RS-15-024, Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

From kanterella
Jump to navigation Jump to search

Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
ML15061A433
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 02/27/2015
From: Kaegi G
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EA-12-049, RS-15-024
Download: ML15061A433 (28)
v • d • e


Text

l ti Order No. EA-12-049 RS-15-024 February 27, 2015 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 NRG Docket Nos. 50-254 and 50-265

Subject:

Fourth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

References:

1. NRG Order Number EA-12-049, "Issuance of Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012
2. NRG Interim Staff Guidance JLD-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," Revision 0, dated August 29, 2012
3. NEI 12-06, Diverse and Flexible Coping Strategies (FLEX) Implementation Guide,"

Revision 0, dated August 2012

4. Exelon Generation Company, LLC's Initial Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated October 25, 2012
5. Exelon Generation Company, LLC Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (RS-13-025)
6. Exelon Generation Company, LLC First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2013 (RS-13-129)
7. Exelon Generation Company, LLC Second Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated February 28, 2014 (RS-14-015)

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 27, 2015 Page2

8. Exelon Generation Company, LLC Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA 049), dated August 28, 2014 (RS-14-213)
9. NRC letter to Exelon Generation Company, LLC, Quad Cities Nuclear Power Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC Nos. MF1048 and MF1049), dated November 22, 2013 On March 12, 2012, the Nuclear Regulatory Commission ("NRC" or "Commission") issued an order (Reference 1) to Exelon Generation Company, LLC (EGC). Reference 1 was immediately effective and directs EGC to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. Specific requirements are outlined in of Reference 1.

Reference 1 required submission of an initial status report 60 days following issuance of the final interim staff guidance (Reference 2) and an overall integrated plan pursuant to Section IV, Condition C. Reference 2 endorses industry guidance document NEI 12-06, Revision O (Reference 3) with clarifications and exceptions identified in Reference 2. Reference 4 provided the EGC initial status report regarding mitigation strategies. Reference 5 provided the Quad Cities Nuclear Power Station, Units 1 and 2 overall integrated plan.

Reference 1 requires submission of a status report at six-month intervals following submittal of the overall integrated plan. Reference 3 provides direction regarding the content of the status reports. References 6, 7, and *8 provided the first, second, and third six-month status reports, respectively, pursuant to Section IV, Condition C.2, of Reference 1 for Quad Cities Station. The purpose of this letter is to provide the fourth six-month status report pursuant to Section IV, Condition C.2, of Reference 1, that delineates progress made in implementing the requirements of Reference 1. The enclosed report provides an update of milestone accomplishments since the last status report, including any changes to the compliance method, schedule, or need for relief and the basis, if any. The enclosed report also addresses the NRC Interim Staff Evaluation Open and Confirmatory Items contained in Reference 9.

This letter contains no new regulatory commitments. If you have any questions regarding this report, please contact David P. Helker at 610-765-5525.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th day of February 2015.

Respectfully submitted,

~T.z_y Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC

U.S. Nuclear Regulatory Commission Integrated Plan Report to EA-12-049 February 27, 2015 Page3

Enclosure:

1. Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events cc: Director, Office of Nuclear Reactor Regulation NRC Regional Administrator - Region Ill NRC Senior Resident Inspector - Quad Cities Nuclear Power Station, Units 1 and 2 NRC Project Manager, NRR - Quad Cities Nuclear Power Station, Units 1 and 2 Ms. Jessica A. Kratchman, NRR/JLD/PMB, NRC Mr. Jack R. Davis, NRR/DPR/MSD, NRC Mr. Eric E. Bowman, NRR/DPR/MSD, NRC Mr. Jeremy S. Bowen, NRR/DPR/MSD/MSPB, NRC Mr. Robert L. Dennig, NRR/DSS/SCVB, NRC Mr. John P. Boska, NRR/JLD/JOMB, NRC Illinois Emergency Management Agency - Division of Nuclear Safety

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (24 pages)

Enclosure Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six Month Status Report for the Implementatio n of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Quad Cities Nuclear Power Station, Units 1 and 2, developed an Overall Integrated Plan (Reference 1 in Section 8) documenting the diverse and flexible strategies (FLEX) in response to NRC Order EA-12-049 (Reference 2). This enclosure provides an update of milestone accomplishments since submittal of the last status report, including any changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.

NOTE: The "Status" indicated in this document is as of January 23, 2015. This date was chosen to support the development, review, approval and submittal of this report by the required February 27, 2015 due date.

2 Milestone Accomplishments The Staffing analysis has been completed since the last update and was submitted in letter RS-14-280 dated November 3, 2014. Also, the National SAFER Response Center (NSRC) is operational.

3 Milestone Schedule Status The following provides an update to Attachment 2 of the Overall Integrated Plan. It provides the activity status of each item, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised target completion dates impact the order implementation date. An explanation of the impact of these changes is provided in Section 5 of this enclosure.

