk Management Actions Fire RMAs will be implemented for each configuration per the guidance in the Online Fire Risk Management Program.
U1 Reactor Bldg, El.
595-0, Ground Floor; U1 Reactor Bldg, El. 623-0, Mezzanine Level; Service Bldg, El.
609-0, Cable Spreading Room; Service Bldg, El.
595-0 Auxiliary Electric Equipment Room; U2 Turbine Bldg, El. 595-0, Ground Floor -
Northern Area.
Staging FLEX Equipment A single FLEX diesel generator will be staged for use.
QCOP 0050-07 Perform Additional Pre-Job Briefs x
Perform pre-job briefs to increase awareness of various operator actions to help minimize risk (e.g., associated with scenarios where AC Power has increased Importance):
x Manually align and start the Unit 1 DGCWP. The Unit 1 DGCWP is still capable of being manually aligned if required.
x Manually align and start the Safe Shutdown Makeup Pump (SSMP). The SSMP does not auto-initiate and is manually initiated from the Main Control Room. In addition, the SSMP room cooler bypass valve needs to be locally, manual closed in the SSMP room. This should include operation of the SSMP for dual unit events where SSMP may be required for both units.
x Actions in SBO scenarios:
x Start the SBO DGs and align to the affect Buses.
QCOP 6600-14 QCOP 2900-02 QCOP 6620-14 /
QCOP 6620-11 QCOA 6100-03
Compensatory Actions for One-Time CT Extension for TS 3.8.1.B.4 Compensatory Action Description Details x
Crosstie AC Buses.
x Shed non-essential loads in Station Blackout conditions to preserve the RPV and containment support systems.
QCOA 6100-03/04 Monitoring Grid Reliability x
System load dispatcher will be contacted once per day to ensure no significant grid perturbations Operator Rounds x
Rounds on the SBO will be changed to shiftly (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) during the extended CT period