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| issue date = 01/12/2018
| issue date = 01/12/2018
| title = NRC Design Bases Assurance Inspection (Teams): Inspection Report 05000254/2017007; 05000265/2017007 (DRS-M.Jones)
| title = NRC Design Bases Assurance Inspection (Teams): Inspection Report 05000254/2017007; 05000265/2017007 (DRS-M.Jones)
| author name = Jeffers M T
| author name = Jeffers M
| author affiliation = NRC/RGN-III/DRS/EB2
| author affiliation = NRC/RGN-III/DRS/EB2
| addressee name = Hanson B C
| addressee name = Hanson B
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| addressee affiliation = Exelon Generation Co, LLC, Exelon Nuclear
| docket = 05000254, 05000265
| docket = 05000254, 05000265
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:
{{#Wiki_filter:UNITED STATES uary 12, 2018
[[Issue date::January 12, 2018]]


Mr. Bryan C. Hanson Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
==SUBJECT:==
QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2- NRC DESIGN BASES ASSURANCE INSPECTION (TEAMS): INSPECTION REPORT 05000254/2017007; 05000265/2017007


SUBJECT: QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 NRC DESIGN BASES ASSURANCE INSPECTION (TEAMS): INSPECTION REPORT 05000254/2017007; 05000265/2017007
==Dear Mr. Hansen:==
On December 28, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Baseline Design Bases Assurance Inspection (Teams) at your Quad Cities Nuclear Power Station. The enclosed report documents the results of this inspection, which were discussed on December 28, 2018, with Mr. Humphrey, and other members of your staff.


==Dear Mr. Hansen:==
Based on the results of this inspection, no violations of significance were identified.
On December 28, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Baseline Design Bases Assurance Inspection (Teams) at your Quad Cities Nuclear Power Station. The enclosed report documents the results of this inspection, which were discussed on December 28, 2018, with Mr. Humphrey, and other members of your staff. Based on the results of this inspection, no violations of significance were identified. This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR Inspections, Exemptions, Requests for  
 
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.


Sincerely,
Sincerely,
/RA/ Mark T. Jeffers, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50254, 50265 License Nos. DPR29;` DPR30 Enclosure: IR 05000254/2017007; 05000265/2017007 cc: Distribution via LISTSERV B. Hanson -2- Letter to Bryan C. Hanson from Mark T. Jeffers dated January 12, 2018
/RA/
Mark T. Jeffers, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-254, 50-265 License Nos. DPR-29;` DPR-30


SUBJECT: QUAD CITIES NUCLEAR GENERATING PLANTNRC DESIGN BASES ASSURANCE INSPECTION (PROGRAMS): INSPECTION REPORT 05000254/2017007; 05000265/2017007 DISTRIBUTION: Jeremy Bowen RidsNrrDorlLpl3 RidsNrrPMQuadCities Resource RidsNrrDirsIrib Resource Steven West Darrell Roberts Richard Skokowski Allan Barker Carole Ariano Linda Linn DRPIII DRSIII ROPreports.Resource@nrc.gov  ADAMS Accession Number ML18012A450 OFFICE RIII RIII RIII RIII NAME MJones:cl MJeffers DATE 01/12/18 01/12/18 OFFICIAL RECORD COPY Enclosure U.S. NUCLEAR REGULATORY COMMISSION REGION III Docket No: 50254; 50265 License No: DPR29; DPR30 Report No: 05000254/2017007; 05000265/2017007 Licensee: Exelon Generating Facility: Quad Cities Nuclear Power Station Location: Cordova, IL Dates: November 13December 28, 2017 Inspectors: M. Jones, Engineering Inspector, Lead A. Dunlop, Senior Engineering Inspector, Mechanical I. Hafeez, Engineering Inspector, Electrical D. Betancourt, Operations Inspector H. Leake, Electrical Contractor W. Sherbin, Mechanical Contractor Approved by: M. Jeffers, Chief Engineering Branch 2 Division of Reactor Safety 2
===Enclosure:===
IR 05000254/2017007; 05000265/2017007
 
REGION III==
Docket No: 50-254; 50-265 License No: DPR-29; DPR-30 Report No: 05000254/2017007; 05000265/2017007 Licensee: Exelon Generating Facility: Quad Cities Nuclear Power Station Location: Cordova, IL Dates: November 13-December 28, 2017 Inspectors: M. Jones, Engineering Inspector, Lead A. Dunlop, Senior Engineering Inspector, Mechanical I. Hafeez, Engineering Inspector, Electrical D. Betancourt, Operations Inspector H. Leake, Electrical Contractor W. Sherbin, Mechanical Contractor Approved by: M. Jeffers, Chief Engineering Branch 2 Division of Reactor Safety Enclosure


=SUMMARY=
=SUMMARY=
Inspection Report 05000254/2017007; 05000265/2017007, 11/13/201712/01/2017; Quad Cities Nuclear Power Station; Design Bases Assurance Inspection (Teams). The inspection was a 2-week onsite baseline inspection that focused on the design of components. The inspection was conducted by regional engineering inspectors and two consultants. No findings of significance were identified by the inspectors. The U.S. Nuclear program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-July 2016.
Inspection Report 05000254/2017007; 05000265/2017007, 11/13/2017-12/01/2017; Quad
 
Cities Nuclear Power Station; Design Bases Assurance Inspection (Teams).
 
The inspection was a 2-week onsite baseline inspection that focused on the design of components. The inspection was conducted by regional engineering inspectors and two consultants. No findings of significance were identified by the inspectors. The U.S. Nuclear Regulatory Commissions program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 201


===NRC-Identified===
===NRC-Identified===
and Self-Revealed Findings No findings were identified during this inspection.
and Self-Revealed Findings No findings were identified during this inspection.


=== Licensee-Identified Violations===
===Licensee-Identified Violations===
 
No findings were identified during this inspection.
No findings were identified during this inspection.
3


=REPORT DETAILS=
=REPORT DETAILS=


==REACTOR SAFETY==
==REACTOR SAFETY==
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity
Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity {{a|1R21}}
{{a|1R21}}
==1R21 Design Bases Assurance Inspection (Teams)==
==1R21 Design Bases Assurance Inspection (Teams)==
{{IP sample|IP=IP 71111.21M}}
{{IP sample|IP=IP 71111.21M}}
===.1 Introduction The objective of the Design Bases Assurance Inspection is to verify that design bases have been correctly implemented for the selected risk significant components, modifications, and that operating procedures and operator actions are consistent with design and licensing bases.===
===.1 Introduction===
As plants age, their design bases may be difficult to determine and an important design feature may be altered or disabled during a modification. The inspection also monitors the implementation of modifications to structures, systems, and components as modifications to one system may also affect the design bases and functioning of interfacing systems as well as introduce the potential for common cause failures. The Probabilistic Risk Assessment (PRA) model assumes the capability of safety systems and components to perform their intended safety function successfully. This inspectable area verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for which there are no indicators to measure performance. Specific documents reviewed during the inspection are listed in the Attachment to the report.


===.2 Inspection Sample Selection Process The inspectors selected risk-significant components and operator actions for review===
The objective of the Design Bases Assurance Inspection is to verify that design bases have been correctly implemented for the selected risk significant components, modifications, and that operating procedures and operator actions are consistent with design and licensing bases. As plants age, their design bases may be difficult to determine and an important design feature may be altered or disabled during a modification. The inspection also monitors the implementation of modifications to structures, systems, and components as modifications to one system may also affect the design bases and functioning of interfacing systems as well as introduce the potential for common cause failures. The Probabilistic Risk Assessment (PRA) model assumes the capability of safety systems and components to perform their intended safety function successfully. This inspectable area verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for which there are no indicators to measure performance.
Quad Cities Nuclear Power Station Standardized Plant Analysis Risk Model. In general, the selection was based upon the components and operator actions having a risk achievement worth of greater than 1.3 and/or a risk reduction worth greater than 1.005. Based on this process, a number of risk-significant components, including those with Large Early Release Frequency implications, were selected for the inspection. The operator actions or operating procedures selected for review included actions taken by operators both inside and outside of the control room during postulated accident scenarios associated with the selected components. The inspectors performed a margin assessment and detailed review of the selected risk-significant components to verify that the design bases have been correctly implemented and maintained. This design margin assessment considered original design reductions caused by design modification, or power uprates, or reductions due to degraded material condition. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as performance test results, significant corrective action, repeated maintenance activities, Maintenance Rule (a)(1) status, components requiring an operability evaluation, system health reports, and U.S. Nuclear Regulatory Commission (NRC) resident inspector input of problem areas/equipment. Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense in depth margins. A summary of the reviews performed and are included in the following sections of the report.


4 The inspectors also identified modifications to mitigating systems for review. In addition, the inspectors selected procedures and operating experience issues associated with the selected components. This inspection constituted 11 samples (5 components, with 1 component associated with Large Early Release Frequency implications, 4 modifications, and 2 operating experience) as defined in Inspection Procedure 71111.21M-02.01.
Specific documents reviewed during the inspection are listed in the Attachment to the report.
 