Milestone Schedule Target Revised Target Milestone Completion Activity Status Completion Date Date Submit 60 Day Status Report Oct 2012 Complete Submit Overall Integrated Plan Feb 2013 Complete Contract with RRC Complete Submit 6 Month Updates:

Update 1 Aug 2013 Complete Update 2 Feb 2014 Complete Update 3 Aug 2014 Complete Page 1of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Target Revised Target Milestone Completion Activity Status Completion Date Date Complete with Update 4 Feb 2015 this submittal Update 5 Aug 2015 Not Started Update 6 Feb 2016 Not Started Update 7 Aug 2016 Not Started June 2018 Submit Completion Report Not Started See Section 5 of this enclosure.

Modifications Development &

Implementation:

Unit 1 Modification Development (All Feb 2014 Completed April 2014 FLEX Phases)

Unit 1 Modification Implementation (All Apr 2015 Started Mar 2015 FLEX Phases)

Unit 2 Modification Development (All Mar 2015 Completed FLEX Phases)

Unit 2 Modification Implementation (All Apr 2016 Started FLEX Phases)

Common Unit Modfication Development Started Mar 2015 (Interim Storage Pads and Deep Wells)

Common Unit Modfication Implementation (Interim Storage Pads Started Mar 2015 and Deep Wells)

Robust Storage Building October 2015 Struted ASCE 7-10 FLEX +1 Storage Building April 2016 Started Procedures:

Create Site-Specific Procedures Apr 2015 Started Mar 2015 Validate Procedures (NEI 12-06, Sect.

Apr 2015 Started Mar 2015 11.4.3)

Create Maintenance Procedures Apr 2015 Started Mar 2015 Perform Staffing Analysis Nov 2014 Completed Storage Plan and Construction Apr 2015 Started Mar 2015 Page 2 of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Target Revised Target Milestone Completion Activity Status Completion Date Date FLEX Equipment Acquisition Apr 2015 Started Mar 2015 Training Completion Apr 2015 Started Mar 2015 National Safer Response Center Operational Dec 2014 Completed Apr 2017 Unit 1 FLEX Implementation Apr 2015 Started See Section 5 of this enclosure.

Apr 2018 Unit 2 FLEX Implementation Apr 2016 Started See Section 5 of this enclosure.

Apr 2018 Full Site FLEX Implementation Apr 2016 Started See Section 5 of this enclosure.

4 Changes to Compliance Method The equipment listings for Phase 2 and Phase 3 (National SAFER Response Center (NSRC) equipment) are updated in Attachments 1 and 2, respectively. The timeline submitted with the OIP has been updated based on additional MAAP analysis (Reference 11) and the timeline is enclosed in Attachment 3.

Change 1 General Integrated Plan Elements BWR Requirement:

Extent to which the guidance, JLD-ISG-2012-01 and NEI 12-06, are being followed. Identify any deviations to JLD-ISG-2012-01 and NEI 12-06. The allowed unavailability time requirements are stated in NEI 12-06 section 11.5.3 and described as: "The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized."

Reason/or Change:

Due to delays in completing the Robust FLEX Building, Quad Cities will be utilizing an outdoor two-pad equipment storage configuration on an interim basis. This configuration will only be utilized until construction of the Robust FLEX Building is complete, which is expected by October 2015. This temporary two-pad storage configuration is an interim approach to the standard FLEX building strategy that meets the requirements of NEI 12-06 and satisfies the intent of NRC Order EA-12-049. During the period Quad Cities is in this configuration for storage, Quad Cities will implement an Alternate Approach to meet the Order for allowed unavailability time.

Page 3 of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Change to Compliance Method:

Unavailability Alternate Approach

1. The unavailability of equipment and applicable connections that directly performs a FLEX mitigation strategy for core, containment, and SFP should be managed such that risk to mitigating strategy capability is minimized.
a. The unavailability of plant equipment is controlled by existing plant processes such as the Technical Specifications. When plant equipment which supports FLEX strategies becomes unavailable, then the FLEX strategy affected by this unavailability does not need to be maintained during the unavailability.
b. The required FLEX equipment may be unavailable for 90 days provided that the site FLEX capability (N) is met. If the site FLEX (N) capability is met but not fully protected for the site's applicable hazards, then the allowed unavailability is reduced to 45 days.
c. Connections to plant equipment required for FLEX strategies can be unavailable for 90 days provided the remaining connection remains available such that the site FLEX strategy is available.
d. If FLEX equipment is likely to be unavailable during forecast site specific external events (e.g., flooding), appropriate compensatory measures should be taken to restore equivalent capability in advance of the event.
e. The duration of FLEX equipment unavailability, discussed above, does not constitute a loss of reasonable protection from a diverse storage location protection strategy perspective.
f. If FLEX equipment or connections becomes unavailable such that the site FLEX capability (N) is not maintained, initiate actions within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to restore the site FLEX capability (N) and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
g. If FLEX equipment or connections to permanent plant equipment required for FLEX strategies are unavailable for greater than 45/90 days, initiate actions to restore the FLEX capability and implement compensatory measures (e.g., use of alternate suitable equipment or supplemental personnel) prior to exceeding the 45/90 days.

