RS-14-133, Updated Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

Updated Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

ML14155A387
Person / Time
Site:	Quad Cities
Issue date:	06/04/2014
From:	Kaegi G Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-14-133
Download: ML14155A387 (8)

Text

ti RS-14-133 10 CFR 50.54(f)

June 4, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk 11555 Rockville Pike, Rockville. MD 20852 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:

Updated Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident

References:

1. NRC Letter, Request for Information Pursuant to Title 1O of the Code of Federal Regulations 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 12, 2012

2. Exelon Generation Company, LLC letter to USNRC, Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 2, Flooding Hazard Reevaluation Report, dated March 12, 2013 (RS-13-047)

3. Exelon Generation Company, LLC letter to USN RC, Supplemental Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding the Flooding Aspects of Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated August 28, 2013 (RS-13-211)

On March 12, 2012, the NRC issued Reference 1 to all power reactor licensees and holders of construction permits in active or deferred status. Enclosure 2 of Reference 1 requested that each licensee perform a reevaluation of external flooding sources and report the results in accordance with the NRC's prioritization plan. Exelon Generation Company, LLC (EGC) submitted the flood reevaluation for Quad Cities Nuclear Power Station, Units 1 and 2 in Reference 2. Reference 2 contains the interim actions that EGC has taken or plans to take to address higher flooding hazards relative to the design basis until the integrated assessment is completed. Reference 3 provided additional information regarding the list of the interim actions taken or planned to be taken, as identified in Reference 2, and converted these interim actions into regulatory commitments along with the dates by which the actions were to be implemented.

U.S. Nuclear Regulatory Commission June 4, 2014 Page2 The purpose of this letter is to provide an update to the regulatory commitments contained in Reference 3, as discussed with NRC staff on April 4, 2014. The enclosed table updates completed Commitment Items 3, 7, 8, 9, and 10 to describe in the Additional Information column the specific actions taken as a result of the completed evaluations. All regulatory commitments have been completed.

This letter contains no new or revised regulatory commitments.

Should you have any questions concerning the content of this letter, please contact Ron Gaston at (630) 657-3359.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of June 2014.

Respectfully submitted,

~T~

Glen T. Kaegi Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Enclosure:

1. Quad Cities Nuclear Power Station, Units 1 and 2 - Flood Hazard Reevaluation Report Interim Action Commitments cc: Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Project Manager, NRA - Quad Cities Nuclear Power Station Mr. Blake A. Purnell, NRR/DORULPL3-2, NRC Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Eric E. Bowman, NRR/DPR/PGCB, NRC or Ms. Eileen M. McKenna, NRO/DSRA/BPTS, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

U.S. Nuclear Regulatory Commission June 4, 2014 Page 3 bee: Site Vice President - Quad Cities Nuclear Power Station Vice President Operations Support Regulatory Affairs Manager Regulatory Assurance Manager - Quad Cities Nuclear Power Station Severe Accident Management Director Site Operations Director - Quad Cities Nuclear Power Station Corporate Licensing Managers - West Corporate Licensing Director- West Exelon Records Management Commitment Tracking Coordinator - West Vinod Aggarwal Joe Bellini Dustin Damhoff

Enclosure 1: Quad Cities Nuclear Power Station, Units 1 and 2 - Flood Hazard Reevaluation Report Interim Action Commitments* ("Commitments" are bolded header columns)

Item Implementation Commitment Commitment Interim Actions Taken or Number Type Type Planned to Take as Date Report Included in the Additional Information (Committed* One-Time Programmatic*

Reference Reevaluation Report Date or Action*

(Commitment*) Outage) (Yes/No) (Yes/No)

The local intense precipitation interim evaluation will include:

1. A visual inspection of plant Report Some of the plant grade March 18, 2013 Yes No grade level doors to confirm Cover level doors do not have Completed proper operation and assess Letter, seals, as seals are not seal condition.

Section d.ii required by the current design basis requirements.

The results of this action are being evaluated under Interim Action Item Number 3.

2. A visual inspection of plant Report The overall drainage system March 14, 2013 Yes No drainage system components Cover condition was found Completed to confirm functionality. Letter, acceptable.

Section d.ii Page 1 of 5

Enclosure 1: Quad Cities Nuclear Power Station, Units 1 and 2 - Flood Hazard Reevaluation Report Interim Action Commitments* ("Commitments" are bolded header columns)

Item Commitment Commitment Interim Actions Taken or Implementation Number Type Type Planned to Take as Date Report Included in the Additional Information (Committed* One-Time Programmatic*

Reference Reevaluation Report Date or Action*

(Commitment*) Outage) (Yes/No) (Yes/No)

3. An evaluation of the effects Report Evaluation determined April 4, 2014 Yes No of local intense precipitation Cover existing plant design has Completed event on the plant, with Letter, margin for the river flood respect to:

Section d.ii event.