===.2 Inspection Sample Selection Process===
 
The inspectors selected risk-significant components and operator actions for review using information contained in the licensees PRA and the Quad Cities Nuclear Power Station Standardized Plant Analysis Risk Model. In general, the selection was based upon the components and operator actions having a risk achievement worth of greater than 1.3 and/or a risk reduction worth greater than 1.005. Based on this process, a number of risk-significant components, including those with Large Early Release Frequency implications, were selected for the inspection. The operator actions or operating procedures selected for review included actions taken by operators both inside and outside of the control room during postulated accident scenarios associated with the selected components.
 
The inspectors performed a margin assessment and detailed review of the selected risk-significant components to verify that the design bases have been correctly implemented and maintained. This design margin assessment considered original design reductions caused by design modification, or power uprates, or reductions due to degraded material condition. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as performance test results, significant corrective action, repeated maintenance activities, Maintenance Rule (a)(1) status, components requiring an operability evaluation, system health reports, and U.S. Nuclear Regulatory Commission (NRC) resident inspector input of problem areas/equipment. Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense in depth margins. A summary of the reviews performed and are included in the following sections of the report.
 
The inspectors also identified modifications to mitigating systems for review. In addition, the inspectors selected procedures and operating experience issues associated with the selected components.
 
This inspection constituted 11 samples (5 components, with 1 component associated with Large Early Release Frequency implications, 4 modifications, and 2 operating experience) as defined in Inspection Procedure 71111.21M-02.01.


===.3 Component Design===
===.3 Component Design===


====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications, design basis documents, drawings, calculations and other available design basis information, to determine the performance requirements of the selected components. The inspectors used applicable industry standards, such as the American Society of Mechanical Engineers Code, Institute of Electrical and Electronics Engineers Standards, design. The NRC also evaluated licensee actions, if any, taken in response to NRC issued operating experience, such as Bulletins, Generic Letters, Regulatory Issue Summaries, and Information Notices. The review was to verify that the selected components would function as designed when required and support proper operation of the associated systems. The attributes that were needed for a component to perform its required function included process medium, energy sources, control systems, operator actions, and heat removal. The attributes to verify that the component condition and tested capability was consistent with the design bases and was appropriate may include installed configuration, system operation, detailed design, system testing, equipment and environmental qualification, equipment protection, component inputs and outputs, operating experience, and component degradation. For each of the components selected, the inspectors reviewed the maintenance history, preventive maintenance activities, system health reports, operating experience-related information, vendor manuals, electrical and mechanical drawings, and licensee corrective action program documents. Field walkdowns were conducted for all accessible components to assess material condition, including age-related degradation and to verify that the as-built condition was consistent with the design. Other attributes reviewed are included as part of the scope for each individual component. The following five components (samples), including a component with Large Early Release Frequency were reviewed:  Unit 1/2 Reactor Building Closed Cooling Water Pump (1/2-3701):  The team inspected the performance of reactor building closed cooling water (RBCCW) pump 1/2-3701 and the associated potential impact on plant operations (failure of the pumps could lead to a plant transient). The inspection included interviews with system and design engineers and operators, system walkdowns; and reviews of drawings, and normal, alarm response, and abnormal plant procedures. postulated automatic initiation of stand-by pump 1/2-3701 due to a discharge header low-pressure signal; and operator actions following this initiation. The team reviewed plant procedures to determine whether the operator actions were acceptable to assure reliable operation of the RBCCW system. Additionally, the 5 inspectors reviewed electrical drawings, including one-lines and schematics to verify consistency with UFSAR descriptions and engineering analyses. Loading and voltage calculations were reviewed for pump operation on both offsite and onsite power sources (emergency diesel generators) to verify the adequacy of the motor power supplies. Finally, the team reviewed condition reports, maintenance history, and system health reports to determine the overall health of the pump, and to determine if issues entered into the Corrective Action Program were properly addressed.
The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications, design basis documents, drawings, calculations and other available design basis information, to determine the performance requirements of the selected components. The inspectors used applicable industry standards, such as the American Society of Mechanical Engineers Code, Institute of Electrical and Electronics Engineers Standards, and the National Electric Code, to evaluate acceptability of the systems design. The NRC also evaluated licensee actions, if any, taken in response to NRC issued operating experience, such as Bulletins, Generic Letters, Regulatory Issue Summaries, and Information Notices. The review was to verify that the selected components would function as designed when required and support proper operation of the associated systems. The attributes that were needed for a component to perform its required function included process medium, energy sources, control systems, operator actions, and heat removal. The attributes to verify that the component condition and tested capability was consistent with the design bases and was appropriate may include installed configuration, system operation, detailed design, system testing, equipment and environmental qualification, equipment protection, component inputs and outputs, operating experience, and component degradation.


Unit 1/2 Emergency Diesel Generator (EDG) Ventilation Fan (1/2-5727):  The team reviewed the calculations related to EDG room supply air ventilation requirements, and compared the calculated airflow requirements with fan test data to ensure adequate heat removal capability. The team reviewed failure positions of pneumatic louver operators in the ventilation enclosures to ensure louvers will open on a loss of instrument air. The team also reviewed the control and wiring diagrams for the starting and stopping of the ventilation fan. Preventive maintenance activities for lubricating the ventilation exhaust fan motor and fan shaft bearings were also reviewed to ensure vendor recommended preventive maintenance activities were being performed. The inspection included interviews with system and design engineers and operators, system walkdowns; and reviews of drawings, and alarm response procedures.
For each of the components selected, the inspectors reviewed the maintenance history, preventive maintenance activities, system health reports, operating experience-related information, vendor manuals, electrical and mechanical drawings, and licensee corrective action program documents. Field walkdowns were conducted for all accessible components to assess material condition, including age-related degradation and to verify that the as-built condition was consistent with the design. Other attributes reviewed are included as part of the scope for each individual component.


125 Vdc Distribution Panels:  The team reviewed load flow calculations to determine whether the panels were applied within their required current ratings. The team reviewed voltage drop calculations to determine whether loads had their required minimum voltage and whether they were applied within their maximum voltage rating during battery equalizing. The team reviewed short circuit and protective device calculations to determine whether equipment was adequately protected and immune from spurious tripping. The team reviewed maintenance schedules, procedures, and maintenance records, including circuit breaker test requirements, to determine whether the panels and their associated circuit breakers were being properly maintained. In addition, the team performed a visual inspection of the 125Vdc Distribution Panels to assess material condition and the presence of hazards. Alternating Current (AC) Bus Supplying Power to Residual Heat Removal (RHR) Pumps 1A and 1B (4160V Switchgear 13-1):  The team reviewed one-line diagrams, drawings, calculations of loading, short circuit, voltage drop, and protective relay trip setpoints to verify the capability of the switchgear to adequately supply the essential loads when powered by the unit auxiliary transformer, reserve auxiliary transformer, or EDG. The team also verified the maximum short circuit current available at the bus was within the interrupting capacity of the feeder breakers. The team reviewed the fast transfer design of the switchgear from the unit auxiliary transformer (main generator source) to the reserve auxiliary transformer (offsite power source) when the main generator trips. The team verified the feeder cable size and ampacity for the RHR pumps was adequate to carry the maximum load current. Administrative controls were reviewed for mitigating potential conductor and EDG overload conditions identified in the load flow and EDG sizing calculations. The inspectors performed a walkdown of 4160V Switchgear 13-1 to observe its material condition. Main Steam Isolation Valves (MSIV) (1-203-001(A-D), 1-203-002(A-D)):  The team reviewed the design basis of the inboard and outboard MSIVs for Unit 1, the basis for its closure time requirement, and the associated control logic. The 6 team reviewed operating procedures associated with the MSIVs under normal and accident conditions. The air accumulator leakage limits, leak test procedures, air quality, and recent test results were reviewed to verify acceptance criteria were met and performance degradation would be identified. The team reviewed closure time surveillance procedures and recent results to verify that the test results were representative of the most limiting postulated accident conditions. The (a)(1) action plan for the MSIV timing issues was reviewed to verify the cause(s) were identified and corrective actions were planned or implemented to resolve the timing issue. The team reviewed the testing of the control circuits required to close the MSIVs to ensure that the testing was comprehensive.
The following five components (samples), including a component with Large Early Release Frequency were reviewed:
Unit 1/2 Reactor Building Closed Cooling Water Pump (1/2-3701): The team inspected the performance of reactor building closed cooling water (RBCCW)pump 1/2-3701 and the associated potential impact on plant operations (failure of the pumps could lead to a plant transient). The inspection included interviews with system and design engineers and operators, system walkdowns; and reviews of drawings, and normal, alarm response, and abnormal plant procedures. This review focused on the RBCCW systems response to a postulated automatic initiation of stand-by pump 1/2-3701 due to a discharge header low-pressure signal; and operator actions following this initiation. The team reviewed plant procedures to determine whether the operator actions were acceptable to assure reliable operation of the RBCCW system. Additionally, the inspectors reviewed electrical drawings, including one-lines and schematics to verify consistency with UFSAR descriptions and engineering analyses. Loading and voltage calculations were reviewed for pump operation on both offsite and onsite power sources (emergency diesel generators) to verify the adequacy of the motor power supplies. Finally, the team reviewed condition reports, maintenance history, and system health reports to determine the overall health of the pump, and to determine if issues entered into the Corrective Action Program were properly addressed.