Basis for an Alternate Approach:

The interim storage pad design requires use of two separate storage pads separated by a large distance. The lower pad and its haul path are qualified to withstand the seismic event, while the upper pad is designed for the seismic event, however, its haul path is not analyzed for seismic capabilities. As a result, the upper pad may become unavailable for accessing FLEX equipment during a seismic event, therefore the Alternate Approach described herein for a reduced Unavailability Time applied to the interim storage pad equipment will be used to compensate for the upper pad haul path not being analyzed for seismic capabilities. If the remaining N equipment is not protected from the applicable hazards, instead of the 90-day allowed out of service time, an allowed out of service time of 45 days will apply.

This is based on 6-week short cycle work scheduling. This will allow the station to continue to manage work associated with equipment important to safety. Placing the FLEX equipment into the site work schedule at the 6-week pe1iod still allows proper planning and resource loading while maintaining schedule compliance and stability. This action will not cause the station to be distracted from other scheduled work.

Page4 of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 The probability of an event causing an ELAP and loss of the UHS is low, and reducing the allowed unavailability time will further reduce the probability of an event during this period. Therefore, it is reasonable to expect equipment availability during periods when it is required.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation By letter dated February 27, 2014 (Ref. 5), Quad Cities Station requested relaxation from certain schedule requirements of Order EA-12-049 (Ref. 2) related to installation of the severe accident capable containment vent required by Order EA-13-109 (Ref. 3). The NRC granted that schedule relief via letter dated April 15, 2014 (Ref. 9).

No additional need for relief/relaxation relative to Order EA-12-049 has been identified at this time.

6 Open Items from Overall Integrated Plan and Draft Safety Evaluation The following tables provide a summary of the open items documented in the Overall Integrated Plan (Reference 1) or the Draft Safety Evaluation (SE) (Reference 7), and the status of each item.

OIP Section Overall Integrated Plan Open Item Status Reference Sequence of 1. The times to complete actions in the Started Events (p. 4) Events Timeline are based on operating judgment, conceptual designs, and current supporting analyses. The final timeline will be time validated once detailed designs are completed and procedures are developed, and the results will be provided in a future six-month update.

Sequence of 2. Issuance of BWROG document NEDC- Complete - See August 2013 Six-Month Events (p. 3377 lP, "GEH Evaluation of FLEX update (Reference 4).

4,5) Implementation Guidelines," on 01/31/2013 did not allow sufficient time to perform the analysis of the deviations between Exelon' s engineering analyses and the analyses contained in the BWROG document prior to submittal of this Integrated Plan. This analysis is expected to be completed, documented on Attachment lB, and provided to the NRC in the August 2013 six-month status update.

Page 5 of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 OIP Section Overall Integrated Plan Open Item Status Reference Sequence of 3. Additional work will be performed Complete - Quad Cities MAAP analysis Events (p. 6) during detailed design development to results for the case used for the strategy ensure Suppression Pool temperature will development indicated that the peak support RCIC operation, in accordance with Suppression Pool temperature was 232°F approved BWROG analysis, throughout the at 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> from the start of the event. event. This temperature provides significant margin to the limits provided in the BWROG Fukushima Response Committee- Beyond Design Basis RCIC Elevated Temperature Functionality Assessment," BWROG-TP-14-018 Rev.

O".

Sequence of 4. Initial calculations were used to Complete - See August 2014 Six-Month Events (p. 7) determine the fuel pool tirnelines. Formal update (Reference 10).

calculations will be performed to validate this information during development of the Spent Fuel Pool Cooling strategy detailed designs, and will be provided in a future six-month update.

Multiple 5. Procedures and programs will be Started Sections developed to address storage structure requirements, haul path requirements, and FLEX equipment requirements relative to the external hazards applicable to Quad Cities.

Programmatic 6. Quad Cities Nuclear Power Station will Started controls (p. 8) implement an administrative program for FLEX to establish responsibilities, and testing and maintenance requirements.

Page 6 of24

Quad Cities Nuclear Power Station, Units 1 and 2 ~ Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 OIP Section Overall Integrated Plan Open Item Status Reference Multiple 7. Detailed designs based on the current Started Sections conceptual designs will be developed to determine the final plan and associated mitigating strategies. Analysis will be performed to validate that the plant modifications, selected equipment, and identified mitigating strategy can satisfy the safety function requirements of NEI 12-06.

Once these designs and mitigating strategies have been fully developed, Exelon will update the integrated plan for Quad Cities Nuclear Power Station during a scheduled six-month update. This update will include any changes to the initial designs as submitted in this Integrated Plan.

Maintain 8. Guidance will be provided to ensure that Stru1ed Core Cooling sufficient area is available for deployment Phase 1 and that haul paths remain accessible (p.13) without interference from outage equipment during refueling outages.