- Building structures Evaluation recommended and doors and amount of leakage the doors upgrades to some doors, would allow; penetrations, openings and building interfaces for

- How the leakage mitigating the LIP event.

through the doors affect plant Subsequent to completion of equipment; this committed evaluation, modifications have been

- Recommended started and installation is actions based on the results of the planned to occur consistent evaluations; and with the FLEX plan implementation schedule.

- Prioritizing actions for hiah risk areas.

4. Develop and implement Report Procedure QCOA 0010-22 March 14, 2013 Yes No appropriate operational Cover (Local Intense Precipitation Completed response procedures to Letter, Procedure) was developed.

mitigate the effects of the LIP Section d.ii Event.

Page 2 of 5

Enclosure 1: Quad Cities Nuclear Power Station, Units 1 and 2 - Flood Hazard Reevaluation Report Interim Action Commitments* ("Commitments" are bolded header columns)

Item Implementation Commitment Commitment Interim Actions Taken or Number Type Type Planned to Take as Date Report Included in the Additional Information (Committed* One-Time Programmatic*

Reference Reevaluation Report Date or Action*

(Commitment*) Outage) (Yes/No) (Yes/No)

5. Perform additional local Report Calculations LIP-QDC-002 June 27, 2013 Yes No intense precipitation Cover and LIP-QDC-003 were Completed calculations to further explore Letter, developed in accordance site drainage affects.

Section d.ii with Appendix B of NUREG/CR-7046, Case 1 and Case 2, respectively.

6. Obtaining a site survey so Report The results of this action are August8,2013 Yes No that the results of the local Cover being evaluated under Completed intense precipitation analysis Letter, Interim Action Item Number can be directly correlated to Section d.ii 3.

the door sill elevations.

7. Determine if interim flood Report Interim flood barriers were May 30, 2014 Yes No barriers are warranted until Cover determined to provide Completed the 2-Year Integrated Letter, negligible benefit for Assessment Report is Section d.ii protection from the new LIP complete.

event. Permanent flood barriers are being installed on an accelerated schedule consistent with the FLEX plan implementation schedule.

The river flood and combined-effects flood interim evaluation will include:

Page 3 of 5

Enclosure 1: Quad Cities Nuclear Power Station, Units 1 and 2 - Flood Hazard Reevaluation Report Interim Action Commitments* ("Commitments" are bolded header columns)

Item Implementation Commitment Commitment Interim Actions Taken or Number Type Type Planned to Take as Date Report Included in the Additional Information (Committed* One-Time Programmatic*

Reference Reevaluation Report Date or Action*

(Commitment*) Outage) (Yes/No) (Yes/No)

8. Evaluate the effects of wind- Report Evaluation determined that November 15, Yes No generated waves on the plant. Cover the effects of wind generated 2013 Letter, waves have negligible Completed Section d.ii impact on the station's ability to reach and maintain safe shutdown.

9. Evaluate the effects of Report Evaluation determined that November 15, Yes No hydrodynamic and debris Cover the effects of hydrodynamic 2013 impact loading on the plant. Letter, and debris impact loading on Completed Section d.ii the plant have negligible impact on the station's ability to reach and maintain safe shutdown.

Page 4 of 5

Enclosure 1: Quad Cities Nuclear Power Station, Units 1 and 2 - Flood Hazard Reevaluation Report Interim Action Commitments* ("Commitments" are bolded header columns)

Item Commitment Commitment Interim Actions Taken or Implementation Number Type Type Planned to Take as Date Report Included in the Additional Information (Committed* One-Time Programmatic*

Reference Reevaluation Report Date or Action*

(Commitment*) Outage) (Yes/No) (Yes/No)

10. Revise Flooding Procedures to Report Revisions to QCOA 0010-16 July 18, 2014 Yes No incorporate new issues (as Cover (Flood Emergency Completed appropriate) in accordance Letter, Procedure) have been made with updated river flood Section d.ii to address evaluations calculations.

completed to date.

All above Interim Actions have been completed. Flood Emergency Procedure has been updated to incorporate additional considerations based on the results of the completed Interim Actions.

Subsequent to completion of this committed incorporation of new issues, additional revisions may be considered as identified during development of the Integrated Assessment Report.

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