===.4 Findings No findings were identified. .5 Mitigating System Modifications===
Unit 1/2 Emergency Diesel Generator (EDG) Ventilation Fan (1/2-5727): The team reviewed the calculations related to EDG room supply air ventilation requirements, and compared the calculated airflow requirements with fan test data to ensure adequate heat removal capability. The team reviewed failure positions of pneumatic louver operators in the ventilation enclosures to ensure louvers will open on a loss of instrument air. The team also reviewed the control and wiring diagrams for the starting and stopping of the ventilation fan.
 
Preventive maintenance activities for lubricating the ventilation exhaust fan motor and fan shaft bearings were also reviewed to ensure vendor recommended preventive maintenance activities were being performed. The inspection included interviews with system and design engineers and operators, system walkdowns; and reviews of drawings, and alarm response procedures.
 
125 Vdc Distribution Panels: The team reviewed load flow calculations to determine whether the panels were applied within their required current ratings. The team reviewed voltage drop calculations to determine whether loads had their required minimum voltage and whether they were applied within their maximum voltage rating during battery equalizing. The team reviewed short circuit and protective device calculations to determine whether equipment was adequately protected and immune from spurious tripping. The team reviewed maintenance schedules, procedures, and maintenance records, including circuit breaker test requirements, to determine whether the panels and their associated circuit breakers were being properly maintained. In addition, the team performed a visual inspection of the 125Vdc Distribution Panels to assess material condition and the presence of hazards.
 
Alternating Current (AC) Bus Supplying Power to Residual Heat Removal (RHR)
Pumps 1A and 1B (4160V Switchgear 13-1): The team reviewed one-line diagrams, drawings, calculations of loading, short circuit, voltage drop, and protective relay trip setpoints to verify the capability of the switchgear to adequately supply the essential loads when powered by the unit auxiliary transformer, reserve auxiliary transformer, or EDG. The team also verified the maximum short circuit current available at the bus was within the interrupting capacity of the feeder breakers. The team reviewed the fast transfer design of the switchgear from the unit auxiliary transformer (main generator source) to the reserve auxiliary transformer (offsite power source) when the main generator trips. The team verified the feeder cable size and ampacity for the RHR pumps was adequate to carry the maximum load current. Administrative controls were reviewed for mitigating potential conductor and EDG overload conditions identified in the load flow and EDG sizing calculations. The inspectors performed a walkdown of 4160V Switchgear 13-1 to observe its material condition.
 
Main Steam Isolation Valves (MSIV) (1-203-001(A-D), 1-203-002(A-D)): The team reviewed the design basis of the inboard and outboard MSIVs for Unit 1, the basis for its closure time requirement, and the associated control logic. The team reviewed operating procedures associated with the MSIVs under normal and accident conditions. The air accumulator leakage limits, leak test procedures, air quality, and recent test results were reviewed to verify acceptance criteria were met and performance degradation would be identified.
 
The team reviewed closure time surveillance procedures and recent results to verify that the test results were representative of the most limiting postulated accident conditions. The (a)(1) action plan for the MSIV timing issues was reviewed to verify the cause(s) were identified and corrective actions were planned or implemented to resolve the timing issue. The team reviewed the testing of the control circuits required to close the MSIVs to ensure that the testing was comprehensive.
 
===.4 Findings===
 
No findings were identified.
 
===.5 Mitigating System Modifications===


====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed 4 permanent plant modifications to mitigating systems that had been installed in the plant during the last 3 years. This review included in-plant walkdowns for portions of the modified Unit 1/2 EDG ventilation fan, 1B RHR pump seal Cooler, 4160V switchgear bus 13-1, 125 Vdc distribution panels, and 125 Vdc normal and alternate batteries. The team reviewed the modifications to verify that the design bases, licensing bases, and performance capability of the components had not been degraded through modifications. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if: the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality. The team also used applicable industry standards to evaluate acceptability of the modifications. The modifications listed below were reviewed as part of this inspection effort:     -1001-29A to Increase   EC 398044 Revision 1ation for an Open 7
The team reviewed 4 permanent plant modifications to mitigating systems that had been installed in the plant during the last 3 years. This review included in-plant walkdowns for portions of the modified Unit 1/2 EDG ventilation fan, 1B RHR pump seal Cooler, 4160V switchgear bus 13-1, 125 Vdc distribution panels, and 125 Vdc normal and alternate batteries. The team reviewed the modifications to verify that the design bases, licensing bases, and performance capability of the components had not been degraded through modifications. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:
the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality.
 
The team also used applicable industry standards to evaluate acceptability of the modifications. The modifications listed below were reviewed as part of this inspection effort:
Engineering Change (EC) 398602, Replace the 1B RHR Pump Seal Cooler; EC 395167, Install Close Torque Switch Bypass Mod in 1-1001-29A to Increase Margin; EC 398044 Revision 1, Unit 1 4kv Bus Transfer Logic Modification for an Open Phase Event Concurrent with a LOCA; and EC 932979, U1 250 VDC MCC Cubicle Bucket Replacement.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The inspectors reviewed 2 operating experience issues (samples) to ensure that NRC generic concerns had been adequately evaluated and addressed by the licensee. The operating experience issues listed below were reviewed as part of this inspection: Information Notice 2015- and Generic Letter 2006-Operability of Offsite Power
The inspectors reviewed 2 operating experience issues (samples) to ensure that NRC generic concerns had been adequately evaluated and addressed by the licensee. The operating experience issues listed below were reviewed as part of this inspection:
Information Notice 2015-13, Main Steam Isolation Valve Failure Events; and Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The team performed a detailed reviewed of selected procedures associated with the inspections component samples. For the procedures listed time critical operator actions were reviewed for reasonableness, in plant action were walked down with a licensed operator, and any interfaces with other departments were evaluated. The procedures were compared to UFSAR, design assumptions, and training materials to assess their two scenarios: Anticipated Transient with a Scram, and Loss of AC to the 125 Volt Direct Current Battery Chargers with a simultaneous loss of auxiliary electrical Power. The following operating procedures were reviewed in detail: QGA   QCOA 6900-ss of AC Power to 125 VDC Battery Charger with   QCOP 3700- QCOA 3700- QCOP 1000- QGOA 6100- The inspectors performed a margin assessment and detailed review of four risk-significant and/or time critical operator actions. These actions were selected from based on risk achievement worth values, and   where possible, margins were determined by the review of the assumed design basis and UFSAR response times and performance times documented by job performance measures results. For the selected operator actions, the inspectors performed a detailed review and walk through of associated procedures, including 8 other actions, with an appropriate plant operator to assess operator knowledge level, adequacy of procedures, and availability of special equipment where required. The following operator actions were reviewed: Initiation of Torus Cooling during Appendix R scenarios; Manual Start of RHR Containment Cooling Mode of RHR; Initiate Drywell Spray during an Anticipate Transient without Scram; and Load Shed 125 VDC Loads following loss of AC Power.
The team performed a detailed reviewed of selected procedures associated with the inspections component samples. For the procedures listed time critical operator actions were reviewed for reasonableness, in plant action were walked down with a licensed operator, and any interfaces with other departments were evaluated. The procedures were compared to UFSAR, design assumptions, and training materials to assess their consistency. In addition, operator actions were observed at the stations simulator for two scenarios: Anticipated Transient with a Scram, and Loss of AC to the 125 Volt Direct Current Battery Chargers with a simultaneous loss of auxiliary electrical Power.
 
The following operating procedures were reviewed in detail:
QGA 101, Reactor Pressure Vessel Control (ATWS);
QCOA 6900-07, Loss of AC Power to 125 VDC Battery Charger with Simultaneous Loss of Auxiliary Electrical Power; QCOP 3700-02, RBCCW System Startup and Operation; QCOA 3700-06, RBCCW Line Break Inside Containment; QCOP 1000-30, Post Accident RHR Operation; and QGOA 6100-03, Loss of Offsite Power.
 
The inspectors performed a margin assessment and detailed review of four risk-significant and/or time critical operator actions. These actions were selected from the licensees PRA rankings of human action importance based on risk achievement worth values, and where possible, margins were determined by the review of the assumed design basis and UFSAR response times and performance times documented by job performance measures results. For the selected operator actions, the inspectors performed a detailed review and walk through of associated procedures, including observing the performance of some actions in the stations simulator and in the plant for other actions, with an appropriate plant operator to assess operator knowledge level, adequacy of procedures, and availability of special equipment where required.
 