Maintain 9. Evaluation of the spent fuel pool area for Started Spent Fuel steam and condensation has not yet been Pool Cooling performed. The results of this evaluation Phase 1 and the vent path strategy, if needed, will be (p.32) provided in a future six-month update.

Safety 10. Habitability conditions will be Started Function evaluated and a strategy will be developed Support (p. to maintain RCIC habitability.

42)

Safety 11. Habitability conditions will be Complete Duplicate of 3.2.4.6.A Function evaluated and a strategy will be developed Support (p. to maintain Main Control Room

42) habitability.

Safety 12. Battery Room Ventilation: Alternate Started Function ventilation will be provided to address Support (p. Hydrogen generation and cold weather, as

43) required.

Page 7 of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 OIP Section Overall Integrated Plan Open Item Status Reference Safety 13. Fuel Oil Supply to Portable Equipment: Started Function A detailed fuel oil supply plan will be Support (p. developed.

43) 4. Provide alternate cooling to the RCIC Started lA, Item 20 rooms. Procedure to be developed.

(p.59)

Section Interim Safety Evaluation Status Reference Open/Confirmatory Items 3.2.3.A SIGNIFICANT OPEN Item. Generic Complete - See Febmary 2014 Six-Month concern related to adoption of Revision 3 to update (Reference 8).

the BWROG EPG/SAG [Emergency Procedure Guidelines/Severe Accident Guidelines] relating to potential detrimental effects on containment response.

3.2.4.6.A OPEN Item Licensee asserts 120 °F used See NOTE below for habitability in SBO is adequate for FLEX. Habitability of the control room should consider 110 degree F temperature limits of NUMARC 87-00 and MIL-STD-1472C.

3.3.2.A OPEN Item Control of equipment and See NOTE below connections for unavailability needs to be addressed.

3.4.B OPEN Item Details not provided to Complete - See Febmary 2014 Six-Month demonstrate the minimum capabilities for update (Reference 8).

offsite resources will be met per NEI 12-06 Section 12.2.

3.1.1.2.A Confirmatory Item Studies for liquefaction See NOTE below and the effects on haul paths and storage location(s) are not complete.

3.1.1.2.B Confirmatory Item A postulated See NOTE below downstream dam failure from a seismic event is still being evaluated.

3.1.1.2.C Confirmatory Item Need to confirm See NOTE below implementation of strategy for power to move or deploy FLEX equipment and opening of doors.

3.1.1.3.A Confirmatory Item Plans for strategies have See NOTE below insufficient information to demonstrate alternate sources of instmment readings and adequate tolerances/accuracies if there is seismic impact to primary sources. Also, need identification of installed Page 8 of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 instrumentation location and power source.

3.1.1.3.B Confirmatory Item Need identification of Complete - See August 2014 Six-month instrumentation used to monitor FLEX update (Reference 10).

electrical power equipment including measurement tolerance/accuracy.

3.1.2.2.A Confirmatory Item A detailed fuel supply See NOTE below plan is to be provided in a future 6-month status update including what is needed, what is available, and how it will be transported.

3.1.3.2.A Confirmatory Item Completion of See NOTE below development of an administrative program to ensure pathways remain clear or compensatory actions will be implemented to ensure all strategies can be deployed during all modes of operation. Procedures and programs are to be developed.

3.1.3.2.B Confirmatory Item Completion of See NOTE below assessment on the adequacy of the debris removal equipment and the effect on the timeline to assure the critical times are capable of being met. This will be tracked as an open item in the 6 month update.

3.2.1.1.A Confirmatory Item Need benchmarks to Complete - See August 2014 Six-month demonstrate Modular Accident Analysis update (Reference 10).

Program (MAAP)4 is the appropriate code for simulation of ELAP.

3.2.1.1.B. Confirmatory Item The collapsed level Complete - See August 2014 Six-month must remain above Top of Active Fuel update (Reference 10).

(TAF) and the cool down rate must be within technical specification limits in the MAAP4 analysis.

3.2.1.1.C. Confirmatory Item MAAP4 must be used Complete - See August 2014 Six-month in accordance with Sections 4.1, 4.2, 4.3, update (Reference 10).

4.4, and 4.5 of the June 2013 position paper.

3.2.1.1.D. Confirmatory Item In using MAAP4, the Complete - See August 2014 Six-month licensee must identify and justify the subset update (Reference 10).

of key modeling parameters cited from Tables 4-1 through 4-6 of the "MAAP4 Application Guidance, Desktop Reference for Using MAAP4 Software, Revision 2" (Electric Power Research Institute Report 1 020236).

3.2.1.1.E. Confirmatory Item The specific MAAP4 Complete - See August 2014 Six-month analysis case that was used to validate the update (Reference 10).

timing of mitigating strategies in the integrated plan must be identified and available on the e-Portal for NRC staff to view. Alternately, a comparable level of information may be included in the Page 9of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 supplemental response.

3.2.1.2.A. Confirmatory Item Questions remain See NOTE below unanswered regarding recirculation pump seal leakage rates. Aspects such as pressure dependence, leakage phase assumptions (single phase liquid, steam, mixed) are not discussed.

3.2.1.3.A. Confirmatory Item Need gap analysis See NOTE below between results of the licensee's analysis results and those of BWROG document NEDC-33771 P. Results are presented in 6 month update; however there is no analysis of the relevance of differences.

3.2.1.3.B. Confirmatory Item Licensee plans further See NOTE below review and analysis to ensure suppression pool temperature will support RCIC operation.

3.2.1.3.C. Confirmatory Item Need identification of Complete - See February 2014 Six-Month the minimum voltage required for the de update (Reference 8).

buses and the basis of that determination.

3.2.1.4.A. Confirmatory Item Water quality issue and See NOTE below guidance on priority of water source usage need to be addressed.

3.2.1.4.B. Confirmatory Item Need completion of See NOTE below current evaluation of FLEX generator sizing calculation.

3.2.1.4.C. Confirmatory Item Need design and See NOTE below working pressure of hoses and fittings.

3.2.1.6.A. Confirmatory Item Licensee identified See NOTE below protection of equipment for Hardened Vent is to Order EA-13-109 (Reference 22).

Explain if this is equivalent to Order EA-12-049, as Order EA-13-109 does not require protection from external events.

3.2.2.A. Confirmatory Item The licensee identified See NOTE below modifications and procedures for SFP cooling are in development.

3.2.4.2.A. Confirmatory Item Modifications to restore Complete - See August 2014 Six-Month RCIC room cooling are being developed by update (Reference 10).

the licensee.

3.2.4.2.B. Confirmatory Item Modifications to restore Complete - See August 2014 Six-Month ventilation to the battery rooms via use of update (Reference 10).

the portable FLEX generators to address hydrogen and cold weather are being developed by the licensee.

3.2.4.4.A. Confirmatory Item Procedures for See NOTE below emergency lighting are to be developed for deployment of hands free flashlights.

Page 10of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 3.2.4.4.B. Confirmatory Item Confirm upgrades to See NOTE below communication system that resulted from the licensee communications assessment.

(ADAMS Accession Nos. ML12306A199 and ML13056A135.)

3.2.4.5.A. Confirmatory Item Verify completion of See NOTE below drafted procedures for protected and internal locked area access.

3.2.4.6.B. Confirmatory Item Site industrial Complete - See February 2014 Six-Month procedures and identification of protective update (Reference 8).

clothing, ice vests/packs, bottled water, etc.

is needed.

3.2.4.6.C. Confirmatory Item Need to address the use See NOTE below of appropriate human performance aids (e.g., component marking, connection schematics, installation sketches, photographs, etc.) which shall be included in the FLEX guidance implementing the FLEX strategies.

3.2.4.8.A. Confirmatory Item The licensee did not See NOTE below provide any information regarding loading/sizing calculations of portable diesel generators(s) and strategy for electrical isolation for FLEX electrical generators from installed plant equipment.

3.2.4.9.A. Confirmatory Item Need detailed fuel plan See NOTE below including fuel storage tank, truck, and day tank volumes and how fuel quality is maintained in the day tanks and in portable FLEX equipment.

3.2.4.10.A. Confirmatory Item Need detailed battery See NOTE below load profile for all mitigating strategies and a detailed discussion of loads that will be shed, how they will be shed, and what are the effects of the load shed.

3.4.A. Confirmatory Item Procedures for interface See NOTE below with the NSRC need to be developed.

NOTE: The information with respect to these ISE Open and Confirmatory items was presented to the NRC FLEX Audit Team during their onsite visit the week of January 26, 2015. Work is either pending closure (designated "See NOTE below") or completed for each of the items. The upcoming "status" of the items (OPEN or CLOSED) will be determined by the NRC in the pending Audit Report. Preliminary classification from the Audit Team, pending review and approval through the NRC audit report generation and approval process, is that all of these items are to be statused as closed with two exceptions as related to ISE Confirmatory Items 3.1.1.2.A, and 3.1.1.2.B. These particular items are being resolved via ongoing discussions between the NRC and Exelon. The status of all of these ISE Open and Confirmatory items will be updated in a future 6-Month Update pending receipt of the NRC FLEX Audit Report.

Page 11of24

Quad Cities Nuclear Power Station, Units 1 and 2 Fourth Six Month Status Report for the N

Implementation of FLEX February 27, 2015 7 Potential Draft Safety Evaluation Impacts There are no potential impacts to the Draft Safety Evaluation identified at this time.