The following operator actions were reviewed:
Initiation of Torus Cooling during Appendix R scenarios; Manual Start of RHR Containment Cooling Mode of RHR; Initiate Drywell Spray during an Anticipate Transient without Scram; and Load Shed 125 VDC Loads following loss of AC Power.


====b. Findings====
====b. Findings====
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====a. Inspection Scope====
====a. Inspection Scope====
The team reviewed a sample of the selected component problems identified by the licensee and entered into the corrective action program. The team reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions related to design issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the Corrective Action Program. The specific corrective action documents sampled and reviewed by the inspectors are listed in the attachment to this report. The team also selected two issues identified during previous Component Design Basis Inspections to verify that the concern was adequately evaluated and corrective actions were identified and implemented to resolve the concern, as necessary. The following issues were reviewed: Non-Cited Violation 5000254/265/2011009-02; Failure to Perform Required In-Service Testing of Shutdown Cooling Suction Valves; and Non-Cited Violation 05000254/2016008-01, Failure to Provide Appropriate Operating Instructions for Aligning a Battery Charger to the Station Black-Out Diesel Generator
The team reviewed a sample of the selected component problems identified by the licensee and entered into the corrective action program. The team reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions related to design issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the Corrective Action Program. The specific corrective action documents sampled and reviewed by the inspectors are listed in the attachment to this report.
 
The team also selected two issues identified during previous Component Design Basis Inspections to verify that the concern was adequately evaluated and corrective actions were identified and implemented to resolve the concern, as necessary. The following issues were reviewed:
Non-Cited Violation 5000254/265/2011009-02; Failure to Perform Required In-Service Testing of Shutdown Cooling Suction Valves; and Non-Cited Violation 05000254/2016008-01, Failure to Provide Appropriate Operating Instructions for Aligning a Battery Charger to the Station Black-Out Diesel Generator.


====b. Findings====
====b. Findings====
No findings were identified.
No findings were identified.
{{a|4OA6}}
==4OA6 Management Meetings==
===.1 Interim Exit Meeting Summary===


{{a|4OA6}}
On December 1, 2017, the inspectors presented the inspection results to Mr. Kenneth S. Ohr, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.
==4OA6 Management Meetings==
 
Any documents reviewed by the inspectors that were considered proprietary information were either returned to the licensee or handled in accordance with NRC policy on proprietary information. The team had outstanding questions that required additional review and a following exit meeting.
 
===.2 Exit Meeting Summary===


===.1 Interim Exit Meeting Summary On December 1, 2017, the inspectors presented the inspection results to Mr. Kenneth S. Ohr, and other members of the licensee staff.===
On December 28, 2017, the team presented the inspection results to Mr. M. Humphrey and other members of the licensee staff. The licensee acknowledged the issues presented. The team asked the licensee weather any materials examined during the inspection should be considered proprietary. Several documents reviewed by the team were considered proprietary information and were either returned to the licensee or handled in accordance with NRC policy on proprietary information.
The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. Any documents reviewed by the inspectors that were considered proprietary information were either returned to the licensee or handled in accordance with NRC policy on proprietary information. The team had outstanding questions that required additional review and a following exit meeting.


===.2 Exit Meeting Summary On December 28, 2017, the team presented the inspection results to Mr. M. Humphrey and other members of the licensee staff.===
ATTACHMENT:  
The licensee acknowledged the issues presented. The team asked the licensee weather any materials examined during the inspection should be considered proprietary. Several documents reviewed by the team were considered proprietary information and were either returned to the licensee or handled in accordance with NRC policy on proprietary information. ATTACHMENT:


=SUPPLEMENTAL INFORMATION=
=SUPPLEMENTAL INFORMATION=


==KEY POINTS OF CONTACT==
==KEY POINTS OF CONTACT==
Licensee  
 
: [[contact::K. Ohr]], Site Vice President  
Licensee
: [[contact::M. Humphrey]], Regulatory Assurance  
: [[contact::K. Ohr]], Site Vice President
: [[contact::R. Swart]], Engineering Supervisor  
: [[contact::M. Humphrey]], Regulatory Assurance
: [[contact::T. Bell]], Engineering Director  
: [[contact::R. Swart]], Engineering Supervisor
: [[contact::J. Bries]], Operations Director  
: [[contact::T. Bell]], Engineering Director
: [[contact::J. Cox]], Operations Supervisor  
: [[contact::J. Bries]], Operations Director
: [[contact::U.S. Nuclear Regulatory Commission R. Murray]], Senior Resident Inspector  
: [[contact::J. Cox]], Operations Supervisor
: [[contact::K. Carrington]], Resident Inspector  
U.S. Nuclear Regulatory Commission
: [[contact::R. Murray]], Senior Resident Inspector
: [[contact::K. Carrington]], Resident Inspector
 
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
==LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED==
Opened, Closed and  
Opened, Closed and  
===Discussed===
===Discussed===
None LIST OF ACRONYMS USED AC Alternating Current   EDG Emergency Diesel Generator MSIV Main Steam Isolation Valve NRC U.S. Nuclear Regulatory Commission   RBCCW Reactor Building Closed Cooling Water UFSAR Updated Final Safety Analysis Report
 
None LIST OF ACRONYMS USED AC             Alternating Current EC            Engineering Change EDG           Emergency Diesel Generator MSIV           Main Steam Isolation Valve NRC           U.S. Nuclear Regulatory Commission PRA            Probabilistic Risk Assessment RBCCW         Reactor Building Closed Cooling Water UFSAR         Updated Final Safety Analysis Report


==LIST OF DOCUMENTS REVIEWED==
==LIST OF DOCUMENTS REVIEWED==
The following is a list of documents reviewed during the inspection.
 