8 References The following references supp01t the updates to the Overall Integrated Plan desctibed in this enclosure.

1. Quad Cites Overall Integrated Plan in Response to March 12, 2012, Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 28, 2013.
2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.
3. NRC Order EA-13-109, "Issuance of Order to Modify Licenses with Regard to reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013.
4. Quad Cities Nuclear Power Station, Units 1 and 2 First Six Month Status Report for the Implementation of Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated August 28, 2013.
5. Quad Cites Nuclear Power Station's Request for Relaxation from NRC Order EA-12-049, "Order Modifying Licenses With Regard To Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" dated February 27, 2014.
6. RCIC Pump and Turbine Durability Evaluation - Pinch Point Study, February 2013, 0000-0155-1545-RO, DRF 0000-0155-1541, Revision 0
7. Quad Cities Nuclear Power Station, Units 1 and 2 - Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies) (TAC NOS.MF 1048 and MF 1049), dated November 22, 2013.
8. Quad Cities Nuclear Power Station, Units 1 and 2 Second Six Month Status Report for the Implementation of Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated February 28, 2014.
9. NRC Approval of Exelon/Quad Cities Request for Relaxation from NRC Order EA-12-049, dated April 15, 2014 (ADAMS Accession No. ML14071A531).
10. Quad Cities Nuclear Power Station, Units 1 and 2 Third Six Month Status Report for the Implementation of Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated August 28, 2014.
11. Quad Cities MAAP Analysis to Support FLEX Initial Strategy, QC-MISC-013 Rev. 2, dated February 14, 2014.

Page 12of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 9 Attachments

1. Quad Cities Portable Equipment Phase 2
2. BWR Portable Equipment Phase 3 (Generic Equipment)
3. Quad Cities Station Sequence of Events Timeline Page 13 of 24

Quad Cities Nuclear Power Station, Units 1 and 2- Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Attachment 1 Quad Cities Portable Equipment Phase 2 Use and (potential I flexibility) diverse uses Peiformance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance I PM requirements equipment Two (2) low x x x 1343 gpm, 270 psia Equipment maintenance and pressure high testing will be performed in capacity self accordance with the industry prime pump templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Five (5) 480 x x x x x 500kW Equipment maintenance and V AC Portable testing will be performed in Diesel Driven accordance with the industry Generators templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Three (3) sets x x x x x (8) 250 ft cable spool Equipment maintenance and cable reels (8) RB 647 @ M-16. testing will be performed in prestaged accordance with the industry (8) 250 ft cable spool RB 647@ H-15. templates, as outlined in JLD-2 of 3 required ISG-2012-01 section 6 and for power (8) 250 ft cable spool NEI 12-06 section 11.

restoration to TB 639@ F-1.

both units Page 14 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Quad Cities Portable Equipment Phase 2 Use and (potential /flexibility) diverse uses Performance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance I PM requirements equipment Two (2) x x x Haul portable water Equipment maintenance and Tandem Axle manifold, 5" and 3" testing will be performed in Hose Trailer hoses, and Well pump accordance with the industry motor starter. templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

One ( 1) Massey x x x x Tow vehicle and debris Equipment maintenance and Ferguson removal testing will be performed in 461 OL Tractor accordance with the industry with bucket, templates, as outlined in JLD-pintel hitch ISG-2012-01 section 6 and NEI 12-06 section 11 Ford F750 x x x x Tow vehicle, portable Equipment maintenance and Truck w/snow equipment refueling testing will be performed in plow and two vehicle, and debris accordance with the industry (2) 118 gal removal vehicle templates, as outlined in JLD-diesel fuel ISG-2012-01 section 6 and tanks with NEI 12-06 section 11.

transfer pump Six (6) 5.5 kW x Equipment maintenance and portable diesel testing will be performed in generators accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Page 15 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Quad Cities Portable Equipment Phase 2 Use and (potential I flexibility) diverse uses Peiformance Criteria Maintenance List portable Core Containment SFP Instrumentation Accessibility Maintenance I PM requirements equipment Ten (10) x x x AC, 6250 SCFM Equipment maintenance and portable fans testing will be performed in with ducting accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

6 large area x AC. 13,300 cfm. Equipment maintenance and fans testing will be performed in accordance with the industry templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

(2) Portable x x x x x Equipment maintenance and diesel fuel testing will be performed in transfer pumps accordance with the industry and hoses templates, as outlined in JLD-ISG-2012-01 section 6 and NEI 12-06 section 11.

Page 16 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Attachment 2 BWR Portable Equipment Phase 3 (Generic Equipment)

Note: The equipment listed is the generic equipment list provided by the National SAFER Response Center and even though Quad Cities does not require this equipment in our FLEX strategies, this equipment will be available from the NSRC and could be utilized in the Phase 3 time period.

{Based on AREVA National SAFER Response Center Equipment Technical Requirements" document 51-9199717-013.}

Use and (potential /flexibility) diverse uses Peiformance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment Medium x x x x x 1 MW output at 4160 Voltage Diesel Vac, three phase Note 1 Generator Low Voltage x x x x x 1100 kW output at 480 Diesel Vac, three phase Notez Generator High Pressure x 2000 psi shutoff head, Injection 60 gpm capacity Pump SG/RPV x 500 psi I 500 gpm Makeup Pump Low Pressure I x x x 300 psi shutoff head, Medium Flow 2500 gpm max flow Pump Low Pressure I x x x 150 psi shutoff head, High Flow 5000 gpm max flow Pump Cable I x x x Various as determined Page 17 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 BWR Portable Equipment Phase 3 (Generic Equipment)

Note: The equipment listed is the generic equipment list provided by the National SAFER Response Center and even though Quad Cities does not require this equipment in our FLEX strategies, this equipment will be available from the NSRC and could be utilized in the Phase 3 time period.

{Based on AREVA "National SAFER Response Center Equipment Technical Requirements" document 51-9199717-013.}

Use and (potential /flexibility) diverse uses Peiformance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment Electrical by AREVA document #

51- 9199717 - 013 Hose/ x x x Various as determined Mechanical by AREVA document#

Connections 51- 9199717 - 013 Lighting x 40,000 lumens Towers Diesel Fuel 500 gallon air-lift Transfer container Diesel Fuel 264 gallon tank, with Transfer Tank mounted AC/DC pumps Portable Fuel 60 gpm after filtration Transfer Pump Electrical 4160 V, 250 MVA Distribution 1200A System Note 1: l MW is the individual generator output, and 2 MW is the total standard output to be supplied by the Phase 3 MV generators to satisfy identified load demands. The total output is created by connection of several smaller generators in parallel. Loads in excess of 2 MW are planned to be addressed as additional generators classified as non-generic equipment (see Section 8.4 of AREVA document).

Page 18 of 24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 BWR Portable Equipment Phase 3 (Generic Equipment)

Note: The equipment listed is the generic equipment list provided by the National SAFER Response Center and even though Quad Cities does not require this equipment in our FLEX strategies, this equipment will be available from the NSRC and could be utilized in the Phase 3 time period.

{Based on AREVA National SAFER Response Center Equipment Technical Requirements" document 51-9199717-013.}

Use and (potential /flexibility) diverse uses Peiformance Criteria Notes List portable Core Containment SFP Instrumentation Accessibility equipment Note 2: The 1100 kW unit is derated to 1000 kW.

Phase 3 Response Equipment/Commodities Item Notes Radiation Protection Equipment The NSRC will not stock this type of equipment but this equipment will be requested from site-to-site and utility-to-utility on an as required basis.

  • Survey instruments
  • Dosimetry
  • Off-site m on itoring/sam piing Commodities The NSRC will not stock these commodities but they will be requested from site-to-site and
  • Food utility-to-utility on an as required basis .
  • Potable water Page 19of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Attachment 3 Quad Cities Station Sequence of Events Timeline Page 20of24

Quad Cities Nuclear Power Station, Units 1 and 2- Fourth Six Month Status Report for the Implementation of FLEX February 27, 20i5 Action Elapsed I Action item Time 1 I 0 I Event Starts NA Plant at 100% power 2 0 Reactor Scram and SBO. NA Event Initiation I

3 I Omin Group I isolation due to loss of power to N Loss of AC power causes Group 1 isolation due to loss of power to trip instrumentation. system [UFSAR 7.3.2.2]

4 l --2min I Operating crew enters applicable EOPs and N QGA 100 RPV Control abnormal procedures for LOOP. EOP entry QCOA 6100-03 Loss of Offsite Power conditions; Low Reactor water level and High Reactor pressure 5 I -2min I RCIC Manually started and injects to restore N Reactor operator initiates or verifies initiation of reactor water level level to normal operating band. restoration with steam driven high pressure injection. [UFSAR Section 1.2.2.5]

QGA l 00 RPV Control QCOP 1300-02 RCIC System Manual Startup This is not time critical because if not completed automatic initiation will occur at the Low-Low level setpoint.

6 I -2min I ERV valves operation is monitored and manual N QGA 100 RPV Control operation initiated to control RPV pressure.

QCOP 0203-01 Reactor Pressure Control Using Manual Relief Valve Actuation.

Not time critical as automatic cycling of ERV s is controlling RPV pressure and manual control stabilizes system operation but does not impact key function control.

1 Instructions: Provide justification in the remark column if No or NA is selected for Time Constraint. If YES, include technical basis discussion as required by NEI 12-06 section 3.2. i .7 Page 21of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Action Elapsed Action Time Remarks /Applicabm~y ',

item Time Constr *

aiot .

YJNl 7 -5 mins Attempt to manually start emergency diesel N QCOA 6100-03 Loss of Offsite Power.

generators (UI, U2 and 1/2), and enter SBO No success will occur from this action.

procedure.