: Inclusion on this list does not imply that the NRC inspectors reviewed the documents in their entirety, but rather, that selected sections of portions of the documents were evaluated as part of the overall inspection effort.
: Inclusion of a document on this list does not imply NRC acceptance of the document or any part of it, unless this is stated in the body of the inspection report. CALCULATIONS Number Description or Title Revision 5570-31-19-1 125 VDC Fault Currents 8
: AOV-MEDP-QDC-RX-001 Inboard Main Steam Isolation Valve D/P Calc 0
: AOV-MEDP-QDC-RX-003 Outboard Main Steam Isolation Valve D/P Calc 0
: MPED-9391-01-001 MSIV Actuator Leakage and Accumulator Pressure Change 0 OPTIMA2-TR026QC-ATWS ATWS Analysis for the Introduction of
: SVEA-96 Optima2 Fuel at Quad Cities Units 1 & 2 1
: QDC-0203-M-0968 Main Steam Isolation Valves Sizing Calculation 1
: QDC-1000-S-2047 Flow Serve Seismic Report
: SR-1476 for RHR Pump Seal Cooler 0A
: QDC-6600-E-2037 Emergency Diesel Generator Technical Specification Allowed Voltage & Frequency Range Analyses 1
: QDC-6700-E-0939 Loss of Voltage Relay Setpoint for Buses 13-1, 14-1, 23-1, and 24-1 1
: QDC-6700-E-1498 Second Level Undervoltage Relay Setpoint 10
: QDC-6700-E-1503 Analysis of Load Flow, Short Circuit and Motor Starting using ETAP PowerStation 10
: QDC-6700-E-2116 Protective Relay Setting Calculation for 4kV Switchgear 13, 14, 13-1, and 14-1 10
: QDC-6700-E-2119 Quad Cities Open Phase Detection LOCA Analysis 0
: QDC-8300-E-0482 Evaluation of 125VDC System Coordination for Appendix R 9
: QDC-3700-M-1324 RBCCW
: System Combined DBD and dp Calculation 0A
: QDC-5700-H-1567 DG Room Ventilation 3 DRE06-0023 Diesel Generator Room Ventilation (Dresden Station) 2 
: CORRECTIVE ACTION DOCUMENTS GENERATED DUE TO THE INSPECTION Number Description or Title Date
: 4075556 DBAI Local Light Indication not lit
: MO-2-1001-23B 11/16/2017
: 4075558 DBAI Local Light Indication not lit
: MO-2-1001-26B 11/16/2017
: 4078813 Overdutied 125VDC Breakers When Batteries are Paralleled 11/27/2017
: 4078819 MSIV Vendor Drawing Not Updated in Timely Manner 11/29/2017
: 4078990 QCTS 4700-01 Procedure Reference Correction 11/29/2017
: 4079561 DBAI Fast Bus Transfer Analysis Documentation Gap
: 11/30/2017
: 4079575 DBAI ETAP Calc Potential Non-Conservatism & Quality Issue 11/30/2017
: CORRECTIVE ACTION DOCUMENTS REVIEWED DURING THE INSPECTION Number Description or Title Date
: 276519 State Estimator Program Transformer Models for Quad Cities 11/24/2004
: 351883 125 VDC Battery Loading 07/11/2005
: 689559 Discrepancy in Flow Data in OP Eval 10/25/2007
: 822508
: CDBI-Seismic Issue with 250VDC & U2 Alt 125VDC Battery 04/09/2010
: 1233693 Lack of Fast Bus Transfer Analysis of 4kV BusesOPEX 06/28/2011
: 1279066 CDBI - Reclassification of SDC Suction Valve for
: IST 10/20/2011
: 1288784 CDBITechnical Specification Limits for
: EDG 11/10/2011
: 1294758 Relay Chatter on the
: 1-0590-102G Relay 11/27/2011
: 1360634 1A RHR Pump Breaker Degraded 04/30/2012
: 1365523 Merlin Gerin Breaker Failure Analysis ReportOE 05/11/2012
: 1385451 Determine 1/2 EDG Vent Fan Motor
: Nameplate
: Data 03/16/2015
: 1407778 1-590-102H MSIV 203-1D 2D Closure Scram Signal Relay Chatter 08/31/2012
: 1425227 RBCCW Expansion Tanks Not Equal Level (1-3703) 10/11/2012
: 1431869 OIO
: Benchmarking for Validation of the Time Critical Actions 10/26/2012
: 1448655 Inability to Meet Time Critical Actions 11/30/2012
: 1452402 1D MSIV Relay
: 1-0595-149D Failed PMT,
: WO 1595343-02 12/14/2012
: 1462317 Dresden IRS1417005, 1443849. Slow Close of 2 Merlin Gerin Bkrs 01/14/2013
: 1485944 QCOS 0250-04 MSIV Closure Time Failed As-Found 03/11/2013
: 1486745 Q1R22 - LLRT INBD MSIV "A" Leakage = 85.358 SCFH 03/12/2013
: 1488540
: 1-0203-1A MSIV Wave Spring Found Damaged 03/16/2013
: 1493074 Q1R22 - 1B MSIV Limit Switch JB does Not Appear Secured 03/27/2013
: 1502238 EDG Freq and Volt TS Tolerance 08/31/2016
: 1506215 MRule: Performance Criteria Exceeded (Main Steam Valves) 04/24/2013
: 1667947
: RBCCW Expansion Tank Level Increasing 2"/Day On Both Units (1-3703) 06/04/2014
: 1669130 RBCCW Expansion Tank Level - Follow Up To
: IR 1667947 (1-3703) 06/08/2014
: 2462135 Q1R23 - INBD MSIV
: 1-0203-1A Exceeded TS Limit 03/02/2015
: 2465362 MSIV 2A Limit Switch 2B does not Operate Smoothly 03/09/2015
: 2487426 QCOA 6100-17 Procedures Issues 04/18/2015
: 2529943 1D MSIV Inboard Open Indication Sparked During Bulb Change 07/18/2015
: 2582864 Protective Relay Setting Enhancements Recommended 11/05/2015
: 2600694 Information Notice 2015-13 Review 02/03/2016
: 2668424 1/2 RBCCW Pump has 3 dpm Leak (0-3701) 05/12/2016
: 2682090 Trending 1/2 RBCCW Pump Leak: 6 dpm (0-3701) 06/16/2016
: 2706435 -17 Revision Issue 08/19/2016 
: CORRECTIVE ACTION DOCUMENTS REVIEWED DURING THE INSPECTION Number Description or Title Date
: 2732501 1A Charger has a step Change in AC Ripple Volts 10/25/2016
: 3986139 Transformer 22 Load Tap Changer 03/17/2017
: 3990038 MSIV As-Found Closure Timing Out of Band 03/27/2017
: 3990758 Q1R24 2C Outboard MSIV Found Outside of 9.8% 03/29/2017
: 3991086 Q1R24 1A MSIV PMT Leakage Exceeds TS Limit 03/29/2017
: 3994355 Q1R24 Potential FME Concerns with MSIV Air Manifolds 04/05/2017
: 4002511 MRULE A1Determenation Required for MSIVS RX0203-01 04/25/2017
: 4017529 NRC Concerns Associated with
: 1-0203-2D MSIV Actuator 06/01/2017
: 4031723 Perform ECAP (DG Ventilation) 08/18/2017
: 4036345 NOS ID: Incomplete Revision of EC392979DCS 7/27/2017
: 4065257 Corporate DC SME: OPEX for Battery Thermal Aging 10/20/2017
: 4066450 U1 1A 125V DC Battery Charger Amperage Oscillations 10/24/2017
: 4074482 OPEX Review
: 4061005 Finds in 2017-06 is Applicable to
: QDC 11/14/2017
: DRAWINGS Number Description or Title Revision 4E-1301 Sh. 3 Single Line Diagram AM 4E-1303 Key Diagram, 4160V Switchgear 11, 12, 13, and 14 Y 4E-1304 Key Diagram, 4160V Switchgears 13-1 and 14-1 AJ 4E-1306 Key Diagram, Reactor Building 480V SW Groups 18 and 19 AC 4E-1328 Single Line Diagram, Emergency Power System F 4E-1334 Relaying and Metering Diagram: 4160V Switchgear Buses 13-1 and 14-1 AJ 4E-1338 Schematic Diagram, Generator and Transformer Tripping Relays AX 4E-1343 Schematic Control Diagram, 4160V Bus 14 Main and Reserve Feed Gas Circuit Breakers AB 4E-1349 Sh. 1 Schematic Diagram, 480V Transformer 18 and 19 and Bus 18 and 19 Main Breakers X 4E-1349 Sh. 2 Schematic Diagram, 480V Transformer 18 and 19 and Bus 18 and 19 Main Breakers X 4E-1349 Sh. 3 Schematic Diagram, 480V Trans 18 and 19 and Buses 18 and 19 Main Breakers Z 4E-1351B Schematic Dia. DG Aux. and Start Relays Y 4E-1397 Schematic Control Diagram, Reactor Building Cooling Water Pumps 0 4E-1430 Sh. 1 Schematic Diagram, Core Spray Systems I and II BN 4E-1430 Sh. 2 Schematic Diagram, Core Spray Systems I and II BD 4E-1685D Wiring Diagram Turbine Building 125V DC Main Bus DIST. PNL. U 4E-1814F Wiring Dia. DG 1/2 Panel I 4E-2318B Overall Key Diagram 125V DC Distribution Centers D 4E-2685C Schematic Diagram Turbine Building 125VDC Main Bus 2 and 2A R 4E-6505A Cable Tabulation Cables 67200 to 67249 S
: DR-34289 20 Inch Y Pattern Globe Valve Pilot Operated to Open Spring to Close Original Welded Liner 4
: FF-11395 Final Assy. Series 1000 Fans Internal Direct Drive 386 M-33 Diagram of RBCCW Closed Cooling Water Piping AS M-813 Diagram of DG Room Ventilation System F 
: MISCELLANEOUS
: Number Description or Title Date or Revision
: MS / RX (MNS - Main Steam) System Health Report 10/26/2017
: Letter from Commonwealth Edison to USNRC, Request for Amendment to Facility Operating Licenses
: DPR-29 and
: DPR-30, Appendix A, Technical Specification (TS), Section 4.9.8.b, Clarification of Diesel Generator Single Load Rejection Test Surveillance Requirements 05/01/1997
: Letter from USNRC to Commonwealth Edison Company, Issuance of Amendments 10/0719/97
: Letter from AmerGen/Exelon Nuclear to USNRC, EGC/AmerGen 60-Day Response to NRC Generic Letter 2006-Reliability and the Impact on Plant Risk and the Operability of
: 04/03/2006
: Letter from AmerGen/Exelon Nuclear to USNRC, EGC/AmerGen 60-Day Response to the Request for Additional Information Regarding Resolution of NRC Generic Letter 2006-Reliability and the Impact on Plant Risk and the Operability of
: 01/31/2007
: Letter from USNRC to Exelon Generation Company/AmerGen Energy Company, Responses to Generic Letter 2006-Reliability and the Impact on Plant Risk and the Operability of
: 05/07/2007
: Validation Package for TSA 2: 125 VDC Load Shed
: 11/20/2015
: Validation Package for
: TCA 13: Initiate DW Sprays during an ATWS with > 2.5 psig DW on DW Temperature > 2810F 12/12/2013
: Validation Package for TCA 9: Manual Start of RHR Containment Cooling Mode for
: DBA 10/03/2016
: Validation Package for TCA 6: Initiate Torus Cooling 05/11/2015
: RCC / TCC (CCW - Closed Cooling Water) Sys. Health Report 1Q/2017  (EDG - Diesel Generator, EDG Vent) Sys. Health Report 3Q/2017
: Letter from NRC to Exelon Generation;
: Quad Cities-Completion of Licensing Action for Generic Letter 96-06 05/08/2002
: 00473026 PSI Quarterly Instrument Air
: Performed 9/5/17 09/06/2017 C0005 GNB Flooded Classic Batteries 1
: EC 354336 Determine 345 kV Minimum Switchyard Voltage that May be Used for Various Plant Configurations 03/28/2005
: EC 371739 EMD Engine Cold Load Derate Evaluation 08/05/08
: EC 399724 Provide New State Estimator Setpoints Based on Percent Voltage Drop 11/09/2014
: IST-QDC-BDOC-V-19 Quad Cities IST Bases Document 09/09/2016 NDIT 98-092 RHR/CS/RHRSW Pump BHP Input Values for Diesel Generator Loading Calculations 03/19/1998
: NO-AA-10 Quality Assurance Topical Report (QATR) 92 SPOG: 1-1 System Planning Operating Guide, Generation Stations Voltage Level 22 
: MODIFICATIONS
: Number Description or Title Date or Revision
: EC 385681 Operator Manual Action Feasibility Study 0
: EC 23169 Install New Breakers at Bus 13-1 05/09/1997
: EC 24157 Bus 18 Lighting Breaker Operator Work AroundCREVS 09/07/2001
: EC 391678 Replace Existing MSIV Angled Disc with Machined Spherical Main Disc to Reduce Leakage
: 1
: EC 395167 Install Close Torque Switch Bypass Mod in
: 1-1001-29A to Increase Margin 0
: EC 398044 Unit 1 4kv Bus Transfer Logic Modification for an Open Phase Event Concurrent with a LOCA 1
: EC 398602 Replace the 1B RHR Pump Seal Cooler 2
: EC-392979 U1 250 VDC MCC Cubicle Bucket Replacement 0 M04-2-88-043A,B,C 125V Battery Installation Unit 2 04/24/1989
: OPERABILITY EVALUATIONS
: Number Description or Title Date
: 4017529 Main Steam Isolation Valve
: 1-0203-2D 0
: 4050287 Main Steam Isolation Valves 1(2)-0203-2A,2B,2C,2D 0
: PROCEDURES
: Number Description or Title Revision
: CC-AA-309 Control of Design Analyses 11
: OP-AA-102-106 Operator Response Time Program 4
: OP-AA-108-107-1001 Station Response to Grid Capacity Conditions 7
: OP-AA-108-107-1002 Interface Agreement between Exelon Energy Delivery and Exelon Generation for Switchyard Operations 11
: OP-QC-102-106 Operator Response Time Program at Quad Cities 7
: OP-QC-102-106 Operator Response Time at Quad Cities 0
: OP-QC-103-102-1002 Quad Cities Strategies  for Successful Transient Mitigation 21
: QAP 0300-02 Conduct of Shift Operations 78
: QAP 0300-03 Operations Shift Staffing 41 QC0A-6100-01 Loss of Reserve Auxiliary Transformer 12(22) During Power Operations 33 QCAN 901-8 E-6 4KV Bus 14-1 Voltage Unbalanced 4 QCAN 912-1
: 10 QCAN 912-1 C-1 Reactor Building Cooling Water Pump Trip 2 QCAN 912-1 F-1 Reactor Building Cooling Water Expansion Tank Hi/Lo Level 6 QCAN 912-7 A-6 Unit 1 Drywell / Outboard MSIV Room High Temp 6 QCARP 0020-02 Injection with SSMP and Bringing the Unit to Cold Shutdown 20 QCARP 0020-02
: RRB-2N Injection with SSMP and Bringing the Unit to Cold Shutdown 20 QCEMS 0230-03 Unit 2 125VDC Service Test on Normal Batteries 06 QCOA 0250-02 MSIV Failure 17 
: PROCEDURES
: Number Description or Title Revision QCOA 3700-06 RBCCW Line Break Inside Containment 8 QCOA 6000-03 Low Switchyard Voltage 19 QCOA 6100-03 Loss of Offsite Power 42 QCOA 6600-06 1/2 Diesel Generator Room Vent Fan Failure 12 QCOA 6900-07 Loss of A.C. Power to the 125 VDC Battery Chargers with Simultaneous Loss of Auxiliary Electrical Power 24
: QCOA-6100-03 Loss of Offsite Power 42 QCOP 0201-16 Terminate and Prevent RPV Injection 7 QCOP 0250-03 Main Steam Line 16 QCOP 1000-30 Post-Accident RHR Operation 31 QCOP 3700-02 RBCCW System Startup And Operation 29 QCOP 4400-02 Circulating Water System Startup and Shutdown 37 QCOP 5750-19 Drywell Cooler Operation 11 QCOP 6500-08 4kV Bus Cross-Tie Operation 30 QCOP 6500-09 Energizing 4KV Switchgear and Transferring Auxiliary Power 20 QCOP 6500-29 Reserve Auxiliary Transformer 12 (22) Load Tap Changer Operation 22 QCOP 6600-05 Shared Unit Diesel Generator Start Up 38 QCOP 6900-224 Transfer of Unit Two 125VDC Bus Between Normal and Alternate Battery 24 QCOP 6900-25 Transfer of Unit One 125VDC Bus Between Normal and Alternate Battery 25 QCOP 6900-40 Unit 1 125 VDC Electrical System 2 QCOS 0005-08 Unit One Electrical Distribution Breaker and Voltage Verification 40 QCOS 0020-02 Safety System Monthly Manual Valve Position Verification 19 QCOS 1000-26 RHR Valve Position Verification 23 QCTS 4700-01 Instrument Air Analysis 6
: QGA 100 RPV Control 11
: QGA 101
: RPV Control (ATWS) 15
: QGA 200 Primary Containment Control
: 11
: QOA 6100-01 Loss of Reserve Auxiliary Transformer 12 (22) During Power Operation 33
: QOA 6900-07 Loss of AC Power to the 125VDC Battery Chargers with Simultaneous Loss of Auxiliary Electrical Power 24 QOM
: 1-1000-02 Unit 1 RHR Valve Checklist (North RHR Room) 14
: WC-QC-8003-1008 Quad Cities Station Units 1 and 2 Nuclear Plant Interface Requirements (NPIRs) 3 QCAN 901-8 H-5 DG Room 1/2 High Temperature Alarm 10
: SURVEILLANCES (COMPLETED) Number Description or Title Date or Revision QCOS 6600-10 Verify Operability of the Auto-Transfer Logic for the 1/2 Diesel Vent Fan
: QCOS 6600-15 Functional Test for DG Vent Nitrogen Backup System 06/17/2016
: WO 1474658 U1 Emergency DG Largest Load Reject 01/21/2013
: WO 1673875 U1 Emergency DG Largest Load Reject 01/09/2015
: WO 1849752 U1 Emergency DG Largest Load Reject 03/19/2017 
: TRAINING DOCUMENTS
: Number Description or Title Date or Revision
: LN-3700 RBCCW Training Manual 3
: LN-6600 Emergency Diesel Generator Training Manual 24
: WORK DOCUMENTS
: Number Description or Title Date or Revision
: 00832688-01 Take Airflow Reading from the Intake of Unit 1/2 EDG Room 07/12/2006
: 00860083 DG Temperature Loop Calibration 01/07/2008
: 01178511 Grease DG Vent Fan Motor 01/01/2010
: 01263059 Disassemble/Clean/Inspect/Regrease Coupling on RBCCW pump
: 01456221-01 Unit 1/2 EDG Damper Internal Inspection and Calibration 10/02/2012
: 01595343 Troubleshoot Relay
: 1-0595-149D Not Energized 12/18/2012
: 01761578 Replace the 1B RHR Pump Seal Cooler Per
: EC 398602
: 01801757 Install Close Torque Switch Bypass Mod in
: 1-1001-29A 04/02/2017
: 01802371 EM EWP 4kV Horizontal Breaker Inspection (Merlin Gerin) 01/12/2017
: 01803155 EWP Perform 4kV Horizontal Breaker Inspection (Merlin Gerin) 12/22/2016
: 01817544 As-Found MSIV Closure Times QCOS 0250-04 03/27/2017
: 01817546 MSIV Fail Safe Test QCOS 0250-08 04/12/2017
: 01819369 Outboard MSIV Pressure Decay Test 04/12/2017
: 01819394 MSIV LLRT QCTS 0600-05 03/27/2017
: 01819549 Inboard MSIV Pressure Decay Test 04/09/2017
: 01819683 MSIV Solenoid Test QCOS 0250-09 04/12/2017
: 01827699 1/2 RBCCW Pump Motor Lube 11/11/2016
: 01842325 EM EWP Pre-Outage Receipt Inspection 4kV Horiz. Breaker #205 12/12/2016
: 01849721 U-1 1B Inboard MSIV 10% Scram Limit Switch Inspection 04/12/2017
: 01849723 U-1 2C Outboard MSIV 10% Scram Limit Switch Inspection 04/12/2017
: 01858174 REPLACE TT 0-5790-1 (THERMOSTAT) FOR EDG 1/2 01/26/2016
: 01947083 Sample and Change Oil for 1/2 RBCCW Pump 08/08/2017
: 04620531 Q1R24 PSU: EO ID Bus 14 FD Bkr Closing Springs Discharged 04/01/2017
: 04623157 Q1R24 Test the 1-203-1B Manifold 04/07/2017
: 04626477 As-Left MSIV Closure Times QCOS 0250-04 04/12/2017
: 04648570 Instrument Air Sample 09/25/2017
: 04653922 MSIV Scram Functional QCOS 0250-10&11 09/25/2017
: 04657452 1/2 Diesel Vent Fan Auto Transfer Logic 09/25/2017
}}
}}