QCOA 6100-04, Station Blackout 8 -5 mins DC load shedding initiated per QCOA 6100-03 N QOA 6900-07 Loss of AC Power to the 125 VDC Battery Charger with Simultaneous Loss of Auxiliary Electric Power. Initiation of load shedding is not time critical - completion of load shedding is time critical.

9 -5 mins Reactor Operator control RPV level with RCIC N QGA 100, RPV Control QCOP 1300-02 This action controls the system operation to maintain parameters within the EOP specified band and is not time critical as system operation will continue without this action.

10 10 mins Commence RPV depressurization using ERVs at N QCOP 0203-01 less than or equal to 80 deg F per hour.

Not time critical as initiation of depressurization controls the RPV pressure prior to EOP directed operation due to HCTL of suppression chamber temperature requiring an emergency depressurization.

11 30 mins DC load shedding completed y QOA6900-07 12 30 mins Defeat RCIC Low Pressure Isolation Logic N Not time critical since RPV depressurization will be stopped prior to the RCIC Low Pressure Isolation setpoint per QGA 100 (in accordance with EPG, Rev 3).

QCOP 1300-10 13 -60 mins Control Room crew has assessed SBO and plant y Time sensitive in that decision drives timeline for setup of FLEX equipment conditions and declares an Extended Loss of AC and early venting.

Power (ELAP) event.

QCOA 6100-04 Page22 of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Action Elapsed I Action item Time 14 I . . . 60 mins I Equipment Operators dispatched to begin y QCOP 0050-01, 02 setup/connection of FLEX equipment (480VAC QCOP 0050-05, 07 generators to power battery chargers and FLEX DC coping analysis shows the following DC battery capabilities:

pump), and commence FLEX DC load shed.

125 VDC / 10 hrs 250 VDC I 9 hrs 15 I 90 mins I FLEX DC load shed complete. ly IDC coping analysis assnmes FLEX load shed is complete by 90 minutes.

Therefore, this action is time critical.

16 I 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />  ! Defeat RCIC High area temperature isolations y QCOP 1300-10. This action is critical at 8.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> when RCIC room temperature reaches 150°F, per Gothic analysis. The RCIC room temperature does not reach 180F in the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

17 4 hrs 480VAC FLEX generators connected to the y Restore AC power to battery chargers prior to loss of each battery at:

Safety Related Busses. This supplies battery 125 VDC / 10 hrs chargers for 125VDC (Div. 1and2) and 250VDC buses. I I 250 VDC I 9 hrs 18 I 4 hrs I FLEX pumps connected and alignment for IN IQCOP 0050-06 suppression pool injection established. This action becomes time critical when early containment venting is initiated.

19 -5.3 hrs Initiate early containment venting strategy at a y QGA 200, Primary Containment Control (EPG Rev 3)

Containment pressure of 10 psig. Open the -5.3 hrs is projected via MAAP analysis as when Containment pressure Reliable Hardened Containment Vent from the reaches 10 psig.

wetwell to maintain suppression pool temperatures less than -230 deg F to support long term RCIC operation.

Page23 of24

Quad Cities Nuclear Power Station, Units 1 and 2 - Fourth Six Month Status Report for the Implementation of FLEX February 27, 2015 Action Elapsed I Action item Time 20 I . . . 5,5 hrs I Heat Capacity Temperature Limit (HCTL) curve projected to be exceeded via MAAP analysis, ly I QGA 200 (EPG Rev 3)

RPV blowdown stops at -200 psig in RPV to preserve RCIC operation.

RPV blowdown to -200 psig required. RPV pressure now maintained 150-250 psig range to support RCIC operation.

I 21 I -5.5 hrs I FLEX pumps connected and alignment for RPV N QCOP 0050-06 injection established.

RPV blowdown is completed and RCIC is shut down.

22 I 12 hrs I Begin makeup to SFP with the FLEX pump to y QCOP 0050-06 maintain level above top of fuel.

QGA 300, Secondary Containment Control (EPG Rev 3)

The worst case SFP heat load scenario shows a time-to-boil of 13.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

The time to reach top of fuel is 147 hours0.0017 days <br />0.0408 hours <br />2.430556e-4 weeks <br />5.59335e-5 months <br />.

23 I 24 hrs l Initial equipment from National SAFER JN I Per NEI 12-06, Section 12 (NSRC).

Response Center becomes available.

24 I 24 -72 hrs I Continue to maintain critical functions of core N Not time critical/sensitive since Phase 2 actions result in indefinite coping cooling (via FLEX pump injection), containment times for all safety functions.

control, and SFP cooling (FLEX pump injection to SFP). Utilize initial NSRC equipment in spare capacity.

Page 24of24

Retrieved from "https://kanterella.com/w/index.php?title=RS-15-024,_Fourth_Six-Month_Status_Report_in_Response_to_March_12,_2012_Commission_Order_Modifying_Licenses_with_Regard_to_Requirements_for_Mitigation_Strategies_for_Beyond-Design-Basis_External_Events_(Order_Number_EA-12-049)&oldid=2449683"