Latest revision as of 06:15, 19 December 2019

NRC Design Bases Assurance Inspection (Teams): Inspection Report 05000254/2017007; 05000265/2017007 (DRS-M.Jones)
ML18012A450
Person / Time
Site: Quad Cities  Constellation icon.png
Issue date: 01/12/2018
From: Jeffers M
NRC/RGN-III/DRS/EB2
To: Bryan Hanson
Exelon Generation Co, Exelon Nuclear
References
IR 2017007
Download: ML18012A450 (19)


Text

UNITED STATES uary 12, 2018

SUBJECT:

QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2- NRC DESIGN BASES ASSURANCE INSPECTION (TEAMS): INSPECTION REPORT 05000254/2017007; 05000265/2017007

Dear Mr. Hansen:

On December 28, 2018, the U.S. Nuclear Regulatory Commission (NRC) completed a Triennial Baseline Design Bases Assurance Inspection (Teams) at your Quad Cities Nuclear Power Station. The enclosed report documents the results of this inspection, which were discussed on December 28, 2018, with Mr. Humphrey, and other members of your staff.

Based on the results of this inspection, no violations of significance were identified.

This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.

Sincerely,

/RA/

Mark T. Jeffers, Chief Engineering Branch 2 Division of Reactor Safety Docket Nos. 50-254, 50-265 License Nos. DPR-29;` DPR-30

Enclosure:

IR 05000254/2017007; 05000265/2017007

REGION III==

Docket No: 50-254; 50-265 License No: DPR-29; DPR-30 Report No: 05000254/2017007; 05000265/2017007 Licensee: Exelon Generating Facility: Quad Cities Nuclear Power Station Location: Cordova, IL Dates: November 13-December 28, 2017 Inspectors: M. Jones, Engineering Inspector, Lead A. Dunlop, Senior Engineering Inspector, Mechanical I. Hafeez, Engineering Inspector, Electrical D. Betancourt, Operations Inspector H. Leake, Electrical Contractor W. Sherbin, Mechanical Contractor Approved by: M. Jeffers, Chief Engineering Branch 2 Division of Reactor Safety Enclosure

SUMMARY

Inspection Report 05000254/2017007; 05000265/2017007, 11/13/2017-12/01/2017; Quad

Cities Nuclear Power Station; Design Bases Assurance Inspection (Teams).

The inspection was a 2-week onsite baseline inspection that focused on the design of components. The inspection was conducted by regional engineering inspectors and two consultants. No findings of significance were identified by the inspectors. The U.S. Nuclear Regulatory Commissions program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, Reactor Oversight Process, Revision 6, dated July 201

NRC-Identified

and Self-Revealed Findings No findings were identified during this inspection.

Licensee-Identified Violations

No findings were identified during this inspection.

REPORT DETAILS

REACTOR SAFETY

Cornerstones: Initiating Events, Mitigating Systems, and Barrier Integrity

1R21 Design Bases Assurance Inspection (Teams)

.1 Introduction

The objective of the Design Bases Assurance Inspection is to verify that design bases have been correctly implemented for the selected risk significant components, modifications, and that operating procedures and operator actions are consistent with design and licensing bases. As plants age, their design bases may be difficult to determine and an important design feature may be altered or disabled during a modification. The inspection also monitors the implementation of modifications to structures, systems, and components as modifications to one system may also affect the design bases and functioning of interfacing systems as well as introduce the potential for common cause failures. The Probabilistic Risk Assessment (PRA) model assumes the capability of safety systems and components to perform their intended safety function successfully. This inspectable area verifies aspects of the Initiating Events, Mitigating Systems, and Barrier Integrity cornerstones for which there are no indicators to measure performance.

Specific documents reviewed during the inspection are listed in the Attachment to the report.

.2 Inspection Sample Selection Process

The inspectors selected risk-significant components and operator actions for review using information contained in the licensees PRA and the Quad Cities Nuclear Power Station Standardized Plant Analysis Risk Model. In general, the selection was based upon the components and operator actions having a risk achievement worth of greater than 1.3 and/or a risk reduction worth greater than 1.005. Based on this process, a number of risk-significant components, including those with Large Early Release Frequency implications, were selected for the inspection. The operator actions or operating procedures selected for review included actions taken by operators both inside and outside of the control room during postulated accident scenarios associated with the selected components.

The inspectors performed a margin assessment and detailed review of the selected risk-significant components to verify that the design bases have been correctly implemented and maintained. This design margin assessment considered original design reductions caused by design modification, or power uprates, or reductions due to degraded material condition. Equipment reliability issues were also considered in the selection of components for detailed review. These included items such as performance test results, significant corrective action, repeated maintenance activities, Maintenance Rule (a)(1) status, components requiring an operability evaluation, system health reports, and U.S. Nuclear Regulatory Commission (NRC) resident inspector input of problem areas/equipment. Consideration was also given to the uniqueness and complexity of the design, operating experience, and the available defense in depth margins. A summary of the reviews performed and are included in the following sections of the report.

The inspectors also identified modifications to mitigating systems for review. In addition, the inspectors selected procedures and operating experience issues associated with the selected components.

This inspection constituted 11 samples (5 components, with 1 component associated with Large Early Release Frequency implications, 4 modifications, and 2 operating experience) as defined in Inspection Procedure 71111.21M-02.01.

.3 Component Design

a. Inspection Scope

The inspectors reviewed the Updated Final Safety Analysis Report (UFSAR), Technical Specifications, design basis documents, drawings, calculations and other available design basis information, to determine the performance requirements of the selected components. The inspectors used applicable industry standards, such as the American Society of Mechanical Engineers Code, Institute of Electrical and Electronics Engineers Standards, and the National Electric Code, to evaluate acceptability of the systems design. The NRC also evaluated licensee actions, if any, taken in response to NRC issued operating experience, such as Bulletins, Generic Letters, Regulatory Issue Summaries, and Information Notices. The review was to verify that the selected components would function as designed when required and support proper operation of the associated systems. The attributes that were needed for a component to perform its required function included process medium, energy sources, control systems, operator actions, and heat removal. The attributes to verify that the component condition and tested capability was consistent with the design bases and was appropriate may include installed configuration, system operation, detailed design, system testing, equipment and environmental qualification, equipment protection, component inputs and outputs, operating experience, and component degradation.

For each of the components selected, the inspectors reviewed the maintenance history, preventive maintenance activities, system health reports, operating experience-related information, vendor manuals, electrical and mechanical drawings, and licensee corrective action program documents. Field walkdowns were conducted for all accessible components to assess material condition, including age-related degradation and to verify that the as-built condition was consistent with the design. Other attributes reviewed are included as part of the scope for each individual component.

The following five components (samples), including a component with Large Early Release Frequency were reviewed:

Unit 1/2 Reactor Building Closed Cooling Water Pump (1/2-3701): The team inspected the performance of reactor building closed cooling water (RBCCW)pump 1/2-3701 and the associated potential impact on plant operations (failure of the pumps could lead to a plant transient). The inspection included interviews with system and design engineers and operators, system walkdowns; and reviews of drawings, and normal, alarm response, and abnormal plant procedures. This review focused on the RBCCW systems response to a postulated automatic initiation of stand-by pump 1/2-3701 due to a discharge header low-pressure signal; and operator actions following this initiation. The team reviewed plant procedures to determine whether the operator actions were acceptable to assure reliable operation of the RBCCW system. Additionally, the inspectors reviewed electrical drawings, including one-lines and schematics to verify consistency with UFSAR descriptions and engineering analyses. Loading and voltage calculations were reviewed for pump operation on both offsite and onsite power sources (emergency diesel generators) to verify the adequacy of the motor power supplies. Finally, the team reviewed condition reports, maintenance history, and system health reports to determine the overall health of the pump, and to determine if issues entered into the Corrective Action Program were properly addressed.

Unit 1/2 Emergency Diesel Generator (EDG) Ventilation Fan (1/2-5727): The team reviewed the calculations related to EDG room supply air ventilation requirements, and compared the calculated airflow requirements with fan test data to ensure adequate heat removal capability. The team reviewed failure positions of pneumatic louver operators in the ventilation enclosures to ensure louvers will open on a loss of instrument air. The team also reviewed the control and wiring diagrams for the starting and stopping of the ventilation fan.

Preventive maintenance activities for lubricating the ventilation exhaust fan motor and fan shaft bearings were also reviewed to ensure vendor recommended preventive maintenance activities were being performed. The inspection included interviews with system and design engineers and operators, system walkdowns; and reviews of drawings, and alarm response procedures.

125 Vdc Distribution Panels: The team reviewed load flow calculations to determine whether the panels were applied within their required current ratings. The team reviewed voltage drop calculations to determine whether loads had their required minimum voltage and whether they were applied within their maximum voltage rating during battery equalizing. The team reviewed short circuit and protective device calculations to determine whether equipment was adequately protected and immune from spurious tripping. The team reviewed maintenance schedules, procedures, and maintenance records, including circuit breaker test requirements, to determine whether the panels and their associated circuit breakers were being properly maintained. In addition, the team performed a visual inspection of the 125Vdc Distribution Panels to assess material condition and the presence of hazards.

Alternating Current (AC) Bus Supplying Power to Residual Heat Removal (RHR)

Pumps 1A and 1B (4160V Switchgear 13-1): The team reviewed one-line diagrams, drawings, calculations of loading, short circuit, voltage drop, and protective relay trip setpoints to verify the capability of the switchgear to adequately supply the essential loads when powered by the unit auxiliary transformer, reserve auxiliary transformer, or EDG. The team also verified the maximum short circuit current available at the bus was within the interrupting capacity of the feeder breakers. The team reviewed the fast transfer design of the switchgear from the unit auxiliary transformer (main generator source) to the reserve auxiliary transformer (offsite power source) when the main generator trips. The team verified the feeder cable size and ampacity for the RHR pumps was adequate to carry the maximum load current. Administrative controls were reviewed for mitigating potential conductor and EDG overload conditions identified in the load flow and EDG sizing calculations. The inspectors performed a walkdown of 4160V Switchgear 13-1 to observe its material condition.

Main Steam Isolation Valves (MSIV) (1-203-001(A-D), 1-203-002(A-D)): The team reviewed the design basis of the inboard and outboard MSIVs for Unit 1, the basis for its closure time requirement, and the associated control logic. The team reviewed operating procedures associated with the MSIVs under normal and accident conditions. The air accumulator leakage limits, leak test procedures, air quality, and recent test results were reviewed to verify acceptance criteria were met and performance degradation would be identified.

The team reviewed closure time surveillance procedures and recent results to verify that the test results were representative of the most limiting postulated accident conditions. The (a)(1) action plan for the MSIV timing issues was reviewed to verify the cause(s) were identified and corrective actions were planned or implemented to resolve the timing issue. The team reviewed the testing of the control circuits required to close the MSIVs to ensure that the testing was comprehensive.

.4 Findings

No findings were identified.

.5 Mitigating System Modifications

a. Inspection Scope

The team reviewed 4 permanent plant modifications to mitigating systems that had been installed in the plant during the last 3 years. This review included in-plant walkdowns for portions of the modified Unit 1/2 EDG ventilation fan, 1B RHR pump seal Cooler, 4160V switchgear bus 13-1, 125 Vdc distribution panels, and 125 Vdc normal and alternate batteries. The team reviewed the modifications to verify that the design bases, licensing bases, and performance capability of the components had not been degraded through modifications. The modifications were selected based upon risk significance, safety significance, and complexity. The inspectors reviewed the modifications selected to determine if:

the supporting design and licensing basis documentation was updated; the changes were in accordance with the specified design requirements; the procedures and training plans affected by the modification have been adequately updated; the test documentation as required by the applicable test programs has been updated; and post-modification testing adequately verified system operability and/or functionality.

The team also used applicable industry standards to evaluate acceptability of the modifications. The modifications listed below were reviewed as part of this inspection effort:

Engineering Change (EC) 398602, Replace the 1B RHR Pump Seal Cooler; EC 395167, Install Close Torque Switch Bypass Mod in 1-1001-29A to Increase Margin; EC 398044 Revision 1, Unit 1 4kv Bus Transfer Logic Modification for an Open Phase Event Concurrent with a LOCA; and EC 932979, U1 250 VDC MCC Cubicle Bucket Replacement.

b. Findings

No findings were identified.

.6 Operating Experience

a. Inspection Scope

The inspectors reviewed 2 operating experience issues (samples) to ensure that NRC generic concerns had been adequately evaluated and addressed by the licensee. The operating experience issues listed below were reviewed as part of this inspection:

Information Notice 2015-13, Main Steam Isolation Valve Failure Events; and Generic Letter 2006-02, Grid Reliability and the Impact on Plant Risk and the Operability of Offsite Power.

b. Findings

No findings were identified.

.7 Operating Procedure Accident Scenarios

a. Inspection Scope

The team performed a detailed reviewed of selected procedures associated with the inspections component samples. For the procedures listed time critical operator actions were reviewed for reasonableness, in plant action were walked down with a licensed operator, and any interfaces with other departments were evaluated. The procedures were compared to UFSAR, design assumptions, and training materials to assess their consistency. In addition, operator actions were observed at the stations simulator for two scenarios: Anticipated Transient with a Scram, and Loss of AC to the 125 Volt Direct Current Battery Chargers with a simultaneous loss of auxiliary electrical Power.

The following operating procedures were reviewed in detail:

QGA 101, Reactor Pressure Vessel Control (ATWS);

QCOA 6900-07, Loss of AC Power to 125 VDC Battery Charger with Simultaneous Loss of Auxiliary Electrical Power; QCOP 3700-02, RBCCW System Startup and Operation; QCOA 3700-06, RBCCW Line Break Inside Containment; QCOP 1000-30, Post Accident RHR Operation; and QGOA 6100-03, Loss of Offsite Power.

The inspectors performed a margin assessment and detailed review of four risk-significant and/or time critical operator actions. These actions were selected from the licensees PRA rankings of human action importance based on risk achievement worth values, and where possible, margins were determined by the review of the assumed design basis and UFSAR response times and performance times documented by job performance measures results. For the selected operator actions, the inspectors performed a detailed review and walk through of associated procedures, including observing the performance of some actions in the stations simulator and in the plant for other actions, with an appropriate plant operator to assess operator knowledge level, adequacy of procedures, and availability of special equipment where required.

The following operator actions were reviewed:

Initiation of Torus Cooling during Appendix R scenarios; Manual Start of RHR Containment Cooling Mode of RHR; Initiate Drywell Spray during an Anticipate Transient without Scram; and Load Shed 125 VDC Loads following loss of AC Power.

b. Findings

No findings were identified.

OTHER ACTIVITIES

4OA2 Identification and Resolution of Problems

.1 Review of Items Entered Into the Corrective Action Program

a. Inspection Scope

The team reviewed a sample of the selected component problems identified by the licensee and entered into the corrective action program. The team reviewed these issues to verify an appropriate threshold for identifying issues and to evaluate the effectiveness of corrective actions related to design issues. In addition, corrective action documents written on issues identified during the inspection were reviewed to verify adequate problem identification and incorporation of the problem into the Corrective Action Program. The specific corrective action documents sampled and reviewed by the inspectors are listed in the attachment to this report.

The team also selected two issues identified during previous Component Design Basis Inspections to verify that the concern was adequately evaluated and corrective actions were identified and implemented to resolve the concern, as necessary. The following issues were reviewed:

Non-Cited Violation 5000254/265/2011009-02; Failure to Perform Required In-Service Testing of Shutdown Cooling Suction Valves; and Non-Cited Violation 05000254/2016008-01, Failure to Provide Appropriate Operating Instructions for Aligning a Battery Charger to the Station Black-Out Diesel Generator.

b. Findings

No findings were identified.

4OA6 Management Meetings

.1 Interim Exit Meeting Summary

On December 1, 2017, the inspectors presented the inspection results to Mr. Kenneth S. Ohr, and other members of the licensee staff. The licensee acknowledged the issues presented. The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary.

Any documents reviewed by the inspectors that were considered proprietary information were either returned to the licensee or handled in accordance with NRC policy on proprietary information. The team had outstanding questions that required additional review and a following exit meeting.

.2 Exit Meeting Summary

On December 28, 2017, the team presented the inspection results to Mr. M. Humphrey and other members of the licensee staff. The licensee acknowledged the issues presented. The team asked the licensee weather any materials examined during the inspection should be considered proprietary. Several documents reviewed by the team were considered proprietary information and were either returned to the licensee or handled in accordance with NRC policy on proprietary information.

ATTACHMENT:

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

K. Ohr, Site Vice President
M. Humphrey, Regulatory Assurance
R. Swart, Engineering Supervisor
T. Bell, Engineering Director
J. Bries, Operations Director
J. Cox, Operations Supervisor

U.S. Nuclear Regulatory Commission

R. Murray, Senior Resident Inspector
K. Carrington, Resident Inspector

LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED

Opened, Closed and

Discussed

None LIST OF ACRONYMS USED AC Alternating Current EC Engineering Change EDG Emergency Diesel Generator MSIV Main Steam Isolation Valve NRC U.S. Nuclear Regulatory Commission PRA Probabilistic Risk Assessment RBCCW Reactor Building Closed Cooling Water UFSAR Updated Final Safety Analysis Report

LIST OF DOCUMENTS REVIEWED